ML18248A073

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Status of Recommendations Audit of the Us Nuclear Regulatory Commission'S Internal Controls Over Fee Revenue (OIG-15-A-12)
ML18248A073
Person / Time
Issue date: 09/12/2018
From: Maureen Wylie
NRC/OCFO
To: Baker B
NRC/OIG/AIGA
Hudson, Sharon
References
OIG-15-A-12
Download: ML18248A073 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 12, 2018 MEMORANDUM TO: Dr. Brett M. Baker Assistant Inspector General for Audits Office of the Inspector General FROM: Maureen E. Wylie /RA/ (B. Ficks for)

Chief Financial Officer

SUBJECT:

STATUS OF RECOMMENDATIONS: AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS INTERNAL CONTROLS OVER FEE REVENUE (OIG-15-A-12)

Please see below a status update pertaining to the subject audit report of March 19, 2015, and the Office of the Inspector General (OIG) correspondence of May 23, 2018.

Recommendation 1 Establish policies and procedures to centralize the control of Technical Assignment Control (TAC) setup.

Status Agree. The Office of the Chief Financial Officer (OCFO) implemented the Cost Activity Code System (CACs) as the central authoritative source for creating and managing CACs, effective October 1, 2017. During Fiscal Year (FY) 2018, the OCFO merged the policy for creating and managing Enterprise Project IDs (EPIDs) into the existing CAC guidance to create a single policy and guidance document for creating and managing labor reporting codes. The OCFO submitted the draft guidance to offices for review and comment during August 2018 and is working on updating the draft guidance planned to issuance date by the end of September or early October 2018. The OCFO continues to work with the Office of Administration (ADM) on updating the agency policy and procedures in Management Directive (MD) 10.43, Time and Labor Reporting. Offices provided their comments on a draft on August 22, 2018. OCFO will finalize MD 10.43 in accordance with the timeline and requirements set forth by ADM.

Milestones:

1. Centralize in the OCFO the control of setup for CACs that are non-billable, non-docket -

Complete (Interim CAC Guidance, ML15328A273, and Yellow Announcement, YA 0016, February 19, 2016).

CONTACT: Carl Fredericks, OCFO/DOC (301) 415-6285

B. Baker 2. Provide guidance and conduct CAC system user training about: the procedures for CAC setup, the data exchange in relation to the program office workload management systems, and the OCFO approval/governance role - Complete (Integrated Training Documents for CAC System and Human Resources Management System (HRMS),

ML17299A170, and Yellow Announcement, YA-17-0074, dated August 16, 2017).

3. Establish policies and procedures to centralize the control of CAC setup for billable, docket-related, and/or project-related CACs - (Draft Labor Reporting Code Guidance, ML17215A939), expected completion date of September 30, 2018. The OCFO lead is Jim Coyle.
4. Update MD 10.43, Time and Labor Reporting - extend to June 30, 2019. The OCFO lead is Erikka LeGrand.

Recommendation 2 Design and implement internal controls that would allow user access in HRMS to TACs related only to their job functions.

Status Closed (ML18143B637, 05/23/2018)

Recommendation 3 Standardize and link TACs to specific tasks.

Status Closed (ML18143B637, 05/23/2018)

Recommendation 4 Design and implement a plan to improve the TAC validation process.

Status Agree. The actions to complete the new standard fee billing validation process began during FY 2018 after implementation of the new CAC/EPID coding structure and the CACs system. The OCFO formed an intra-agency workgroup to design and implement a standard fee billing validation process. The workgroup developed a draft design process that improves accountability and control by adding management oversight and awareness concerning the use of the EPID for capturing fee billable labor hours. To aid in this management oversight, two data elements are being added to the EPID data record in the Reactor Program System and in CACs. Once the system changes are complete, the workgroup will finalize the design and provide training for implementation with a revised target completion date of June 30, 2019.

B. Baker Milestones:

1. Design a plan to standardize and improve the staff hours validation process - complete (ML17290A261, 10/16/2017).
2. Design and complete a more effective validation report - extend to 06/30/2019. The OCFO lead is Jawanza Gibbs-Nicholson.
3. Provide guidance and training for the standard validation process - extend to 06/30/2019. The OCFO lead is Jawanza Gibbs-Nicholson.
4. Implement the improved CAC validation process - extend to 06/30/2019. The OCFO lead is Jawanza Gibbs-Nicholson.

Recommendation 5 Develop and implement a project manager and resident inspector overhead allocation methodology that will produce accurate, timely, and reliable overhead cost data for invoicing.

Status Closed (ML16048A015, February 17, 2016)

Recommendation 6 Design and implement procedures and processes that provide sufficient contractor information on the validation reports for NRC project managers and resident inspectors to identify and validate the specific tasks performed and related reimbursable contractor costs.

Status Closed (ML15153A399, June 2, 2015)

Recommendation 7 Design and implement procedures and processes that provide sufficient contractor information on invoices for licensees and applicants to identify the specific tasks performed and related reimbursable contactor costs.

Status Closed (ML16048A015, February 17, 2016) cc: S. Zane, OIG E. Rivera, OIG J. Storch, OIG J. Jolicoeur, OEDO

ML18248A073 *EMAIL CONCURRENCE PROVIDED OFFICE OCFO/DOC/ARB OCFO/DOC/ARB OCFO/DOC/ARB OCFO/DOC/PPB OCFO/DOC/ARB NAME JGibbs-Nicholson JCoyle* MBlair* ELeGrand* CFredericks DATE 9/ /18 9/07/18 9/07/18 9/07/18 9/07/18 OFFICE OCFO/DDOC OCFO/DOC DCFO CFO NAME DDAbate GPeterson BFicks MEWylie DATE 9/07/18 9/12/18 9/12/18 9/12/18 (B. Ficks for)