Compliance With Professional Standards by the Commerce Inspector General

AFMD-85-57: Published: Aug 12, 1985. Publicly Released: Aug 12, 1985.

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GAO reviewed the Department of Commerce Office of the Inspector General's (OIG) compliance with professional standards to determine whether: (1) audits were conducted in accordance with generally accepted government auditing standards; (2) investigations were performed in compliance with professional standards; and (3) inspections complied with the Inspector General's (IG) own policies and procedures for documenting observations and recommendations contained in inspection reports.

GAO found that: (1) the IG audit function satisfactorily complied with the professional standards in the areas of staff qualifications, organizational and external impairments to independence, and fraud and abuse, but corrective action was needed in the areas of supervision, internal controls, and audit follow-up; and (2) the quality control system did not adequately communicate to the audit staff the policies and procedures to be followed to ensure compliance with audit standards in certain areas. GAO also found that: (1) IG satisfactorily complied with professional investigative standards concerning staff qualifications, screening allegations, and the establishment of a quality assurance program, but needed to take corrective action in the areas of preserving confidentiality, planning, and reporting; (2) IG made a number of improvements in the inspection functions, but there were still some problems in documenting the inspection work; and (3) improvements were needed in the written quality control policies and procedures to ensure better compliance with professional standards.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: OIG Staff Memorandum 87-A1G/PEI-1, Inspection Reports, requires that all inspection reports include a specified statement in the purpose and scope section which tells the reader that inspections do not include the detailed testing normally associated with a management audit.

    Recommendation: IG should require that inspection reports include appropriate scope statements and limitations.

    Agency Affected: Department of Commerce: Office of the Inspector General

  2. Status: Closed - Implemented

    Comments: OIG conducted on-the-job training courses on investigative planning during FY 1986.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should train investigators in preparing these plans.

    Agency Affected: Department of Commerce: Office of the Inspector General

  3. Status: Closed - Implemented

    Comments: The new OIG investigations manual requires regional IG for investigation to receive and review all investigation plans. In addition, copies of the plans must be submitted to headquarters, where they are available for review. Investigation plans for all current cases, and the supervisors comments on them, are also reviewed during visits to the regional offices.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should specify appropriate OIG officials to review case plans and the progress in implementing them.

    Agency Affected: Department of Commerce: Office of the Inspector General

  4. Status: Closed - Implemented

    Comments: Section 6262 of the new OIG investigations manual contains detailed instructions for the case agent's plan of investigation.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should write policies and procedures requiring investigative plans for individual cases.

    Agency Affected: Department of Commerce: Office of the Inspector General

  5. Status: Closed - Implemented

    Comments: The OIG investigations manual, section 6266, now requires monthly monitoring and documentation of the status of all cases. A go/no go decision is required for all investigations open for 6 months or more.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should establish milestones for completing each investigation and monitor the progress in meeting these milestones.

    Agency Affected: Department of Commerce: Office of the Inspector General

  6. Status: Closed - Implemented

    Comments: OIG developed merit pay performance plans to hold managers, supervisors, and division and office directors responsible for ensuring compliance with professional standards.

    Recommendation: IG should hold audit managers, supervisors, and division and office directors responsible, through the annual appraisal process, for ensuring that their staffs and all work performed by them conform with the standards.

    Agency Affected: Department of Commerce: Office of the Inspector General

  7. Status: Closed - Implemented

    Comments: IG established a quality assurance program. Each audit, investigation, inspection, and support unit will be evaluated on a 4-year cycle against applicable OIG, President's Council on Integrity and Efficiency, and GAO standards.

    Recommendation: IG should implement a quality assurance program that requires independent reviews of individual audit assignment compliance with standards and ensures the accuracy of report information.

    Agency Affected: Department of Commerce: Office of the Inspector General

  8. Status: Closed - Implemented

    Comments: OIG conducted more training in fiscal year (FY) 1986, particularly in the areas GAO mentioned.

    Recommendation: IG should require that all auditors take training in those areas in which deficiencies were identified, including compliance with generally accepted government auditing standards on supervision, evidence, reporting, internal control identification and evaluation, and audit follow-up.

    Agency Affected: Department of Commerce: Office of the Inspector General

  9. Status: Closed - Implemented

    Comments: Each IG office received a complete directives manual and IG auditors and investigators received the directives applicable to them.

    Recommendation: IG should distribute a copy of the directive system to each staff member.

    Agency Affected: Department of Commerce: Office of the Inspector General

  10. Status: Closed - Implemented

    Comments: This recommendation was implemented in the IG overall annual plan for FY 1986.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should include in the annual plan all major investigation functions and staffing estimates.

    Agency Affected: Department of Commerce: Office of the Inspector General

  11. Status: Closed - Implemented

    Comments: Appendix 62-02 of the new investigations manual contains detailed instructions for transmitting source-data pages within the Office of Investigations. These instructions include a check-and-balance procedure to ensure the correct filing and location of source documents.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should revise procedures for sending information about confidential sources between offices to include a verification by investigators ensuring that the information is correctly filed.

    Agency Affected: Department of Commerce: Office of the Inspector General

  12. Status: Closed - Implemented

    Comments: OIG conducted on-the-job training courses on protecting confidential sources in investigative files during FY 1986.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should prepare guidance for the investigators that alerts them to ways that investigative files can inadvertently provide clues about the identity of a confidential source.

    Agency Affected: Department of Commerce: Office of the Inspector General

  13. Status: Closed - Implemented

    Comments: IG Directive 7110, Inspection Performance, was revised, and a new inspection handbook was prepared which emphasizes the team supervisors' responsibility to ensure compliance with OIG policies and procedures, particularly the OIG work-paper requirement for inspection report observations and recommendations.

    Recommendation: IG should revise written quality control policies and procedures to designate that inspection team supervisors should ensure adherence to the OIG work-paper support requirement for inspection report observations and recommendations.

    Agency Affected: Department of Commerce: Office of the Inspector General

  14. Status: Closed - Implemented

    Comments: IG Directive 7110, Inspection Performance, was revised and a new inspection handbook was prepared. Both emphasize the importance of complying with OIG policies and procedures, particularly OIG work-paper support for inspection report observations and recommendations.

    Recommendation: IG should reiterate the importance of complying with OIG written quality control policies and procedures regarding work-paper support for inspection report observations and recommendations.

    Agency Affected: Department of Commerce: Office of the Inspector General

  15. Status: Closed - Implemented

    Comments: IG established a goal for every investigator to receive a basic investigative course, followed by 40 hours of technical training each year. This should improve the perceived inadequacies in staff training. OIG instituted a procedure whereby the Deputy IG meets with each Assistant IG to discuss all proposed appraisals to ensure consistency in ratings among the various units.

    Recommendation: IG should determine why some investigators perceive inadequacies in staff training and appraisals and act to improve those perceptions.

    Agency Affected: Department of Commerce: Office of the Inspector General

  16. Status: Closed - Implemented

    Comments: OIG indicated that it does require GS-13-and-above investigators to submit annual financial disclosure statements.

    Recommendation: To strengthen controls for ensuring that investigators are free of financial impairments to their personal independence, IG should instruct new investigators at the GM-13 level and above to submit financial disclosures, which IG or other OIG management officials will review.

    Agency Affected: Department of Commerce: Office of the Inspector General

  17. Status: Closed - Implemented

    Comments: Sections 6220, 6261b, and 6266 of the new investigations manual describe procedures for liaison with program officials in case planning and investigations. In addition, the Office of Investigations' Integrity Assistance Program requires close and continuous liaisons with program officials.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should prepare guidance for investigators explaining when a department official should be briefed about an investigation, what type of information should be conveyed in the briefings, and who should do the briefing.

    Agency Affected: Department of Commerce: Office of the Inspector General

  18. Status: Closed - Implemented

    Comments: Under the new internal control procedures outlined in the investigations manual, an annual inspection will be made of each field office, during which every investigative file is examined and, among other things, checked for compliance with policies and procedures on retention of interview notes.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should develop procedures for verifying that the notes are appropriately filed with official records of investigations.

    Agency Affected: Department of Commerce: Office of the Inspector General

  19. Status: Closed - Implemented

    Comments: Section 6325d of the new investigations manual now contains detailed instructions on this matter.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should instruct investigators on OIG policy to retain interview notes for criminal cases.

    Agency Affected: Department of Commerce: Office of the Inspector General

  20. Status: Closed - Implemented

    Comments: Sections 6267 and 6325 of the new investigations manual provide detailed instructions on the retention and storage of interview notes.

    Recommendation: To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should expand OIG policy on retaining interview notes to specify where and how long to retain the notes.

    Agency Affected: Department of Commerce: Office of the Inspector General

  21. Status: Closed - Implemented

    Comments: OIG completed all directive system revisions by September 30, 1986.

    Recommendation: IG should ensure that the remaining planned revisions to the directive system are completed within the most recently established time frames.

    Agency Affected: Department of Commerce: Office of the Inspector General

 

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