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

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 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 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, andc) 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, 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.

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 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.

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 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.

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) 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 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 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 that the Chief Information Officer require the Information Technology Division (ITD) to perform an annual validation of the ITD Authorized Access List, in accordance with ITD Authorized Data Center Proxy Card Access List Maintenance standard operating procedure.

We recommend that the Architect of the Capitol (AOC) review the Government Accountability Office’s Framework for Assessing the Acquisition Function at Federal Agencies and make necessary adjustments to AOC’s current hierarchical reporting structure to provide sufficient independence and support for Contracting Officers.

We recommend that the Architect of the Capitol (AOC) review the contracting manual to determine whether the language restricting access to Independent Government Estimate (IGE) information solely to AOC personnel who require knowledge of the estimate is appropriate. If the AOC determines the language is appropriate as written, it should enforce this requirement. If the AOC determines that it is appropriate to use non-AOC personnel in the IGE process, it should update its contracting manual to reflect that decision and implement appropriate safeguards to ensure the process remains both independent and confidential.

We recommend that the Architect of the Capitol (AOC) update the requirements prescribed in the contracting manual for serving as a Contracting Officer and/or include a reference to AOC Order 30-1.

We recommend that the Architect of the Capitol (AOC) implement compliance monitoring and enforcement standards for the current policies and procedures requiring Contracting Officer’s Representatives to document their roles and responsibilities.

We recommend that the Architect of the Capitol (AOC) develop and implement guidance that directs the format and manner that Contracting Officer’s Representatives (CORs) maintain documentation. This guidance should require that COR files be maintained in a readily accessible and uniform manner.

We recommend that the Architect of the Capitol (AOC) develop and implement guidance that requires Contracting Officers to document the procedures they undertook to complete their audit of Contracting Officer’s Representative files, explain how any deficiencies were resolved, and report the results to their management.

Review and assess the human capital policy management roles and responsibilities to identify opportunities for improvement in human capital policy management and oversight. Enhance or develop and implement specific measures to foster consistent communication and collaboration between the Human Capital Management Division and the Policy and Special Programs Division.

Per AOC Order 4-1, Issuing Architect of the Capitol (AOC) Policy, effectively execute the process to verify the assignment of policies to the appropriate Office of Primary Responsibility within the AOC Policy Library, particularly following any transfers or changes in ownership between offices/jurisdictions.Additionally, this recommendation should include a focus on ensuring that, when applicable, policy memorandums reference the original order number and section of the overarching policies to maintain alignment with their provisions.

Review and assess the policy governance framework over the jurisdictions to identify opportunities to improve policy governance, standards and communication. Enhance or develop and implement a comprehensive policy governance framework across all jurisdictions. Furthermore, this recommendation should include a focus on designating a Point of Contact at the Human Capital Management Division to handle policy-related inquiries, thereby discouraging reliance on non-designated resources and promoting adherence to policies.

Establish a review process that effectively addresses any inconsistencies or manual input errors encountered during preparation and submission of Standard Form 52 forms.

Establish data management protocols, incorporating routine review and reconciliation of employee data, alongside procedures for data entry and updates.

Revise the “Feedback to Non-Selected Internal Candidates Interviewed Form” to incorporate explicit criteria and pertinent evidence validating that feedback was extended to interviewed, non-selected internal candidates for vacant positions.

Establish clear procedures and defined timelines for administering and conducting exit interviews with separating employees.

Review and assess AOC Order 4-1, Issuing Architect of the Capitol Policy, protocols for update and retirement of outdated policies and identify opportunities to improve policy protocol activities. Enhance or develop and implement protocol measures to affect timely updates to older policies and the prompt retirement or revision of outdated or unclear policies, ensuring continuous alignment with regulatory requirements and organizational objectives.

Ensure all interrelated policies are tracked to facilitate the identification of those potentially impacted by the update of a single policy.

Practice timely reporting of the exit interview survey program to ensure its results are analyzed consistently and effectively. This includes defining timelines for reporting results to upper management and ensuring prompt action on identified issues.

Implement a centralized repository where all telework application packages, both approved and denied, across the agency are maintained. This includes establishing a regular review process of the repository to sustain its integrity and ensure consistency, fairness and policy compliance.

Review and align the processes for submitting, tracking and maintaining Quality Step Increase (QSI) awards with the established policy provisions to address potential noncompliance in QSI submission and approval processes

We recommend that the Architect of the Capitol develop standardized policies and procedures that govern how jurisdictions should evaluate and document their decision to either engage internal resources or hire external contractors.

We recommend that the Construction Division finalize and formalize its standard operating procedures.

We recommend the Architect of the Capitol (AOC) Chief Administrative Officer require the Supplies, Services and Material Management Division to identify and leverage data analytics to perform purchase card reviews to ensure compliance with AOC purchase card policies and procedures.

We recommend the Architect of the Capitol Chief Administrative Officer require the Supplies, Services and Material Management Division to update and implement the Purchase Card Review Process Standard Operating Procedure 4-13, January 27, 2020, to include criteria and procedures for conducting all purchase card reviews.

We recommend the Architect of the Capitol (AOC) Chief Administrative Officer require that purchase card approving officials perform quarterly or semiannual purchase card reviews to assist the Agency Program Coordinator in ensuring compliance with AOC purchase card policies and procedures.

We recommend the Architect of the Capitol (AOC) update the AOC Contracting Manual to include examples of split transactions and instructions on how to avoid them.

We recommend the Architect of the Capitol (AOC) develop guidance and update the AOC Contracting Manual to describe the use of third-party processors and vendors and define terms like “questionable merchant category codes,” “mandatory sources,” “third-party merchants,” “third-party processors” and “third-party vendors” in accordance with federal government best practices.

We recommend that the Architect of the Capitol (AOC) update the AOC Contracting Manual to describe the process for avoiding sales tax and add the requirement to reclaim improperly assessed taxes.