Recommendation Dashboard

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.

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.