Table of Contents

I.  INTRODUCTION 2

II. AUDITS 6

III. INVESTIGATIONS 15

IV. LEGISLATION 19

V.  TECHNICAL ADVICE AND ASSISTANCE 20

VI. SPECIFIC REPORTING REQUIREMENTS OF SECTION 5(a)

OF THE INSPECTOR GENERAL ACT 23

ATTACHMENTS

A.  TABLE I: OIG AUDIT REPORTS WITH QUESTIONED COST

B.  TABLE II: OIG AUDIT REPORTS WITH RECOMMENDATIONS

    THAT FUNDS BE PUT TO BETTER USE

    Introduction

> ![](media/image1.wmf)The Federal Communications Commission (FCC) is an
> independent regulatory agency exercising authority delegated to it by
> Congress under the Communications Act of 1934 as amended by the
> Telecommunications Act of 1996. The FCC is charged with regulating
> interstate and international communications by radio, television,
> wire, satellite and cable. The FCC\'s jurisdiction covers the fifty
> states, the District of Columbia, and U.S. possessions. The mandate of
> the FCC under the Communications Act is to make available to all
> people of the United States a rapid, efficient, nationwide, and
> worldwide wire and radio communication service. The FCC performs four
> major functions to fulfill this charge:

-   spectrum allocation;

-   creating rules to promote fair competition and protect consumers
    where required by market conditions;

-   authorization of service; and

-   enforcement.

> The Chairman and four Commissioners are appointed by the President and
> confirmed by the Senate. William E. Kennard was confirmed as Chairman
> on October 29, 1997. Harold W. Furchtgott-Roth, Michael Powell, Gloria
> Tristani and Susan P. Ness serve as Commissioners. The majority of FCC
> employees are located in Washington, DC. FCC field offices and
> resident agents are located throughout the United States. FCC
> headquarters staff are now housed in entirety in the Portals II
> building located at 445 12^th^ Street, SW, Washington D.C. 20554.
> Office of Inspector General (OIG) personnel continue to work with the
> FCC Security Officer to evaluate overall building security and develop
> recommendations as appropriate to best ensure the safety and integrity
> of FCC staff and operational systems.
>
> The OIG has dedicated itself to assisting the Commission as it
> continues to improve its efficiency and effectiveness. The Inspector
> General (IG), H. Walker Feaster III, reports directly to the Chairman.
> The OIG is now located in the West wing of the Portals II in the FCC
> headquarters building at 445 12^th^ Street, SW, Washington, D.C.
> 20554. With the departure of Paul Brachfeld to the National Archives
> and Records Administration as Inspector General, Thomas D. Bennett was
> appointed as the Assistant Inspector General for Audits (AIGA).
> Charles J. Willoughby serves as the Counsel and Assistant Inspector
> General for Investigations (AIGI).
>
> *This report includes the major accomplishments and general activities
> of the OIG during the period October 1, 1999, through March 31, 2000,
> in accordance with Section 5 of the Inspector General Act of 1978, as
> amended 5 U.S.C. App. 3, 5.*
>
> ***[Highlighted OIG Activity]{.underline}***

Year 2000

As part of our program of monitoring and supporting Commission efforts
to address the Year 2000 problem, the OIG performed a series of reviews
to determine Commission readiness. For example, we performed a special
review of Business Continuity & Contingency Planning (BCCP). The
objective of this review was to evaluate the status of continuity
planning. As a result of this review, we reported that the Commission
did not have a sufficiently detailed and tested BCCP in place to prepare
for an outage of one or more mission critical systems (with one
exception). We recommended that the Commission work aggressively to
institute and test BCCP\'s for all mission critical systems.

In addition to reviewing BCCP activities, we performed a special review
to assess the feasibility of the Commission's plan to ensure the
continuity and operation of core business processes during the midnight
transition from December 31, 1999 continuing through the first day of
business January 3, 2000 (i.e., the "Day One Plan"). As a result of this
review, we reported that the Day One Plan needs to accurately reflect
the current status of Y2K readiness and that the plan did not adequately
address Day One rehearsal and reporting activities. The Commission
successfully completed the transition to Year 2000 without any major
problems.

Spectrum Auctions

As part of the Omnibus Budget Reconciliation Act of 1993, the Federal
Communications Commission (FCC) was authorized by Congress to auction
electromagnetic spectrum. Since the inception of the "auctions program",
the OIG has performed numerous reviews of various aspects of the
program, ranging from application processing and bid management through
detailed technical reviews of Information Technology (IT) management.
During this semiannual reporting period, we participated in a
multi-agency OIG review entitled "PCIE/ECIE Review of Non-Tax Delinquent
Debt" as part of our ongoing review of this critical program. The
objective of this review was to assess the collectibility of delinquent
debts that have arisen out of the spectrum auctioning process and
evaluating the portfolio management activities of the FCC to ensure that
these practices minimize losses to the Government. As a result of this
review, we reported that the FCC is experiencing significant collection
issues with its Spectrum Auction installment loan portfolio. Based on
discussions with FCC management and other information obtained, the high
level of FCC's delinquent debt is due to a number of contributing
factors including, but not limited to, balancing program social goals
with the need for front-end loan underwriting, changes in market
conditions, and inability of licensees to raise additional capital. The
CFO has reported implementation of three of the seventeen accepted
recommendations thus far and partial implementation of three others.

In addition to our review of Non-Tax Delinquent Debt, we performed a
special review of IT security for the critical Commission sub-network
supporting auction operations. This review was initiated in response to
a referral from the Commission's Computer Security Officer. Based upon
initial reports of potential system compromise, the OIG established a
task order under our contract with a computer security firm and created
a review team comprised of representatives from the contractor and OIG.
During the review, we determined that the system had not been
compromised and that the incident actually resulted from a feature of
the database management system. However, as part of the review process
we examined aspects of security and technology management and identified
areas where improvements could be made..

Financial Management

During the semiannual reporting period, the OIG, with the support of an
independent CPA firm, substantially completed audit work relating to the
FY 1999 audit of FCC's financial statement. Draft versions of the
independent auditor's report and related reports on internal control and
compliance were submitted for agency management's review and outstanding
issue resolution. Additionally, FCC management is resolving issues
precluding general release of its FY 1999 financial statement.

Field Inspection Program

*The OIG conducts inspections of Commission field offices as part of the
Field Inspection Program (FIP). We conduct field inspections in order to
independently assess and report upon the effectiveness and efficiency of
field operations. The FIP also serves as a means to evaluate and test
internal controls, address employee concerns, identify best practices
and, conversely, impediments to operations. During the semiannual
reporting period, we prepared a report summarizing the results of field
inspection visits during FY 1999. A recurrent concern raised by the
field employees during FY 1999 field office visits was over personal
safety when responding to interference complaints or unauthorized
transmissions, particularly in areas with significant "local militia"
activities. On January 27, the Chief of the Enforcement Bureau reminded
all of its employees to follow all existing Field safety policies while
a study was conducted to see what, if any, additional steps should be
taken to maximize employee safety.*

For the current fiscal year, we are assessing the FIP to determine
whether the program should be modified in its scope and conduct. The
review procedures utilized in the FIP have not been materially revised
since the program's inception. We are currently identifying areas where
the program can be enhanced and developing a risk-based approach to
selecting sites for field visits. This effort is being performed through
internal review of procedures used in prior FIPs, discussions with
Commission representatives to obtain their suggestions, and review of
similar programs in other federal agencies. Due to budget constraints,
funding for travel expenses is currently under severe limitations. As a
result, we may forgo the conduct of the FIP in fiscal year 2000, and
concentrate our effort on revamping the program for future fiscal years.

***Technical Advice and Assistance***

*OIG continued to broaden its role as a provider of technical advice and
assistance to Agency officials in developing sound management
information and financial reporting systems and in streamlining programs
and organizations. In addition to concentrating in the areas of
financial management and procurement, we worked closely with Commission
representatives to develop a Systems Development Life Cycle and
participated with the Licensing Work Group.*

*OIG continued to further FCC employees' understanding of the role of
the Inspector General by publishing the first edition of the OIG
Policies and Procedures in pamphlet form. Copies have been widely
distributed throughout the Commission.*

***Audits***

***OVERVIEW***

*During the semiannual reporting period, the Office of Inspector General
(OIG) issued the following reports:*

1.  *October 21, 1999 -- Special Review Report of the Commission's Draft
    Business Continuity and Contingency Plan (BCCP)*

2.  *November 2, 1999 -- Status Report on the Commission's Year 2000
    Activities*

3.  *December 23, 1999 -- Reports Related to Non-Tax Delinquent Debt*

4.  *March 28, 2000 -- Report on Special Review of Auctions Security*

*OIG reports can generally be obtained via the Internet from the OIG
webpage located on the FCC website \[http://www.fcc.gov/oig/\]. However,
OIG reports containing sensitive or proprietary information will be
restricted to specific individuals and organizations with a need to know
the detailed information.*

***OIG REPORTS ISSUED***

***Special Review Report of the Commission's Draft Business Continuity
and Contingency Plan (BCCP) issued on October 21, 1999, Report No.
00-AUD-01-02***

As part of the OIG's monitoring and support of the FCC's internal
efforts to address the Year 2000 problem, the OIG performed a special
review of the critical area of Business Continuity & Contingency Plans
(BCCPs). OIG auditors reported that the Commission had made progress
addressing BCCP issues for the Year 2000 problem. However, the FCC did
not have a sufficiently detailed and tested BCCP in place to prepare for
an outage of one or more mission critical systems (with one exception).
As of October 6, 1999, the Commission had not completed thirteen of its
fourteen local BCCPs for its Bureaus and Offices. No documented plan had
been tested.

OIG auditors recommended that the Commission continue to aggressively
work to institute and test BCCP\'s for all mission critical systems.
Further, we recommended that, if timing is insufficient to fully
simulation test all systems, only those systems of the highest
criticality and risk should be simulation tested. All systems should, at
a minimum, be subject to an independent desktop test. We noted that a
desktop test is not optimal, as it does not replicate the conditions
related to an actual system outage. Nonetheless, a desktop test provides
some measure of familiarity to program operators and users of
contingency measures, which may require implementation.

Status Report on the Commission's Year 2000 Activities issued on
November 2, 1999, Report No. 00-AUD-01-02

As part of the OIG's monitoring and support of the FCC's internal
efforts to address the Year 2000 problem, we performed a special review
to assess the feasibility of the FCC\'s Year 2000 Day One Plan. A Day
One Plan is a document designed to ensure the continuity and operation
of the FCC's core business processes during the midnight transition from
December 31, 1999 to January 1, 2000, continuing through the first day
of business January 3, 2000. As a result of our review, we reported
that:

-   The Day One Plan needs to accurately reflect the current status of
    Y2K readiness

-   The Plan does not adequately address Day One rehearsal and reporting
    activities.

The Commission agreed with the findings and stated that these conditions
were caused by the short time frame in which the FCC had to comply with
the development of this plan for the Office of Management and Budget
(OMB). The Commission also stated that they would carry out rehearsal
activities in December 1999. The transition to Year 2000 was
successfully completed without any major problems.

Reports on Non-Tax Delinquent Debt issued on December 23, 1999, Report
No. 00-AUD-01-03

We participated in a Government-wide review of Non-Tax Delinquent Debt
sponsored by the President's Council on Integrity and Efficiency (PCIE).
This review was initiated by the PCIE in response to concerns raised by
the Subcommittee on Government Management, Information and Technology,
Committee on Government Oversight and Reform. The primary objectives of
the Government-wide PCIE Review were to (1) determine whether previously
reported amounts of Federal government-wide non-tax delinquent debt
accurately represent the universe of non-tax delinquent debt, and (2) to
attempt to assess the collectibility of the delinquent debt. To
accomplish the objectives of the review, we established a task order
with the Public Accounting firm of Ernst & Young LLP (hereinafter
referred to as "Ernst & Young"). Ernst & Young used a performance review
guide prepared by the Department of the Treasury to conduct the review.
In addition, at our direction, the scope of the review was limited to
FCC's Spectrum Auction installment loan program.

*Ernst & Young concluded that the FCC is experiencing significant
collection issues with its Spectrum Auction installment loan portfolio.
Based on discussions with FCC management and other information obtained,
the high level of FCC's delinquent debt is due to a number of
contributing factors including, but not limited to, balancing program
social goals with the need for front-end loan underwriting, changes in
market conditions, and inability of licensees to raise additional
capital. The FCC's collection efforts have also been hampered by various
internal and external accounting and organizational problems, such as:*

-   *unclear and undefined internal FCC debt collection policies,
    procedures and responsibilities;*

-   *non-performance of certain debt collection activities;*

-   *insufficient reporting and monitoring of installment loan portfolio
    performance; and*

-   *difficulties and problems with the outsourced Nortridge Loan
    Tracking System.*

To address the current situation, the FCC is taking steps to improve
debt management practices, including defining the bureaus and offices
responsible for collection actions as well as formalizing and
documenting debt management policies and procedures. This project
resulted in eighteen formal recommendations of which management
concurred with seventeen. We believe that this commitment on the part of
the FCC to address deficiencies in the auction loan program will result
in more accurate computation and reporting of loan balances. This
effort, when taken in conjunction with improved loan servicing and debt
collection practices, as recommended by this office, will result in
overall program improvements. These improvement in internal controls,
consistency in processing standards, and compliance with Federal laws
and regulations will result in better protection of the financial assets
of the Federal government. The CFO has reported implementation of three
of the seventeen recommendations thus far and partial implementation of
three others.

Fiscal Year 1999 Field Inspection Program -- Summary Inspection Report
issued on

January 21, 2000, Report No. 00-AUD-01-15

*The OIG conducts an annual review known as the Field Inspection
Program, or FIP. This program has been in place since 1996 and has
proven to be a useful management tool for the Commission. The FIP
consists of OIG visits to selected field offices to perform a detailed
review of office procedures for controls over program functions and
administrative activities. Additionally, field office employees are
given the opportunity to discuss their concerns with OIG auditors and
provide feedback to Commission management.*

During the semiannual reporting period, we prepared and issued our
Summary Inspection Report for field inspections conducted at the
following offices during FY 1999:

-   Office of Regional Director, Northeast Region

-   Chicago Field Office

-   New York Field Office

-   Detroit Field Office

-   Philadelphia Field Office

Our inspection included the evaluation of internal controls over
payroll, imprest funds, credit cards and other government assets.
Additionally, the status and serviceability of facilities and equipment
were assessed. Our inspection disclosed minor payroll and equipment
inventory discrepancies that were subsequently resolved. The inspection
team also sought out best practices at each office that could be adopted
on a Bureau-wide basis, and obtained feedback from the field employees
on topics of concern or interest. A recurrent concern raised by the
field employees was over personal safety when responding to interference
complaints or unauthorized transmissions, particularly in areas with
significant "local militia" activities.

We issued a summary report and individual reports on each field visit to
Commission management. The reports did not contain findings and
recommendation as in a formal audit report, but are designed to be
observations for management's information and use. On January 27, the
Chief of the Enforcement Bureau reminded all of its employees to follow
all existing Field safety policies while a study was conducted to see
what, if any, additional steps should be taken to maximize employee
safety.

Report on Special Review of Auctions Security issued on March 28, 2000,
Report No. 00-AUD-01-21

In response to a referral from the Commission's Computer Security
Officer, the OIG performed a special review of Information Technology
(IT) security on a critical sub-network within Commission's IT
infrastructure. The affected sub-network is used to support the
Commission's spectrum auction activities. Based upon the initial reports
of potential system compromise, the OIG responded by establishing a task
order under our contract with the computer security firm of TWM
Associates, Inc. (hereinafter referred to as "TWM") and creating a
review team comprised of representatives from TWM and OIG. The special
review was conducted in two phases. The objective of the initial phase
of the review was to investigate the incident and, to the extent that
this information could be developed, determine who was inappropriately
using a privileged account on the sub-network. The objective of the
second phase of the review was to evaluate the security of IT components
within the sub-network.

The review team completed the first phase of the review and reported the
results of that portion of the review in an OIG flash report that was
issued on October 12, 1999. In that report, the OIG review team
concluded that the specific incident triggering this investigation
appears to have been the result of a database system security feature
and not a malicious attack. Working with IT staff from the Auctions
group, the review team was able to re-create the system behavior
displayed during the incident to support the hypothesis that the
incident was the result of a database management system feature. Based
on these event re-creations and our examination of the security boundary
surrounding the Auctions technology, the review team concluded that the
incident actually resulted from a feature of the Sybase database
management system and that the security boundary is configured
correctly.

During the second phase of the review, the review team identified
findings covering two general areas: 1) the administration of the
Auctions systems and 2) the technology assets employed by the Auctions
site. The administrative findings focus on the plans, policies and
procedures in place to ensure that the systems in question are
administered in a secure manner. Our review determined that, in general,
the plans, policies and procedures in place over the Auctions system
need improvement. In addition, our review indicates that adherence to
the existing plans, policies and procedures was not sufficient to ensure
adequate security for the Auctions system. The review team made several
recommendations to strengthen existing plans, policies, and procedures.
The technology-based findings focus on the secure implementation and
deployment of technology within the system. The review team made several
recommendations to strengthen controls over specific components of the
IT infrastructure.

Because of the sensitive nature of the specific conditions identified
during this review, specific information about findings was included in
the appendices to the report and distributed only to those personnel
with a need for the information.

***ONGOING OIG AUDIT ACTIVITY***

Audit of Civil Monetary Penalties

We are in the process of completing an audit of the Commission's Civil
Monetary Penalty Program. The Communications Act of 1934 authorizes the
Federal Communications Commission (FCC) to use civil monetary penalties
as a means of enforcing Commission rules and regulations. For the period
from Fiscal Year (FY) 1995 through the second quarter of FY 1999,
Commission records indicate that 375 civil monetary penalty actions with
a total dollar value of \$27,342,500 were initiated. For those
transactions initiated during this period, the Commission reports
collections totaling \$6,364,650 and some level of monetary collection
on 213 of the 375 actions. The objective of this review was to determine
if the Commission has established an effective program for managing
civil monetary penalties. To conduct this review, we examined all
aspects of the process by which the Commission manages civil monetary
penalty actions. On March 24, 2000, we issued a draft report summarizing
the results of our review. The Commission is expected to provide a
response to the draft report by April 28, 2000.

Audit of Computer Controls at the Federal Communication Commission (FCC)
National Call Center (NCC)

We are in the process of completing an audit of computer controls at the
Commission's National Call Center (NCC). The FCC opened the NCC in 1996
at the Commission's facility located in Gettysburg, Pennsylvania. Since
its introduction in 1996, the NCC has seen a tremendous increase in the
volume of activity and is heavily reliant upon automated tools to
respond to customer inquiries. The objective of this audit was to
examine the automated computer system and the control environment in
which the call center operates to ensure that adequate security
safeguards exist to protect NCC data. To accomplish the objectives of
this review, the OIG established a task order with the computer security
firm of TWM Associates, Inc. To conduct the review, TWM used the
guidelines contained in the Federal Information System Controls Audit
Manual (FISCAM) developed by the United States General Accounting Office
(GAO). On March 31, 2000, we issued a draft report summarizing the
results of our review of the computer controls at NCC. The Commission is
expected to provide a response to the draft report during the third
quarter.

Because of the sensitive nature of the specific conditions identified
during this review, specific information about findings will be included
in the appendices to the report and distributed only to those personnel
with a need for the information.

FY 1999 Financial Statement Audit

In coordination with the FCC's Chief Financial Officer (CFO), the OIG
contracted with an independent public accounting firm (IPA) to assist
the OIG in conducting the first-ever financial statement audit of the
FCC. While presently the FCC is not a designated agency per the CFO Act,
amended, the OIG with the concurrence of the Department of the Treasury,
Financial Management Service (FMS), incorporated within the scope of its
work that the audit meet the requirements of a CFO scope audit.

Significant changes to audit scope impacted the OIG and its contractor's
ability to complete the audit by the March 1, 2000 expected date. FCC
management, with the concurrence of the OIG and its contractor, limited
its financial statements prepared per Office of Management and Budget
(OMB) Bulletin No. 97-01, Form and Content of Agency Financial
Statements, amended, to an overview of the reporting entity, a
consolidating balance sheet and related notes (financial statement), and
required supplementary information relating to intra-governmental
amounts and the related Federal trading partners for assets and
liabilities. Additionally, FCC identified a significant component of its
reporting entity that had a material impact on the financial statements
and greatly expanded the scope of the work performed.

At the close of the current semi-annual period, the OIG and its
contractor have substantially completed key audit tasks including: the
development and refinement of the comprehensive audit plan, an internal
control and compliance review, and substantive testing of the FY 1999
line items. Draft versions of the independent auditor's report and
related reports on internal control and compliance were submitted for
agency management's review and outstanding issue resolution.
Additionally, FCC management is resolving issues precluding general
release of its FY 1999 financial statement.

The aforementioned reports identify areas where FCC management needs to
concentrate to ensure adherence to Federal accounting standards and
processes. To date, draft reports identify six material weaknesses,
seven reportable conditions, and seven instances of noncompliance with
laws and regulations required to be reported under Government Auditing
Standards and OMB Bulletin No. 98-08, Audit Requirements for Federal
Financial Statements, amended.

## 

## 

## *FACTS Agreed-Upon Procedures Attestation*

In support of the FY 1999 Audit of the Consolidated Financial Statements
of the United States Government, the Department or the Treasury,
Financial Management Service requested "non-CFO Act" designated agencies
to verify Federal Agencies' Centralized Trial Balance System (FACTS)
data submissions. As part of the verification process, the OIG and its
contractor performed procedures detailed in FMS' Treasury Financial
Manual and prepared a report describing such procedures and the results
of performing those procedures. These agreed-upon procedures were
performed in accordance with American Institute of Certified Public
Accountants' Standards. At the close of the current semi-annual period,
the OIG and its contractor have substantially completed the required
procedures and drafted the accompanying report. Per OMB and FMS
guidance, agreed-upon procedures reports were to be delivered to the
General Accounting Office, OMB, and FMS by March 3, 2000 or within one
week of issuing the audit report on the agency financial statements. To
date, FCC has not finalized it FY 1999 financial statement due to the
fact management is resolving issues precluding its general release. The
OIG intends to transmit the agreed-upon procedures report once FCC
finalizes the FY 1999 financial statement.

## *Government Performance Results Act Audit*

OIG audit staff continue to monitor the FCC's activity related to the
Government Performance and Results Act (GPRA) of 1993. During the
reporting period, the OIG conducted initial meetings and completed work
relating to the preliminary planning stage of the audit. Recently, the
FCC published its first annual performance report as required by GPRA.
The scope of our audit is to assess FCC's GPRA management and reporting
systems as follows:

-   update our understanding of and review FCC's methodology for
    developing GPRA requirements;

-   assess compliance with the Act;

-   review annual performance plan(s) and report per guidance; and

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-   perform verification and validation of sampled performance measures
    and review status of prior audit recommendations (OIG 98-01; dated
    3/3/99).

Contract Audits

OIG auditors continue to provide technical input and assistance to the
Manager of the Contracts and Purchasing Center in addressing a contract
dispute between a prime contractor and the FCC. In a prior reporting
period, the OIG questioned approximately \$236,000 of subcontract labor
costs billed to the FCC by the prime contractor. The prime contractor
disputed the OIG findings and submitted an approximate \$288,000 counter
claim for the same subcontract labor costs. During this reporting
period, the FCC's Manager, Contracts and Purchasing Center, issued a
final determination denying the prime contractor's claimed costs.

Universal Licensing System (ULS) Survey

On March 17, 1999, the Chairman of the Federal Communications Commission
submitted a report titled "A New Federal Commissions Commission for the
21^st^ Century." In this paper, the Chairman outlined his views on how
the FCC should function. One of major goals stated in this document is
"streamlining and automating the FCC licensing process." A cornerstone
of this goal is Universal Licensing System (ULS). The ULS is one of the
FCC's largest systems development efforts ever undertaken. A Wireless
Bureau project, ULS has several goals, including: The development of an
on-line and web based licensing system, the consolidation of eleven
Wireless legacy systems into one, the reduction of manual handling by
automation of the license processing function, and simplification of the
licensing process.

*OIG auditors have initiated a survey review of the ULS project. The
purpose of this survey is to examine the progress of the ULS project and
report the results to the Inspector General. To meet this goal, this
survey has a series of milestones. The first milestone is to provide an
overview of the Universal Licensing System (ULS). The next goal is to
analyze and report any identified problems in the ULS development
process. The final milestone is to determine if any aspects of ULS need
further OIG involvement and review. The survey report will recommend
what, if any, additional action the OIG should take on ULS. We
anticipate completing this review and issuing a report in the third
quarter, FY 2000.*

## *Disbursements and Accounts Payable Analysis*

Disbursements traditionally represent a high risk factor to a business
entity. To assist in identifying and minimizing this risk, audit
activity has been initiated using advanced software tools to identify
payments that meet identified exception criteria. After identification,
audit work will validate that disbursements are legitimate and accurate
and supported by appropriate documentation.

The initial objective will be to search for indicators of questionable
or unusual disbursement attributes using advanced audit software. This
information resides in the Federal Financial System (FFS) other accounts
payable databases. Any disbursement meeting this definition will be
subject to detailed audit scrutiny.

The review will benefit the Commission by determining if the
disbursement process is functioning in a manner that minimizes the
potential for waste, fraud, abuse, and mismanagement. This system will
also act as a check that can identify indicators of possible abuse. We
anticipate completing this review and issuing a report in the fourth
quarter, FY 2000.

Web Presence

*The Internet and the World Wide Web (WWW) have become essential
components in conducting business with the FCC. Users can file licenses
and applications electronically and access Commission information via
the Internet. A key Commission goal is the "paperless FCC," where filing
would occur electronically using services such as the Internet. However,
security problems, such as the recent hacker attacks, constitute a
significant risk to the fulfillment of these goals. To ensure that the
Commission's "web presence" is secure, the OIG initiated an audit of the
FCC's Web Presence. The objective of this review is to assess the
security posture of the FCC's Web Presence and its associated
components. The scope of this review encompasses a review of the primary
servers providing web resources, components that provide and secure
communication pathways to and from the Internet and between web
resources, and hosts providing back-end data sources to web resources.
We anticipate completing the Web Presence review in the fourth quarter,
FY 2000.*

Investigations

## *OVERVIEW*

Investigative matters pursued by this office are generally initiated as
a result of allegations received through the OIG hotline or from FCC
managers and employees who contact the OIG directly. Investigations may
also be predicated upon audit or inspection findings of fraud, waste,
abuse, corruption, or mismanagement by FCC employees, contractors,
and/or subcontractors. Upon receipt of an allegation of an
administrative or criminal violation, the OIG usually conducts a
preliminary inquiry to determine if an investigation is warranted.
Investigations may involve possible violations of regulations regarding
employee responsibilities and conduct, federal criminal law, and other
regulations and statutes pertaining to the activities of the Commission.
Investigative findings may lead to criminal or civil prosecution, or
administrative action.

The OIG also receives complaints from the general public, both private
citizens and commercial enterprises, about the manner in which the FCC
executes its programs and oversight responsibilities. All complaints are
examined to determine whether there is any basis for OIG audit or
investigative action. If nothing within the jurisdiction of the OIG is
alleged, the complaint is usually referred to the appropriate FCC bureau
or office for response directly to the complainant. A copy of the
response is also provided to the OIG. Finally, matters may be referred
to this office for investigative action from other governmental
entities, such as the Office of Special Counsel.

ACTIVITY DURING THIS PERIOD

During this reporting period, fourteen complaints were received in the
OIG. All of the complaints have resulted in the initiation of
investigations or preliminary inquiries, and eight of the matters were
closed. Three complaints were closed because of determinations of no
violations of standards of conduct by FCC employees. Five complaints
were closed because they were found not to merit further action. Seven
complaints are still pending.

The one case pending at the beginning of the period was closed. It was
closed because the allegations were found not to warrant further action
by the OIG.

STATISTICS

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  Cases pending as of September 30, 1999                         1

  New cases                                                      14

  Cases closed                                                   8

  Cases pending as of March 31, 2000                             7
  -------------------------------------------------------------- --------

SIGNIFICANT INVESTIGATIVE CASE SUMMARIES

• The OIG continues to monitor the matter concerning an employee at the
FCC\'s Laurel laboratory facility who was videotaped allegedly stealing
government supplies from the facility on multiple occasions. An
investigative report was issued on April 9, 1998. The matter was also
referred to the Federal Protective Service for consideration of criminal
charges. Federal law enforcement authorities have declined to prosecute.
Disciplinary action has been taken against the employee. The employee
has appealed the disciplinary action and the appeal is currently
pending.

• On May 2, 1999, the OIG received a complaint that an employee was
spending a significant amount of time during normal working hours
accessing the E-bay auction program on his Commission computer
workstation. Based on the information received, an investigation was
initiated. As a result of the investigation, it was determined that
during the period in question the employee did in fact expend a
significant amount of time during normal working hours accessing the
auction program on a Commission workstation. Disciplinary action was
taken by management and the matter has been closed.

• On September 27, 1999, the OIG commenced an investigation into
allegations of employee misconduct with respect to the presentation of a
matter before the Administrative Law Judges of the Commission. The OIG
determined that the allegations related to the merits of the matter
pending before the Commission, and the issues which were the subject of
the allegations were in fact formally before the Commission for
resolution. Accordingly, the OIG determined that the matter did not
warrant action by this office and the matter was closed.

• On November 3, 1999, the OIG initiated an investigation into
allegations of misconduct and abuse of authority by senior level
employees at the Commission. The Office of the Special Counsel had
referred the matter to the OIG. The complaint alleged that the
employees' conduct in allowing the temporary broadcasting of events at a
racetrack and/or involvement with respect to the issuance of an
experimental license for the broadcasting at the track constituted
misconduct and an abuse of authority. It was alleged that the conduct
violated, among other things, the Communications Act and the Code of
Federal Regulations pertaining to Commission regulations and standards
of conduct for federal employees. The OIG was unable to find any
evidence of misconduct by the employees or that they had exceeded their
authority in allowing broadcasting at the track.

• On November 12, 1999, the OIG received a complaint concerning
allegations of possible improper conduct by a Commission employee with
respect to the Commission's awarding of a contract for the purchase of
specific absorption rate devices. It was alleged or inferred, among
other things, that an employee involved in the evaluation process may
have improperly released information regarding the bids. An
investigation was initiated and is currently pending.

• On November 24, 1999, the OIG initiated a preliminary inquiry into
allegations that a former employee may have made or had an improper
contact with the Commission in violation of 18 U.S.C. Section 207, which
prohibits certain post-employment activities by former employees. The
alleged conduct consisted of the making of an affidavit by the former
employee, which appears to have been filed with the Commission
concerning an issue upon which the former employee had rendered a
judgment. The OIG, through investigation, determined that the issue in
question was never under consideration by the employee. Accordingly,
because of the determination of no violation by the employee, the matter
was closed.

• On November 26, 1999, the OIG initiated a preliminary inquiry into the
circumstances of the public release of an internal memorandum of the
Commission. Through investigation it was determined that the memorandum
was released erroneously and that there was no evidence of employee
misconduct.

• On December 22, 1999, the OIG initiated an investigation based on
allegations of a supervisory FCC employee routinely utilizing his
computer workstation to access pornographic sites on the Internet in
violation of FCC regulations and provisions of the Code of Federal
Regulations concerning use of Government equipment and use of official
time. The investigation is currently pending.

• On January 11, 2000, the Computer Security Officer of the Commission's
Information Technology Center (ITC) notified the OIG that due to an
apparent misuse of the Commission's electronic mail system by an
employee, the Commission's outbound electronic mail system shut down on
two recent occasions. An initial review of the employee's electronic
mail system by the ITC revealed that the shut downs appear to have
occurred as a result of the employee generating electronic mail related
to the conducting of a music business on Commission premises during
working hours. The OIG initiated an investigation, which is currently
pending.

• On February 18, 2000, the OIG initiated a preliminary inquiry into
allegations by a licensee that a Commission field office employee had
abused his official position and harassed the licensee by, among other
things, citing the licensee for non-existent telecommunications related
violations. The inquiry is currently pending.

• On March 14, 2000, the OIG received a request that it look into the
circumstances of the issuance by a bureau of letters of revocation for
certain licenses, to determine if there was any wrongdoing by Commission
employees. Specifically, the letters, which were dated December 22, 1999
and revoked licenses granted on November 23, 1999, allegedly were not
mailed until February 8, 2000. The OIG initiated a preliminary inquiry,
which is currently pending.

##### **HOTLINE CALLS**

During this reporting period, the OIG Hotline Technician received one
hundred and sixty-eight (168) hotline calls to the published hotline
numbers of (202) 418-0473 and 1-888-863-2244 (toll free). One hundred
and sixty-five (165) of the calls were referred either to the National
Consumer Center or to the appropriate federal agency. Three were
determined not to warrant investigation or referral by the OIG. The OIG
Hotline continues to be a vehicle by which Commission employees and
parties external to the FCC can contact the OIG to speak with a trained
Hotline Technician. Callers who have general questions or concerns not
specifically related to the missions or functions of the OIG office are
referred to the FCC National Consumer Center at 1-888-225-5322. Examples
of calls referred to the Consumer Center include complaints pertaining
to customers phone service and local cable providers, long-distance
carrier slamming, interference, or similar matters within the program
responsibility of other FCC bureaus and offices.

Legislation

OVERVIEW

Pursuant to section 4(a)(2) of the Inspector General Act of 1978(IG
Act), as amended, our office monitors and reviews existing and proposed
legislative and regulatory items for their impact on the Office of the
Inspector General and the Federal Communications Commission programs and
operations. Specifically, we perform this activity to evaluate their
potential for encouraging economy and efficiency and preventing fraud,
waste, and mismanagement.

ACTIVITY DURING THIS PERIOD

The Counsel to the IG continued to monitor legislative activities
affecting the activities of the OIG and the FCC.

During this period, this office monitored those legislative proposals,
which directly or indirectly impact on the ability of Designated Federal
Entity IGs to function independently and objectively. Those specific
proposals concerned proposals to consolidate OIGs and to directly and/or
indirectly draw distinctions between presidentially -- appointed IGs and
Designated Federal Entity IGs, which may have the effect of undermining
the role of the latter. Also during this period, in accordance with the
Federal Activities Reform Act (FAIR Act), the OIG presented its
commercial inventory submission, which was approved by the Office of
Management and Budget and published in the Federal Register. The FAIR
Act directs federal agencies, commencing October, 1999, to submit each
year an inventory of all their activities that are performed by federal
employees but are not inherently governmental in nature.

Technical Advice and Assistance

During the six-month reporting period covered by this report, OIG
management and staff have continued to dedicate resources towards
assisting the Commission in those areas where our expertise can provide
benefit. For example, OIG personnel have participated in the following
projects:

Systems Development Life Cycle

Auditors from the OIG are working closely with Commission
representatives to develop a Systems Development Life Cycle (SDLC). The
purpose of the SDLC project is to provide a structured process for
managing the development of information systems and for managing system
modification and operation after systems are deployed in the production
environment. During this reporting period, auditors co-hosted a series
of sessions with representatives from Commission Bureaus and Offices as
well as representatives from the Commission's procurement office and
Information Technology Center (ITC). The purpose of these sessions was
to finalize the structure of each of the six (6) phases of the SDLC and
the SDLC glossary. In addition, OIG auditors are working closely with
ITC staff to determine the most effective way to pilot test and
implement the SDLC.

Because of our work in the development of the SDLC, the OIG was invited
to participate in the development of the new information system for the
Commission's Consumer Information Bureau (CIB). CIB is piloting the
Commission's SDLC methodology that the OIG was instrumental in
developing. The OIG will participate in the project by assuming the
SDLC's auditor role. Audit staff will also observe the process and issue
a report on the results of the use of the SDLC on this project.

Licensing Working Group

The OIG participated on the Licensing Work Group, which was established
by the FCC to develop options for streamlining and consolidating the
Commission's licensing processes. This effort was performed in support
of the Chairman's Draft Strategic Plan, dated August 1999. The work
group collected and analyzed information on all phases of the
Commission's licensing and authorization of service activities and
identified three main options for streamlining these functions. The
options ranged from continuing with process improvements that were
currently underway within the Bureaus/Offices, through the use of
automation to create a virtual Licensing Bureau with a single point of
entry and a consolidated database within the existing Bureau/Office
structure, to a complete reorganization of the functions and creation of
a Licensing Bureau. These options and the work group's methodology were
discussed in a report prepared by the Licensing Work Group, "Improving
the Commission's Licensing and Authorization of Service Functions --
Options for Consideration", dated March 24, 2000.

Financial Management Advisory Services

The OIG provided advisory and assistance service to the Commission as it
continues the challenging task of realigning its financial management
functions to implement CFO Act financial reporting. Specifically, OIG
staff attended working sessions, shared best practices from other
Federal agencies, and provided subject matter consulting on Federal
financial management initiatives. OIG staff provided extensive
assistance to the CFO working group as FCC prepared its firstr financial
statement per OMB Bulletin No. 97-01, amended. Significant assistance
was also provided to resolve first year audit issues and expose CFO
staff to the requirements of an audit per OMB Bulletin No. 98-08,
amended. The OIG and FCC management are fostering a relationship that
will facilitate CFO Act financial reporting at the Commission.

-   Provided technical advice to the Office of Financial Operations
    regarding the design of Form 159 -- Remittance Advice. The
    verification of regulatory fee payments was being adversely affected
    by imprecise instructions to FCC filers. Four specific
    recommendations to correct the problem were provided to the CFO for
    his consideration.

Procurement Advisory Services

In the OIG's efforts to provide comprehensive contract audit services to
the FCC's Contracts and Purchasing Center, the OIG also advises the
Commission's contracting officers (COs) on contract and contractor
financial and performance matters that do not require contract audits.
OIG contract auditors performed the following contract advisory services
during this reporting period:

-   Advised the CO on a government caused work disruption issue. The CO
    sought advice about whether a time and materials service contractor,
    who was not notified in advance, should be reimbursed or be required
    to take unreimbursed leave for time lost when the FCC moved the
    contractor to a new location within the FCC headquarters building.
    OIG advice resulted in the CO notifying the contracting officer's
    technical representative (COTR), because the contractor did not
    receive adequate notification of the disruption, the contractor
    would have to be compensated.

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-   Advised a contracting officer's technical representative (COTR) on a
    contractor time verification oversight issue. The COTR sought advice
    about verifying hours claimed by contractor employees performing
    services under his/her task order in order to improve the audit
    trail for approving monthly invoices for payment. OIG advice
    resulted in the COTR instituting new daily sign in/out procedures by
    requiring his/her contractor employees to e-mail the COTR when they
    arrive and depart each day.

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-   Accompanied and provided support to the Contracts and Purchasing
    Center Manager and CO when they met with contractor representatives
    who were disputing prior contract constructive change order proposal
    audit findings. The contractor represented that they had new
    information that would prove the audit findings wrong and convince
    the CO to concur with the contractor's position. The meeting
    concluded with the contractor not even trying to dispute the audit
    findings. Instead, the contractor representative took a different
    tact by proposing that certain of its employees should be moved into
    higher labor categories and be billed out at a higher labor rate
    under the contract. As a result, the OIG strongly recommended that
    the Contracts and Purchasing Center should initiate and require
    formal contract modification request procedures that require
    contractors to submit cost proposals and certify to the accuracy or
    their cost or pricing data. The Contracts and Purchasing Center
    Manager concurred with our recommendation.

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-   Met with and advised Contracts and Purchasing Center and Office of
    General Council (OGC) representatives about possible contract audit
    requirements for the North American Numbering Council (NANC) and
    Universal Service Administrative Company (USAC) support service
    contract proposals. Numerous issues were discussed, including
    Federal Acquisition Regulation (FAR) applicability and requirements
    and potential "federal fund" implications. As a result, the OIG will
    not be auditing the NANC proposal, because it changed from a
    negotiated sole-source to a competitive bid procurement once two or
    more qualified competitors were allowed to submit proposals.

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-   Provided advisory services to the FCC Automated Time Accountability
    System Task Force. The Contracts and Purchasing Center sponsored
    this task force in order to research and investigate different
    off-the-shelf automated time reporting systems to assist COTRs with
    verifying contract employee hours for services performed under cost
    reimbursable contracts at FCC facilities. OIG advisory services on
    this project continue as of this reporting period.

***SPECIFIC REPORTING REQUIREMENTS OF SECTION 5(a) OF THE INSPECTOR
GENERAL ACT***

> The following summarizes the Office of Inspector General response to
> the twelve specific reporting requirements set forth in Section 5(a)
> of the Inspector General Act of 1978, as amended.

1.  A description of significant problems, abuses, and deficiencies
    relating to the administration of programs and operations of such
    establishment disclosed by such activities during the reporting
    period.

    No such problems, abuses, or deficiencies were disclosed during the
    reporting period.

> 2\. A description of the recommendations for corrective action made by
> the Office during the reporting period with respect to significant
> problems, abuses, or deficiencies identified pursuant to paragraph
> (1).

No recommendations were made. See the response to paragraph (1).

> 3\. An identification of each significant recommendation described in
> previous semiannual reports on which corrective action has not been
> completed.

No significant recommendations remain outstanding.

4.  A summary of matters referred to prosecutive authorities and the
    prosecutions and convictions which have resulted

    No matters were referred to prosecutive authorities during this
    reporting period.

> 5\. A summary of each report made to the head of the establishment
> under section (6)(b)(2) during the reporting period.
>
> No report was made to the Chairman of the FCC under section (6)(b)(2)
> during the reporting period.
>
> 6\. A listing, subdivided according to subject matter, of each audit
> report issued by the Office during the reporting period, and for each
> audit report, where applicable, the total dollar value of questioned
> costs (including a separate category for the dollar value of
> unsupported costs) and the dollar value of recommendations that funds
> be put to better use.
>
> Each audit report issued during the reporting period is listed
> according to subject matter and described in part II, above.
>
> 7\. A summary of each particularly significant report.
>
> Each significant audit and investigative report issued during the
> reporting period is summarized within the body of this report.
>
> 8\. Statistical tables showing the total number of audit reports with
> questioned costs and the total dollar value of questioned costs.

The required statistical table can be found at Attachment A to this
report.

> 9\. Statistical tables showing the total number of audit reports with
> recommendations that funds be put to better use and the dollar value
> of such recommendations.

The required statistical table can be found at Attachment B to this
report.

> 10\. A summary of each audit report issued before the commencement of
> the reporting period for which no management decision has been made by
> the end of the reporting period (including the date and title of each
> such report), an explanation of the reasons such management decision
> has not been made, and a statement concerning the desired timetable
> for achieving a management decision on each such report.
>
> One audit report meets this criteria. [The Report on Incurred Costs
> for Fiscal Years 1995, 1996 and Short Year 1997 (OIG
> 97-18)]{.underline} was issued in September 1997. This incurred cost
> audit identified questioned costs of \$265,180. The contractor has
> formally contested the OIG finding and submitted a counterclaim to the
> Chief, Contracts and Purchasing Center.
>
> 11\. A description and explanation of the reasons for any significant
> revised management decision made during the reporting period.

No management decisions fall within this category.

> 12\. Information concerning any significant management decision with
> which the Inspector General is in disagreement.

No management decisions fall within this category.

Attachment A

Table I: OIG Audit Reports With Questioned Costs

+---+---+----------------------------+---------+----------+---+-----------+
| I |   |                            | Number  | #        |   |           |
| N |   |                            | of      | # *Dolla |   |           |
| S |   |                            | Reports | r Value* |   |           |
| P |   |                            |         |          |   |           |
| E |   |                            |         |          |   |           |
| C |   |                            |         |          |   |           |
| T |   |                            |         |          |   |           |
| O |   |                            |         |          |   |           |
| R |   |                            |         |          |   |           |
| G |   |                            |         |          |   |           |
| E |   |                            |         |          |   |           |
| N |   |                            |         |          |   |           |
| E |   |                            |         |          |   |           |
| R |   |                            |         |          |   |           |
| A |   |                            |         |          |   |           |
| L |   |                            |         |          |   |           |
| R |   |                            |         |          |   |           |
| E |   |                            |         |          |   |           |
| P |   |                            |         |          |   |           |
| O |   |                            |         |          |   |           |
| R |   |                            |         |          |   |           |
| T |   |                            |         |          |   |           |
| S |   |                            |         |          |   |           |
| W |   |                            |         |          |   |           |
| I |   |                            |         |          |   |           |
| T |   |                            |         |          |   |           |
| H |   |                            |         |          |   |           |
| Q |   |                            |         |          |   |           |
| U |   |                            |         |          |   |           |
| E |   |                            |         |          |   |           |
| S |   |                            |         |          |   |           |
| T |   |                            |         |          |   |           |
| I |   |                            |         |          |   |           |
| O |   |                            |         |          |   |           |
| N |   |                            |         |          |   |           |
| E |   |                            |         |          |   |           |
| D |   |                            |         |          |   |           |
| C |   |                            |         |          |   |           |
| O |   |                            |         |          |   |           |
| S |   |                            |         |          |   |           |
| T |   |                            |         |          |   |           |
| S |   |                            |         |          |   |           |
+===+===+============================+=========+==========+===+===========+
|   |   |                            |         | Qu       | U |           |
|   |   |                            |         | estioned | n |           |
|   |   |                            |         | Costs    | s |           |
|   |   |                            |         |          | u |           |
|   |   |                            |         |          | p |           |
|   |   |                            |         |          | p |           |
|   |   |                            |         |          | o |           |
|   |   |                            |         |          | r |           |
|   |   |                            |         |          | t |           |
|   |   |                            |         |          | e |           |
|   |   |                            |         |          | d |           |
|   |   |                            |         |          | C |           |
|   |   |                            |         |          | o |           |
|   |   |                            |         |          | s |           |
|   |   |                            |         |          | t |           |
|   |   |                            |         |          | s |           |
+---+---+----------------------------+---------+----------+---+-----------+
| A | F |                            | 1       | 265,180  |   | 265,180   |
| . | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
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|   | i |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
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|   | d |                            |         |          |   |           |
|   | . |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
| B | W |                            | 0       | 0        |   | 0         |
| . | h |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
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|   | . |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
|   | S |                            | 1       | 265,180  |   | 265,180   |
|   | u |                            |         |          |   |           |
|   | b |                            |         |          |   |           |
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|   | s |                            |         |          |   |           |
|   | ( |                            |         |          |   |           |
|   | A |                            |         |          |   |           |
|   |   |                            |         |          |   |           |
|   | + |                            |         |          |   |           |
|   | B |                            |         |          |   |           |
|   | ) |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
| C | F |                            |         |          |   |           |
| . | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | g |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | u |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | g |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | p |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | g |                            |         |          |   |           |
|   | p |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | . |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
|   | \ | Dollar value of disallowed | 0       | 0        |   | 0         |
|   | ( | costs.                     |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | \ |                            |         |          |   |           |
|   | ) |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
|   | \ | Dollar value of costs      | 0       | 0        |   | 0         |
|   | ( | allowed.                   |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | \ |                            |         |          |   |           |
|   | ) |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
| D | F |                            | 1       | 265,180  |   | 265,180   |
| . | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | g |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | b |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | b |                            |         |          |   |           |
|   | y |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | f |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | p |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | g |                            |         |          |   |           |
|   | p |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | . |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+
|   | R |                            | 1       | 265,180  |   | 265,180   |
|   | e |                            |         |          |   |           |
|   | p |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | f |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | r |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | g |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | d |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | w |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | x |                            |         |          |   |           |
|   | m |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | t |                            |         |          |   |           |
|   | h |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | o |                            |         |          |   |           |
|   | f |                            |         |          |   |           |
|   | i |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | s |                            |         |          |   |           |
|   | u |                            |         |          |   |           |
|   | a |                            |         |          |   |           |
|   | n |                            |         |          |   |           |
|   | c |                            |         |          |   |           |
|   | e |                            |         |          |   |           |
|   | . |                            |         |          |   |           |
+---+---+----------------------------+---------+----------+---+-----------+

Attachment B

Table II: OIG Audit Reports With Recommendations that Funds Be Put To
Better Use

+---+---+-----------------------------------+---------+---------------+
| I |   |                                   | Number  | ## *          |
| N |   |                                   | of      | Dollar Value* |
| S |   |                                   | Reports |               |
| P |   |                                   |         |               |
| E |   |                                   |         |               |
| C |   |                                   |         |               |
| T |   |                                   |         |               |
| O |   |                                   |         |               |
| R |   |                                   |         |               |
| G |   |                                   |         |               |
| E |   |                                   |         |               |
| N |   |                                   |         |               |
| E |   |                                   |         |               |
| R |   |                                   |         |               |
| A |   |                                   |         |               |
| L |   |                                   |         |               |
| R |   |                                   |         |               |
| E |   |                                   |         |               |
| P |   |                                   |         |               |
| O |   |                                   |         |               |
| R |   |                                   |         |               |
| T |   |                                   |         |               |
| S |   |                                   |         |               |
| W |   |                                   |         |               |
| I |   |                                   |         |               |
| T |   |                                   |         |               |
| H |   |                                   |         |               |
| R |   |                                   |         |               |
| E |   |                                   |         |               |
| C |   |                                   |         |               |
| O |   |                                   |         |               |
| M |   |                                   |         |               |
| M |   |                                   |         |               |
| E |   |                                   |         |               |
| N |   |                                   |         |               |
| D |   |                                   |         |               |
| A |   |                                   |         |               |
| T |   |                                   |         |               |
| I |   |                                   |         |               |
| O |   |                                   |         |               |
| N |   |                                   |         |               |
| S |   |                                   |         |               |
| T |   |                                   |         |               |
| H |   |                                   |         |               |
| A |   |                                   |         |               |
| T |   |                                   |         |               |
| F |   |                                   |         |               |
| U |   |                                   |         |               |
| N |   |                                   |         |               |
| D |   |                                   |         |               |
| S |   |                                   |         |               |
| B |   |                                   |         |               |
| E |   |                                   |         |               |
| P |   |                                   |         |               |
| U |   |                                   |         |               |
| T |   |                                   |         |               |
| T |   |                                   |         |               |
| O |   |                                   |         |               |
| B |   |                                   |         |               |
| E |   |                                   |         |               |
| T |   |                                   |         |               |
| T |   |                                   |         |               |
| E |   |                                   |         |               |
| R |   |                                   |         |               |
| U |   |                                   |         |               |
| S |   |                                   |         |               |
| E |   |                                   |         |               |
+===+===+===================================+=========+===============+
| A | F |                                   | 0       | 0             |
| . | o |                                   |         |               |
|   | r |                                   |         |               |
|   | w |                                   |         |               |
|   | h |                                   |         |               |
|   | i |                                   |         |               |
|   | c |                                   |         |               |
|   | h |                                   |         |               |
|   | n |                                   |         |               |
|   | o |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | n |                                   |         |               |
|   | a |                                   |         |               |
|   | g |                                   |         |               |
|   | e |                                   |         |               |
|   | m |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | t |                                   |         |               |
|   | d |                                   |         |               |
|   | e |                                   |         |               |
|   | c |                                   |         |               |
|   | i |                                   |         |               |
|   | s |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
|   | n |                                   |         |               |
|   | h |                                   |         |               |
|   | a |                                   |         |               |
|   | s |                                   |         |               |
|   | b |                                   |         |               |
|   | e |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | d |                                   |         |               |
|   | e |                                   |         |               |
|   | b |                                   |         |               |
|   | y |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | e |                                   |         |               |
|   | c |                                   |         |               |
|   | o |                                   |         |               |
|   | m |                                   |         |               |
|   | m |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | c |                                   |         |               |
|   | e |                                   |         |               |
|   | m |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | t |                                   |         |               |
|   | o |                                   |         |               |
|   | f |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | e |                                   |         |               |
|   | p |                                   |         |               |
|   | o |                                   |         |               |
|   | r |                                   |         |               |
|   | t |                                   |         |               |
|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | g |                                   |         |               |
|   | p |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
|   | d |                                   |         |               |
|   | . |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
| B | W |                                   | 0       | 0             |
| . | h |                                   |         |               |
|   | i |                                   |         |               |
|   | c |                                   |         |               |
|   | h |                                   |         |               |
|   | w |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | e |                                   |         |               |
|   | i |                                   |         |               |
|   | s |                                   |         |               |
|   | s |                                   |         |               |
|   | u |                                   |         |               |
|   | e |                                   |         |               |
|   | d |                                   |         |               |
|   | d |                                   |         |               |
|   | u |                                   |         |               |
|   | r |                                   |         |               |
|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | g |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | e |                                   |         |               |
|   | p |                                   |         |               |
|   | o |                                   |         |               |
|   | r |                                   |         |               |
|   | t |                                   |         |               |
|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | g |                                   |         |               |
|   | p |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
|   | d |                                   |         |               |
|   | . |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
|   | S |                                   | 0       | 0             |
|   | u |                                   |         |               |
|   | b |                                   |         |               |
|   | t |                                   |         |               |
|   | o |                                   |         |               |
|   | t |                                   |         |               |
|   | a |                                   |         |               |
|   | l |                                   |         |               |
|   | s |                                   |         |               |
|   | ( |                                   |         |               |
|   | A |                                   |         |               |
|   |   |                                   |         |               |
|   | + |                                   |         |               |
|   | B |                                   |         |               |
|   | ) |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
| C | F |                                   |         |               |
| . | o |                                   |         |               |
|   | r |                                   |         |               |
|   | w |                                   |         |               |
|   | h |                                   |         |               |
|   | i |                                   |         |               |
|   | c |                                   |         |               |
|   | h |                                   |         |               |
|   | a |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | n |                                   |         |               |
|   | a |                                   |         |               |
|   | g |                                   |         |               |
|   | e |                                   |         |               |
|   | m |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | t |                                   |         |               |
|   | d |                                   |         |               |
|   | e |                                   |         |               |
|   | c |                                   |         |               |
|   | i |                                   |         |               |
|   | s |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
|   | n |                                   |         |               |
|   | w |                                   |         |               |
|   | a |                                   |         |               |
|   | s |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | d |                                   |         |               |
|   | e |                                   |         |               |
|   | d |                                   |         |               |
|   | u |                                   |         |               |
|   | r |                                   |         |               |
|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | g |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | e |                                   |         |               |
|   | p |                                   |         |               |
|   | o |                                   |         |               |
|   | r |                                   |         |               |
|   | t |                                   |         |               |
|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | g |                                   |         |               |
|   | p |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
|   | d |                                   |         |               |
|   | . |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
|   | \ | Dollar value of recommendations   | 0       | 0             |
|   | ( | that were agreed to by            |         |               |
|   | i | management.                       |         |               |
|   | \ |                                   |         |               |
|   | ) |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
|   |   | \- Based on proposed management   | 0       | 0             |
|   |   | action.                           |         |               |
+---+---+-----------------------------------+---------+---------------+
|   |   | \- Based on proposed legislative  | 0       | 0             |
|   |   | action.                           |         |               |
+---+---+-----------------------------------+---------+---------------+
|   | \ | Dollar value of recommendations   | 0       | 0             |
|   | ( | that were not agreed to by        |         |               |
|   | i | management.                       |         |               |
|   | i |                                   |         |               |
|   | \ |                                   |         |               |
|   | ) |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
| D | F |                                   | 0       | 0             |
| . | o |                                   |         |               |
|   | r |                                   |         |               |
|   | w |                                   |         |               |
|   | h |                                   |         |               |
|   | i |                                   |         |               |
|   | c |                                   |         |               |
|   | h |                                   |         |               |
|   | n |                                   |         |               |
|   | o |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | n |                                   |         |               |
|   | a |                                   |         |               |
|   | g |                                   |         |               |
|   | e |                                   |         |               |
|   | m |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | t |                                   |         |               |
|   | d |                                   |         |               |
|   | e |                                   |         |               |
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|   | s |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
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|   | e |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | d |                                   |         |               |
|   | e |                                   |         |               |
|   | b |                                   |         |               |
|   | y |                                   |         |               |
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|   | h |                                   |         |               |
|   | e |                                   |         |               |
|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | d |                                   |         |               |
|   | o |                                   |         |               |
|   | f |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | e |                                   |         |               |
|   | r |                                   |         |               |
|   | e |                                   |         |               |
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|   | o |                                   |         |               |
|   | r |                                   |         |               |
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|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | g |                                   |         |               |
|   | p |                                   |         |               |
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|   | r |                                   |         |               |
|   | i |                                   |         |               |
|   | o |                                   |         |               |
|   | d |                                   |         |               |
|   | . |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+
|   | F |                                   | 0       | 0             |
|   | o |                                   |         |               |
|   | r |                                   |         |               |
|   | w |                                   |         |               |
|   | h |                                   |         |               |
|   | i |                                   |         |               |
|   | c |                                   |         |               |
|   | h |                                   |         |               |
|   | n |                                   |         |               |
|   | o |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
|   | n |                                   |         |               |
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|   | e |                                   |         |               |
|   | n |                                   |         |               |
|   | t |                                   |         |               |
|   | d |                                   |         |               |
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|   | i |                                   |         |               |
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|   | n |                                   |         |               |
|   | w |                                   |         |               |
|   | a |                                   |         |               |
|   | s |                                   |         |               |
|   | m |                                   |         |               |
|   | a |                                   |         |               |
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|   | w |                                   |         |               |
|   | i |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | i |                                   |         |               |
|   | n |                                   |         |               |
|   | s |                                   |         |               |
|   | i |                                   |         |               |
|   | x |                                   |         |               |
|   | m |                                   |         |               |
|   | o |                                   |         |               |
|   | n |                                   |         |               |
|   | t |                                   |         |               |
|   | h |                                   |         |               |
|   | s |                                   |         |               |
|   | o |                                   |         |               |
|   | f |                                   |         |               |
|   | i |                                   |         |               |
|   | s |                                   |         |               |
|   | s |                                   |         |               |
|   | u |                                   |         |               |
|   | a |                                   |         |               |
|   | n |                                   |         |               |
|   | c |                                   |         |               |
|   | e |                                   |         |               |
|   | . |                                   |         |               |
+---+---+-----------------------------------+---------+---------------+