Recommendation Dashboard

M/OAA/RM/LEMO determine the allowability of the $2,658,301.45 in unsupported questioned costs and the $150,668.35 in ineligible questioned costs and collect any amounts determined to be unallowable from the DPW Training & Associates, LLC.

M/OAA/RM/LEMO verify that DPW develop policies and procedures to improve its internal control process for: Billing fixed fees to USAID. Such internal controls should include second level reviews to validate the accuracy, completeness and correctness of calculations. Billing Fringe, General and Administrative, and Overhead cost pools on invoices to USAID; and maintain proper documentation of any changes to the contractually agreed calculation. Billing Other Direct Costs on invoices to USAID. Payroll documentation and approval process such that direct labor hours billed to USAID are fully supported by the payroll registers and other labor distribution reports and personnel activity records used to determine the billable level of effort. The retention of supporting documentation for all costs billed to USAID.

USAID's Chief, Travel and Transportation Division, prepare a written checklist for its travel assistants to confirm that travel authorization packages for premium travel are reviewed under the same standards. The checklist should, at a minimum, include determining whether:
Based on the final itinerary, the flight meets all requirements, as applicable, for the 14hour rule or as recommend by the Office of Civil Rights and Diversity.
Trips categorized as "Travel in excess of 14 hours TDY" provide an adequate justification for not taking a rest stop in lieu of traveling premium class and confirming that the traveler does not take a rest stop.
The business-class certification form is completed, has the supervisor's signature for approval, and is uploaded into E2.
Trips in the "No space available in coach air accommodations" exception include documentation to show that the airline carrier did not have coach accommodations and that travel at that time was critical.
Trips include documentation to show that busi

USAID's Chief, Travel and Transportation Division, provide training to its travel assistants to use the checklist so travel authorization packages are reviewed using the same standards.

USAID's Chief, Travel and Transportation Division, revise Automated Directives System 522 to include an explicit list of documents that need to be uploaded into E2 with the travel request. At a minimum, that must include:
Completed, approved business-class travel certification forms.
Final flight itineraries when the traveler is requesting premium-class travel because of a disability and the 14-hour rule.
Documentation to show that the airline carrier did not have coach accommodations and that it is critical for them to travel at that time, when applicable.
Office of Civil Rights and Diversity documentation stating that premium travel was needed to reasonably accommodate the traveler, when applicable.
Documentation to show that business class was necessary for security reasons, when applicable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 5737485-1 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 5978583 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 5687541-1 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 6128085-1 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 5969238-2 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 6406982 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 5709101-3 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 6412021 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 6228535-1 are allowable, and recover any amount that is not allowable.

USAID's Chief, Travel and Transportation Division, make a written determination whether the premium-class travel costs for trip number 5671134-3 are allowable, and recover any amount that is not allowable.

USAID's Chief Financial Officer, in coordination with the Chief, Travel and Transportation Division, include in the Automated Directives System an explicit list of documents required for travel vouchers so the Agency can fully validate whether charges for airfare are accurate. At a minimum, that list must require supporting documentation for the cost of all issued airfare tickets.

USAID's cognizant contracting officer for contract no. AID-OAA-M-11-00006 work with the contracting officer's representative and the Cash Management and Payments Division staff to develop and include in the contract with Duluth Travel Inc. a clear description of the data that should be presented in the monthly reconciliation report of the centrally billed account.

USAID's Chief Financial Officer, in coordination with the Chief, Travel and Transportation Division, develop and implement a written process for reviewing each centralized Citibank travel card airfare expense to supporting documentation for the issued ticket before approving the payment. That process should include requirements for supporting documentation to prevent questioned costs.

USAID's Chief Financial Officer, in coordination with the Chief, Travel and Transportation Division, implement a written process for reviewing agent fees before approving payment in accordance with the Federal Managers' Financial Integrity Act of 1982. This process could include a monetary threshold for reviewing details of the agent fees, as necessary.

USAID's Chief Financial Officer, in coordination with the Chief, Travel and Transportation Division, include an explicit requirement in the Automated Directives System for travelers to document and report all requests for the travel management center to issue airfare tickets. The requirement must include:
Justification of all issued tickets requested.
A limit to the number of times a traveler can do the following without a supervisor's approval: make changes to issued tickets that result in agent fees, and use after-hour and weekend travel management center services.
Consequences for not following the Agency's agent fee requirements.

USAID's Chief, Travel and Transportation Division, in coordination with the Chief Financial Officer, provide training to all USAID staff regarding traveler actions that result in agent fees to the Agency, traveler's responsibilities, and all applicable related policies.

USAID's Chief, Travel and Transportation Division, obtain approval from the Information Records Division for the revised business-class certification form. At a minimum that form must be:
Marked as "sensitive but unclassified once filled in," in accordance with ADS 505.
A fillable form to allow travelers to complete the required information.

USAID's Chief, Office of Civil Rights and Diversity, update Automated Directives System 110, Equal Employment Opportunity, to reflect the current Agency policies and procedures. At a minimum, that must include:
Current policies and procedures for approving requests for reasonable accommodations.
An explanation of when approvals for reasonable accommodations expire for disabilities that are not permanent.

USAID's Chief, Travel and Transportation Division, update Automated Directives System 522 to reflect the current policies and procedures for
approving requests for premium-class travel based on disabilities.

USAID's Chief Information Officer conduct a written review of the U.S. General Services Administration's security package for the E2 system.

USAID's Chief Information Officer make a written determination whether the E2 system should be authorized for Agency operations.

USAID's Chief Information Officer update Automated Directives System 545, Information Systems Security, to clearly discuss the requirements for authorizing third-party systems for Agency operations.

USAID's Chief, Travel and Transportation Division, develop procedures and revise Standard Operating Procedures for USAID E2 HelpDesk to certify periodically-within an Agency-defined time frame-whether E2 accounts should remain active and disable unneeded accounts.

USAID's cognizant contracting officer remove the second paragraph from the C.12.2 section of contract no. AID-OAA-M-15-00001 with C. I. Travel Center.

USAID/Zambia determine the allowability of the $702,685 in questioned costs ($6,731 ineligible and $695,954 unsupported) identified on page 17 of Deloitte & Touche's audit report and recover from the Agribusiness in Sustainable Natural African Plant Product the amounts determined to be unallowable.

USAID/Zambia ensure that Agribusiness in Sustainable Natural African Plant Product corrects the seven material weaknesses and ten significant deficiencies in internal control detailed on pages 25 to 57 of Deloitte & Touche's audit report.

USAID/Zambia ensure that Agribusiness in Sustainable Natural African Plant Product corrects the eleven instances of material noncompliance detailed on pages 61 to 75 of Deloitte & Touche's audit report.

USAID/Paraguay complete an analysis of Centro de Estudios Ambientales y Sociales that meets the requirements for a Non-U.S. Organization Preaward Survey, assessing areas not covered by the preaward survey or this audit, which will also serve as a learning experience on how to conduct a Non-U.S. Organization Preaward Survey.

USAID/Paraguay determine whether to add specific conditions to the award for the Democracy and Governance Program and whether to extend timelines for specific conditions already imposed, and have the agreement officer modify the award as necessary.

USAID/Paraguay develop a formal plan for facilitating and monitoring progress by Centro de Estudios Ambientales y Sociales on specific conditions to improve the program's financial and administrative control environment, or terminate the agreement with Centro de Estudios Ambientales y Sociales.

USAID/Paraguay instruct Centro de Estudios Ambientales y Sociales in writing to revise its procurement practices to meet requirements for competition, including proper advertising and unbiased selection of vendors.

USAID/Paraguay determine the allowability of $406,910 in ineligible questioned costs related to the lack of competitive bidding and recover from Centro de Estudios Ambientales y Sociales the amount determined to be unallowable.

USAID/Paraguay, in coordination with Centro de Estudios Ambientales y Sociales, mitigate the impact of the conflict of interest, calculate the fair value of office space funded by USAID for the Democracy and Governance Program that the subcontracted consulting firm occupied rent-free, have the agreement officer determine the allowability of the calculated amount, and recover from Centro de Estudios Ambientales y Sociales any amount determined to be unallowable.

USAID/Paraguay work with Centro de Estudios Ambientales y Sociales to revise its payroll process to track payroll hours for employees not fully dedicated to the program.

USAID/Paraguay, in coordination with Centro de Estudios Ambientales y Sociales, review the subaward between Management Systems International and Centro de Estudios Ambientales y Sociales, document and calculate the costs of any subaward requirements that Management Systems International did not meet and have the agreement officer determine the allowability of the calculated amount, and recover from Centro de Estudios Ambientales y Sociales any amount determined to be unallowable.

USAID/Paraguay develop a formal plan for monitoring and supporting Centro de Estudios Ambientales y Sociales that provides appropriate oversight through coaching and regular financial reviews to ensure proper accountability for funds provided to the organization.

USAID/Paraguay instruct Centro de Estudios Ambientales y Sociales, in writing, to pay employees at the rates in the award budget.

USAID/Paraguay work with Centro de Estudios Ambientales y Sociales to determine and document the most cost-effective method for staffing program positions that complies with local labor law.

USAID/Paraguay have the agreement officer amend the Democracy and Governance Program agreement to include the latest mandatory standard provisions for non-U.S. nongovernmental organizations as noted in the mandatory reference to Automated Directives System 303, "Standard Provisions for
Non-U.S. Nongovernmental Organizations."

USAID/Paraguay have the agreement officer amend the award for the Democracy and Governance Program to cover the indirect costs of the Centro de Estudios Ambientales y Sociales or require Centro de Estudios Ambientales y Sociales to seek new funding sources so that costs associated
with doing so would become direct costs.

USAID/Paraguay evaluate and document whether to adjust the cost-share percentage for the Centro de Estudios Ambientales y Sociales in light of its circumstances, and have the agreement officer modify the award as necessary.

USAID/Haiti develop, in accordance with current USAID policy, indicators and targets that reflect the project's goals and expected results.

USAID/Haiti require Tetra Tech DPK to implement procedures to verify reported data before submitting them to the mission.

USAID/Haiti implement procedures to allow contracting officer's representatives to inform the monitoring and evaluation specialist, in writing, if additional data quality assessments for custom indicators are critical to the
performance of the project or as a basis for payment for completing a milestone.

USAID/Haiti release a mission notice establishing
quality standards for record keeping, determining timelines for submission, and approvals of principle guiding documents.

The USAID Office of Transition Initiatives, in collaboration with the Office of Acquisition and Assistance and the Office of the General Counsel, develop and implement a plan in which future class deviations from acquisition policies and/or procedures clearly state the conditions for which the deviation will apply.

The USAID Office of Transition Initiatives, in collaboration with the Office of Acquisition and Assistance, review all deviations from Automated Directives System or acquisition regulations for its active awards, and determine whether they comply with Title 48 of the Code of Federal Regulations, Subpart 701.4, and correct any instances of noncompliance.

The USAID Office of Acquisition and Assistance review its procedure for approving and managing deviations, and determine whether it needs to be updated to comply with Title 48 of the Code of Federal Regulations, Subpart 701.4, and make any corrections necessary.

The USAID Office of Transition Initiatives establish and implement procedures that require oversight of implementing partners' proper compliance with exception to competition requirements.

The USAID Office of Acquisition and Assistance review the control procedures for the Office of Transition Initiatives' grants under contract and implement a plan to conduct periodic monitoring of the Office of Transition Initiatives' grants under contract.

The USAID Office of Acquisition and Assistance establish Automated Directives System guidance to identify and prevent personal conflicts of interest, including by contractor staff when executing grants under contract.

The USAID Office of Transition Initiatives develop a plan to implement the new requirements that prohibit personal conflicts of interest, including how to identify and avoid them.

The USAID Office of Transition Initiatives, in collaboration with the Office of General Counsel and the Office of Acquisition and Assistance, develop and implement a policy that requires including clearly delineated legal responsibilities in its awards in the context of the Office of Transitive Initiatives unique business model, and communicating legal responsibilities to its partners.

The USAID Office of Transition Initiatives and the Office of the General Counsel develop procedures on when and how the Office of Transition Initiatives country teams should seek legal counsel, which includes during implementation and administration of a program.

The USAID Office of Transition Initiatives develop and implement a policy to document actions taken to address recommendations stemming from program performance reviews, and, if a program performance review is not conducted or recommendations are not followed, that those decisions are documented.

The USAID Office of Transition Initiatives check that all Cuban Civil Society Support Program formal reviews and project deliverables are finalized properly and labeled accordingly.

The USAID Office of Transition Initiatives update its office guidance and inform current staff on the need to finalize project deliverables properly and to finalize deliverables of ongoing projects that were not done properly before.

The USAID Office of Transition Initiatives submit Cuban Civil Society Support Program documents, including the final program evaluation with lessons learned, to the Development Experience Clearinghouse in accordance with Automated Directives System, or obtain the appropriate waiver.

The USAID Office of Transition Initiatives inform current staff in writing and update office guidance on the requirement to document legal guidance, including correspondence, in project files and maintain these files in accordance with the Agency disposition schedule.

The USAID Office of General Counsel inform current staff in writing and update office guidance on the requirement to follow the Agency's disposition schedule and require attorneys to maintain appropriate documentation of legal opinions, including legal correspondence, in accordance with that schedule.

USAID Bureau for Management conduct an agency-wide analysis to determine whether a screening policy is needed to address intelligence and subversion threats that apply to USAID, and, if so, develop and implement one.

The Chief Information Officer finalize and implement the Standard Operating Procedure for the Use of ePolicy Orchestrator Policy Auditor For Baselines Monitoring and Reporting.

The Chief Information Officer document and implement a process to ensure that all baselines are appropriately implemented and periodically checked for compliance in accordance with Agency policy.

The Chief Information Officer develop and implement a process to remediate vulnerabilities within an Agency-defined time frame, as appropriate, or document acceptance of the risks of those vulnerabilities.

The Chief Information Officer document and implement a process for monitoring Agency devices for unauthorized application software, preventing the installation of such software, and removing it if found.

USAID/Afghanistan implement written standards for what constitutes effective, sufficient oversight, including the amount of monitoring deemed necessary for an activity to continue, the relative contributions of the five tiers, and potential events that warrant a decision on the status of the activity.

USAID/Afghanistan implement written procedures for having mission managers decide whether to continue an activity if standards are not met or if such future events occur.

USAID/Afghanistan prepare a written determination to add a module to capture and analyze monitoring data in Afghan Info, or establish a different system to store centralized monitoring data for analysis and set a deadline for making any design changes.

USAID/Afghanistan implement procedures to periodically reconcile awards listed in Afghan Info with records held by the Office Acquisition and Assistance, the Office of Program and Project Development, and technical offices, including those based in Washington, D.C., and update Afghan Info as necessary.

USAID/Afghanistan adopt a policy of reviewing Mission Order 203.02 or any subsequent order on monitoring at its quarterly monitoring review meetings to make sure all staff are aware of the requirement to promptly verify and approve reports submitted in Afghan Info.

USAID/Afghanistan implement a strategy to analyze project performance information and make recommendations to mission leaders in light of anticipated staffing reductions and travel restrictions.

USAID/Afghanistan develop procedures to verify that annual monitoring plans required under Mission Order 203.02 or any subsequent order on monitoring are prepared and used to structure the activities of its third-party monitors.

USAID/Afghanistan implement procedures to help ensure that all evaluations, assessment reports, and recommendations are recorded and tracked in Afghan Info.

USAID/Afghanistan implement procedures to follow up on the status of open evaluation recommendations periodically.

USAID's Office of U.S. Foreign Disaster Assistance implement procedures to identify, include in its standard set, and monitor performance indicators that measure effectiveness in responding to a pandemic.

USAID's Office of U.S. Foreign Disaster Assistance, in coordination with Global Communities, implement procedures to identify
and monitor performance indicators that measure program effectiveness.

USAID's Office of U.S. Foreign Disaster Assistance, in coordination with Global Communities, implement procedures to improve
controls over payments to burial and disinfection team members by depositing salaries directly in bank accounts when possible or confirming team members' identities with identification cards.

USAID's Office of U.S. Foreign Disaster Assistance implement standard operating procedures for rotating Disaster Assistance Response Team members to transfer program information. These procedures should include documenting site visits and all other efforts to verify program activity.

USAID's Office of U.S. Foreign Disaster Assistance, in coordination with Global Communities, implement procedures to verify that reported results are accurate.

USAID's Office of U.S. Foreign Disaster Assistance, in coordination with Global Communities, document a disposition plan for the transfer of vehicles purchased by the program.

USAID's Office of U.S. Foreign Disaster Assistance, in coordination with Global Communities and the Government of Liberia, document a transition plan for the transfer and management of the Disco Hill burial site prior to program completion.

The U.S. African Development Foundation's Chief Financial Officer develop and fully implement a documented process to confirm that the foundation's security assessment and authorization activities for systems transitioned to cloud service providers are compliant with National Institute of Standards
and Technology requirements. At a minimum, this should include a review of the security
authorization package for the cloud service provider and a determination of risk to the
foundation documented in an authorization-to-operate memo based on a completed security controls assessment and updated system security plan, risk assessment, and plan of action and milestones.

The U.S. African Development Foundation's Chief Financial Officer update the General Support System security plan to reflect National Institute of Standards and Technology Special Publication 800-53, Revision 4, Security and Privacy Controls for Federal Information Systems and Organizations.

The U.S. African Development Foundation's
Chief Financial Officer develop and implement a documented process to review and update the General Support System's system security plan annually. At a minimum, this should include a determination whether the security requirements and controls for the system are documented adequately and reflect the current information system environment.

The U.S. African Development Foundation's Chief Financial Officer develop and implement a documented process to confirm that security assessment plans are documented for the General Support System that describe the scope of the assessment. At a minimum, this should include the security controls and control enhancements under assessment, and the assessment procedures to be used to determine security control effectiveness as required by the National Institute of Standards and Technology.

The U.S. African Development Foundation's Chief Financial Officer develop and fully implement a documented process to confirm that a security assessment is conducted annually for the General Support System, as required by foundation policy.

The U.S. African Development Foundation's Chief Financial Officer develop and fully implement a documented process to enforce the required review of user accounts by system owners to confirm that they are aligned with the individual's job function.

The U.S. African Development Foundation's President appoint a Senior Agency Official for Privacy/Chief Privacy Officer who has the authority within the foundation to consider information privacy policy issues at a national and agency-wide level.

The U.S. African Development Foundation's President develop and fully implement a documented process to confirm that the Senior Agency Official for Privacy/Chief Privacy Officer meets privacy reporting requirements as stipulated by National Institute of Standards and Technology and foundation policy.

The U.S. African Development Foundation's President develop and fully implement a documented process to confirm that privacy impact assessments are updated when a system change creates a new privacy risk, and the Senior Agency Official for Privacy/Chief Privacy Officer reviews and approves them.

The U.S. African Development Foundation's Chief Financial Officer update the contingency plan for the General Support System and Program Support System to reflect the transition to cloud-based service providers.

The U.S. African Development Foundation's Chief Financial Officer develop and fully implement a documented process to confirm that the contingency plan for the General Support System and Program Support System are tested to make sure foundation personnel are trained on how to respond in the event of a disruption of cloud-based services.

The U.S. African Development Foundation's Chief Financial Officer develop and fully implement a documented process to confirm that contracts for service providers include requirements for security and privacy controls in compliance with the foundation's information technology security policies, associated standards, and any applicable federal laws, directives, regulations, and guidance.