Recommendation Dashboard

We recommend that MCC's Department of Administration and Finance perform a more comprehensive review of advances by comparing MCA advances reported to MCC to the source data maintained by the fiscal agent.

We recommend that MCC's Department of Administration and Finance employ substantive fluctuation and trend analyses of the advances account and promptly investigate unusual fluctuation and trends.

We recommend that MCC enhance its Expense Accruals Financial Management Division Procedure Manual to:
a. Define the criteria for when the assumption that MCC's maximum liability being equivalent to unused spending authority at the end of the quarter is not valid and why.
b. Fully address the MCA confirmation process and how it is carried out and documented.
c. Incorporate the desk procedures so that the procedures are formally reviewed and approved
d. Address how a grant accrual estimate provided by an MCA should be evaluated
to determine if it is reasonable.
e. Establish a procedure to ensure that MCC provides an MCA with sufficient time to address MCC's request to assess the reasonableness of the MCC calculated grant accrual for an MCA.
f Formalize the guidance provided to an MCA on what supporting documentation should be provided to address the reasonableness of the MCC calculated grant accrual for an MCA or providing an accrual estimate for an MCA to MCC.

We repeat the prior years' recommendation that MCC's Department of Administration and Finance continue to investigate and correct the root
causes for the system limitations or problems that prevent or delay the recording,
processing, and summarizing of accounting transactions.

The Inter-American Foundation assess and document how selected grantees in El Salvador could contribute greater resources to their grants to maximize chances for sustainability.

The Inter-American Foundation develop a plan to train selected grantees on their responsibilities for properly reporting and retaining supporting documentation for reported results.

The Inter-American Foundation assess the Office of Management and Budget requirements and incorporate all those that are cost-effective for its grantees.

The Inter-American Foundation train selected
grantees in Brazil and El Salvador on compliance requirements.

The Inter-American Foundation modify its internal policies to require appropriate reporting of crimes (including fraud), waste, and abuse to the USAID Office of Inspector General.

USAID/West Africa determine the allowability of $278,525 in ineligible questioned costs and recover from Conseil Ouest et Centre Africain pour la Recherche et le Developpement Agricoles the amount determined to be unallowable.

USAID/West Africa acknowledge in writing the unauthorized commitment that occurred under these programs and include language to ratify any payments determined to be allowable.

USAID/West Africa implement procedures to verify that agreement officers approve modifications to extend awards before their end dates.

USAID/West Africa determine the allowability of $77,749 in unsupported questioned costs related to the outstanding funds from the Global Food Security Response projects and $40,074 in funds that Conseil Ouest et Centre Africain pour la Recherche et le Developpement Agricoles reimbursed into its own account, and recover from Conseil Ouest et Centre Africain pour la Recherche et le Developpement Agricoles the amount determined to be unallowable.

USAID/West Africa identify and determine the allowability of ineligible questioned costs related to the salaries paid for Conseil Ouest et Centre Africain pour la Recherche et le Developpement Agricoles employees who worked on other donors' projects and recover from Conseil Ouest et Centre Africain pour la Recherche et le Developpement Agricoles the amount determined to be unallowable.

USAID/Pakistan integrate gender sensitivity (women equality and empowerment) into project training to provide awareness to all dairy farmers, artificial insemination workers, and women livestock extension workers to improve women's access to economic opportunities.

USAID/Pakistan work with Dairy and Rural Development Foundation to provide additional support to the women livestock extension workers by extending the follow-up timeframe.

USAID/Pakistan, with the National Democratic Institute, reassess and document whether program activities remain viable given the security and political realities in Pakistan, and modify the agreement and work plans to update program activities, deliverables, and funding accordingly.

USAID/Pakistan, with the National Democratic Institute, implement a recruitment plan to fill vacant positions and maintain a staffing level commensurate with the program's planned results.

USAID/Pakistan, with the National Democratic Institute and Strengthening Participatory Organization, set written criteria for selecting subject matter experts and briefing them on issues of concern to the parties before holding discussion forums, and develop a written strategy to facilitate follow-up meetings between subject matter experts and members of policy working groups to discuss policy interventions as needed.

USAID/Pakistan, with the National Democratic Institute, identify and document the skills and experience necessary for members of research units and policy working groups; the relevant selection standards; and the procedures political parties will use to identify, select, and recruit qualified participants.

USAID/Pakistan, with the National Democratic Institute, implement a written plan to facilitate coordination between research units and policy working groups and share event schedules with them well in advance.

USAID/Pakistan, with the National Democratic Institute, implement a plan to obtain leadership commitment from each participating political party, clarify expectations and responsibilities, and focus the program on parties that are fully committed.

USAID/Pakistan, with the National Democratic Institute and the International Republican Institute, determine and document whether to continue program support and activities for the Institute for Public Opinion Research or to put the remaining funds to better use.

USAID/Pakistan, if it decides to continue supporting the Institute for Public Opinion Research, work with the National Democratic Institute and the International Republican Institute to implement a corrective action plan to address the slow progress in providing capacity building to the Institute for Public Opinion Research.

USAID/Pakistan require the National Democratic Institute to reassess and document the capabilities of Strengthening Participatory Organization and determine how to effectively involve it in the program.

USAID/Pakistan determine the allowability of, and recover from the National Democratic Institute as appropriate, ineligible questioned costs of $138,375.

USAID/Pakistan develop a plan to conduct regular site visits or devise alternatives to provide adequate oversight of the program if site visits are not possible, and document the results.

USAID/Pakistan work with the National Democratic Institute to develop an action plan to strengthen controls over performance data collection and reporting, including supervisory review of the data before submission to USAID/Pakistan.

USAID/Pakistan require the National Democratic Institute to have the Institute for Public Opinion Research undergo an audit of fiscal year 2013 expenditures in compliance with the Office of Inspector General's Guidelines for Financial Audits Contracted by Foreign Recipients.

USAID/Pakistan require the National Democratic Institute to modify agreements with the International Republican Institute and the Institute for Public Opinion Research to include the standard audit provisions.

We recommend that the Millennium challenge Corporation's Chief Information Officer implement automated controls to disable inactive MCCNet accounts when they reach the Corporations inactivity threshold. If management determines that using such controls is not feasible, document that decision in writing and implement mitigating manual controls.

We recommend that the Millennium Challenge Corporation's Vice President of Administration and Finance document and implement a process to perform periodic, as defined by the Corporation, reviews of the exit clearance process to determine whether personnel are maintaining exit forms as required.

We recommend that the Millennium Challenge Corporation's Chief Information Office develop and implement a written process to validate whether the plans of action and milestones are completed and updated on time.

We recommend that the Millennium Challenge Corporation's Chief Information Officer document and implement a process to verify whether mobile devices are encrypted prior to use for Corporation business.

We recommend that the Millennium Challenge Corporation's Chief Information Officer document and implement a process to verify on a periodic basis, as defined by the corporation, the status of encryption on all mobile devices containing corporation data and take corrective action, if necessary.

We recommend that the Millennium Challenge Corporation's Chief Information Officer implement multifactor authentication for all network accounts and document the results.

We recommend that the Millennium Challenge Corporation's Chief Information Officer document and implement a written process to confirm that system risk assessments are completed in compliance with the corporation's risk assessment policy and procedures.

We recommend that the Millennium Challenge Corporation's Chief Information Officer complete and implement automated system controls to support the detection and protection of information related to privacy.

USAID/Haiti, through the Feed the Future North Project contracting officer, identify activities that will have the greatest impact on project objectives given the remaining time and resources in the base implementation period, and reduce the scope of the contract accordingly.

USAID/Haiti direct Development Alternatives Inc. to revise its strategy for implementing Feed the Future North Project activities to address the dearth of capable local organizations in the northern corridor.

USAID/Haiti formally communicate to Development Alternatives Inc. the actual opportunities that exist for local organizations to bid on and receive direct USAID funding.

USAID/Haiti report problems staffing its contracting office in its next Federal Manager's Financial Integrity Act of 1982 annual certification.

USAID/Haiti, through the Feed the Future North Project contracting officer, amend the contract to define deliverables and results.

USAID/Haiti establish criteria for determining
whether to exercise the option years for the Feed the Future North Project.

USAID/Haiti, through the Feed the Future North Project contracting officer, realign the remaining fixed fee attributed to intermediate results 1, 2, and 3 to demonstrating "best-effort" toward achieving the deliverables and results defined in response to Recommendation 5.

USAID/Haiti, through the Feed the Future North Project contracting officer, determine whether the fixed fee attributed to intermediate result 4 should allow for making 2 local organizations eligible for direct USAID funding and 12 local organizations eligible for fixed-obligation grants, and modify the contract if necessary.

USAID/Haiti reflect concerns with project implementation, schedule, and staffing in its contractor performance assessment reports for Development Alternatives Inc. for the Feed the Future North Project, including revising the previous report as necessary, and maintain documentation to support the assessments.

USAID/Haiti begin a performance evaluation of the Feed the Future North Project by September 30, 2015.

USAID/Haiti remind contracting officer's representatives of their designated responsibilities to document performance concerns,
elevate the concerns to the contracting officer for timely resolution, and maintain complete documentation in the official project file.

USAID/Haiti document clear procedures, responsibilities, and timelines for requesting and approving waivers for restricted goods.

USAID/Haiti document clear procedures, responsibilities, and timelines for requesting and approving waivers for restricted goods.

USAID/Haiti document clear procedures designating the contracting officer's representative, or alternate contracting officer's representative as applicable, as the sole liaison between USAID and contractor staff unless otherwise specified, with procedures to document justification for any exceptions.

USAID/Haiti document clear roles and responsibilities for managing complex Feed the Future projects, and implement a plan to make sure these roles and responsibilities are respected and enforced.

USAID/Haiti set a deadline for Development
Alternatives Inc. to correct critical staffing deficiencies for the Feed the Future North Project and take formal corrective action if this deadline is not met.

USAID/Haiti review its requirement to approve all professional staff positions for the Feed the Future North Project, determine whether the requirement is in the best interests of the U.S. Government, and, through the project contracting officer, revise the requirement in the contract if necessary.

USAID/Haiti set a deadline for Development Alternatives Inc. to finalize the project-level environmental assessment for the Feed the Future North Project and take formal corrective action if the deadline is not met.

USAID/Haiti identify ongoing Feed the Future North Project activities that do not comply with environmental requirements and direct Development Alternatives Inc. to stop all identified activities until the required level of environmental review is completed.

USAID/Haiti incorporate procedures in Mission Order 204-1 to document, at the start of the award, agreement between the contracting officer's representative; mission-, regional-, and bureau-level environmental officers; and the contractor on procedures and timelines to meet environmental compliance requirements.

USAID/Haiti modify its initial environmental examination for the food security and economic growth portfolio to remove any ambiguity about the required level of environmental review for its projects, programs, and activities, and request approval of the initial environmental examination from the bureau environmental officer.

USAID/Haiti develop a timeline with milestones for Development Alternatives Inc. to complete irrigation activities for the Feed the Future North Project and take formal corrective action if they are not met.

USAID/Haiti develop procedures to make sure contracts for infrastructure projects include clear specifications for cost-benefit analyses.

USAID/Haiti, through the Feed the Future North Project contracting officer, modify the contract to remove road rehabilitation activities and put $9.93 million to better use.

USAID/Haiti include an in-depth review of Development Alternative Inc.'s internal controls for procurement and distribution of project materials in its upcoming financial review of the Feed the Future North Project.

USAID/Haiti, through the Feed the Future North Project contracting officer, determine the allowability of $10,028 in unsupported questioned costs ($9,746 from unsupported distributions in our test sample and $264 from the banana plants delivered to cacao farmers) and recover from Development Alternatives Inc. any amount determined to be unallowable.

USAID/Haiti implement alternative measures to estimate the impact of the Feed the Future North Project and the progress of outcome indicators in the absence of a valid baseline study.

USAID/Haiti implement a plan to confirm that its future Feed the Future projects establish valid baselines at the start of the awards.

USAID/Haiti establish a timeline with milestones for Development Alternatives Inc. to bring performance data for the Feed the Future North Project in line with USAID's data quality standards and take formal corrective action if they are not met.

USAID/Haiti determine whether its strategy for increasing food security in Haiti should include water, sanitation, and hygiene activities, document the decision, and modify the strategy accordingly.

USAID/Haiti, in consultation with the contracting officer for the Feed the Future North Project, determine whether the contract should be modified to meet criteria for the water, sanitation, and hygiene earmark, document the decision, and modify the contract accordingly.

USAID/Haiti incorporate reporting progress toward meeting earmarks into its biannual portfolio reviews, add a section on earmarks to its portfolio review project data sheet template, and include earmark criteria in the guidance disseminated to mission staff in preparation for its biannual portfolio reviews.

USAID/Haiti provide to USAID/Washington details on its water, sanitation, and hygiene earmark allocations for fiscal years 2012 and 2013 so that USAID/Washington can notify Congress as appropriate as to overall Agency execution of the earmark.

USAID/Indonesia, through the responsible contracting officer, modify the Higher Education Leadership and Management Project contract to identify clearly in section C.4.4 which results Chemonics International Inc. will be required to deliver and report on.

USAID/Indonesia work with Chemonics International Inc. to revise indicator definitions in the project's monitoring and evaluation plan to clarify calculation methodology and disclose data limitations for seven indicators.

USAID/Indonesia require Chemonics International Inc. to document the rationale for the project target for every indicator in the monitoring and evaluation plan.

USAID/Indonesia review and verify the accuracy of three baseline studies completed in January 2015.

USAID/Indonesia direct Chemonics International Inc. to strengthen oversight and controls over data verification and reporting by creating written procedures that clearly describe responsibilities of the project's monitoring and evaluation staff, consultants, and technical staff.

USAID/Indonesia require Chemonics International Inc. to create written procedures for database management that include periodic data integrity checks.

USAID/Indonesia provide additional training in performance monitoring to the contracting officer's representative and the alternate contracting officer's representative.

USAID/Indonesia require contracting officer's representatives to track accruals by contract line item number in their quarterly reports.

USAID/Indonesia clarify branding requirements for subcontracts under the Higher Education Leadership and Management Project.

USAID/Indonesia require Chemonics International Inc. to determine the allowability of approximately $85,275 in costs for the subcontract to create webinars for the Higher Education Leadership and Management Project and collect from Gadjah Mada University any amount determined to be unallowable.

The Chief Information Officer document and implement procedures to review active network accounts that have not logged in over a specified period of time, as defined by Automated Directives System Chapter 545, "Systems Security Policy," or that have never logged into the system to determine whether accounts are necessary and disable or delete accounts that are unnecessary.

The Director of the Office of Management Policy, Budget, and Performance, in coordination with the Chief Information Officer, the Chief Human Capital Officer, and the Director of the Office of Acquisition and Assistance, document and implement procedures to promptly remove system accounts associated with people no longer at USAID.

The Chief Information Officer implement improved procedures to make sure approved access request forms are maintained for anyone with access to the network.

The Chief Information Officer work with the AIDtracker system owner to update AIDtracker security settings for user inactivity to comply with policy, or issue a written authorization for deviations.

The Chief Information Officer work with the AIDtracker system owner to document and implement procedures to make sure approved access request forms are maintained for anyone with access to the system.

The Director for the Office of Security document and implement procedures to review Partner Vetting System accounts that have not logged in over a specified period of time, as defined by USAID, or that have never logged into the system to determine whether accounts are necessary.

The Chief Information Officer work with the State Department's Director for the Office of U.S. Foreign Assistance Resources to implement procedures to complete, approve, and maintain approved access request forms for privileged users with access to the Foreign Assistance Coordination and Tracking System Info as required in accordance with policies.

The Chief Information Officer work with the State Department's Director for the Office of U.S. Foreign Assistance Resources to document and implement procedures to review active Foreign Assistance Coordination and Tracking System Info accounts that have not logged in over a specified period of time or that have never logged into the system to determine whether accounts are necessary.

The Chief Information Officer work with the State Department's Director for the Office of U.S. Foreign Assistance Resources to document and implement procedures to review Foreign Assistance Coordination and Tracking System Info accounts periodically for appropriateness.

The Chief Information Officer conduct a full system reauthorization for the AIDtracker system in accordance with USAID's policy.

The Chief Information Officer conduct a full system reauthorization for the Partner Vetting System in accordance with USAID's policy.

The Chief Information Officer implement a documented validation process to confirm that continuous monitoring activities-such as updating system security plans, risk assessments, security assessments, and plans of action and milestones-are occurring for all USAID systems on a periodic basis, as defined by USAID, and as significant system changes occur.

The Chief Information Officer document and implement a process to confirm that the role-based training program is implemented as applicable for all employees and contractors requiring role-based training, and be sure the training is tracked and documented.

The Chief Information Officer update the AIDNet system security plan to fully document the system's security controls.

The Director for the Office of Security implement a documented validation process to confirm that the Partner Vetting System contingency plan is reviewed, updated, and tested annually.

The Chief Information Officer document a formal memorandum of understanding with the alternate processing vendor.

The Director for the Office of Security document, implement, test, and maintain a current, accurate baseline configuration for the Partner Vetting System.

USAID/Nigeria determine the allowability of $5,672,236 in unsupported questioned costs (page 6 of the audit report) and recover from Hope Worldwide Nigeria the amount determined to be unallowable.

USAID/Nigeria determine the allowability of $399,198 in ineligible questioned costs (page 6 of the audit report) and recover from Hope Worldwide Nigeria the amount determined to be unallowable.

USAID/Nigeria verify that Hope Worldwide Nigeria correct the internal control material weakness and the significant deficiency identified on page 15 of the audit report relating to its inabilities to reconcile subsidiary accounting books to the trial balance and provide a detail transactions list for lump sum amounts recorded in the general ledger.

USAID/Nigeria determine the allowability of $1,411,996 in unsupported questioned costs relating to costsharing contribution, and recover from Hope Worldwide Nigeria the amount determined to be unallowable (page 12 of the audit report).

USAID/Nigeria verify that Hope Worldwide Nigeria implement the outstanding prior year audit recommendations identified on page 32 of the management letter.

USAID/Nigeria verify that Hope Worldwide Nigeria liquidate the advances identified on page 4 of the report and recover from Hope Worldwide Nigeria the amount determined to be unallowable.