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Reports
Audit of Entitlements for Activated Army National Guard and Air National Guard Members Supporting the Coronavirus Disease–2019 Mission
Rec. 1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with the Under Secretary of Defense for Personnel and Readiness, update the DoD Financial Management Regulation, volume 7A, "Military Pay Policy - Active Duty and Reserve Pay," chapter 27, "Family Separation Allowance" to clearly state that the permanent duty station of a Reserve Component member on temporary duty status is the member's primary residence for the purpose of determining Family Separation Allowance entitlement.
Rec. 1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with the Under Secretary of Defense for Personnel and Readiness, update the DoD Financial Management Regulation, volume 7A, "Military Pay Policy - Active Duty and Reserve Pay," chapter 27, "Family Separation Allowance" to clarify that Family Separation Allowance entitlement determination is based on the commuting distance between the member's primary residence and their temporary duty location.
Rec. 2.a: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to require the Army National Guard and Air National Guard to complete a review of proof of residency documentation when the member's primary residency is established or changed for the Basic Allowance for Housing entitlement to ensure consistency throughout all Army National Guard and Air National Guard units and organizations within every state, territory, and the District. The policies and procedures should also include requirements that: * document a member's primary residence address; * require members to provide proof of their primary residence address; * certify the primary address of members and review supporting documentation; and * provide oversight to ensure primary residence address information is complete and accurate.
Rec. 2.b: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to outline the process and frequency of recertification for Basic Allowance for Housing entitlement that Army National Guard and Air National Guard officials will use to verify and fully document the dependency status of members to provide clarification to the DoD Financial Management Regulation, volume 7A, chapter 26. These procedures should include: * how recertifications will be completed; * which members will complete a recertification; and * how Army National Guard and Air National Guard officials will provide oversight to ensure that information is complete and accurate.
Rec. 2.c: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to require Army National Guard and Air National Guard officials to review and document the status of a military member married to another military member regardless of which Military Service, Reserve or Active Component, or Army National Guard or Air National Guard unit the member's spouse belongs to, and identify which member will claim any applicable dependents.
Rec. 2.d: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to specify the methods for confirming eligibility and paying Family Separation Allowance for Army National Guard and Air National Guard members, in accordance with the DoD Financial Management Regulation, volume 7A, chapter 27, and include the: * timeliness of payments; * determination of Family Separation Allowance eligibility for back to back orders; * members assigned to their normal duty locations; and * requirement to track members to know when they return to their primary residence.
Rec. 2.e: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to establish formal dissemination and communication procedures for National Guard Bureau policies related to entitlements provided to the Army National Guard and Air National Guard, including the policies in the preceding recommendations. The procedures should require: * creation of a central location where policies and procedures will be kept for easy access by all states, territories, and the District; and * confirmation of receipt from all of the states, territories, and the District when procedures are communicated or obtained.
Rec. 3: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement additional internal control procedures for the review of transactions manually submitted by the Army National Guard and Air National Guard to the payment system prior to payment to ensure the completeness and accuracy of transactions.
Management Advisory Regarding Results from Research for Future Audits and Evaluations Related to the Effects of the 2019 Novel Coronavirus on DoD Operations
Rec. 1: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD work with DoD Components to implement procedures to ensure award amounts funded under the Coronavirus Aid, Relief, and Economic Security Act are appropriately recorded and reported with the accurate Disaster Emergency Fund Codes through the respective reporting systems.
Rec. 2: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD work with the Navy and the Marine Corps to ensure that the Coronavirus Aid, Relief, and Economic Security Act obligation and disbursement transactions processed through their accounting systems and journal vouchers are properly reported in USASpending.gov.
Rec. 3.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD develop procedures to confirm that DoD Components have appropriately implemented the policies DoD prescribed for coding Coronavirus Aid, Relief, and Economic Security Act fund transactions.
Rec. 3.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD issue funding authorization documents that include a Disaster Emergency Fund Code value to ensure all DoD budget and accounting systems have a consistent basis to record and report funding and execution by Disaster Emergency Fund Code, in accordance with Office of Management and Budget Memorandum M-18-08.
Remington College’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants
Require Remington College to return to the Department the $80,121 in Institutional grant funds spent beyond the supplemental Institutional grant period or reallocate the funds to other allowable costs.
Clarify whether the costs that Remington College initially charged to its Institutional grant for student computers were allowable under the law and existing guidance, and determine whether Remington College’s subsequent reallocation of costs for other expenses in the amount of $64,985 (corrective actions) was appropriate.
Determine whether the $639,400 that Remington College charged to its Institutional grant for contracts awarded without a competitive procurement process was reasonable when compared to the quality and costs of suitable alternatives, and if not, require appropriate corrective actions.
Require Remington College to incorporate in its policies and procedures for managing HEERF grant funds the Federal requirements related to charging only allowable costs during the grant performance period, using competitive processes for selecting vendors when purchases are over $10,000, obtaining price or rate quotations from an adequate number of qualified vendors for purchases between $10,000 and $250,000, and using formal procurement methods for purchases over $250,000.
Require Remington College to ensure that school officials responsible for making purchasing decisions receive sufficient training on Federal rules and regulations related to grant administration and management.
Require Remington College to incorporate in its policies and procedures for managing Institutional grant funds the Federal cash management requirements related to minimizing the time between drawing down and spending Federal grant funds, including HEERF funds; maintaining the funds in an interest-bearing account; and remitting interest earned in excess of $500 in accordance with 2 C.F.R. § 200.305(b).
Require Remington College to incorporate in its policies and procedures for managing Student Aid grant funds the Federal cash management requirements related to maintaining the funds in an interest-bearing account and remitting interest earned in excess of $500 in accordance with 2 C.F.R. § 200.305(b).
Determine whether Remington College accurately calculated interest and ensure that the correct amount of interest is returned to the Federal government in accordance with 2 C.F.R. § 200.305(b)(9).
Audit of the Reimbursement for Department of Defense Mission Assignments for Coronavirus Disease–2019 Pandemic Response in the U.S. Northern Command Area of Responsibility
Rec. 1: The DoD OIG recommended that the Deputy Comptroller (Program/Budget), Office of the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with DoD Component comptrollers, initiate a review of all COVID-19 pandemic response mission assignments to ensure reimbursement requests for costs incurred are submitted in accordance with DoD policy.
Rec. 2.a: The DoD OIG recommended that the Director, Army Budget, Office of the Assistant Secretary of the Army (Financial Management and Comptroller), immediately require tasked units to review costs incurred for mission assignments 4480DR-NY-DOD-10, 4480DR-NY-DOD-11, 4480DR-NY-DOD-12, and 4481DR-WA-DOD-02 as of July 31, 2020, for completeness and accuracy, and submit reimbursement requests for those costs with required documentation to the Federal Emergency Management Agency in accordance with DoD policy.
Rec. 2.b: The DoD OIG recommended that the Assistant Director of the Office of Budget Fiscal Management, Office of the Assistant Secretary of the Navy (Financial Management and Comptroller), immediately require tasked units to review costs incurred for mission assignments 4482DR-CA-DOD-01, 4482DR-CA-DOD-02, and 4488DR-NJ-DOD-04 as of July 31, 2020, for completeness and accuracy, and submit reimbursement requests for those costs with required documentation to the Federal Emergency Management Agency in accordance with DoD policy.
Rec. 2.c: The DoD OIG recommended that the Deputy for Budget, Office of the Assistant Secretary of the Air Force (Financial Management and Comptroller), immediately require tasked units to review costs incurred for mission assignment 4480DR-NY-DOD-10 as of July 31, 2020, for completeness and accuracy, and submit reimbursement requests for those costs with required documentation to the Federal Emergency Management Agency in accordance with DoD policy.
Rec. 2.d: The DoD OIG recommended that the Comptroller of the United States Marine Corps immediately require tasked units to review costs incurred for 4482DR-CA-DOD-01, 4482DR-CA-DOD-02, and 4488DR-NJ-DOD-04 as of July 31, 2020, for completeness and accuracy, and submit reimbursement requests for those costs with required documentation to the Federal Emergency Management Agency in accordance with DoD policy.
Rec. 2.e: The DoD OIG recommended that the Comptroller of the National Guard Bureau immediately require tasked units to review costs incurred for mission assignments 4480DR-NY-DOD-05, 4481DR-WA-DOD-05, 4482DR-CA-DOD-07, and 4491DR-MD-DOD-01 as of July 31, 2020, for completeness and accuracy, as well as any additional costs incurred and identified after July 31, 2020, and submit reimbursement requests for those costs with required documentation to the Federal Emergency Management Agency in accordance with DoD policy.
Rec. 3.a.1: The DoD OIG recommended that the Director, Army Budget, Office of the Assistant Secretary of the Army (Financial Management and Comptroller), in coordination with the Financial Management Augmentation Team, develop and provide to tasked units, an Army-specific desk manual for mission assignments that includes, at a minimum, step-by-step procedures for initial set-up, real-time cost input, cost tracking, cost reporting, and submitting partial and final billings to ensure compliance with DoD policy.
Rec. 3.a.2: The DoD OIG recommended that the Director, Army Budget, Office of the Assistant Secretary of the Army (Financial Management and Comptroller) train tasked-unit personnel on how to navigate the Army-specific desk manual and apply the procedures appropriately.
Rec. 3.b.1: The DoD OIG recommended that the Assistant Director of the Office of Budget Fiscal Management, Office of the Assistant Secretary of the Navy (Financial Management and Comptroller), in coordination with the Financial Management Augmentation Team, develop and provide to tasked units, a Navy-specific desk manual for mission assignments that includes, at a minimum, step-by-step procedures for initial set-up, real-time cost input, cost tracking, cost reporting, and submitting partial and final billings to ensure compliance with DoD policy.
Rec. 3.b.2: The DoD OIG recommended that the Assistant Director of the Office of Budget Fiscal Management, Office of the Assistant Secretary of the Navy (Financial Management and Comptroller) train tasked-unit personnel on how to navigate the Navy-specific desk manual and apply the procedures appropriately.
Rec. 3.d.1: The DoD OIG recommended that the Comptroller of the United States Marine Corps, in coordination with the Financial Management Augmentation Team, develop and provide to tasked units, a Marine Corps-specific desk manual for mission assignments that includes, at a minimum, step-by-step procedures for initial set-up, real-time cost input, cost tracking, cost reporting, and submitting partial and final billings to ensure compliance with DoD policy.
Rec. 3.d.2: The DoD OIG recommended that the Comptroller of the United States Marine Corps train tasked-unit personnel on how to navigate the Marine Corps-specific desk manual and apply the procedures appropriately.
Rec. 3.e.1: The DoD OIG recommended that the Comptroller of the National Guard Bureau, in coordination with the Financial Management Augmentation Team, develop and provide to tasked units a National Guard-specific desk manual for mission assignments that includes, at a minimum, step-by-step procedures for initial set-up, real-time cost input, cost tracking, cost reporting, and submitting partial and final billing to ensure compliance with DoD policy.
Rec. 3.e.2: The DoD OIG recommended that the Comptroller of the National Guard Bureau train tasked-unit personnel on how to navigate the National Guard-specific desk manuals and apply the procedures appropriately.
Rec. 3.c.1: The DoD OIG recommended that the Deputy for Budget, Office of the Assistant Secretary of the Air Force (Financial Management and Comptroller), in coordination with the Financial Management Augmentation Team, develop and provide to tasked units, an Air Force-specific desk manual for mission assignments that includes, at a minimum, step-by-step procedures for initial set-up, real-time cost input, cost tracking, cost reporting, and submitting partial and final billings to ensure compliance with DoD policy.
Rec. 3.c.2: The DoD OIG recommended that the Deputy for Budget, Office of the Assistant Secretary of the Air Force (Financial Management and Comptroller) train taskeDODIG-unit personnel on how to navigate the Air Force-specific desk manual and apply the procedures appropriately.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – Florida International University
Resolve the $1,252 in questioned Award Cash Management $ervice drawdowns for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $14,167 of questioned costs for which it has agreed to reimburse NSF.
Direct FIU to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes should ensure FIU appropriately documents how it calculates the final draw amounts for awards with expiring appropriations, to ensure it only uses the draws to cover costs incurred before the appropriation expired.
Direct FIU to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.
Resolve the $791 in questioned fringe benefit costs for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $5,934 of questioned promotional and salary costs for which it has agreed to reimburse NSF.
Direct FIU to establish clear guidance regarding the <span class="tx-tooltip" tabindex="0">
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of participant support cost funding. This guidance should address: a. Allowable uses of participant support cost funding. b. How to verify personnel did not apply fringe benefit rates to participant stipends or other non-salary expenses.
Direct FIU to strengthen its monitoring procedures surrounding costs charged to its NSF Research Experiences for Undergraduates programs. Updated procedures should ensure FIU charges costs associated with promotional and/or other unallowable items to nonFederal funding sources.
Direct FIU to update its current practices to ensure it only applies fringe benefits using fringe benefit rates that have been approved by its cognizant audit agency.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – State University of New York at Stony Brook
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $20,530 of questioned Award Cash Management $ervice drawdowns associated with unspent funds.
Direct Stony Brook to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes could include validating that Stony Brook only draws down funding based on immediate cash needs and/or adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $6,913 in questioned travel costs for which it has agreed to reimburse NSF.
Direct Stony Brook to provide additional guidance to ensure personnel reimburse NSF timely for cash drawn down for unused travel advances.
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $3,898 in questioned travel costs for which it has agreed to reimburse NSF.
Direct Stony Brook to strengthen its monitoring procedures and internal controls surrounding the allocation of travel expenses to sponsored projects. Processes could include reviewing and assessing the allocation of all travel expenses charged to NSF awards.
Direct Stony Brook to separately track its on-campus and off-campus activities so that it can appropriately apply the approved on-campus and off-campus indirect cost rates.
Direct Stony Brook to update its current budget proposal process to eliminate the use of blended indirect cost rates.
Direct Stony Brook to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct Stony Brook to update its current award set-up practices to remove the establishment of indirect cost budget caps.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of New Mexico
Resolve the $17,269 in questioned unreasonable per diem, airfare, and ground transportation costs for which UNM has not agreed to reimburse NSF and direct UNM to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct UNM to strengthen its administrative and management procedures for reviewing travel expenses incurred on sponsored projects. Updated procedures could include periodic training for Principal Investigators to ensure they understand when NSF Grant Officer approval should be requested and how to appropriately document that only reasonable costs were charged to NSF awards.
Direct UNM to strengthen its policies and procedures regarding the reasonableness of per diem expenses incurred when employees are temporarily relocated for a period longer than 30 days.
Resolve the $3,613 in questioned tuition costs for which UNM has not agreed to reimburse NSF and direct UNM to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct UNM to provide documentation supporting that it has repaid or otherwise credited the $83 of questioned travel costs for which it has agreed to reimburse NSF.
Direct UNM to strengthen its controls surrounding the approval of expense reimbursements to ensure approvers appropriately verify that travelers are reimbursed at the appropriate U.S. General Services Administration per diem rate(s).
Direct UNM to strengthen its policies and procedures surrounding the use of participant support cost funding to cover tuition remission expenses. Specifically, UNM should update its current tuition remission policies and procedures to ensure that it does not use participant support costs to cover costs associated with credit hours that do not benefit student participants.
Direct UNM to update its award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct UNM to require subawardees to apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the subaward agreement, rather than using the rates included within the subaward budget and proposal.
Evaluation of Access to Department of Defense Information Technology and Communications During the Coronavirus Disease-2019 Pandemic
Rec. 1.a: The DoD OIG recommended that the Assistant Secretary of Defense for Homeland Defense and Global Security revise the "DoD Implementation Plan for Pandemic Influenza" to update the planning assumptions in the DoD Implementation Plan for Pandemic Influenza to include the use of telework for essential and non-essential personnel and to align the DoD Implementation Plan for Pandemic Influenza with the DoD Telework Policy, Enclosure 3, Section 3(i)(2).
Rec. 1.b: The DoD OIG recommended that the Assistant Secretary of Defense for Homeland Defense and Global Security revise the "DoD Implementation Plan for Pandemic Influenza" to require DoD Components to update their Pandemic Plans to include the revised assumptions regarding telework for essential and non-essential personnel and the resources required to support the teleworking workforce.
Rec. 2: The DoD OIG recommended that the Under Secretary of Defense for Policy, in coordination with the Under Secretary of Defense for Personnel and Readiness, establish management oversight procedures to verify that DoD Components have performed the testing, training, and exercise requirements of the DoD Implementation Plan for Pandemic Influenza and the DoD Telework Policy. The oversight procedures should assess the ability of DoD Components to support Government-wide mandated telework, including the results from tests of network and communications systems and telework exercises with personnel.
Assessment of the Department’s Reconstitution Plans Following COVID-19
We recommend that the Acting Assistant Secretary for OFO ensures that the Department’s Reconstitution Plan addresses anti-retaliation, including practices for ensuring that no adverse or retaliatory action is taken against an employee who adheres to guidelines or raises workplace safety and health concerns.
We recommend that the Acting Assistant Secretary for OFO ensures that the Department reassesses the self-screening questions and updates the information in the Reconstitution Plan as necessary, or includes a link to relevant CDC guidance in the self-assessment section of the Department’s Reconstitution Plan for employees to access and reference.
Evaluation of Department of Defense Medical Treatment Facility Challenges During the Coronavirus Disease-2019 (COVID-19) Pandemic
Rec. 1.a: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to develop guidance for coordinating the staffing of multi-Service military treatment facilities during a pandemic.
Rec. 1.b: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to consolidate Coronavirus Disease-2019 reporting requirements and recipients to reduce duplication and inconsistent requirements.
Rec. 1.c: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to create a pandemic-related informational website and a toll-free number for beneficiaries to find Coronavirus Disease-2019-related information and ensure the website and toll-free number are advertised and maintained.
Rec. 1.d: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to issue clarifying guidance for defining essential personnel for civilian healthcare workers.
Rec. 1.e: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to update contracts to allow for more flexibility regarding the use of contracted personnel during extenuating circumstances, such as a pandemic.