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Open Recommendations


Election Assistance Commission Policy Review

  • Recommendation #2

    Enhance the records management system to document EAC's decisions, operations, policies, procedures, and practices.



Audit of the Help America Vote Act Grants Awarded to the State of Delaware

  • Recommendation #3

    We recommend the EAC require the Office to provide the inventory listing maintained by the IT Department and each County.


  • Recommendation #6

    We recommend that the EAC require the Office to provide transaction detail of interest income earned for the Election Security and CARES Act grants.


  • Recommendation #7

    We recommend that the EAC require the Office to complete and file FFRs for the Section 251 funds or if the Office is unable to complete the Section 251 FFR, obtain financial services to support the completion of the filings.



Audit of the U.S. Election Assistance Commission's Compliance with the Federal Information Security Modernization Act for Fiscal Year 2022

  • Recommendation #2

    We recommend EAC OCIO develop and implement a flaw remediation plan for vulnerabilities that cannot be remediated within the policy recommended timeframes.



Audit of the Help America Vote Act Grants Awarded to the Commonwealth of the Northern Mariana Islands

  • Recommendation #1

    Determine the allowability of $246,556 in questioned costs ($242,982 unsupported; $3,574 ineligible) under Election Security Award MP20101001 and recover any amount that is unallowable.


  • Recommendation #2

    Determine the allowability of $440,905 in questioned costs ($327,085 unsupported; $113,820 ineligible) under CARES Act Award MP20101CARES and recover any amount that is unallowable.


  • Recommendation #4

    Determine the best course of action to identify and recover additional funds from Election Security Award MP20101001 and CARES Act Award MP20101CARES that remain unspent or improperly spent.



Audit of the U.S. Election Assistance Commission's Testing and Certification Program

  • Recommendation #1

    Establish regular coordination with NIST and review the accreditation procedures for voting system test labs to reduce potential areas of duplication or identify efficiencies.


  • Recommendation #2

    Develop policies to ensure periodic meetings with voting system test laboratories and voting system manufacturers occur and the non-sensitive meeting minutes are published.


  • Recommendation #5

    Update the records disposition schedule for the testing and certification program.


  • Recommendation #6

    Utilize federal guidance to conduct a staffing assessment for the testing and certification program. As part of this, consider what technical competencies are required for the team and if any are already covered with the NIST review.


  • Recommendation #7

    Identify, measure, and assess risks related to its testing and certification program, ideally as part of a broader enterprise risk management program.



Audit of the U.S. Election Assistance Commission's Compliance with the Federal Information Security Modernization Act for Fiscal Year 2023

  • Recommendation #1

    We recommend EAC OCIO resolve conflicting baseline configuration settings for Windows 10 devices and ensure iPhones meet the agency’s configuration setting requirements.


  • Recommendation #2

    We recommend EAC OCIO ensure information systems meet STIGs secure configuration settings as required by the agency’s policy.


  • Recommendation #3

    We recommend EAC OCIO update its hardware inventory system to include the level of detail needed to manage devices according to Federal requirements and document management’s oversight and review.


  • Recommendation #4

    We recommend EAC OCIO update its POA&M procedures and, in coordination with management, develop and maintain POA&M reports based on Federal requirements.


  • Recommendation #5

    We recommend EAC OCIO update the agency’s SSP document to align with NIST requirements and include the network environment's current state.


  • Recommendation #6

    We recommend EAC OCIO fully implement its GRC solution to manage and monitor cybersecurity risk activities required by NIST SP 800-39 and provide a centralized enterprise-wide view of all risk across the agency.



Audit of the Help America Vote Act Grants Awarded to the State of Missouri

  • Recommendation #1

    We recommend that the EAC require the Office to return the non-match portion of the $3,703 to the EAC for the unallowable CARES Act grant expenditures noted.


  • Recommendation #2

    We recommend that the EAC require the Office to implement procedures and training to ensure that subawards are adequately monitored.


  • Recommendation #3

    We recommend that the EAC require the Office to implement procedures to ensure that all subrecipients are properly monitored in accordance with Federal statutes and the terms and conditions of the subaward.


  • Recommendation #4

    We recommend that the EAC require the Office to ensure all property purchased with Federal funds is placed on a compliant property record.


  • Recommendation #5

    We recommend that the EAC require the Office to provide sufficient supporting documentation to demonstrate that interest was earned on the HAVA funds from the date of deposit to the date of close-out for each HAVA grant.


  • Recommendation #6

    We recommend that the EAC require the Office to provide sufficient supporting documentation to demonstrate that all interest income earned on the HAVA funds was deposited into the election fund.


  • Recommendation #7

    We recommend that EAC require the Office to implement procedures to ensure Federal expenditures are accurately identified in the Schedule of Expenditures of Federal Awards going forward.



Audit of the Help America Vote Act Grants Awarded to the Territory of Guam

  • Recommendation #1

    We recommend that the EAC require the Office to implement procedures to ensure federal expenditures are accounted for in the AS400 accounting system and in accordance with procedures in place for the accounting of local appropriations.


  • Recommendation #2

    We recommend that the EAC require the Office to return $30,991 to the EAC for the unallowable and unsupported CARES Act grant expenditures noted.


  • Recommendation #3

    We recommend that the EAC require the Office to Implement procedures and training to ensure adequate documentation is maintained to support the allowability of expenditures charged to the HAVA grants.


  • Recommendation #4

    We recommend that the EAC require the Office to implement procedures to ensure federal expenditures are accurately identified in the Schedule of Expenditures of Federal Awards going forward.


  • Recommendation #5

    We recommend that the EAC require the Office to implement procedures and training to ensure required Federal Financial Reports are timely filed.



Management Letter Report Related to the Audit of the U.S. Election Assistance Commission's Financial Statements for Fiscal Year 2023

  • Recommendation #1

    Perform thorough routine reviews of Official Personnel Files to ensure the following:
    (1) All relevant employee benefit election forms are appropriately documented and retained.
    (2) The information processed on the Notification of Personnel Action (SF-50) agrees to the originating Request for Personnel Action (SF-52) form.
    (3) The Notification of Personnel Action (SF-50) is appropriately authorized, evidenced by an electronic signature in Box 50.
    (4) The appropriate Request for Personal Action (SF-52) and Notification of Personnel Action (SF-50) forms are complete.
    (5) The appropriate Request for Personal Action (SF-52) and Notification of Personnel Action (SF-50) forms are retained.
    (6) Overall Official Personnel Files are complete and accurate.


  • Recommendation #2

    Utilize an internal shared folder to store documentation so that it is readily available for authorized EAC personnel to access.


  • Recommendation #3

    Implement appropriate segregation of duties so that no one individual or team controls custody of documentation to support transactions.


  • Recommendation #4

    Perform periodic reviews of records to ensure that all relevant documentation is appropriately stored and accessible.


  • Recommendation #5

    Provide BFS with all necessary documentation to support transactions recorded in the financial system. Ensure that copies are maintained by BFS in addition to EAC.


  • Recommendation #6

    Review and maintain documentation processed and stored by GSA, to ensure that EAC can access relevant information when necessary.


  • Recommendation #7

    Document policies and procedures for the maintenance and retrieval of documentation, including the responsibilities of EAC personnel and the responsibilities of EAC’s service providers.



Audit of the U.S. Election Assistance Commission's Financial Statements for Fiscal Year 2023

  • Recommendation #1

    Utilize a contracting officer(s), such as their designated service provider, to enter into all new contracts on behalf of the EAC.


  • Recommendation #2

    Review all current open obligations and identify all contracts entered into without proper authorization and have the EAC and/or service provider contracting officer ratify the contracts. Ensure that the authorization is properly documented.


  • Recommendation #3

    Ensure that all signed contracts are appropriately retained by EAC and or their service provider.



Audit of the Help America Vote Act Grants Awarded to the Territory of American Samoa

  • Recommendation #1

    We recommend that the EAC require the Office to return $77,074 to the EAC for CARES expenditures outside of the budget period.


  • Recommendation #2

    We recommend that the EAC require the Office to transfer to the Election Security election fund $130,945 for the unsupported non-payroll expenditures and $18,673 and associated fringe benefits for the unsupported payroll expenditures.


  • Recommendation #3

    We recommend that the EAC require the Office to return $8,811 and associated fringe benefits to the EAC for the unsupported CARES Act payroll expenditures.


  • Recommendation #4

    We recommend that the EAC require the Office to implement procedures and training to ensure adequate documentation is maintained to support the allowability of expenditures charged to the HAVA grants.


  • Recommendation #5

    We recommend that the EAC require the Office to implement procedures to ensure interest is earned on any election funds received going forward.


  • Recommendation #6

    We recommend that the EAC address and resolve the following recommendation that the Office perform a reconciliation of the grant activity for the Election Security grant through March 31, 2022 to ensure that all expenditures are fully disclosed and reconcile into the fund balance.


  • Recommendation #7

    We recommend that the EAC address and resolve the following recommendation that the Office prepare and submit revised financial reports to the EAC for Election Security activities as of March 31, 2022.


  • Recommendation #8

    We recommend that the EAC address and resolve the following recommendation that the Office implement procedures and training to ensure proper reporting of HAVA grant activity on future financial reports.


  • Recommendation #9

    We recommend that the EAC require the Office to implement a policy to ensure amounts reported on the Territory-wide SEFA are properly identified by ALN title and number in compliance with Uniform Guidance.


  • Recommendation #10

    We recommend that the EAC require the Office to implement a policy to ensure property purchased with federal funds is used, managed, and disposed in accordance with the Office’s procedures.


  • Recommendation #11

    We recommend that the EAC require the Office to ensure all property purchased with Federal funds is placed on a compliant property record.



Audit of EAC's Internal Procurements

  • Recommendation #2

    Separate the head of procurement position from human resources and administration and fill the position with an individual who has the appropriate knowledge, skills, and experience for the role, if EAC determines that they will continue the practice of executing procurements internally.


  • Recommendation #3

    Perform a risk assessment of all nonexpired internal procurements and determine which, if any, should be re-awarded using competitive procedures.


  • Recommendation #4

    Update the EAC Procurement Handbook to reflect current requirements in the Federal Acquisition Regulation.


  • Recommendation #5

    For EAC program offices that routinely contract for goods or services, designate one or more contracting officer’s representatives, and provide training to them that meets the requirements set forth by the Office of Federal Procurement Policy.


  • Recommendation #6

    Issue letters of delegation to contracting officer’s representatives assigned to work on all nonexpired internal contracts.


  • Recommendation #7

    For each nonexpired internal contract that names a former employee as the alternate contracting officer’s representative, modify the contract to name a current contracting officer’s representative.


  • Recommendation #8

    Implement an acquisition planning process for the Commission.


  • Recommendation #9

    Create contract files containing required information for all nonexpired internal contracts.


  • Recommendation #10

    Complete contractor performance evaluations for all nonexpired internal contracts.


  • Recommendation #11

    Record the required procurement information for all nonexpired internal contracts in the Federal Procurement Data System.


  • Recommendation #12

    Implement a process to ensure timely and accurate reporting of contractual obligations to the Federal Procurement Data System.


  • Recommendation #13

    Rescind contracting authority from the executive director position until the individual in the position meets the requirements of the Federal Acquisition Certification in Contracting (FAC-C) Program set by the Office of Federal Procurement Policy.



Audit of the Help America Vote Act Grants Awarded to the State of North Carolina

  • Recommendation #3

    Determine the allowability of $400,696 in questioned costs ($382,645 unsupported; $18,051 ineligible) under CARES Act Award NC20101CARES-01 and recover any amount that is unallowable.


  • Recommendation #4

    Determine the allowability of $324,753 in questioned costs ($320,344 unsupported; $4,409 ineligible) under Election Security Award NC20101001-01 and recover any amount that is unallowable.


  • Recommendation #5

    Require the North Carolina State Board of Elections to strengthen its policies and procedures for subawardee monitoring, including the procedures for reviewing invoices and supporting information submitted by subawardees.


  • Recommendation #6

    Require the North Carolina State Board of Elections to implement procedures and training to ensure assets purchased with HAVA funds are completely documented in the Fixed Asset System and asset tags are affixed to the asset in a visible location.