Department of Education: Improved Oversight and Controls Could Help Education Better Respond to Evolving Priorities

The Department of Education addressed this recommendation with several actions. The Human Capital Planning, Policy and Accountability office is collaborating with the Department's program offices and other Department support offices in a workforce planning process. In 2012, the agency conducted a series of interviews with program offices and issued a corporate workforce planning proposal. In addition, the Human Capital and Client Services Office (HCCS) conducted a position review in September 2012 and issued recommendations for reclassifying positions.

The Department of Education indicated that as part of the launch of its new performance management system, REsults ACHieved (REACH), it provided extensive training to both managers/supervisors and employees on setting expectations and creating an effective performance management culture. In FY12, the Office of Management: 1) provided training for managers and supervisors on conducting 2011 performance appraisals as well as training for employees; 2) provided coaching to managers and supervisors on establishing FY12 REACH performance plans, and 3) conducted a review of FY12 REACH plans. In June and July 2012, the agency conducted an independent review of FY12 REACH plans across most Education offices. The Human Capital and Client Services Office worked with each office to review the entire 10% sample from each office, using a worksheet to assure consistent expectations of performance plans. The agency will include the results of the review into training and assistance for managers, supervisors and employees. The agency will also continue to review a 10-25% sample of REACH plans each year to ensure that proper performance guidance is followed.

In June 2011, the Department of Education's Office of Federal Student Aid (FSA) issued a new policy entitled Contracting Officer's Representative (COR) Records File Management and Policy and updated the duties in its COR appointment memorandum to address the filing and retention of evidence demonstrating receipt and acceptance of contracted goods and services. The new COR file management policy provides that CORs' files should contain copies of all correspondence pertaining to contract performance, including recommendation on the acceptance of deliverables. The contracting officer's appointment memorandum provides that CORs should document their recommendation for acceptance through email to the Contracting Officer.

In June 2011, the Department of Education's Office of Federal Student Aid (FSA) issued a new policy entitled Contracting Officer's Representative (COR) Records File Management and Policy, which outlines how contract monitoring activities and results should be documented, retained, and shared. The policy provides that the COR should 1) file and retain a Contract Monitoring Plan, records related to the inspection or testing of deliverables, and documentation to support the acceptance of deliverables in the contract file; 2) use hardcopy files with references to the location of electronic records as needed; 3) ensure that electronic records are accessible in the COR's absences, and 4) provide the file to the Contracting Officer on a yearly basis, for review and inclusion in the official contract file.

In June 2011, the Department of Education (Education) and Education's Office of Federal Student Aid (FSA) developed quality control procedures for review of contract files and contractor past performance reports. Education established procedures requiring a yearly review of contractor performance evaluations for a sample of contracts by groups within Education and FSA. FSA updated its Contract Review Board and Peer Review Procedures to include steps for reviews of contract monitoring plans and the inclusion of the COR appointment letter. In addition, FSA's new Contracting Officer's Representative (COR) Records File Management and Policy provides that the Contracting Officer review the COR file on an annual basis for completeness of documentation. According to the policy, the COR file shall include contract monitoring plans and COR appointment memoranda letter.

The Department's Information Resources Management Strategic Plan was revised to reflect the latest Department Strategic Plan (May 2012).

The Department of Education indicated that the Office of the Chief Information Officer (OCIO) has collaborated more broadly among the subject matter experts. The Information Resources Management Strategic Plan was revised in May 2012 and reflects the efforts to address the contents of the Open Government, Strategic Sustainability Performance and Data Center Consolidation plans.

Procedures for conducting post-implementation reviews were developed and deployed in August 2011.