Recommendation Dashboard

USAID/Southern Africa determine the allowability of the $20,057 in ineligible questioned costs comprised of $5,597 in ineligible costs identified on page 27 of PricewaterhouseCoopers' audit report and the $14,460 unexplained difference between the prior year ending fund balance and the current year opening balance included on page 29 and recover from the Church Alliance for Orphans the amounts determined to be unallowable.

USAID/Southern Africa ensure that Church Alliance for Orphans corrects the fifteen significant deficiencies in internal control detailed on pages 34 to 53 of PricewaterhouseCoopers' audit report.

USAID/Southern Africa ensure that Church Alliance for Orphans corrects the four instances of material noncompliance detailed on pages 56 to 59 of PricewaterhouseCoopers' audit report.

USAID/Cambodia work with Winrock International Institute for Agriculture Development to implement a plan advocating governmental approval of the subdecree protecting the core forest in Prey Lang Landscape.

USAID/Cambodia work with Winrock International Institute for Agriculture Development to implement a plan to find buyers for nontimber forest products in Prey Lang Landscape so producers get fair prices.

USAID/Cambodia work with Winrock International Institute for Agriculture Development to revise its data collection methods for income-generating activities to count only participants that reside in the communities supported by the project.

USAID/Cambodia work with Winrock International Institute for Agriculture Development to align the performance monitoring and evaluation plan with the performance indicator definitions, data collection methodology, and intended results in the reference sheets for performance indicators.

USAID/Cambodia implement a plan to comply with the mission order on performance monitoring, which requires agreement officer's representatives to verify data during site visits and document the results.

USAID/Cambodia work with Winrock International Institute for Agriculture Development to implement an advocacy plan with the Cambodian Government for the adoption of a revenue-sharing agreement for the Seima Protection Forest demonstration site.

USAID/Cambodia implement a plan to conduct and document periodic physical inspections of all award files to ensure compliance with the requirements in designation letters.

USAID/Guatemala work with Rainforest Alliance to review and document whether the program's established indicators and targets need to be revised to align with expected results, and modify the performance management plan and agreement as needed.

USAID/Guatemala work with Rainforest Alliance to prepare a data quality assessment and clearly define, develop, and implement data quality standards as stated in the data quality assessment completed in 2014 and include in the assessment the method and frequency of data collection, and
who is responsible for it.

USAID/Guatemala work with Rainforest Alliance to have its regional staff and consortium members trained on data quality standards for the program's indicators.

USAID/Guatemala work with Rainforest Alliance to develop a written sustainability plan as defined under the agreement of the program.

USAID/Guatemala include a sustainability analysis in the midterm evaluation of the Climate, Nature, and Communities in Guatemala Program.

USAID/Guatemala issue clear written guidance to Rainforest Alliance on how to report on new private resources that meets criteria, and revise the previously reported results based on the agreement.

USAID/Guatemala develop and implement a process to verify and monitor the amounts reported by Rainforest Alliance as new private resources to make sure it is properly calculated and supported.

USAID/Guatemala work with Rainforest Alliance to implement procedures to monitor, validate, and correctly report cost sharing in progress reports in accordance with USAID and U.S. federal regulations.

USAID/Guatemala work with Rainforest Alliance to modify the standardized sign-in sheet to accurately report the duration of training sessions held by the program, clearly define the difference between training and technical assistance, identify what training should be entered into USAID's Webbased participant training management system database in the future, and retrain regional staff on participant training matters to avoid misreporting.

USAID/Guatemala update Mission Order 253 to spell out implementers' responsibilities and procedures for verifying information entered into USAID's Web-based participant training management database to follow the requirements of Automated Directives System 253.

USAID/Guatemala review and update its training approval process in Mission Order 253 to prevent participants from attending training without undergoing background checks, and distribute the revised process to mission personnel and implementers.

USAID/Guatemala submit to the embassy the names of participants who attended the training session "Exchange of Experiences About Payment for Hydric Environmental Services" held in Olanchito, Honduras, to determine whether U.S. Government funds were used in violation of Automated
Directives System 206.3.9.

USAID/Afghanistan immediately instruct the Volunteers for Economic Growth Alliance to stop establishing new public-private alliances under the Assistance in Building Afghanistan by Developing Enterprises Program.

USAID/Afghanistan, in coordination with the Volunteers for Economic Growth Alliance, implement a detailed plan, including milestones, for concluding the Assistance in Building Afghanistan by Developing Enterprises Program at no additional cost to USAID.

USAID/Afghanistan not fund any currently contemplated job apprenticeship activity via the Assistance in Building Afghanistan by Developing Enterprises Program.

USAID/Afghanistan develop a case study for training purposes that uses the lessons learned from the Assistance in Building Afghanistan by Developing Enterprises Program.

USAID/Afghanistan conduct and document a review to determine whether to continue activities under the Assistance in Building Afghanistan by Developing Enterprises Program's enterprise enabling environment activity (Component 3) or put the remaining $1.6 million in unused funds to better use.

USAID/Afghanistan evaluate whether the methodology used in compiling results reported under the performance indicators for the Assistance in Building Afghanistan by Developing Enterprises Program is justifiable and, based on the results of this review, require the implementer to update its monitoring and evaluation plan to reflect any changes.

USAID/Afghanistan develop a schedule of periodic meetings with Assistance in Building Afghanistan by Developing Enterprises Program staff at the U.S. Embassy compound in Kabul to review performance results and other related issues.

USAID/Afghanistan implement a plan to have third-party monitoring contractors verify performance indicator results reported by the Assistance in Building Afghanistan by Developing Enterprises Program.

USAID/Afghanistan implement a plan to confirm that the Assistance in Building Afghanistan by Developing Enterprises Program is included in the annual performance plan and report and any mission-wide data quality assessments.

USAID/Afghanistan require the Volunteers for Economic Growth Alliance to include in quarterly reports for the Assistance in Building Afghanistan by Developing Enterprises Program detailed information on the status of equipment procurements, delivery, installation, and any actions taken or planned to resolve delays and expedite activities that are behind schedule.

USAID/Afghanistan require the Volunteers for Economic Growth Alliance to implement a plan to improve financial oversight over all partners implementing the Assistance in Building Afghanistan by Developing Enterprises Program.

USAID/Afghanistan determine the allowability of $18,034 in questioned costs ($6,638 ineligible and $11,396 unsupported) and recover from the Volunteers for Economic Growth Alliance any amounts determined to be unallowable.

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.