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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
May 1, 2014
MEMORANDUM
SUBJECT: EPA OIG's Compliance With EPA Passport Guidance
Report No. 14-B-0244
FROM: Kevin Christensen, Acting Assistant Inspector General
Office of Audit
TO:
Charles Sheehan, Deputy Inspector General
As part of our continuing work on internal controls as a result of the John Beale investigation, we
initiated an audit of the U.S. Environmental Protection Agency's internal controls over passport security.
We identified issues that impact the Office of Inspector General (OIG) and require immediate attention.
Action Required
Please provide a written response to this report within 60 calendar days. You should include planned
corrective actions and completion dates for the recommendations. Your response will be posted on the
OIG's public website, along with our memorandum commenting on your response. Your response
should be provided as an Adobe PDF file that complies with the accessibility requirements of Section
508 of the Rehabilitation Act of 1973, as amended. If your response contains data that you do not want
released to the public, you should identify the data for redaction or removal, along with corresponding
justification. We will post this report to our website at http://www.epa.gov/oig.
If you have any questions, please contact me at (202) 566-1007 or christensen.kevin@epa.gov; or
Robert Adachi, Director of Forensic Audits, at (415) 947-4537 or adachi.robert@epa.gov.
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U.S. Environmental Protection Agency
Office of Inspector General
EPA OIG s Compliance
With EPA Passport Guidance
Report No. 14-B-0244
May 1,2014
A
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Reasons for Review
~ Part of continuing work on internal controls in response
to a member of the U.S. Senate Committee on
Environmental and Public Works request for work in
connection with a fraud committed by John C. Beale.
~ As part of an audit of the U.S. Environmental Protection
Agency's (EPA's) vetting process for new employees, we
looked into the EPA's vetting of official passports.
~ Issues have been identified that impact the Office of
Inspector General (OIG) and require immediate
attention.
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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Scope and Methodology
Performed fieldwork from February 3 through March 19, 2014.
~ Conducted assignment in accordance with generally
accepted government auditing standards issued by the
Comptroller General of the United States.
~ Sought to determine whether the OIG had policies and
procedures associated with official passports.
~ Met with OIG Chief of Staff and Deputy Assistant Inspector
General for Investigations.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Scope and Methodology (cont'd.)
Reviewed the EPA's Office of International and Tribal Affairs
(OITA) universe of official passports to determine the number of
OIG personnel issued an official passport.
Requested that OIG's Office of Audit, Office of Program
Evaluation and Office of Investigations identify OIG staff most
likely to have an official passport.
Contacted some current OIG employees and one prior OIG
employee identified as being issued an official passport.
Conducted an audit of the agency's passport controls and will
issue a separate report about the results.
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Criteria-Official Passport
~ The Code of Federal Regulations, under 22 CFR 51.3 (b),
provides:
An official passport is issued to an official or employee of the
U.S. Government traveling abroad to carry out official duties.
~ Under 22 CFR 51.52 (b) and (b)(1), official passports are
exempt from fees when the individual is:
An officer or employee of the United States traveling on official
business.... The applicant must submit evidence of the official
purpose of the travel.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Criteria-Passport Acceptance Agents
~ Under 22 CFR 51.22 (b)(5), the U.S. Department of State is
authorized to select an employee of a federal agency to
accept passport applications on its behalf.
~ Within the EPA, four employees have been designated as
passport acceptance agents:
o Two are in the OITA.
o Two are in EPA Region 5.
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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Sensitive Personally
Identifiable Information
~ OITA website provides the following
guidance:
Official passports are controlled United States Government
documents and must be returned between trips to the Travel
Office of the Office of International and Tribal Affairs (OITA). Please
return your official passport to OITA within 15 days after
returning to the United States. When not in use for travel, all
official passports will be maintained in a secure facility within OITA.
All official passports must be forwarded to OITA for immediate
cancellation: if you retire; if you accept employment elsewhere
(even if at another government agency); or if you move to another
position within EPA that does not require official travel.
14-B-0244
@EPAoig
www.epa.gov/oig
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
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Sensitive Personally
Identifiable Information (cont'd.)
~ Official passports are sensitive personally identifiable
information (PII).
~ EPA Privacy Policy 2151.0 defines sensitive Pll as:
Social Security numbers, or comparable identification numbers...
Sensitive Pll, a subset of Pll, requires additional levels of security
controls.
~ OIG Policy 413 states:
Users must store hard copies of sensitive Pll in locked file cabinets
and limit access to only individuals who are authorized to use the
information.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Results
~ We found the OIG is not in compliance with EPA guidance
over the control and security of official passports issued
to OIG employees.
~ The total number of OIG employees with an official
passport is unknown.
~ The OIG does not have any policies and procedures
associated with official passports (i.e., the issuance,
control and security of official passports).
14-B-0244
OFFICE OF INSPECTOR GENERAL
\ U.S. Environmental Protection Agency @EPAoig
\ www.epa.gov/oig
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How Did This Happen?
Lack of knowledge within the OIG concerning official
passport requirements.
Lack of guidance and oversight from the OITA and the OIG
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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Why Is This Important?
~ Lack of compliance with OITA guidance may put the
OIG in the position where sensitive Pll is not being
adequately protected.
~ Lack of control could result in the release of sensitive
Pll due to missing, misused or improperly destroyed
official passports.
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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Total OIG Official Passports Unknown
~ OIG has no record of who was issued an official
passport or the passport's status.
Official passports identified
Current
employees
Former
employees
Total
Official passports held by OIG employees
and identified as an OIG employee by
OITA
3
2
5
Official passports held by OIG employees
and identified as an employee in an
agency office by OITA
4
1
5
Official passports not in OITA records
provided
0
1
1
TOTAL
7 4
11
@EPAoig
www.epa.gov/oig
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
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Location of Official Passports
OIG has no record of the location of official passports
issued. According to the OITA:
Current
Former
Location of passport*
employees
employees
Total
OITA Possession**
3
1
4
Traveler
4
2
6
Unknown
0
1
1
TOTAL
7
4
11
* Locations is based upon OITA records.
** Location in OITA records denotes passport as being in OITA possession.
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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OIG Official Passports Unknown
Based on information provided:
~ We could not determine how many employees came to
and left the OIG since OITA began compiling its records.
~ We could not determine how many employees obtained
an official passport.
~ We could not determine whether additional OIG
employees are identified as being part of other EPA offices
in the universe provided by OITA.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Lack of Policies and Procedures
~ OIG does not have any policies and procedures for the
issuance and control of official passports.
~ OIG's Office of Investigations is in the process of
preparing a policy and procedure for official passports
issued to its employees (that proposed procedure would
not be applicable to the OIG as a whole).
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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Lack of International Travel Coordinator
~ There is no international travel coordinator within the OIG.
~ The most recent OIG international travel coordinator retired over
2 years ago.
~ The international travel coordinator is the initial contact when
developing an international travel plan and provides instruction to
travelers on obtaining official passports.
~ The Fast International Approval Tracking database indicated three
OIG employees could have traveled internationally without having an
official passport. U.S. Department of State policy says federal
government employees on official international travel must travel
with their official passport. i4-B-c
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Official Passport Issuance
o Any future requests for an official passport should be
approved by the Inspector General prior to contacting
the OITA.
o One official passport was issued in 2013 without the approval of
OIG management. Employee followed instructions provided by
the OITA and paid a fee for the official passport.
o Payment of a fee defeats the benefit of an official, no-fee
passport.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Control and Security of Official
Passports for Current OIG Employees
~ All official passports need to be returned to the OITA
consistent with its guidelines.
~ According to the information provided by the OITA, seven
current OIG employees have official passports.
o Four passports are in the possession of the employees,
o Three passports are with the OITA.
~ Two official passports could not be located in the OITA's safe.
o Both passport were in the possession of the employees.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Proper Disposal of Official Passports
~ Official passports for employees leaving the OIG need to be
returned to the OITA. Guidelines for passport return are
posted on the OITA website.
~ We identified three employees who left the OIG with an
official passport.
o We were able to contact only one former employee, who stated
that he returned his official passport when he left the OIG.
However, there is no record that the official passport was ever
received or disposed of in accordance with OITA guidelines.
14-B-0244
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency
@EPAoig
www.epa.gov/oig
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Proper Disposal of Official Passports
(cont'd.)
~ OIG guidance in place at the initiation of audit fieldwork did not
include any information concerning official passports for employees
leaving the OIG.
~ A new separation and clearance procedure dated February 27, 2014,
was added to the OIG Intranet. The new procedure requires:
a. The OIG Office of Human Resources be made aware of its
responsibility to contact the OITA Passport Office when an OIG
employee is planning to separate from employment.
b. The OITA to confirm whether an official passport was issued to
the separating employee.
~ The new procedure was not disseminated OIG-wide.
14-B-0244
OFFICE OF INSPECTOR GENERAL
V U.S. Environmental Protection Agency @EPAoig
\ www.epa.gov/oig
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Recommendations
~ We recommend that the Deputy Inspector General:
1. Identify official passports issued to OIG employees.
2. Request that all official passports be returned to the OITA for proper
storage or cancellation.
3. Provide the OITA with the names and available passport numbers of
OIG employees whose passports have not been located, and
request that the OITA notify the U.S. Department of State.
14-B-0244
V
OFFICE OF INSPECTOR GENERAL
U.S. Environmental Protection Agency @EPAoig
www.epa.gov/oig
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Recommendations (cont'd.)
Develop and implement one OIG-wide policy and procedure to
include, at a minimum:
a. Designation of an international travel coordinator position and a
description of the coordinator's function and responsibilities.
b. Procedures for requesting an official passport.
c. A requirement that all OIG personnel traveling outside of the
United States on official government business obtain an official
passport prior to traveling.
d. A requirement that upon completion of travel the official
passport be returned in accordance with OITA guidelines.
14-B
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Planned
Rec.
Page
Completion
Claimed
Agreed To
No.
No.
Subject
Status1
Action Official
Date
Amount
Amount
21 Identify official passports issued to OIG employees. 0 Deputy Inspector General
2 21 Request that all official passports be returned to the
OITA for proper storage or cancellation.
3 21 Provide the OITA with the names and available
passport numbers of OIG employees whose
passports have not been located, and request that
the OITA notify the U.S. Department of State.
4 22 Develop and implement one OIG-wide policy and
procedure to include, at a minimum:
a. Designation of an international travel
coordinator position and a description of the
coordinator's function and responsibilities.
b. Procedures for requesting an official
passport.
c. A requirement that all OIG personnel
traveling outside of the United States on
official government business obtain an official
passport prior to traveling.
d. A requirement that upon completion of travel
the official passport be returned in
accordance with OITA guidelines.
0 Deputy Inspector General
0 Deputy Inspector General
0 Deputy Inspector General
1 0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
14-B-0244
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EPA OIG Distribution
Inspector General
Deputy Inspector General
Counsel to the Inspector General
Deputy Assistant Inspector General for Congressional and Public Affairs
14-B-0244
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