Inspectors General
Limitations of IG Oversight at the Department of State Gao ID: GAO-08-135T October 31, 2007GAO was asked to provide testimony about the effectiveness and reliability of the State Department's Office of Inspector General (State IG). We focused on the independence of the State IG, the use of inspections instead of audits to provide oversight of the department, and the effectiveness of the IG's investigative function. The testimony is based primarily on our March 2007 report, Inspectors General: Activities of the Department of State Office of Inspector General (GAO-07-138).
The effectiveness of the oversight provided by the State IG is limited by (1) a lack of resources, (2) structural independence issues, (3) gaps in audit coverage, and (4) the lack of assurance that the department obtains independent IG investigations. These limitations serve to reduce the credibility and oversight provided by the State IG. From fiscal years 2001 through 2006, the State Department's budgets have increased from $13.7 billion to about $24 billion, an increase of almost 75 percent (or 55 percent in constant dollars adjusted for inflation) in order to manage an expanding role in the global war on terrorism. During this same period, the State IG's budget increased from $29 million to $31 million, which when adjusted for inflation is a decrease of about 6 percent in constant dollars. In addition, of the 318 authorized staff in the State IG's fiscal year 2006 budget, the actual onboard staff averaged 182, or about 57 percent of the authorized level and about 20 percent less than in fiscal year 2001. We continue to identify concerns regarding the independence of the State IG that are similar to concerns we reported almost three decades ago. Independence is critical to the quality and credibility of all the work of the State IG and is one of the most important elements of the overall effectiveness of the IG function. Our concerns include (1) the appointment of line management officials to head the State IG in an acting capacity for extended periods, and (2) the use of ambassador-level Foreign Service staff to lead inspections of the department's bureaus and posts even though they may have conflicts of interest resulting from their roles in the Foreign Service. In addition, because the State IG provides oversight coverage of high-risk areas and management challenges primarily through inspections rather than audits, the department has significant gaps in audit oversight. Compared to audits, oversight provided by inspections is fundamentally limited. To illustrate, the Inspector General Act requires the State IG to follow Government Auditing Standards, while use of inspection standards are voluntary. In addition, unlike auditing standards, inspection standards do not require an external peer review of quality. The State IG's ratio of inspections to audits in fiscal year 2005 was 2 to 1 while the ratio for the statutory federal IG community was about 1 to 10. We reviewed 10 of the State IG's inspections performed over fiscal years 2004 and 2005 and found that they relied heavily on questionnaires completed by management at each bureau or post being inspected without verification or testing for accuracy. We also found that investigations of the State Department lack a formal written agreement between the State IG and DS. Such an agreement is critical to help ensure that investigations of internal department operations are performed by the IG and not by bureau investigators who report to department management.
GAO-08-135T, Inspectors General: Limitations of IG Oversight at the Department of State
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United States Government Accountability Office: GAO:
Testimony:
Before the Subcommittee on International Organizations, Human Rights,
and Oversight, Committee on Foreign Affairs, House of Representatives:
For Release on Delivery:
Expected at 2:00 p.m. EDT:
Wednesday, October 31, 2007:
Inspectors General:
Limitations of IG Oversight at the Department of State:
Statement of David M. Walker:
Comptroller General of the United States:
GAO-08-135T:
GAO Highlights:
Highlights of GAO-08-135T, a testimony before the Subcommittee on
International Organizations, Human Rights, and Oversight, Committee on
Foreign Affairs, House of Representatives.
Why GAO Did This Study:
GAO was asked to provide testimony about the effectiveness and
reliability of the State Department‘s Office of Inspector General
(State IG). We focused on the independence of the State IG, the use of
inspections instead of audits to provide oversight of the department,
and the effectiveness of the IG‘s investigative function. The testimony
is based primarily on our March 2007 report, Inspectors General:
Activities of the Department of State Office of Inspector General (GAO-
07-138).
What GAO Found:
The effectiveness of the oversight provided by the State IG is limited
by (1) a lack of resources, (2) structural independence issues, (3)
gaps in audit coverage, and (4) the lack of assurance that the
department obtains independent IG investigations. These limitations
serve to reduce the credibility and oversight provided by the State IG.
From fiscal years 2001 through 2006, the State Department‘s budgets
have increased from $13.7 billion to about $24 billion, an increase of
almost 75 percent (or 55 percent in constant dollars adjusted for
inflation) in order to manage an expanding role in the global war on
terrorism. During this same period, the State IG‘s budget increased
from $29 million to $31 million, which when adjusted for inflation is a
decrease of about 6 percent in constant dollars. In addition, of the
318 authorized staff in the State IG‘s fiscal year 2006 budget, the
actual onboard staff averaged 182, or about 57 percent of the
authorized level and about 20 percent less than in fiscal year 2001.
We continue to identify concerns regarding the independence of the
State IG that are similar to concerns we reported almost three decades
ago. Independence is critical to the quality and credibility of all the
work of the State IG and is one of the most important elements of the
overall effectiveness of the IG function. Our concerns include (1) the
appointment of line management officials to head the State IG in an
acting capacity for extended periods, and (2) the use of ambassador-
level Foreign Service staff to lead inspections of the department‘s
bureaus and posts even though they may have conflicts of interest
resulting from their roles in the Foreign Service.
In addition, because the State IG provides oversight coverage of high-
risk areas and management challenges primarily through inspections
rather than audits, the department has significant gaps in audit
oversight. Compared to audits, oversight provided by inspections is
fundamentally limited. To illustrate, the Inspector General Act
requires the State IG to follow Government Auditing Standards, while
use of inspection standards are voluntary. In addition, unlike auditing
standards, inspection standards do not require an external peer review
of quality. The State IG‘s ratio of inspections to audits in fiscal
year 2005 was 2 to 1 while the ratio for the statutory federal IG
community was about 1 to 10. We reviewed 10 of the State IG‘s
inspections performed over fiscal years 2004 and 2005 and found that
they relied heavily on questionnaires completed by management at each
bureau or post being inspected without verification or testing for
accuracy.
We also found that investigations of the State Department lack a formal
written agreement between the State IG and DS. Such an agreement is
critical to help ensure that investigations of internal department
operations are performed by the IG and not by bureau investigators who
report to department management.
What GAO Recommends:
GAO‘s March report recommends that the State IG and the Secretary of
State (1) develop a succession planning policy which avoids using
management personnel to serve in an acting IG capacity, (2) develop
staffing options to ensure State IG inspections are not led by Foreign
Service officials, (3) reassess the proper mix of audits and
inspections for department oversight, and (4) develop a formal
agreement with the department‘s Bureau of Diplomatic Security (DS) to
coordinate investigations.
In comments to our report the State IG disagreed with our
recommendations regarding the use of line management personnel as
acting IGs, not having inspections lead by Foreign Service officials,
and reassessing the mix of audit and inspection coverage. The IG did
agree to work with DS to develop a written agreement for
investigations. Consequently, we reaffirmed our recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-135T]. For more information, contact
Jeanette Franzel at (202) 512-9470 or franzelj@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I am pleased to be here today to discuss the activities of the
Department of State Office of Inspector General (State IG), which is
responsible for providing oversight of the department, the Broadcasting
Board of Governors, the foreign affairs community, and more than 260
embassies, consulates, and other posts worldwide. The State IG has a
critical responsibility to provide effective and objective oversight to
assist both the department and the Congress.
In our March 2007[Footnote 1] report on the activities of the State IG,
we raised a number of concerns about the lack of adequate resources,
the independence of the office, the lack of audit oversight in high-
risk areas, and the lack of assurance that the department is receiving
independent investigations.
My statement today is based primarily on our March report and recent
testimonies[Footnote 2] we have provided on the need for effective
inspector general (IG) offices. I will discuss in more detail (1) the
importance of auditor and IG independence, (2) independence concerns
regarding the State IG that are similar to those we reported almost
three decades ago, (3) gaps in State IG audit coverage in some high-
risk areas due to the IG's reliance on inspections, and (4) a lack of
assurance that investigations within the State Department are
independent of management. We performed this work in accordance with
generally accepted government auditing standards.
Background:
The current State IG was created by a 1986 amendment to the Inspector
General Act of 1978 (IG Act) to prevent and detect fraud, waste, abuse,
and mismanagement in the department's programs and operations; conduct
and supervise independent audits and investigations; and recommend
policies to promote economy, efficiency, and effectiveness. Unique to
the State IG is a requirement to provide inspections of the
department's Foreign Service posts, bureaus, and operating units. The
State Department has had inspection functions in various forms since
1906. The function has changed and evolved over the years in response
to numerous statutory changes.
Since the terrorist attacks of September 11, 2001, the State Department
has become involved in expanded reconstruction and stabilization roles
and manages a global presence that includes mobilizing some 180
countries and territories in the war on terrorism. To manage this
expanded role, the State Department's budget has increased over fiscal
years 2001 through 2006 from $13.7 billion to about $24 billion, an
increase of about 75 percent (55 percent in constant dollars adjusted
for inflation). At the same time, the State IG's budget has been
inadequate and its workforce has declined by approximately 20 percent.
For example, from 2001 to 2006, the State IG's budget for oversight has
increased from $29 million to $31 million, which when considered
relative to inflation, is a budget decrease of approximately 6 percent
over 6 years in constant dollars. During that same period, the State
IG's staffing level has declined from 227 to 182. Of the 318 authorized
staff in the State IG's fiscal year 2006 budget, the actual onboard
staff averaged 182, or about 57 percent of the authorized level. (See
fig. #1.)
In the State Department's Performance and Accountability Report
[Footnote 3] for fiscal year 2006, the State IG reported the need for
expanded oversight to encompass new department initiatives in
transformational diplomacy, global repositioning, and public diplomacy,
as well as substantial increases in programs for Iraq and Afghanistan,
counternarcotics, counterterrorism, embassy construction, and
information technology. In addition, the IG has noted significant
growth in the number of programs and grants with mandated IG oversight,
congressional and management requests for special reviews and
investigations, and opportunities for joint activities with other
departments.
Figure 1: State Department and IG Resources for Fiscal Years 2001
through 2006:
[See PDF for image]
Percentage change (fiscal years 2001–2006)
State IG: -6%;
State Department: +55%.
From fiscal year 2001 through 2006 the State IG‘s overall budgetary
resources went from $33 million to $31 million, which, expressed in
constant dollars, is a decrease of approximately 6 percent. Over the
same period of time the State Department‘s overall budgetary resources
increased from $15.5 billion to $24.0 billion for an increase of
approximately 55 percent in constant dollars.
Fiscal year: 2001;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources: $13,679;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources (in
constant dollars): $15,499;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG office budgetary resources: $29;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG budgetary resources (in constant
dollars): $33;
IG staff full-time equivalent (FTE) and actual staff:
Authorized FTEs: 289;
Actual staff: 227.
Fiscal year: 2002:
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources: $16,266;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources (in
constant dollars): $18,084;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG office budgetary resources: $29;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG budgetary resources (in constant
dollars): $32;
IG staff full-time equivalent (FTE) and actual staff:
Authorized FTEs: 314;
Actual staff: 229.
Fiscal year: 2003;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources: $16,311;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources (in
constant dollars): $17,775;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG office budgetary resources: $29;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG budgetary resources (in constant
dollars): $32;
IG staff full-time equivalent (FTE) and actual staff:
Authorized FTEs: 314;
Actual staff: 219.
Fiscal year: 2004;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources: $18,235;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources (in
constant dollars): $19,371;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG office budgetary resources: $32;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG budgetary resources (in constant
dollars): $34;
IG staff full-time equivalent (FTE) and actual staff:
Authorized FTEs: 314;
Actual staff: 214.
Fiscal year: 2005;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources: $22,371;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources (in
constant dollars): $23,061;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG office budgetary resources: $32;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG budgetary resources (in constant
dollars): $33;
IG staff full-time equivalent (FTE) and actual staff:
Authorized FTEs: 314;
Actual staff: 191.
Fiscal year: 2006;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources: $23,985;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), Department budgetary resources (in
constant dollars): $23,985;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG office budgetary resources: $31;
State Department and State IG total budgetary resources for fiscal
years 2001–2006 (in millions), IG budgetary resources (in constant
dollars): $31;
IG staff full-time equivalent (FTE) and actual staff:
Authorized FTEs: 318;
Actual staff: 182.
Source: OMB, State IG.
[End of figure]
The 1986 amendment that created the current IG office was a reaction to
concerns expressed in prior GAO reports in 1978 and 1982. In those
reports, we raised concerns about the independence of the previous IG
offices established administratively by the department and through
statutes prior to 1986.[Footnote 4] At the same time, our concerns
about the State IG's independence were based in part on the IG's use of
temporarily assigned Foreign Service officers to staff the IG office
for performing inspections.
Importance of Auditor and IG Independence:
We continue to be concerned about the independence of the State IG, an
issue that we first reported on almost three decades ago. Independence
is the cornerstone of professional auditing. Without independence, an
audit organization cannot conduct independent audits in compliance with
generally accepted government auditing standards (Government Auditing
Standards). Likewise, an IG who lacks independence cannot effectively
fulfill the full range of requirements for the office. Lacking this
critical attribute, an audit organization's work might be classified as
studies, research reports, consulting reports, or reviews, rather than
independent audits.
Independence is one of the most important elements of an effective IG
function. In fact, much of the IG Act provides specific protections to
IG independence that are unprecedented for an audit and investigative
function located within the organization being reviewed. These
protections are necessary in large part because of the unusual
reporting requirements of the IGs, who are both subject to the general
supervision and budget processes of the agencies they audit, while at
the same time being expected to provide independent reports of their
work externally to the Congress.
Government Auditing Standards[Footnote 5] states, "in all matters
relating to the audit work, the audit organization and the individual
auditor, whether government or public, must be free from personal,
external, and organizational impairments to independence, and must
avoid the appearance of such impairments to independence. Auditors and
audit organizations must maintain independence so that their opinions,
findings, conclusions, judgments, and recommendations will be impartial
and viewed as impartial by objective third parties with knowledge of
the relevant information." [Emphasis added.]
* Personal independence applies to individual auditors at all levels of
the audit organization, including the head of the organization.
Personal independence refers to the auditor's ability to remain
objective and maintain an independent attitude in all matters relating
to the audit, as well as the auditor's ability to be recognized by
others as independent. The auditor needs an independent and objective
state of mind that does not allow personal bias or the undue influence
of others to override the auditor's professional judgments. This
attitude is also referred to as intellectual honesty. The auditor must
also be free from direct financial or managerial involvement with the
audited entity or other potential conflicts of interest that might
create the perception that the auditor is not independent.
* External independence refers to both the auditor's and the audit
organization's freedom to make independent and objective judgments free
from external influences or pressures. Examples of impairments to
external independence include restrictions on access to records,
government officials, or other individuals needed to conduct the audit;
external interference over the assignment, appointment, compensation,
or promotion of audit personnel; restrictions on funds or other
resources provided to the audit organization that adversely affect the
audit organization's ability to carry out its responsibilities; or
external authority to overrule or to inappropriately influence the
auditors' judgment as to appropriate reporting content.
* Organizational independence refers to the audit organization's
placement in relation to the activities being audited. Professional
auditing standards have different criteria for organizational
independence for external and internal audit organizations. The IGs, in
their statutory role of providing oversight of their agencies'
operations, represent a unique hybrid of external and internal
reporting responsibilities.
The IG Act requires IGs to perform audits in compliance with Government
Auditing Standards. In addition, much of the act provides specific
protections to IG independence for all the work of the IGs. Protections
to IG independence include the requirement that IGs report only to
their agency heads and not to lower-level management,[Footnote 6] and a
prohibition on the ability of the agency head to prevent or prohibit
the IG from initiating, carrying out, or completing any audit or
investigation. This prohibition is meant to protect the IG office from
external forces that could compromise an IG's independence. The IG's
personal independence and the need to appear independent to
knowledgeable third parties is also critical when the IG makes
decisions related to the nature and scope of audit and investigative
work performed by the IG office. The IG must determine how to utilize
the IG Act's protection of independence in conducting and pursuing the
audit and investigative work. The IG's personal independence is
necessary to make the proper decisions in such cases.
The IG Act also provides the IG with protections to external
independence by providing access to all agency documents and records,
prompt access to the agency head, the ability to select and appoint IG
staff, the authority to obtain services of experts, and the authority
to enter into contracts. The IG may choose whether to exercise the
act's specific authority to obtain access to information that is denied
by agency officials. Again, each IG must make decisions regarding the
use of the IG Act's provisions for access to information, and the IG's
personal independence becomes key in making these decisions.
The IGs' external reporting requirements in the IG Act include
reporting the results of their work in semiannual reports to the
Congress. Under the IG Act, the IGs are to report their findings
without alteration by their respective agencies, and these reports are
to be made available to the general public. The IG Act also directs the
IGs to keep their agency heads and the Congress fully and currently
informed, which they do through these semiannual reports and otherwise,
of any problems, deficiencies, abuses, fraud, or other serious problems
relating to the administration of programs and operations of their
agencies. Also, the IGs are required to report particularly serious or
flagrant problems, abuses, or deficiencies immediately to their agency
heads, who are required to transmit the IG's report to the Congress
within 7 calendar days.
With the growing complexity of the federal government, the severity of
the problems it faces, and the fiscal constraints under which it
operates, it is important that an independent, objective, and reliable
IG structure be in place at federal agencies to ensure adequate audit
and investigative coverage of federal programs and operations. The IG
Act provides each IG with the ability to exercise judgment in the use
of protections to independence specified in the act. While the IG Act
provides for IG independence, the ultimate success or failure of an IG
office is largely determined by the individual IG placed in that office
and that person's ability to maintain personal, external, and
organizational independence both in fact and appearance while reporting
the results of the office's work to both the agency head and to the
Congress. An IG who lacks independence cannot effectively fulfill the
full range of requirements for the office.
Continuing Concerns regarding the State IG's Independence:
Two continuing areas of concern that we have with the independence of
the office of the State IG involve (1) the appointment of management
officials to head the State IG in an acting capacity for extended
periods of time and (2) the use of Foreign Service staff to lead State
IG inspections. These concerns are similar to those independence issues
we reported in our 1978 and 1982 reports.
In 1978, GAO reviewed the operations of the office of the IG of Foreign
Service and questioned the independence of Foreign Service officers who
were temporarily detailed from program offices to the IG's office. In
1982, we reviewed the operations of the IG and again expressed our
concerns about the independence of inspection staff reassigned to and
from management offices within the department. In these reports we
stated that the desire of State IG staff to receive favorable
assignments after their State IG tours could influence their
objectivity. Reacting to concerns similar to those in our 1982 report,
the Congress established an IG for the Department of State through
amendments to the IG Act in both 1985 and 1986. The 1986 amendment
requires the State IG continue to perform inspections of the
department's bureaus and posts, but also prohibits a career member of
the Foreign Service from being appointed as the State IG.
After almost three decades, we continue to have similar concerns
regarding the independence of the State IG's operations. In our March
2007 report we stated that during a period of approximately 27 months-
-from January 24, 2003, until May 2, 2005--four management officials
from the State Department were acting in an IG capacity. All four of
these officials served in the Foreign Service in prior line management
positions, including political appointments as U.S. ambassadors to
foreign countries. In addition, three of these officials returned to
significant management positions within the State Department after
heading the IG office. Therefore, over more than a 2-year period,
oversight of the State Department was being provided by the
department's own management officials. The 1986 amendment to the IG Act
that created the current IG office prohibits a career Foreign Service
official from becoming an IG of the State Department due to concerns
about personal impairments to independence that could result. That same
concern exists when Foreign Service officials head the State IG in an
acting capacity, resulting in limitations to the independence and
effectiveness of the office.
The second continuing concern discussed in our March 2007 report
regarding State IG independence deals with the use of Foreign Service
officers to lead inspections of the department's bureaus and posts.
This practice creates the mistaken impression that because these
inspections are products of an IG office, they are performed with the
appropriate IG independence. However, State IG policy is for
inspections to be led by Foreign Service officers at the ambassador
level who are expected to help formulate, implement, and defend
government policy. The resulting conflict of interest for career
Foreign Service staff and others at the ambassador level who lead
inspections that may criticize the department's policies provides an
appearance of impaired independence to the State IG's inspection
results.
To address these concerns about the independence of the State IG
Office, we recommended in our March 2007 report that the IG work with
the Secretary of State to develop a succession planning policy that
would prohibit career Foreign Service officers and other department
managers from heading the State IG office in an acting capacity and to
develop options to ensure that State IG inspections are not led by
career Foreign Service officials or other staff who rotate to
assignments within State Department management.
In formal comments to a draft of our March 2007 report, the State IG
agreed with our concerns about having career Foreign Service officers
serving in an acting IG capacity and acknowledged that the temporary
nature of such arrangements can have a debilitating effect on the
office particularly over a lengthy period of time. However, the State
IG disagreed with our recommendation that personnel with State
Department management careers also not be considered for acting IG
positions due to the need to obtain prompt and capable personnel to
fill these positions. Also, the State IG agreed that use of Foreign
Service personnel at the ambassador level to lead inspections does
create an appearance of impaired independence; however, the IG plans to
continue this practice in order to utilize the diplomatic expertise of
these Foreign Service officers, which the IG believes is necessary for
inspections.
We disagree with the State IG's comments. Independence is a critical
element for IG effectiveness and success and is at the heart of
auditing standards and the IG Act. The State IG's reluctance to take
steps that would preclude career management officials from leading the
office in an acting IG capacity and to stop the practice of having
Foreign Service officers at the ambassador level lead inspections
weakens the credibility of the entire office. For example, appointing
career department managers as acting State IGs could have the practical
effect of subjecting the State IG to supervision by management
officials other than the Secretary or Deputy Secretary. As noted above,
the IG Act limits supervision of the IG to the head of the department
or the principal deputy rather than lower-level managers as an
important protection to the IG's independence.
In addition, the State IG's decision to accept impairments to the
appearance of independence for all inspections performed at the
department limits the usefulness of these results for both the
department and the Congress in taking appropriate actions. We agree
that Foreign Service expertise could be a part of the inspection team,
but we disagree with placing independence second to experience and
expertise. The State IG can achieve both objectives with the proper
staffing and structuring of its inspections. To illustrate, our
position remains that the State IG's inspection teams should not be led
by career Foreign Service officers and ambassadors, but could include
experienced ambassadors and staff at the ambassador level as team
members, consultants, or advisors to help mitigate concerns about the
appearance of independence caused by the State IG's current practice.
State IG's Reliance on Inspections Results in Gaps in Audit Oversight
for High Risk Areas:
In addition to the specific requirements for independent audits and
investigations, the State IG has a unique statutory requirement to
inspect each post at least every 5 years. However, since 1996, the
Congress, through the department's appropriations acts, annually waives
the 5-year requirement. Nevertheless, the State IG completed
inspections at 223 of the department's 260 bureaus and posts over the 5-
year period of fiscal years 2001 through 2005. Consequently, the State
IG relies on inspections rather than audits to provide the primary
oversight of the State Department. As a comparison, in fiscal year
2005, the statutory IGs[Footnote 7] issued a total of 443 inspection
reports compared to 4,354 audit reports, a ratio of inspections to
audits of about 1 to 10. During the same year, the State IG issued 99
inspection reports and 44 audit reports during fiscal year 2005, or a
ratio of inspections to audits of over 2 to 1.
A troubling outcome of the State IG's heavy emphasis on inspections is
the resulting gaps in audit coverage for high-risk areas we have
identified and the management challenges reported annually by the State
IG in the department's performance and accountability reports. In our
reports of the government's high-risk areas issued in January
2003[Footnote 8] and January 2005,[Footnote 9] we identified seven such
areas at the State Department, which were also included in management
challenges identified by the State IG.[Footnote 10] These critical
areas are (1) the physical security and protection of people and
facilities, (2) information security, (3) financial management, (4)
human resources, (5) counterterrorism and border security, (6) public
diplomacy, and (7) postconflict stabilization and reconstruction.
To illustrate the State IG's reliance on inspections for oversight of
these areas during fiscal years 2004 and 2005 combined, the State IG
covered human resource issues with 1 audit and 103 inspections,
counterterrorism and border security with 2 audits and 190 inspections,
public diplomacy with 2 audits and 103 inspections, and information
security with 1 audit and 13 inspections. (See table 1.) The high-risk
areas of physical security and protection of people and facilities had
limited audit coverage that addressed specific contracts and
procurements, whereas financial management was covered by the State
IG's financial audits. Postconflict stabilization and reconstruction
was covered by both audits and inspections.
Table 1: State IG Audit and Inspection Coverage of High-Risk Areas and
Management Challenges for Fiscal Years 2004 through 2005:
GAO high-risk areas[A]: Physical security and management of U.S.
facilities overseas;
Management challenges identified by the State IG[B]: Protection of
people and facilities;
Fiscal year 2004 State IG reports[C]: Audits: 27;
Fiscal year 2004 State IG reports[C]: Inspections: 98;
Fiscal year 2005 State IG reports[D]: Audits: 21;
Fiscal year 2005 State IG reports[D]: Inspections: 92.
GAO high-risk areas[A]: Enhance information technology and security,
strengthen financial management, improve performance planning[E];
Management challenges identified by the State IG[B]: Information
security;
Fiscal year 2004 State IG reports[C]: Audits: 1;
Fiscal year 2004 State IG reports[C]: Inspections: 6;
Fiscal year 2005 State IG reports[D]: Audits: 0;
Fiscal year 2005 State IG reports[D]: Inspections: 7.
GAO high-risk areas[A]: [Empty];
Management challenges identified by the State IG[B]: Financial
management;
Fiscal year 2004 State IG reports[C]: Audits: 10;
Fiscal year 2004 State IG reports[C]: Inspections: 0[F];
Fiscal year 2005 State IG reports[D]: Audits: 16;
Fiscal year 2005 State IG reports[D]: Inspections: 0[F].
GAO high-risk areas[A]: Continue to rightsize embassy staffing levels;
Management challenges identified by the State IG[B]: Human resources;
Fiscal year 2004 State IG reports[C]: Audits: 1;
Fiscal year 2004 State IG reports[C]: Inspections: 50;
Fiscal year 2005 State IG reports[D]: Audits: 0;
Fiscal year 2005 State IG reports[D]: Inspections: 53.
GAO high-risk areas[A]: Better manage human capital strategies;
Management challenges identified by the State IG[B]: [Empty];
Fiscal year 2004 State IG reports[C]: Audits: [Empty];
Fiscal year 2004 State IG reports[C]: Inspections: [Empty];
Fiscal year 2005 State IG reports[D]: Audits: [Empty];
Fiscal year 2005 State IG reports[D]: Inspections: [Empty].
GAO high-risk areas[A]: Strengthen the visa process through issuance of
policies and procedures as an antiterrorism tool;
Management challenges identified by the State IG[B]: Counterterrorism
and border security;
Fiscal year 2004 State IG reports[C]: Audits: 0;
Fiscal year 2004 State IG reports[C]: Inspections: 98;
Fiscal year 2005 State IG reports[D]: Audits: 2;
Fiscal year 2005 State IG reports[D]: Inspections: 92.
GAO high-risk areas[A]: Improve the management of public diplomacy
programs;
Management challenges identified by the State IG[B]: Public diplomacy;
Fiscal year 2004 State IG reports[C]: Audits: 1;
Fiscal year 2004 State IG reports[C]: Inspections: 50;
Fiscal year 2005 State IG reports[D]: Audits: 1;
Fiscal year 2005 State IG reports[D]: Inspections: 53.
GAO high-risk areas[A]: Manage the large-scale reconstruction and
nation-building programs;
Management challenges identified by the State IG[B]: Postconflict
stabilization and reconstruction;
Fiscal year 2004 State IG reports[C]: Audits: 4;
Fiscal year 2004 State IG reports[C]: Inspections: 0;
Fiscal year 2005 State IG reports[D]: Audits: 4;
Fiscal year 2005 State IG reports[D]: Inspections: 6.
GAO high-risk areas[A]: Total high-risk areas and management challenges
addressed by audit and inspection reports;
Management challenges identified by the State IG[B]: [Empty];
Fiscal year 2004 State IG reports[C]: Audits: 44;
Fiscal year 2004 State IG reports[C]: Inspections: 302;
Fiscal year 2005 State IG reports[D]: Audits: 44;
Fiscal year 2005 State IG reports[D]: Inspections: 303.
GAO high-risk areas[A]: Total audit and inspection reports issued;
Management challenges identified by the State IG[B]: [Empty];
Fiscal year 2004 State IG reports[C]: Audits: 44;
Fiscal year 2004 State IG reports[C]: Inspections: 104;
Fiscal year 2005 State IG reports[D]: Audits: 44;
Fiscal year 2005 State IG reports[D]: Inspections: 99.
Source: GAO.
[A] GAO-05-207 and GAO-03-119.
[B] Department of State, Fiscal Year 2005 Performance and
Accountability Report.
[C] State IG semiannual reports to the Congress for the periods ending
March 31 and September 30, 2004.
[D] State IG semiannual reports to the Congress for the periods ending
March 31 and September 30, 2005.
[E] Strategic and performance planning were removed in recognition of
the State Department's considerable progress in addressing that
challenge.
[F] Post inspections include a selected financial management component.
[End of table]
Because of State IG's heavy reliance on inspections, it is important to
note that there are fundamental differences between inspections and
audits. Audits performed under Government Auditing Standards[Footnote
11] are subject to more in-depth requirements in the areas of
sufficient, appropriate, relevant, and complete evidence and
documentation supporting the findings than are inspections performed
under the Quality Standards for Inspections.[Footnote 12] Also,
auditing standards require independent external quality reviews of
audits, or peer reviews, on a 3-year cycle, while inspection standards
do not call for any such external quality reviews.
We reviewed the documentation for 10 State IG inspections to gain an
understanding of the extent of documented evidence to support each
report's findings and recommendations.[Footnote 13] We found that the
inspectors relied heavily on questionnaires completed by management at
each bureau or post that was inspected, official department documents,
correspondence and electronic mail, internal department memorandums,
interviews, and the inspection review summaries. We did not find any
examples of additional testing of evidence or sampling of agency
responses to questionnaires and interviews to test for the accuracy,
relevance, validity, and reliability of the information as would be
required by auditing standards. In other words, for the inspections we
reviewed, the State IG's results relied on the responses of department
management through questionnaires, interviews, and agency documents
without further verification.
We also found that for 43 of the 183 recommendations contained in the
10 inspections we reviewed, the inspection files did not contain
documented support of any kind beyond the written summaries of the
findings and recommendations contained in the final inspection reports.
While the State IG's inspection policies require that supporting
documentation be attached to the written summaries, the summaries
indicated that there was no additional supporting documentation. Due to
the significance of the high-risk areas covered largely by inspections,
the limited nature of inspections, and the appearance of impaired
independence, the State IG would benefit by reassessing the mix of
audit and inspection coverage for those areas.
In our March 2007 report, we recommended that in order to provide the
appropriate breadth and depth of oversight coverage at the department,
especially in high-risk areas and management challenges, the State IG
reassess the proper mix of audit and inspection coverage. This
assessment should include an analysis of an appropriate level of
resources needed to address the increasing growth of the department's
risks and responsibilities.
In formal comments on our report, the State IG disagreed with our
recommendation to reassess the mix of audit and inspection coverage
while agreeing that inspections are much more subjective than audits
and have a different level of requirements for evidence. The State IG
explained that the use of inspections is due to the congressional
mandate for IG inspections, which has been waived annually late in the
IG's planning cycle, and the limited resources to hire more auditors.
Therefore, things that could be done in an audit have to be done
through inspections.
We remain concerned that the State IG's current mix of audits and
inspections does not provide adequate independent oversight. In
addition, the State IG's use of inspections can create an "expectation
gap" that inspections will have the same credibility and independence
as the IG's audits. By ultimately placing the results of inspections in
the IG's semiannual reports without clarifying that they are a
substitute for audit coverage and are fundamentally limited in their
results, the IG may be creating a misleading image of oversight
coverage of the department and its high-risk areas.
Department Lacks Assurance of Obtaining Independent IG Investigations:
The IG Act, as amended, established the State IG to conduct and
supervise independent investigations, in addition to audits, in order
to prevent and detect fraud, waste, abuse, and mismanagement in the
State Department.[Footnote 14] In addition, the department's Bureau of
Diplomatic Security (DS), as part of its worldwide responsibilities for
law enforcement and security operations, also performs investigations
that include passport and visa fraud both externally and within the
department.
While both the State IG and DS pursue allegations of passport and visa
fraud by State Department employees, DS reports organizationally to the
State Department Undersecretary for Management and is performing
investigations as a function of management. Therefore, DS
investigations of department employees, especially when management
officials are the subjects of allegations, can result in management
investigating itself. In contrast, the State IG is required by the IG
Act to be independent of the offices and functions it investigates.
However, State IG officials stated that they were aware of DS
investigations in these areas that were not coordinated with the State
IG.
Our March 2007 report noted that DS and the State IG had no functional
written agreement or other formal mechanism in place to coordinate
their investigative activities. Without a formal agreement to outline
the responsibilities of both DS and the State IG regarding these
investigations, there is inadequate assurance that this work will be
coordinated to avoid duplication or that independent investigations of
department personnel will be performed. Moreover, we also reported that
in fiscal year 2005, DS entailed a global force of approximately 32,000
special agents, security specialists, and other professionals who make
up the security and law enforcement arm of the State Department. In
contrast, the State IG, which also has global responsibilities for
independent investigations of the State Department, had a total of 21
positions in its investigative office with 10 investigators onboard at
the time of our review.
In other federal agencies where significant law enforcement functions
like those of DS exist alongside their IGs, the division of
investigative functions between the agency and the IG is established
through written agreement. Our March report provides examples of formal
written agreements between (1) the U.S. Postal Service IG and the Chief
Postal Inspector who heads the U.S. Postal Inspection Service and (2)
the Treasury Inspector General for Tax Administration and the Internal
Revenue Service's Criminal Investigation. These signed memorandums can
serve as models for a formal agreement between DS and the State IG for
delineating jurisdiction in investigative matters to help ensure that
the independence requirements of the IG Act are implemented.
In order to provide for independent investigations of State Department
management and to prevent duplicative investigations, we recommended in
our March 2007 report that the State IG work with DS and the Secretary
of State to develop a formal, written agreement that delineates the
areas of responsibility for State Department investigations. In
comments on our report, the State IG agreed with this recommendation.
Concluding Observations:
The mission of the State IG is critical to providing independent and
objective oversight of the State Department and identifying any
mismanagement of scarce taxpayer dollars. However, the effectiveness of
the IG's oversight is limited by the lack of resources, the lack of an
appearance of independence, gaps in audit coverage of high-risk areas,
and the lack of assurance that investigations of internal department
operations are performed by independent IG investigators. We made
recommendations to address each of these areas in our related report
(GAO-07-138). Overall, our recommendations are intended to assist in
strengthening the IG office and the independence and effectiveness of
oversight of the State Department.
We remain concerned about the weaknesses identified especially in light
of the State IG's response to our March 2007 report. The State IG's
comments to our report defend the status quo, and indicate an
inadequate concern and regard for the independence necessary to provide
effective and credible oversight of the department. Consequently, we
reiterated the importance of our recommendations because of our
continuing concerns about the adequacy of independent oversight
provided by the State IG.
Mr. Chairman, this concludes my prepared statement. I would be happy to
respond to any questions you or other members of the subcommittee might
have at this time.
Contacts and Acknowledgments:
If you have any additional questions on matters discussed in this
testimony, please contact Jeanette Franzel at (202) 512-9471 or by e-
mail at franzelj@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this testimony. Other key contributors to this testimony
include Jackson Hufnagle (Assistant Director) and Clarence Whitt.
[End of section]
Appendix I: A Comparison of Agency and IG Fiscal Year 2006 Budgetary
Resources (Dollars in millions):
No. 1;
Federal departments and agencies: Nuclear Regulatory Commission;
IG total budgetary resources: $10;
Agency total budgetary resources: $811;
IG budgetary resources as a percentage of agency budgetary resources:
1.23.
No. 2; Federal departments and agencies: Corporation for National and
Community Service;
IG total budgetary resources: 8;
Agency total budgetary resources: 1,267;
IG budgetary resources as a percentage of agency budgetary resources:
0.63.
No. 3; Federal departments and agencies: Small Business Administration;
IG total budgetary resources: 21;
Agency total budgetary resources: 3,950;
IG budgetary resources as a percentage of agency budgetary resources:
0.53.
No. 4; Federal departments and agencies: Environmental Protection
Agency;
IG total budgetary resources: 54;
Agency total budgetary resources: 13,383;
IG budgetary resources as a percentage of agency budgetary resources:
0.40.
No. 5; Federal departments and agencies: Agency for International
Development;
IG total budgetary resources: 47;
Agency total budgetary resources: 12,984[A];
IG budgetary resources as a percentage of agency budgetary resources:
0.36.
No. 6; Federal departments and agencies: Department of Justice;
IG total budgetary resources: 83;
Agency total budgetary resources: 33,031;
IG budgetary resources as a percentage of agency budgetary resources:
0.25.
No. 7; Federal departments and agencies: Department of Commerce;
IG total budgetary resources: 22;
Agency total budgetary resources: 10,764;
IG budgetary resources as a percentage of agency budgetary resources:
0.20.
No. 8; Federal departments and agencies: Treasury Inspector General for
Tax Administration[B];
IG total budgetary resources: 134;
Agency total budgetary resources: 66,964;
IG budgetary resources as a percentage of agency budgetary resources:
0.20.
No. 9; Federal departments and agencies: General Services
Administration;
IG total budgetary resources: 48;
Agency total budgetary resources: 25,356;
IG budgetary resources as a percentage of agency budgetary resources:
0.19.
No. 10; Federal departments and agencies: Tennessee Valley Authority
(TVA);
IG total budgetary resources: 15[C];
Agency total budgetary resources: 9,265;
IG budgetary resources as a percentage of agency budgetary resources:
0.16.
No. 11; Federal departments and agencies: National Aeronautics and
Space Administration;
IG total budgetary resources: 32;
Agency total budgetary resources: 19,881;
IG budgetary resources as a percentage of agency budgetary resources:
0.16.
No. 12; Federal departments and agencies: Department of the Interior;
IG total budgetary resources: 42;
Agency total budgetary resources: 27,604;
IG budgetary resources as a percentage of agency budgetary resources:
0.15.
No. 13; Federal departments and agencies: Department of State;
IG total budgetary resources: 31;
Agency total budgetary resources: 23,985[D];
IG budgetary resources as a percentage of agency budgetary resources:
0.13.
No. 14; Dollars in millions: Federal departments and agencies:
Department of Energy;
IG total budgetary resources: 42;
Agency total budgetary resources: 34,392;
IG budgetary resources as a percentage of agency budgetary resources:
0.12.
No. 15; Federal departments and agencies: Department of Housing and
Urban Development;
IG total budgetary resources: 114;
Agency total budgetary resources: 98,189;
IG budgetary resources as a percentage of agency budgetary resources:
0.12.
No. 16; Federal departments and agencies: Department of Homeland
Security;
IG total budgetary resources: 120;
Agency total budgetary resources: 104,577;
IG budgetary resources as a percentage of agency budgetary resources:
0.11.
No. 17; Federal departments and agencies: Department of Labor;
IG total budgetary resources: 71;
Agency total budgetary resources: 75,744;
IG budgetary resources as a percentage of agency budgetary resources:
0.09.
No. 18; Federal departments and agencies: Department of Veterans
Affairs;
IG total budgetary resources: 75;
Agency total budgetary resources: 88,018;
IG budgetary resources as a percentage of agency budgetary resources:
0.09.
No. 19; Federal departments and agencies: Railroad Retirement Board;
IG total budgetary resources: 7;
Agency total budgetary resources: 11,305;
IG budgetary resources as a percentage of agency budgetary resources:
0.06.
No. 20; Federal departments and agencies: Department of Agriculture;
IG total budgetary resources: 88;
Agency total budgetary resources: 143,228;
IG budgetary resources as a percentage of agency budgetary resources:
0.06.
No. 21; Dollars in millions: Federal departments and agencies:
Department of Transportation;
IG total budgetary resources: 69;
Agency total budgetary resources: 116,769;
IG budgetary resources as a percentage of agency budgetary resources:
0.06.
No. 22; Federal departments and agencies: Department of Health and
Human Services;
IG total budgetary resources: 512[E];
Agency total budgetary resources: 947,318;
IG budgetary resources as a percentage of agency budgetary resources:
0.05.
No. 23; Federal departments and agencies: Department of Education;
IG total budgetary resources: 49;
Agency total budgetary resources: 108,823;
IG budgetary resources as a percentage of agency budgetary resources:
0.05.
No. 24; Federal departments and agencies: Federal Deposit Insurance
Corporation;
IG total budgetary resources: 23;
Agency total budgetary resources: 51,848;
IG budgetary resources as a percentage of agency budgetary resources:
0.04.
No. 25; Federal departments and agencies: Department of Defense -
Military;
IG total budgetary resources: 214;
Agency total budgetary resources: 756,136;
IG budgetary resources as a percentage of agency budgetary resources:
0.03.
No. 26; Federal departments and agencies: Social Security
Administration;
IG total budgetary resources: 92;
Agency total budgetary resources: 630,549;
IG budgetary resources as a percentage of agency budgetary resources:
0.01.
No. 27; Federal departments and agencies: Office of Personnel
Management;
IG total budgetary resources: 18;
Agency total budgetary resources: 173,168;
IG budgetary resources as a percentage of agency budgetary resources:
0.01.
No. 28; Federal departments and agencies: Department of the Treasury;
IG total budgetary resources: 19;
Agency total budgetary resources: 389,581[F];
IG budgetary resources as a percentage of agency budgetary resources:
0.005.
No. 29; Federal departments and agencies: Central Intelligence Agency;
IG total budgetary resources: na[G];
Agency total budgetary resources: na[G];
IG budgetary resources as a percentage of agency budgetary resources:
na[G].
Source: GAO analysis of OMB data:
Note: The agencies presented are those with IGs established by the IG
Act and appointed by the President.
[A] Total budgetary resources appearing in the Agency for International
Development's FY 2006 Performance and Accountability Report.
[B] The Treasury Inspector General for Tax Administration is the IG for
the Internal Revenue Service (IRS).
[C] Amount for TVA IG is from PCIE.
[D] State Department budget does not include amounts for the
Broadcasting Board of Governors.
[E] Includes budget authority to combat Medicare and Medicaid fraud.
[F] Department of the Treasury's budgetary resources exclude IRS.
[G] Information is not available.
[End of table]
[End of section]
Footnotes:
[1] GAO, Inspectors General: Activities of the Department of State
Office of Inspector General, GAO-07-138 (Washington, D.C.: Mar. 23,
2007).
[2] GAO, Inspectors General: Proposals to Strengthen Independence and
Accountability, GAO-07-1021T (Washington, D.C.: June 20, 2007), and
Inspectors General: Opportunities to Enhance Independence and
Accountability, GAO-07-1089T (Washington, D.C.: July 11, 2007).
[3] United States Department of State, Performance and Accountability
Report, Fiscal Year 2006.
[4] GAO, State Department's Office of Inspector General, Foreign
Service, Needs to improve Its Internal Evaluation Process, ID-78-19
(Washington, D.C.: Dec. 6, 1978), and State Department's Office of
Inspector General Should Be More Independent and Effective, GAO/ AFMD-
83-56 (Washington, D.C.: June 2, 1982).
[5] GAO, Government Auditing Standards, January 2007 Revision, GAO-07-
162G, Secs. 3.02 and 3.03 (Washington, D.C.: January 2007).
[6] The head of the agency may delegate supervision of the IG only to
the officer next in rank below the agency head.
[7] There are currently 64 statutory IG offices in the federal
government created by the IG Act, as amended, and other legislation.
[8] GAO, High-Risk Series: An Update, GAO-03-119 (Washington, D.C.:
January 2003).
[9] GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.:
January 2005).
[10] The Reports Consolidation Act of 2000, Pub. L. No. 106-531, 114
Stat. 2537, 2538 (Nov. 22, 2000), requires executive agencies,
including the State Department, to include their IGs' lists of
significant management challenges in their annual performance and
accountability reports to the President, the Office of Management and
Budget, and the Congress.
[11] IGs are required by the IG Act to follow Government Auditing
Standards when performing audits. 5 U.S.C. App. § 4(b)(1)(A).
[12] Use of inspection standards by the IGs is not mandated by statute.
Rather, IGs are encouraged by the President's Council on Integrity and
Efficiency (PCIE) and the Executive Council on Integrity and Efficiency
(ECIE) to follow the councils' jointly created standards, Quality
Standards for Inspections, when conducting inspections. PCIE is
composed principally of the presidentially appointed and Senate-
confirmed IGs, and ECIE is composed principally of IGs appointed by the
heads of designated federal entities defined by the IG Act. Both were
established by Executive Order to coordinate and enhance the work of
the IGs.
[13] The 10 inspections were taken from a total of 112 inspections
completed over fiscal years 2004 and 2005 that were not classified for
national security purposes, and did not include inspections of the
Board of Broadcasting Governors.
[14] 5 U.S.C. App. § 2.
[End of section]
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