twenty percent of odca recommendations implemented ......2020/01/24 · lilai gebreselassie, audit...

January 24, 2020

Twenty Percent of ODCA Recommendations Implemented; 49% In Progress

Kathleen Patterson, District of Columbia Auditorwww.dcauditor.org

Audit TeamJoshua Stearns, Agency Risk Manager

Julie Lebowitz, Deputy Auditor

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Kathleen Patterson, District of Columbia Auditor

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May 30, 2019

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Julie Lebowitz, Deputy Auditor

Leslie Flores, Auditor


1Twenty Percent of ODCA Recommendations Implemented; 49% In Progress

January 24, 2020

January 24, 2020

The Hon. Phil Mendelson, ChairmanCouncil of the District of ColumbiaThe John A. Wilson Building1350 Pennsylvania Avenue N.W.Washington, DC 20004

Dear Chairman Mendelson:

What follows is a letter report providing the status of recommendations made by this office over the last three years. We hope this is useful to the Council in conducting its FY 2020 performance oversight hearings.

Background

The Office of the District of Columbia Auditor (ODCA) conducts audits, reviews programs, and issues recommendations to improve the effectiveness, efficiency, and accountability of District government operations. The benefit from our work is not in the recommendations made, but in their effective implementation by agency management. We take steps to improve the likelihood that a recommendation will be appropriately implemented by providing sound and reasonable proposals and following up with agency management to determine the status of each agency’s response.

Objective, Scope, and Methodology

The purpose of this report is to make public the implementation status of the recommendations we have made to District of Columbia government agencies.

Through December 18, 2019, we tracked 186 open recommendations contained in 26 reports issued from October 2016 through September 2019. These 26 reports included audits conducted under Generally Accepted Government Auditing Standards (GAGAS) as well as other engagements, all consistent with policies and procedures published on ODCA’s website. We typically do not include recommendations included in contract audit reports though we may reconsider this practice in the future.

We begin our follow-up process by entering all recommendations contained in completed reports into our tracking database. We then follow up with agencies once a year, asking them to report on the implementation status of all open recommendations made to them in the last three years.


January 24, 2020

Recommendations reported as implemented usually require documentary evidence showing what actions the agency took. Follow-up continues annually until all recommendations have been confirmed as either implemented or no longer applicable, or three years have elapsed, whichever comes first.

This report includes all recommendations deemed open in last year’s recommendation status report, except for those issued more than three years ago. “Open” recommendations are any that we have not been able to confirm as implemented or no longer applicable, or that the agency has reported that they will not be implementing.

Results

This report describes the status of 186 recommendations issued from October 2016 through September 2019. The status of each audit recommendation is identified using the following classifications:

ImplementedWe reviewed information provided by the audited agency’s management and agreed that the recommendation was implemented.

In progress

This status is assigned in two instances: Recommendations that management reported as underway but not yet fully implemented; orRecommendations that management reported as implemented but lacked documentary evidence supporting their claim.

No longer applicable Circumstances have changed since the audit report was issued that render the recommendation no longer relevant.

Will not be implemented; management accepts risk

Management does not agree with the recommendation and/or does not intend to implement it. In making this choice, agency management is accepting the risk that accompanies the associated finding.

Not started Agency management reports that they have not yet begun to implement the recommendation.

No information available The agency has not responded to our requests for information about this recommendation.

For purposes of future tracking, all recommendations confirmed as implemented or no longer applicable will be considered closed and no additional follow-up will be conducted. All other recommendations are considered open and regular follow-up will continue until they are considered closed––either because of being implemented or if more than three years have passed since the recommendation was issued.


January 24, 2020

As shown in the chart below, as of December 18, 2019, 20 percent of the recommendations included in this report have been implemented, 49 percent were in progress, 6 percent had not yet been started, and 11 percent will not be implemented, according to the responsible party. In addition, we lack information to report on an additional 13 percent of our recommendations either because responsible parties did not provide a response to our written request regarding implementation status or because the information is otherwise not available.

Figure 1: Recommendation Implementation Status Summary

20+49+11+13+7Implemented 20%

In Progress 49%

Will not be implemented

11%

No information available

13%

Not Started6%

Figure 2: Open Recommendations by Agency as of December 18, 2019*

Entity Number of Open Recommendations*

Council of the District of Columbia 33

Department of Housing and Community Development 31

Office of the Chief Financial Officer 10

Department of Health 10

Department of Employment Services 9

Office of the Mayor 9

Department of General Services 8

Department of Consumer and Regulatory Affairs 7


January 24, 2020

Entity Number of Open Recommendations*

District of Columbia Public Schools 7

Office of the City Administrator 7

Department of Corrections 7

Office of the State Superintendent of Education 6

Department of Human Resources 3

Department of Public Works 2

Office of Advisory Neighborhood Commissions 2

Office of the Chief Medical Examiner 1

Office of Contracting and Procurement 1

Office of the Chief Technology Officer 1

Office of Victim Services and Justice Grants 1

Deputy Mayor for Education 1

*Totals differ from the previous chart because several open recommendations were directed to more than one agency.

We hope this update on our previous work will be useful to Councilmembers and to the public.

Thank you.

Sincerely yours,

Kathleen Patterson District of Columbia Auditor

cc: D.C. Councilmembers


January 24, 2020

Ref. # Report Title Rec. # Recommendation Status Notes

1 Contracting Out School Food Services Failed to Control Costs as Promised(October 7, 2016)

1 DCPS should effectively negotiate for succeeding years of the current privatization contracts with [food service management companies], to include either lower base prices or sliding scale unit prices based on expanding participation so that vendors have clear monetary incentives to both expand participation and reduce overall costs or other alternatives that achieve the same goals.

In progress DCPS reported this recommendation as no longer applicable, but has not provided sufficient documentation

2 [Develop] significantly more robust Office of Food and Nutrition Services (OFNS) operations and a return to a cost-reimbursable contract for school food services in which DCPS has a greater and more effective range of control over expenditures, quality, participation and all other aspects of the school food program, OR…. []transition to a self-operated food service program as has been accomplished by systems in Philadelphia, Detroit, New Haven, and other cities, so that District government employees accountable to District government leaders – DCPS leadership, the Mayor, and the D.C. Council – are empowered to pursue the policy objectives of better nutrition and greater participation while also reducing the proportion of food service expenditures that come from D.C. taxpayer dollars.

In progress DCPS reported this recommendation as implemented, but has not provided sufficient documentation

Status of Audit Recommendations by the Office of the D.C. Auditor, as of December 18, 2019 Listed Chronologically, by Date of Report Publication


January 24, 2020


2 The D.C. Government Must Improve Policies and Practices for the Protection of Personally Identifiable Information(January 6, 2017)

4 District agencies should develop written policies that govern data collection based upon NIST guidelines or OCTO or another central governmental agency should accomplish this on behalf of all Executive Branch agencies.

CFSA: Implemented; OCTO: In progress; DCHR: In progress

We chose to follow up with CFSA, OCTO, and DCHR. CFSA has demonstrated that they implemented the recommendation. Both OCTO and DCHR have reported it as implemented but have not provided sufficient documentation.

9 The Mayor should require that all District-issued laptops and USBs that maintain PII are encrypted.

In progress The Mayor previously reported this recommendation as in progress with an expected completion date of June 2019. We have no more recent information.

3 D.C. Spent $41 Million in Emergency Contingency Funds Responding to Winter Storm Jonas, and Could Have Saved Money Through Negotiation and Improved Management of Retainer Contracts (January 11, 2017)

2 OCP should conduct an audit of all PCard expenses related to Winter Storm Jonas to ensure that the District paid no credit card fees on any transaction and require District agencies to seek reimbursement from vendors where it finds the District did pay such fees.


5 OCP should review and revise the District’s policies regarding food and lodging expenditures to ensure compliance with federal procurement and appropriations laws.

Implemented


January 24, 2020


4 Planning, Buying, and Implementing A New Information Technology System: A Case Study of the D.C. Business Center(February 9, 2017)

1 The Mayor and the D.C. Council should require a comprehensive planning process for IT projects. That should include giving OCTO the personnel and political standing to use its statutory authority to review and oversee District government IT projects.


2 The Mayor and the D.C. Council should establish a dedicated budget for information technology projects.


3 The Mayor should ensure that for IT implementation, and particularly for District-wide or multi-agency systems, a steering committee, or other management structure envisioned in the comprehensive planning document, include representation from the City Administrator and appropriate Deputy Mayors’ offices. This committee can manage the project, following procedures in the planning document to reflect changes in the project goals and schedule. It should also monitor the contractor’s completion deadlines and the results of the project’s performance measures.

In progress The Mayor’s office did not provide an expected completion date.

4 The D.C. Council should ensure that oversight committee responsibility for monitoring and oversight of IT projects is clear so committees can hold the executive management team accountable, including across administrations or changes in agency leadership.

Not started


January 24, 2020


5 DHCD Should Improve Management of the Housing Production Trust Fund to Better Meet Affordable Housing Goals(March 16, 2017)

1 DHCD should develop income certification procedures and distribute them to HPTF projects, including a standard form, a list of sufficient documentation, and guidance about when and how certification should be conducted, including the requirement for bank statement submission.

Implemented

2 DHCD should develop a monitoring strategy that includes site inspections to ensure HPTF projects are complying with the procedures.

Implemented

3 DHCD should coordinate periodic training on income certification procedures.

In progress DHCD reported this recommendation as implemented but has not provided sufficient documentation.

4 As this is a policy issue that cuts across different affordable housing programs operating in the District, the D.C. Council should amend D.C. Code § 42-2802.02 to address how to handle tenant income increases above HPTF limits.

Not started This section of the D.C. Code has not been amended as recommended as of the date of this report.

5 Once the D.C. Council determines how to handle tenant income increases, DHCD should include this guidance in its procedures that are distributed to HPTF projects and language should be added to loan agreements.

Not started


January 24, 2020


6 DHCD should create a standard certification form for all HPTF projects to submit annually that requires valuable data, i.e., household income, household size, tenant information, unit size, unit #, rent amount for reserved units.


7 DHCD should include the annual certification form as an exhibit in the loan agreements.


8 DHCD should make the annual certification form available on DHCD’s website.


9 DHCD’s Portfolio and Asset Management Division should send this certification form annually to HPTF borrowers.


10 DHCD should enforce Kentucky Scott’s loan agreement to create 21 units of affordable housing for senior citizens and work to bring the property in compliance with the agreement without adversely affecting current tenants.



January 24, 2020


11 DHCD should enforce the requirement for properties to submit annual certifications.


12 DHCD should determine the utility allowance annually and publish it with the rent and income limits.


13 The loan agreement between DCHD and the borrower should include information about the utility allowance and rent and income limits, as well as a website link to find the limits.

In progress DHCD previously reported the expected completion date of this recommendation as the end of FY2019. We have no more recent information.

14 DHCD Portfolio and Asset Management Division should establish a system of communication to inform borrowers and property management companies when the updated rent and income limits and utility allowance have been posted.


15 DHCD should include methods for checking borrower compliance with rent limits in the monitoring strategy it should implement per Recommendation 2.



January 24, 2020


16 DHCD should add language to the loan agreements when projects are expected to exceed rent limits due to their participation in other local and federal programs.


19 DHCD should conduct a cost benefit analysis to determine if outsourcing repayments of HPTF loans is beneficial.


20 DHCD should designate staff to conduct specific procedures for reconciliation of AmeriNat remittances.


21 DHCD should create an accurate system to track borrower compliance with loan agreements, including loan repayments.


22 DHCD should immediately provide information about subordinate loans to AmeriNat.



January 24, 2020


23 DHCD should develop SOPs for the timely transfer of subordinate loan documentation to AmeriNat and tracking borrower compliance with loan agreements.


25 DHCD should develop a system to ensure that audits are completed going forward.


28 DHCD should create detailed SOPs that address the compilation of the quarterly and annual reports, that include: retention of back-up information and calculations to support the reported figures; explanations for any adjustments after the fiscal year closes; and reconciliation of the annual report information with SOAR data prior to report release.


30 DHCD should ensure that future HPTF Requests for Proposals (RFPs) target projects to extremely low- and very low-income households.


31 DHCD should develop a compliance plan to ensure that future obligations do not deviate from the required 40 percent for both extremely low income and very low-income households.



January 24, 2020


32 DHCD should develop, publish, and follow annual outreach plans.


33 DHCD should incorporate requirements into both the loan agreements and covenants about where and how to advertise vacant units and waitlists when there are no vacancies.


34 DHCD should make information easily accessible on its website about the HPTF-funded projects including their names, locations, number of units, and AMI requirements.

Implemented

35 DHCD should conduct annual housing needs assessments as required by D.C. Code § 42-2802 (d) (3).



January 24, 2020


37 Prior to the development of the RFP, DHCD should use the data determined by the annual needs assessment to target the RFP to specific housing needs.


38 DHCD should ensure that all needs assessments, even those conducted by other vendors, are accessible on the DHCD website.


6 Internal Weaknesses Found in Marion S. Barry Summer Youth Employment Program (March 21, 2017)

1 DOES should establish and periodically update a comprehensive policies and procedures manual that governs all aspects of MBSYEP and serves as a basis for internal staff training.

Implemented

5 DOES should develop and implement a comprehensive management information system capable of supporting MBSYEP operations and with sufficient internal controls to prevent waste, fraud, and abuse.


10 DOES should develop and implement a formal training plan for MBSYEP staff and host employers that focuses on MBSYEP operations and incorporate policies for staff training into a comprehensive MBSYEP policies and procedures manual.

Implemented


January 24, 2020


14 DOES financial staff should pay vendors promptly and pay the Quick Payment Act interest penalty required by law when the agency has failed to make timely payments.

In progress DOES reported this recommendation as “no longer applicable,” however, they did not provide documentation. In addition, their written explanation seems to indicate implemented may be more accurate. We have followed up.

15 DOES should subject the summer youth employment activities funded by its MOU with OLA to the same rules as other D.C. government agencies that provide summer positions to MBSYEP participants.


16 DOES finance staff should ensure that MBSYEP is charged only for expenses related to the six-week summer program.


17 DOES should compensate contractors based on the actual number of youths who attended their programs, as provided in their Human Care Agreements.


19 DOES should comply with the statutory requirement to publish data about MBSYEP participants’ demographics, activities, and employment by February 1 of each year.

In progress DOES has published data about MBSYEP participants’ demographics, as required by law, but continues to publish the data past the mandated deadline.


January 24, 2020


7 The Department of Public Works’ Performance Measures were Effective but Lacked Proper Controls (June 15, 2017)

2 The Chief Performance Officer of the Office of the City Administrator should develop and implement procedures to retain documentation detailing OCA’s activities related to the review and approvals of KPIs.


OCA has not responded to our request for information regarding this recommendation.

8 The Department of General Services Needs Guidance and Assistance to Develop Effective Internal Controls(July 17, 2017)

1 The Mayor of the District of Columbia should ensure that DGS has the guidance and technical assistance necessary to properly design and implement effective internal controls, using an internal control framework. The framework should be instructive on how to design and implement both operational and financial controls, in addition to controls that will ensure District compliance with laws and regulations at both the local and federal level. At a minimum, the framework should:• Start with a risk assessment so that DGS can identify the agency’s objectives and any related risks that could prevent it from achieving its mission.• Establish the structure, responsibility, and authority for the agency’s control environment, including standards of conduct.• Include guidance for DGS on how to design, implement, and periodically test internal control processes.• Assist DGS in ensuring that it collects and uses data and information of a high quality.• Encourage effective monitoring of the internal control environment, so that management can ensure that the agency’s internal controls continue to adapt and improve as the agency’s objectives, laws, resources, and risks change over time.

In progress The Mayor previously reported that this recommendation will be implemented by March 2019. We have no more recent information.


January 24, 2020


5 DGS should ensure that processes used to detect Davis-Bacon Act violations are properly designed and implemented, including the retention of sufficient appropriate documentation to facilitate ODCA’s review of the operating effectiveness of the processes.

In progress DGS reported this recommendation as implemented but has not provided sufficient documentation.

6 The D.C. Council should conduct a fact-finding oversight hearing and draft and enact a local law providing implementation guidelines for the District’s compliance with and enforcement of the Davis-Bacon law, including specific responsibility for reviewing and following up on complaints that are currently forwarded to DOL. At a minimum, a D.C. government agency should have explicit authority, responsibility, and funding to ensure that any prevailing wage law violations result in appropriate action by D.C. agencies, including debarment of a contractor.

In progress The Council is exploring ways to improve enforcement of all wage laws. Estimated completion date: December 31, 2020.


January 24, 2020


9 Critical Work of the Child Fatality Review Committee Should Build on Recent Reforms(July 21, 2017)

2 The D.C. Council should hold a public hearing on each CFRC annual report, as required by law.

Not started The Council reported this recommendation as implemented but there is no public record of this hearing having been conducted.

3 The City Administrator should ensure that agencies incorporate CFRC recommendations into annual performance plans and reports, as required by law.


OCA has not responded to our request for information regarding this recommendation.

4 OCME should seek to identify an additional staff position for the CFRC to conduct statistical reviews and help the CFRC fulfill its mission to review all child deaths in the District of Columbia.

Implemented

5 OCME should include in its annual performance plans the goal of publishing the CFRC’s annual report by September 30 of the following year.

In progress OCME reported this recommendation will be implemented by 9/30/20.

6 The D.C. Council should revise the law to require a minimum of four community representatives on the CFRC.



January 24, 2020


10 Significant Improvements Needed in DCRA Management of Vacant and Blighted Property Program(September 21, 2017)

1 DCRA should ensure its management information system properly reports on the vacant and blighted property program, integrated with other relevant systems used, and includes automated notifications to staff for important deadlines (i.e., sending of vacant notices, NOIs, responding timely to appeals), possibly by updating or replacing its information management system.

In progress DCRA previously reported this recommendation would be implemented by 11/20/19. We have no more recent information.

2 DCRA staff should regularly produce vacant property program performance reports that supervisors examine for completeness and accuracy.

In progress DCRA reported this recommendation as implemented but has not provided sufficient documentation.

3 DCRA should issue detailed regulations based on the D.C. Code for the vacant and blighted property program.

In progress DCRA reported this recommendation as no longer applicable but has not provided sufficient documentation. In addition, their comments indicated that perhaps “no action intended” is more accurate. We have followed up with the agency.


January 24, 2020


4 DCRA should adopt and train staff on Standard Operating Procedures (SOPs) based on D.C. Code and regulations that detail:A. Supervisory approval and monitoring of timeliness of DCRA actions,B. Instructions about when penalties are due, and when and how cases are to be referred to OAG,C. Exemption document requirements and retention, receipt and review timelines, and verification processes,D. Supervisory review of exemption approvals (i.e., ensuring no more than three years of exemptions granted),E. Procedures for implementing the new requirement to semiannually publish information on vacant and exempt properties on its websiteF. What documentation DCRA needs in its management information system.G. Data quality controls (i.e., how to ensure the same property does not have multiple records).H. Procedures and criteria for determining which properties to include on the bulk list data and weekly transmissions to OTR.I. Internal deadlines for ensuring timely submission of the lists, data quality guidelines, and supervisory review processes of the bulk list data and weekly transmissions to OTR.J. Procedures for recording the date and source of a vacant complaint.K. An internal deadline for when vacant notices are to be sent.

In progress DCRA reported this as implemented but has not provided sufficient documentation. In addition, their comments indicated that perhaps “in progress” was more accurate. We have followed up with the agency.


January 24, 2020


4 L. Guidance on DCRA attendance at RPTAC hearings.M. Procedures to ensure that blighted status follow-up inspections are conducted in a timely manner.N. Consistent and strong criteria for proving occupied status.O. Procedures for ensuring that occupied status is granted only when owners provide that required documentary support.P. Clarity that occupied status is not an exemption.

5 DCRA should update its website, correspondence, and forms to properly inform owners about:The timelines for action per D.C. Code,Exemption requirements per the D.C. Code and DCRA requirements, including specific criteria for qualifying for the economic hardship exemption,DCRA’s required documentation to prove occupied status.

Implemented

6 DCRA should end the granting of Special Exemptions.

Implemented

7 DCRA should address how RPTAC appeals should be categorized for the purpose of exemption limits.

Implemented

8 DCRA and OTR should execute a written agreement that outlines the responsibilities and timelines of each agency related to the classification and billing of vacant and blighted properties, as well as shared reports used for reconciliations.

Implemented


January 24, 2020


14 In order to better achieve the vacant property program objectives, DCRA should conduct a formal, structured risk assessment of the program and, for all significant risks identified, should select and implement appropriate risk responses, including, when appropriate, internal controls.

In progress DCRA reported this as implemented but has not provided sufficient documentation. In addition, their comments appear to indicate that “in progress” may be more accurate.

15 DCRA should conduct regular monitoring to ensure internal controls are properly functioning to meet program goals.

Implemented

11 Budgeting and Staffing at Eight DCPS Elementary Schools(October 30, 2017)

1 Under the current provisions of the D.C. Code and using intent reflected in the legislative history, DCPS should draft clear guidance on how school principals and local school advisory teams can provide input on at-risk funding allocations in its FY 2019 budget development guide, including a description of at-risk funding options that schools can recommend or modify.

Implemented

2 The D.C. Council should provide careful oversight on how at-risk funding is utilized, whether the utilization is consistent with legislative intent, whether legislative intent is clearly reflected in the D.C. Code language and consider amending the law if necessary, to better meet the goal of the additional funding.

Implemented


January 24, 2020


3 To improve transparency and budget execution and be consistent with the Every Student Succeeds Act, DCPS should substitute actual salaries in local school budgets as soon as practicable after staffing decisions have been made.

In progress DCPS reported this recommendation will be implemented by 7/31/20.

4 DCPS should create and make public a multi-year technology needs plan to define and provide adequate technology to each school. The plan should include expected costs and planned funding sources.

In progress DCPS reported this recommendation will be implemented by 1/27/20.

12 Audit of the Public Vehicles For-Hire Consumer Service Fund(November 2, 2017)

4 OCFO should perform reviews to verify gross receipts certified by DDS to ensure that 1% fees submitted are accurate.

Implemented

13 Stronger Management of the Housing Production Trust Fund Could Build More Affordable Housing(March 20, 2018)

1 DHCD should maintain a database with complete, accurate, and accessible information on the HPTF. The agency should seek to use HPTF data verified by ODCA; store an accessible copy of all agreements (with the borrower’s name, date award occurred, number of affordable units, AMI, loan amount, interest rate, and period of affordability); track borrower compliance with loan agreements; and provide access to the public and the OCFO to enable OCFO monitoring of HPTF agreements and expenditures.



January 24, 2020


2 The OCFO’s Office of Integrity and Oversight should conduct a written assessment of whether management of the Economic Development and Regulation Cluster regularly enforces the requirement to use a reprogramming when repurposing “budget authority for uses other than originally planned and approved.” If they do not, the OCFO should create a written action plan to increase enforcement.

In progress OCFO has not provided an estimate of when this recommendation will be fully implemented.

3 The OCFO’s Office of Integrity and Oversight should conduct a written assessment of whether management of the Economic Development and Regulation Cluster uses appropriate funding sources for reprogramming, and specifically to determine if the Cluster should use more appropriate funds (such as the General Fund surplus or the reserve fund) that would keep HPTF funding in circulation for new affordable housing projects. If they do not, the OCFO should create a written action plan to improve the execution of reprogramming.

In progress OCFO has not provided an estimate of when this recommendation will be fully implemented.

5 DHCD should work with the Mayor and the D.C. Council to develop a written assessment of the goals of the HPTF regarding revenue from loan repayment, including whether the ratio of deferred to amortized loans is appropriate and whether the current rate of repayment is acceptable. If a consensus determines repayments are not sufficient, DHCD should develop a written report on how the agency will improve repayment through more efficient collections or assessing ability to pay or both.

In progress DHCD previously reported this recommendation would be implemented in FY2019. We have no more recent information.


January 24, 2020


8 The OCFO and DHCD should enter into an MOU on an annual basis that defines the intra-District transfer of HPTF funds. This MOU should include the amount that administrative costs are not to exceed for the year based on funds deposited.


Both agencies have reported that they will not implement this recommendation.

10 DHCD should work with the OCFO to develop criteria for what constitutes appropriate HPTF administrative and project expenditures, include the criteria in the HPTF SOPs and MOU, and document compliance with the criteria during the closeout of the MOU at year-end.

In progress DHCD did not provide a date by which they expect to complete this recommendation.

11 To address the breakdown in controls relating to the administration of the HPTF, the OCFO should conduct a written assessment on how it will reassert its independence from the agencies it serves by instituting new safeguards, such as a prescribed rotation of key OCFO employees between agencies and/or clusters to reduce entrenchment and bias; train staff on existing laws, regulations, and SOPs relating to financial transactions; and impose disciplinary actions for personnel when they do not follow laws, regulations, and SOPs.


12 DHCD should approve a written policy to formalize its efforts to standardize personnel allocation and spending across funding sources to ensure all programs meet their objectives.

Implemented


January 24, 2020


14 DOES Lacks Policies and Procedures to Effectively Monitor D.C.’s First Source Program(April 19, 2018)

1 The Mayor, in collaboration with the Director of DOES, should convene a committee between contracting agencies to establish written policies and procedures to:Ensure that an employment agreement is entered into before finalization of contract award.Establish an automatic notification when a new contract is awarded or beneficiary enters into an agreement with the District.Establish a system to track agreements by beneficiary as well as project.Include additional requirements in employment agreements that general contractors or developers include in their monthly report a list of all new subcontractors, including subcontractors that have subcontracted out work, the amounts of these subcontracts, and certification that an employment agreement has been submitted to DOES for approval, where required.Establish a system to ensure that contracting agencies submit contract or project award status for all beneficiaries of contracts or projects required to enter into a First Source Agreement to DOES within seven days of the award to ensure that DOES is fully aware of every contract or project subject to an employment agreement.


4 The Director of DOES should develop standardized forms that capture all necessary reporting requirements.

Implemented


January 24, 2020


7 The Director of DOES should document and maintain records of all committee meeting actions.

In progress DOES reported this recommendation as implemented but has not provided sufficient documentation.

8 The Director of DOES should document when allowable fines are waived and make this information accessible on their website.


9 Council should require that the semi-annual reports also accurately capture achievement of percentage hour hiring rates as outlined in D.C. Code § 2-219.03 (e)(1A)(a).

In progress The Council previously reported that this recommendation would be implemented by March 1, 2019. We have no additional information.

10 DOES should establish written policies and procedures, including retention of supporting documents, related to calculating the reporting requirements in the law and presented to D.C. Council to ensure that hiring statistics can be fully supported. These supporting documents at a minimum should include, for each reporting period:A report detailing who the beneficiaries were that entered into a First Source agreement.A report listing individual names of unemployed District residents on the First Source Register.A report listing individual names of persons hired subject to a first source agreement.



January 24, 2020


15 District Overtime Tops $108 Million; Better Management and Additional Staff Could Reduce Costs(May 22, 2018)

2 The City Administrator should develop and implement an option to secure parking and towing enforcement for the D.C. Streetcar operations that does not require use of overtime.


OCA has not responded to our request for information about this recommendation.

4 DFS should regularly assess personnel needs with respect to ongoing changes in the agency’s mission or caseload and ensure that the agency’s annual budget submission reflects the FTE levels necessary to minimize the need for overtime.

Implemented

5 DOC should continue monitoring overtime use and FTE needs to determine whether the additional FTEs in the FY 2018 budget are sufficient for the agency to meet its mission with minimal need for overtime. If insufficient, the agency should inform the Mayor and D.C. Council of the need for more staff to further reduce overtime costs to taxpayers.

Implemented

7 DCHR should update issuance bulletin 11-88 requiring all subordinate agencies to document overtime approvals that match time worked. That instruction should include specific criteria regarding the information such approvals must contain and how those approvals should inform employee time entry.

Implemented

8 Within one year, DCHR should implement a module within PeopleSoft that replicates DFS’s SharePoint system of electronic overtime approvals for District-wide use.

In progress DCHR has not provided an estimate of when this recommendation will be fully implemented.


January 24, 2020


9 DCHR should promulgate an issuance bulletin within the District Personnel Manual to accompany the implementation of the electronic overtime approval and tracking system.

In progress DCHR has not provided an estimate of when this recommendation will be fully implemented.

10 DFS should continue its efforts to strengthen internal controls requiring reconciliation between approved overtime and time entered into PeopleSoft for payment and ensure managers comply with those controls.

Implemented

11 DOC should seek to improve internal controls and eliminate human error that could result in overpayment or underpayment of overtime hours, potentially through the implementation of an electronic overtime approval system.


14 DPW should develop, promulgate, and train staff on agency-wide policies and procedures that require, prior to payment at the end of each pay period, proper authorization, documentation, and verification of overtime hours worked.

In progress DPW reported this recommendation as implemented but has not provided sufficient documentation.

15 DPW should ensure that all overtime work have an individualized associated approval form specifying the number of hours worked by each employee and signed by the employee’s supervisor.

In progress DPW reported this recommendation as implemented but has not provided sufficient documentation.


January 24, 2020


16 The District’s Worksite Parking Program Treats Employees Inequitably and Could Increase Revenue(August 2, 2018)

1 DGS should terminate use of Facilities decals and collect all that were issued.


2 DGS should ensure that the DGS Parking Manager is properly supervised and segregation of duties exist when ordering and disseminating parking decals for fleet vehicles, program participants, and temporary use.

In progress DGS reported this recommendation as implemented but has not provided sufficient documentation

3 DGS should significantly improve management of the payment processes including segregation of duties, SOPS that outline check and money order handling procedures, stronger supervision, and fair and equitable enforcement of payment policies among all like-situated employees and contractors.



January 24, 2020


5 OCFO should consult with DGS and OCTO and establish an MOU describing procedures for how the District will comply with IRS qualified parking requirements at the end of calendar year 2018. These agencies should determine the processes and parties responsible for: completing annual analyses for District-owned and leased properties, identifying locations where the average market rate for parking exceeds the IRS’s annual qualified parking threshold, determining which employees received parking at those locations and which employees should pay the cost of parking reflected in the least according to the DGS Parking Policy, and then providing the OPRS with the names of the employees and the value of taxable qualified parking that should be reported in employees’ income, (i.e., the different between the “cap” or tax-free sum provided for “qualified parking,” and the actual market rate of the parking.)

In progress DGS has not provided an estimate of when this recommendation will be fully implemented.

6 DGS should require employees who currently park at leased buildings for free to pay the cost of parking as defined in the lease agreement consistent with current policy. Alternatively, DGS could consider amending the Citywide Parking Policies to permit these employees to be enrolled in the parking program, or to have their parking treated as a part of employee compensation subject to income tax according to IRS guidelines.



January 24, 2020


7 DGS should obtain control over all Henry Daly Building parking spaces and ensure that all employees who park their personal vehicles there are enrolled in the program and charged the program fee.


8 DGS should ensure that guards do not grant unauthorized individuals access to the Daly Building garage by conducting unannounced site visits and notifying DGS’s Protective Services Division when violations occur.

Implemented

9 The DGS Parking Manager should administer employee parking for the OCFO and DCPS, per DGS’s Citywide Parking Policies, or DGS should officially delegate authority to the OCFO and DCPS and update DGS’s Citywide Parking Policies to reflect this policy change.


12 DGS’s SOPs should be updated to require that the DGS Parking Manager: collect Agency Parking Coordinator (APC) rosters at least quarterly, reconcile APC information with DGS’s parking assignment log, garage rosters, and OPRS payroll reports; and document the completion and outcomes of this reconciliation. The SOPs should also include supervisory reviews of monitoring and reconciliation activities.

Implemented


January 24, 2020


13 The OCFO should make a determination or seek an advisory opinion from the IRS on whether parking at the Wilson Building falls under the definition of qualified parking and if it does, include the amount of taxable qualified parking for employees who park at that location in their income.

Implemented

14 DGS should work with the District’s elected leadership to determine whether the program should be modified and broadened to support “Sustainable DC” initiatives.

In progress DGS reported this recommendation as implemented but has not provided sufficient documentation.

17 Housing Code Enforcement: A Case Study of Dahlgreen Courts(September 24, 2018)

1 The D.C. Council should require DCRA to revise the DCMR to establish the abatement periods for violations, with authority given to the director to reduce the abatement period under specific circumstances that must be documented.


The Council has not responded to our requests for information about this recommendation.

2 The D.C. Council should require DCRA to collect and report data on time to re-inspection.



3 The D.C. Council should require DCRA to use a service delivery method other than the US Mail.



4 DCRA should explore the use of delivery services (such as Federal Express) to serve. While the per-unit charge to deliver a notice is likely greater, it may be that the tracking services provided along with delivery would offset the cost.

Implemented


January 24, 2020


5 The D.C. Council should require DCRA to re-inspect 30-day violations after 30 days, instead of 45. This could be achieved by reducing the allowance for service or starting internal processing and mail delivery service 15 days after the initial inspection, instead of waiting a full 30 days.



6 DCRA should revise its SOPs to clarify who, how, and when re-inspections are scheduled. SOPs should also establish a target timeframe for re-inspections.

Implemented

7 DCRA should provide complete and accurate information on the usual process of housing code compliance as it is carried out, including criteria used to determine and disclose the number of days allowed to the landlord to abate the violation.

Implemented

8 The D.C. Council should require DCRA to revise the DCMR to allow extensions only when specific criteria are met, including clarifying the process for landlords to apply and DCRA to approve.



9 The D.C. Council should require DCRA to revise the DCMR to combine the NOV and NOI or bypass the NOV altogether for properties that meet specific criteria. These criteria might include properties that house vulnerable populations, owners with a poor track record, and owners who receive or received financial support from the District government or other public sources for the building or property subject to the complaint.




January 24, 2020


10 DCRA should implement KPIs that measure the time to cure, including the time between the initial inspection and issuance of a NOI or time to abatement. Indicators might include the average number of days to first re-inspection for 30-day violations; number and percentage of NOVs in which an extension was allowed; average number of days to cure; average number of days between issuance of a NOV and issuance of a NOI.

In progress DCRA reported this recommendation as implemented but has not provided sufficient documentation.

10a The D.C. Council should limit business activity of problematic landlords (who meet defined criteria). This could include prohibiting landlords from entering into new rental agreements, requesting or receiving new financial support from any city agency, or renewing a business license.



10b DCRA should publish data on housing code violations by buildings or landlords, to allow tenants to make better informed decisions regarding their housing.

Implemented

11 The D.C. Council should significantly increase the dollar value of fines by at least 25 percent.



12 DCRA should charge a fine for each additional day that a violation persists, as currently allowed in 14 DCMR § 102.7. This measure could be limited to problematic properties or landlords.

In progress DCRA reported this recommendation as no longer applicable but has not provided sufficient documentation.


January 24, 2020


13 The D.C. Council should increase the re-inspection fee or eliminate it altogether.



14 The D.C. Council should require DCRA to standardize recordkeeping in activity logs. Standards should ensure the collection of enough information and the right type of information to be able to initiate each case appropriately and allow for inspectors to report on results of inspections and required next steps.



15 The D.C. Council should require DCRA to make inspections and case data available through the District’s open data portal.



16 The D.C. Council should require DCRA to make information on pending and past cases available to the public.



17 The D.C. Council should require programs that provide financial assistance to developers to consider applicants’ track records in complying with the housing code.



18 The D.C. Council should establish more stringent housing code enforcement standards for publicly supported affordable housing properties.




January 24, 2020


19 In the course of its oversight hearings, the Council should seek testimony on options to support the preservation of affordable housing in DCHFA, DCHD, and other agencies’ programs.



18 OSSE Lacked an Effective Methodology for Developing the D.C. Early Intervention Program Budget(December 7, 2018)

1 OSSE should develop a written budget methodology for the program, follow it in a transparent fashion, and provide documentation to the D.C. Council and the public.

Implemented

2 OSSE should formulate and document a process to accurately determine the average cost per child and the average number of service hours per child.

Implemented

3 OSSE should continue the enhancement of the new data system to ensure data integrity and report reliability, particularly in the number of children who receive services and the number of service hours provided. OSSE should also monitor the impact brought about by any changes in funding to the number of service hours and participants of the program.

In progress OSSE reported that this recommendation will be fully implemented by September 2020.

4 OSSE should review the current contracts with Child Find vendors and ensure that work performed against the contracts fulfills the requirements for Child Find services.

In progress OSSE reported this recommendation as no longer applicable but has not provided sufficient documentation.


January 24, 2020


5 OSSE and OCP should continue to work collaboratively through documented bi-weekly meetings and ensure that all contracts (Blanket Purchase Agreements, Human Care Agreements, and contract modifications) are fully executed with signatures and requirements and are compliant with applicable policies, laws, and regulations.

Implemented

6 OSSE should develop written policies and procedures for documented invoice review and approval and provide training to relevant staff on those policies and procedures.

In progress OSSE reported this recommendation as implemented but has not provided sufficient documentation.

7 OSSE should discontinue the practice of authorizing payment for invoices that lack required monthly reports and supporting documentation.


8 OSSE should review its payment processing process and identify areas for improvement to expedite the process and ensure that vendors are paid within 30 days as stipulated in OSSE policies and procedures.



January 24, 2020


9 OCFO and OSSE should work to ensure compliance with policies and procedures regarding booking of year-end accruals and obligations, that includes documentation of a detailed description of the methodology used for estimated accruals as required by OCFO-OFOS policies and procedures.

In progress OSSE reported this recommendation as no longer applicable but has not provided sufficient documentation. OCFO reported it as implemented but has not provided sufficient documentation.

10 OSSE should continue its collaboration with DHCF to ensure that procedures are in place for the timely submission of Medicaid claims for reimbursement. The agency should also examine the possibility of exploring additional sources of funding for the program.

Implemented

11 While not statutorily mandated, OSSE should develop a system to determine the cost of providing early intervention services, based on insurance coverage categories (children with no insurance, children covered by private insurance, or children covered by MCO fee-for-service.)

Implemented

19 Accuracy and Consistency Needed in Travel Advances and Reconciliations (December 20, 2018)

1 The Office of the Chief Financial Officer should institute additional checks on travel payments, including regular spot audits of travel documentation by Associate Chief Financial Officers, and deliver periodic training to employees who approve and process travel payments.

In progress OCFO previously reported that this recommendation would be complete by 12/15/19. We have no more recent information.


January 24, 2020


2 The Office of the City Administrator should finalize updated District-wide travel regulations and forms with emphasis on provisions that address sales and use tax exemptions and proper calculation of per diem payments and ground transportation costs.



3 The Office of the City Administrator should work with OCFO clusters and agency leadership to educate District government travelers on travel policy and best practice when booking, conducting, and submitting documentation for travel.



20 Poor Conditions Persist at Aging D.C. Jail; New Facility Needed to Mitigate Risks(February 28, 2019)

1 DOC should take all steps necessary, including requesting additional funding if necessary, to achieve and maintain full compliance with all ACA and APHA requirements.

In progress DOC has reported this recommendation as implemented but has not provided sufficient documentation.

2 DOC should conduct regular documented monitoring of Aramark’s compliance with all requirements of its contract and District food safety laws and regulations and sanction the contractor appropriately if necessary.

In progress DOC reported this recommendation as implemented but has not provided sufficient documentation. In addition, their comments appear to indicate that “no longer applicable” may be more accurate. We have followed up with the agency.


January 24, 2020


4 When considering a new correctional facility, DOC should analyze DOH violations to ensure that the design of the new facility minimizes the challenges of complying with standards and regulations that DOH frequently cited as having been violated.

In progress DOC has not provided an estimate by which they expect to fully implement this recommendation.

5 The Mayor and Council should provide a capital budget for DOC that considers the risk of failure to address health and safety hazards identified by the DOH including the risk to the safety of inmates and staff and the risk of additional litigation.


The Mayor has not responded to our request for information about this recommendation. We have no information about Council action on this recommendation.

6 EOM should, working with the other members of the District’s Capital Budget Team, develop policies and procedures for the capital budgeting process that ensure the plan accurately reflects the known capital needs of agencies, including DOC, over the entire six-year capital budgeting period.


The Mayor has not responded to our request for information about this recommendation.

7 DOH should continue to comply with D.C. Code Sec. 7-731(a-1)(1) and conduct three inspections per year of the D.C. Jail to help ensure that environmental conditions meet required standards.

Implemented


January 24, 2020


8 DOC should update their mental health intake screening policies and procedures to ensure thy fully meet ACA and NCCHC accreditation requirements without having to rely on questions and procedures administered as part of the intake medical exam, ensure that the agency’s health services contractor’s []policies and procedures mirror those of DOC and are in full compliance with ACA and NCCHC accreditation requirements and see that OHSA’s and contractors written policies remain consistent with the standards.

In progress DOC reported this recommendation as implemented but has not provided sufficient documentation.

9 DOC and the Council should review this inspection requirement and make necessary adjustments to the Code in the best interest of inmates housed at the CTF.

Not started

10 DOC should closely study the effects of its video visitation systems and consider including sufficient space in the plans for the new jail for both in-person and video visitations for all inmates, depending on which forms of visitation families prefer.

In progress DOC has not provided an estimate by which they expect to fully implement this recommendation.


January 24, 2020


21 Elected Officials Create Special Funds But “Sweep” Dollars for Other Purposes (April 25, 2019)

1 The D.C. Council should amend D.C. Code § 1-204.50 to require:a) an explicit statement of the Fund’s necessity for the efficient operation of the District government,b) language encompassing purpose, type, revenue source(s), allowable and unallowable uses of the Fund, whether personnel and/or administrative costs are permissible, and how the agency will measure the Fund’s effectiveness, andc) a fixed time for the review of the Fund’s performance and authorization for its continuation

Not started

2 The D.C. Council and the Executive should determine whether each existing Fund continues to be necessary for the efficient operation of the District and repeal those that are not necessary.


The Mayor has not responded to our request for information about this recommendation. We have no information about what actions the Council may have taken.

3 The OCFO should ask the D.C. Council for authorizing legislation for all SPRF’s created administratively.


4 The OCFO should include the following in its SPRF report: Fund expenditures, percent of revenue spent each year, and sweep amounts.



January 24, 2020


5 The Office of the City Administrator should use performance data on Fund effectiveness and efficiency to annually report on whether fees or other revenue sources should be reduced or eliminated.



6 The OCFO should strengthen its SOPs to include: 1) requirements for monitoring SPRF compliance with purpose and allowable uses (research legislative intent of Funds, if necessary); 2) criteria for AFO SPRF expenditure final approval process; 3) direction to AFOs to regularly monitor SPRFs legal status and activity, ensure the revenue source is appropriate; and 4) procedures and timelines for the timely inactivation of Funds in the event they are repealed.

Implemented

7 The OCA should establish SOPs for agencies to ensure that only personnel costs that are permissible and advance the Fund purpose are charged to the Fund.



8 The D.C. Council should revise its legislative drafting manual to require using standard statutory language to repeal Funds.

Not started

9 The OCFO should document a single methodology for calculating the amount of revenue to be transferred to the General Fund each year for the Delinquent Debt Fund and ensure that it is followed.

In progress OCFO reported this recommendation as no longer applicable but has not provided sufficient documentation.


January 24, 2020


22 Low-Ranked Projects Secure Affordable Housing Funds (May 30, 2019)

1 The D.C. Council should enact legislation to increase the transparency of the affordable housing Request for Proposals (RFP) selection process by modifying D.C. Code to include requirements that address when and how the DHCD Director can exercise discretion in the RFP process, and require public release of the final selection criteria, evaluators’ rating sheets, DHCD’s Development Finance Division (DFD) staff’s recommendations to the Director, final and signed Decision Memorandum, and the Director’s written justification for awarding projects that were not recommended by DFD.

In progress The Council held hearings on June 17, 2019, and July 10, 2019, on Bill 23-0123, the Housing Production Trust Fund Transparency Amendment Act of 2019.


January 24, 2020


23 D.C. Schools Shortchange At-Risk Students (June 25, 2019)

1 DCPS should establish transparent base funding for each school tied to enrollment and grade level. The annual budget process should use a specific and transparent methodology so that school communities are informed on both the method and the results.

In progress DCPS reported that this recommendation will be fully implemented by May 29, 2021.

2 DCPS should publish each school’s base funding and supplemental at-risk allocations so principals and LSATs can identify what is base funding and what is supplemental.


3 DCPS should establish internal controls for any adjustments to base funding including policies and procedures for allocating at-risk funds.


4 The Council should amend D.C. Code to strengthen at-risk provisions on “supplement not supplant” and apply these provisions to all public schools in D.C. to aid in its oversight of compliance with the at-risk funding requirements.

Not started

5 The District should evaluate and continuously improve its at-risk funded programs. In partnership with the forthcoming Research Practice Partnership (RPP), DME should initiate formal research on the context and impact of its at-risk funded initiatives, using rigorous quantitative and qualitative methods.

In progress The Deputy Mayor for Education reported that this recommendation will be fully implemented by April 30, 2020.

6 The Council should require consistent reporting of at-risk spending across all public schools.

In progress The Council is currently considering legislation that addresses this recommendation.


January 24, 2020


24 Panel Meets Most Requirements for Domestic Violence Fatality Review (July 12, 2019)

1 The Board Coordinator should develop a standardized information request system, based upon the types of information to be used in case reviews as listed in the Board’s Operating Rules and Procedures to formally request information. The information request should be completed on Board letterhead and received by Board representatives as well as agency and organization directors.

Implemented

2 The Board Coordinator should incorporate in the current case summary form a method to detail dates of requests and compliance with these requests and a system to track this information.

Implemented

3 To ensure that the Board continues to review domestic violence fatalities and produce annual reports as required, OVSJG should perform an annual staffing assessment and ensure that there is adequate funding for a dedicated Coordinator. If not, the lack of review of domestic violence fatalities that occurred while the Board was under OCME could reoccur.

Implemented

4 The Board should work to eliminate the four-year lag in reporting by reviewing and reporting on more than one year of data in their upcoming reports.



January 24, 2020


25 ANC 8C Misappropriated Funds (August 23, 2019)

2 The D.C. Council should amend the law to require that any equipment (i.e. computers, cell phones, laptops, printers, tablets, iPads, etc.) not turned in by January 31, will be charged to the Commissioner holding such equipment, who should be held financially responsible for reimbursing the Commission.

Not started

3 The OANC should review all 40 ANC bylaws to ensure compliance with D.C. Code.

Not started OANC reported that this recommendation will be fully implemented by September 30, 2020.

4 The Council should amend the law to require additional financial controls, including requiring the OANC to freeze ANC bank accounts if an ANC does not comply with submission of two consecutive quarterly reports that meet the requirements of D.C. Code § 1-309.13(j)(1), including supporting documentation, bank statements and minutes to ensure proper review. The bank account should remain frozen until the ANC has documented and the OANC has confirmed its adherence to the law.

Not started

5 The OANC should receive and review monthly bank statements form the Office of Finance and Resource Management (OFRM) for all ANCs to identify any suspicious or non-authorized activity and to ensure that ANCs that do not participate in the Security Fund or submit a cash surety bond do not have disbursements beyond bank fees.

In progress OANC reported this recommendation as implemented but has not provided sufficient documentation.


January 24, 2020


26 D.C. Department of Health Has Systems to Monitor Nursing Homes but Some Risks Remain (September 30, 2019)

1 HRLA should train staff with responsibility for reviewing Plans of Correction on how to determine if a Plan of Correction identifies the underlying cause of the problem, and the importance of doing so. HRLA also may want to consider offering a similar training to nursing homes so nursing home staff can determine underlying causes, and the importance of including and addressing them in the Plan of Correction.

In progress DOH reported that this recommendation will be fully implemented by February 18, 2020.

2 HRLA should obtain credible evidence that problems no longer exist in the following areas: inadequate supervision and failure to provide oral care at Washington Center; failure to comply with physician’s orders related to respiratory status at Deanwood; and exposed wiring and failure to provide nail care at Bridgepoint Capitol Hill. If these problems persist or evidence is not available that the identified problems have been rectified, HRLA should use existing enforcement mechanisms such as fines to obtain such evidence or incentivize compliance.

In progress DOH reported this recommendation as implemented but has not provided sufficient documentation.

3 HRLA should conduct an assessment and determine which practices that are noncompliant with federal or D.C. regulations have the potential for the highest risks to resident well-being, and design and implement procedures to monitor all nursing homes for repeated instances of those problems and incentivize returning to and maintaining compliance.



January 24, 2020


4 HRLA should design, implement, and train staff in: (a) policies that establish timeframe requirements from initial complaint receipt to priority assessment, regardless of receipt method; (b) procedures for monitoring each point of complaint receipt; and (c) formal procedures for making priority assessments; that will ensure that all complaints are prioritized appropriately and in a timely manner so that they are investigated timely.


5 HRLA should assess the sufficiency of existing regulations to require nursing homes to record actual staffing legibly in a standardized form every day and strengthen these requirements or seek additional authorities as appropriate. The form should capture a listing of individuals who worked during each shift, their titles or roles and their professional qualifications (e.g., RN, CNA), the number of hours they worked, and the resident census for the nursing home. It should not contain notes about staffing changes.


6 For any dates for which HRLA reviews staffing ratios at a nursing home, HRLA should cross-reference the number of hours a sample of employees worked with official payroll time and attendance cards to ensure accuracy and retain both the documentation and the inspector’s calculations to enable managerial review (regardless of whether the nursing home is found in or out of compliance.)



January 24, 2020


7 In non-emergency situations, HRLA should ensure that before the resident is discharged or transferred, it obtains the copy of the written notice of the move that the resident or the resident’s representative signed and dated. It is not necessary to obtain the signed copy before and emergency move as described by D.C. Code §44-1003.02(b). HRLA should use the signed copy of the notice to confirm that the resident or his or her representative was in fact given advance written notice of the discharge or transfer (or that he or she consented to abbreviated notice) and that all required information was provided in the written notice.

In progress DOH reported this recommendation as implemented, however, their comments appear to indicate it is actually in progress. We have followed up.

8 HRLA should design, implement, and train staff in policies and procedures for all complaint intake methods, including individual staff email addresses, to:a) Immediately record the date each complaint is received, along with an indication of the intake method (e.g., email, fax, telephone).b) Reconcile records of all complaints from each complaint intake method made as recommended in (a), above, with a listing of all complaints that received a priority rating to ensure that all complaints are prioritized for investigation.


9 HRLA should use a procedure or automated tool to schedule its inspections, ensuring they are performed in a different sequence each year, and considering the order and timing of prior inspections.



January 24, 2020


10 The process for identifying and reporting DCMR infractions and the level of harm for federal deficiencies is generally effective, but to avoid errors, HRLA should design and implement procedures to ensure a supervisor reviews and approves State Forms before they are issued in complaint investigations. The procedure should designate a responsible party for each step. This will help HRLA ensure that the correct conclusion has been drawn from the evidence and that the State Form is free of errors.


About ODCA

The mission of the Office of the District of Columbia Auditor (ODCA) is to support the Council of the District of Columbia by making sound recommendations that improve the effectiveness, efficiency, and accountability of the District government.

To fulfill our mission, we conduct performance audits, non-audit reviews, and revenue certifications. The residents of the District of Columbia are one of our primary customers and we strive to keep the residents of the District of Columbia informed on how their government is operating and how their tax money is being spent.

Office of the District of Columbia Auditor717 14th Street N.W.Suite 900Washington, DC 20005Call us: 202-727-3600Email us: [email protected] us: https://twitter.com/ODCA_DCVisit us: www.dcauditor.org

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sharing of this report, but ask that you credit ODCA with authorship when any information, findings, or recommendations are used. Thank you.

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twenty percent of odca recommendations implemented ......2020/01/24 · lilai gebreselassie, audit...

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