Work with Cal OES to ensure that it provides the necessary guidance for its subrecipients to report only VOCA-funded activities in PMT, prorating when appropriate.

Work with Cal OES to establish procedures to verify subrecipients' VOCA performance data to ensure that it is prorated, when appropriate, to prevent duplicative reporting.

Work with Cal OES to enhance its subrecipient monitoring policies and procedures to ensure subrecipients are recording or allocating expenditures by funding source, as required.

Work with Cal OES to revise its subrecipient compliance assessment procedures to ensure corrective action plans are implemented in a timely manner.

Assess current challenges imposed on CHP recipients (such as hiring, retention, and the $125,000 officer funding cap), develop potential strategies to address those challenges, communicate this information to the Department and, in coordination with the Department, consider program changes that may be necessary, potentially including statutory changes, to address the viability and success level of the program.

Complete its analysis of 2022 and 2023 awards to determine the extent to which anomalous or inaccurate application data was not flagged for review; and to complete its review of data cleaning thresholds and adjust thresholds as necessary to improve the process for identifying outliers to strengthen and improve the accuracy of applicant-provided data.

Develop and implement a process to periodically review and update data validation queries and thresholds to further strengthen the application review process.

Evaluate the colorectal cancer screening practices of the 40 facilities that are meeting the sustained, demonstrated, or developed colorectal cancer screening performance levels and use that assessment to identify any best practices that may be effective BOP-wide.

Require each BOP facility to develop a written plan for consistent colorectal cancer screening that details: how the facility will identify the average-risk population; the screening process, to include timeframes; assigned employee responsibilities; and plans for providing colorectal cancer screening education to inmates. Each facility's evaluation should take into account staffing challenges and the other factors identified in this report that contribute to the BOP's failure to consistently offer colorectal cancer screening, as well as any best practices identified during the BOP's evaluation of the 40 facilities referenced in the report.

Establish a process for the Central or Regional Offices to periodically review the facilities' written colorectal cancer screening and education plans and to work with the facilities to make changes to the plans that address new and ongoing factors that affect the ability to consistently provide screening.

Transition to using the fecal immunochemical test as the primary stool-based screening method for colorectal cancer.

Update the Preventive Health Care Screening Clinical Guidance and National Performance Measures to match the age range described in the U.S. Preventive Services Task Force and American Cancer Society recommendations on preventive colorectal cancer screening.

Require facilities to review positive fecal immunochemical test and guaiac fecal occult blood test results from the past 12 months to determine whether appropriate follow-up on positive test results occurred in all cases, and develop an after-action plan to correct deficiencies, which could include developing standardized guidance and training to ensure that appropriate follow-up occurs and is properly documented, as needed.

Consider strategies and practices to eliminate the need for off-site pre-colonoscopy evaluations at each facility.

Develop and distribute best practices for facilities to establish relationships with external medical providers in the community.

Implement a reliable, consistent process throughout all BOP facilities to monitor and analyze wait times for outside inmate appointments and the causes for canceled or rescheduled appointments in order to ensure that inmates receive timely medical care.

Develop and distribute guidance on how to consistently input International Classification of Diseases-10 codes for colorectal cancer increased-risk factors within the Bureau Electronic Medical Records System so they can more completely and accurately identify inmates at increased risk for colorectal cancer.

Following completion of Recommendation 10, ensure that increased-risk inmates are properly categorized in the increased-risk roster within the Colorectal Cancer Screening Dashboard based on their specific risk factor(s) (e.g., family history).

Institute or append to the current peer review process for Clinical Directors and other BOP physicians who directly supervise clinical employees, as appropriate, an evaluation of the management of inmates at increased risk for colorectal cancer.

Standardize the process for ordering, or otherwise documenting within the Bureau Electronic Medical Records System, when a future screening is required for inmates at increased risk for colorectal cancer.

Ensure the Alliance develops and implements written policies and procedures for awarding VOCA funds and ensuring that the selection process is documented to demonstrate how VOCA funds were awarded
among Alliance member centers.

Ensure the Alliance communicates all subaward and VOCA-specific requirements to its member centers going forward.

Ensure that the Alliance implements its risk assessment tool to inform its subrecipient monitoring activities.

Ensure the Alliance designs and implements a monitoring plan that demonstrates how planned activities will adhere to its risk-based monitoring requirement.

Ensure the Alliance completes its annual financial site visits in accordance with its Member Center Financial Oversight Policy and implements its updated procedures requiring follow-up with member centers when findings are identified.

Ensure the Alliance enhances its programmatic monitoring policies and procedures to include substantive procedures detailing how monitoring officials should review program-related information and develop procedures to ensure that member centers comply with VOCA requirements.

Ensure the Alliance develops and implements written policies and procedures for taking timely and corrective action on all monitoring findings significant within the context of the VOCA program.

Ensure the Alliance develops and implements a strategy to ensure that subrecipient PMT data is complete and accurately reflects activities supported by VOCA.

Ensure the Alliance develops and implements updated written financial policies and procedures that ensure compliance with the DOJ Grants Financial Guide requirement that drawdowns be based upon
immediate disbursement or reimbursement needs.

Ensure Connecticut develops and implements updated written financial policies and procedures that ensure compliance with the DOJ Grants Financial Guide requirement that drawdowns be based upon
immediate disbursement or reimbursement needs.