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Agency Reviewed
Any Open Recommendations
Reports
Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Ensure Water Quality in GSA-Controlled Facilities
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by defining roles and responsibilities for maintaining water quality in GSA-controlled facilities.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that: water quality is maintained through consistent policies and practices nationwide; deviations to PBS’s Drinking Water Quality Management policy and the PBS water safety guidance are approved by PBS’s Central Office; and any water safety policies or guidance developed by regional offices do not contradict policies and guidance issued at the national level.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that PBS’s water safety activities are incorporated into O&M contracts, recorded in PBS’s National Computerized Maintenance Management System, and overseen by PBS personnel.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by incorporating PBS’s water safety oversight responsibilities into quality assurance surveillance plans for O&M contracts to ensure contractor compliance with water safety activities.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that PBS personnel and O&M contractors have access to tenant spaces so flushing can be performed.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by amending O&M and other contracts to ensure that energy efficiency and water conservation requirements do not conflict with PBS’s Drinking Water Quality Management policy and the PBS water safety guidance.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that water is tested in GSA’s child care centers as required by PBS’s Drinking Water Quality Management policy.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring water quality test results—especially those above EPA action levels—are communicated timely to building tenants, GSA child care center operators, and parents and guardians of affected children.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by amending and implementing PBS’s Drinking Water Quality Management policy to: include reduced occupancy or decreased water usage as additional criteria for lead, copper, Legionella bacteria, and other contaminant testing; ensure requirements in PBS’s Drinking Water Quality Management policy, its companion Desk Guide for Drinking Water Quality Management, and the PBS water safety guidance are incorporated into the amended policy, unless there are safety reasons why such requirements cannot or should not be incorporated; and formalize its requirement to complete additional testing at child care centers that close for extended periods of time.
Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Meet the Ventilation and Acceptable Indoor Air Quality Standard in GSA-Owned Buildings
We recommend that the PBS Commissioner complete a comprehensive assessment to determine whether GSA-owned building air handlers meet the ASHRAE ventilation standard’s minimum outdoor air requirements and develop a comprehensive plan to address deficiencies identified.
We recommend that the PBS Commissioner create and implement a plan to notify building occupants whenever deficiencies and hazards associated with outdoor air requirements are identified.
We recommend that the PBS Commissioner ensure that all PBS staff with ventilation system responsibilities, including contracting officer’s representatives, contracting officers, project managers, and building managers, are trained on the requirements of the ASHRAE ventilation standard.
We recommend that the PBS Commissioner ensure operations and maintenance contracts define requirements for regular testing, adjusting, and balancing of air handlers.
We recommend that the PBS Commissioner ensure that GSA’s Guidance for COVID-19 HVAC Operations adheres to CDC COVID-19 guidance for improved building ventilation.
COVID-19: PBS Faces Challenges in Its Efforts to Improve Air Filtration in GSA-Controlled Facilities
We recommend that the PBS Commissioner for GSA-owned facilities: a. Conduct an accurate and complete assessment of HVAC systems to identify deficiencies in air filtration. Based upon the assessment, PBS should maximize central air filtration in existing HVAC systems without significantly reducing design airflow; b. Review and update current and future operations and maintenance contracts to ensure that they clearly identify the required MERV air filters and preventive maintenance schedules; c. Establish controls to ensure that PBS obtains and maintains complete preventive maintenance records; and d. Ensure that contracting officer representatives conduct inspections of mechanical rooms and preventive maintenance records to ensure that air filters meet MERV requirements.
We recommend that the PBS Commissioner for GSA-leased space: a. Review and update current and future lease agreements to ensure that they clearly identify the required MERV air filters and preventive maintenance schedules; b. Ensure that lessors maintain and provide required preventive maintenance records and provide timely access to mechanical rooms; and c. Ensure that PBS representatives inspect mechanical rooms and preventive maintenance records to ensure that air filters meet MERV requirements.
PBS Did Not Always Follow CDC and Internal Guidance to Limit the Risk of COVID-19 Exposure
Issue timely notification of all COVID-19 incidents in GSA-controlled facilities to all occupant agencies, contractors, and visitors. In addition, take steps to maximize awareness of COVID-19 incidents in GSA-controlled facilities.
Ensure that tenant agencies are aware of the requirement to immediately notify PBS of COVID-19 incidents.
Ensure that Scope 3 – COVID-19 Cleaning is followed whenever a COVID-19 incident occurs in a GSA-controlled facility.
Ensure inspection procedures and guidance are clear, concise, and include appropriate processes to conduct and document inspections for Scope 3 – COVID-19 Cleaning. Also, ensure that inspection requirements are communicated to staff.
Implement quality assurance procedures that ensure PBS’s consistent oversight of the delivery of safe, efficient, and effective custodial services.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Michigan
Direct UM to provide documentation supporting that it has repaid or otherwise credited the $11,499 of questioned participant support costs for which it has agreed to reimburse NSF.
Direct UM to establish clear guidance regarding the rebudgeting of participant support cost funding. This guidance should address when and how to request approval to rebudget participant support cost funding, as well as how to document the approval.
Direct UM to update its current award set-up practices to require that, when setting up accounts established for NSF awards and/or funding supplements, personnel ensure that the accounts apply indirect costs using the rate(s) that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF award, rather than using the rate(s) included in the original Notice of Award.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Central Florida
Direct UCF to provide documentation supporting that it has repaid or otherwise credited the $134 in questioned fringe benefit costs for which it has agreed to reimburse NSF.
Direct UCF to notify its Federal sponsors that its personnel have not yet certified their effort for the Fall 2019, Spring 2020, Summer 2020, and Fall 2020 semesters.
Direct UCF to require its employees to certify their effort for the Fall 2019, Spring 2020, Summer 2020, and Fall 2020 semesters and then process any cost transfers needed to ensure that UCF charged NSF for salary costs that were consistent with the effort certified.
Direct UCF to review all salary earned during June 2020 to verify that its accounting system appropriately applied fringe benefits at the correct rate and, if the accounting system did not apply fringe benefits at the correct rate, process any adjustments necessary.
Direct UCF to provide documentation supporting that it has repaid or otherwise credited the $160 of questioned participant support costs for which it has agreed to reimburse NSF.
Direct UCF to establish policies and procedures to ensure that it obtains and documents proper approval for insurance costs before charging the costs to NSF awards.
Direct UCF to establish policies and procedures to ensure that it does not apply fringe benefit rates to participant support costs that it processes through its payroll subledger.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – California Institute of Technology
Resolve the $16,351 in questioned salary expenses for which Caltech has not agreed to reimburse NSF and direct Caltech to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $418 of questioned salary expenses for which it has agreed to reimburse NSF.
Direct Caltech to strengthen its policies and procedures by retroactively establishing expiration dates on its use of the Other Paid Leave Pool on Federal awards and ensuring that these expiration dates align with the expiration dates and criteria specific to Flexibility 6 of Office of Management and Budget Memorandum M-20-17.
Resolve the $31,856 in questioned subaward expenses for which Caltech has not agreed to reimburse NSF and direct Caltech to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct Caltech to strengthen its internal control processes and procedures surrounding the transfer of significant portions of NSF-funded research to other organizations. Updated processes could include: a. Establishing procedures to verify whether the scope of work for a proposed subcontract on an NSF award is programmatic in nature before issuing the subcontract. If the scope of work is programmatic in nature, Caltech should obtain the NSF Grants Officer’s approval before issuing the subcontract. Caltech could obtain this approval either as part of the initial NSF grant proposal/budget or through a formal request to transfer the research or effort, submitted through NSF’s FastLane system. b. Requiring periodic training for Caltech personnel that are permitted to subaward, issue, or subcontract out research under NSF awards, to ensure that they request the appropriate approvals. c. Establishing procedures to confirm that Caltech personnel perform pass-through entity risk assessments to identify the appropriate monitoring procedures when Caltech awards NSF research to a pass-through entity. d. Establishing periodic monitoring procedures to ensure that Caltech appropriately assesses indirect costs on the first $25,000 invoiced by each subawardee.
Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $1,515 of questioned indirect costs for which it has agreed to reimburse NSF.
Direct Caltech to strengthen its monitoring procedures and internal control processes for applying indirect costs to Federal awards. Updated procedures could include: a. Requiring that personnel review rental expenses charged to NSF awards to assess whether the expenses included indirect costs. Specifically, Caltech should ensure the general ledger account codes it establishes to account for equipment rental charges do not apply indirect costs. b. Requiring that personnel review capitalized expenses charged to an NSF award to ensure that the capitalized amount includes all applicable costs.
Direct Caltech to quantify the total indirect costs inappropriately applied to NSF awards as a result of its rental equipment account inappropriately applying indirect costs and to reimburse NSF for the appropriate amount.
Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $581 of questioned salary and fringe costs for which it has agreed to reimburse NSF.
Direct Caltech to strengthen its administrative and management controls and processes surrounding the charging of salary to Intergovernmental Personnel Act awards. Updated processes could include requiring departmental payroll personnel to perform additional procedures to ensure that Caltech appropriately established initial salary payments, including verifying that all payments are within the Intergovernmental Personnel Act assignment dates.
Direct Caltech to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using either the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award or the rates identified in the NSF award letters, as appropriate.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities - University of Wisconsin - Madison
Resolve the $26,974 in questioned Award Cash Management $ervice drawdowns for which UW-Madison has not agreed to reimburse NSF and direct UW-Madison to repay or otherwise remove the sustained questioned drawdowns from its NSF awards.
Direct UW-Madison to provide documentation supporting that it has repaid or otherwise credited the $20,431 of questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.
Direct UW-Madison to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice procedures for awards with expiring appropriations. Updated processes could include validating that UW-Madison adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.
Direct UW-Madison to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.
Direct UW-Madison to provide documentation supporting that it has repaid or otherwise credited the $1,593 in questioned costs for which it has agreed to reimburse NSF.
Direct UW-Madison to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice system to ensure that UW-Madison appropriately incorporates credits when calculating the total amount to draw down from, or return to, NSF.
Direct UW-Madison to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct UW-Madison to strengthen its Research Experience for Undergraduate award setup procedures to ensure that personnel select the appropriate indirect cost base.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities - Florida State University
Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $4,808 of questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.
Direct FSU to update its administrative and management processes and internal control procedures for awards with expiring appropriations. Updated processes could include: a. Validating that FSU adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs. b. Ensuring that FSU’s system prohibits personnel from posting costs to an award after the award’s appropriation expires.
Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $3,648 in questioned publication and other direct costs for which it has agreed to reimburse NSF.
Direct FSU to establish clear guidance regarding the allowability of publication expenses, including the need to acknowledge NSF funding sources.
Direct FSU to strengthen its grant closeout procedures to ensure that it reimburses NSF for any expenses that it determines did not benefit the NSF award(s) charged. Additional procedures should ensure that FSU refunds the NSF award(s) for any materials and supplies that it was unable to use before the award’s period of performance expired.
Direct FSU to implement additional controls to prevent personnel from directly charging NSF awards for costs charged to accounts established to accumulate expenses that are not typically allowed on Federal awards, such as credit/debit fees, unless the personnel obtain specific prior approval.
Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $567 of questioned indirect costs for which it has agreed to reimburse NSF.
Direct FSU to strengthen its administrative and management processes and internal controls for applying indirect costs to Federal awards. Updated procedures could include implementing an annual review of other direct costs charged to sponsored awards that include funding for participant support costs to ensure that FSU is appropriately segregating other direct costs incurred on behalf of participants in accounts to which it does not apply indirect costs.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – Florida International University
Resolve the $1,252 in questioned Award Cash Management $ervice drawdowns for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $14,167 of questioned costs for which it has agreed to reimburse NSF.
Direct FIU to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes should ensure FIU appropriately documents how it calculates the final draw amounts for awards with expiring appropriations, to ensure it only uses the draws to cover costs incurred before the appropriation expired.
Direct FIU to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.
Resolve the $791 in questioned fringe benefit costs for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $5,934 of questioned promotional and salary costs for which it has agreed to reimburse NSF.
Direct FIU to establish clear guidance regarding the <span class="tx-tooltip" tabindex="0">
allowable uses
<span class="tx-tooltip-text">
<span class="cf0">An allowable use is any expenditure on which an entity can spend funding.</span>
</span>
</span>
of participant support cost funding. This guidance should address: a. Allowable uses of participant support cost funding. b. How to verify personnel did not apply fringe benefit rates to participant stipends or other non-salary expenses.
Direct FIU to strengthen its monitoring procedures surrounding costs charged to its NSF Research Experiences for Undergraduates programs. Updated procedures should ensure FIU charges costs associated with promotional and/or other unallowable items to nonFederal funding sources.
Direct FIU to update its current practices to ensure it only applies fringe benefits using fringe benefit rates that have been approved by its cognizant audit agency.