OPIC Lacks Policy and Procedures To Ensure Compliance With Annual Appropriations Requirements

Audit Report
Report Number

In response to a request from the House of Representatives Appropriations Sub-Committee on State, Foreign Operations, and Related Programs, we conducted this audit to (1) assess OPIC’s overall practices and controls to ensure compliance with fiscal year 2018 annual appropriations, and (2) determine whether OPIC complied with select appropriations requirements.

While OPIC had some practices and tools in place, the agency’s approach to appropriations compliance lacked the level of documentation and formality needed to effectively ensure compliance with requirements. For example, OPIC did not have a formal written policy describing assigned roles and responsibilities, procedural steps, and timelines to guide appropriations compliance efforts, and there were gaps in OPIC’s annual appropriations review process. Weaknesses in OPIC’s internal controls led to noncompliance with six of the seven requirements we tested. Instances of noncompliance included the absence of a required clause in project documents, late and incomplete submissions of required reports, failing to publically post certain information on its website, and not tracking or responding to a congressional notification requirement. Some of these issues arose from a pattern of disregard for requirements OPIC officials felt were either duplicative in nature or did not, in their judgment, specifically apply to the agency’s operations.

We made three recommendations to strengthen OPIC’s internal controls for complying with appropriations requirements and better position OPIC and its successor agency to ensure compliance with other applicable legislative requirements.


Recommendation 1

OPIC management develop and implement a policy that documents and formalizes processes and procedures for ensuring compliance with appropriations requirements.

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Recommendation 2

OPIC management develop and implement a formal system that includes sufficient detail to ensure timely identification, preparation, and submission of deliverables as required by appropriations law and related congressional reports.

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Recommendation 3

OPIC management based on formal outreach to the House and Senate Committees on Appropriations, internally produce a written determination on the applicability of the following appropriations requirements reviewed in this report, along with any others that require clarification: (1) submission of quarterly financial unobligated balances reports; (2) submission of annual budgeted operating plan; (3) public posting of required reports on the agency website; and (4) congressional notification for assistance activities in Pakistan.

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