Implementation of the IT Modernization Centers of Excellence Improvements
OCIO should seek an Office of the General Counsel (OGC) opinion to determine if an Antideficiency Act violation occurred due to the lack of E-Board concurrence for the CoE initiative, and, if a violation did occur, take appropriate legal and administrative action.
OCIO needs to develop an effective mechanism to ensure the AAR process is followed.
OCIO should seek an OGC opinion to determine if an Antideficiency Act violation occurred regarding the classification of the CoE initiative as capital investments, and, if a violation occurred, take appropriate legal and administrative action. (Note: The Recommendation 3 amount is $22,581,550, and is a subset of the amount from Recommendation 1. To avoid an incorrect grand total, we put “$1” for this amount in ARGOS, and reduced the Recommendation 1 amount by $1.)