oversight

Management Advisory Report - Digital Accountability and Transparency Act Readiness Review

Published by the Office of Personnel Management, Office of Inspector General on 2017-02-16.

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

                          UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 

                                                Washington, DC 20415



  Office of the
Inspector General
                                            February 16, 2017


                                                                        Report No. 4A-CF-00-16-038

     MEMORANDUM FOR KATHLEEN M. McGETTIGAN 

                    Acting Director 


     FROM:                    	NORBERT E. VINT

                               Acting Inspector General 


     SUBJECT: 	               Management Advisory Report – Digital Accountability and
                              Transparency Act Readiness Review

     The Office of the Inspector General (OIG) conducted a readiness review of the U.S. Office of
     Personnel Management’s (OPM) efforts to be in compliance with the Digital Accountability and
     Transparency Act (hereafter referred to as the DATA Act). The objective of our review was to
     gain an understanding of the processes, systems and controls which OPM has implemented, or
     plans to implement, to report financial and payment data in accordance with the requirements of
     the DATA Act.

     We issued our draft review memorandum to Dennis D. Coleman, Chief Financial Officer (CFO),
     on September 30, 2016. The CFO’s October 17, 2016, comments on the draft review were
     considered in preparing this final memorandum and are included as appendices. For specific
     details on the review results, please refer to the “Results” section of the memorandum.

     This final memorandum has been issued by the OIG to OPM officials to improve the likelihood
     of compliance with the requirements of the DATA Act prior to full implementation. As part of
     this process, OPM may release the report to authorized representatives of the reviewed party.
     Further release outside of OPM requires the advance approval of the OIG. Under section 8M of
     the Inspector General Act, the OIG makes redacted versions of its final reports available to the
     public on its webpage. We interpret these reporting requirements to be applicable to this
     memorandum.

     Please contact me, at (202) 606-1200, if you have any questions, or someone from your staff
     may wish to contact Michael R. Esser, Assistant Inspector General for Audits, at




 www.opm.gov	                                                                                 www.usajobs.gov
Kathleen M. McGettigan                                               2

Attachment

cc: 	 Dennis D. Coleman
      Chief Financial Officer and Acting Chief Management Officer

    Daniel K. Marella 

    Deputy Chief Financial Officer 


    Rochelle S. Bayard
    Associate CFO, Center for Financial Systems Management

    David L. DeVries 

    Chief Information Officer 


    Mark W. Lambert
    Associate Director, Merit System Accountability and Compliance

    Janet L. Barnes 

    Director, Internal Oversight and Compliance 


                          

    Chief, Policy and Internal Controls 

 U.S. OFFICE OF PERSONNEL MANAGEMENT
    OFFICE OF THE INSPECTOR GENERAL
             OFFICE OF AUDITS




     Management Advisory
           Report
            THE U.S. OFFICE OF PERSONNEL MANAGEMENT’S
  DIGITAL ACCOUNTABILITY AND TRANSPARENCY ACT READINESS REVIEW

                                          Report No. 4A-CF-00-16-038
                                              February 16, 2017




                                                          -- CAUTION --
This report has been distributed to Federal officials who are responsible for the administration of the subject program. This non-public
version may contain confidential and/or proprietary information, including information protected by the Trade Secrets Act, 18 U.S.C. §
1905, and the Privacy Act, 5 U.S.C. § 552a. Therefore, while a redacted version of this report is available under the Freedom of Information
Act and made publicly available on the OIG webpage (http://www.opm.gov/our-inspector-general), this non-public version should not be
further released unless authorized by the OIG.
BACKGROUND
The DATA Act, enacted on May 9, 2014, requires that Federal agencies report financial and
payment data in accordance with data standards established by the U.S. Department of Treasury
(Treasury) and the U.S. Office of Management and Budget (OMB). The data reported will be
displayed on a website available to taxpayers and policy makers. In addition, the DATA Act
requires that agency Inspectors General (IG) review statistical samples of the data submitted by
the agency under the DATA Act and report on the completeness, timeliness, quality and
accuracy of the data sampled and the use of the data standards by the agency.

The DATA Act provides for this oversight by way of the IGs and the Comptroller General of the
United States. The DATA Act requires a series of oversight reports to include, among other
things, an assessment of the completeness, timeliness, quality, and accuracy of data submitted.
Specifically, the first set of IG reports were originally due to Congress in November 2016;
however, agencies are not required to submit spending data in compliance with the DATA Act
until May 2017. As a result, the IGs could not report on the spending data submitted under the
DATA Act by the statutory deadline, as this data would not exist until the following year.

To this end, the Council of the Inspectors General on Integrity and Efficiency (CIGIE) issued a
letter, dated December 22, 2015, to Congress addressing the timing anomaly and informing them
that the IGs plan to provide Congress with their first required reports in November 2017, a one-
year delay from the due date in the statute, with subsequent reports following on a two-year
cycle, in November 2019 and November 2021. CIGIE believes that moving the due dates back
one year will enable IGs to meet the intent of the oversight provisions in the DATA Act and
provide useful reports for the public, the Congress, the Executive Branch, and others.

Although CIGIE determined the best course of action was to delay the IG reports, CIGIE is
encouraging IGs to undertake DATA Act “Readiness Reviews” at their respective agencies well
in advance of the first November 2017 report. The IG community, through the Federal Audit
Executive Council (FAEC) stood up the FAEC DATA Act Working Group. The working group
issued the DATA Act Readiness Review Guide to assist agencies in their readiness reviews.
This readiness review, in addition to the requirements of the DATA Act, will assist all parties in
helping to ensure the success of the DATA Act implementation efforts and with future audits
required by the DATA Act. The primary criteria for this review were OMB’s M-15-121 and
Treasury’s DATA Act Implementation Playbook2 (version 1.0).




1
  M-15-12 “Increasing Transparency of Federal Spending by Making Federal Spending Data Accessible, Searchable,
and Reliable” provides guidance for agencies to carry out current transparency reporting requirements pursuant to

the Federal Funding Accountability and Transparency Act and new reporting requirements pursuant to the DATA 

Act. 

2
  The DATA Act Implementation Playbook describes eight key steps that, if followed together, should help agencies 

leverage existing capabilities to drive implementation of the DATA Act.


                                                                 1                              Report No. 4A-CF-00-16-038
    This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
       proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
 SCOPE AND METHODOLOGY
 We performed our review from May 12 through August 31, 2016, at OPM’s headquarters in
 Washington, D.C. The scope of our review concentrated on the following four steps of the
 “Agency 8-Step Plan” as described in the DATA Act Implementation Playbook (version 1.0):

      1.	 Organize team: Create an agency DATA Act work group including impacted
          communities (e.g., Chief Information Officer, Budget, Accounting, etc.) and identify the
          Senior Accountable Officer.

      2.	 Review elements: Review list of DATA Act elements and participate in data definitions
          standardization.

      3.	 Inventory data: Perform inventory of Agency data and associated business processes.

      4.	 Design and strategize:
             a.	 Plan changes (e.g., adding award identification numbers (Award ID) to financial
                 systems) to systems and business processes to capture data that are complete
                 multi-level (e.g., summary and award detail) fully-linked data.
             b.	 Prepare cost estimates for fiscal year (FY) 2017 budget projections.

 To accomplish the review, we:

      	 Obtained an understanding of the laws, legislation, directives, and any other regulatory
         criteria (and guidance) related to OPM’s responsibilities to report financial and payment
         information under the DATA Act.

      	 Conducted interviews with OPM’s DATA Act working group responsible for the
         implementation of the DATA Act at the agency-level.

      	 Identified the major reporting components within OPM responsible for implementation of
         the DATA Act.

      	 Assessed OPM’s efforts and formal implementation plans (at the agency and component
         levels) to report financial and payment information under the DATA Act.

 RESULTS
 Based on our analysis, we determined that OPM’s implementation process is on track for
 meeting the requirements of the DATA Act.




                                                                2	                              Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
 OPM’s DATA Act Implementation Narrative

 We found OPM’s DATA Act Implementation Narrative, which addresses new requirements that
 agencies must employ pursuant to the DATA Act and was submitted to OMB in September
 2015, to be adequate. OPM’s plan includes an implementation timeline, estimates for resource
 requirements, and a target for identification of foreseeable challenges to implementation of the
 DATA Act by May 2017.

 DATA Act Subject Matter Experts

 OPM has aligned knowledgeable personnel within OPM’s DATA Act Implementation
 Workgroup (DAIW) to provide a vision for a successful implementation of the DATA Act and
 its requirements. The DAIW has an effective management structure with clearly defined roles
 and responsibilities, which include, but are not limited to:

      	 the Senior Accountable Official, who for the DATA Act implementation is also OPM’s
         Chief Financial Officer, and who assumes responsibility for coordinating and
         collaborating OPM’s efforts pursuant to the development and implementation of the
         DATA Act and data quality framework for reporting OPM Federal spending information;

      	 the Chief Acquisition Officer, who leads policy development, establishment of
         acquisition goals, evaluation and monitoring of bureau organizations, strategic sourcing,
         governance of Federal-wide and Treasury procurement systems, and continuous
         improvement of the acquisition environment; and

      	 the Chief Information Officer, who is responsible for endorsing and providing input on
         the DATA Act implementation.

 Information Technology Systems under the DATA Act

 OPM has two separate financial systems affected by the implementation of the DATA Act: (1)
 the Consolidated Business Information System (CBIS), an Oracle application, for its Salaries &
 Expenses and Revolving Fund business operations, and (2) the Federal Financial System (FFS),
 a long running Consultants to Government and Industries - American Management System
 mainframe solution of over 20 years, for its Trust Funds processing.

 Data mapping ensures an agency has identified and linked all 57 required data elements in its
 source systems. In addition, data mapping is necessary so agencies can successfully extract data
 in the required DATA Act format. Specifically, data mapping ensures OPM is able to extract the
 required data from its procurement and grant systems to the broker3 to extract the data. The data
 mapping for OPM’s systems involves several files containing various payment data elements.


 3
   The broker is a virtual data layer at the agency that maps, ingests, transforms, validates, and submits agency data
 into a format consistent with the DATA Act Schema.

                                                                3	                              Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
 OPM is currently excluding File C4 for FFS and is using Governmentwide Treasury Account
 Symbol/Standard Form 133 (GTAS/SF133) information for the File A5 extract for CBIS. CBIS
 received a technical patch on October 10, 2016, that introduced reporting form updates to File
 B6. Furthermore, OPM is performing custom extracts for File C for CBIS until Oracle releases
 the DATA Act patch. Once Oracle releases its DATA Act patch in FY 2017, OPM will use the
 delivered software extracts for testing all CBIS related files in the DATA Act broker to ensure all
 agency data is consistent with the DATA Act Schema7 for File C. OPM is using GTAS/SF133
 information for FFS to generate the File A extract and OPM’s Office of the Chief Information
 Office and Office of the Chief Financial Officer (OCFO) departments are in the process of
 assessing File B for FFS.

 OPM has established an Award ID link for CBIS between Oracle and CompuSearch
 PRISM8; however, they do not maintain any award data in FFS. The DAIW stated that Treasury
 verbally acknowledges the fact that OPM’s File C, of FFS, cannot be generated; however,
 without supporting documentation, we are unable to verify that an official waiver has been
 granted to exclude File C from OPM’s FFS DATA Act reporting requirements. OPM submitted
 and validated both CBIS and FFS Files A, B, and C in the DATA Act broker to which all files
 were validated.

 Areas of Concern
 In spite of the fact that we believe OPM is on track for meeting the requirements of the DATA
 Act, we have identified two areas of concern that should be immediately addressed by OPM to
 improve the implementation process moving forward. Specifically:

 (1) Oversight of the Implementation Process

 OPM’s DATA Act narrative states, “The goal for the DAIW risk management process is to
 manage risks, issues and related action items in a timely manner and execute mitigation
 strategies and adhere to related due dates. At a minimum, high priority risks and new risks will
 be reviewed at the bi-weekly DAIW status meetings.”

 We were unable to determine that OPM’s DAIW functioned in the capacity stated by OPM’s
 DATA Act narrative above, in regards to coordinating and collaborating OPM’s implementation
 efforts across multiple offices within OPM. Our determination was based on the following
 factors:

      	 The DAIW provided Power Point presentations from two of their DAIW status meetings
         held on May 26 and June 7, 2016. However, the DAIW did not provide actions taken
 4
   File C reports obligations at the award and object class level. 

 5
   File A contains appropriation summary level data that is aligned to the SF133 reporting. 

 6
   File B includes obligation and outlay information at the program activity and object class level. 

 7
   A data standard that contains both a human-readable and a machine-readable version of the standard.

 8
   PRISM is a powerful, web-based application that provides federal and defense acquisition communities with the
 tools needed to effectively support the complete acquisition management lifecycle. 


                                                                4	                              Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
             during the status meetings, such as; documenting the roles and responsibilities for each
             DATA Act team member, recording key decisions and actions from team meetings, and
             formalizing the review and approval of deliverables submitted to OMB and the Treasury.
             Meeting minutes are a valuable project management tool that is vital to any successful
             implementation plan to discuss the project’s goals, assigned tasks, and progress or
             deviation towards intended outcomes. OPM should strengthen documentation of the
             DAIW regularly scheduled status meetings held to exchange information about the
             project. This will allow key managers to track the progress of work results, change
             requests, corrective actions, and lessons learned of the DAIW implementation endeavors.

        	 The DAIW denied OIG’s request to attend their August 2, 2016, meeting, the purpose of
           which was to allow the OIG to observe the DAIW’s risk management process first hand.

        	 The DAIW missed a milestone date, which stated a completion timeframe of the first
           quarter of FY 2016. During our review, we were unable to validate the completion of
           the requested FFS data element inventory, in “Step 3: Define Inventory of Data
           Elements”, outlined in the OPM DATA Act Implementation narrative provided to OMB,
           dated September 11, 2015. OPM should strengthen project management over the DATA
           Act’s implementation effort by ensuring that they complete the tasks and meet the
           milestones projected in the eight step DATA Act Implementation Playbook.

 CFO’s Response:

 OPM will track the progress of the project as they work toward the May 2017 implementation
 date. In regard to the missed milestone, “Treasury and OMB did not release the DATA Act
 Information Model Schema Version … until April [29, 2016; therefore,] the original milestone
 date of Quarter 1, 2016 [first quarter of FY 2016] was no longer feasible. OPM completed this
 step in June. … OPM will continue our efforts toward the successful implementation of the
 DATA Act by ensuring tasks are completed timely and milestone dates are met in accordance
 with the eight step DATA ACT Implementation Playbook.”

 OIG’s Reply:

 The OIG acknowledges the fact that Treasury and OMB did not release the DATA Act
 Information Model Schema until April 29, 2016; however, OPM’s DATA Act implementation
 narrative stated that an initial inventory, which identified OPM’s source systems data extractions,
 was to be completed by the first quarter in FY 2016, during which time a 90 beta version of the
 DATA Act Information Model Schema existed.

 (2) Inventory Data

 Program activity is not automatically stored and produced in CBIS or FFS; therefore, OPM is
 relying on manual calculations to bridge this gap9. As a result, during our review we did not

 9
     Data that is not captured or data that is hard to extract.

                                                                5	                              Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
 conduct a formal, adequate, and complete data inventory of the DATA Act elements for each
 major reporting component, and therefore could not confirm that OPM is properly reporting
 complete, reliable or accurate data. An upcoming Oracle patch for OPM’s CBIS is expected to
 be released in FY 2017, which will update the Reporting Code form to accommodate mapping
 for program activities.

 During our review we were also unable to validate the completion of the FFS data inventory, as
 the inventory had not yet been completed by the Office of the Chief Information Officer and the
 OCFO. In response to our draft memorandum, the OCFO provided the OIG with a copy of the
 completed FFS inventory. While we acknowledge that the FFS inventory has since been
 completed, we did not review the inventory for content and the requirements of the DATA Act,
 due to reporting time constraints. We will complete a detailed review of the FFS inventory as
 part of our FY 2017 DATA Act audit.

 CFO’s Response:

 OPM acknowledges this area of concern. “Regarding FFS, OPM is in the final stages of
 development of a new reporting program that will extract File B balances from the financial
 system. Within this program is a crosswalk that will derive program activity codes and object
 class information aligned with FFS accounting Entry Identifications. User Acceptance Testing
 (UAT) is expected to begin in late October.”

 CONCLUSION
 We found that OPM is in position to report financial and payment data in accordance with the
 requirements of the DATA Act. Nonetheless, we have identified two areas of concern that if not
 addressed may impact our FY 2017 DATA Act audit.

      	 Our review of OPM’s coordination and collaboration of DAIW efforts between the
         program offices concluded that OPM’s oversight was inefficient.

      	 In addition, our review of the CBIS and FFS data element inventory concluded that OPM
         requires manual calculations to extract data vital to reporting complete, reliable, and
         accurate data as mandated by the DATA Act. While the OCFO understands this process
         is not ideal, it was a necessary progression to allow inclusion of a functional inventory in
         the timeframe outlined by the DAIW to complete the implementation process. Plans are
         currently in place to upgrade the system and begin the implementation of automated
         calculations for any element that previously required a manual effort. OPM is working
         with Treasury and OMB to rectify all material gaps identified during the implementation
         process and satisfy all requirements set forth by the DATA Act.




                                                                6	                              Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
                                                             7                              Report No. 4A-CF-00-16-038
This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
                                                           8                                  Report No. 4A-CF-00-16-038
This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or
   proprietary information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
                                                                                                                               Appendix B

      From:                                                       

      To:                                                      

      Cc:                                       Coleman, Dennis D;             ;                    

      Subject:                                  FW: Emailing - Draft DATA Act Readiness Review.pdf Date:

                                                Thursday, November 03, 2016 4:03:32 PM Attachments:
                                                FW DATA Act Request for Status Update.msg
                                                RSS - FFS Data Act Elements Inventory v2.xlsx
      Importance:                               High


      Good afternoon                      ,

      Thank you for the opportunity to provide a response to the OIG assessment of the missed
      milestone. Please find below the OPM response. Additionally, as requested, attached is the
      completed FAA data inventory for OIG review.

      If additional information is required, please let us know.

      OPM RESPONSE: OIG indicated that OPM's DAIW missed milestones dates that were
      outlined in the September 2015 Implementation Plan narrative provided to the Office of
      Management and Budget (OMB), as part of their oversight of the implementation process
      concern. However, Treasury and OMB did not release the DATA Act Information Model
      Schema Version 1.0 (DAIMS v 1.0) until April 29th, 2016. Therefore, the original milestone
      date of Quarter 1 - 2016 was no longer feasible. OPM completed Step 3 in June, 2016.

      Thank you,

      Chief, Projects & Initiatives
      Office of Personnel Management Office of the Chief Financial Officer (OCFO) E-mail:
                       @opm.gov Phone:

      Begin forwarded message: 


      From: "                 "<            @opm.gov> 

      Date: November 1, 2016 at 4:11:11 PM EDT 

      To: "Coleman, Dennis D" <                @opm.gov> 

      Cc: "            "<              @opm.gov>, "                                                             "<
               @opm.gov> 

      Subject: RE: Emailing - Draft DATA Act Readiness Review.pdf





                                                                     9                                 Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or proprietary
                information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
      Good afternoon Dennis,

      Thank you for your response to our DATA Act Readiness Review draft report. In an effort
      to keep our promise of reporting a complete, accurate and fair final memorandum, I would
      like to further clarify our comments in the draft with supporting documentation provided
      within this email. On your response, dated October 17, 2016, it was stated that:

      “OIG also indicated that OPM's DAIW missed milestones dates that were outlined in the
      September 2015 Implementation Plan narrative provided to the Office of Management and
      Budget (OMB), as part of their oversight of the implementation process concern. OPM is
      unable to address this concern, as we are not aware of the specific missed milestone date that
      OIG references.”

      OIG sited “Step 3: Define Inventory of Data Elements”, of the OPM DATA Act
      Implementation narrative dated September 11, 2015, which stated that this task was
      estimated to be completed by the first quarter of fiscal year 2016. (Please see attachment -
      OPM DATA Act Implementation narrative, page 7, section 3.2.3)

      In addition, we reviewed the following documentation which identified the status of “Step 3:
      Define Inventory of Data Elements” as still “in progress” (see attachments for the bulleted
      three items below):
                Data Act - Status Update - 05262016 FINAL v3 (see slide 9 of 15, step 3 and 3.5)
                DATA_Act_PMO_OPM_Meeting Deck_Final_20160523 (see slide 6 of 6, items
                  for discussion and timeline provided)
                2016 0607 DATA Act Status Bi-Weekly (See page 3 of 7, status update chart for
                  step 3)

      OPM RESPONSE: OIG also indicated that OPM's DAIW missed milestones dates that were
      outlined in the September 2015 Implementation Plan narrative provided to the Office of
      Management and Budget (OMB), as part of their oversight of the implementation process
      concern.

      Treasury and OMB did not release the DATA Act Information Model Schema Version 1.0
      (DAIMS v 1.0) until April 29th, 2016. Therefore, the original milestone date of Quarter 1,
      2016 was no longer feasible. OPM completed this step in June.

      Please provide a response, by 11/3/16, notifying us whether you agree or disagree with our
      assessment of a missed milestone date for the completion estimate for “Step 3: Define
      Inventory of Data Elements”, located within OPM DATA Act Implementation narrative.




                                                                     10                                Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or proprietary
                information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
      Respectfully,


      Auditor, Internal Audits Group Office of Inspector General
      U.S. Office of Personnel Management 1900 E. Street, NW, Room 6400 Washington, DC
      20415
      Direct:               / Fax:
                    @opm.gov

      All labor that uplifts humanity has dignity and importance

      From:
      Sent: Monday, October 17, 2016 4:42 PM
      To:                         <                    @opm.gov>
      Cc: Coleman, Dennis D <                @opm.gov>; Barnes, Janet L
      <            @opm.gov>;                      <                 @opm.gov>
      Subject: Emailing - Draft DATA Act Readiness Review.pdf Please see attached CFO
      response.

      Thanks



      Program Analyst - Administrative Operations Resource Management Office
      Office of the Chief Financial Officer Room 7512A
      1900 E. Street, N.W.
      Washington, DC 20415




                                                                     11                                Report No. 4A-CF-00-16-038

This report is non-public and should not be further released unless authorized by the OIG, because it may contain confidential and/or proprietary
                information that may be protected by the Trade Secrets Act, 18 U.S.C. § 1905, or the Privacy Act, 5 U.S.C. § 552a.
                                                                                                                      




                                      Report Fraud, Waste, and Mismanagement



                                             Fraud, waste, and mismanagement in
                                          Government concerns everyone: Office of
                                              the Inspector General staff, agency
                                           employees, and the general public. We
                                         actively solicit allegations of any inefficient
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                                         and operations. You can report allegations
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                        By Mail:              Office of the Inspector General
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                                                       -- CAUTION --
This report has been distributed to Federal officials who are responsible for the administration of the subject program. This non-public
version may contain confidential and/or proprietary information, including information protected by the Trade Secrets Act, 18 U.S.C. §
1905, and the Privacy Act, 5 U.S.C. § 552a. Therefore, while a redacted version of this report is available under the Freedom of Information
Act and made publicly available on the OIG webpage (http://www.opm.gov/our-inspector-general), this non-public version should not be
further released unless authorized by the OIG.
                                                                                                    Report No. 4A-CF-00-16-038