oversight

Response - Congressional Request on Open Office of Inspector General Audit Recommendations; Nonpublic, Closed Reports of Investigation; and Restrictions on Access to Information

Published by the Farm Credit Administration, Office of Inspector General on 2016-04-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

Farm Credit Administration                                              Office of Inspector General
                                                                        1501 Farm Credit Drive
                                                                        McLean, Virginia 22102-5090




Via Email and U.S. Mail

April 27, 2016


The Honorable Jason Chaffetz
Chairman
Committee on Oversight and Government Reform
United States House of Representatives
2157 Rayburn House Office Building
Washington, DC 20515

The Honorable Elijah E. Cummings
Ranking Member
Committee on Oversight and Government Reform
United States House of Representatives
2471 Rayburn House Office Building
Washington, DC 20515

Dear Chairman Chaffetz and Ranking Member Cummings:

This is in reply to your April 6, 2016, letter requesting information on open and unimplemented Office of
Inspector General (OIG) recommendations and related cost savings; summaries of nonpublic, closed
investigations, evaluations, and audits; number of referrals to the U.S. Department of Justice for criminal
prosecution and number of related prosecutions; and a list of any instances in which the Agency refused
to provide or otherwise restricted or delayed the OIG’s access to records or information since March 1,
2015.

This letter provides responsive data for the time period from March 1, 2015 through April 1, 2016. We
have included information from our two most recent Semiannual Reports to Congress, the first issued
on October 26, 2015 for the time period dating from April 1, 2015, through September 30, 2015, and the
second issued last week for the time period dating from October 1, 2015, through March 31, 2016.

Request No. 1 – “The current number of recommendations by your office that are open or
unimplemented.”

        As of April 1, 2016, OIG has 21 agreed-upon actions that remain open or unimplemented. (An
        agreed-upon action is a recommendation made in an OIG audit, evaluation, or inspection which
        the Agency has accepted. All of OIG’s open recommendations discussed in this report have
        already been accepted by the Agency and are, therefore, designated as “agreed-upon actions”.)

Requests No. 2 and 3 – “The cumulative estimated cost savings associated with the current number of
open and unimplemented recommendations” and “[f]or those recommendations that would result in
                                                                                                           2

cost savings if implemented, specify the recommendation, the date the recommendation was made,
and an estimate for the cost savings that would be realized if the recommendation were
implemented.”

       With respect to open recommendations with associated cost savings, as of April 1, 2016, OIG
       has two such agreed-upon recommendations and they amount to a cumulative estimated
       amount of $304,477 in funds put to better use, as follows:

           ·   Farm Credit Administration’s Risk Project, Audit No. A-16-01 (March 31, 2016), Agreed-
               Upon Action Number 1, which identified funds put to better use of $143,200: “Add or
               modify current procedures for large IT investments to:
                  o Designate a project manager and project management responsibilities;
                  o Assess resources and determine whether consultants are needed for project
                      planning and implementation; and
                  o Establish guidelines for incremental investment.”

           ·   Farm Credit Administration’s Commissioning Program, Audit No. A-14-04 (March 31,
               2015), Agreed-Upon Action Number 3, which identified funds put to better use of
               $161,277: “Analyze the costs and benefits of streamlining and consolidating current
               testing and assessment milestones through the elimination of the final Commissioning
               Test simulations.”

Request No. 4 – “Which three open or unimplemented recommendations does your office consider to
be the most important or urgent? For each, identify:
       a. The status of the recommendation, including whether agency management has agreed or
           disagreed with the recommendation and the expected date of implementation; and,
       b. The cost savings associated with the recommendation (if applicable).”

       The Agency has already accepted all 21 recommendations that are currently open. Of these 21
       recommendations, OIG considers the following to be the three most important or urgent:

           ·   The Farm Credit Administration’s Commissioning Program, No. A-14-04
               (March 31, 2015), Agreed-Upon Action No. 3, “Analyze the costs and benefits of
               streamlining and consolidating current testing and assessment milestones through the
               elimination of the final Commissioning Test simulations.” The Agency has agreed with
               this recommendation and we anticipate this item being completed by the end of this
               fiscal year. We also identified funds put to better use as a result of this
               recommendation, in the amount of $161,277.

           ·   The Farm Credit Administration’s Risk Project, No. A-16-01 (March 31, 2016), Agreed-
               Upon Action No. 1, “Add or modify current procedures for large IT investments to:
                   o Designate a project manager and project management responsibilities;
                   o Assess resources and determine whether consultants are needed for project
                        planning and implementation; and
                   o Establish guidelines for incremental investment.”
               The Agency has agreed with this recommendation and we anticipate this item being
               completed by the end of this fiscal year. We also identified funds put to better use as a
               result of this recommendation, in the amount of $143,200.
                                                                                                          3

            ·   The Farm Credit Administration’s Risk Project, No. A-16-01 (March 31, 2016), Agreed-
                Upon Action No. 5, “Evaluate Risk Project software licenses before the next renewal
                period.” The Agency has agreed with this recommendation and the expected date of
                implementation is by the end of the fiscal year.

Request No. 5 – “A summary of all closed investigations, evaluations, and audits that were not
disclosed to the public since March 1, 2015, including case number, disposition, a brief description of
the allegation, and the date the investigation was closed.”

With respect to information on nonpublic, closed reports issued from March 1, 2015 to the present, all
reports generated through OIG audits, inspections, and evaluations conducted during the period were
publicly disclosed and are posted on my office’s public website at FCA Office of Inspector General
Reports. Our office also issued three Reports of Investigation for which Closing Memoranda
summarizing the allegations are posted on my office’s public website as follows:

    ·   OIG Report of Investigation No. 15-01 addressed allegations relating to an employee’s access to
        Equal Employment Opportunity counseling. The OIG completed its investigation on July 15,
        2015, and issued Report of Investigation No. 15-01 to FCA management for appropriate action.
        On July 31, 2015, FCA management notified the OIG that it had taken administrative action. The
        OIG Closing Memorandum is published online at: Closing Memorandum No. 15-01.

    ·   OIG Report of Investigation No. 15-03 addressed questions relating to employee suitability
        adjudications by the FCA. The allegation was not substantiated and OIG closed the investigation
        on September 29, 2015. The OIG Closing Memorandum is published online at: Closing
        Memorandum No. 15-03.

    ·   OIG Report of Investigation No. 15-05 addressed an allegation that the Agency was using
        contract employees to conduct inherently governmental activities in violation of Federal law and
        FCA policy. The allegation was not substantiated and OIG closed the investigation on December
        16, 2015. The OIG Closing Memorandum is published online at: Closing Memorandum No. 15-
        05.

    Our office also issued two unpublished Management Advisories to the FCA Board during this time
    period:

        ·   OIG Management Advisory No. 15-02, Federal Records Act Amendments on Personal Emails
            and Text Messages as Federal Records. This advisory was issued on April 16, 2015, and
            recommends that the Agency implement procedures and issue policy statements to address
            new Federal statutory requirements regarding use of email and text messaging in the
            context of Federal records requirements. The Agency subsequently developed and shortly
            thereafter, published a policy addressing the statutory mandate.

        ·   OIG Management Advisory No. 15-03, Eligibility to Participate in FCA 401(k) Plan. This
            advisory was issued on September 16, 2015, addressing questions regarding eligibility to
            participate in the Agency’s 401(k) plan. The Agency responded in a timely manner, and
            resolved the eligibility issue in its 2016 Compensation and Benefits Program issued in
            December 2015.