RESTORE Act Operational Self-Assessment

RESTORE Act
Direct Component and Centers of Excellence Research Grants Program
Operational Self-Assessment (OSA)
Department of the
Treasury
OMB Approval No. 1505-0250

On July 6, 2012, the President signed the Resources and Ecosystems Sustainability, Tourist
Opportunities, and Revived Economies of the Gulf Coast States Act of 2012 (RESTORE Act) into law.
The Act establishes a Trust Fund in the Treasury of the United States, known as the Gulf Coast
Restoration Trust Fund. Under the Act, amounts in the Trust Fund are available for programs,
projects, and activities that restore and protect the environment and economy of the Gulf Coast
region.
The Act gives Treasury several roles in administering the Trust Fund. For the Direct Component and
Centers of Excellence Research Grants Program, Treasury is responsible for determining eligibility
and monitoring compliance with other requirements in the RESTORE Act and federal laws and
policies on grants.
Treasury’s RESTORE Act guidance requires that all eligible entities under the Direct Component
and the Centers of Excellence Research Grants Program complete an operational self-assessment
(OSA) prior to receiving funding and once a year thereafter. The OSA focuses on operational
internal control areas and will be used, in part, to assist Treasury in determining an appropriate
compliance monitoring protocol. The OSA is not intended to provide guidance regarding
compliance or audit requirements, but simply as a data gathering tool.
Please email your completed responses to [email protected]

Organization Information
Entity Name
OSA Completed By
Job Title
Contact Details

Email

Phone
number

Entity Address
Date OSA Completed
Comments
According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays
a valid OMB control number. The valid OMB control number for this information collection is 1505-0250. Comments concerning the
time required to complete this information collection, including the time to review instructions, search existing data resources, gathering
and maintaining the data needed, and completing and reviewing the collection of information, should be directed to the Department of
the Treasury, Office of Gulf Coast Restoration, 1500 Pennsylvania Ave., NW, Washington, DC 20220.

Page 1

Self-Assessment Questions
Environment
Questions

Please respond
“YES” or “NO”

1. Does management promote open communications
throughout the organization and effectively provide
information to employees and other stakeholders?

Y

N

2. Does management model and support ethical
behavior?

Y

N

3. Is adequate training and supervisory oversight
provided to all employees to ensure that the
organization effectively carries out its programs and
activities, including employees working on federal
grant programs?

Y

N

Y

N

Y

N

6. Does the organization periodically assess and
maintain proper segregation of duties?

Y

N

7. Are the organization’s internal controls in
compliance with guidance in ‘‘Standards for
Internal Control in the Federal Government’’
issued by the Comptroller General of the
United States and the ‘‘Internal Control
Integrated Framework’’, issued by the
Committee of Sponsoring Organizations of the
Treadway Commission (COSO)?

Y

N

Y

N

9. Is there a written conflict of interest policy that is
reviewed and signed off by employees at least
annually?

Y

N

10. Is anti-fraud awareness training conducted at least
annually that is evidenced by attendance sheets or
other mechanisms?

Y

N

Y

N

4. Do policies, procedures and processes for
managing federal grant funds meet the
requirements of OMB 2 CFR Chapter I and
Chapter II, Uniform Administrative
Requirements, Cost Principles and Audit
Requirements for Federal Awards?
5. Are policies, procedures and processes regularly
reviewed, updated and created to ensure that the
organization effectively carries out its
programs and activities, including updates that
may be needed for federal grant funds?

8. Is there a written code of conduct that is reviewed
and signed off by employees at least annually?

11. Are there formal policies and procedures in place for
employees to confidentially report suspected
violations of policies and or suspected instances of
fraud or other criminal activity, including specifically
those related to federal grant programs?

Comments

Page 2

12. Are breaches of policy and/or instances of fraud or
other criminal activity addressed by management?
Including taking steps to prevent future violations?
Does the policy include notification to the
appropriate federal agency in cases of confirmed
fraud related to federal funds?
13. Does the organization complete criminal and
financial background checks on employees?

Y

N

Y

N

Risk Assessment
Questions
14. Does the organization have a formalized internal
control program and risk assessment methodology
for managing and monitoring operational and
financial risks that is periodically tested and updated
as needed?
15. Does the organization maintain a formalized
compliance program for managing and monitoring
risks associated with regulatory compliance?
16. Does the organization have a formalized risk
assessment process in place specifically for federal
grant programs, including standard forms and
checklists, for assessing subrecipient eligibility and
monitoring performance?

Please respond
“YES” or “NO”

Comments

“YES” or “NO”
Y

N

Y

N

Y

N

Objectives
Please confirm that internal controls, including written policies, procedures, processes,
systems and reporting, exist and meet The Standards for Internal Control in the Federal
Government (GAO-14-704G) issued by the U.S. Government Accountability Office
(“Green Book”); Treasury’s RESTORE Act Financial Assistance Standard Terms and
Conditions; and OMB 2 CFR Chapter I and Chapter II, Part 200 Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards, and that the
following objectives are being met:
Questions
17. Allowable / Unallowable Activities & Costs - An
effective system of internal controls exists to provide
reasonable assurance that federal awards are
expended only for allowable activities and that the
costs of goods and services charged to federal
awards are allowable and in accordance with the
applicable cost principles.
18. Cash - An effective system of internal controls exists
to provide reasonable assurance that the (1)
drawdown of federal cash is only for immediate
needs, (2) reimbursement is requested only after
costs have been incurred, (3) Entities comply with
applicable Treasury agreements, and (4) recipients
limit payments to subrecipients to immediate cash
needs.

Please respond
“YES” or “NO”

Y

N

Y

N

Comments

Page 3

19. Davis-Bacon Act - An effective system of internal
controls exists to provide reasonable assurance that
contractors and subcontractors were properly
notified of the Davis-Bacon Act requirements and
the required certified payrolls were submitted to the
non-federal entity.
20. Eligibility - An effective system of internal controls
exists to provide reasonable assurance that only
eligible individuals and organizations receive
assistance under federal award programs and that
subawards are made only to eligible subrecipients.
21. Equipment & Real Property - An effective system of
internal controls exists to provide reasonable
assurance that proper records are maintained for
equipment acquired with federal awards, equipment
is adequately safeguarded and maintained,
disposition or encumbrance of any equipment or
real property is in accordance with federal
requirements, and the federal awarding agency is
appropriately compensated for its share of any
property sold or converted to non-federal use.
22. Matching, Level of Effort, Earmarking - An effective
system of internal controls exists to provide
reasonable assurance that matching, level of effort,
or earmarking requirements are met using only
allowable funds or costs which are properly
calculated and valued.
23. Availability - An effective system of internal controls
exists to provide reasonable assurance that federal
funds are used only during the authorized period of
availability.
24. Procurement, Suspension & Debarment - An
effective system of internal controls exists to provide
reasonable assurance that procurement of goods
and services are made in compliance with the
provisions of 2 CFR 200 and that covered
transactions (as defined in the suspension and
debarment common rule) are not made with a
debarred or suspended party.
25. Program Income - An effective system of internal
controls exists to provide reasonable assurance that
program income is correctly earned, recorded, and
used in accordance with the program requirements.
26. Real Property Acquisition & Relocation - An
effective system of internal controls exists to provide
reasonable assurance of compliance with the real
property acquisition, appraisal, negotiation, and
relocation requirements.
27. Reporting - An effective system of internal controls
exists to provide reasonable assurance that reports
of federal awards submitted to the federal awarding
agency include all activity of the reporting period,
are supported by underlying accounting or
performance records, and are fairly presented in
accordance with program requirements.

Y

N

Y

N

Y

N

Y

N

Y

N

Y

N

Y

N

Y

N

Y

N

Page 4

28. Subrecipient Monitoring - An effective system of
internal controls exists to provide reasonable
assurance that federal award information and
compliance requirements are identified to
subrecipients, subrecipient activities are monitored,
subrecipient audit findings are resolved, and the
impact of any subrecipient noncompliance on the
pass-through entity is evaluated. Also, the passthrough entity should perform procedures to provide
reasonable assurance that the subrecipient
obtained required audits and takes appropriate
corrective action on audit findings.
Self-Assessment Questions
Information & Communication
Questions
29. External and internal Communication channels are
established between organization and (1) federal
agency (2) state agencies (3) sub-recipients and (4)
contractors and vendors and (5) other stakeholders.
30. Information related specifically to federal fund
awards, including grant agreements, program
guidelines, legal requirements, required reporting
and other requirements are communicated to
relevant internal and external stakeholders.
31. Information systems and accounting systems are in
place and designed to meet all federal program
requirements, including reporting and record
retention requirements.
32. Information systems policies and procedures exist
for the safeguarding of data, including personally
identifiable information (PII), authorization and
addition of system users, termination of user rights,
information back-up and recovery, and retention and
destruction of data.
33. The organization performs vulnerability, penetration
and disaster recovery testing on IT and data storage
systems and has documented these processes and
testing outcomes.
34. Access to data, including PII, is protected against
unauthorized access and is limited to appropriate
individuals based on job functions.
Monitoring
Questions

Y

N

Please respond
“YES” or “NO”

Y

N

Y

N

Y

N

Y

N

Y

N

Y

N

Please respond
“YES” or “NO”

35. Are the associated grant fund operations regularly
assessed by an internal auditor, Inspector General
and external audit function (A-133)?

Y

N

36. Does the organization formally respond to all
internal audit, Inspector General and external audit
findings in writing and make timely corrections?

Y

N

37. Does management periodically review all reports,
deliverables, expenditures, and other requirements
related to federal grant programs to ensure that
guidelines and requirements are being met?

Y

N

Comments

Comments

Page 5

CERTIFICATION OF APPLICANT'S AUTHORIZED OFFICIAL (REQUIRED)
I certify that the statements made on this form are true, accurate, and complete. I acknowledge that any
knowingly false or misleading statement may be punishable by fine or imprisonment or both under the
applicable law.
Name of Authorized
Official
Title of Authorized
Official
Signature
Date

Page 6