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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Analysis of Office of
Inspector General Policies
and Procedures Addressing
CIGIE Quality Standards
Report No. 12-N-0516
June 4, 2012
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Report Contributors: Carolyn J. Hicks
Tina Lovingood
Kevin L. Christensen
Anthony Grear
Abbreviations
CIGIE
Council of the Inspectors General on Integrity and Efficiency
CPE
Continuing Professional Education
ECIE
Executive Council on Integrity and Efficiency
EPA
U.S. Environmental Protection Agency
IG
Inspector General
IO
Immediate Office
OA
Office of Audit
OC
Office of Counsel
OCOS
Office of the Chief of Staff
OCPA
Office of Congressional and Public Affairs
OI
Office of Investigations
OIG
Office of Inspector General
PCIE
President's Council on Integrity and Efficiency
PMH
Project Management Handbook
QA
Quality Assurance
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotiirie@epa.aov write: EPA Inspector General Hotline
phone: 1-888-546-8740 1200 Pennsylvania Avenue NW
fax: 202-566-2599 Mailcode 2431T
online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
12-N-0516
June 4, 2012
Why We Did This Review
We analyzed U.S. Environmental
Protection Agency (EPA) Office of
Inspector General (OIG) policies
and procedures addressing the
Council of the Inspectors General
on Integrity and Efficiency (CIGIE)
Quality Standards for Federal
Offices of Inspector General
(Silver Book). We sought to
determine whether the EPA OIG
has adequate policies, procedures,
and other guidance that will help
ensure compliance with the CIGIE
standards and to determine
compliance with our own internal
standards.
Background
CIGIE was statutorily established
as an independent entity within the
executive branch by the Inspector
General Reform Act of2008.
The CIGIE mission is to address
integrity, economy, and
effectiveness issues that transcend
individual government agencies;
and to increase the professionalism
and effectiveness of personnel by
developing policies, standards, and
approaches to aid in the
establishment of a well-trained and
highly skilled workforce in the
offices of the Inspectors General.
For further information,
contact our Office of Congressional
and Public Affairs at (202) 566-2391.
The full report is at:
www.epa.gov/oiq/reports/2012!
20120604-12-N-0516.pdf
Analysis of Office of Inspector General
Policies and Procedures Addressing
CIGIE Quality Standards
What We Found
EPA OIG has policies and procedures or other guidance to satisfy Silver
Book requirements in all except one area. The one area lacking guidance
pertains to training for the auditors and evaluators and the responsibility of
key managers to ensure their staff members have the skills necessary to
match the OIG's needs.
We noted that 21 of the 28 policies and procedures reviewed, or 75 percent,
are past the required review date prescribed by EPA OIG Policy 001,
OIG Directives System. Of those 21 that are out of date, 48 percent are at
least 3 years overdue for review/update.
We concluded that our Policy 503, Allegations Against OIG Employees
(last approved September 2001), needs to be updated to be consistent with
current law and provisions. Further, we concluded that additional policies
and procedures need to be assessed by the responsible offices to determine
whether they are subject to Silver Book requirements or are sufficient to meet
those requirements. These policies and procedures cover management
challenges; annual plans; training provided to the Agency on fraud, waste,
abuse, and mismanagement; and the need for independent external peer
reviews.
What We Recommend
We recommend that the Inspector General direct offices we identified as
having policies, procedures, or other guidance past the required review date
to update them. We also recommend that the Inspector General direct
responsible offices to develop and issue necessary guidance and improve
current guidance.
Inspector General's Response
The Inspector General agreed with all recommendations and directed the
responsible OIG offices to provide specific milestone and/or completion
dates for their respective policies highlighted in the report.
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< H0? s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ V\l// Ū WASHINGTON, D.C. 20460
PRO^
OFFICE OF
INSPECTOR GENERAL
June 4,2012
MEMORANDUM
SUBJECT: Analysis of Office of Inspector General Policies and Procedures
Addressing CIGIE Quality Standards
Report No. 12-N-0516
FROM: Anthony Grear, Auditor
Immediate Office (on detail)
TO: Arthur A. Elkins, Jr.
Inspector General
Attached is our final report on our analysis of Office of Inspector General (OIG) policies and
procedures addressing the Council of the Inspectors General on Integrity and Efficiency (CIGIE)
Quality Standards for Federal Offices of Inspector General (Silver Book). This analysis of
whether our organization has adequate policies, procedures, and other guidance will help ensure
our compliance with the CIGIE standards. For our review, we selected overarching CIGIE
requirements and determined whether our policies and procedures met those requirements. We
explain the details of our process in the "Scope and Methodology" section of this report.
In your response to the draft report, you agreed with all recommendations and directed that the
responsible offices provide estimated completion dates to make the policies and procedures
current. Those offices provided estimated completion dates, which can be found in the
"Estimated Completion Dates for Recommendations" table in appendix A. We also made
revisions to the report for factual and clarity purposes where appropriate.
If you have any questions about this report and its recommendations, please contact Carolyn Hicks
at (202) 566-1238, Tina Lovingood at (202) 566-2906, Kevin Christensen at (202) 566-1007, or
Anthony Grear at (202) 566-2541.
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Analysis of Office of Inspector General Policies and 12-N-0516
Procedures Addressing CIGIE Quality Standards
Table of Contents
Purpose 1
Background 1
Noteworthy Achievements 2
Scope and Methodology 2
Results of Review 3
Policies and Procedures Out of Date 3
New Policy and Procedure Needed 4
Policy Needs Updating 4
Policies and Procedures Need to Be Assessed by Responsible Offices 5
Recommendations 6
IG Response and QA Evaluation 7
Appendices
A Estimated Completion Dates for Recommendations 8
B Analysis of OIG Policies and Procedures Addressing
Overarching Silver Book Requirements 9
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Purpose
The purpose of this review is to report the results of our analysis of whether
U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG)
policies, procedures, and other guidance conform with the Council of the
Inspectors General on Integrity and Efficiency (CIGIE) Quality Standards for
Federal Offices of Inspector General (Silver Book).1 These standards are the
overall quality framework for managing, operating, and conducting the work of
OIGs and are intended to guide the Inspector General (IG) community's efforts.
The objectives of this review were to determine whether EPA OIG:
Has policies and procedures to help ensure compliance with the Silver
Book.
Policies and procedures in place are current based on the expected review
date.
Background
The Inspector General Reform Act of2008 (P.L. 110-409), which amended the
Inspector General Act of1978, created the CIGIE by combining what were
formerly known as the President's Council on Integrity and Efficiency (PCIE) and
the Executive Council on Integrity and Efficiency (ECIE). The Inspector General
Reform Act of2008 established CIGIE as an independent entity within the
executive branch to:
Address integrity, economy, and effectiveness issues that transcend
individual government agencies; and
Increase the professionalism and effectiveness of personnel by developing
policies, standards, and approaches to aid in the establishment of a well-
trained and highly skilled workforce in IG offices.
The Silver Book contains quality standards for the management, operation, and
conduct of federal OIGs. The standards incorporate by reference the existing
professional standards for audit, investigation, inspection, and evaluation efforts.
OIGs have a special need for high standards of professionalism and integrity in
light of the mission of the IGs under the Act. Because of this special need, the
PCIE/ECIE adopted the general quality standards contained in the Silver Book.
The EPA OIG has developed Policy 001, OIG Directives System, to provide a
framework for identifying, developing, reviewing, approving, and assessing internal
OIG policies and procedures. EPA OIG policies and procedures are to be reviewed,
at a minimum, every 3 years from the date of issuance and be either (1) reissued
as is with a new approval date, (2) updated and reissued, or (3) rescinded. Offices
shall revise their policies and procedures sooner if new regulations, requirements,
1 http://www.ignet.gov/pande/standards/igstds.pdf
12-N-0516
1
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or processes dictate. IG Statements are in effect for 1 year from the date of
issuance, at which time they must be reviewed by the IG or a designee and be
either rescinded or incorporated into a new or existing EPA OIG policy or
procedure.
In our quality assurance report Measuring the Quality of Office of Inspector
General Reports Issued in Fiscal Years 2008 and 2009 (Report No. 10-N-0134,
issued June 2, 2010), we concluded that several recommendations from a
February 2008 quality assurance report had been implemented and helped to
improve the quality of reports and work processes. Although this current report is
not designed to be a follow-up to that report, both discuss areas for improvement
that are being addressed in a revision currently being undertaken of the EPA
OIG's Policy 101, Project Management Handbook (PMH).
Noteworthy Achievements
During our analysis we identified areas where some offices have already taken
steps to bring about necessary improvements. For example, the Office of
Investigations expects to issue its hotline policy for internal review by the end of
May 2012. The Office of Audit issued updated Policy and Procedure 102,
regarding independence. With the revision to the Government Auditing Standards
in December 2011, the Quality Assurance staff has begun a thorough review and
updating process to make the 2008 PMH current. The Office of the Chief of Staff
is developing a training policy and procedure that will address continuing
professional education (CPE), among other topics.
Scope and Methodology
We performed this review from December 2011 to March 2012. The scope of
work performed does not constitute an audit under generally accepted government
auditing standards. This review compared EPA OIG policies and procedures with
the October 2003 Silver Book. The review involved a study of the Silver Book
and the identification of significant requirements in areas including ethics,
internal controls, quality assurance, and human capital. Through our analysis we
identified 14 overarching requirements related to our work and cross-referenced
them to 28 policies, procedures, and other EPA OIG guidance (see appendix B).
These policies and procedures were the responsibility of the following OIG
offices:
Office of Audit (OA)
Office of Congressional and Public Affairs (OCPA)
Office of Counsel (OC)
Office of Investigations (OI)
Office of the Chief of Staff (OCOS), in the Immediate Office (IO)
Quality Assurance (QA), also in the IO
12-N-0516
2
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No Office of Program Evaluation or Office of Mission Systems policies and
procedures, within the scope of our review, relate to the standards established by
the Silver Book.
We evaluated OIG policies and procedures current as of December 31, 2011, to
determine whether or to what extent they addressed the Silver Book requirements.
We also took note of policies and procedures past the required review date (out of
date). Because of the highly technical nature of investigation functions, we
suggest that OI perform its own review of its significant policies and procedures
that may be subject to Silver Book requirements for independent external reviews.
Results of Review
Policies and Procedures Out of Date
We noted that 21 of the 28 policies and procedures reviewed, or 75 percent, are
past the required review date. Of those 21 that are out of date, 48 percent are at
least 3 years overdue for review/update. Table 1 provides a breakdown by type of
guidance; table 2 provides a breakdown by office.
Table 1: Out-of-date guidance (by type)
Status by type
Policies
Proc.
IG
stmts.
Other
internal
Totals
%of
totals
OIG guidance
reviewed
20
5
2
1*
28
OIG guidance
out of date
15
4
2
0
21
75%
Guidance at least
3 years out of date
6
3
1
0
10
48%
Source: OIG analysis.
*Personal Impairment Form
Table 2: Out-of-date guidance (by office)
Status by office
ocos
(IO)
OI
QA
(IO)
OC
OA
OCPA
Totals
OIG guidance
reviewed
9
9
4
4
1
1
28
OIG guidance
out of date
9
8
3
1
0
0
21
Guidance at least
3 years out of date
3
5
1
1
0
0
10
Source: OIG analysis.
12-N-0516
3
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New Policy and Procedure Needed
We found that EPA OIG has policies and procedures or other guidance to satisfy
the overarching Silver Book requirements we identified in all areas except one (a
list of the requirements and our conclusions is in appendix B). The OIG lacks an
office-wide policy pertaining to training and the responsibility of key managers to
ensure their staff members have the skills necessary to match the OIG's needs. We
noted that OI has a detailed internal training policy (EPA OIG Policy 202, Special
Agent Training, last approved July 2007). However, EPA OIG does not have a
training policy and procedure in place for staff required to maintain CPE hours.
According to the Silver Book:
To ensure that the OIG staff members collectively possess needed
skills, the Inspector General and key managers should assess the
skills of their staff members and determine the extent to which
these skills match the OIG's requirements. OIG management is
responsible for deciding the methods by which identified needs can
be met by hiring contractors or outside consultants, using staff
members who possess the requisite skills, developing staff
members and providing training, or recruiting new staff. Each OIG
must also ensure that staff members meet the requirements for
continuing professional education contained in the applicable
professional standards.
OCOS is developing a training policy and procedure that will likely address areas
of this Silver Book requirement not covered by existing guidance. The new policy
and procedure will need to ensure:
Staff members possess needed skills
Managers assess skills to match OIG requirements
Management decides upon methods to meet OIG requirements
Staff meets CPE requirements.
We met with OCOS on February 22, 2012, to discuss the roles of an EPA OIG
training officer and items we believe the new training policy and procedure need
to address. It is our understanding that only a policy document will be issued
initially, with a procedures document to follow.
Policy Needs Updating
We identified one area where our current guidance should be updated to be
consistent with a change in law. According to the Silver Book, Executive Order
12993, Administrative Allegations Against Inspectors General, provides an
independent investigative mechanism to ensure that administrative allegations
against IGs and OIG senior staff are expeditiously investigated and resolved. The
Inspector General Reform Act of2008 (P.L. 110-409 of October 14, 2008,
12-N-0516
4
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122 Stat. 4302) (IG Reform Act) established that CIGIE is to have an Integrity
Committee tasked with reviewing allegations of wrongdoing received against an
IG or a OIG staff member. CIGIE adopted policies and procedures for the
Integrity Committee in 2009. This statutorily-created Integrity Committee
assumes the responsibilities of the Integrity Committee that functioned previously
under Executive Orders 12805, Integrity and Efficiency in Federal Programs, and
12993. EPA OIG Policy 503, Allegations Against OIG Employees (last approved
September 2001), addresses allegations against the IG and senior OIG staff.
However, the policy needs to be updated to include appropriate references to the
IG Reform Act and current Integrity Committee policies and procedures.
Policies and Procedures Need to Be Assessed by Responsible Offices
The following three additional areas need to be assessed by the responsible offices
to determine whether they are sufficient to meet Silver Book requirements:
Management challenges (OA). EPA OIG Policy 009, OIG Strategic Plan
Policy, mentions management challenges, but neither the policy nor the
corresponding procedure addresses specific steps to develop/prepare them
(see appendix B, item #7).
Annual plan (OCOS). While the OIG has EPA OIG Policy 009,
OIG Strategic Plan Policy, and EPA OIG Policy 010, Two Year
Assignment Plan Policy, the OIG does not have an annual plan policy as
required by the Silver Book (see appendix B, item #8, requirement 3).
Training Agency on fraud, waste, abuse, and mismanagement (OI).
According to the Silver Book, "OIG planning should develop a strategy to
identify the causes of fraud, waste, abuse, and mismanagement in high-
risk agency programs, and to help agencies implement a system of
management improvements to overcome these problems" (see appendix B,
item #9). There is no EPA OIG policy to document the details of the
OIG's strategy. However, we met with OI staff and were provided copies
of instructive brochures and were informed that posters are placed
throughout EPA facilities. We verified that these brochures are accessible
at EPA's public Web site. We were also informed that OI performs some
briefings for the Agency in these areas.
We also identified six significant investigations-related policies and procedures
that appear to be subject to Silver Book requirements for independent external
review. According to the Silver Book, "Independent external reviews are
conducted by sources not assigned to the unit being reviewed. These reviews are
distinct from ongoing management and supervision, and encompass the entirety
of internal control, including administrative operations and professional services
(audits, investigations, inspections, and evaluations)" (see appendix B, item #5).
12-N-0516
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Following are the six key OI policies and procedures already in place that we
believe are subject to independent external review:
EPA OIG Policy 201, Authority and Responsibility of Special Agents
(last approved March 2007)
EPA OIG Policy 204, Firearms and Law Enforcement Equipment
(last approved December 2009)
EPA OIG Policy and Procedure 206, Case Administration
(last approved April 2005)
EPA OIG Policy 208, Confidential Funds, Sources of Information, and
Confidential Informants (last approved April 2008)
EPA OIG Policy and Procedure 209, Technical Surveillance
(last approved June 2005)
EPA OIG Policy 210, Undercover Operations (last approved
September 2008)
In our meeting with OI, we determined that OI undergoes external peer reviews
every 3 years. Based on a July 2011 review of OI's operations, including the
policies and procedures aforementioned, OI was found to be in compliance with
the quality standards established by CIGIE and the Attorney General's guidelines.
However, although the policies and procedures appear sufficient in substance,
they still need to be updated according to EPA OIG Policy 001, OIG Directives
System.
Recommendations
We recommend that the Inspector General:
1. Direct the offices of OA, OC, OCOS, OI, and QA to refer to appendix B
to identify policies and procedures they are responsible for reviewing to
ensure the policies and procedures are up to date according to EPA OIG
Policy 001, OIG Directives System.
2. Direct OCOS to finalize and issue training policy and procedures that
include, among other issue areas, instructions about CPEs (see appendix B,
item #12, "Training Policy").
3. Direct OC to update EPA OIG Policy 503, Allegations Against OIG
Employees, to include appropriate references to the Inspector General
Reform Act of2008 and current procedures for handling allegations (see
appendix B, item #1).
4. Direct offices to assess whether policies and/or procedures need to be
developed for management challenges (OA); an annual plan (OCOS); and
training of the Agency on fraud, waste, abuse, and mismanagement (OI).
12-N-0516
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IG Response and QA Evaluation
The IG agreed with all recommendations and directed OA, OC, OCOS, OI, and
QA to provide specific milestone and/or completion dates for their respective
policies highlighted in the report.
With regard to recommendation 3, OC is revising Policy 503 in its entirety to
capture IG Reform Act requirements, and other organizational changes that have
taken place within the OIG.
For recommendation 4, we were informed that OA will develop an EPA OIG
policy and procedure on developing top management challenges. Regarding
training of the Agency on fraud, waste, abuse, and mismanagement, we concluded
after meeting with OI that there is sufficient evidence of providing instruction to
the Agency and the general public on these areas.
In our draft report, we recommended that OI assess its significant policies and
procedures to determine whether the activity is subject to Silver Book
requirements for independent external reviews. We met with OI and confirmed
that OI undergoes an external peer review every 3 years. Part of this assessment
includes a review of its policies and procedures for compliance with CIGIE and
IG Act guidelines. OI successfully completed the most recent assessment, which
was reported in July 2011. Based on the results of this assessment, we concluded
that the OI policies and procedures we noted in this report were covered by the
peer review and therefore warranted a removal of a fifth recommendation that had
been in the draft report.
12-N-0516
7
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Appendix A
Estimated Completion Dates
for Recommendations
Recommendation
Description
Action
Office
Estimated
Completion
Date
1. Direct the offices of OA, OC, OCOS, Ol, and QA to refer to
appendix B to identify policies and procedures they are
responsible for reviewing to ensure the policies and
procedures are up to date according to EPA OIG Policy 001,
OIG Directives System.
Policy 503, Allegations Against OIG Employees
OC
8/15/12
Policy 009, OIG Strategic Plan Policy
OCOS
6/30/12
Policy 010, Two Year Assignment Plan Policy (Annual Plan)
OCOS
6/30/12
Policy 013, OIG Review of Regulations and Agency Directives
OCOS
9/30/12
Policy 301, Student Loan Repayment Program
OCOS
Completed
Policy 307, Workforce Diversity
OCOS
12/20/12
Policy 317, Documenting Training in the Training Information
System
OCOS
6/30/12
Policy 319, Workforce Planning
OCOS
9/30/12
Procedure 009, Strategic Planning Process
OCOS
6/30/12
Procedure 319, Workforce Planning: Guidance and
Procedures for the OIG
OCOS
9/30/12
Policy 201, Authority and Responsibility of Special Agents
Ol
9/30/12
Policy 206, Case Administration
Ol
9/30/12
Policy 208, Confidential Funds and Sources of Information and
Confidential Informants
Ol
9/30/12
Policy 209, Technical Surveillance
Ol
9/30/12
Policy 210 .Undercover Operations
Ol
9/30/12
Policy 610, Hotline Policy
Ol
9/30/12
Procedure 206, Case Administration
Ol
9/30/12
Procedure 209, Technical Surveillance
Ol
9/30/12
IG Statement No. 2, Measuring the Quality of Audit,
Evaluation and Public Liaison Assignments
QA
7/31/12
IG Statement No. 5, Completing and Archiving Assignments in
AutoAudit
QA
7/31/12
Policy 101, Project Management Handbook
QA
7/31/12
2. Direct OCOS to finalize and issue training policy and
procedures that include, among other issue areas,
instructions about CPEs (see appendix B, Item 12,
"Training Policy").
Training policy
OCOS
6/30/12
Training procedure
OCOS
6/30/12
3. Direct OC to update EPA OIG Policy 503, Allegations
Against OIG Employees, to include appropriate references to
the Inspector General Reform Act of 2008 and current
procedures for handling allegations (see appendix B, item 1).
Policy 503, Allegations Against OIG Employees
OC
8/15/12
4. Direct offices to assess whether policies and/or
procedures need to be developed for management
challenges (OA); an annual plan (OCOS); and training of the
Agency on fraud, waste, abuse, and mismanagement (Ol).
Management Challenges
OA
9/30/12
Annual Plan
OCOS
6/30/12
Training Agency on fraud, waste, abuse, and mismanagement
Ol
Completed
12-N-0516
8
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Appendix B
Analysis of OIG Policies and Procedures Addressing
Overarching Silver Book Requirements
EXPLANATION:
Policies and/or procedures that are yet to be developed or issued.
Policies and/or procedures out of date by at least 3 years.
Policies and/or procedures out of date by less than 3 years.
External guidance.
IG Statement #2 will be incorporated into the PMH currently under revision and when all working group recommendations are approved and implementation begins (Scorecard).
IG Statement #5 will be terminated once the procedures are incorporated into the PMH currently under revision.
Yes*
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
1
Executive Order 12993 ("Administrative Allegations Against Inspectors
General") provides an independent investigative mechanism to ensure
that administrative allegations against IGs and OIG senior staff are
expeditiously investigated and resolved. The order establishes a
PCIE/ECIE Integrity Committee to receive, review, and refer such
allegations. OIGs should maintain policies and controls to ensure that
allegations are handed consistent with the executive order. OIGs
should also have in place policies and procedures to ensure that
criminal allegations against the IG or senior OIG staff are appropriately
referred to the Attorney General.
Section B.,
pdf page
11/48
Policy 503
Allegations Against OIG
Employees
http ://oi g i n tra/pol icy/doc um
ents/OIGPol icy503.pdf
oc
09/01/01
09/01/04
Yes
Policy needs to be
updated to reflect
and refer to
inspector General
Reform Act of 2008,
and 2009 Integrity
Committee
procedures, which
supersedes
Executive Order
12993.
2
Personal impairments of staff members result from relationships and
beliefs that might cause OIG staff members to limit the extent of an
inquiry, limit disclosure, or weaken or slant their work in any way.
OIG staff are responsible for notifying the appropriate officials within
their organization if they have any personal impairments to
independence.
Section 2.,
pdf page
13/48
Policy 501
Standards of Conduct
http://oig i n tra/pol icy/doc um
en ts/Pol i cy 501 Sta n dards of
Conduct. FINAL. signed9-30-
11.pdf
oc
09/30/11
09/30/14
No
Appears sufficient.
12-N-0516
9
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REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
Procedure 501
Standards of Conduct
oc
09/30/11
09/30/14
No
Appears sufficient.
h ttp: //oi g i n tra/pol icy/doc um
ents/Procedure501 Standar
dsofConduct. FINAL, signed
9-30-11.pdf
Personal Impairments
Forms
oc
n/a
n/a
n/a
Appears sufficient.
h ttp: //oi g i n tra/D ocumentLibr
ary/documents/lmpairments
_Form.pdf
Policy 102
OIG Independence
OA
04/03/12
04/03/15
No
Appears sufficient.
h ttp://oig i n tra/pol icy/doc um
ents/Policy102finalsigned20
07.pdf
3
Factors external to the OIG may restrict the work or interfere with an
OIG's ability to form independent and objective opinions and
conclusions. External impairments to independence occur when the
OIG staff is deterred from acting objectively and exercising
professional skepticism by pressures, actual or perceived, from
management and employees of the reviewed entity or oversight
organizations. OIGs should have policies and procedures in place to
resolve or report external impairments to independence when they
exist.
Section 3.,
pdf page
14/48
Policy 102
OIG Independence
h ttp://oig i n tra/pol icy/doc um
ents/Policy102finalsigned20
07.pdf
OA
04/03/12
04/03/15
No
2011 Government
Auditing Standards
(Yellow Book)
Section 3.14e
Appears sufficient.
12-N-0516
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Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
4
The Inspector General should provide for an assessment of the risks
the OIG faces from both external and internal sources. Risk
assessment includes identifying and analyzing relevant risks
associated with achieving the OIG's objectives, such as those defined
in strategic and annual performance plans, and forming a basis for
determining how risks should be managed. Risk assessment
methodologies and the formality of their documentation may vary from
OIG to OIG, depending on the OIG's size, mission, and other factors.
Section D.
pdf page
20/48
Procedure 009
Strategic Planning Process
http: //oi g i n tra/pol icy/doc um
ents/OPAR-07.pdf
ocos
(IO)
06/25/04
06/25/06
Yes
Appears sufficient
but could better
explain risk
management
methodologies.
Risk assessment
covered in PMH.
Policy 009
OIG Strategic Plan Policy
http://oig i n tra/pol icy/doc um
ents/pol icy28.pdf
ocos
(IO)
06/16/03
06/16/06
Yes
Appears sufficient
but could better
explain risk
management
methodologies.
Risk assessment
covered in PMH.
Policy 010
Two Year Assignment Plan
Policy
http://oig i n tra/pol icy/doc um
ents/OIG_21_000.pdf
ocos
(IO)
10/13/04
10/13/07
Yes
Appears sufficient
but could better
explain risk
management
methodologies.
Risk assessment
covered in PMH.
Policy 101
Project Management
Handbook
http://oig i n tra/pol icy/doc um
ents/Pol icy 101 .PMH.Final.O
5.08.08.pdf
(applies to OPE, OA, and
OMS)
OA
(IO)
05/08/08
05/08/11
Yes
Appears sufficient.
PMH currently in
revision process.
12-N-0516
11
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
5
Independent external reviews are conducted by sources not assigned
to the unit being reviewed. These reviews are distinct from ongoing
management and supervision, and encompass the entirety of internal
control, including administrative operations and professional services
(audits, investigations, inspections, and evaluations). Quality
assurance is intended to assess the internal controls of the entire OIG
or specific OIG components. The Quality Assurance Program is a type
of independent review that focuses on complying with professional
standards in conducting professional services (see the Maintaining
Quality Assurance standard).
Section 3.,
pdf page
22/48
Policy 101
Project Management
Handbook
http: //oi g i n tra/pol icy/doc um
ents/Policy101 .PMH.Final.O
5.08.08.pdf
(applies to OPE, OA, and
OMS)
QA
(IO)
05/08/08
05/08/11
Yes
Appears sufficient.
PMH currently in
revision process.
Policy 006
OIG Quality Assurance
Program
QA
(IO)
07/21/11
07/21/14
No
Current and up to
date.
http://oig i n tra/pol icy/doc um
en ts/Pol i cy006Qu al i tyAss u r
anceProgram. Final.signed.
07-21-11_000.pdf
IG Statement No. 2
Measuring the Quality of
Audit, Evaluation and
Public Liaison Assignments
QA
(IO)
10/10/06
10/10/07
Yes*
Scorecard guidance.
This policy will be
updated after the
PMH is finalized.
http://oig i n tra/pol icy/doc um
ents/IGStmtNo.210-10-
06.pdf
IG Statement No. 5
Completing and Archiving
Assignments in AutoAudit
h ttp://oig i ntra/pol icy/doc um
ents/IGStmtNo.505-12-
10.pdf
QA
(IO)
05/12/10
05/12/11
Yes*
IG Statements will
terminate upon the
updating of the PMH
currently under
revision.
12-N-0516
12
-------
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
Standards that apply for
investigation's external peer
reviews (CIGIE) found at
http://www.ignet.gov/pande/
standards/i nvprg0509.doc
n/a
n/a
n/a
n/a
Policy 201
Authority and Responsibility
of Special Agents
h ttp: //oi g i n tra/pol icy/doc um
e n ts/Pol i cy 2013-18-
2007.pdf
OI
03/28/07
03/28/10
Yes
Covered under
external peer review
completed July
2011.
Policy 204
Firearms and Law
Enforcement Equipment
h ttp://oig i n tra/pol icy/doc um
e n ts/Pol i cy204Fi rearms 12-
08-2009.pdf
OI
12/08/09
12/09/12
No
Covered under
external peer review
completed July
2011.
Policy 206
Case Administration
h ttp://oig i n tra/pol icy/doc um
e n ts/O I-206PO LI CY. pdf
OI
04/26/05
04/26/07
Yes
Covered under
external peer review
completed July
2011.
Procedure 206
Case Administration
(including sections 1-8)
h ttp://oig i n tra/pol icy/doc um
ents/OI-
06PROCEDURE.pdf
OI
04/26/05
04/26/07
Yes
Covered under
external peer review
completed July
2011.
12-N-0516
13
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
Policy 208
Confidential Funds and
Sources of Information and
Confidential Informants
OI
04/24/08
04/24/11
Yes
Covered under
external peer review
completed July
2011.
h ttp: //oi g i n tra/pol icy/doc um
e n ts/ Pol i cy208Co nf i de n ti al F
unds.fianl.pdf
Policy 209
Technical Surveillance
h ttp://oig i n tra/pol icy/doc um
ents/pol icy209_002.pdf
OI
06/02/05
06/02/07
Yes
Covered under
external peer review
completed July
2011.
Procedure 209
Technical Surveillance
h ttp://oig i n tra/pol icy/doc um
ents/procedure09_002.pdf
OI
06/02/05
06/02/07
Yes
Covered under
external peer review
completed July
2011.
Policy 210
Undercover Operations
h ttp://oig i n tra/pol icy/doc um
ents/Policy210Undercover
Operations.pdf
OI
09/18/08
09/18/11
Yes
Covered under
external peer review
completed July
2011.
CIGIE's Guide for
Conducting External Peer
Reviews of the Audit
Organizations of
Federal Offices of Inspector
General (Appendix A)
n/a
n/a
n/a
n/a
Results from Peer
review evaluated.
12-N-0516
14
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
6
Each OIG shall establish and maintain a quality assurance program to
ensure that work performed adheres to established OIG policies and
procedures; meets established standards of performance, including
applicable professional standards; and is carried out economically,
efficiently, and effectively.
Section A.,
pdf page
23/48
Policy 101
Project Management
Handbook
http: //oi g i n tra/pol icy/doc um
ents/Policy101 .PMH.Final.O
5.08.08.pdf
(applies to OPE, OA, and
OMS)
OA
(IO)
05/08/08
05/08/11
Yes
Appears sufficient.
PMH currently in
revision process.
Policy 006
OIG Quality Assurance
Program
OA
(IO)
07/21/11
07/21/14
No
Current and up to
date.
http://oig i n tra/pol icy/doc um
en ts/Pol i cy006Qu al i tyAss u r
anceProgram. Final.signed.
07-21-11_000.pdf
IG Statement No. 2
Measuring the Quality of
Audit, Evaluation and
Public Liaison Assignments
OA
(IO)
10/10/06
10/10/07
Yes*
Scorecard guidance.
This policy will be
updated after the
PMH is finalized.
http://oig i n tra/pol icy/doc um
ents/IGStmtNo.210-10-
06.pdf
IG Statement No. 5
Completing and Archiving
Assignments in AutoAudit
h ttp://oig i ntra/pol icy/doc um
ents/IGStmtNo.505-12-
10.pdf
OA
(IO)
05/12/10
05/12/11
Yes*
IG Statements will
terminate upon the
updating of the PMH
currently under
revision.
12-N-0516
15
-------
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
7
Each OIG shall maintain a planning system assessing the nature,
scope, and inherent risks of agency programs and operations. This
assessment forms the basis for establishing strategic and performance
plans, including goals, objectives, and performance measures to be
accomplished by the OIG within a specific time period.
Section A.,
pdf page
27/48
Procedure 009
Strategic Planning Process
http: //oi g i n tra/pol icy/doc um
ents/OPAR-07.pdf
ocos
(IO)
06/25/04
06/25/06
Yes
Appears sufficient.
Audit plans that
consider risk are
presented to Agency
annually as well as
management
challenge
assessments.
Policy 009
OIG Strategic Plan Policy
http://oig i n tra/pol icy/doc um
ents/pol icy28.pdf
ocos
(IO)
06/16/03
06/16/06
Yes
Appears sufficient.
Policy 010
Two Year Assignment Plan
Policy
http://oig i n tra/pol icy/doc um
ents/OIG_21_000.pdf
ocos
(IO)
12/13/04
12/13/07
Yes
Appears sufficient.
Policy 101
Project Management
Handbook
http://oig i n tra/pol icy/doc um
ents/Pol icy 101 .PMH.Final.O
5.08.08.pdf
(applies to OPE, OA, and
OMS)
OA
(IO)
05/08/08
05/08/11
Yes
Appears sufficient.
PMH currently in
revision process.
12-N-0516
16
-------
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
8
OIGs should develop an appropriate planning process, giving
consideration to the following elements.
1. Use a strategic planning process that carefully considers current
and emerging agency programs, operations, risks, and management
challenges. This analysis will identity the nature of agency programs
and operations, their performance measures and anticipated
outcomes, their scope and dollar magnitude, their staffing and
budgetary trends, their perceived vulnerabilities, and their inherent
risks.
2. Develop a methodology and process for identifying and prioritizing
agency programs and operations as potential subjects for audit,
investigation, inspection, or evaluation. The methodology should be
designed to use the most effective combination of OIG resources,
including previous OIG work and input from OIG staff. Also, the OIG
should consider the plans of other organizations both internal and
external to the agency.
3. Use an annual performance planning process that identifies the
activities to audit, investigate, inspect, or evaluate and translates these
priorities into outcome-related goals, objectives, and performance
measures. As part of this planning process, OIGs should consider
agency actions to address recommendations from prior OIG work.
Because resources are rarely sufficient to meet requirements, the OIG
must choose among competing needs.
Section B.,
pdf page
28/48
Procedure 009
Strategic Planning Process
http: //oi g i n tra/pol icy/doc um
ents/OPAR-07.pdf
ocos
(IO)
06/25/04
06/25/06
Yes
Appears sufficient.
Policy 009
OIG Strategic Plan Policy
http://oig i n tra/pol icy/doc um
ents/pol icy28.pdf
ocos
(IO)
06/16/03
06/16/06
Yes
Appears sufficient.
12-N-0516
17
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
Policy 010
Two Year Assignment Plan
Policy
h ttp: //oi g i n tra/pol icy/doc um
ents/OIG_21_000.pdf
ocos
(IO)
12/13/04
12/13/07
Yes
Appears sufficient.
It is not clear at this
point whether
developing
"outcome"-related
goals is still the
federal government
plan since the
Program
Assessment Rating
Tool (PART)
process has been
placed on hold.
Policy 101
Project Management
Handbook
h ttp://oig i n tra/pol icy/doc um
ents/Policy101 .PMH.Final.O
5.08.08.pdf
(applies to OPE, OA, and
OMS)
OA
(IO)
05/08/08
05/08/11
Yes
Appears sufficient.
PMH currently in
revision process.
12-N-0516
18
-------
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
9
OIG planning should develop a strategy to identity the causes of fraud,
waste, abuse, and mismanagement in high-risk agency programs, and
to help agencies implement a system of management improvements
to overcome these problems. OIG prevention efforts may include the
following:
1. A routine procedure for OIG staff to identity and report prevention
opportunities as these may come up in their work, and for OIG
managers to refer these to agency management, as appropriate;
2. Special awareness and training initiatives designed to alert agency
employees to systemic weaknesses in the programs and operations of
their agencies;
3. Review and comment on initial design of new agency programs and
operations;
4. Analyses of audit, investigative, and other OIG reports to identity
trends and patterns;
5. Education and training to ensure that appropriate OIG staff have
requisite abilities in the loss prevention area, as well as fraud detection
and prevention; and
6. An effective means for tracking the implementation of
recommendations.
Section D.,
pdf page
30-31/48
Policy 101
Project Management
Handbook
http: //oi g i n tra/pol icy/doc um
ents/Policy101 .PMH.Final.O
5.08.08.pdf
OA
(IO)
05/08/08
05/08/11
Yes
Appears sufficient.
PMH currently in
revision process.
10
The Inspector General should timely advise department and agency
heads, consistent with requirements of confidentiality, of any agency
official who attempts to impede or fails to require a contractor under
his or her responsibility to desist from impeding an audit, investigation,
inspection, evaluation, or any other OIG activity.
Section
B.2., pdf
page 32/48
Policy 102
OIG Independence
http://oig i n tra/pol icy/doc um
ents/Policy102finalsigned20
07.pdf
OA
04/03/12
04/03/15
No
12-N-0516
19
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
11
Each OIG's process for ensuring that its staff members possess the
requisite qualifications should encompass processes for recruiting,
hiring, continuously developing, training, and evaluating their staff
members, and succession planning to assist the organization in
maintaining a workforce that has the ability to meet the OIG's mission.
Section B.,
pdf page
36/48
Policy 319
Workforce Planning
http: //oi g i n tra/pol icy/doc um
ents/Policy319WorkforcePI
anningPoliey.pdf
ocos
(IO)
03/20/06
03/20/09
Yes
Policy needs new
office titles, etc.
Procedure 319
Workforce Planning:
Guidance and Procedures
for the OIG
ocos
(IO)
03/20/06
03/20/09
Yes
Requires additional
analysis by
responsible office.
http://oig i n tra/pol icy/doc um
ents/Procedure319Workfor
cePlanningGuidance.pdf
Policy 307
Workforce Diversity
ocos
(IO)
03/28/06
03/28/09
Yes
http://oig i n tra/pol icy/doc um
ents/Pol icy307Diversity.pdf
Policy 301
Student Loan Repayment
Program
ocos
(IO)
01/14/08
01/14/11
Yes
http://oig i n tra/pol icy/doc um
ents/Pol icy301 StudentLoan
Repayment.final.pdf
12-N-0516
20
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
12
To ensure that the OIG staff members collectively possess needed
skills, the Inspector General and key managers should assess the
skills of their staff members and determine the extent to which these
skills match the OIG's requirements. OIG management is responsible
for deciding the methods by which identified needs can be met by
hiring contractors or outside consultants, using staff members who
possess the requisite skills, developing staff members and providing
training, or recruiting new staff. Each OIG must also ensure that staff
members meet the requirements for continuing professional education
contained in the applicable professional standards.
Section D.,
pdf page
37/48
Policy 319
Workforce Planning
http: //oi g i n tra/pol icy/doc um
ents/Policy319WorkforcePI
anningPoliey.pdf
ocos
(IO)
03/20/06
03/20/09
Yes
Policy needs new
office titles, etc.
Procedure 319
Workforce Planning:
Guidance and Procedures
for the OIG
ocos
(IO)
03/20/06
03/20/09
Yes
No mention of CPEs
in the policies and
procedures listed.
http://oig i n tra/pol icy/doc um
ents/Procedure319Workfor
cePlanningGuidance.pdf
Policy 307
Workforce Diversity
ocos
(IO)
03/28/06
03/28/09
Yes
Appears sufficient.
http://oig i n tra/pol icy/doc um
ents/Pol icy307Diversity.pdf
Policy 301
Student Loan Repayment
Program
ocos
(IO)
01/14/08
01/14/11
Yes
Appears sufficient.
http://oig i n tra/pol icy/doc um
ents/Pol icy301 StudentLoan
Repayment.final.pdf
12-N-0516
21
-------
REVIEW DATES
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
Last
Updated
Update
Due
Review
Overdue?
C omm ents /Res o I uti o n
Policy 317
Documenting Training in
the Training Information
System
ocos
(IO)
04/25/06
04/25/09
Yes
Will be rescinded
when new training
policy is issued.
h ttp: //oi g i n tra/pol icy/doc um
ents/Pol icy317TIS.pdf
Training Policy
(UNDER DEVELOPMENT)
ocos
(IO)
n/a
n/a
n/a
Policy is currently in
development
process.
New policy will need
to address skills,
OIG requirements,
and CPEs.
13
Each OIG shall establish and maintain a system to review and
comment on existing and proposed legislation, regulations, and those
directives that affect either the programs and operations of the OIG's
agency or the mission and functions of the OIG. The system should
result in OIG recommendations designed to (1) promote economy and
efficiency in administering agency programs and operations;
(2) prevent and detect fraud and abuse in such programs and
operations; and (3) protect the integrity and independence of the OIG.
Section A.,
pdf page
38/48
Policy 611
OIG Legislative Review
Policy
http://oig i n tra/pol icy/doc um
ents/Pol icy611 Leg Review, s
igned10-26-09.pdf
OCPA
10/26/09
10/26/12
No
Policy 013
OIG Review of Regulations
and Agency Directives
ocos
(IO)
05/06/08
05/06/11
Yes
http://oig i n tra/pol icy/doc um
en ts/Pol i cy 013 Reg an d Di rec
tivesReview.05.06.08.pdf
12-N-0516
22
-------
Item
#
Requirement for OIG Policies
(Quoted from Silver Book)
Citation in
Silver Book
OIG Policy/Procedure
Number
Respons.
Office
REVIEW DATES
C omm ents /Res o I uti o n
Last
Updated
Update
Due
Review
Overdue?
14
Each OIG shall establish and follow policies and procedures for
receiving and reviewing allegations. This system should ensure that an
appropriate disposition, including appropriate notification, is made for
each allegation.
Section A.,
pdf page
40/48
Policy 610
Hotline Policy
http: //oi g i n tra/pol icy/doc um
ents/Pol icy61 OOI GHoti i neP
olicy12-28-2005.pdf
OI
12/28/05
12/28/07
Yes
Policy does not
discuss appropriate
disposition and how
OI and other parts of
the OIG will work
together during an
investigation and/or
after a referral.
According to OI
staff, a draft is being
processed.
12-N-0516
23
------- |