To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop and implement procedures to collect indirect cost data from implementers in a systematic manner that will allow it to comprehensively report and analyze the indirect costing methodology and rates for implementers. This information should include indirect cost rate agreement type (e.g., cognizant agency-negotiated indirect cost rate or de minimis agreements).
To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Review the results of the prime implementer's sub-awardee monitoring specifically for indirect cost concerns during site visits or other reviews of the prime.
To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop written internal control policies, procedures, or guidance specific to USAID's Overhead, Special Cost, and Closeout Branch indirect cost processes to clarify minimal documentation retention rules during every phase of the indirect cost process, notably first time, subsequent, and final negotiations.
To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop checklists to verify completion of for-profit organizations files similar to the checklist used for non-profit organizations.
To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop a process to conduct periodic reviews of a sample of implementer files for missing documents or accuracy of indirect costs charged and report unsupported payments as improper payments.
To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Consider implementation of a centralized document control methodology and tracking mechanism to improve internal document control practices.