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 2016-11-09.

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




November 9, 2016




The Honorable Ron Johnson
Chairman
Committee on Homeland Security and Governmental Affairs
United States Senate
328 Hart Senate Office Building
Washington, DC 20510

The Honorable Charles E. Grassley
Chairman
Committee on the Judiciary
United States Senate
135 Hart Senate Office Building
Washington, DC 20510

Dear Chairman Johnson and Chairman Grassley:

This is in reply to your February 27, 2015, letter requesting information relating to the Farm Credit
Administration (FCA or Agency) Office of Inspector General (OIG). Information requested involves open
OIG recommendations; OIG reports provided to the Agency for comment but not responded to within
60 days; investigative reports on employees at a GS-15 level or above or equivalent; instances of
whistleblower retaliation; descriptions of attempts to interfere with IG independence; detailed
descriptions of instances in which the Agency has resisted or objected to oversight activities of the OIG
or restricted or significantly delayed access to information; and nonpublic, closed reports of
investigation, audit, or evaluation by the OIG.

We are providing the requested information for the reporting period dating from April 1, 2016 through
September 30, 2016, in conjunction with the issuance of OIG’s Semiannual Report to the Congress for
this same time period.

Request No. 1: An accounting of all outstanding unimplemented recommendations, as well as the
aggregate potential cost savings of these open recommendations, including:
       a. The current number of open and unimplemented recommendations;
       b. The dates on which the open and unimplemented recommendations were initially made;
       c. Whether agency management has agreed or disagreed with the recommendations; and
       d. The total potential cost savings to the agency of the current open and unimplemented
           recommendations.

        FCA OIG Response: As of September 30, 2016, OIG has 18 agreed-upon actions that remain
        open or unimplemented. (An agreed-upon action is a recommendation made in an OIG audit,
                                                                                                                   2

    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”.) Information as requested on these agreed-upon actions
    follows:

        a. The current number of open and unimplemented recommendations
           FCA OIG Response: FCA OIG has 18 open recommendations/agreed-upon actions.

        b. The dates on which the open and unimplemented recommendations were initially
           made
           FCA OIG Response: See below charts.

        c. Whether agency management has agreed or disagreed with the recommendations
           FCA OIG Response: The Agency has agreed with all 18 open recommendations/agreed-
           upon actions.

        d. The total potential cost savings to the agency of the current open and unimplemented
           recommendations
           FCA OIG Response: As of September 30, 2016, two of the open 18 agreed-upon actions
           would result in 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.”


      Audit: FCA’s Commissioning Program (Issued 3/31/2015)
                AGREED-
  DATE OF
                 UPON
RECOMMEN-                                       RECOMMENDATION/AGREED-UPON ACTION
                ACTION
  DATION
                NUMBER
                             Identify and track specific commissioning costs to evaluate the cost of the program
 March 31,
                   1         and identify cost‐saving opportunities and consider timekeeping code revisions,
  2015
                             with OMS assistance in implementation.

                             Analyze the costs and benefits of streamlining and consolidating current testing
 March 31,
                   3         and assessment milestones through the elimination of the final Commissioning Test
  2015
                             simulations.

 March 31,                   Revise processes to provide feedback to every Associate Examiner on Technical
                   9
  2015                       Evaluations and Commissioning Test multiple‐choice test performance.
                                                                                                                  3


                  Audit: FCA’s Risk Project (Issued 3/31/16)
                 AGREED-
  DATE OF
                  UPON
RECOMMEN-                                       RECOMMENDATION/AGREED-UPON ACTION
                 ACTION
  DATION
                 NUMBER

                           Add or modify current procedures for large IT investments to:
                               •   Designate a project manager and project management responsibilities;
March 31, 2016      1          •   Assess resources and determine whether consultants are needed for
                                   project planning and implementation; and
                               •   Establish guidelines for incremental investment.
                           Establish a control to ensure project management guidance is implemented for
March 31, 2016      2
                           large IT investments.

                           Create an incremental project plan for the remainder of the Risk Project in
                           coordination with the Risk Project workgroup. Include an assessment of required
March 31, 2016      3
                           resources and tasks requiring consultants and evaluate other tools that may be
                           incorporated to accomplish Risk Project goals and objectives.
                           Modify standard operating procedures to define levels of approval for large IT
March 31, 2016      4      acquisitions and establish a control to ensure appropriate reviews and approvals
                           are obtained.




   Audit: FCA’s Position Management and Job Evaluation Program
                          (Issued 9/23/16)
                 AGREED-
  DATE OF
                  UPON
RECOMMEN-                                      RECOMMENDATION/AGREED-UPON ACTION
                 ACTION
  DATION
                 NUMBER
                           Create internal procedures on the job evaluation and position management
September 23,              program to memorialize and standardize HR processes. Include additional controls
                    1
    2016                   over inputs into the job evaluation system.

                           Establish and initiate a plan to update all position descriptions to the new format.
September 23,
                    2      Address inconsistencies identified between position descriptions and the rating
    2016
                           system.
September 23,              Document the method chosen to increase transparency of the job evaluation
                    3      system.
    2016
                           Document how the job evaluation system works and how weights are assigned to
September 23,
                    4      the factors to ensure adequate knowledge of the system exists in the Agency.
    2016
                           Safeguard the information as appropriate. Seek contractor assistance as necessary.
                           Document the promotion process at the Executive Management Team phase of the
September 23,
                    5      OE career ladder.
    2016
                           Revise Policy and Procedure Manual 819 for the position description review and
September 23,
                    6      desk audit withdrawal processes.
    2016
                                                                                                                       4


      Audit: FCA’s Oversight of Young, Beginning, and Small Farmer
                      Programs (Issued 9/28/2016)
                    AGREED-
     DATE OF
                     UPON
   RECOMMEN-                                        RECOMMENDATION/AGREED-UPON ACTION
                    ACTION
     DATION
                    NUMBER
                                 ORP document policies and procedures for YBS oversight activities, including:
                                      •  A methodology for YBS comparison reporting that accounts for
  September 28,                          institution size; and
                        1
      2016                            •  A process to address deficiencies identified through YBS reporting and
                                         analysis.

  September 28,                  ORP incorporate YBS oversight activities and processes in internal control planning
                        2        and evaluation.
      2016
  September 28,                  ORP develop a plan for addressing recommendations in the Agency’s YBS
                        3
      2016                       definitions review.
  September 28,                  OE provide guidance to examiners to ensure YBS transaction testing and
                        4
      2016                       conclusions are appropriately documented.
                                 ORP complete an interpretation on YBS disclosure requirements in annual reports
  September 28,
                        5        to shareholders.
      2016




Request No. 2: A narrative description of all audits, evaluations, and investigations provided to the
agency for comment but not responded to within 60 days.

    FCA OIG Response: All OIG audit, evaluation, and investigation reports provided to the FCA during
    this reporting period were responded to within 60 days.

Request No. 3: A report on each investigation involving GS-15 level or above employees, or other
Federal pay scale equivalent employees, at a Federal agency or department where misconduct was
found, but no prosecution resulted, including:
        a. A detailed description of the facts and circumstances of the investigation; and
        b. A detailed description of the status and disposition of the matter, including whether there
            was a referral to the Department of Justice, the date of any such referral, whether there
            was a declination from the Department, the date of any such declination, and an
            explanation of the reasons for any such declination.

    FCA OIG Response: During this reporting period, OIG issued no reports finding misconduct by FCA
    employees at a Federal pay scale equivalent to a GS-15 level or above.

Request No. 4: Detailed descriptions of any instances of whistleblower retaliation, including
information about the official found to have engaged in retaliation and what, if any consequences, the
agency imposed to hold that official accountable. However, please seek whistleblower consent before
revealing any whistleblower's personally identifiable information to Congress.

    FCA OIG Response: OIG identified no instances of whistleblower retaliation within FCA or involving
    FCA employees during this reporting period.
                                                                                                          5

Request No. 5: Detailed descriptions of any attempts to interfere with IG independence, including:
       a. Restricting communications between the IG office and Congress; and
       b. Budgetary constraints designed to limit the capabilities of the IG office.

    FCA OIG Response: OIG has had no instances of attempts to interfere with IG independence during
    this reporting period.

Request No. 6: A detailed description of any incident where the Federal agency or department, as
applicable, has resisted or objected to oversight activities of the IG office or restricted or significantly
delayed access to information, including the justification of the Federal agency or department for such
action.

    FCA OIG Response: During this reporting period, the Agency has cooperated in information and
    document requests, including providing access to Agency databases, written materials, and Agency
    employees for interviewing, and has not significantly delayed the FCA OIG’s access to records or
    other information. The FCA OIG has also had no instances in which the FCA resisted or objected to
    OIG oversight activities.

Request No. 7: A detailed description of any investigation, evaluation, audit, or report that is closed
and was not disclosed to the public.

    FCA OIG Response: With respect to information on nonpublic, closed reports issued from April 1,
    2016 to September 30, 2016, 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.

Thank you for your efforts on behalf of the Inspectors General, and please contact my office at
(703) 883-4030, if we may further assist.

Sincerely,



Elizabeth M. Dean
Inspector General