Open Recommendations

Ensure the CNCS GSS Information System Owner establishes and enforces the policy for mobile devices that do not connect to the CNCS GSS to include usage restrictions, configuration and connection requirements, and implementation guidance. (New);

Ensure the facilities implement the following in regards to protection of mobile devicesEnforce the prohibition of displaying passwords in public view
• Require the use of passwords on mobile computer assets for all users
• Change passwords and re-image...

Disallow and recover $1,663,952 in Federal costs awarded to Madison;

Rec No. 2(d): Disallow and, if already used, recover education awards made to members who did not serve the minimum required service hours.

Rec. No. 2: CNCS VISTA should develop a standard for capturing capacity building and measuring sustainability during and after the VISTA project is completed.

Rec No. 5: VISTA should specifically measure the effectiveness of the policy allowing VISTA members to take classes while serving in the VISTA program. CNCS VISTA should build performance measures into all policy/procedure changes as a means to...

Enforce the agency‐wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities.

Pending since FY 2017

Develop a multi‐year strategy to better strategically prioritize and allocate resources to address the new and continuing weaknesses identified and work towards automation, continuous monitoring and consistent application of controls.

Implement a peer review process to carry out the necessary quality control reviews of the TSAL model.

Pending since FY 2017

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.
Pending since FY 2017

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems....

use of specific and accurate SV descriptions;

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems.

Pending since FY 2017

The process to determine and document CNCS’s balance fluctuation expectations should be based on a combination of internal and external operating factors, and program and financial relevant information available.
Pending since FY 2017

Review and ensure the reasonableness of assumptions used and document the rationale behind these assumptions;

Conduct detailed analysis and validation of data sources;

Detailed process to research significant balance fluctuations. CNCS should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.
Pending since FY...

Institute continued cross‐training so that knowledge of the model will reside with multiple staff rather than with one person; and

Pending since FY 2017

Train, mentor, and work to retain qualified employees;

Pending since FY 2017

Strengthen and refine the process for communicating CNCS facility specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies.

Pending since FY 2017

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors and consistent with the materiality thresholds used by the OCRO (as part of the...

Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary;

tracking the sequence of SVs for completeness;

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Address fatal and non‐fatal Government wide Treasury Account Symbol Trial Balance (GTAS) edit failures.
Pending since FY 2017

ensure obligations are sufficiently supported (i.e., by documentary evidence);

Pending since FY 2017

review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation) and age are accurately reflected in the status of the obligation to confirm their validity;

Pending since FY 2017

timely review and approval of SVs; and

Implement all detailed recommendations in the FY 2018 FISMA Evaluation report.

Pending since FY 2017

Address all balance differences and retain supporting documentation of related research.
Pending since FY 2017

appropriate use of SVs;

perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved.

Pending since FY 2017

determining and maintaining relevant documentation to support each SV;

Develop a plan to upgrade its financial system to include OC codes which should be associated with USSGL in accordance with OMB Circular No. A‐11.
Pending since FY 2017

Provide mandatory training to CNCS accounting staff on the proper use of OC, sub general ledger accounts, and document/transaction types on all obligation and expense transactions.

Develop a succession plan to ensure the required expertise is available in the event of employee turnover. Such succession planning is key to helping CNCS continue achieving its internal and external reporting objectives. CNCS needs to:

Pending since FY...

Strengthen controls to ensure the TSAL modelling is performed by trained personnel to:

Enforce the agency‐wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities.
Pending since FY 2017

Trend the validation results and adjust the IBNR estimation process to address any recurring significant fluctuations; and

Review and ensure the reasonableness of assumptions used and document the rationale behind these assumptions;

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.

Pending since FY 2017

Strengthen and refine the process for communicating CNCS facility specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies.
Pending since FY 2017

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems....

Train, mentor, and work to retain qualified employees;

Pending since FY 2017

review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation) and age are accurately reflected in the status of the obligation to confirm their validity;

Pending since FY 2017

The process to determine and document CNCS’s balance fluctuation expectations should be based on a combination of internal and external operating factors, and program and financial relevant information available.

Pending since FY 2017

Update the IBNR estimation process as necessary to reflect changes in payment patterns.

appropriate use of SVs;

tracking the sequence of SVs for completeness;

Detailed process to research significant balance fluctuations. CNCS should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.

Pending since FY...

Document justifications for all required reports submission extensions granted to the grantee.

ensure obligations are sufficiently supported (i.e., by documentary evidence);

Pending since FY 2017

All financial, performance and other required reports are submitted no later than 90 calendar days after the end date of the period of performance.

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors and consistent with the materiality thresholds used by the OCRO (as part of the...

Develop a multi‐year strategy to better strategically prioritize and allocate resources to address the new and continuing weaknesses identified and work towards automation, continuous monitoring and consistent application of controls.

Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary;

Implement a peer review process to carry out the necessary quality control reviews of the TSAL model.

Pending since FY 2017

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Address fatal and non‐fatal Government wide Treasury Account Symbol Trial Balance (GTAS) edit failures.

Pending since FY 2017

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems.
Pending since FY 2017

Institute continued cross‐training so that knowledge of the model will reside with multiple staff rather than with one person; and

Pending since FY 2017

perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved.

Pending since FY 2017

Implement all detailed recommendations in the FY 2018 FISMA Evaluation report.
Pending since FY 2017

timely review and approval of SVs; and

determining and maintaining relevant documentation to support each SV;

Address all balance differences and retain supporting documentation of related research.

Pending since FY 2017

Conduct detailed analysis and validation of data sources;

use of specific and accurate SV descriptions;

Subsequent activities against the amount estimated to determine the level of precision in the estimation;

Develop a plan to upgrade its financial system to include OC codes which should be associated with USSGL in accordance with OMB Circular No. A‐11.

Pending since FY 2017

Provide mandatory training to CNCS accounting staff on the proper use of OC, sub general ledger accounts, and document/transaction types on all obligation and expense transactions.

Develop a succession plan to ensure the required expertise is available in the event of employee turnover. Such succession planning is key to helping CNCS continue achieving its internal and external reporting objectives. CNCS needs to:

Pending since FY...

Strengthen controls to ensure the TSAL modelling is performed by trained personnel to:

Coordinate with the program and grant officers to gather and analyze key grant programs’ (AmeriCorps State and National and Senior Corps) historical data and the grantees’ spending pattern to develop factors relevant for grant accrual estimation....

Centralize storage of all procurement documents in contract files and maintain them electronically.

Strengthen internal control to ensure procurement documents are properly approved and retained.

Analyze procurement UDO balances quarterly to verify that balances are still valid for those without financial activities for an extended period.

Research, resolve and document the disposition of any abnormal UDO transactions/balances.

Correct the financial system’s posting logic to ensure all future transactions are recorded properly in accordance with USSGL.

Develop, document and implement an accounts payable accrual methodology to include the recognition and reporting of the IBNR. The methodology should also document key controls related to review and approval process of the accrual estimation.
Pending...

Conduct validation assessment of amounts accrued for the IBNR on a periodic basis. As part of the validation, CNCS should consider the following:

Analyze contractor‐developed‐software costs that were expensed but not capitalized in accordance with accounting standards. CNCS should record appropriate adjustments to correct the IUS balance based on its analysis.

Update CNCS policy to recognize and record capitalized costs during the period they are incurred.

Determine the root causes and resolve discrepancies in the grant award amounts recorded in the NGA in eGrants and in Momentum to prevent such differences from occurring in future.

Determine the root causes and resolve expenditure differences between PMS and Momentum.

Update the CNCS transaction code posting logic for recording grant expenditures to comply with the USSGL guidance.

Require the program and grant officers who perform the grant close‐out in Momentum to certify that all required grantee information has been received and reviewed; and any final notices or changes to grant funding have been communicated and accepted by...

Develop a financial reporting checklist to ensure completeness and recording of all transactions.

Reconcile the AR subsidiary ledger to the general ledger monthly.

Reevaluate the policies and procedures for calculating the allowance for doubtful accounts. Related policies and procedures should include: (a) CFO Office’s staff’s periodic review of the accounts receivable aging report, (b) assessment of the...

Revise the Allowance for Doubtful Accounts methodology to be consistent with the Debt Management Policy.

Track and revise collection efforts based on data analysis. A reasonable timeframe for writeoffs should be established for accounts receivable without any activity. Once an outstanding receivable is deemed uncollectible, it should be written off in...

Recover the $43,626 in questioned Federal costs and $19,390 in education awards and address any impact to Federal costs of the $33,720 in questioned match costs for American Red Cross of Indiana for grant No. 15ACHIN001.

Require that SGC provide Sanctuary with the requirements of an adequate financial management system and ensure that Sanctuary implements an adequate system. The documentation provided should include guidance on how to determine the allowability of grant...

Require Serve Guam Commission to submit an updated Financial Federal Report for the 14AH award that removes the $18,761 of questioned match costs.

Require SGC, as part of its subgrantee monitoring processes, to perform periodic testing of subgrantees’ other direct costs to ensure that they incurred and claimed all costs in accordance with grant provisions, laws, and regulations.

Ensure DGCCVS implements a process to determine whether the results of the subgrantee’s audit or other monitoring indicate conditions that necessitate an adjustment to its own records; and

Develop a documented process to determine if subgrantees accurately presented CNCS awards on the Schedule of Expenditures of Federal Awards (SEFA);

Retain documentation of DGCCVS monitoring and reviews of subgrantee audit reports, along with management decisions made or corrective actions implemented.

Review the single audit report for all subgrantees with CNCS expenditures for each fiscal year for findings that affect CNCS grants to determine if DGCCVS records require an adjustment and take enforcement action against noncompliant subgrantees;

Ensure DGCCVS revises and implements its policies and procedures for assessing the financial capability of the subgrantee applicants. DGCCVS should verify the applicant’s financial management responses from the AmeriCorps Readiness Self-Assessment.

Verify that DGCCVS revise its subgrantee monitoring procedures to ensure it complies with pass-through entity responsibilities for sub-recipients’ Single Audits and includes the following procedures:

Require DGCCVS to revise its subgrantee monitoring procedures to include formal and timely subgrantee feedback to address: When the monitoring site visit took place; What the monitoring covered; The monitoring results; Required corrective actions; and...

Require DGCCVS to revise its subgrantee monitoring procedures to include formal reporting of follow-up conducted on any outstanding corrective actions.

Verify that DGCCVS is performing on-site monitoring of its subgrantees in accordance with its revised internal policies and procedures.

Verify DGCCVS has controls in place to ensure fees collected for grant-supported events were used to cover the cost of those events.

Verify DGCCVS used the fees collected for the event to reduce the Federal share charged to the grant or were used as match.

Ensures DGCCVS strengthens its monitoring to verify subgrantee compliance with CNCS best practices for member NSOPW check.

Confirm DGCCVS has established and implemented a procedure to have all staff involved in conducting subgrantee on-site monitoring to have a NSCHC.

Ensure DGCCVS revises its Program Director Handbook to include guidance on how to address and document a change in member living allowance when a member’s term is changed to ensure living allowance payments after conversion is correct.

Ensure DGCCVS strengthens its monitoring to verify subgrantee compliance with member living allowance requirements.

Work with DGCCVS to resolve the living allowance underpayments to DPR members.

Ensure DGCCVS strengthens its monitoring to verify subgrantee compliance with DGCCVS approval requirement for changes in a member’s term of service.

Ensures DGCCVS strengthens and implements its monitoring tools to verify subgrantee compliance with timekeeping requirements.

Require DGCCVS put procedures in place to ensure that DGCCVS is providing reporting guidance and reporting templates to the subgrantees before the end of the first month of the subgrantee’s program year and all subgrantees are reporting its costs in...

Require DGCCVS to obtain PERs from DPR covering the Federal and match costs incurred during the program year 2017-2018 as of March 31, 2018, along with transaction-level detail, so that CNCS can test those costs for allowability.

Calculate and recover the questioned Federal costs, match costs, and related administrative costs. Also, determine the impact on Federal costs due to questioned match costs.

Conduct detailed analysis and validation of data sources.

Establish a thorough and robust quality control process to ensure that the Trust Obligation and Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are reviewed by qualified CNCS personnel prior to relying on its outputs...

Implement a peer review process to carry out the necessary quality control reviews of the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

Detailed process to research significant balance fluctuations. CNCS should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.

Review and ensure the reasonableness of assumptions used and document the rationale behind estimation assumptions.

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.

Train, mentor, and work to retain qualified employees;

CFO Office’s staff’s periodic review of the accounts receivable aging report, (repeat)

Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

Cross-train employees so that knowledge of the model will reside with multiple staff rather than with one person; and

The process to determine and document CNCS’s balance fluctuation expectations. Expectations should be documented based on a combination of internal and external operating factors, and program and financial relevant information available.

Appropriate use of SVs/JVs;

Determination for possible write-offs. (repeat)

Document justifications for all required reports submission extensions granted to the grantee. (repeat)

Post-accrual analysis to compare the accrual (without the IBNR) and the expenditures reported in the FFRs for the same quarter. Thresholds should be established and documented based on materiality and the degree of risk that management is willing to...

Perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved. (repeat)

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors.

Subsequent activities against the amount estimated to determine the level of precision in the estimation;

It addresses how the calculations are used to arrive at the Grants Payable and Advances to Other line items in the financial statements. (modified repeat)

A validation process is established for management to verify the accuracy of the grant accrual, so that management can make any necessary adjustments to improve the precision of the grant accrual and to account for grant advances and payables to ensure...

Determining and maintaining relevant documentation to support each SV/JV;

Address all balance differences and retain supporting documentation of related research.

Assessment of the collectability of outstanding balances based on the age of the debt, collections attempted and received thus far and other information about the debtor (repeat)

An inventory of relevant and reliable grant data to be used for the grant accrual assumptions and documentation to support what data is considered relevant and reliable;

Update the incurred but not reported estimation process as necessary to reflect changes in payment patterns. (repeat)

Use of specific and accurate SV/JV descriptions; and

Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

Document and maintain support for all prior period adjustments and changes to Net Position accounts, Cumulative Result of Operations, and Unexpended Appropriations. (repeat)

Timely review and approval of SVs/JVs for accuracy and propriety. (modified repeat)

Tracking the sequence of SVs/JVs for completeness;

Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to ensure the accounting information is valid and proper;

Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary.

Percentage of CNCS grantees who drawdown funds in advance versus those on a reimbursable basis and their related grant amounts to its grant spending as a whole. If different key programs have different spending patterns, perform this analysis at the...

Trend the validation results and adjust the incurred but not reported estimation process to address any recurring significant fluctuations; and

Address fatal and non-fatal Government-wide Treasury Account Symbol Trial Balance edit failures.

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation);

Grantees' incurred but not reported (IBNR) reporting pattern from when the expenses have been incurred to the time those expenses are included the grantees' Federal Financial Reports (FFR). Grantee surveys may be conducted to confirm the...

Revise the FY 2019 CNCS Grants Financial Management Business Process Narrative to address the control gap concerning the verification of the Advances to Others balance accuracy. (new)

Develop comprehensive policies and procedures for the financial statements preparation process and related internal controls. The policies and procedures should address, among other subjects:

Monitor outstanding balances resulting from financial system configuration issues and fix these issues prior to data migration to the future shared service provider (Department of Treasury’s Administrative Resource Center) in FY 2021. While waiting to...

Coordinate with the future shared service provider to ensure that its accounting platform is compatible with CNCS’s operations and the type of accounting transactions that the CNCS process. (new)

Develop a plan to clean up CNCS’s balances prior to migration to the shared service provider’s system (Department of Treasury’s Administrative Resource Center). The plan should include coordination with the future service provider to review CNCS...

Validate and ensure standard vouchers/journal vouchers are properly supported, documented, and are readily available for examination. (modified repeat)

Strengthen coordination between Accounting and Financial Management Services and the Office of Budget to ensure that transactions are recorded accurately and timely. (modified repeat)

Develop and implement policies and procedures for the standard vouchers/journal vouchers (SV/JV) process that include:

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including establishing control activities; finalize materiality thresholds...

Develop for a more standardized, secure, and automated method to estimate the Trust obligations and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing CNCS’s transition to shared service, coordinate with the service...

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

Document and implement policies and procedures to include the following:

Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National Service Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual testing of key controls. (modified repeat)

Develop a succession plan to ensure the required expertise is available in anticipation of planned employee turnover, particularly with respect to the complex trust calculations. CNCS needs to:

Coordinate with the program and grant officers to gather and analyze key grant programs’ (AmeriCorps State and National and Senior Corps) historical data and the grantees’ spending pattern to develop the following key factors for grant accrual estimation:

Revise and implement policies and procedures for the grant accrual methodology so that:

Develop a process to validate grant advances, incurred but not reported and payable estimates. Such validation should be performed for all program elements included in the estimation process and over a few years to show a trend of the estimates. Unusual...

Strengthen internal control to ensure procurement documents are properly approved and retained. (repeat)

Analyze procurement undelivered orders balances quarterly to verify that balances are still valid for those without financial activities for an extended period. (repeat)

Research, resolve and document the disposition of any abnormal undelivered orders transactions/balances. (repeat)

Conduct validation assessment of amounts accrued for the incurred but not reported on a periodic basis. As part of the validation, CNCS should consider the following:

Evaluate the materiality thresholds used in the accrual estimation to ensure it is appropriate to prevent misstatements. The materiality threshold used should be appropriate that, in the aggregate, identified misstatements would not rise to a level that...

Implement controls to ensure that transactions interfaced from eGrants are reflected in Momentum for the correct amounts, accounts, and number of transactions. (new)

Update CNCS policy to recognize and record capitalized costs in the period incurred. (repeat)

Update CNCS policy to include requirements for compliance with accounting standards; track direct labor and other indirect costs, including hours, worked and payroll costs dedicated to existing and new software-in-development projects; track and amortize...

Consult with the future shared service provider and other stakeholders to determine the feasibility of procuring and using project management software to track project costs from the inception to completion. The results of the analysis should be...

Establish and implement periodic training on capitalization accounting standard, and CNCS Capitalization Policy for accounting, program, Office of Facility Support Services, and information technology staff. (new)

Determine the root cause behind the differences noted in the Undelivered Orders balance between Momentum and the Undelivered Orders balance derived from the net of grant award amount from the Notice of Grant Award and the grant expenditures from the...

Determine the root causes and resolve discrepancies in the grant award amounts recorded in the NGA in eGrants and in Momentum to prevent such differences from occurring in the future. (repeat)

Determine the root causes and resolve expenditure differences between the Payment Management System and Momentum. (repeat)

Strengthen controls around the review of expired grant obligations by ensuring that:

Update the CNCS transaction code posting logic for recording grant expenditures to comply with the United States Standard General Ledger guidance. (repeat)

Establish a requirement for Grant Officer/Portfolio Managers to provided documented certification that all required grantee information has been received, accepted, and documented before the grant is closed out. (repeat)

Establish a control requiring the Grant Officer/Portfolio Manager to provide documented certification, upon grant closeout, verifying the total award amount to total award expenses for the deobligated recovery amount. (repeat)

Inform all Grant Officers/Portfolio Managers to ensure that a reduction in funding to the award of a grant should be documented in eGrants which would result in modified Notice of Grant Awards. (new)

Reconcile the amounts reported in Other Liabilities to supporting documents to verify that Other Liabilities are supported by valid transactions and properly classified. (repeat)

Strengthen financial reporting internal controls and ensure that financial statements accounting line items are reviewed and reconciled to supporting documents prior to recording. The internal control activities should ensure proper posting of Member...

Develop a multi-year strategy to better strategically prioritize and allocate resources to address the new and continuing weaknesses identified and work towards automation, continuous monitoring and consistent application of controls. (repeat)

Enforce the agency-wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities. (repeat)

Strengthen and refine the process for communicating CNCS facility-specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies. (repeat)

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems. (...

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems. (repeat)

Implement all detailed recommendations in the FY 2019 FISMA Evaluation report. (repeat)

Reconcile the Accounts Receivable subsidiary ledger to the general ledger monthly. (repeat)

Reevaluate the policies and procedures for calculating the allowance for doubtful accounts. Related policies and procedures should include:

Revise the Allowance for Doubtful Accounts methodology to be consistent with the Debt Management Policy. (repeat)

Develop a process and proactively monitor and follow-up on delinquent accounts receivables. Document any procedures performed and results reached as part of the follow-up process. (new)

Track and revise collection efforts based on data analysis to understand vendor payment characteristics. A reasonable timeframe for write-offs should be established for accounts receivable without any activity. Once an outstanding receivable is deemed...

Establish a documented process between accounting and the Office of Chief Risk Officer (OCRO) to ensure that key controls related to the Accounts Receivable cycle are properly identified and implemented. These key controls should be considered for...

Develop, implement and document procedures to identify all CNCS grantees that are required to submit single audit reports with their due dates. (new)

Develop, implement and document procedures on timely follow-up for those grantees whose audits have become past due, and to ascertain why report submission was late, when the audit report will be submitted to the Federal Audit Clearinghouse, and what...

Develop a practice to capture the single audit data to assess the effectiveness of the single audit report submission for all its grantees. (new)

Develop, implement and document procedures for implementing Office of Budget and Management (OMB) approved single audit report submission extensions, so that OMB approved extension approvals are documented and tracked as part of the single audit...

Update the Single Audit Resolution Policy to: Reflect the current monitoring process to track all audit findings related to CNCS-funded grants, and   Address CNCS’s responsibilities as the cognizant/oversight agency and how these responsibilities would...

Develop and implement procedures to monitor the effectiveness of the single audit monitoring process in accordance with the Uniform Grant Guidance, 2 Code of Federal Regulation §200.513 Responsibilities, (a) (3) (iv), related to monitoring the...

Perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved. (repeat)

Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to ensure the accounting information is valid and proper;

Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation);

Train, mentor, and work to retain qualified employees;

Document and maintain support for all prior period adjustments and changes to Net Position accounts, Cumulative Result of Operations, and Unexpended Appropriations. (repeat)

Implement a peer review process to carry out the necessary quality control reviews of the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

Determining and maintaining relevant documentation to support each SV/JV;

Appropriate use of SVs/JVs;

Detailed process to research significant balance fluctuations. CNCS should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.

Review and ensure the reasonableness of assumptions used and document the rationale behind estimation assumptions.

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Timely review and approval of SVs/JVs for accuracy and propriety. (modified repeat)

Address all balance differences and retain supporting documentation of related research.

Conduct detailed analysis and validation of data sources.

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors.

The process to determine and document CNCS’s balance fluctuation expectations. Expectations should be documented based on a combination of internal and external operating factors, and program and financial relevant information available.

Tracking the sequence of SVs/JVs for completeness;

Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

Cross-train employees so that knowledge of the model will reside with multiple staff rather than with one person; and

Address fatal and non-fatal Government-wide Treasury Account Symbol Trial Balance edit failures.

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.

Use of specific and accurate SV/JV descriptions; and

Develop comprehensive policies and procedures for the financial statements preparation process and related internal controls. The policies and procedures should address, among other subjects:

Monitor outstanding balances resulting from financial system configuration issues and fix these issues prior to data migration to the future shared service provider (Department of Treasury’s Administrative Resource Center) in FY 2021. While waiting to...

Coordinate with the future shared service provider to ensure that its accounting platform is compatible with CNCS’s operations and the type of accounting transactions that the CNCS process. (new)

Develop a plan to clean up CNCS’s balances prior to migration to the shared service provider’s system (Department of Treasury’s Administrative Resource Center). The plan should include coordination with the future service provider to review CNCS...

Validate and ensure standard vouchers/journal vouchers are properly supported, documented, and are readily available for examination. (modified repeat)

Strengthen coordination between Accounting and Financial Management Services and the Office of Budget to ensure that transactions are recorded accurately and timely. (modified repeat)

Develop and implement policies and procedures for the standard vouchers/journal vouchers (SV/JV) process that include:

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including establishing control activities; finalize materiality thresholds...

Develop for a more standardized, secure, and automated method to estimate the Trust obligations and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing CNCS’s transition to shared service, coordinate with the service...

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

Document and implement policies and procedures to include the following:

Develop a multi-year strategy to better strategically prioritize and allocate resources to address the new and continuing weaknesses identified and work towards automation, continuous monitoring and consistent application of controls. (repeat)

Enforce the agency-wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities. (repeat)

Develop, implement and document procedures to identify all CNCS grantees that are required to submit single audit reports with their due dates. (new)

Develop, implement and document procedures on timely follow-up for those grantees whose audits have become past due, and to ascertain why report submission was late, when the audit report will be submitted to the Federal Audit Clearinghouse, and what...

Develop a practice to capture the single audit data to assess the effectiveness of the single audit report submission for all its grantees. (new)

Replacement of information system components when support for the components is no longer available from the developer, vendor or manufacturer.

Implement a process to track patching of network devices and servers by the defined risk-based patch timelines in CNCS policy.

Monitor and record actions taken by the contractor to ensure vulnerability remediation for network devices and servers is addressed or the exposure to unpatchable vulnerabilities is minimized.

Ensure that OIT monitors and promptly installs patches and antivirus updates across the enterprise when they are available from the vendor. Enhancements should include:

Pending since FY 2017

Ensure that OIT evaluates if the internet connections at the National Civilian Community Corps Campuses and Regional Offices are sufficient to allow patches to be deployed to all devices within the defined risk-based patch timeline in CNCS policy. If...

Develop and implement a written process to ensure manual updates to the CMDB inventory and FasseTrack system are made simultaneously when the inventory is updated.

Perform and document analysis to determine the feasibility of completely automating the inventory management process.

Physically or mechanically disable the networking capability of the laptop used for member badging at the NCCC Pacific Region Campus.

Document and implement a process to validate that physical counselor files from the NCCC Southwest Region Campus are disposed of within six years after the date of the member’s graduation in accordance with the AmeriCorps NCCC Manual.

Disallow and recover $310,316 ($47,220 in Federal and $263,096 in match cost) for contract costs claimed for Search Institute, the Mentoring Partnership of Minnesota, and the Minnesota Department of Employment Economic Development from July 2016 through...

Recover additional costs expended during program years 4 and 5 on contracts for Search Institute, the Mentoring Partnership of Minnesota, and the Minnesota Department of Employment Economic Development due to noncompliance with Federal procurement...

Disallow and recover $11,335 ($2,271 in Federal and $9,064 in match costs) for unapproved timesheets and incorrectly coded salaries.

Disallow and recover $3,059 in Federal cost for the employees' salaries and benefits for noncompliance with maintaining proper documentation of criminal history checks.

Require Youthprise to strengthen its timekeeping policies and train employees to ensure time is accurately recorded, approved, and charged to the correct funding code.

Disallow and recover $603,476 ($231,806 in Federal and $371,861 in match costs) from Sauk-Rapid Rice due to the lack of support for employee's time worked on the grant and $3,192 for other Federal costs claimed because of insufficient match...

Require Youthprise to strengthen its timekeeping policies and train employees to ensure time is accurately recorded, approved, and charged to the correct funding code.

Require Youthprise design and implement internal controls to ensure that employee personnel files comply with CNCS's criminal history check requirements.

Disallow and recover $603,476 ($231,806 in Federal and $374,861 in match costs) from Sauk-Rapids Rice due to the lack of support for employee's time worked on the grant and $3,192 for other Federal costs claimed because of insufficient match...

Disallow and recover $11,681 ($5,681 in Federal from Amherst H. Wilder, and $6,000 in match from Sauk-Rapids Rice) due to unsupported costs in its financial management systems

Specify how quickly users must apply security and operating system updates on AmeriCorps mobile devices, and implement a process to deny access to AmeriCorps enterprise services for mobile devices that have not been updated within the prescribed period...

Complete the process of configuring the scanning tool to account for the approved deviations for the standard baseline configurations.

Ensure all personnel whose responsibilities include access to PII complete annual privacy-role based training.

Disallow the $592,737 in questioned match costs to recover the $254,014 in Federal costs from LearningWorks for the program years 2017 and 2018 due to inadequate documentation to support its in-kind match contributions: donated classroom and office space...

Conduct an assessment of LearningWorks’ match contribution for its third-year funding to determine whether it met its match requirement, disallow any unsupported match contributions and recover any Federal funds that were overpaid as a result of...

Oversee the Maine Commission when coordinating with LearningWorks to revise its policies to define supporting documentation for the usage and valuation of donated spaces for in-kind contributions;

Instruct the Maine Commission to evaluate compliance of LearningWorks procedures on internal controls for time recordkeeping for donated personnel time at its service sites to provide reasonable assurance that charges are accurate, allowable, and...

Provide training to the Maine Commission staff and offer training to LearningWorks and other subgrantees concerning acceptable valuation and documentation of in-kind match costs.

Require the Maine Commission to develop and implement oversight or quality control of all fiscal monitoring performed by its staff.

Coordinate with the Maine Commission to develop guidance explaining and illustrating what constitutes acceptable documentation to support in-kind contributions;

Conduct an assessment of LearningWorks’ match contribution for its third-year funding to determine whether it met its match requirement, disallow any unsupported match contributions and recover any Federal funds that were overpaid as a result of...

Oversee the Maine Commission when coordinating with LearningWorks to revise its policies to define supporting documentation for the usage and valuation of donated spaces for in-kind contributions;

Instruct the Maine Commission to evaluate compliance of LearningWorks procedures on internal controls for time recordkeeping for donated personnel time at its service sites to provide reasonable assurance that charges are accurate, allowable, and...

Provide training to the Maine Commission staff and offer training to LearningWorks and other subgrantees concerning acceptable valuation and documentation of in-kind match costs.

Require the Maine Commission to develop and implement oversight or quality control of all fiscal monitoring performed by its staff.

Coordinate with the Maine Commission to develop guidance explaining and illustrating what constitutes acceptable documentation to support in-kind contributions;

Detailed process to research signification balance fluctuations. AmeriCorps should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.

esearch and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.

Strengthen its policies and procedures over the processing of JEs going forward now that AmeriCorps has transitioned to the shared service environment. The policies and procedures should cover the following:

Address fatal and non-fatal Government-wide Treasury Account Symbol edit failures prior to GTAS certification.

A requirement to provide a fact-specific description of the purpose of the JE, along with adequate supporting documentation.

Document resolution for all balance differences and retain supporting documentation of related research.

A policy as to when it is appropriate to use a JE and approval procedures for JEs recorded to ensure segregation of duties

A requirement to provide a fact-specific description of the purpose of the JE, along with adequate supporting documentation.

The process to determine and document AmeriCorps’ balance fluctuation expectations based on a combination of internal and external operating factors, and program and financial relevant information available.

Perform a risk assessment over the current state of the conversion to ARC and work jointly with ARC, senior leadership, Office of Chief Risk Officer, and functional groups affected by the risk to develop a mitigation strategy and execute a realistic and...

Fix incorrect outstanding balances and missing data resulting from financial system configuration issues and ensure future interfaces with Oracle do not have the same issues. (Modified Repeat)

Continue coordinating with ARC to ensure that its accounting platform is compatible with AmeriCorps’ operations and the type of accounting transactions that AmeriCorps processes. (Modified Repeat)

Conduct a review of transactions processed in Momentum and already migrated to Oracle through interface or reported in Oracle using journal entries, to ensure that correct object class codes were applied. (New)

Establish controls and training to ensure that each functional office/unit performs independent assessment of internal controls to inform the CEO’s statement of assurance, even if unfavorable outcomes are expected. This proactive approach will promote...

Develop and implement audit readiness procedures to ensure that audit information is complete, accurate, has undergone proper quality control procedures, and readily available or can be retrieved timely. The audit readiness procedures should include...

Develop comprehensive policies and procedures to document its financial statement preparation process. The policies and procedures should clearly delineate responsibilities among various members of the Accounting and Financial Management Service (AFMS)...

Continue working with Administrative Resource Center to review and correct AmeriCorps’ balances in detail to ensure they are properly supported and that balances migrated to the ARC platform are complete, accurate, and reliable. (Modified Repeat)

Strengthen its policies and procedures over the processing of JEs going forward now that AmeriCorps has transitioned to the shared service environment. The policies and procedures should cover the following:

Validate and ensure JEs are properly supported, documented, and are readily available for examination. (Modified Repeat)

Address fatal and non-fatal Government-wide Treasury Account Symbol edit failures prior to GTAS certification.

A policy as to when it is appropriate to use a JE and approval procedures for JEs recorded to ensure segregation of duties.

Document resolution for all balance differences and retain supporting documentation of related research.

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.

Detailed process to research significant balance fluctuations. AmeriCorps should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.

The process to determine and document AmeriCorps’ balance fluctuation expectations based on a combination of internal and external operating factors, and program and financial relevant information available.

Documentation needed to support JEs and how it will be maintained. (Modified Repeat).

A requirement to provide a fact-specific description of the purpose of the JE, along with adequate supporting documentation.

A process to track the sequence of JE transactions for completeness.

Perform a risk assessment over the current state of the conversion to ARC and work jointly with ARC, senior leadership, Office of Chief Risk Officer, and functional groups affected by the risk to develop a mitigation strategy and execute a realistic and...

Fix incorrect outstanding balances, missing data, and missing supporting contract documentation resulting from financial system configuration issues and ensure future
interfaces with Oracle do not have the same issues. (Modified Repeat).

Continue coordinating with ARC to ensure that its accounting platform is compatible with AmeriCorps’ operations and the type of accounting transactions that AmeriCorps processes. (Modified Repeat).

Conduct a review of transactions processed in Momentum and already migrated to Oracle through interface or reported in Oracle using journal entries, to ensure that correct object class codes were applied. (New)

Establish controls and training to ensure that each functional office/unit performs an independent assessment of internal controlsto inform the CEO’s statement of assurance, even if unfavorable outcomes are expected. This proactive approach will promote...

Develop and implement audit readiness procedures to ensure that audit information is complete, accurate, has undergone proper quality control procedures, and readily available or can be retrieved timely. The audit readiness procedures should include...

Develop comprehensive policies and procedures to document its financial statement preparation process. The policies and procedures should clearly delineate responsibilities among various members of the Accounting and Financial Management Service (AFMS)...

Continue working with Administrative Resource Center to review and correct AmeriCorps’ balances in detail to ensure they are properly supported and that balances migrated to the ARC platform are complete, accurate, and reliable. (Modified Repeat)

Strengthen its policies and procedures over the processing of JEs going forward now that AmeriCorps has transitioned to the shared service environment. The policies and procedures should cover the following:

Validate and ensure JEs are properly supported, documented, and are readily available for examination. (Modified Repeat)

Validate that the underlying data used in the accrual methodology, such as the use of grantee Undelivered Order balances to allocate accrual amounts, is reliable by ensuring previously reported conditions are remediated and recommendations are...

Design and implement an effective accountability system that includes clear expectations of goals, performance measures, estimated target dates, and monitoring to hold OIT leadership accountable for improving AmeriCorps’ information security program to...

Develop, document, and communicate an overall SCRM strategy, implementation plan, and related policies and procedures to guide and govern supply chain risk management activities. If AmeriCorps intends to limit its IT purchases to GSA vendors, it should...

Develop and implement a plan to modify external emails to include information to assist the recipient of the level of risk posed by external email. For example, the Subject line of an email should be modified to identify the source of the email as...

Implement a plan to increase the frequency of behaviortraining directed at the identification of unwanted spam emails with an emphasis on continual reminders of recognition techniques, appropriate actions, and confidence that self‐reporting poor...

Implement a process to improve the detection rate to reduce the occurrence of email spam that reaches the users’ inboxes.

Develop an oversight mechanism to retain receipts and monthly reconciliations to ensure record retention. (Finding 1)

Develop an oversight mechanism to hold cardholders and Approving Officials accountable for timely completion and approval of monthly statement reconciliation and consider disciplinary actions for repeat offenders. (Finding 1)

Revise purchase request and approval controls to implement a mechanism to hold cardholders accountable to obtain Approving Official’s approval prior to making purchases. (Finding 2)

Verify purchase transactions were for allowable expenses and consider remediation action of any unallowable or unauthorized charges. (Findings 2 and 3)

Develop and document a mechanism to hold the Agency Program Coordinator accountable for proper oversight of the overall purchase card program including periodic review of the supporting documentations, certificates of training, monthly reconciliation,...

Provide training for Approving Officials to ensure proper retention of required supporting documentations such as the evidence of cardholder’s reconciliation of statements, Approving Official’s approval of the statement, signed purchase request forms,...

Implement a mechanism to hold travelers accountable to obtain travel approval prior to travel dates. (Finding 5)

Verify travel card transactions were for allowable expenses and consider remediation action of any unallowable or unauthorized charges. (Findings 5 and 7)

Develop an oversight mechanism to enforce its controls record retention of travel receipts and timely submission of travel authorizations and vouchers in accordance with Federal Travel Regulation and AmeriCorps policies and procedures. (Finding 5 and 6)

Research and verify that the travels were for official business purposes and maintain proper documentations to support the travel related charges. (Finding 7)

Develop and document a monitoring control to ensure Centrally Billed Accounts (CBA) Citibank statements are properly reconciled prior to payment submission. (Finding 8)

Implement a mechanism to hold Office of Human Capital accountable for timely notification of employee termination to the Agency Program Coordinator upon completion of exit form. (Finding 9)

Coordinate with Treasury Administrative Resource Center to timely disable the terminated employee’s account and identify root cause for accounts that are not closed timely. (Finding 9)

Follow up on the 36 separated cardholder accounts to verify no charges were made after employee separation date. (Finding 9)

Perform a root cause analysis of the untimely account closeout and develop remediation plan as appropriate. (Finding 9)

AmeriCorps enhance its process of performing enterprise risk management assessments to determine the respective risk posture of its systems to include the entity-wide performance metrics for measuring the effectiveness of its:
• Data exfiltration and...