That the FBI assess the processes and procedures it uses to prepare for events that it determines present potential domestic security issues-but have not been designated as NSSE or SEAR events by DHS-to ensure that its processes and procedures set forth with clarity the division of responsibilities between and within the relevant FBI field office and FBI headquarters; clearly define a mechanism for making a formal determination whether and what kind of a nationwide intelligence and CHS canvass is necessary and appropriate under FBI policies; and provide sufficient guidance to ensure that relevant intelligence can be timely shared among the relevant FBI components and with non-FBI stakeholders.

Ensure that NWDCS establishes written policies and procedures specific to the performance reporting of VOCA-funded services and distributes this guidance to relevant personnel.

Ensure that NWDCS establishes written policies and procedures specific to the payroll process and distributes this guidance to relevant personnel.

Ensure that NWDCS develop and implement an incentive compensation policy that adheres to the requirements of the Uniform Guidance.

Ensure that FMC Devens Executive Leadership and the Central Office's Human Resource Management Division discuss the staffing projection tool methodology and how it compares with FMC Devens Executive Leadership's understanding of its current and potential future mission needs to ensure greater alignment between stakeholder staffing projections.

Ensure that FMC Devens follows BOP guidance for buprenorphine and naloxone administration and observation and that all FMC Devens employees who administer medication receive training on BOP guidance and policies for medication administration.

Ensure that FMC Devens develops a consistent and accurate medical record tracking procedure with the contracted company that includes regular and recurring reconciliation of outside inmate medical records between FMC Devens and the contracted company.

Ensure that FMC Devens follows the BOP Patient Care Policy for sick call and provides training to all FMC Devens Health Services Department employees on the policy, as well as on FMC Devens sick call procedures.

Ensure that all FMC Devens inmates over age 50 are receiving preventive healthcare screenings, including cognitive impairment screening.

Ensure that FMC Devens verifies the credential files of all providers prior to allowing them to administer care to inmates, and ensure that FMC Devens completes peer reviews in accordance with BOP policy.

Ensure that inmates admitted to and housed in the Memory Disorder Unit are appropriately placed in accordance with FMC Devens's established criteria.

Ensure that FMC Devens adheres to BOP policy on medical inmate companion screening and hiring and that FMC Devens employees screening and hiring these companions are trained on the policies and procedures.

In order for senior leadership to be able to consider and decide matters potentially raising constitutional separation of powers issues, we recommend that the Department evaluate when advance notification to a senior Department official, such as the Deputy Attorney General or Attorney General, should be required before compulsory process is issued, and any corresponding NDOs are sought, for records of a Member of Congress or congressional staffers and establish, as necessary, implementing policies and guidance.

We recommend that the Department consider whether there are circumstances in which an exhaustion requirement should be a prerequisite for issuing compulsory process to obtain records of Members of Congress and congressional staffers.

Ensure West Virginia JCS develops policies and procedures to ensure compliance with victim assistance priority areas funding requirements.

Ensure West Virginia JCS: (1) updates its VOCA Administrative Manual with applicable VOCA Fix and federal award requirements, and (2) periodically reviews and makes necessary updates to the document to ensure compliance with federal statutes, regulations, and the award terms and conditions.

Work with West Virginia JCS to establish a monitoring mechanism that will ensure that it adheres to the frequency of on-site monitoring visits, as required by its policies.

Coordinate with West Virginia JCS to establish procedures, such as staff instructions and control mechanisms, to: (1) maintain a comprehensive schedule of monitoring activities, (2) ensure monitoring actions effectively assess subrecipients' implementation of VOCA-funded programs, (3) develop and provide to subrecipients reports of monitoring activities complete with required signatures in accordance with West Virginia JCS policies, and (4) pursue and close out monitoring report findings and recommendations.

Remedy $198,099 in unsupported subaward expenditures.

Require West Virginia JCS to establish adequate controls to ensure its monitoring staff performs monthly financial reviews in compliance with the West Virginia JCS policies and that it maintains evidence to support all claimed subrecipient expenditures reviewed as part of monitoring activities.

Work with West Virginia JCS to develop and implement written policies and procedures to ensure compliance with the Uniform Guidance requirements for pass-through agency action on subrecipient single audit reports.

Ensure West Virginia JCS updates its policies and procedures to implement a process to collect, verify, and maintain monthly progress reports and their respective support.

Ensure West Virginia JCS updates its policies and procedures to implement a process to collect, verify, maintain, and provide accurate data to the OVC that measures the performance and effectiveness of activities funded by the VOCA awards.

Require West Virginia JCS to: (1) reconcile and correct its SARs and its subaward list for the audited grants to ensure OVC has accurate information for those previously awarded VOCA subawards, and (2) implement procedures to ensure that West Virginia JCS' subaward list and SARs are accurate and submitted timely as well as periodically reviewed to make necessary updates.

Remedy $24,464 in unallowable questioned costs related to excess administrative expenditures beyond the 5-percent allowance charged to the 2018 award.

Require West Virginia JCS to develop and implement written policies and procedures to ensure compliance with the 5-percent administrative expenditure limit.

Remedy $16,168 in unsupported questioned costs related to non-personnel administrative costs.

Require West Virginia JCS to enhance its written drawdown policies and procedures to include: (1) an adequate system of internal controls over the disbursement of VOCA funds to ensure funds are only provided to subrecipients for allowable costs that were incurred, and (2) supervisory review (or another control) of the reconciliation process used to calculate drawdown amounts to ensure West Virginia JCS does not request funds in excess of its needs.

Remedy $196,776 in unallowable questioned costs related to excess drawdowns for the 2018 award.

Require West Virginia JCS to train its financial staff on the DOJ Grants Financial Guide FFR requirements and the instructions within the West Virginia JCS' Accounting Policies and Procedures.