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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Highlights
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.
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Office of the Inspector General | IG should ensure that the remaining planned revisions to the directive system are completed within the most recently established time frames. |
Closed – Implemented
OIG completed all directive system revisions by September 30, 1986.
|
| Office of the Inspector General | IG should distribute a copy of the directive system to each staff member. |
Closed – Implemented
Each IG office received a complete directives manual and IG auditors and investigators received the directives applicable to them.
|
| Office of the Inspector General | 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. |
Closed – Implemented
OIG conducted more training in fiscal year (FY) 1986, particularly in the areas GAO mentioned.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
OIG developed merit pay performance plans to hold managers, supervisors, and division and office directors responsible for ensuring compliance with professional standards.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
Section 6262 of the new OIG investigations manual contains detailed instructions for the case agent's plan of investigation.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | To assist OIG in satisfactorily complying with certain aspects of the proposed standards, IG should train investigators in preparing these plans. |
Closed – Implemented
OIG conducted on-the-job training courses on investigative planning during FY 1986.
|
| Office of the Inspector General | 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. |
Closed – Implemented
This recommendation was implemented in the IG overall annual plan for FY 1986.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
OIG conducted on-the-job training courses on protecting confidential sources in investigative files during FY 1986.
|
| Office of the Inspector General | 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. |
Closed – Implemented
Sections 6267 and 6325 of the new investigations manual provide detailed instructions on the retention and storage of interview notes.
|
| Office of the Inspector General | 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. |
Closed – Implemented
Section 6325d of the new investigations manual now contains detailed instructions on this matter.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
OIG indicated that it does require GS-13-and-above investigators to submit annual financial disclosure statements.
|
| Office of the Inspector General | IG should determine why some investigators perceive inadequacies in staff training and appraisals and act to improve those perceptions. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | 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. |
Closed – Implemented
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.
|
| Office of the Inspector General | IG should require that inspection reports include appropriate scope statements and limitations. |
Closed – Implemented
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.
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