Open Recommendations

We recommend that the AOC develop and publish a discipline policy for exempt personnel, for transparency and consistency with other employee groups.

Determine whether the NFC, IPP, and subservice provider SOC 1® reports will be delivered in a timely manner and contain the following information required for an effective review and analysis.

Complete an IPP/TWAI-specific risk assessment to ensure implementation of key controls relevant to the AP financial statement assertion (e.g., through complete and timely SOC 1® reports and/or internal AOC CUECs). If the AOC becomes aware that the content of IPP/TWAI-related SOC 1® reports will continue to be provided in an untimely manner or presented in redacted format, AOC management should implement, through its risk assessment, a process to separately identify and assess mitigating and compensating controls to its environment. Additionally, for known control deficiencies at the service and key subservice providers, the AOC should identify compensating control(s) to mitigate the risks within the AOC control environment.

Complete an NFC-specific risk assessment to ensure implementation of key controls relevant to the Payroll financial statement assertion (e.g., through complete and timely SOC 1® reports and/or internal AOC CUECs). If the AOC becomes aware that the content of NFC-related SOC 1® reports will continue to be provided in an untimely manner, AOC management should implement, through its risk assessment, a process to separately identify and assess mitigating and compensating controls to its environment. Additionally, for known control deficiencies at the service and key subservice providers, the AOC should identify compensating control(s) to mitigate the risks within the AOC control environment.

We recommend the AOC Office of the Chief Security Officer coordinate with U.S. Capitol Police to draft a memorandum of agreement to support the roles and responsibilities and services required for preparation and execution of the perimeter security plans for large public events.

We recommend the AOC Office of the Chief Security Officer establish well-defined policies and procedures with a preparation checklist for jurisdictions based on the severity of threat that provides clear guidance on execution of support activities related to coordination, mobilization, de-mobilization, asset protection and reporting of activities associated with special events across the Capitol campus.

We recommend the AOC coordinate with the U.S. Capitol Police Board and legislative stakeholders to evaluate the overall focus on campus security, and reevaluate the responsibilities for design, installation and maintenance of the Capitol campus security systems and determine who should execute those responsibilities.

We recommend the AOC Office of the Chief Security Officer hold a security briefing with AOC senior leadership for each event, which highlights the security threats and risks identified during their monitoring and received from coordinating agencies along with AOC’s approach to manage such risks and instructions for jurisdictions to execute the developed preparation checklist.

We recommend the AOC inform the U.S. Capitol Police of the deferred security maintenance work elements prior to large public gatherings and events on the Capitol campus.

We recommend that AOC review and properly closeout the following dormant unliquidated obligations (ULOs):
• 68 invalid ULOs valued at $479,907.61;
• Nine unsupported questioned ULOs valued at $90,109.58;
• Nine valid ULOs valued at $8,230 that have not received a final invoice; and
• 231 ULOs with balances less than $50.

Funds put to better use: $479,907.61 and Questioned costs: $90,109.58

We recommend that AOC ensure supporting documentation for unliquidated obligations is maintained and readily available.

We recommend that AOC:
• Finalize the new Quarterly Financial Review SharePoint application and ensure this new application addresses the current and prior year audit findings; and
• Revise the AOC’s policies and procedures to align with the new application.

We recommend that:
1. The Chief Administrative Officer develop and implement additional policies and procedures that:
a. ensure adherence to vehicle utilization reporting,
b. include a more formal scheduled vehicle maintenance program,
c. collect, track, monitor and analyze fleet costs throughout the vehicle lifecycle at the vehicle level;

The Chief Administrative Officer review jurisdiction-level fleet policies and standardize jurisdictional best practices across the AOC where appropriate;

The Chief Administrative Officer procure an AOC-wide fleet management information system with best-in-class fleet management capabilities, to include vehicle inventory, acquisition, disposal, utilization, cost, mileage and fuel use information for each vehicle, and automatic notification to fleet managers of maintenance due;

The Chief Administrative Officer conduct a feasibility study to develop and implement centralized vehicle maintenance contract(s) for routine (and non-routine) maintenance to standardize AOC’s maintenance processes and realize efficiencies resulting from centralized contract(s);

The Chief Administrative Officer, in coordination with AOC organization leaders, review and revise AOC-wide and jurisdictional policies to include standards for vehicle utilization, and guidance for implementing these standards while maintaining jurisdiction-level operational flexibility.

The Chief Administrative Officer procure a fleet management information system with fleet management capabilities, to include vehicle utilization information for each vehicle.

We recommend that AOC management implement the existing, documented procedures over the review of SOC reports, establish procedures to transfer responsibilities for control operations to other team members upon an employee’s separation, and monitor internal controls to assess their effectiveness.

We recommend the Office of the Chief Security Officer develop and implement a suitability policy for AOC employees and consolidate and implement revisions, as appropriate, to the current contractor suitability policy. Additionally, develop and implement a standardized timeline for policy revision and update within the current Fiscal Year.

We recommend that the Office of the Chief Security Officer, in coordination with the United States Capitol Police and the House Sergeant at Arms, perform a joint feasibility study to consider:
a) Re-assigning signature authority for the CP-491 for the House of Representatives Sergeant at Arms-issued contractor badges from the OCSO to Contracting Officer Representatives, eliminating the hand carry of the CP-491 to USCP/Fairchild for Fingerprinting, and implementing the use of approval buttons or pdf secure signatures in place of manual signatures.
b) Identification, development or acquisition of a badge management software solution that uses notification-based processes that ensures secure, efficient execution, monitoring and tracking of badging actions.

We recommend that the Office of the Chief Security Officer develop and implement suitability policy language to include clear lines of responsibility and processes. Improvements should include:
• In the contractor suitability policy, assign the responsibility for the centralized recordkeeping of intra-agency badging agreement Memorandums of Understanding or Agreements to the OCSO; and
• In both policies, guidance and requirements for secure badge return and protection and oversight of Personally Identifiable Information.

We recommend that the Office of the Chief Security Officer in coordination with the U.S. Capitol Police and the House Sergeant at Arms, perform a joint feasibility study to develop and implement a centralized security badge management process through the use of shared software that allows for secure and efficient issuance, monitoring and tracking of badging actions, to include tracking and reporting of lost/stolen badges and follow-up actions.

The Chief Information Officer update ITD’s current policy for accountable IT property, to include the incorporation of defined program personnel roles, requirements aligned with the property management lifecycle and all current program procedures.

The Chief Information Officer continue pursuit of transitioning to a single asset management system that addresses its program needs to track accountable and consumable IT property and establish a detailed implementation plan with target dates to transition to a single asset management system for accountable and consumable IT property as currently captured in Cireson and Jumpstock.

The AOC revise the Board of Survey Process with codified punitive actions to act as a deterrent against future instances of employee negligence and misconduct regarding the loss of AOC property, including both IT mobile devices and personal property.

We recommend that the Architect of the Capitol (AOC) consider structuring future Guaranteed Maximum Price contracts as 1) fixed-price amounts for general conditions and general requirements and 2) cost reimbursement for subcontracts that are fixed-price amounts between the general contractor and subcontractors, to assist in alleviating the AOC’s administrative burden in properly administering the contract.

We recommend that the Architect of the Capitol (AOC) issue contract modifications for the sampled contracts to include any applicable clauses that the AOC did not include in the contract at the time of award or in any modifications already issued, if the AOC determines that it is feasible to do so.

We recommend that the Architect of the Capitol (AOC) issue contract modifications to remove the inapplicable clauses included in the contract, if the AOC determines that it is beneficial and feasible to do so.

As a part of the Architect of the Capitol (AOC) annual review of active contracts to determine whether any contract modifications are necessary, we recommend that the AOC incorporate a review to identify (1) applicable clauses erroneously omitted during the formulation of the contract, (2) applicable contract clauses issued after contract award, and (3) inapplicable contract clauses.

We recommend that the Architect of the Capitol (AOC) consider requiring its contractors to carry builder’s risk policies on a project-by-project basis, based on an evaluation of the risks that each project poses to the AOC.

We recommend that AOC management design control activities, including policies and procedures, that require the use of quality information in the preparation of the footnote

We recommend that AOC management 1) enforce adherence to the existing, documented proceduresto require appropriate review of SOC reports and 2) monitor the status of internal controls performed bythird parties to assess their effectiveness

We recommend the Architect of the Capitol (AOC) perform the following:
a. Recover the questioned costs of $6,464 identified within the R-Tunnel Project to the extent legally and administratively possible.
b. Review the questioned costs of $68,940 ($75,404 - $6,464) identified within the CHOBr ($53,663) and R-Tunnel ($15,277) projects to determine if the costs are allowable in accordance with contract requirements; and as applicable, recover any additional amounts resulting from the application of items like overhead and profits to the unallowable costs.
c. Ensure future change orders adhere to the contractual language regarding overhead costs not being allowed as direct costs; and when the AOC determines that overhead costs are allowable as direct costs, document how and why that determination was made.

We recommend the Architect of the Capitol (AOC) perform the following:
a. Review the questioned costs of $167,628 once the AOC determines whether Clark/Christian, A Joint Venture (CCJV) met the incentive fee requirements; if CCJV does not meet the incentive fee requirements and the 100 percent unspent project contingency funds are not awarded, the AOC should recover to the extent legally and administratively possible the AOC’s proportional share of the of the questioned costs.
b. Ensure project funds are not used to pay for damages caused by the contractor, even if those funds may be earned by the contractor at a later date.

We recommend the Architect of the Capitol perform the following:
a. Review the questioned costs of $6,958 identified within the Cannon House Office Building Renewal Project for potential improper overhead and profit markups by the first-tier subcontractor for a second-tier subcontractor’s work.
b. Review and modify the contract language to specify the allowable markups on change orders aligns with the memorandum dated June 26, 2017.

We recommend the Architect of the Capitol perform the following:
a. Recover the questioned costs of $2,716 identified within the R-Tunnel Project to the extent legally and administratively possible.
b. Review the insufficient supported questioned costs of $478,557 ($481,273 - $2,716) identified within the Cannon House Office Building Renewal ($367,315) and R-Tunnel ($111,242) projects to determine if the costs are supported and allowable; for any of the costs deemed unsupported and/or unallowable, recover the costs to the extent legally and administratively possible; as applicable, recover any additional amounts resulting from the application of items such as overhead and profits to the unallowable costs.

We recommend the Architect of the Capitol recover the unsupported questioned costs of $6,944 identified within the Cannon House Office Building Renewal ($226) and R-Tunnel ($6,718) projects to the extent legally and administratively possible.

We recommend the Architect of the Capitol work with the contractor to ensure proposals submitted for change orders are factually sound, contain the required cost detail and exclude unallowable costs.

We recommend the Architect of the Capitol (AOC) comply with the sequence of review and approval for its change orders as prescribed by its policies and procedures and ensure sufficient documentation is maintained. If the AOC deviates from its policies and procedures, the AOC should fully document the reason for the deviation.

We recommend the Architect of the Capitol recovers or not award the questioned costs of $3,551 identified within the Exterior Stone & Metal Preservation, Phase III project to the extent legally and administratively possible and ensure the contractor excludes subcontractor profit prior to applying contractual markups.

We recommend AOC management develop a process that will assess and monitor payment accuracy in its program and activities:
1. The process should include procedures to identify and assess all programs and activities that are susceptible to significant improper payments annually (max triennially).
2. For programs and activities identified as susceptible to significant improper payments, the AOC should consider the following procedures using the Office of Management and Budget guidance:
i. Perform testing to estimate the cost of improper payments in the program;
ii. Implement a plan to reduce erroneous payments;
iii. Report estimates of the annual amount of improper payments in programs and activities and progress toward reducing them within the Performance and Accountability Report.

We recommend AOC management execute the process that assesses and monitors payment accuracy in its program and activities every one to three years.

We recommend AOC management design a recovery plan that is consistent with federal guidance for implementation when improper payments are identified.

The Chief Administrative Officer should prioritize revision of the Records and Archives policies, procedures and all other associated policy directives to establish effective and efficient operational guidance and internal controls. Additionally, develop and implement a standardized timeline for policy revision and update within the current Fiscal Year. Though the AOC is not required to follow the National Archives and Records Administration (NARA) guidelines and polices, they are noted as best practices.

The Chief Administrative Officer should, within 60 days, conduct an organizational assessment of the RMAB structure and responsibilities to determine if the branch is appropriately staffed and assigned.

The Chief Administrative Officer, to address the immediate need of archival backlog items and digitalization processes, should:
a) source a temporary contracting staffing option to assist RMAB staff with processing and clearing backlog items
b) procure the services of an archival digitalization specialist to assist records retention, processing, research and preservation.

The Chief Administrative Officer should, within 60 days, develop a corrective action plan for the RMAB and Curator Division leaders to address the leadership and management deficiencies within the Division. At a minimum, the corrective action plan should address communication skills, change management, leading and empowering high-performing teams and effective federal leadership.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) develop and implement office specific policies and procedures for documenting, monitoring and reporting cases in Entellitrak to ensure quality non- Equal Employment Opportunity (EEO) and EEO data.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) perform a climate assessment for jurisdictions that frequently work with the public to identify and address concerns regarding nonemployee harassment and hostile work environments.

We recommend that the Architect of the Capitol (AOC) jurisdictions that frequently work with the public review and update all visitor guidelines and communications, as needed, to include language that promotes an anti-harassment workplace.

We recommend that the Architect of the Capitol (AOC) develop or update policies and procedures to address how the agency will document and investigate nonemployee harassment.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) establish and document minimum training requirements for its staff related to the staff’s field and area of expertise.

We recommend that the Architect of the Capitol (AOC) document and implement a process to conduct follow up inquiries after resolution to identify employee concerns, verify safety, address fears of retaliation and ensure effective reintegration (as appropriate) to minimize negative impacts on its workforce.

We recommend that the Architect of the Capitol (AOC) update AOC Order 24-1 Conciliation Program Guide, May 22, 2013, to ensure it is providing consistent and current information about the conciliation process and resources available.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) develop office specific internal policies and procedures that require regular communication and updates to individuals on the status of their complaints and cases.

We recommend that the Architect of the Capitol (AOC) develop and implement a process to report Equal Employment Opportunity-related information, as appropriate, to increase transparency and employee trust.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) develop and implement a process to receive and document recommendations and actions taken by Architect of the Capitol jurisdictions deciding officials involving sexual harassment allegations.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) update its anti-harassment training to include language options that employees commonly use; examples specific to the Architect of the Capitol (AOC) workplace and workforce; consequences for supervisors if they fail to fulfill their responsibilities related to reporting and preventing harassment, retaliation and other prohibited conduct; consequences for misconduct; and explanations of the complaint process.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

We recommend that the Office of Safety and Code Compliance (SCC) issue guidance to the Architect of the Capitol’s organizations to complete all elements of the self-inspection checklists (e.g., no blank responses or unchecked boxes).

We recommend that the Office of Safety and Code Compliance (SCC) issue guidance instructing the Architect of the Capitol’s organizations to report all self-inspection findings, including those resolved during the self-inspection process, in a centralized and consistent manner, and for the SCC to analyze this data for proactive safety and compliance issue identification and management.

We recommend that the Office of Safety and Code Compliance (SCC) update its WebTMA Inspection Findings Module Quick Guide to: 1) document how to categorize non-Architect of the Capitol (AOC) findings that are the responsibility of other agencies (e.g., U.S. Capitol Police), 2) reiterate that the SCC is responsible for both coordinating findings remediation with other agencies and defining the processes it will use to remediate findings and 3) provide the SCC’s contact information. The SCC should ensure that each AOC organization acknowledges receipt and understanding of the process for documenting and reporting other agencies’ findings.

We recommend that the Office of Safety and Code Compliance (SCC) obtain an understanding of escape hood respirators to ensure that the Senate and House Sergeants at Arms regularly inspect the respirators and ready them for use by Architect of the Capitol employees and others in emergency situations.

We recommend the Office of Safety and Code Compliance, in its next update to the self-inspection checklists, consider adding steps to address applicable items related to hazardous materials, including hazard communication.

We recommend that the Office of Safety and Code Compliance develop guidance for how Architect of the Capitol organizations should develop a complete list of self-inspection areas, including guidance for shared spaces.

We recommend that Architect of the Capitol (AOC) organizations review their lists of physical areas to self-inspect to validate they are complete and in line with updated guidance from the Office of Safety and Code Compliance. In addition, AOC organizations should report validation review results to the SCC during ongoing and regular intervals.

We recommend that the Office of Safety and Code Compliance (SCC) require all Architect of the Capitol employees performing self-inspections to complete standardized self-inspection training. The SCC should also consider requiring periodic refresher training to maintain readiness and awareness.

The Architect of the Capitol review and consider updating AOC Order 310-1, Employment of Relatives, September 12, 2012.

The Architect of the Capitol review the referenced polices (at minimum) and apply a consistent definition of “Management Official.”

The Architect of the Capitol conduct a review of the hiring process pertaining to vacancy announcement, CVC-2023-093, Director of Visitor Services, U.S. Capitol Visitors Center (CVC), to ensure that the applications of all internal candidates were processed in accordance with AOC Order 335 Career Staffing Plan, October 15, 2020.

We recommend that the Architect of the Capitol (AOC) update and revise AOC Order 34-45 (Personal Property Manual) to (1) establish a dollar threshold for accountable property, (2) the greatest extent possible, ensure mission critical non-consumable property is consistently defined across AOC jurisdictions, (3) provide guidance on how to identify, document and track mission critical non-consumable and non-accountable property, (4) provide clear directions on administrative controls and (5) develop and enforce additional inventory and accountability procedures for accountable and non-accountable property to reduce the risk of mismanagement and lost property in accordance with federal best practices.

We recommend that the Architect of the Capitol (AOC) research and implement federal government best practices for acquiring and maintaining adequate storage space to reduce the risk of theft.

We recommend that the Architect of the Capitol (AOC) conduct an organizational-wide assessment to identify disposable property and discard the property per AOC Order 34-45 (Personal Property Manual) to ensure adequate storage space.

We recommend the Architect of the Capitol ensure the Construction Manager as Constructor complies with the contractual requirements outlined in the Cannon House Office Building Renewal Project’s Building Information Modeling Project Execution Plan.

We recommend the Architect of the Capitol ensure the final as-built model of the Caucus Room includes all work performed in the room, regardless of which organization performed the work.

We recommend the Architect of the Capitol develop and adopt agencywide requirements for its Building Information Modeling Project Execution Plan to ensure contractors are informed and capable of meeting the required contractual deliverables. 

We recommend the Architect of the Capitol (AOC) require the Construction Manager as Constructor (CMc) to submit a final Testing, Adjusting and Balancing report. If the CMc is unable to do so, the AOC should assess a credit against the CMc for failing to properly complete its contractual obligations.

We recommend the Architect of the Capitol (AOC) identify any other incomplete or incorrect work pertaining to the Heating, Ventilation and Air Conditioning system in the Caucus Room. The AOC should require the Construction Manager as Constructor (CMc) to complete the work in accordance with the contractual specifications or assess credits against the CMc for failing to properly complete its contractual obligations.

We recommend the Architect of the Capitol review its commissioning process and implement internal controls to ensure that the commissioning agent properly completes all required steps prior to commissioning work.

We recommend the Architect of the Capitol add steps to the commissioning process that require the commissioning agent to test Heating, Ventilation and Air Conditioning systems for acceptable sound levels in all rooms deemed to be sensitive to elevated noise.

We recommend the Architect of the Capitol ensure design specifications clearly identify sound design A-weighted decibels goals for all rooms deemed to be sensitive to elevated noise.

We recommend the Architect of the Capitol ensure the supply diffusers near the Caucus Room ceiling are adjusted or replaced so they do not interfere with the use of the projector screen.

We recommend the Architect of the Capitol (AOC) require the Construction Manager as Constructor (CMc) to either address the damages resulting from the incorrect or improper work that the CMc performed during Phase 1 or recover the costs that the AOC incurs to remediate the damages. If feasible, the AOC should recover the costs it has already incurred for the repairs to date ($29,324).

We recommend the Architect of the Capitol review its potential change order (PCO) notification criteria and implement the following:
• Ensure that any diagrams or flowcharts referencing the criteria for PCO notification forms are consistent with the criteria outlined in the
Planning and Project Management Memorandum (PPM Memo).
• Ensure the criteria in any PCO notification form templates are consistent with the criteria outlined in the PPM Memo.

We recommend the Architect of the Capitol (AOC) evaluate the $2,320 in questioned costs related to improper application of markups for the following projects:
• Russell Stone Exterior Envelope Repair and Restoration $2,105 - contractor’s improper application of overhead and profit markups to first-tier subcontractor work.
• Thurgood Marshall Federal Judiciary Building Administrative Office Space Realignments $215 - 1st tier subcontractor’s improper application of markups on a 2nd tier subcontractor.
The AOC should recover any erroneously awarded costs to the extent legally and administratively possible.

We recommend the Architect of the Capitol (AOC) evaluate the $288 in questioned costs for duplicative overhead costs awarded as direct costs for the Russell Stone Exterior Envelope Repair and Restoration. The AOC should recover any erroneously awarded costs to the extent legally and administratively possible.

We recommend the Architect of the Capitol review the insufficiently supported questioned costs identified within the Russell Stone Exterior Envelope Repair and Restoration ($66,449) and the Thurgood Marshall Federal Judiciary Building Administrative Office Space Realignments ($18,968) projects to determine if the costs are supported and allowable; for any of the costs deemed unsupported and/or unallowable, recover the costs to the extent legally and administratively possible; as applicable, recover any additional amounts resulting from the application of items such as overhead and profits to the unallowable costs.

We recommend the Architect of the Capitol ensure that it uses the contractual markups when preparing Independent Government Estimates to ensure that the resulting price is consistent with the costs allowed under the contract and avoids overpayment (Funds Put to Better Use $17,199).