The Department’s accountability framework for managing Recovery Act activities leverages and builds on existing accountability mechanisms within the Department, such as the annual internal control assessment for OMB A-123. The framework is comprised of various mechanisms, such as a governance structure and processes for managers to identify/mitigate risk, regularly review performance results, and ensure completion of corrective actions. As detailed below, the framework reflects the coordinated efforts among all offices and components with Recovery Act responsibilities to ensure effective achievement of the Act’s objectives.
Governance Structure. The Department established a top-down governance structure to support its implementation of the Recovery Act and manage the funds received. The structure includes a Governance Board, consisting of officials from the Office of the Associate Attorney General, OJP, COPS, OVW, and ATF and the Assistant Attorney General for Administration. The Board’s responsibilities include:
• Developing an implementation approach that establishes management accountability over Recovery Act funds
• Ensuring Recovery Act objectives and requirements are communicated clearly and achieved in a thorough, effective, and timely manner
• Monitoring prompt correction of weaknesses
Communications Strategy. The Department established a top-down communications strategy to address Recovery Act information needs and reporting requirements. The strategy establishes clear accountability for providing accurate, timely, and transparent reporting to stakeholders. A key aspect of the strategy is early reporting of risks and associated action plans to prevent major issues from occurring.
Risk Identification and Management. The Department developed a Risk Management Plan to provide a common framework for components to use in identifying and managing risks associated with Recovery Act activities. Components are required to complete the risk assessment and develop risk mitigation plans for significant risks.
Internal Control Assessment. The Department will evaluate the effectiveness of internal control over Recovery Act activities though existing review activities, including the Department’s annual assessment for OMB A-123. The annual assessment uses a top-down, risk-based approach, which focuses on the risks related to achieving program objectives and reliable financial reporting and assessing the controls to address those risks.
The Department’s FY 2009 Guidance for Implementation of OMB A-123 requires components to update business process documentation and test key controls for material business processes. For FY 2009, all material business processes requiring testing cover the processes involved with Recovery Act funds (e.g., Grants Management and Financial Reporting). The Department’s OMB A-123 Senior Assessment Team oversees the annual assessment and will monitor results related to Recovery Act funds.
Performance Monitoring. Each component receiving Recovery Act funds is responsible for monitoring performance related to the Act to ensure progress is on track to achieve program-specific and Recovery Act objectives. To facilitate performance monitoring from a Departmental perspective, each component’s performance monitoring mechanism is to include:
• Clear definitions of performance indicators
• Targeted levels of performance and milestones
• Source, method, frequency of data collection
• Weaknesses identified
• Accountable official
Corrective Action Implementation. Components are to use the Department’s existing FMFIA corrective action framework to ensure resolution of weaknesses related to Recovery Act funds. The framework includes assessing significance of weaknesses, developing corrective actions plans, and tracking the prompt and effective implementation of corrective actions. Guidance on the framework is provided in the Department’s FY 2009 Guidance for Implementation of OM