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OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Quality Assurance Report
Quality Assurance Review
of Three Resource Centers in
Office of Investigations
Report No. 08-A-0036
November 20, 2007
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Report Contributor:
Mathew Walinski
Abbreviations
AIGI
Assistant Inspector General for Investigations
CRC
Central Resource Center
DOJ
Department of Justice
ECIE
Executive Council on Integrity and Efficiency
EPA
U.S. Environmental Protection Agency
ERC
Eastern Resource Center
FBI
Federal Bureau of Investigation
HQ
Headquarters
LEO
Law Enforcement Officer
LETS
Law Enforcement Tracking System
01
Office of Investigations
OIG
Office of Inspector General
PCIE
President's Council on Integrity and Efficiency
QAR
Quality Assurance Review
QCRS
Quarterly Case Review Sheet
ROI
Report of Investigation
SA
Special Agent
SAC
Special Agent-in-Charge
TIGER
The Inspector General Enterprise Resource
WRC
Western Resource Center
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
November 20, 2007
MEMORANDUM
SUBJECT: Quality Assurance Review of Three Resource Centers in
Office of Investigations
Report No. 08-A-0036
FROM: Robert K. Bronstrup /s/
Special Assistant to the Acting Inspector General
TO: Bill A. Roderick
Attached is the consolidated report of our quality assurance review of three resource centers in
the Office of Investigations. We performed this quality assurance review as part of the Office of
Inspector General's ongoing quality assurance program that covers all Office of Inspector
General activities. The overall purpose of this specific review was to determine whether internal
control systems are in place and operating effectively to provide reasonable assurance that
professional investigative standards are followed.
As part of this assignment, we issued a separate quality assurance review report to each of the
three resource centers. For each report, we required a response from the Special Agent-in-
Charge and from the Assistant Inspector General for Investigations. We include their comments
in the body of this report. As part of the review at each location, we held a meeting with the
Office of the United States Attorney for the district(s) where the specific offices were located.
At each resource center, we also met with another Federal law enforcement agency with which
the Office of Investigations has conducted a joint investigation. We held an exit conference with
the Assistant Inspector General for Investigations on August 28, 2007.
If you have any questions about the final report or our observations and recommendations, please
contact me at 312-886-7169.
Deputy Inspector General
cc: Assistant Inspector General for Investigations
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Quality Assurance Review of Three Resource Centers
in Office of Investigations
Table of Contents
Introduction 1
Purpose 1
Background 1
Scope and Methodology 1
Noteworthy Achievements 3
Summary of Results 3
Evidence 4
Grand Jury Material 6
Law Enforcement Equipment 7
Technical Equipment 10
Firearms 11
Firearms Training and Qualifications Requirements 13
Ammunition 15
Open Cases 16
Closed Cases 20
Other Matters 24
Exit Briefing with the Office of Investigations 25
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Introduction
From February 2007 to June 2007, the U.S Environmental Protection Agency's (EPA's)
Office of Inspector General (OIG) conducted a Quality Assurance Review (QAR) of the
Office of Investigations (01) at three resource centers. To conduct this review, Special
Agent (SA) Mathew Walinski was temporarily assigned to the OIG, QAR Team, and
under the direct supervision of Robert Bronstrup.
Purpose
The purpose of the QAR is to determine whether internal controls systems are in place
and operating effectively to provide reasonable assurance that professional investigative
standards are being followed. This process is intended to be positive and constructive
rather than negative or punitive.
Background
This QAR is based, in part, on the Inspector General Act of 1978, as amended (Public
Law 95-452); the President's Council on Integrity and Efficiency (PCIE)/Executive
Council on Integrity and Efficiency (ECIE) Quality Standards for Investigations
(December 2003); and the Attorney General Guidelines for Offices of Inspector General
with Statutory Law Enforcement Authority (December 8, 2003). These standards and
guidelines are further delineated and amplified by OI's policies and procedures.
The Quality Standards for Investigations were developed by the PCIE and the ECIE.
The Standards contain three general standards and four qualitative standards. The
general standards (Qualifications, Independence, and Due Professional Care) apply to
investigators and the organizational environment in which they perform. The qualitative
standards (Planning, Execution, Reporting, and Information Management) apply to the
management functions and processes that investigators perform.
Th q Attorney General Guidelines for Offices of Inspector General with Statutory Law
Enforcement Authority govern the exercise of statutory law enforcement powers by
offices of Inspectors General and eligible employees.
Scope and Methodology
The QAR of the OI was conducted as part of the OIG's ongoing quality assurance
program. This specific quality assurance review was conducted utilizing the PCIE/ECIE
Qualitative Assessment Review Guidelines [QAR Guidelines] for Federal Offices of
Inspector General, Appendix B, Appendix C, and Appendix D, with references, and the
corresponding policies and procedures of the OI. The review covered the following
locations: (1) Central Resource Center (CRC) (Chicago and Dallas offices); (2) Western
Resource Center (WRC) (San Francisco and Seattle offices); and Eastern Resource
Center (ERC) (Atlanta and Philadelphia offices).
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The following "High Risk Vulnerably" areas were extrapolated from the QAR
Guidelines, along with applicable sections of the 01 policies and procedures after
consultation with the Acting Inspector General and the Assistant Inspector General for
Investigations (AIGI). The inspection review areas included Evidence, Grand Jury
Material, Law Enforcement Officer (LEO) Equipment, Technical Equipment, Firearms,
Firearms Training, Ammunition, a review of Open Cases using 8 criteria concerning case
planning and documentation and 5 criteria concerning case execution and documentation,
and a review of Closed Cases using 23 select criteria from the QAR Guidelines.
As part of the review, we reviewed open cases. Thirteen of 20 (65 percent) open
investigations in the CRC (all open cases in the Chicago and Dallas offices), 18 of 27
(66 percent) open investigations in the WRC (all open cases in the San Francisco and
Seattle offices), and 14 of 28 (50 percent) open investigations in the ERC (all open cases
in the Atlanta and Philadelphia offices) were reviewed during this inspection, resulting in
a total of 45 of 75 (60 percent) of the open cases in the three resource centers inspected.
We inspected the case plans, the required notification letters to the Federal Bureau of
Investigation (FBI), supervisory review of investigative activity, and contemporaneous
interview notes. We discuss each of these four inspection criteria in detail below. We
inspected each open case using 13 selected criteria from the QAR Guidelines, and
10 selected criteria deemed necessary from the Quality Standards for Investigations,
concerning the investigative plan. Thus, we reviewed a total of 1,035 individual
inspection points.
This quality assurance review included closed cases at the three resource centers. The
PCIE Guidelines, Planning and Performing the Investigative Qualitative Assessment
Review, Section 7, Sample Selection, require the inspection of a set number of closed
cases to ensure that investigations are conducted in a diligent and complete manner. The
number of cases to be reviewed is based on a pre-established sampling range of cases
closed during a selected period. During calendar year 2006, OI closed 163 investigations.
Based on the pre-established range, the size for 163 closed cases is 30. These 30 closed
cases were split between the three resource centers inspected. We judgmentally selected
cases which had criminal, civil, or administrative actions. We inspected each closed case
utilizing 22 selected criteria from the QAR Guidelines, Appendix D, and 9 selected
criteria deemed necessary from the Quality Standards for Investigations, concerning
investigative plans. Thus, we reviewed a total of 930 individual inspection points.
Also, at the direction of the Acting Inspector General, we conducted liaison meetings
with various external and internal agencies to assess the effectiveness of the office's
working relationship with others within the criminal justice system, to include at least one
liaison meeting with the Department of Justice (DOJ), Office of United States Attorney
for the district(s) where the specific offices are located, one liaison meeting with another
Federal law enforcement agency with whom joint investigations have been conducted,
and a liaison meeting with an EPA official who has been the recipient of an OI Report of
Investigation (ROI).
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After we completed the inspection, we prepared a preliminary inspection report. We
gave the Special Agent-in-Charge (SAC) of the resource center and the AIGI the
opportunity to respond to the findings. Their comments to each specific finding are
included within each finding. All three of these preliminary inspection reports are the
basis for this QAR. An exit conference with the AIGI was held on August 28, 2007, and
we provide a summary of this meeting at the end of the report.
Noteworthy Achievements
Of the 30 closed cases selected for review, 29 had significant reportable criminal, civil,
and/or administrative actions documented in the case file. These 29 cases resulted in
113 separate accountable actions:
• 60 actions were associated with criminal convictions.
• 13 actions were associated with civil recoveries.
• 40 results were associated with administrative actions.
Summary of Results
• The system of internal safeguards and management procedures for the
investigative function of the EPA OIG is in full compliance with the quality
standards established by the PCIE/ECIE and the Attorney General guidelines.
These safeguards and procedures provide reasonable assurance of conforming to
professional standards in the conduct of investigations.
• We noted no systematic weaknesses during the course of this inspection.
• The offices accounted for all evidence, grand jury material, law enforcement
officer equipment, technical equipment, and firearms.
• All firearms training and the required quarterly firearms qualifications were being
completed.
All of the findings noted during the inspection were minor and procedural in nature.
None of the findings impacted the outcome of any investigation. In general, most of
these minor and procedural findings were caused by the SAs' inattention to detail, and
the SACs were not following up with the SA to ensure that established procedures were
being followed.
As a result of this review, we made recommendations to the SACs to address the
deficiencies identified. In all cases, the SACs implemented the recommendations with
"On the Spot" corrections. Where appropriate, the AIGI implemented other corrective
actions on a national basis.
We delineate the specific recommendations and corresponding corrective action within
each section of this report.
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Evidence
Summary. During the inspection, we completed a 100-percent inventory of all evidence
and the accompanying chain of custody documentation. The inspection accounted for all
evidence. In total, we inspected 187 individual pieces of evidence. We inspected each
item utilizing 4 selected criteria from the OAR Guidelines and 10 selected criteria deemed
essential from Procedural Guidance 01-11. Thus, we reviewed a total of 2,618
individual inspection points for evidence. Of these 2,618 inspection points, 12 had
findings (discrepancy with the existing criteria) for a less than 1-percent error rate. The
following is a more detailed description of the inspection point findings with a notation of
the corrective action taken.
Finding 1. In one office, 9 of 13 (69 percent) entries in the Evidence Log Book did not
have the disposition portion of the entry completed.
Corrective Action. An "On-The-Spot" correction was made and the disposition portion
of the nine pages in question was completed, as required.
Finding 2. In three instances (two open cases and one closed case), Part B of the
"Evidence Custody Form, EPA Form 2720-6," was not placed as required in the official
case files.
Corrective Action. "On-the-Spot" corrections were made and the Part Bs of the EPA
Form 2720-6, Evidence Custody Forms, were placed in the three case files, as required.
Finding 3. In one instance, an office completed, but did not memorialize, the required
evidence inventory when the evidence custodian duties were transferred in February
2006.
Corrective Action. To confirm that all evidence was accounted for, the quality assurance
reviewer, with the participation of the primary evidence custodian, undertook and
completed an inventory of all evidence from September 2005, to the present. This
inventory accounted for all evidence. An "On-the-Spot" correction was made and the
primary and alternate evidence custodians, who completed the inventory in February
2006, prepared e-mails to that effect and placed those e-mails in the evidence custody
record keeping system of the office in question.
Finding 4. In two offices, key type pad locks were used to secure the evidence cages.
OI procedure requires three-position changeable dial type locks.
Corrective Action. Each office made "On-the-Spot" corrections and installed three-
position dial type pad locks on both of the evidence cages.
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Finding 5. In one office, a small two-drawer safe was located inside the evidence cage
used for storing unassigned weapons.
Corrective Action. An "On-the-Spot" correction was made and the SAC advised that the
weapons were moved to another safe located outside of the evidence cage. The safe
inside the evidence cage is now empty.
Criteria for Findings. The OAR Guidelines, Appendix C, Section B, "DUE
PROFESSIONAL CARE, " Paragraph 12, ask "Does the organization have policies and
procedures for receiving, identifying, storing, and preserving documentary and physical
evidence?" Procedural Guidance 01-11, Physical and Documentary Evidence,
delineates evidence custody procedures within the 01.
Cause. In general, the review found that the above findings and deficiencies were caused
by the SAs' inattention to detail. The SACs were not following up with the SAs to
ensure that correct procedures were implemented.
Recommendations. As a result of this review, specific recommendations were made to
the SAC of each resource center to address the deficiencies identified. In all cases, the
SAC implemented the recommendations and corrected the deficiencies.
AIGI Response. For the findings noted, "On-the-Spot" corrections were made. As
reflected by the results of the evidence inspection completed as part of this review, these
administrative oversights did not result in the loss of any evidence and the integrity of the
evidence custody system remained intact. To further strengthen our evidence custody
program, we are developing a training program for all evidence custodians and alternates.
This training will include the requirement that all evidence custodians and alternates,
upon initial appointment and annually thereafter, certify that they have read and
understand OIG Policy 211: Physical and Documentary Evidence.
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Grand Jury Material
Summary. During the inspection, a 100-percent inventory of all grand jury material was
conducted to ensure compliance with policy and procedure: The inspection accounted for
all grand jury material. However, during this review, we noted the following inspection
finding:
Finding 1. The review of the grand jury material disclosed one instance where the
individual pages of the grand jury material were properly marked, but the accordion
folders used to store the grand jury material were not marked properly as containing
grand jury material. Further, the folders were stored in a file cabinet that also contained
non-grand jury material. The locked file cabinet, in which the material was stored, was
located in a locked interior office and only the SAC and the case agent have access to the
file cabinet.
Criteria. The OAR Guidelines, Appendix C, Section B, "DUE PROFESSIONAL CARE, "
Paragraph 14, ask "Are organizational policies and procedures for securing, storing, and
disposing of federal grand jury information consistent with Rule 6(e) of the Federal Rules
of Criminal Procedure?" 01 Procedural Guidance 01-12, "Grand Jury Secrecy and
Subpoenas," outlines the procedures for using, storing, and marking grand jury material.
Cause. The case agent stated that he thought that he was properly marking and storing
the grand jury material. The SAC, however, had not followed up with the SA to ensure
that established procedures were being followed.
Corrective Action. An "On-the-Spot" correction was made and the accordion folders
were properly marked and the non-grand jury material removed from the file cabinet.
Recommendations. As a result of this review, specific recommendations were made to
the SAC to address the deficiencies identified. The SAC implemented the
recommendation which corrected the deficiency. In addition, SAs were instructed to
review the 01 policy and procedure concerning handling grand jury materials.
AIGI Response. This inspection accounted for all grand jury material. For the finding
noted, an "On-the-Spot" correction was made. No further action is warranted.
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Law Enforcement Equipment
Summary. During this inspection, we completed a 100-percent inventory of all
accountable LEO equipment and a review of the associated accountability records. This
inspection accounted for all LEO equipment. This inventory was accomplished by using
the original OI-Personal Property Receipts, as required by policy. The inventory
included SA credentials, badges, belt badges, weapons, hand cuffs, ballistic vests, and
communication devices. Previously, in September 2006, all three resource center SACs
had completed the required fiscal year end LEO equipment inventories and reported the
results to the AIGI. In March 2007, the SACs of WRC and ERC also completed the
required mid-year inspection of the SA credentials, badges, belt badges, and weapons.
In mid-2005, 01 developed the "Law Enforcement Tracking System" (LETS), in
preparation for the PCIE QAR to help the SACs and Headquarters (HQ) manage the
required 1811 (Criminal Investigator) training and to better control OI's LEO equipment
inventories to included high risk items such as credentials, badges, weapons, handcuffs,
ballistic vests, personal raid equipment, and personal communication devices. Prior to
the 2005 PCIE inspection, all of the above LEO equipment was entered into LETS and
the SACs were granted access into the system. In 2005, via electronic message and in
training, the SACs were advised that it was their responsibility to keep both portions of
LETS (training and LEO equipment) current.
During this review, we noted the following findings:
Finding 1. A comparison of the law enforcement equipment portion of LETS to the
individuals' Personal Property Receipts disclosed that all three resource centers had
current errors in the LETS LEO equipment inventories. Also, the inspection and
inventory dates of LEO equipment were not being entered into LETS.
Criteria. The OAR Guidelines, Appendix C, Section B, "DUE PROFESSIONAL CARE, "
Paragraph 15, ask "Do organizational policies and procedures require periodic inventory
of accountable property such as credentials...? " OI Procedural Guidance OI-04,
Firearms and Law Enforcement Equipment, requires that the SAC maintain a record of
all LEO equipment issued to each SA. The SAC is required to conduct an inventory
inspection of the LEO equipment at the end of each fiscal year, and a mid-year inventory
inspection of selected law LEO equipment. Procedural Guidance OI-04, Firearms and
Law Enforcement Equipment, Section 4, Law Enforcement Equipment, Paragraph 4-7,
Inventory and Inspection, a, Mid-Year Inventory and Inspection, and b, Year-end
Inventory and Inspection, delineate the LEO equipment to be inventoried and inspected.
Appendix 4, OIG Office of Investigations Personal Property Receipt, lists the LEO
equipment to be issued to each SA.
Cause. The three SACs advised that they had relinquished the responsibility for updating
LETS to various office personnel. The SACs and the office personnel all advised that
there were data entry problems with LETS and that data entry was very time consuming.
A check with OI's Information Technology Specialist, who is the administrator for
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LETS, disclosed a problem with the server where LETS was electronically stored.
During the past year, information that was entered into LETS was corrupted. When
LETS was restored from a backup tape, information that had been entered was lost
because the backup tape predated the data entry date.
Corrective Action. "On-the-Spot" corrections were made and the LETS entries were
updated to correctly reflect the LEO equipment issued to each SA. As of April 27, 2007,
LETS was reconfigured to allow for global data entry of inventory and inspection dates
completed by the SACs.
Recommendations. As a result of this review, specific recommendations were made to
the SACs to address the deficiency identified. The SACs implemented the
recommendation, which corrected the deficiency in the LETS database.
It was recommended during the CRC inspection that a determination be made concerning
OI's continued use of LETS. If LETS is to be used, 01 Procedural Guidance 01-04,
Firearms and Law Enforcement Equipment, should be amended to include the
requirement that all issued LEO equipment be entered into the database in a timely
manner. The required SAC inventory certifications should be amended to include a
statement that LETS has been reviewed by the SAC and all of the LEO equipment entries
are current as of the date of the SAC's inventory. It was recommended during the WRC
inspection that LETS be reconfigured to allow for global data entry of inventory and
inspection dates.
AIGI Response. As noted above, LETS was developed in mid-2005 to help produce
information for several inspection points during the PCIE QAR. LETS contains
information captured in certain paper-based systems, including information on required
certifications and training, and personal LEO equipment inventories. While LETS did
not replace the paper-based systems, LETS was an automated method that served the 01
well during the PCIE QAR by having a centralized system for providing information to
the PCIE QAR inspection team. Because this system proved to be so successful during
the PCIE QAR, the 01 continued to use it to augment our paper-based systems. 01 issued
electronic guidance and held training concerning LETS. OI's written policies and
procedures continue to reflect the paper-based systems as the official systems. At the
time LETS was developed, 01 should have updated its policies and procedures to reflect
the addition of LETS to the official paper-based systems. As a result of not issuing
revised policies, not all responsible parties are keeping the automated system properly
updated. In this instance, while LETS was not properly updated, the Personal Property
Receipts accurately reflected the issued equipment in accordance with established policy.
At no time was there any loss of accountability of property.
As we initially designed OI's new electronic case management system ("The Inspector
General Enterprise Resource" (TIGER)) system, we are re-evaluating and refining our
requirements for automated records keeping. The functionality of LETS was included in
the original design of TIGER. However, due to budget constraints and requirement
changes, not all of the LETS functions have been incorporated into TIGER. Currently,
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two of the LETS functions have been incorporated into TIGER (certifications and
training) and these are in the final testing and roll-out phase. We are re-evaluating the
design and requirement for the equipment inventory module.
As TIGER continues its roll-out and implementation, we are issuing interim guidance
memoranda and revising policies and procedures to clarify the transition from paper-
based systems (augmented by LETS) to the TIGER system.
Finding 2. No procedure in 01 Procedural Guidance 01-04, Firearms and Law
Enforcement Equipment, indicates who is responsible for issuing the LEO equipment
items to the field and what to do with the equipment, specifically the ballistic vests, when
SAs leave the organization. Several SAs had not been issued the required raid hats,
shirts, jackets, and bags. One SA did not have a ballistic vest. Unserviceable excess
ballistic vests are in various offices throughout 01.
Criteria. 01 Procedural Guidance 01-04, Firearms and Law Enforcement Equipment,
Section 4, Law Enforcement Equipment, Paragraph 4-5, Protective Vests and Raid
Jacket, establishes that agents will have these items issued to them and notes when they
will be worn.
Cause. The SACs advised that they were unaware of who was responsible for the
issuance of various LEO items, specifically hats, shirts, and jackets. The SACs advised
that they were also unaware of the procedures for excessing unserviceable ballistic vests.
Corrective Action. An "On-the-Spot" correction was made and the LEO equipment items
were issued from HQ to the SAs. The resource center ordered the ballistic vest.
Recommendation. As a result of this review, specific recommendations were made to
the SACs to address the deficiencies identified. The SACs implemented the
recommendation. During the CRC inspection, it was recommended to the AIGI that 01
Procedural Guidance 01-04, Firearms and Law Enforcement Equipment, Section 4, Law
Enforcement Equipment, Paragraph 4-5, Protective Vests and Raid Jacket, be amended
to include language delineating the process for having required LEO equipment issued
and the procedures for the transfer or destruction of unserviceable excess ballistic vests.
AIGI Response. We have updated guidance and included a section which delineates the
process for procuring personal LEO equipment. Certain items such as hats, jackets,
shirts, and equipment bags are purchased by HQ and will be issued to all new SAs. The
SACs are authorized to purchase all other LEO equipment locally.
01 generally does not include other agencies' procedures in its internal procedures as it is
duplicative. However, 01 will include a statement and hyperlink in its next procedure
revision to reflect that the existing General Services Administration procedures for
transferring, surplussing, or destroying excess equipment should be followed.
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Technical Equipment
Summary. During this inspection a 100-percent inventory of the accountable technical
equipment and the associated accountability records was completed. This inspection
accounted for all technical equipment. The SACs were completing the required
inventory certifications to HQ. In mid-2005, in preparation for the PCIE QAR, the 01
developed an Excel spreadsheet to help SACs and HQ personnel to manage the technical
equipment issued to each office. Prior to the 2005 PCIE inspection, all technical
equipment was entered into the Excel spreadsheet and a copy provided to each SAC. In
2005, in training and via electronic message, the SACs were advised it was their
responsibility to keep the technical equipment Excel spreadsheets current. However,
during this review, the following finding was noted:
Finding 1. In one resource center, comparing the technical equipment to the Excel
spreadsheet disclosed that four Motorola portable radios issued to the resource center in
the spring of 2006 by HQ, had not been included on the correct Excel spreadsheet.
Criteria. The OAR Guidelines, Appendix C, Section B, "DUE PROFESSIONAL CARE, "
Paragraph 15, ask "Do organizational policies and procedures require periodic inventory
of accountable property such as ... specialized technical equipment... ?" OIProcedural
Guidance OI-05, Investigative, Administrative, and Operational Support, lists the
authorized standard technical equipment required for each office and advises, "This
equipment is accountable property... .An annual inventory of the equipment listed... will
be conducted by the SAC and forwarded to HQ by September 30 of each year."
Cause. Some confusion was in the resource center as to which Excel spreadsheet was the
correct one to use and what technical equipment needed to be listed on that spreadsheet.
Corrective Action. An "On-the-Spot" correction was made and the radios were added to
the correct Excel spreadsheet.
Recommendation. As a result of this review, a specific recommendation was made to
the SAC to address the deficiency identified. The SAC implemented the
recommendation, which corrected the deficiency.
During the CRC inspection, it was recommended that consideration be given to adding
technical equipment inventories into LETS. If this recommendation is implemented, OI
Procedural Guidance OI-05, Investigative, Administrative, and Operational Support,
should be amended to include that the required yearly SAC inventory certification must
incorporate a statement that the technical equipment portion of LETS has been reviewed
and all of the issued technical equipment entries are current as of the date of the SAC's
certification.
AIGI Response. OI is assessing the option of including the technical equipment
inventory either in LETS or TIGER. Once a decision has been made, appropriate policies
and procedures will be issued.
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Firearms
Summary. This inspection completed a 100-percent inventory of all firearms assigned to
the three resource centers. This inspection accounted for all weapons. The inspection
determined that the SACs were completing the required inventories and inspections of all
issued and unissued weapons and certifying the results to 01 Headquarters.
LETS was developed to better control OI's LEO equipment inventories to include high
risk items such as credentials, badges, weapons, handcuffs, ballistic vests, personal raid
equipment, and personal communication devises. Prior to the 2005 PCIE inspection, all
of the above LEO equipment was entered into LETS and the SACs were granted access
into the system. In 2005, via electronic message and in training, the SACs were advised
that it was their responsibility to keep this portion of LETS current. During this review,
the follow finding was noted:
Finding 1. In one resource center, LETS did not accurately reflect the actual disposition
of weapons. In another resource center, the disposition of weapons that had been sent to
HQ were not accurately reflected in LETS. This led to the resource centers and the
National Firearms Coordinator not having access to accurate records concerning the
disposition of weapons within OI in LETS.
Criteria. The OAR Guidelines, Appendix C, Section B, "DUE PROFESSIONAL CARE, "
Paragraph 15, ask "Do organizational policies and procedures require periodic inventory
of accountable property such as .. .handguns..."? OI Procedural Guidance OI-04,
Firearms and Law Enforcement Equipment, requires that the SAC will visually inspect
and inventory all issued and unissued firearms semiannually (March and September).
Cause. There was confusion concerning whose responsibility it was within the field
office to ensure that LETS accurately reflected the actual disposition of weapons within
that resource center. For another resource center there was confusion on the part of OI's
National Firearms Coordinator concerning the responsibility to ensure that LETS
accurately reflected the disposition of weapons received from the field.
Corrective Action. On-the-Spot" corrections were made and LETS currently reflects the
accurate disposition of all weapons within OI.
Recommendations. As a result of this review, specific recommendations were made to
the SACs to address the deficiencies identified. The SACs implemented the
recommendations which corrected the deficiencies.
During the CRC inspection, it was recommended that OI Procedural Guidance OI-04,
Firearms and Law Enforcement Equipment, be amended to include language that the
National Firearms Coordinator will ensure the integrity of the firearms recorded in LETS
immediately after receiving or transferring weapons to the field and after the required
semiannual weapons inventories and inspections are completed and certified by the
SACs. It was also recommended that OI-04 be amended to include the requirement that
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the yearly SAC inventory certification must incorporate a statement that the weapons
inventory portion of LETS has been reviewed by the SAC and the entries are current as
of the date of the SAC's certification.
AIGI Response. As noted above, all of the weapons were accounted for that were
assigned to the respective offices inspected. At no time was there a loss of accountability
of the weapons. As previously noted, however, LETS, which augments the paper-based
system, was not updated. As 01 continues to transition from paper-based systems
(augmented by LETS) to TIGER, issues such as this will be eliminated.
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Firearms Training and Qualification Requirements
Summary. A 100-percent inspection of each SA's training profile and the office
firearms qualification records was conducted to ensure compliance with periodic firearms
qualifications standards and to ensure that the required deadly force training was being
completed. The inspection also reviewed the entries of the firearms training and
qualifications in LETS. All of the SAs assigned to the three resource centers inspected
had completed their required quarterly firearms qualifications during the preceding four
quarters. They all had completed the other required associated firearms training. All of
the SACs had completed their required yearly training certifications to HQ. In 2005, in
training and via electronic message, the SACs were advised it was their responsibility to
keep both portions of LETS (training and LEO equipment) current. During the review
the following finding was noted:
Finding 1. LETS did not accurately reflect firearm qualification dates and scores for
agents assigned to two resource centers. As a result, the resource centers and the
National Firearms Coordinator did not have access to accurate firearms training and
qualification records in the LETS database.
Criteria. The OAR Guidelines, Appendix B Section C, "FIREARMS TRAINING AND
QUALIFICATION REQUIREMENTS," ask "(1) Have eligible individuals received initial
and periodic firearms training and recertification in accordance with FLETC (Federal
Law Enforcement Training Center) standards? (2) Has the OIG Investigations Division
(received and adapted) the DOJ deadly force policy? (3) Are eligible individuals
completing quarterly firearms qualifications?" Both 01 Procedural Guidance 01-02,
Special Agent Training, and 01 Procedural Guidance 01-04, Firearms and Law
Enforcement Equipment, further delineate firearms training and qualification
requirements.
Corrective Action. "On-the-Spot" corrections were made and LETS currently reflects the
disposition of all weapons within 01 and the qualification dates and scores for the
resource centers inspected.
Cause. The SAC in one resource center advised that there was confusion as to the
responsibility concerning the entry of qualification dates and scores into LETS. In the
other resource center, the SAC remembered that the missing dates and scores had been
entered into LETS.
Recommendation. As a result of this review, specific recommendations were made to
the SACs to address the deficiencies identified. The SACs implemented the
recommendations which corrected the deficiency. We recommended that 01 procedures
be amended to include that the required yearly SAC training and firearms certification
must incorporate a statement that the SAC review the training portion of LETS.
Additionally, we recommended that all of the firearms qualifications, scores, and other
associated training be current as of the date of the SAC's certification.
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AIGI Response. All SAs completed the required firearms training and qualifications. In
accordance with written policy and procedures, paper records of the training and
qualifications are maintained. As previously noted, however, the LETS systems, which
augments the paper-based system, was not updated. As we continue our transition from
paper-based systems (augmented by LETS) to TIGER, issues such as this will be
eliminated.
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Ammunition
Summary. During this review, a 100-percent inventory of the ammunition was
completed. All ammunition is being accounted for and stored properly in all three
resource centers. However, during this review, the following finding was noted:
Finding 1. One resource center has 393 rounds of excess/unserviceable .40 caliber
ammunition and 2,331 rounds of excess/unserviceable .38 caliber ammunition in their
inventory. Both the .38 caliber and .40 caliber ammunition are left over from a prior time
when the 01 had .38 caliber and .40 caliber weapons.
Criteria. The OAR Guidelines, Appendix C, Section B., "DUE PROFESSIONAL
CARE, " Paragraph 15, ask "Do organizational policies and procedures require periodic
inventory of accountable property such as ... ammunition?" 01 Procedural Guidance 01-
04, "Firearms and Law Enforcement Equipment, " requires that the SAC inspect
ammunition semiannually (March and September) to ensure that ammunition is properly
accounted for, stored in a safe, and maintained in a serviceable condition.
Cause. 01 Procedural Guidance 01-04, "Firearms and Law Enforcement Equipment, "
has no procedure for excessing of unserviceable ammunition.
Recommendation. It was recommended that the National Firearms Coordinator
determine the proper procedures for excessing unserviceable ammunition and this process
should be incorporated in 01 Procedural Guidance 01-04, "Firearms and Law
Enforcement Equipment."
Corrective Action. The resource center should utilize these procedures to excess its
unserviceable ammunition.
AIGI Response. The National Firearms Coordinator will work with the SAC to ensure
this outdated ammunition is disposed of properly.
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Open Cases
Summary. This quality assurance review of 01 was the first where information in 01' s
new electronic case management system TIGER was inspected for quality assurance.
Specifically, for the last resource center inspected, TIGER was checked to ensure that all
of the open cases included in this inspection had up-to-date case plans and that the SAC
was recording the required quarterly case reviews in the case plans. Of the 1,035
inspection points as described in the Scope and Methodology section, 28 inspection
points had findings (discrepancy with the exiting criteria) resulting in a 3-percent error
rate among various cases. The discrepancies are grouped into four findings which are
described in more detail below:
Finding 1. The review determined there was one instance where the case plan was not
updated to reflect the case work that had been completed
Criteria. (Case Planning) The OAR Guidelines, Appendix C, Section C, "PLANNING,"
state that when a decision to initiate an investigation is made, the organization should
prepare an investigative case plan as soon as possible. The plan should contain the
information deemed necessary by the Quality Standards for Investigations. 01
Procedural Guidance 01-06, "Case Administration, " Section 8, "Investigative Plans,"
delineates the scope of the initial plan, updating the plan, and the contents of the
investigative plan. 01 Procedural Guidance 01-06, "Case Administration, " Section 8,
"Investigative Plans, " Paragraph 8-3, "Updating the Plan, " advises that "As the
investigation progresses, the investigative plan must be updated to reflect.. .completed
steps...."
Cause. In general, the review found that the above finding was caused by the SA's
inattention to detail, and the SAC was not following up with the SA to ensure that
established procedures were being followed.
Corrective Action. An "On-the-Spot" correction was made and the plan was updated to
accurately reflect the investigative steps completed.
Recommendations. As a result of this review, specific recommendations were made to
the SAC to address the deficiency identified. The SAC implemented the
recommendation which corrected the deficiency.
AIGI Response. The SAC was reminded to update the case plan for all completed
investigative steps. This action is now being performed in TIGER. No further action is
required.
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Finding 2. The review determined that in one instance, in one resource center, for a qui
tarn investigation opened in 2005 predicated on a referral from the DOJ, there was no
notification letter to the FBI.
Criteria. (Federal Bureau of Investigation Mutual Notification Requirement)
The OAR Guidelines, Appendix B, Section B, COMPLIANCE WITH APPLICABLE
ATTORNEY GENERAL GUIDELINES, ask if policy contains the mutual notification
requirement for all cases where there is reasonable grounds to believe there is a violation
of federal criminal law. 01 Procedural Guidance OI-Ol, Authority and Responsibility of
Special Agents, Section 3, Responsibility of Special Agents, Paragraph 3, Responsibilities
Under Statutory Law Enforcement Authority, Sub-paragraph 1-b, Mutual Notification
Requirement, advises that notification to the FBI must occur within 30 calendar days
upon initiating any criminal investigation.
Cause. Both the SAC and the case agent stated it was their belief that because this
investigation was a qui tarn investigation initiated by the DOJ, no notification letter to the
FBI was necessary or required.
Corrective Action. An "On-the-Spot" correction was made and a notification letter was
sent to the FBI.
Recommendations. As a result of this review, a specific recommendation was made to
the SAC to address the deficiency identified. The SAC implemented the
recommendation which corrected the deficiency.
AIGI Response. Notification letters are sent to the FBI at the initiation of any criminal
investigation. This was clarified in Interim Guidance 2005-001, issued on May 5, 2005,
and incorporated into Policy 201 in the revision issued on March 28, 2007. This isolated
instance has been corrected and no further action is needed.
Finding 3. The review determined that in one resource center, the SAC was utilizing the
outdated Quarterly Case Review Sheet (QCRS) to document case reviews for four of the
older cases instead of utilizing the case plan to memorialize the quarterly case reviews.
In another resource center, the SAC was utilizing the QCRS to document case reviews
for all 18 of the open investigations inspected. In the same resource center, the SAC was
not memorializing the review of "Investigatively Closed" cases.
Criteria. (Supervisory Review of Case Activities) The OAR Guidelines, Appendix C,
Section D, "EXECUTION, " Paragi'aph 11, advises that supervisory reviews of case
activity should occur periodically to ensure that cases are progressing in an efficient,
effective, thorough, and legal manner, and that documentation exists that periodic case
reviews are being conducted. OIProcedural Guidance 206, Case Administration,
Section 8, Investigative Plan, Paragraph 8-5, Quarterly Case Reviews, delineates the
procedures for the SACs to complete quarterly case reviews and requires using the case
plan as the means of documenting the required quarterly case reviews.
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Cause. The SAC of one resource center stated that he understood the current 01
procedure mandated using the case plan to memorialize the completion of the quarterly
case reviews and it was his responsibility to complete them, which he is accomplishing.
However, he believed that the QCRS could still be used for the older cases until they
were closed. The other SAC stated that she was not aware of the procedure change,
which occurred on April 26, 2005. She also advised that she completed reviews of
"Investigatively Closed" cases every 90 days when the 90-Day Status Reports were due.
However, she was not memorializing these reviews anywhere.
Corrective Action. On March 27, 2007, the AIGI directed an amendment to OIG
Procedure 223, "Investigative Reports, " Section 2-5, Investigatively Closed Status
Reports, which now provides that, "Effective after the submission of the April 1, 2007,
Status Reports, the category of "Investigatively Closed" will be eliminated. Accordingly,
Section 2-5 of OIG Procedure 223 and any other references to "Investigatively Closed"
are deleted from the OIG Policies and Procedures.
Recommendation. It was recommended to both SACs that they follow existing
procedures and ensure that quarterly case reviews are memorialized in the case plans as
required. When the above 22 cases are closed, the SACs must ensure that the completed
QCRS are included in the case files forwarded to HQ for retention.
AIGI Response. The SACs are reminded to update the case plan for all investigations to
reflect the required quarterly case review. This action is now being performed in TIGER.
As the category of "Investigatively Closed" has been eliminated, this specific condition
will not be repeated. No further action is required.
Finding 4. The inspection determined that in three cases, the SA's notes were not
properly labeled. The SA only labeled the first page of the notes. Thus, there were notes
in the investigative files that, if separated, could not be identified to a specific case.
Criteria. (Contemporaneous Interview Notes) The OAR Guidelines, Section D,
"EXECUTION\ " Paragraph 7, require that, "... contemporaneous interview notes in a
criminal investigation be retained at least until final disposition of the case." OI
Procedural Guidance 01-206, Case Administration, Section 14, Other Investigative
Matters, Paragraph 14-1, Investigative Notes, advises that, "Each page of the agent's
notes will be identified with the agent(s)' name, date, and case number in the upper right
hand corner."
Cause. In general, the review found that the above finding was caused by the SA's
inattention to detail. In addition, the SAC was not following up with the SAs to ensure
that established procedures were being followed.
Corrective Action. An "On-the-Spot" correction was made and the additional pages were
marked as required.
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Recommendation. As a result of this review, a specific recommendation was made to
the SAC to address the deficiency identified. The SAC implemented the
recommendation which corrected the deficiency.
AIGI Response. All investigative staff will be instructed to review 01 Procedural
Guidance 206 concerning investigative notes.
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Closed Cases
Summary. Of the 930 inspection points for all closed cases reviewed, 28 inspection
points had findings (discrepancy with the exiting criteria) resulting in a 3-percent error
rate. The discrepancies are grouped into six findings, which are described in more detail
below:
Finding 1. Our review determined that in 12 instances, no QCRS was in the closed case
file. Thus, no documentation existed in the closed case file that a supervisor was
conducting periodic case reviews.
Cause. In two resource centers, the SACs did not know why the QCRS had been
removed from the case file prior to the case file being forwarded to HQ for file retention.
In one resource center, the SAC disclosed that the QCRS had been removed from 9 of the
10 closed cases prior to them being sent to 01 HQ for file retention. It was the SAC's
understanding that the QCRS were considered management records which were not
considered part of the official investigative case file. All of the SACs and the assigned
SAs who were available noted that the SAC had completed the required periodic reviews.
Finding 2. Our review determined that in one closed case, periodic case reviews were
being completed; however, they were not completed on a quarterly basis. This case was
opened on February 1, 2005, and supervisory reviews were documented within the case
planning document in May 2005 and November 2005. The case was closed in May 2006.
Cause. The SAC advised that he had completed the required reviews, but for some
reason did not memorialize the reviews within the plan.
Criteria for Findings 1 and 2. The OAR Guidelines, Appendix C, Section D,
"EXECUTION\ "Paragraph 77, advise that supervisory reviews of case activity should
occur periodically to ensure that cases are progressing in an efficient, effective, thorough,
and legal manner, and that documentation exists that periodic case reviews are being
conducted. The OAR Guidelines, Appendix I), ask the same question. OIProcedural
Guidance 206, Case Administration, Section 8, Investigative Plan, Paragraph 8-5,
Quarterly Case Reviews, delineates the procedures utilized by the SACs to complete
quarterly case reviews. Since April 2005, it requires using the case plan as the means of
documenting the required quarterly case reviews. The prior version of OI-06 called for
using the QCRS and its inclusion in the closed case file.
Corrective Action. None, closed case.
Recommendation 1. The AIGI should ensure that the SACs are completing and
properly documenting the required case review of the case plans in TIGER.
Recommendation 2. The AIGI should ensure that the SACs are completing and
properly recording the required case reviews by reviewing the case plans in TIGER.
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AIGI Response. Regarding Finding 1, as the quarterly case reviews are now performed
in TIGER, these reviews will be included in the electronic file. No further action is
necessary.
Regarding Finding 2, the SAC is reminded to update the case plan for all investigations to
reflect the required quarterly case review. This action is now being performed in TIGER.
No further action is required.
Finding 3. In eight closed cases reviewed, the first page of the interview notes were
properly labeled; however, any additional pages of notes were not. The official closed
case file contained notes that were not properly identified and, if separated from the case
file, could not be identified.
Criteria. The OAR Guidelines, Appendix C, SectionD, "EXECUTION, "Paragraph 7,
advise that contemporaneous interview notes in a criminal investigation be retained at
least until the final disposition of the case. The OAR Guidelines, Appendix D, ask the
same information in the form of a question. 01 Procedural Guidance 01-06, Case
Administration, Section 14, Investigative Notes, Paragraph 14-1, Investigative Notes,
provided that, "each page of the agent's notes will be identified with the agent(s)' name,
date, and case number in the upper right-hand corner." This requisite was included as a
requirement in the three previous versions of 01-06.
Cause. In general, the above findings were caused by the SA's inattention to detail. In
addition, the SAC was not following up with the SAs to ensure that established
procedures were being followed.
Corrective Action. An "On-the-Spot" correction was made and the case number was
added to the other pages of the notes so that the notes could be identified to a specific
case.
Recommendation. The SACs must ensure that the SAs are properly labeling the
investigative notes completed during the course of an investigation.
AIGI Response. All investigative personnel will be instructed to review 01 Procedural
Guidance 206 concerning investigative notes.
Finding 4. In two of the closed cases reviewed the SA had not updated the investigative
plan since the initiation of the case. The SA had completed investigative steps that were
not delineated in the plan.
Criteria. The OAR Guidelines, Appendix C, advise that when a decision to initiate an
investigation is made, the organization should prepare an investigative case plan as soon
as possible. The plan should contain information deemed necessary by the Quality
Standards for Investigations. This question is repeated in Appendix D. 01 Procedure
Guidance 01-206, "Case Administration, " Section 8, "Investigative Plans, " delineates
the scope of the initial plan, updating the plan, and the contents of the investigative plan.
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01 Procedure Guidance 01-206, ''Case Administration, "Section 8, "Investigative
Plans, " Paragraph 8-3, "Updating the Plan, " advises that "As the investigation
progresses, the investigative plan must be updated to reflect... completed steps...
Cause. In general, the above findings were caused by the SAs' inattention to detail. In
addition, the SACs were not following up with the SAs to ensure that established
procedures were being followed.
Corrective Action. None, closed case.
Recommendation. The SACs and the AIGI should ensure that the established
procedures are being followed.
AIGI Response. The SAC is being reminded to update the case plan for all completed
investigative steps. This action is now being performed in TIGER. No further action is
required.
Finding 5. The review determined that in two cases in one resource center, the case
agent prepared ROIs and removed original EPA Forms 2720-15 (Results of Interviews)
from the case file and utilized them as exhibits to the ROI. In one of the cases, a
completed original EPA Form 2720-18, "Warning and Assurance to a Federal Employee
Requested to Provide Information on a Voluntary Basis," was included as an exhibit.
The official closed case files did not include the original case documentation, only the
original completed ROI which had the documents included.
Criteria. The OAR Guidelines, Appendix C, Section B, "Due Profession Care, " ask,
"Are investigative report findings and accomplishments supported by adequate
documentation in the case file?" This question is repeated in Appendix D. 01 Procedural
Guidance 223, "Investigative Reports, " Section 3, "Reports of Investigation, "
Paragraph 3-10., "Exhibits, " provides that [the Report of Investigation (ROI)] "... will
include copies of the relevant and material information upon which Section A of the
report is based..."
Cause. The SA stated that she was not aware that copies, not originals, were to be
included as exhibits in ROIs. The SAC advised that copies of the completed ROIs were
distributed to the region and the originals never left the control of the resource center.
Corrective Action. Corrections were completed by the resource center and 01 HQ.
Copies of the originals documents for the exhibits were reproduced and placed in the
ROIs. The original documentation was returned to the case files, as required.
Recommendation. The SAC must ensure that the proper procedures are followed when
ROIs are prepared for distribution to agency officials.
AIGI Response. The SAC has reviewed the requirements for preparing ROIs with his
staff. No further action is needed.
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Finding 6. The review of the closed case files at one resource center showed that for one
case, the SA sent no notification letter to the FBI.
Criteria. The OAR Guidelines, Appendix B, Section B, "COMPLIANCE WITH
APPLICABLE ATTORNEY GENERAL GUIDELINES," ask if policy contains the FBI
mutual notification requirement for all cases where there is reasonable grounds to believe
there is a violation of federal criminal law. This question is repeated in Appendix D. 01
Procedural Guidance OI-Ol, "Authority and Responsibility of Special Agents," Section 2,
"Responsibility of Special Agents," Paragraph 3-1, "Responsibilities Under Statutory
Law Enforcement Authority," Sub-paragraph b, Mutual Notification Requirement,"
advises that notification to the FBI must occur within 30 calendar days upon the initiation
of any criminal investigation.
Cause. Both the SAC and the SA stated they believed that the required notification to
the FBI had, in fact, occurred. However, the notification documentation was somehow
inadvertently not included in the closed case file.
Corrective Action. None, closed case.
Recommendation. The SAC must ensure that the FBI notification documentation is
included in the case file.
AIGI Response. Notification letters are sent to the FBI at the initiation of any criminal
investigation. This was clarified in Interim Guidance 2005-001, issued on May 5, 2005,
and incorporated into Policy 201 in the revision issued on March 28, 2007.
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Other Matters
During the review, two other issues were noted involving the inspection process. These
two issues and the corrective actions are summarized below:
Finding 1. During this inspection process, it was noted that three closed case files have
not been sent to HQ for file retention as provided in 01 Procedural Guidance
01-06, "Case Administration, " Section 11 "Cases, "Paragraph 11-4, "Closing Cases, "
sub-paragraph f which states: "Within 20 days of receiving the HQ closing
memorandum, the SAC should ensure the Official Case File is organized and sent to
Headquarters for data imaging and storage." One of the cases is pending the Federal
Appeals process. One case is being appealed to the Merit Systems Protection Board.
And, in one case, there is an outstanding fugitive arrest warrant because the subject, after
he was convicted, fled the country.
Recommendation. The AIGI should consider amending 01-06 to allow the field offices
to retain closed case files in those cases that are in the criminal, civil, or administrative
appeal process or where there is outstanding law enforcement activity yet to be
completed.
AIGI Response. These case files are being maintained in the field offices at the
direction of the assigned attorney. Upon resolution of the pending litigation, they will be
sent to 01 Headquarters for data imaging and file retention. We will issue revised policy
to reflect the above exemptions from the 20-day requirement. We will review TIGER to
determine how to track this in the electronic system.
Finding 2. During the course of the inspection of the 30 closed cases, it was noted that
the HQ Desk Officers are completing a closed case file review prior to the closed cases
being sent for data imaging. However, these reviews do not include all of the topic
subject areas that are delineated in the OAR Guidelines, Appendix D, "Closed Case File
Review. " Had these topical areas been utilized to review closed cases, the case files with
minor deficiencies could have been returned to the resource centers for corrective action.
Recommendation. The AIGI should consider amending the processes the Desk Officers
utilize during their closed case reviews to include the selected criteria delineated in the
OAR Guidelines, Appendix D, "Closed Case File Review. "
AIGI Response. This matter is currently being addressed by 01 Headquarters.
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Exit Briefing with the Office of Investigations
We held an exit briefing with the AIGI, Deputy AIGI, and another senior 01 official on
August 28, 2007. In general, the AIGI committed to completing, in Fiscal Year 2008, the
recommendations made in this report. The AIGI commented that OI was restructuring
itself, which could affect completing the recommendations.
With respect to specific recommendations, the AIGI stated:
1. 01 Policy 204 has been revised and reissued by the AIGI.
2. With respect to the excess ammunition, the National Firearms Coordinator would
work with the resource center to have the ammunition destroyed. Destroying the
excess ammunition is a complicated matter involving Federal laws, General
Services Administration regulations, and transportation issues. However, the
AIGI expected to have this issue resolved by the beginning of calendar year 2008.
3. Regarding the AIGI's comments that investigative personnel will be instructed to
review certain procedural guidance, the AIGI explained that this instruction will
be accomplished during the next several weeks during telephone conferences with
the SACs, where he emphasizes areas of procedural guidance. The AIGI would
supplement these calls with other e-mails covering the areas in the report.
4. The AIGI explained that he is initiating a policy change, including a change to
TIGER, which would allow the resource centers, in certain limited circumstances,
to retain closed case files past the 20 days after the AIGI closing case memo was
issued. The AIGI also stated that the duties and responsibilities of the desk
officers would be changing by the reorganization, and the process of quality
assurance for closed case file reviews would be an issue discussed during the
pending reorganization.
5. The AIGI continues to act to have open communication with the field that is
positive, looks to the future, and emphasizes stability. One positive
accomplishment was the recent "all hands" meeting.
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