U.S. OFFICE OF PERSONNEL MANAGEMENT 

OFFICE OF THE INSPECTOR GENERAL 

OFFICE OF AUDITS 

Final Audit Report 

Subject: 

AUDIT OF THE QUALITY ASSURANCE PROCESS 


OVER BACKGROUND INVESTIGATIONS 


Report No. 4A-IS-OO-09-060 

Date: June 22, 2010 

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Office of the 

In~peClor Genera l 

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 


Washington, DC 20415 


AUDIT REPORT 

AUDIT OF THE QUALITY ASSURANCE PROCESS OVER 


BACKGROUND INVESTIGATIONS 


Report No. 4A-IS-OO-09-060 Date: June 22, 2010 

Michael R. Esser 

Assistant Inspector General 

for Audits 

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UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 

Washington, DC 204 [5 

Office of the 

Inspector General 

EXECUTIVE SUMMARY 


AUDIT OF THE QUALITY ASSURANCE PROCESS OVER 


BACKGROUND INVESTIGATIONS 


Report No. 4A-IS-OO-09-060 Da~: June 22, 2010 

The Office of the Inspector General has completed a performance audit of the Quality Assurance 

Process over Background Investigations. Our main objective was to determine whether the 

Federal Investigative Services (FrS) has effectively implemented controls for the quality 

assurance process over background investigations. In order to make this determination, our audit 

included the following specific objectives: (1) determine whether the FIS and the US 

Investigations Services, Inc. (USIS); KeyPoint Govenunent Solutions (KGS), fonnerly Kroll; 

and CACI International, Inc. (CAeI), hereafter referred to as the "Contractors", are following 

their respective case/quality review process; (2) detennine if the FrS and the Contractors have 

controls in place to ensure that their review personnel are trained to perform their duties; (3) 

determine if the FIS and the Contractors have controls in place to ensure that their investigative 

personnel are trained to perform their duties; and (4) determine if the FIS and the Contractors 

have adequate controls in place to identify falsification and/or integrity issues. 

Our audit was conducted from July 22, 2009 through October 22, 2009 at FrS offices located in 

the U.S. Office of Personnel Management's (OPM) headquarters in Washington D.C. and 

Boyers, Pennsylvania. In addition, we visited Contractors' sites located in Chantilly, Virginia; 

Loveland, Colorado; and Grove City, Pennsylvania. Our audit identified 15 areas requiring 

improvement. 

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A. General Observations 

1. General Observations Procedural 

We have identified three areas we feel could have a positive impact 

on the quality assurance process over background investigations. 

The areas include: training, the quality case review initiative, and 

the use of an integrity statement. 

B. Case Quality Review Process 

1. Random Review Process Procedural 

Random reviews of cases by the Quality Management Group, an 

internal control that helps identify potential problems with 

background investigations, were not in place for the last half of 

fiscal year 2009. 

2. Oversigbt of tbe Closing Autborization and Support Team 

(CAST) 

Procedural 

Deficient cases are being closed in the CAST by the support 

contractor. 

C. Training for Investigative Personnel 

1. Investigative Technician Training Procedural 

USIS and KGS did not provide an OPM approved training course to 

employees who conduct record checks. 

2. Mentor Training Procedural 

Eighteen of the 20 mentors that we reviewed did not complete a 

mentor training course. 

3. Investigator Training for Contractors Procedural 

Two of the 50 Background Investigators we sampled did not meet 

all qualifications needed to perform their duties as a Background 

Investigator. 

11 
4. Check Rides Not Conducted by Contractor Procedural 

USIS did not conduct check rides for 2 of the 25 new Background 

Investigators that we s,ampled, 

5. Check Rides at FIS Not Conducted Procedural 

Seven of the 25 experienced Background Investigators we sampled 

did not have a check ride assessment conducted during the period 

October 1,2008 to September 4, 2009. 

6. Evaluation Results Not Documented Procedural 

CAC! does not have a process in place to document the results of 

their evaluations of Background Investigators, 

7. Oversight of Contractors' Evaluation Submissions Procedural 

FIS does not have controls in place to ensure that the Contractors 

are submitting their evaluation results to the Contracting Officer's 

Representati ve. 

D. FalsificationlIntegrity Issues 

1. Misconduct Issues Not Submitted Timely ProceduraL 

USIS did not forward misconduct issues to OPM within the required 

timeframe for 7 of the 40 Background Investigators we sampled. 

2. Record Source Validations Not Performed Procedural 

The Contractors did not have controLs in place to conduct record 

source validations. 

3. Review of Record Checks Procedural 

FIS did not conduct the required number of record check reviews 

for aLL Investigative Assistants. 

4. Re-Contact of Personal Sources by Contractors Procedural 

CAeI and KGS did not conduct re-contacts for 12 of the 50 new 

Background Investigators that we sampled. In addition, for CACI 

we were unable to determine whether the re-contacts that were 

performed were completed within 60 calendar days of the initial 

contact. 

111 
5. Re-Contact of Personal Sources by FIS Procedural 

FIS did not conduct the required three re-contacts for 11 of the 80 


Background Investigators we sampled. 


IV 

TABLE OF CONTENTS 

I. INTRODUCTION AND BACKGROUND ...................................... .. 


II. OBJECTIVES, SCOPE, AND METHODOLOGY ......... ________ .... ____ ... 
 4 

III. AUDIT FINDINGS AND RECOMMENDAnONS .. ____ ................... 7 


A. General Observations 

1. Training................................................................. 7 


2. Quality Case Review Initiative ................................. __ ... 8 


3. Integrity Statement ........................................ __ .... ..... 9 


B. Case Quality Review Process 

1. Random Review Process. . . . . . . . . . . . . . . . . . . . .... . . . . . . . . . . . . . . . . . . . . . 9 


2. Oversight of the Closing Authorization and Support Team 


(CAST)................................................................. 10 


C. Training for Investigative Personnel 

l. Investigative Technician Training ...., ... __ .. __ ..................... 12 


2. Mentor Training .................................................. , . ... 13 


3. Investigator Training for Contractors.............................. 14 


4. Check Rides Not Conducted by Contractor.. ..... ................. 15 


5. Check Rides at PIS Not Conducted................. ..... ........... 16 


6. Evaluation Results Not Documented ................ __ ...... ,. ..... 17 


7. Oversight of Contractors' Evaluation Submissions.............. 18 


D. Falsification/Integrity Issues 

1. Misconduct Issues Not Submitted Timely ................... __ ... 19 


2. Record Source Validations Not Performed ____ .. __ ...... ' ...... __ 20 


3. Review of Record Checks .. __ .... ____ .... __ ...... __ ........ __ ....... 21 


4. Re-Contact of Personal Sources by Contractors.. ... . . .......... 23 


5. Re-Contact of Personal Sources by FIS .......... __ .... __ .. __ __ __ __ 24 


IV. MAJOR CONTRIBUTORS TO THIS REPORT ............................. 
 27 

APPENDIX (Federal Investigative Services Response, received January 22,2010, 

to our draft report) 

I. INTRODUCTION AND BACKGROUND 


Introduction 

This final audit report details the findings, conclusions, and recommendations resulting from our 

performance audit of the Quality Assurance Process over Background Investigations. The audit 

was performed by OPM's Office of the Inspector General (OIG), as authorized by the Inspector 

General Act of 1978, as amended. 

Background 

OPM's Federal Investigative Services (FIS) is responsible for conducting background 

investigations on Federal applicants, employees, and contractor personnel to determine the 

fitness and suitability of these individuals to hold security clearances. Background investigations 

are conducted to resolve issues, enforce the civil service laws, rules, and regulations, and verify 

the qualifications of applicants for certain high level administrative and professional positions. 

FIS conducts approximately ninety percent of all personnel background investigations for the 

Federal Government. 

During fiscal year (FY) 2009, FrS contracted with three background investigative contractors: 

US Investigations Services, Inc. (US IS); KeyPoint Government Solutions (KGS), formerly 

Kroll; and CACl International, Inc. (CACI), hereafter referred to as the "Contractors", to assist 

with completing background investigations. FrS currently has almost 8,600 Federal and contract 

staff devoted to the background investigations program, including 6,800 Federal and contractor 

field Background Investigators, hereafter referred to as "Investigators". They are strategicaliy 

located throughout the United States and overseas to facilitate and expedite investigations. 

Case Review Process 

When completed background investigations are determined to be eligible for closing they are 

sent to PIS' Investigations Review Group (lRO) for full review or to the support contractor, 

known as the Closing Authorization and Support Team (CAST), for limited review and closing. 

FrS stated that on average, the CAST closes 140,127 cases per quarter. If the IRO finds 

problems with the background investigation that rise to the deficient level, they refer the case to 

the Quality Management Group (QMO) in FIS for action. Since the CAST only conducts a very 

limited review, they neither correct errors nor do they refer the investigation to QMO. If the 

CAST finds a problem of significance (i.e., quality issues), they will send the background 

investigation to the IRG for full review. 

FIS' Quality Assurance (QA) team oversees the quality assurance process for both the Federal 

and Contractor staff. Their duties include reviewing cases prior to closing the case and random 

case review for cases that have closed. In addition, FIS has a Contractor Oversight Program 

which monitors the quality, timeliness, productivity, and performance against contract 

requirements, identifies problem areas, and provides the results to the contractor. 

1 

One of the main groups in FrS involved in the quality assurance process over background 

investigations is the Quality Management Group (QMG). The QMG provides feedback to both 

the Federal and contractor field investigative elements as well as the Federal case review staff to 

ensure a consistent, high quality product to their customers, as well as to use their findings to 

enhance Investigator and reviewer training. Specifically, the QMG evaluates closed background 

investigations and provides feedback to the review staff. In addition, the QMG provides 

feedback to field investigators on investigations that the reviewers have referred to the QMG for 

review. The QMG also conducts a random review of background investigations. The random 

review process consists of selecting cases for review.after reviewers in FIS' IRG have completed 

the closing action in the Personnel Investigations Processing System (PIPS). These 

investigations are randomly selected by the QMG personnel and include cases that were never 

referred to the QMG as a deficiency; however, random review cases can also be selected through 

other mechanisms. The cases are evaluated to determine if there were any problems with the 

investigation that should have been caught by the reviewer and corrected. If there are problems, 

the QMG will prepare a quality feedback document outlining the problems and send the 

investigation back to the reviewer's supervisor to have the investigation reopened and corrected. 

The QMG maintains a database of this infonnation and supplies statistical reports to IRG 

documenting the quality problems that have been found. 

According to OPM's contract with the Contractors, each Contractor is required to have a quality 

assurance process in place. FIS does not mandate what the process should entail; instead, 

management for each of the Contractors decides what they want to review and how often. 

Training 

All Contractors and FIS employees conducting background investigations must be trained on 

FIS' requirements for background investigations. For Contractors, the contract outlines 

specialized training, experience, and/or education qualifications that an individual must have in 

order to hold a position as an Investigator, Reviewer, or Investigative Technician. Investigators 

initially receive classroom training prior to receiving their first case load as an Investigator. 

Required training is commensurate with prior experience. 

Falsification/Integrity Issue 

FIS' Integrity Assurance Group (lAG) validates information gathered during source interviews 

directly with that source via the Re-Contact Letter Program. The re-contact letters are done for 

Federal and Contractor Agents (US1S, CACI, and KGS). The Processing Support Branch (PSB) 

is responsible for mailing out the re-contact letters. They are supposed to send out three recontact letters per Investigator (Federal and Contractor) per month. The re-contact letters are 

generated based on a PIPS data dump of all Investigator leads. The re-contact letter is auto 

populated (i.e., investigator name, subject name, address, etc.) based on the information the 

Investigator entered into PIPS while the background investigation was being conducted. The 

responses to the letters are returned to PSB. The findings from re-contact letter results are 

processed by referring congratulatory comments to the field management staff to provide 

positive quality feedback to the Investigator workforce and refer potential integrity issues to the 

Integrity Assurance Group for further investigation and resolution. They also serve as a quality 

2 

assurance tool to evaluate Investigators' investigative teclmiques and overall professionalism and 

to assess training needs in the field. 

For the Contractors, the contract provisions require that at least two record sources per quarter 

per investigative personnel are rand~mly re-contacted to validate the fact that the search was 

conducted and the accuracy ofthe record information obtained. In addition, Contractors must 

conduct re-contacts of personal sources during the first year of the Investigator's employment. 

The contact must be done randomly and telephonically. On an annual basis, no less than three 

percent of all personal sources obtained by each background investigative personnel shall be recontacted within 60 calendar days of the initial contact. 

3 

II. OBJECTIVES, SCOPE, AND METHODOLOGY 


Objectives 

The primary objective of our audit was to determine whether FIS has effectively implemented 

controls for the quality assurance process over background investigations. 

In order to achieve our primary objective, our audit included the following specific objectives: 

1. 	 Determine whether FIS and the Contractors are following their respective case quality 

review process; 

2. 	 Determine if FIS and the Contractors have controls in place to ensure that their review 

personnel are trained to perform their duties; 

3. 	 Determine if FIS and the Contractors have controls in place to ensure that their 


investigative personnel are trained to perform their duties; and 


4. 	 Determine if FIS and the Contractors have adequate controls in place to identify 


falsification and/or integrity issues. 


The recommendations included in this final report address these objectives. 

Scope and Methodology 

We conducted this performance audit in accordance with generally accepted government 


auditing standards as established by the Comptroller General of the United States. Those 


standards required that we plan and perform the audit to obtain sufficient, appropriate evidence 


to provide a reasonable basis for our findings and conclusions based on our audit objectives. We 


believe that the evidence obtained provides a reasonable basis for our findings and conclusions 


based on our audit objectives. 


The scope ofour audit covered FIS' and the Contractors' policies and procedures for fiscal year 


2009, governing the quality assurance process over background investigations. 


We performed this audit from July 22, 2009 through October 22, 2009 at FIS offices located in 


OPM headquarters in Washington D.C. and Boyers, Pennsylvania. In addition, we visited 


Contractors' sites located in Chantilly, Virginia; Loveland, Colorado; and Grove City, 


Pennsyl vania. 


To accomplish the audit objectives noted above, we: 


• 	 Sampled closed cases and tested FIS' and the Contractors' policies for reviewing cases to 

ensure they are adhering to their processes and to determine if the process was efficient; 

4 

• 	 Sampled and tested FIS' and the Contractors' training records for their reviewers and 

Investigators; 

• 	 Tested FIS' and the Contractors' falsification and integrity process, which included 

sampling and testing the re-c?ntact program for both personal and record sources; and 

• 	 Interviewed FIS and Contractor employees. 

In planning our work and gaining an understanding of the internal controls over the quality 

control process over background investigations, we considered the internal control structure to 

the extent necessary to develop our audit procedures. These procedures were mainly substantive 

in nature, although we did gain an understanding of management procedures and controls to the 

extent necessary to achieve our audit objectives. The purpose of our audit is not to provide an 

opinion on internal controls, but merely to evaluate controls over the processes that were 

included in the scope of our audit. Our audit included such tests of FIS' and the Contractors' 

records and other procedures as we considered necessary under the circumstances. The results of 

our tests indicate that with respect to the items tested FIS has implemented controls to assure the 

quality of background investigations, except for the areas set forth in the details ofthis audit 

report. 

In conducting our audit, we tested FIS' and the Contractors' compliance with their policies and 

procedures, as well as the Contractors' compliance with the Conformed Fieldwork Contract by 

selecting samples of cases; Background Investigator, Reviewer, and Investigative Technician 

training records; integrity reports; and re-contact reports. 

Our sampling methodology consisted of the following: 

Case Review Process 

In order to verify that FrS and the Contractors are adhering to their case review process, we 

selected the following judgmental samples: 

• 	 25 out of 1 1,581 USIS closed cases from May 4 through 8, 2009; 

• 	 25 out of 1,086 KGS closed cases from May 4 through 8, 2009; and 

• 	 25 out of343 CACI closed cases from August 1 through 12,2009. 

We also judgmentally sampled 25 out of 48 new and 25 out of 1,417 experienced FIS 

Investigators and requested all cases reviewed for each of the Investigators for the month of May 

2009 to verify that FIS is adhering to their case review process. 

In order to determine if FIS and USIS were following their internal polices and procedures for 

random case reviews, we selected the following judgmental samples: 

• 	 25 out of 73 cases randomly reviewed by Frs from March 1 through 31, 2009 and 

• 	 25 out of 719 cases randomly reviewed by USIS from May 1 through 31, 2009. 

KGS and CAeI do not perform random case reviews. 

5 
Reviewer Training 

We tested a judgmental sample of25 out of 325 FIS case reviewers; 25 out of232 USIS case 

reviewers; 25 out of 33 KGS case reviewers; and all 11 CACI case reviewers to determine if they 

have completed an OPM-approved reviewer training course. 

Investigator Training 

For new Investigators hired during June 2008 through June 2009, we judgmentally sampled 25 

out of 48 FIS Investigators; 25 out of 137 USIS Investigators; and 25 out of299 KGS 

Investigators to determine if they have completed an OPM-approved Investigators training 

course. We also tested a random sample of25 out of68 CACI Investigators. 

For experienced Investigators, we judgmentally sampled 25 out of 1,417 FIS Investigators; 25 

out of 2,292 USIS Investigators; and 25 out of 330 KGS Investigators to detennine if they have 

completed an OPM-approved Investigators training course. We also tested a random sample of 

25 out of 240 CACI Investigators. 

Record Searcher Training 

We tested a judgmental sample of 25 out of 59 FIS record searchers; all 8 USIS record searchers; 

and all 14 KGS record searchers to deterrnine if they have completed an OPM-approved record 

searcher training course. CACI does not have official record searchers. AU Investigators at 

CAeI are able to do their own record checks. 

The remainder ofour samples are discussed in the body of our findings. The results from the 

various samples were not projected to the population. 

6 

III. AUDIT FINDINGS AND RECOMMENDATIONS 


Our audit disclosed that, with respect to the items tested, FIS has an adequate quality control process over 

background investigations, except for the ~reas set forth in the details of this audit report. For those 

Contractors not specifically identified below in the detail of this report, it was determined that their process 

was adequate for that particular issue. The areas requiring improvements are described below. 

A. General Observations 

Over the course of our audit we were able to observe the quality assurance process for FIS 

and the Contractors. We have identified tluee overarching areas for which we feel 

improvements would have a positive impact on the overall quality assurance process for 

background investigations. The three areas that came to our attention are discussed below. 

1. Training 

All Contractors and FIS employees conducting background investigations must be trained on 

FIS' requirements for background investigations. For the Contractors, the contract outlines 

specialized training, experience, and/or education qualifications that an individual must have 

in order to hold a position as an Investigator, Reviewer, or Investigative Technician. 

However, there is no standardized, universal training for personnel who perform the same job 

functions (e.g., Investigator, Reviewer) at FIS, USIS, CACI, and KGS. 

Even though each organization has its own, organization-specific training program that is 

approved by FIS, it is not consistent from contractor to contractor or with FIS. For example, 

there may be additional training modules that may be presented to Investigators that work for 

USIS that are not included in the training program used by CAC£. Not training all persollilel 

(whether FIS or Contractor) in the same manner may lead to a lack of uniformity in 

conducting background investigations. This may lead to work products being incomplete, 

inaccurate, and possibly compromised. 

The Government Accountability Office's (GAO) Standards/or Internal Control in the 

Federal Government state that "Management should ensure that skill needs are continually 

assessed and that the organization is able to obtain a workforce that has the required skills 

that match those necessary to achieve organizational goals. Training should be aimed at 

developing and retaining employee skill levels to meet changing organizational needs." 

Recommendation 1 

We recommend that FIS implement a standardized universal training program that is required 

to be used by FIS and the Contractors for all persollilel who perform work completing 

background investigations (e.g., Investigators, Reviewers, and personnel completing record 

checks). 

7 
FIS' Response: 

"FIS concurs with this recommendation" and stated that "When the new contracts are 

awarded in 2011, FrS will mandate that all companies doing investigati ve work on behalf of 

OPM send their investigators to training classes conducted by OPM. In the interim, 

contractor companies can voluntarily send their investigators to the OPM Basic Investigators 

course. . .. With the issuance of new field contractors in 2011, FrS Training and 

Professional Development (TPD) will have adequate capacity to provide training to all field 

agent staff (Federal and contractor) that supports OPM's investigations program." 

2. Quality Case Review Initiative 

The Standard Operating Procedures (SOP) Supporting the FY09 Quality Case Review 

Initiative for the Northern Region was issued as a single resource for supervisors and case 

reviewers in the Northern Region as a means of standardizing the methodology for 

evaluating, documenting, and analyzing the quality of background investigations conducted 

within the region. The SOP provides instruction, criteria, and guidance for quality reviews 

conducted in the region. The SOP addresses the need for objective, clearly defined criteria 

that reasonably separates an "Adequate" report of investigation from one that is "Deficient". 

The SOP identifies four core elements for an investigation to be rated as "Adequate". The 

SOP also includes the use of a standardized form, The Report a/Quality Review version 2.3, 

which is used by all reviewers to document the results of the quality review. A quality case 

review shall not be considered complete until the supervisor has entered the results of the 

review into the Quality Review Database (QRD) and provided a copy of the evaluative 

results to the Investigator. The QRD has been created to serve as the single resource for 

recording, documenting, and analyzing the results of all completed quality case reviews. 

As of September 2009, the Quality Case Review program had not been fully initialized 

throughout all of FIS' regions. Based on the documentation we reviewed concerning the 

Northern Region, it appears this will be a quality assurance asset once implemented 

nationally. This program will help to bring continuity and standardization to the review 

process which should help in identifying and fixing deficient background investigations prior 

to the case being provided to the customer agency. 

Recommendation 2 

We recommend that FIS implement the Quality Case Review program throughout all of the 

reglOns. 

FIS' Response: 

"FIS concurs with this recommendation" and stated that "All regions have been provided 

with the standard review tools and tracking system developed by the Northern Region. FIS is 

reviewing this process to make additional changes and will continue to refine this tool as we 

move forward. All regions have received training on the automated tool that will allow 

8 
standard tracking of reviewed cases throughout the Federal field. Full implementation is 

expected by the end of January 2010." 

3. Integrity Statement 

While conducting our audit work on FIS and its Contractors' integrity programs, we became 

aware of USIS' practice of having their employees sign an Integrity Pledge as a part of their 

Security Awareness Tool. . 

The pledge states that the employee understands that deliberate misrepresentation, 

misconduct, negligence, or falsification of any part of a personneL security investigation can 

. affect the individual, the customer agency, and the employee. The pledge also states that the 

employee is aware that there will be severe consequences, including possible termination, 

possible criminal prosecution and/or potential civil liability for damages if the employee 

commits any of these acts as adjudged by USIS, a customer agency, or an independent third 

party. We discussed this pledge with our investigative staff that has been working on 

falsification cases to determine what impact a signed statement like this could have on an 

investigation and found that in a prior case this statement was vital evidence for winning the 

case. 

As a result, we found this procedure to be a practice that should be considered by FIS and its 

Contractors. By requiring this pledge of all employees conducting background investigative 

work for FIS, it will serve as a reminder as to the roles and responsibilities individuals have 

while performing their job functions and would hopefully help to serve as a deterrent for 

those considering actions that may lead to fraud, waste, and abuse. 

Recommendation 3 

We recommend that FIS implement the use of an annual Integrity Statement for its 

employees and Contractors to assist in any possible falsification cases. 

FIS' Response: 

"FIS cannot concur with this recommendation until the legality of such a statement is 

determined by OPM's Office of General Counsel (OGC). We will present this issue to OGe 

for an opinion before developing an action pian." 

B. Case Quality Review Process 

1. Random Review Process 

The Quality Management Group's internal control that helps to identify potential problems 

with a background investigation was not in place for half of FY 2009. 

9 
Frs' QMG is made up of three branches: the Quality Management Branch, the Random 

Review Branch eRRB), and the Program Training Branch. We requested a list of all cases 

randomly reviewed by QMG from May 1 to May 31, 2009; however, QMG stated that they 

ceased the random reviews in April 2009. QMG ceased the random review process in order 

for them to focus on developing specific training modules based on errors discovered by the 

random reviews. They then conducted reviewer refresher training in May, June, and early 

July 2009. 

OMB Circular A-I23 (Introduction) indicates that "Management has a fundamental 

responsibility to develop and maintain effective internal controL The proper stewardship of 

Federal resources is an essential responsibility of agency managers and staff. Federal 

employees must ensure that Federal programs operate and Federal resources are used 

efficiently and effectively to achieve desired objectives." 

GAO's Standards for Internal Control in the Federal Government state that management is 

responsible for developing control activities, which are the policies, procedures, techniques 

and mechanisms that enforce management's directives. Control activities occur at all levels 

and functions of an entity and include a wide range of activities, such as approvals, 

authorizations, verifications, reconciliations, performance reviews, maintenance of security, 

and the creation and maintenance of related records which provide evidence of execution of 

these activities, as well as appropriate documentation. 

In addition, internal controls should be designed to assure that ongoing monitoring occurs in 

the course of normal operations. It should be performed continually and ingrained in the 

agency's operations. 

Without internal controls in place to identify potential problems in cases closed by the 

Federal review staff, there is an increased risk that these closed cases may be of poor quality 

and contain errors. 

Recommendation 4 

We recommend that FIS resume the random case review process and ensure that internal 

controls are designed to assure that ongoing monitoring occurs in the course ofnonnal 

operations. 

FIS' Response: 

"FIS concurs with this recommendation" and stated that they "resumed random review as of 

January 8, 2010." 

2. Oversight of the Closing Authorization and Support Team (CAST) 

Deficient cases are being closed in the CAST by the support contractor. As of 

September 2, 2009, we requested the most recent audits of the CAST to determine ifFIS has 

proper oversight of the CAST. Based on the QMG audits in March 2009,28.24 percent of 

10 
the 85 sampled closed cases were unacceptable, and in June 200926.87 percent of the 67 

sampled closed cases were unacceptable. 

FIS is not enforcing the CAST case cursory review requirements, which should be followed 

by the support contractor. 

On a quarterly basis, QMG conducts audits ofthe limited review and closing functionas 

performed by the CAST. This is an internal control that FIS has in place to evaluate the 

quality ofthe closing review process performed by the CAST. During the audit, QMG 

compares the review and closing work perfonned by the CAST to the requirements set forth 

in their contract. The results are provided to PIS' Capacity Development and Oversight 

Group, which forwards the results to the contractor. Depending on the nature of the problem 

with the background investigation, QMG may require the support contractor to correct it or it 

may be turned over to IRG for Federal review staff to correct the problem. 

The criteria for closing cases in the CAST are based upon section 36.2.3 of the Case Cursory 

Review document which states "Ensure that the fieldwork covers case requirements. If the 

fieldwork does not cover what is required for a particular case type, the case must go back to 

the Review Contractor for full review." 

The Support Services Contract, section c.l.7.1, states that OPM will initiate a quality 

assurance program to monitor services provided which includes the contractor's quality. 

Section CA states that all work perfOlmed under the contract will be performed according to 

the operation manuals, instructions, memos, and as instructed by authorized OPM Personnel. 

The Case Cursory Review requirements are used to determine if a case has the correct 

documentation needed to be closed. 

GAO's Standards for Internal Control in the Federal Government state that management is 

responsible for developing control activities, which are the policies, procedures, teclmiques 

and mechanisms that enforce management's directives. Control activities occur at all levels 

and functions of an entity and include a wide range of activities, such as approvals, 

authorizations, verifications, reconciliations, performance reviews, and the creation and 

maintenance ofrelated records which provide evidence of execution of these activities as 

well as appropriate documentation. Examples of control activities/techniques include top 

level reviews of actual perfonnance and reviews by management at the functional or activity 

leveL 

In addition, internal controls should be designed to assure that ongoing monitoring occurs in 

the course of normal operations. It should be performed continually and ingrained in the 

agency's operations. 

By not enforcing the CAST case cursory review requirements, there is an increased risk that 

the number of deficient cases being closed will continue to increase. 

11 
Recommendation 5 

We recommend that FIS design internal controls to ensure that ongoing monitoring of the 

CAST occurs during the normal ~ourse of operations. 

FIS' Response: 

"FIS concurs with this recommendation" and stated that "The internal control of Quality 

Management auditing the contractor-conducted CAST process, on a quarterly basis, will 

remain in effect until the function is moved to the Federal staff. The most recent audit was 

completed on October 9,2009 for the first quarter of Fiscal Year 2010. QMG is in the 

process of scheduling an audit for the current quarter. Once the function moves to the Federal 

staff, Quality Management will audit this function as part of its random review process (daily 

basis)." 

C. Training for Investigative Personnel 

1. Investigative Technician Training 

USIS and KGS did not provide an OPM-approved training course to Investigative 

Technicians who conduct record checks. 

We selected ail 8 new USIS Record Searchers and all 14 KGS Investigator Technicians to 

detennine if the employees that conduct record checks have met the qualifications to perform 

their duties. The results of our review disclosed that all 8 USIS Record Searchers and 13 out 

of 14 KGS Investigator Technicians had not received training, as required by the FIS 

contract. 

USIS did not provide a reason as to why seven individuals had not been trained. One Record 

Searcher had received training offered at the local/field level; however, the training has not 

been approved by OPM. USIS also stated that they were currently being audited by OPM's 

Program Training Branch and that they have not received approval or rejection for their 

Record Search training. 

KGS does not conduct formal training; instead, the Investigator Technicians that perform 

record checks have received on-the-job training related to the specific tasks that they 

complete. KGS stated that although they have an OPM-approved training program in place, 

tests are not given because KGS considers them to be unnecessary due to post-audits and 

reviews being performed on all cases after on-the-job training is completed. We noted that 

KGS could not provide documentation to support that they have an OPM-approved training 

course. 

The Conformed Fieldwork Contract, Attachment 4: QualificalionslTraining Standards, dated 

January 8,2009, states that the qualifications for an Investigative Teclmician include 

12 
"Successful completion of an IT/Record Courier training course which has been approved by 

aPM .... " 

The Contract also states that "OPM requires that certain personnel performing work under 

this contract possess minimum qualifications and training, ... and reserves the right to review 

these qualifications, determine ifthe minimum requirements are met, and whether the 

individual shall be permitted to perfonn work on the contract. All contract personnel 

conducting work on the contract must be trained through an aPM approved contractor 

training plan." 

As a result of USIS and KGS not providing employees that conduct record checks with 

formal OPM-approved training, there is an increased risk that the work performed by the 

technicians may be incomplete and inaccurate. 

Recommendation 6 

We recommend that FIS require USIS and KGS to provide an OPM~approved training course 

to all employees who perform record checks. 

FIS' Response: 

"FIS concurs with this recommendation." FIS has been informed by USIS that the course is 

no longer being provided and they are working with KGS on an approved training course. 

OIG Comment: 

FIS' response that USIS is no longer providing this training does not satisfy our 

recommendation. It is our opinion that an OPM~approved training course is still needed for 

any employee who perform record checks, including the eight USIS employees identified 

above. We continue to recommend that FIS ensure that all employees who perform record 

checks complete an aPM~approved training course. 

2. Mentor Training 

We found that 18 of the 20 mentors at FIS did not complete a mentor training course. The 

names of the mentors were provided to FIS separate from this report. 

Mentors are assigned to new Investigators and are responsible for helping the new 

Investigator become acclimated with their work life, their tasks, and their responsibilities. 

The mentor also evaluates the new Investigator to ensure they are developing the skills 

required to become an Investigator. 

We judgmentally sampled 25 out of 48 new Investigators to determine if each was assigned a 

mentor. We than selected the 20 mentors assigned to these Investigators for our review. We 

tested the training records of the 20 mentors and determined that training had only been 

provided to 2 of them. 

13 
GAO's Standards/or Internal Control in the Federal Government state that "All personnel 

need to posses and maintain a level of competence that allows them to accomplish their 

assigned duties, as well as under~tand the importance of developing and implementing good 

internal control. Management needs to identify appropriate knowledge and skills needed for 

various jobs and provide needed training ...." 

GAO's Standards/or Internal Control in the Federal Government also state that 

"Management should ensure that skill needs are continually assessed and that the 

organization is able to obtain a workforce that has the required skills that match those 

necessary to achieve organizational goals. Training should be aimed at developing and 

retaining employee skill levels to meet changing organizational needs." 

By not having all mentors attend mentor training, there is a risk that new Investigators may 

not receive the proper instruction to perfonn their duties, which may lead to a decrease in the 

quality of background investigations. 

Recommendation 7 

We recommend that FIS have all mentors complete a mentor training course prior to serving 

as a mentor to new Background Investigators. 

FIS' Response: 

"FIS concurs with this recommendation" and stated that four mentors for each FISD Region 

participated in the first standard mentor training course that was conducted May 24 

through 28,2010. 

3. Investigator Training for Contractors 

We judgmentally selected 25 out of 330 experienced KGS Investigators and 25 out of 2,292 

experienced USIS Investigators to determine if they met the qualifications to perfonn their 

duties. We concluded that: 

• 	 KGS could not support that one Investigator passed the training course final exam 

with a score of at least 80 percent. 

• 	 One USIS Investigator failed the New Investigator Training (NIT) final exam, but 

their training system showed that the Investigator passed the NIT course on the same 

date that the final exam was failed. No documentation was provided showing that 

the Investigator ever re-took and passed the NIT final exam. 

The Con/armed Fieldwork Contract, Attachment 4: Qualifications/Training Standards, dated 

January 8, 2009, states that "All contract personnel conducting work on the contract must be 

trained through an OPM approved contractor training plan. The plan must include, but is not 

limited to, in class instruction on all aspects of duties, mock interviews applicable to position, 

14 

an open book final exam that must be passed with at least an 80% score, a minimum of one 

week on-the-job training for all Investigative staff with experience and 3 weeks for those 

with no experience." 

In addition, the Contract states that "An incumbent (. .. investigator ...) in good standing 

currently conducting investigations on OPM contracts may be transferred to another entity 

without any additional training. Training is left to the discretion ofthe investigative entity 

when the incumbent has 18 months of consecutive OPM experience (in the respective job 

title) and less than 8 months of inactivity working OPM investigations." 

The absence of documentation to support that all Investigators are properly qualified 

increases the risk that there are Investigators who have not been properly trained and cleared 

to perform background investigations on behalf of FIS. Unqualified individuals working on 

background investigations can lead to the investigation and related Personally Identifiable 

Information being compromised. 

Recommendation 8 

We recommend that FIS require KGS and usrs to provide documentation to support that the 

Investigators have completed all qualifications necessary in order to perform background 

investigations on behalf of FrS. 

FIS' Response: 

FIS concurs with this recommendation and stated that, "OPM will conduct inspections to 

ensure that the contractor's are maintaining the qualifications as outlined in the contract." 

4. Check Rides Not Conducted by Contractor 

USIS did not conduct check rides for 2 ofthe 25 new Investigators that we sampled. A 

check ride is an evaluation tool used to verify that Investigators are conducting background 

investigations according to field standards. We judgmentally sampled 25 out of 137 new 

Investigators to determine if USIS conducts a check ride at the conclusion of the new 

Investigator's field training process. 

usIS stated that check rides for the two identified Investigators had not yet been conducted 

this year. We noted that both Investigators completed field training prior to October 2008. 

For new Investigators, USIS' Check Ride Standards/Field Quality Assurance Policy states 

that "The investigator will complete their field training with the Field Training Officer 

(FTO), Certified Field Trainer (eFT), or Team Leader. The trainer will complete the initial 

check ride with the new investigator at the completion of the new investigator field training 

process." 

Not completing the required check ride for each new Investigator at the completion of their 

field training process increases the risk that USIS will not be able to ensure the new 

15 
Investigator is efficient, capable, andlor reveal any weaknesses that may compromise their 

investigations. There is also an increased risk that the information contained in the new 

Investigator's Report of Investigation may be incorrect or falsified. 

Recommendation 9 

We recommend that FIS instruct USIS to update its Check Ride Standards/Field Quality 

Assurance Policy to include a defined timeframe as to when USIS must conduct check rides 

for their new Investigators once they have completed their field training. 

FIS' Response: 

"FIS concurs with this recommendation" and stated that they "will instruct USIS to review 

their internal check-ride policy and make a determination on a defined timeframe." 

5. Check Rides at FIS Not Conducted 

We judgmentally sampled 25 out of 1,417 experienced FIS Investigators to determine if each 

Investigator received, at a minimum, one check ride in the last 12 months. Seven of the 25 

experienced Investigators we sampled did not have a check ride assessment conducted during 

the period October 1,2008 to September 4,2009. The names of the Investigators were 

provided to FIS separate from this report. 

FIS' Check Ride Performance Standards state, "At a minimum, one supervisory check-ride 

shall be accomplished during the performance appraisal period. Two additional supervisory 

check-rides must be accomplished when the initial check-ride results in an unacceptable 

rating." 

As a result of FIS not conducting an arumal check ride of their experienced Investigators 

there is an increased risk that FIS is not identifying poor performers who need additional 

training and mentoring in order to properly perform their job. In addition, FIS may not be 

detecting instances of fraudulent background investigations since these check rides are used 

as a tool for supervisors to monitor and review the Investigator's work. 

Recommendation 10 

We recommend that FIS ensure that all Background Investigators receive at least one 

supervisory check ride assessment per appraisal period. 

FIS'Response: 

"FIS has complied with this recommendation. In the case of <DELETED BY OPM-OIG, 

NOT RELEVANT TO THE AUDIT REPORT>, she was promoted to an Agent on April 12, 

2009 from an Investigative Assistant position. Prior to becoming an agent there would have 

been no requirement or need for her to attend the BIC [Basic Investigative Course]. She 

completed the BIC on 10123/2009. Prior to that she would have been in training and 

16 
assigned a mentor. The documentation for the other six agents is attached showing they had 

a check ride conducted or were in training. FIS did meet all requirements for each agent" 

OIG Comment: 

Based on FIS' response, they have complied with the recommendation; however, we were 

not provided support that the agent did not complete the BIC until after the end of our 

fieldwork and therefore would not have had a check ride completed. In addition, we were 

not provided copies of the check rides in order to verify the dates that they were completed. 

6. Evaluation Results Not Documented 

CAC! does not have a process in place to document the results of their evaluations of 

Investigators. 

We requested copies of the results of evaluations conducted under the CACI evaluation 

program which were submitted to FIS from October 1, 2008 through our audit site visit, 

which was August 10 through 14,2009. Based on this request, there was some uncertainty 

from CACI as to what specific documents should be sent to FIS. 

CACI stated that they do not conduct check rides with Investigators. CAeI currently has a 

mentoring program; however, it does not include any written evaluations ofthe Investigator 

candidate. 

FIS Fieldwork Contract Quality Assurance Provisions Applicable to CAC] 

(OPM040600012) fieldwork contracts, section C.6.1.8, states that "The Contractor shall 

establish a program for the evaluation of investigators and investigative technicians during 

the performance of their work to ensure compliance with the professional conduct 

requirements and investigative standards of this contract This may include, but is not limited 

to, such things as a mentoring program, a ride-along program, or similar evaluation 

programs. The results of evaluations conducted under the Contractor's evaluation program 

must be forwarded to the COR within 30 days of the date of the evaluation or, if otherwise 

appropriate, in accordance with the requirements of this contract." 

By not documenting the results of evaluations, CACI and FIS will not be able to ensure that 

field Investigators are maintaining professional conduct and investigative standards outlined 

in the contract. If Investigators are not adhering to professionalism and investigative 

standards, investigations may be compromised, leading to a decrease in their quality. 

Recommendation 11 

We recommend that FIS require CACI to implement controls to ensure that the results of 

evaluations conducted under CACI's evaluation program are documented and forwarded to 

the COR within 30 days of the date ofthe evaluation. 

17 
FIS' Response: 

"FIS does not concur with this recommendation." FIS stated that "CACI has an established 

evaluation program. CACI sub~itted their evaluations on January 8, 2010 (attached), and 

will submit their evaluations no later than 30 days after the end of the rating period for future 

submissions. FrS has incorporated a review and validation of the report as part of the 

workload goals and FIS will conduct inspections for all contractors tbroughout the year to 

ensure compliance." . 

OIG Comment: 

As stated in our finding CACI did not have documentation to support the results of its 

evaluation program during our audit. Based on FIS' response, CACI submitted their 

evaluation results on January 8, 2010. FIS provided a copy ofCACI's spreadsheet which 

covered the period December 1,2008 through December 1,2009. Since there was no 

discussion during our audit that the rating period was still in progress or a discussion of how 

the ratings were in fact tracked, it appears that this is a new process that has been 

implemented since our audit work ended. 

7. Oversight of Contractors' Evaluation Submissions 

FIS does not have controls in place to ensure that the Contractors are submitting their 

evaluation results to the Contracting Officer'S Representative (COR). 

We requested copies of the results of evaluations, which were submitted to FIS, conducted by 

each Contractor since October 1, 2008. As stated under finding C.6. above, we detennined 

that CAeI did not have a process in place to document the results of their evaluations of 

investigators. We also found that USIS and KGS conduct and document employee 

evaluations; however, they do not submit the evaluation results to FIS. 

KGS stated that they have not submitted evaluations to OPM because "the contract is vague 

about exactly what is supposed to be submitted and on whom. It does not specifically state if 

there are differences between full timers and contract investigators and whether they needed 

all documents. It does not state in what format they need to be submitted and OPM has never 

requested this infonnation. We can provide the data if we knew more parameters." USIS 

keeps their evaluations on file and they have been reviewed by OPM personnel during on-site 

visits; however, USIS has never received a request from FIS asking for the submission of 

employee evaluations. 

FIS has not issued any procedures or guidance to the Contractors as to what documentation 

regarding evaluation results should be submitted to the COR. In addition, FIS stated that 

they have not requested employee evaluations in the past year. 

The FIS Fieldwork Contract Quality Assurance Provisions Applicable to USIS 

(OPM040600013), CAeI (OPM040600012), and Kroll <KGS> (OPM040600011)jieidwork 

contracts, section C. 6.1. 8, states that "The Contractor shall establish a program for the 

18 
evaluation of investigators and investigative technicians during the performance of their 

work to ensure compliance with the professional conduct requirements and investigative 

standards of this contract. This may include, but is not limited to, such things as a mentoring 

program, a ride-along program, qr similar evaluation programs. The results of evaluations 

conducted under the Contractor's evaluation program must be forwarded to the COR within 

30 days of the date of the evaluation or, if otherwise appropriate, in accordance with the 

requirements of this contract." 

As a result of FIS not overseeing that the results of Contractors' evaluations are submitted, 

FIS will not be able to ensure that Contractor personnel are maintaining professional conduct 

and investigative standards outlined in the contract and/or the Investigator's Handbook. If 

personnel are not adhering to professionalism and investigative standards, investigations may 

be compromised leading to a decrease in the quality of background investigations. 

Recommendation 12 

We recommend that FIS issue guidance to clearly explain what documentation is expected 

from the Contractors related to their evaluation program for investigative personnel. 

FIS' Response: 

FIS concurs with this recommendation and stated that they "will immediately issue 

clarification to the contractor as to what is required to be submitted in accordance with the 

contract section C.6.1.8 and attachment 4." 

D. FalsificationlIntegrity Issues 

1. Misconduct Issues Not Submitted Timely 

USIS did not forward misconduct issues to OPM within the required timeframe for 7 of the 

40 Investigators reviewed. Details regarding the seven Investigators were provided to FIS 

separate from this report. 

We reviewed all 40 Investigators with misconduct issues identified from October 1,2008 to 

August 11, 2009 to determine ifthe information was properly referred to OPM. USIS stated 

that there is no formal procedure on when to record the times that the USIS Integrity 

Assurance Team receives a misconduct issue. 

The Conformed Fieldwork Contract dated January 8, 2009, Section Cll. O. 6, states, "in 

regard to notification of allegations of misconduct, the Contractor shall make such 

notification within one workday whenever possible but in no case exceed 3 workdays in 

doing so." 

Section H3 also states: "Any action or misconduct by a Contractor employee or 

subcontractor that might adversely affect (1) the integrity of an investigative product or 

19 
OPM's automated system, (2) OPM's access to source information, (3) a subject or source's 

privacy rights, (4) the security of investigative material or OPM equipment or facilities, or 

(5) the individual's basic suitability to perform work under this contract, or (6) workplace 

safety, is of concern to OPM. If qiscovered by the Contractor, the Contractor shall 

immediately notify OPM of the individual's identity, the nature of the alleged negligence or 

misconduct, and any investigations that may require review and/or reopening." 

The USIS Fieldwork Services Quality Assurance Surveillance Plan, Section B. 7, states, "The 

USIS Integrity Assurance Team will notify OPM within 24 hours of any integrity issue 

developed by the field." 

If misconduct issues are not forwarded to aPM in accordance with established timelines, 

there is an increased risk that an unethical Investigator may be performing background 

investigations, thus increasing the risk to national security. 

Recommendation 13 

We recommend that FIS require USIS to establish procedures to ensure that misconduct 

issues are documented and reported to aPM within the timeliness standards outlined in the 

contract and USIS policy. 

FIS'Response: 

FIS concurs with this recommendation and stated that they "will require USIS to adhere to 

the time frame in section C.ll.06, Section H.3, and Section B.7 once a misconduct issue is 

identified. " 

2. Record Source Validations Not Performed 

We requested documentation (i.e., reports, spreadsheets, etc.) to support that record 

validations were performed, from October 1,2008 through August 19,2009, on all 

investigative personnel who perform record searches. The results of our review disclosed 

that the Contractors did not have controls in place to conduct record source validations. 

Specifically we found that: 

• 	 USIS and CACI do not re-contact and validate at least two record sources per quarter 

per investigative personnel. USIS stated that they were under the impression that FIS 

would complete all record source re-contacts similar to the personal source recontacts that FIS performs. 

• 	 KGS could not provide support that record validations were completed prior to 

August 19,2009 for Investigator Technicians. In addition, they were unable to 

support that they completed two record validations per quarter for each Background 

Investigator. KGS stated that documentation to support record validations done for 

Investigator Technicians was destroyed after 120 days. In addition, KGS does not 

20 

maintain a system to demonstrate that a sufficient number of record validations are 

performed for each Background Investigator or Investigator Technician that performs 

record searches. 

FIS Fieldwork Contract Quality Assurance Provisions Applicable to CAeL USIS, and KGS 

(OPM040600012, OPM0406000J3, OPM04060001J) fieldwork contracts, section C.6.1.5, 

states that "The Contractor shall validate record sources; at least two record sources per 

quarter per investigative personnel must be randomly re-contacted to validate the fact that the 

search was conducted and the accuracy of the record information obtained." 

If record sources are not validated in accordance with the contract, there is an increased risk 

that if the initial record search was not conducted or the information reported is inaccurate, it 

will not be discovered. 

Recommendation 14 

We recommend that FIS require the Contractors to develop and implement internal controls 

to ensure that at least two record sources per quarter per investigative personnel are randomly 

re-contacted to validate the fact that the search was conducted and the accuracy of the record 

information obtained. Internal controls should include a requirement for KGS to maintain 

documentation to support the completion of the re-contacts. 

FIS~ Response: 

"Frs concurs with this recommendation" and stated that they "will conduct inspections 

throughout the year to ensure contractor compliance." 

3. Review of Record Checks 

FIS did not conduct the required number of record check reviews for all Investigative 

Assistants. 

FIS' Centralized Lead Branch (eLB) assists field resources in conducting certain 

investigative work. Specifically, this group can accomplish credit record reviews, law 

searches, Internal Revenue Service record reviews, as well as access bankruptcy, 

employment and education records. Mentors and Team Leaders within the CLB review 

record checks on a monthly basis to determine if the completed record search is acceptable, 

correct, and complete. 

In order to verify that record checks are being reviewed, we requested documentation (i.e., 

reports, spreadsheets, etc.) to support reviews/validations of record checks performed from 

October 1,2008 through August 25, 2009. FIS provided a spreadsheet that is used to record 

the results of the random reviews conducted on the 54 Investigative Assistants. The 

spreadsheet captures the numbers reviewed as deficient, acceptable, and acceptable with 

advisory; however, it does not provide details to support the ratings. That information is 

maintained by the Team Leader in the individual's folder. The spreadsheet also does not 

21 
contain the last name for each Investigative Assistant; therefore, we selected all Investigative 

Assistants for our review. 

Based on the results of our revie~ we found that: 

• 	 The CLB Mentors did not complete any reviews of record checks. 

• 	 Four of the six CLB Team Leaders (teams 1,4,5, and 6) have not perfonned their 

required random reviews for two Investigative Assistants per month. . 

• 	 There were no record check reviews perfonned for 18 of the 54 Investigative 

Assistants in one or more quarters from October 1,2008 through August 25,2009. 

PIS stated that due to the number of new employees this fiscal year and the extensive time 

involved in a 100 percent review of these trainees' work, the two quality/training team 

personnel (the Mentors) were unable to assist with the random reviews. 

The Performance Standards Formfor aPMEmployees states that Investigator GS-181O-12 

(Team Leaders) "Maintains quality controls for those investigative leadslrecords checks that 

have been assigned as a primary responsibility. Conducts random review ofthe work of2 

Investigative Assistants per month at a rate of 10 checks per Investigative Assistant." 

For the Mentors, the Performance Standards Formfor aPM Employees states that 

Investigator GS-181 0-12 (Quality/Training) "Maintains quality controls by contributing to the 

effort to ensure that random review of work is conducted at an overall rate of 10 per quarter per 

Investigative Assistant, GS-06 and above." 

GAO's Standards for Internal Control in the Federal Government state that management is 

responsible for developing control activities, which are the policies, procedures, techniques 

and mechanisms that enforce management's directives. Control activities occur at all levels 

and functions of an entity and include a wide range of activities, such as approvals, 

authorizations, verifications, reconciliations, performance reviews, and the creation and 

maintenance of related records which provide evidence of execution of these activities as 

well as appropriate documentation. Examples of control activities/techniques include top 

level reviews of actual performance and reviews by management at the functional or activity 

leveL 

In addition, internal controls should be designed to assure that ongoing monitoring occurs in 

the course of normal operations. It should be performed continually and ingrained in the 

agency's operations. 

Ifrecord sources are not reviewed and validated, there is an increased risk that future record 

searches may not be conducted or the information reported may be inaccurate. 

22 

Recommendation 15 

We recommend that FIS develop and implement internal controls to ensure that at least 10 

reviews of record checks per quarter per Investigative Assistant are completed to validate 

that the search was conducted and that the record information reported is accurate. 

FIS'Response: 

FIS concurs with this recommendation and stated that "The Centralized Leads unit has 

developed and implemented the recommended internal controls. In addition, we are planning 

this FY to include the review results in the unit's database to allow automated analysis of 

problems/trends. During the first qum1er of FY20 1 0, our random review efforts have 

improved greatly. The required audit will exceed the requested 10 checks per quarter (per 

IA) as recommended." 

4. Re-Contact of Personal Sources by Contractors 

CACI and KGS did not conduct the required amount of re-contacts for all new Investigators 

that we sampled. In addition, for CACI we were unable to determine whether the re-contacts 

that were performed were completed within 60 calendar days of the initial contact. 

For the period of May 1 through 31, 2009, we selected 25 out of 68 new CACI Investigators 

and 25 out of 299 new KGS Investigators. We reviewed re-contact documentation to 

determine whether CAeI and KGS performed personal source re-contacts for each of the 

Investigators in accordance with contract provisions. The results of our review disclosed that 

seven of the CACI and five ofthe KGS Investigators had not received the appropriate 

number of re-contacts. Details about the Investigators were provided to FIS separate from 

this report. 

The re-contacts were not completed by CACI's Quality Assurance Department due to the 

following reasons: 

• 	 Three re-contacts were not performed because two Investigators did not turn in 

their Source Listing Sheets; 

• 	 One re-contact was not performed because the source only spoke Spanish~ and 

• 	 Four re-contacts for four Investigators were not performed because QA did not 

complete them. 

We were unable to determine if re-contacts were made within 60 calendar days ofthe initial 

source interview because neither the Personnel Investigations Processing System nor CACI's 

iTRAX system (CACl's primary case management tool) tracks the dates of when initial 

source interviews are conducted. 

KGS' system only generates a re-contact when at least 34 sources are interviewed per 

investigator per year. KGS explained that doing one re-contact out of a sample of 26 source 

interviews would be asking too much since it is over three percent. 

23 
FIS Fieldwork Contract Quality Assurance Provisions Applicable to CAe! and Kroll 

<KGS> (OPM040600012, OPM040600011)jieldwork contracts, section C.6.1.5, states that 

"The Contractor shall conduct re~contacts of personal sources by mail, telephone, or in 

person on a random sampling basis. During the first year of the investigator's employment 

the contact will be done telephonically. Randomly, on an annual basis, no less than three (3) 

percent of all personal sources obtained by each investigative personnel shall be re-contacted 

within 60 calendar days of the initial contact." . 

Not completing the required re-contacts for each Investigator during their first year of 

employment increases the risk that CACI and KGS will not be able to ensure the new 

Background Investigator is efficient and capable and/or reveal any weaknesses that may 

compromise their background investigations. 

Recommendation 16 

We recommend that FIS require CACI to strengthen their internal controls to ensure that 

during the first year of the Investigator's employment CACI randomly contacts no less than 

three percent of all personal sources obtained by each investigative personnel within 60 

calendar days of the initial contact. 

Recommendation 17 

We recommend that FIS require KGS to strengthen its policy/procedures over their recontact program to ensure that at least one re-contact is performed during the first year of the 

Investigator's employment. The re-contact programs should be conducted within 60 calendar 

days of the initial interview and should be no less than three percent of all personal sources 

obtained by each Investigator. 

FIS'Response: 

FIS concurs with these recommendations and stated that "In response to the sample taken and 

referenced in the 010 letter of 12122/09, FIS asserts the foHowing: The requirement for the 

3% re-contact of all personal sources is based on a yearly requirement. A sampling taken 

during a portion ofthe year is not an adequate sampling method. To further ensure 

compliance is met for the year, FIS will conduct unannounced inspections to verify 

compliance. " 

5. Re-Contact of Personal Sources by FIS 

FIS did not conduct the required 3 re-contacts for It of the 80 Investigators we sampled. 

Details regarding the Investigators that did not receive the required three re-contacts per 

month were provided to FIS separate from this repo11. 

We judgmentally sampled 80 out of 4,831 Investigators from both FIS and the Contractors. 

Our sample consisted of 10 new and 10 experienced Investigators from FIS and each of the 3 

24 
Contractors. For the period of May I through 31,2009, we reviewed re-contact 

documentation to determine whether FrS performed personal source re-contacts for each of 

the 80 Investigators. 

Re-contacts for seven Investigators were not performed because a database problem excluded 

all Investigators with a staff identification starting with the letter "W". FIS stated that the 

problem was not identified until we selected the sample and that it was localized to new 

Investigators. Re-contact letters for three Investigators were not perfonned because the 

database excludes all Investigators that did not complete the zip code field within the 

database. Lastly, no specific reason could be identified as to why a re-contact letter was not 

sent for one Investigator; however, FIS believes it may be due to an anomaly resulting from 

database modifications. 

FIS' Personnel Source Re-Contact Program includes conducting at least three source recontacts per Investigator (both Federal and Contractor) per month. 

OMB Circular A-123 (Introduction) indicates that "Management has a fundamental 

responsibility to develop and maintain effective internal controL The proper stewardship of 

Federal resources is an essential responsibility of agency managers and staff. Federal 

employees must ensure that Federal programs operate and Federal resources are used 

efficiently and effectively to achieve desired objectives." 

GAO's Standards for Internal Control in the Federal Government state that management is 

responsible for developing control activities, which are the policies, procedures, techniques 

and mechanisms that enforce management's directives. Control activities occur at all levels 

and functions of an entity and include a wide range of activities, such as approvals, 

authorizations, verifications, reconciliations, performance reviews, maintenance of security, 

and the creation and maintenance of related records which provide evidence of execution of 

these activities, as well as appropriate documentation. 

In addition, internal controls should be designed to assure that ongoing monitoring occurs in 

the course of normal operations. It should be performed continually and ingrained in the 

agency's operations. 

Not completing the required re-contacts for each Investigator results in an increased risk that 

FrS will not be able to ensure the Investigator is efficient, capable, and/or identifies any 

weaknesses that may compromise background investigations. 

Recommendation 18 

We recommend that FIS strengthen their internal controls over their re-contact program to 

ensure that they complete the required number of re-contacts per Investigator each month. 

25 

FIS' Response: 

"FIS concurs with this recommendation" and stated that they have "implemented an audit of 

the information generated from tp.e re-contact letter database to ensure that the required 

numbers of re-contact letters are sent per investigator on a monthly basis. . .. The results of 

each monthly audit are filed and maintained by Investigations Support, .. ," 

26 

Auditor 

Audi tor-in-Charge 

IV. MAJOR CONTRIBUTORS TO THIS REPORT 


Internal Audits Group 

Senior Team Leader 

••••••Chief 

27 

[January 22,2010] APPENDIX 

MEMORANDUM FOR 


Chief, Internal Audits Group 

FROM KATHYL. DILLAMAN 

Associate Director 

Federal Investigative Services 

SUBJECT: Draft Report on the Audit of the Quality Assurance Process over 

Background Investigations. 

Report No. 4A-IS-00-09-060 

The Federal Investigative Service (FIS) has reviewed the draft audit report of the Quality 

Assurance Process over Background Investigations and we concur with the findings and 

recommendations (except as otherwise noted) identified in the report. FIS is responsible for 

resolving the issues raised and implementing the recommendations provided in this audit. The 

response to the recommendations and an action plan (when applicable) are included as indicated. 

We recognize that even the best performing programs benefit from an independent external 

evaluation and we appreciate the input of the Office of the Inspector General in an effort to 

ensure the effectiveness and efficiency of our Quality Assurance Process over Background 

Investigations. We will use your recommendations as part of our on-going effort and focus to 

improve our program and operations. 

Recommendation 1: 

We recommend that FIS implement a standardized universal training program that is required to 

be used by FIS and its Contractors for all personnel who perform work completing background 

investigations (i.e. Investigators, reviewers and personnel completing records checks). 

FIS Management Response 

FIS concurs with this recommendation. The current field contracts do not require the contractors 

to have their investigators training conducted by OPM. They are responsible for conducting 

their own training. However, their training plans must be approved by OPM in advance and their 

curriculum must be based on OPM's Investigator's Handbook. OPM/FrS staffregularly audits 

contractor-conducted training classes. When the new contracts are awarded in 2011, FrS will 

mandate that all companies doing investigative work on behalf of OPM send their investigators 

to training classes conducted by OPM. In the interim, contractor companies can voluntarily send 

their investigators to the OPM Basic Investigators course. To date, OPM/FIS has provided the 
full training course to four CACI investigators, and investigators/staff from USIS and CACI have 

monitored the course. 

Necessary modifications have been ~ade to training materials to ensure that they are suitable for 

Federal and contractor field agents. With the issuance of new field contractors in 2011, FIS 

Training and Professional Development (TPD) will have adequate capacity to provide training to 

all field agent staff (Federal and contractor) that supports OPM's investigations program. 

Recommendation 2: 

We recommend that Frs implement Quality Case review program throughout all ofthe regions. 

FIS Management Response 

FIS concurs with this recommendation. All regions have been provided with the standard review 

tools and tracking system developed by the Northern Region. FlS is reviewing this process to 

make additional changes and will continue to refine this tool as we move forward. All regions 

have received training on the automated tool that will allow standard tracking of reviewed cases 

throughout the Federal field. Full implementation is expected by the end of January 2010. 

Recommendation 3: 

We recommend that FIS implement the use of an annual Integrity Statement for its employees 

and Contractors to assist in any possible falsification cases. 

FIS Management Response 

FIS cannot concur with this recommendation until the legality of such a statement is determined 

by OPM's Office of General Counsel (OGC). We will present this issue to OGC for an opinion 

before developing an action plan. 

Recommendation 4: 

We recommend that FrS resume the random case review process and ensure that internal controls 

are designed to assure that ongoing monitoring occurs in the course of normal operations. 

FIS Management Response 

FIS concurs with this recommendation and has resumed random review as of January 8, 2010. It 

should be noted that the random review process was only temporarily suspended in order to 

develop a training refresher course based on the findings of the year-long random review pilot. 

Recommendation 5= 

We recommend that FIS design internal controls to ensure that ongoing monitoring of the CAST 

occur during the normal course of operations. 
FIS Management Response 

FIS concurs with this recommendation. The internal control of Quality Management auditing the 

contractor-conducted CAST process, on a quarterly basis, will remain in effect until the function 

is moved to the Federal staff. The most recent audit was completed on October 9, 2009 for the 

first quarter of Fiscal Year 2010. QMG is in the process of scheduling an audit for the current 

quarter. Once the function moves to the Federal staff, Quality Management will audit this 

function as part of its random review process (daily basis). 

Recommendation 6: 

We recommend that FIS require USIS and KGS to provide an OPM approved training course to 

all employees who perform record checks. 

FIS Management Response 

FIS concurs with this recommendation. FlS is currently working with USIS and KGS on an 

approved training course with an anticipated implementation date of March 1, 2010 

Recommendation 7: 

We recommend that FIS have all mentors complete a mentor training course prior to them 

serving as a mentor to the Investigators. 

FIS Management Response 

FIS concurs with this recommendation. A standard mentor training course will be in place by 

March 1, 2010, and all new mentors will be required to successfully complete the training before 

serving as a mentor. 

Recommendation 8: 

We recommend that FIS require KGS, and USIS to provide documentation to support that the 

investigators have completed all qualifications necessary in order to perform background 

investigation on behalf of FIS. 

FIS Management Response 

FIS concurs with the recommendation of having the contractors provide documentation to 

support the investigators qualifications. In accordance with Attachment A and Section H.16 of 

the contract, the contractor is required to maintain documentation regarding the investigator's 

qualifications. OPM will conduct inspections to ensure that the contractor's are maintaining the 

qualifications as outlined in the contract. 
Recommendation 9: 

We recommend that FIS instruct USIS to update its Check-Ride Standards/Field Quality 

Assurance Policy to include a define,d timeframe as to when USIS must conduct check rides for 

their new investigators once they have completed their field training. 

FIS Management Response 

FIS concurs with this recommendation. FIS will instruct US IS to review their internal check-ride 

policy and make a determination on a defined timeframe. 

Recommendation 10: 

We recommend that FIS ensure that all Investigators receive at least one supervisory check-ride 

assessment per appraisal period. 

FIS Management Response 

FIS has complied with this recommendation, In the case of <DELETED BY OPM-OIG, NOT 

RELEVANT TO THE AUDIT REPORT>, she was promoted to an Agent on April 12,2009 

from an Investigative Assistant position. Prior to becoming an agent there would have been no 

requirement or need for her to attend the BIC. She completed the BIC on 1012312009. Prior to 

that she would have been in training and assigned a mentor. The documentation for the other six 

agents is attached showing they had a check ride conducted or were in training. FIS did meet all 

requirements for each agent. 

Recommendation 11: 

We recommend that FIS require CACI to implement controls to ensure that the results of 

evaluations conducted under CACI's evaluation program are documented and forwarded to the 

COR within 30 days ofthe date of evaluation. 

FIS Management Response 

FIS does not concur with this recommendation. CACI has an established evaluation program. 

CAeI submitted their evaluations on January 8,2010 (attached), and will submit their 

evaluations no later than 30 days after the end of the rating period for future submissions. FIS 

has incorporated a review and validation of the report as part of the workload goals and FrS will 

conduct inspections for all contractors throughout the year to ensure compliance, 

Recommendation 12: 

We recommend that FIS issue guidance to clearly explain what is expected from the Contractors. 
FIS Management Response 

FIS concurs with this recommendation. FIS will immediately issue clarification to the contractor 

as to what is required to be submitted in accordance with the contract section C.6.1.8 and 

attachment 4. ' 

Recommendation 13: 

We recommend that FIS requires USIS to establish procedures to ensure that misconduct issues 

are documented and reported to OPM within the timeliness standards outlined in the contract and 

USIS policy. 

FIS Management Response 

Frs concurs with this recommendation. FIS will require USIS to adhere to the time frame in 

section C.ll.06, Section H.3, and Section B.7 once a misconduct issue is identified. 

Recommendation 14: 

We recommend that FIS require the Contractors to develop and implement internal controls to 

ensure that at least two record sources per quarter per investigators are randomly recontacted to 

validate the fact that the search was conducted and the accuracy ofthe record information 

obtained. Internal controls should include a requirement for KGS to maintain documentation to 

support the completion ofthe re-contacts. 

FIS Management Response 

FIS concurs with this recommendation. As outlined in Section C.6.1.S, the contractors are 

required to conduct and maintain documentation on the record source re-contacts. FIS will 

conduct inspections throughout the year to ensure contractor compliance. 

Recommendation 15: 

We recommend that Frs develop and implement internal controls to ensure that at least ten 

reviews of record checks per quarter per Investigative Assistant are completed to validate that the 

search was conducted and that the record information reported is accurate. 

FIS Management Response 

FIS concurs with this recommendation. The Centralized Leads unit has developed and 

implemented the recommended internal controls. In addition, we are planning this FY to include 

the review results in the unit's database to allow automated analysis of problems/trends. During 

the first quarter of FY20 1 0, our random review efforts have improved greatly. The required 

audit will exceed the requested 10 checks per quarter (per IA) as recommended. 

The field contracts do not state when during the year or how often source re-contacts be 

conducted. The contracts only specify that 3% of all sources interviewed by an investigator be 
re-contacted. Contracting can make a recommendation to the contractors that they spread the recontacts throughout the year. 

Recommendation 16: 

We recommend that FIS require CACI to strengthen their internal controls to ensure that during 

the first year of the investigator's employment, CAeI randomly contacts no less than three 

percent of all personal sources obtained by each investigative personnel within 60 calendar days 

of the initial contact. 

FIS Management Response 

FIS concurs with this recommendation presented above. 

In response to the sample taken and referenced in the OIG letter of 12122/09, FIS asserts the 

following: The requirement for the 3% re-contact of all personal sources is based on a yearly 

requirement. A sampling taken during a portion of the year is not an adequate sampling method. 

To further ensure compliance is met for the year, FIS will conduct unannounced inspections to 

. verify compliance. 

Recommendation 17: 

We recommend that FIS require KGS to strengthen its policy/procedures over their re-contact 

program to ensure that at least one re-contact is perfonned during the first year of the 

investigator's employment. The re-contact programs should be conducted within 60 calendar 

days of the initial interview and should be no less than three percent of all personal sources 

obtained by each investigator. 

FIS Management Response 

FIS concurs with this recommendation presented above. 

In response to the sample taken and referenced in the OIG letter of 12122/09, FIS asserts the 

following: The requirement for the 3% re-contact of all personal sources is based on a yearly 

requirement. A sampling taken during a portion of the year is not an adequate sampling method. 

To further ensure compliance is met for the year, FIS will conduct unannounced inspections to 

verify compliance. 

Recommendation 18: 

We recommend that frS strengthen their internal controls over their re-contact program to ensure 

that they complete the required number of re-contacts per Investigator each month. 
FIS Management Response 

FrS concurs with this recommendation. FIS has implemented an audit of the information 

generated from the re-contact letter database to ensure that the required numbers of re-contact 

letters are sent per investigator on a monthly basis. Investigations Support personnel perform a 

monthly database query that compares the number of sources interviewed by each investigator to 

the number of re-contact letters sent. In instances where less than three letters are sent, an 

analysis is performed to determine the reason. The reason may be legitimate (e.g., the sallie 

source interview was transmitted several times, the same source received a re-contact letter the 

previous year, an address field was blank, etc.) or the issue may require further research to 

determine if there is a database problem. In either case, the issue receives irmnediate attention 

and when possible, additional re-contact letters are sent as appropriate. The results of each 

monthly audit are filed and maintained by Investigations Support and include the following 

information: 

o Number of instances where Less than three letters were sent 

o Appropriate case numbers and investigator SIOs 

o Reason(s) Less than three letters were generated per investigator