Audit Division 12-044 March 2020

Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the United States Marshals 

Service’s Administration of Joint 

Law Enforcement Operation Funds
i

Executive Summary

Audit of the United States Marshals Service’s Administration of Joint Law 

Enforcement Operation Funds

Objective

The objectives of this audit were to assess whether the 

United States Marshals Service (USMS): (1) has proper 

controls for Joint Law Enforcement Operations (JLEO)

funds reimbursement, and (2) reimburses state and 

local law enforcement agencies for allowable and 

supported costs.

Results in Brief

We found that the USMS generally had adequate internal 

controls to ensure it used JLEO funds for appropriate 

expenses, and that it made additional improvements to 

those controls during and after our audit. However, we 

found that controls for overtime reimbursement should 

be strengthened, as the USMS processed approximately 

$2.2 million overtime reimbursements to state and local 

agencies despite lacking either the support or the 

authorization required by USMS policy. Of this amount, 

we specifically questioned $508,720 in reimbursements 

to state and local agencies for which the underlying 

documentation did not support the reimbursement 

request. We also identified a lack of controls over 

handwritten changes to timesheets and the 

determination of overtime rates. In addition, we had 

concerns regarding USMS controls over vehicle 

purchases. From fiscal years (FY) 2012 through 2016, 

the USMS purchased 1,609 vehicles for approximately 

$53.9 million and immediately titled the vehicles to state 

and local law enforcement agencies for joint operations 

so long as needed. When no longer needed, the 

vehicles should have been returned to the USMS for 

disposition. However, we determined that the vehicles 

remained in the possession of state and local agencies, 

and the USMS was unable to determine that all

purchased vehicles were being used for task force 

operations. Beginning in FY 2017, the USMS ceased 

purchasing vehicles and began to lease vehicles.

Recommendations

This report makes five recommendations to improve the 

USMS’s administration over JLEO funds.

Audit Results

JLEO funds are used to reimburse state and local law 

enforcement for costs incurred during law enforcement 

operations with federal law enforcement agencies. 

Allowable uses of JLEO funds include overtime, travel, 

fuel, training, and equipment. From October 2015 to 

August 2019, the USMS expended $97.5 million in JLEO 

funds, primarily for overtime reimbursements.

We evaluated JLEO policy and determined whether the 

USMS complied with the policy when administering JLEO 

funds at its Headquarters, 24 district task forces, and 

7 regional task force levels.

Overtime Testing Compliance – We found that the 

USMS did not always comply with its policy when 

reimbursing state and local law enforcement agencies 

for overtime. The USMS approved overtime 

reimbursements to agencies totaling $508,720 that were 

not fully supported. An additional $1.7 million in

overtime reimbursement was approved even though the 

support provided to justify the reimbursement requests 

lacked the required supervisory approval. We also found 

that timesheets had hand-written changes without 

indication of who made the change or why it occurred. 

These changes increase the risk of fraud because 

timesheets could be manipulated. We also found that 

the method for calculating the overtime rate for task 

force officers was inconsistent among participating state 

and local law enforcement agencies.

Vehicle Purchases – Prior to FY 2017, the USMS 

purchased vehicles and immediately titled the vehicles 

to participating state or local law enforcement agencies. 

During FYs 2012 through 2016, the USMS purchased 

with JLEO funds 1,609 vehicles for approximately $53.9 

million. Department of Justice (DOJ) policy requires that 

vehicles must be available to the task force as long as 

the task force is in existence, yet at the time of our 

audit the USMS could not determine whether all 

purchased vehicles were still in use for task force 

operations or whether the state and local law enforcement

agencies had properly returned the vehicles to the USMS 

for disposition. In FY 2017, the DOJ’s Asset Forfeiture 

Management Staff no longer permitted the USMS to 

purchase vehicles.
p 

AUDIT OF THE UNITED STATES MARSHALS SERVICE’S

ADMINISTRATION OF JOINT LAW ENFORCEMENT OPERATION 

FUNDS

TABLE OF CONTENTS

INTRODUCTION .............................................................................................1

Background..........................................................................................1

Office of the Inspector General Audit Approach.........................................3

AUDIT RESULTS.............................................................................................5

The USMS Should Strengthen its Internal Controls over JLEO Funding ......... 5

Testing of Task Force Officer Overtime Reimbursements ................... 5

USMS Vehicle Purchases for Task Force Officers............................... 9

AFMS Testing of Circuit Costs ...................................................... 10

Testing of Other Non-Overtime Expenditures................................. 11

CONCLUSION AND RECOMMENDATIONS......................................................... 12

STATEMENT ON INTERNAL CONTROLS............................................................ 13

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS.......................... 14

APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY ................................. 15

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS................................ 18

APPENDIX 3: REIMBURSEMENT TESTING RESULTS FOR DISTRICT AND 

REGIONAL TASK FORCES..................................................................... 19

APPENDIX 4: USMS RESPONSE TO THE DRAFT REPORT................................... 20

APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT................................... 22
1

INTRODUCTION

Joint Law Enforcement Operations (JLEO) funds are used to reimburse costs 

that state and local law enforcement officers incur during joint law enforcement 

operations with federal law enforcement agencies. Allowable uses of JLEO funds 

include law enforcement overtime, travel, fuel, training, equipment, and other 

similar costs. We initiated this audit to review the United States Marshals Service

(USMS) internal controls over these funds and determine whether weaknesses exist 

in the design and implementation of established controls.

Background

The law and Department of Justice (DOJ) policy govern the use of JLEO 

funds. 28 U.S.C. § 524 (c)(1)(I) provides that the Assets Forfeiture Fund (AFF) 

may be used for payments of overtime salaries, travel, fuel, training, equipment, 

and other similar costs incurred by state or local law enforcement officers in joint 

law enforcement operations with federal agencies. The DOJ established further 

guidance for the use of JLEO funds in a July 1, 1997, memorandum from Assistant 

Attorney General for Administration (1997 Guidance). This memorandum, which 

remained in effect as of August 2019, provides specific guidance on allowable JLEO 

costs.1 The JMD’s Asset Forfeiture Management Staff (AFMS) provides 

administrative management and oversight of the AFF, including review and 

evaluation of all program activities funded through the AFF. AFMS also manages 

budgeting, financial management, and contracting operations related to the AFF.

The USMS also provides annual internal guidance for the JLEO program to its 

56 district and 8 regional task forces across the country.2 In some years, the USMS 

guidance outlined allocation funding levels for each district and regional task forces 

and provided step-by-step accounting procedures for the use of JLEO funds in its 

internal guidance.

As of August 22, 2019, the USMS had expended approximately $97.5 million 

in JLEO funds since October 1, 2015. The USMS distributed JLEO funds to its 

district task forces, regional task forces, and its Headquarters. Figure 1 reflects the 

expenditures of JLEO funds to task forces and USMS Headquarters from FY 2016

through fiscal year (FY) 2019.

 

1 As of August 2019, the DOJ was developing a new Asset Forfeiture Manual that would 

supersede the 1997 Guidance.

2 USMS has 94 judicial districts, 59 of which received JLEO funding from FY 2016 to FY 2018. 

After the initiation of the audit and our transaction sample selection, the USMS created the Carolinas 

Regional Fugitive Task Force, resulting in a total of 56 district and 8 regional task forces that are 

eligible to receive JLEO funding.
2

Figure 1

Expenditures of JLEO Funds for FYs 2016 through 2019

Note: The data reflects JLEO expenditures as of October 2019.

Source: USMS Data

The USMS allocated approximately 69 percent of JLEO funds for overtime 

costs. District and regional task forces used the majority of these funds to 

reimburse state and local law enforcement officials for officer overtime incurred on 

task force operations. USMS Headquarters received approximately 31 percent of 

the funds, which are primarily used for other non-overtime JLEO program areas 

such as training and database access.3 Table 1 shows the funding allocations from 

FY 2016 through FY 2019.

 

3 Headquarters expenditures declined after FY 2016 in part because the USMS ceased 

purchasing vehicles and began to lease vehicles.

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

FY 2016 FY 2017 FY 2018 FY 2019

District Task Forces Regional Task Forces USMS Headquarters
3

Table 1

Initial Spending Allocation among Categories for

FYs 2016 through 2019 of JLEO Funds

Category FY 2016* FY 2017 FY 2018 FY 2019

Overtime - $23,525,000 $23,210,000 $23,558,000

Circuit Costs - 4,160,000 4,160,000 3,619,000

Commercial Database - 1,890,000 1,915,000 1,993,000

Vehicle Lease and Retrofitting - 2,350,000 2,950,000 5,900,000

Contract Support - 0 200,000 200,000

Training - 600,000 600,000 600,000

Background Investigation - 250,000 250,000 250,000

Total $32,500,000 $32,775,000 $33,285,000 $36,120,000

Note: Retrofitting is the modification of vehicles by installing policing equipment. Because JMD’s 

FY 2016 Funding Instructions did not allocate JLEO funds by category, we were unable to obtain 

initial allocations among categories for FY 2016.

Source: FYs 2016, 2017, 2018, and 2019 JMD Funding Instructions to the USMS

As shown in Table 1, the USMS uses the majority of its JLEO funds to 

reimburse state and local agencies for overtime worked by officers assigned to 

task force operations. Prior to reimbursing agencies, the USMS allocates JLEO 

funds to its district and regional task forces. The allocation to district task forces is 

based on each district’s crime statistics, and state and local warrants eligible for 

USMS adoption. To make the allocations, the USMS uses the data from the 

Federal Bureau of Investigation’s Uniform Crime Reports, the National Crime 

Information Center wanted persons file, and from the Justice Detainee Information 

System.4

The allocations to regional task forces were based on the previous year’s 

allocation to each task force. USMS officials told us that no record was available to 

support how the regional task force allocations were originally established. As of 

August 2019, USMS officials were reconsidering the basis for the regional task 

force allocations so that a newly established regional task force could be allocated 

a share of available funds.

Office of the Inspector General Audit Approach

The objectives of this audit were to assess whether the USMS: (1) has 

proper controls for JLEO funds reimbursement and (2) reimburses state and local 

law enforcement for allowable and supported costs. The scope of our audit was

generally fiscal years (FYs) 2016 through 2018.

To accomplish our objectives, we reviewed policies and procedures, as well 

as JLEO transactions. We conducted site visits at USMS Headquarters in Arlington, 

 

4 The Justice Detainee Information System is a central database that has complete prisoner 

records of all prisoners who are in custody or have a federal warrant issued or are scheduled for a 

move.
4

Virginia and the Southeast Regional Fugitive Task Force in Atlanta, Georgia. We

determined that transactions from task forces and USMS Headquarters could be 

readily assessed by having the USMS provide support documentation for those 

transactions to our office. As a result, we selected JLEO transactions from USMS 

Headquarters, 24 district task forces, and 7 regional task forces. In total, we 

reviewed transactions totaling $10.1 million from USMS Headquarters, $3 million 

from district task forces, and $5.4 million from regional task forces.

The Audit Results section of this report discusses the effectiveness of policies 

and procedures and compliance with established policies. See Appendix 1 for 

further discussion of the audit objectives, scope, and methodology.
5

AUDIT RESULTS

The USMS Should Strengthen its Internal Controls over JLEO Funding

We found that the USMS generally had adequate internal controls in place to 

ensure it used JLEO funds for appropriate expenses. However, we found that 

controls for overtime reimbursement should be strengthened. The USMS processed 

overtime reimbursements to state and local agencies without proper support or 

authorization as required by USMS policy. We also identified a lack of controls over 

handwritten changes to timesheets and the determination of overtime rates. In 

addition, the USMS was unable to determine that purchased vehicles were being 

used for task force operations. These problems reduce the USMS’s accountability 

for JLEO funds. The results of our testing are discussed in detail below.

Testing of Task Force Officer Overtime Reimbursements

District and Regional Task Force Testing

From FY 2016 through FY 2018, the USMS reimbursed state and local law 

enforcement agencies approximately $61 million for overtime paid to task force 

officers. The USMS’s internal JLEO program guidance requires that district and 

regional task force supervisors review timesheets for task force officers, approve or 

return rejected timesheets for correction, and retain timesheets for use in verifying 

agency requests for reimbursement. Task force officers must document the hours 

that they work and submit the timesheets each month to a task force supervisor. 

The USMS provided a timesheet template for use by task force officers. The 

template included a section for a supervisor signature, but some participating 

officers submitted the timesheets of their home agency, some of which did not 

require a supervisory signature.

State and local agencies periodically submit to the task force a 

reimbursement request consisting of an invoice that shows the number of hours 

each participating officer worked. Each agency submits reimbursement requests 

either monthly or quarterly at its discretion. Upon receipt by the task force, the 

reimbursement requests are required to be compared by a task force supervisor to 

the timesheets previously submitted by the participating officers. If the timesheets 

do not correspond to the invoice, the invoice is returned to the submitting agency 

for correction. If the documents and timesheets do correspond, the supervisor 

signs the reimbursement request to approve payment.

We reviewed reimbursements totaling $8.4 million made to state and local 

law enforcement agencies whose officers worked on fugitive task forces. Our 

samples included $3 million reimbursed to 62 agencies by 24 district task forces 

and $5.4 million reimbursed to 45 agencies by 7 regional task forces. We tested 11 

percent of the JLEO funds allocated to district task forces during FYs 2016 through 

2018 and 15 percent of the JLEO funds allocated to regional task forces for the 

same period.
6

For the $8.4 million in reimbursement requests we tested, the USMS 

reimbursed state and local agencies $508,720 for unsupported overtime. We 

identified two types of missing support. For $369,398 of reimbursement paid, 

officer time was not supported by timesheets. For $139,322 of reimbursement 

paid, hours included in the reimbursement requests were supported by timesheets 

with fewer approved overtime hours than those included in the reimbursement 

request. We detail the unsupported costs resulting from our overtime testing for 

each of the district and regional task forces in Appendix 3.

We also determined that the USMS reimbursed state and local agencies 

$1,693,037 for overtime for which there was no evidence that a task force 

supervisor approved the timesheets supporting the reimbursement requests. As 

demonstrated in Appendix 3, the lack of supervisor approved timesheets occurred 

to a greater extent among the regional task forces than it did among the district 

task forces.

Errors associated with unsupported and improperly authorized overtime 

combined totaled approximately $2,201,757 of the $8.4 million in reimbursement 

requests we tested. However, $11,237 in transactions we tested were identified as 

having both types of errors and the dollar value of those transactions is included 

twice in the $2,201,757 calculation. When the duplicate costs are removed, the 

dollar value of errors associated with both transactions is reduced to $2,190,520.

We provided the USMS with details regarding reimbursement requests that 

we found to be unsupported and timesheets not signed by a task force supervisor, 

and we requested any available additional support. In response, the USMS 

provided no additional documentation and told us that administrative errors and 

“careless mistakes” occurred throughout the year causing the problems we 

identified. We consider the $508,720 in unsupported reimbursements to be 

questioned costs and recommend that the USMS remedy the questioned costs. We 

do not question the reimbursements associated with missing supervisor signatures 

insofar as the unsigned timesheets otherwise supported the reimbursement 

requested.

During the period we tested, the USMS implemented improvements to its

internal controls in an effort to better ensure that reimbursements are properly 

supported and approved.

• In FY 2017, the USMS’s Investigative Operation Division (IOD)

incorporated periodic assessments of district and regional task force 

processes used to manage JLEO funds received for task force officer 

overtime reimbursements. The assessment includes reviewing a sample 

of timesheets and invoices to determine any discrepancies, ensuring that 

there are adequate support and approval of reimbursements, and other

quality control areas. As of August 2019, the IOD had conducted 

assessments at five district task forces and one regional task force, which 

were randomly selected. The IOD concluded that each of the six task 

forces generally used JLEO funds properly. The IOD provided each task 

force a summary of findings, notes describing discrepancies between 
7

practice and policy, and recommendations to address concerns. We 

reviewed each assessment and believe that the assessments adequately 

covered most of the areas of concern described in this section. However, 

in more than 2 years the IOD had assessed only 6 of the 64 task forces. 

Even at its targeted pace of assessing 3 to 4 district offices and 1 regional 

office each year, the district offices will be assessed only once every 14 

years at best, and regional offices will be assessed only once every 8 

years. USMS officials told us that the results of the reviews are shared 

with the task force reviewed but are not shared more broadly with other 

task forces.

• At the beginning of FY 2018 the USMS implemented a standard invoice 

that includes fields for officer name, base and overtime rate, number of 

overtime hours worked, and total amount. USMS officials told us that the 

standard invoice has four layers of review including representatives from 

both the participating agency and the USMS before processing the 

reimbursement.

• At the beginning of FY 2019, the USMS implemented a standard 

timesheet that includes fields for date, start and end time, regular hours 

worked, overtime hours worked at either the base or one and a half times 

the base salary, and the case identification. The new form requires both 

the task force officer and supervisor’s signature.

We sought to assess the effectiveness of these internal control improvements

in two ways.

First, we tested a sample of FY 2018 reimbursements made by the Southeast 

Regional Fugitive Task Force, which had implemented the use of the standard 

invoice and timesheet for that year. We found no issues except that the USMS 

reimbursed one local law enforcement agency without supporting timesheets. The 

USMS staff who reviewed the reimbursement stated that timesheets were not 

submitted because a supervisor was at the location with the task force, verified the 

task force officers worked the overtime, and thus did not believe timesheets were 

needed. However, the USMS appropriately requires the use of timesheets to support

reimbursement requests. For this one reimbursement, USMS officials subsequently 

obtained the supporting timesheets based on our request that they do so.

Second, for our sample transactions, we compared error rates for FYs 2016 

and 2017 to the error rates for FY 2018, which was the year the new internal 

controls became effective. For each time period, we calculated the combined error 

rate for both insufficient support and lack of supervisory signatures. We calculated 

separate error rates for district and regional task forces.5 For district task forces in 

FYs 2016 and 2017, 27 percent ($428,273) of the dollar value associated with the 

reimbursements we tested was unsupported while in FY 2018 only 4 percent 

($60,053) of the dollar value tested was unsupported. We recalculated the district 

task force rates after removing errors for the Eastern District of Pennsylvania, 

which lacked support for nearly all of its reimbursements and was an outlier among 

 

5 We calculated the error rates after we removed duplicated costs.
8

the districts tested. With this adjustment, the error rates dropped to 11 percent 

($138,539) of the dollar value of reimbursements tested for FYs 2016 and 2017 and

3 percent ($41,384) of the dollar value tested for FY 2018. For regional task forces 

in FYs 2016 and 2017, 32 percent ($1.2 million) of the dollar value associated with

the reimbursements we tested was unsupported. In FY 2018, 37 percent 

($497,000) of the dollar value was unsupported.

Because we employed a risk-based non-statistical sample design, our results

cannot be projected to the universe of reimbursements and the error rates for the 

universe may be different. Our results indicate that the internal control

improvements implemented in 2018 may have reduced the errors for that year, 

particularly for the district task forces. However, the results also demonstrate that 

further improvement to the internal controls are needed to minimize and correct 

errors, which will reduce the potential for misuse or abuse of JLEO funds. We 

recommend that the USMS strengthen its monitoring of task forces by establishing 

a schedule sufficient to ensure that each task force is periodically reviewed within 

reasonable timeframes for compliance with JLEO requirements. This monitoring 

could be accomplished remotely, thus reducing the cost and time of the monitoring 

effort. We also recommend that the USMS share with all task forces any 

information developed during its monitoring assessments—such as best practices or 

issues of common concern—that could assist the task forces in ensuring compliance

with JLEO requirements.

Controls over Obligation and Invoice Documents

The USMS’s internal JLEO guidance states that each task force should 

prepare an obligation document, USM-607, and if necessary an obligation

modification document, USM-607A. Each task force completes the obligation 

document prior to receiving its JLEO obligation, and then submits a modification for 

any adjustments needed to the obligation. The USMS JLEO guidance also states 

that the document must be filled out in its entirety and include all required 

signatures. The USMS also requires agencies to use a standard invoice, USM-607B, 

for each monthly or quarterly request for reimbursement, which must be approved 

by both agency and USMS officials.

During our task force testing of overtime, we found the task forces did not 

fully complete 90 of 212 obligation or modification documents we tested, and 15 of 

328 invoice documents we tested. The missing information included the description

of the obligation or modification of the obligation, contact information for the task 

force and the state and local participating agencies, and signatures for state and 

local agency acknowledgements of the amount of JLEO funds available for use. 

USMS officials again attributed these problems to administrative errors and 

“careless mistakes.” The USMS JLEO guidance provides that a valid obligation

document must be filled out in its entirety and include all required signatures. 

These documents are included in the review process discussed above for district 

and regional task forces. We believe that our recommended improvement to that 

process will identify and help prevent errors with the obligation documents.
9

Controls over Timesheets

During our testing of overtime reimbursements, we found timesheets that 

had irregular handwritten changes such as insertion of overtime hours without 

indication of who made the changes. For example, five task force officers from one 

local agency had 1 to 2 hours of overtime inserted in their timesheets, coinciding 

with the last few days of the fiscal year when the obligation expired. Because of 

these insertions, the local agency incurred overtime costs equal to its full obligation 

of JLEO funds. Although these timesheets and the invoice were properly approved, 

the timesheets did not have an explanation for when, why, and who made the 

changes. Such changes to timesheets weaken the assurance that a task force 

officer worked the overtime hours, thus increasing the risk of mismanagement of 

funds. Therefore, we recommend that the USMS develop a policy that handwritten 

changes to timesheets must identify who made the change, when the change was 

made, and for what purpose.

Consistency in Reimbursed Overtime Rates

We found that the USMS reimbursed task force officers in 56 of the 58

agencies at either their base hourly rate or one and a half times their base hourly 

rate. However, two district task forces paid two participating agencies at an 

overtime rate much higher than the others. One of those task forces, the District of 

Arizona Task Force, reimbursed one agency at one and a half times the base hourly 

rate but the task force reimbursed another agency at more than two times the base 

hourly rate. It appears this agency set its own standard billable overtime rate 

instead of relying on each task force officer’s salary. In so doing, this agency set 

overtime rates contrary to those established in its own internal policies of one and a 

half times the base hourly rate. We found that the total reimbursement would have 

been at least $12,363 less if the agency had used the overtime rate specified in its 

policies.

The USMS does not have a policy that sets the overtime rate for task force 

officers, and USMS officials told us that some jurisdictions have different bylaws or 

union rules pertaining to overtime that the USMS follows. The officials also told us 

that excess overtime payments such as that discussed above should be avoided 

through the use of the new standard invoice and timesheet implemented in 

FY 2019. However, these forms were not accompanied by implementation guidance

specifying when higher rates may be paid and how those rates must be justified. 

We agree that the new standard documents will help ensure that appropriate 

overtime amounts are calculated, and we recommend that the task forces be 

provided with implementation guidance specifying the circumstances, if any, under 

which overtime rates may be greater than one and a half times the base hourly 

rate.

USMS Vehicle Purchases for Task Force Officers

Prior to 2017, the USMS purchased vehicles with JLEO funds for state and 

local task force officers assigned to USMS fugitive task forces, and it immediately 

titled the vehicles to the officers’ home agencies. During FYs 2012 through 2016 
10

the USMS purchased with JLEO funds 1,609 vehicles for an approximate acquisition 

cost of $53.9 million. These vehicles were initially for the use of state and local 

officers assigned to fugitive task forces.

As of January 2017, 656 of the 1,609 vehicles with an estimated acquisition 

cost of $22 million were known to still be in task force service. In February 2019, a 

USMS official told us the USMS did not know if the 656 vehicles were still in task 

force service or had been otherwise disposed. Another official said he believed

that, because the vehicles were the property of the state and local law 

enforcement, the USMS did not track the vehicles other than through a survey to 

see how many were still in service.

Also as of January 2017, 953 of the 1,609 vehicles with an estimated 

acquisition cost of $31.9 million were known by the USMS to no longer be in task 

force service. However, the USMS did not know if the 953 vehicles had been 

disposed of by state and local agencies or placed into use for non-task force

operations.

We analyzed the purchase of approximately $3.6 million worth of vehicles 

purchased for task force officers in FY 2016. We noted that the USMS’s practice of 

using JLEO funds to purchase vehicles for use by state and local officers on task 

force operations was allowed by policy established in the 1997 Guidance and in 

effect at the time. Despite this, the policy required that such vehicles remain in use 

for joint operations so long as needed. The USMS’s standard Memorandum of 

Understanding (MOU) with agencies was not in accordance with the 1997 Guidance 

in that the MOU allowed State and local law enforcement agencies to retain vehicles 

after withdrawing from an existing task force. The vehicles of withdrawing agencies 

should have been returned to the USMS for disposition or use by agencies that 

continued with task force operations. Consequently, all 1,609 vehicles purchased 

during FYs 2012 through 2016 should have remained available for use on other task 

force operations or disposition by the USMS.

In 2017, the AFMS informed the USMS that the practice of allowing state and 

local agencies to keep the vehicles even when the task force is still in existence was 

not permitted. The USMS initially maintained to the AFMS that the Colgate Memo 

allowed for the purchase of vehicles, but in FY 2017 it discontinued the practice. 

Instead, the USMS worked with the General Services Administration to provide 

leased vehicles to task force officers.

Because the USMS ended purchasing vehicles at the direction of the JMD, we 

make no recommendation regarding the practice.

AFMS Testing of Circuit Costs

We reviewed the USMS’s use of JLEO-reimbursed circuit costs, which are 

telecommunications-related expenses incurred in tracking fugitives including trap 
11

and trace devices, and pen registers.6 In June 2018, AFMS engaged a team of 

consultants to review USMS circuit costs paid with JLEO funds. The review

assessed internal controls, identified risks, and documented and monitored the 

effectiveness of internal controls over the use of undercover accounts relating to 

circuit costs. The review identified several areas of concern including:

• inadequate segregation of duties when processing, reviewing, and 

authorizing telecommunication expenses;

• improper use of JLEO funds to pay federal expenditures that directly 

supported federal fugitive investigations rather than state and local 

reimbursements;

• significant delays in the payment of invoices;

• missing or insufficient documentation to verify accurate and proper payment.

We reviewed the methodology for the AFMS assessment, which included:

(1) an evaluation of the process to manage the circuit costs; (2) interviews with 

process owners involved with circuit costs; (3) examinations of records to validate 

the corresponding invoices; (4) and testing a sample of circuit cost transactions in 

FY 2017. We believe that the AFMS employed an appropriate methodology to 

assess the USMS controls over circuit costs.

The USMS concurred with all the recommendations and provided a response 

to AFMS for each. Consequently, we performed no further testing and make no 

recommendations in this area.

Testing of Other Non-Overtime Expenditures

As of August 22, 2019, USMS Headquarters divisions had expended 

$20.4 million in JLEO funds for database and circuit costs, vehicle leasing, task 

force officer training, contractor support, and other costs from FY 2016 through

FY 2018. We reviewed 31 of these transactions totaling approximately $6.4 million

and found that the expenses were allowable in accordance with the 1997 Guidance

and the DOJ’s budget guidance. Additionally, appropriate USMS officials authorized 

and certified the supporting documents.

We also reviewed documentation supporting one transaction totaling 

$109,129 for circuit costs. These costs were associated with wireless data 

communication collection activities. We determined that the costs were allowable 

and supported.

 

6 Trap and trace devices capture the telephone numbers of incoming calls without revealing 

the content of communications. Pen registers are surveillance devices that capture the phone 

numbers dialed on outgoing telephone calls.
12

CONCLUSION AND RECOMMENDATIONS

We found that the USMS generally had adequate internal controls in place to 

ensure it used JLEO funds for appropriate expenses, and that it made additional 

improvements to those controls during our audit. However, we found that controls 

for overtime reimbursement could be strengthened. Specifically, based on our 

findings the USMS must ensure that it processes overtime reimbursements to state 

and local agencies with proper support and authorization, as required by USMS 

policy. Further, the USMS should implement controls over handwritten changes to 

timesheets and establish policy for the determination of overtime rates. We make 

six recommendations to improve the USMS’s administration of JLEO funds.

We recommend that the USMS:

1. Remedy the $508,720 in unsupported overtime costs.

2. Strengthen its monitoring of task forces by establishing a schedule sufficient 

to ensure that each task force is periodically reviewed within reasonable 

timeframes for compliance with JLEO requirements.

3. Share with all task forces any information developed during its monitoring 

assessments—such as best practices or issues of common concern—that 

could assist the task forces in ensuring compliance with JLEO requirements. 

4. Develop a policy that handwritten changes to timesheets must identify who 

made the change, when the change was made, and for what purpose.

5. Provide task forces with implementation guidance specifying the 

circumstances under which overtime rates may be reimbursed at greater 

than one and a half times the base hourly rate.
13

STATEMENT ON INTERNAL CONTROLS

As required by the Government Auditing Standards, we tested, as 

appropriate, internal controls significant within the context of our audit objectives. 

A deficiency in an internal control exists when the design or operation of a control 

does not allow management or employees, in the normal course of performing their 

assigned functions, to timely prevent or detect: (1) impairments to the 

effectiveness and efficiency of operations, (2) misstatements in financial or 

performance information, or (3) violations of laws and regulations. Our evaluation 

of the United States Marshal Service’s (USMS) internal controls was not made for 

the purpose of providing assurance on its internal control structure as a whole. The 

USMS’s management is responsible for the establishment and maintenance of 

internal controls.

As noted in the Audit Results section of this report, we identified deficiencies 

in the USMS’s internal controls that are significant within the context of the audit 

objectives and based upon the audit work performed that we believe may affect the 

USMS’s ability to fully oversee its use of JLEO funds. Specifically, there were lack of 

controls pertaining to hand-written changes to timesheets and the calculated rates 

for overtime. The effect of these deficiencies is that the USMS remains exposed to 

heightened risks of fraud, waste, and abuse. We consider these risks to be 

significant enough to merit the attention of USMS leadership. However, we do not 

believe the issues discussed in the report represent a material weakness to the 

agency based on their nature, likelihood, and the potential magnitude of the risks.

Because we are not expressing an opinion on the USMS’s internal control 

structure as whole, this statement is intended solely for the information and use of 

the USMS. This restriction is not intended to limit the distribution of the report, 

which is a matter of public record.
14

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS

As required by the Government Auditing Standards we tested, as appropriate 

given our audit scope and objectives, selected transactions, records, procedures, 

and practices, to obtain reasonable assurance that the United States Marshals 

Service’s (USMS) management complied with federal laws and regulations for which 

noncompliance, in our judgment, could have a material effect on the results of our 

audit. The USMS’s management is responsible for ensuring compliance with 

applicable federal laws and regulations. In planning our audit, we identified the 

following laws and regulations that concerned the operations of the auditee and 

that were significant within the context of the audit objectives:

• 28 U.S.C. § 524, Availability of Appropriations

Our audit included examining, on a test basis, the USMS’s compliance with 

the aforementioned law that could have a material effect on the USMS’s operations, 

through interviewing agency personnel, assessing internal controls, and analyzing 

transaction-level documentation. Nothing came to our attention that caused us to 

believe that the USMS was not in compliance with the aforementioned law.
15

APPENDIX 1

OBJECTIVES, SCOPE, AND METHODOLOGY

The objectives of this audit were to assess whether the USMS: (1) has 

proper controls for Joint Law Enforcement Operations (JLEO) funds reimbursement 

and (2) reimburses state and local law enforcement for allowable and supported 

costs. The scope of our audit is generally fiscal years (FY) 2016 through 2018.

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require 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.

This performance audit was of the United States Marshals Services’ (USMS)

controls over JLEO funds. The audit generally covered, but was not limited to, the 

period FYs 2016 to 2018. To complete our objectives, we interviewed USMS

personnel and assessed the system of internal controls that was in place during the 

audit period. We used computer-processed data from the United Financial 

Management System (UFMS), which contained data on JLEO expenditures. We 

used spending line data from UFMS to determine our sample selection. We also 

tested the reliability of UFMS data during our testing of JLEO expenditures by 

reconciling it with the original source documents. We had occasions where the 

UFMS data did not reconcile with the original source documents from our testing. 

However, this occurred because we received UFMS data on October 17, 2018, and 

not all FY 2018 spending was captured in UFMS at that time.

We conducted site visits at the USMS Headquarters and the Southeast 

Regional Fugitive Task Force. We determined that transactions from task forces 

and USMS Headquarters could be readily assessed by having the USMS provide 

support documentation for those transactions to our office. As a result, we selected 

JLEO transactions from USMS Headquarters, 24 district task forces and 7 regional 

task forces. In total, we reviewed transactions totaling $10.1 million from USMS 

Headquarters, $3 million from district task forces, and $5.4 million from regional 

task forces.

Sampling Methodology

To assess USMS controls over JLEO funds, we selected sample transactions 

from the three organizational levels within the USMS. We requested that the USMS 

provide us documentation for sample task force transactions we selected, and we 

used that documentation to test the transactions. Our sampling strategy included: 

identifying potential high risk districts based on previous allegations of misusing 

JLEO funds; and identifying potential high risk transactions based on high dollar 

amounts, Headquarters-generated transactions, and training-related transactions. 

We sampled transactions totaling $18.5 million from 24 district task forces, 

7 regional task forces, and Headquarters.
16

We used a non-statistical sampling method to select a sample of district and 

regional task forces and the reimbursements to state and local law enforcement 

agencies for testing. The specific methodology used to select the district and 

regional fugitive task forces and the reimbursements varied to achieve multiple 

goals for our audit coverage. In addition, we used a non-statistical sampling 

method to test reimbursements made by USMS Headquarters. The approach 

employed for each segment of our sample is described below.

On-Site Testing

We initially selected one location, the Southeast Regional Fugitive Task 

Force, for on-site testing because of its geographical proximity to the audit team, 

which allowed us to plan our testing methodology and refine the specific audit 

procedures performed during the audit. Within the Southeast Regional Fugitive 

Task Force, we selected reimbursements totaling $272,888 across 9 state and local 

law enforcement agencies. We analyzed data from the UFMS and selected 17 separate

months of reimbursements based on various factors such as sub-object code and 

amount spent. We determined after our testing of this task force that the 

remaining tests could be conducted remotely from an OIG office.

Headquarters Testing

We used two methodologies to select the sample of reimbursements made by 

USMS Headquarters. First, we selected 14 vendors that were reimbursed at least 

$20,000 within any year from FY 2016 through October 17, 2018, which is the date 

that the USMS provided to us the universe of reimbursements.7 For each of these 

vendors, we selected the highest monthly reimbursement amount except for two 

vendors, which we selected 2 months of reimbursements. In total, we selected 

16 monthly reimbursements encompassing 6 unique accounting codes. Second, we 

selected a sample of 16 individual names that appeared on the spending lines 

based on the top 8 highest and bottom 8 lowest amounts reimbursed. Using both 

selections, we selected a total of $10.1 million for testing.

District and Regional Task Force Testing

We used 3 methodologies to select the 24 district task forces. First, we 

received a list of all state and local law enforcement agencies through UFMS and 

judgmentally selected any unique names from the list. Second, we selected two 

districts that had previous JLEO related allegations. Third, we performed a risk 

assessment using five variables to identify a sample of high-risk districts. We then 

scored each of the districts based on the five variables and selected the districts 

that had highest indicators of risk based on their score. After determining the 24 

district task forces to test, we used UFMS data to select 57 annual reimbursements 

totaling $3 million. Each of the reimbursements were made to differing state and 

 

7 In addition to reimbursing state and local law enforcement agencies, the USMS uses JLEO 

funds to support these agencies’ efforts through other non-overtime related expenditures such as for

vehicles and the cost of lodging for training. As such, “vendors” here refers to those entities that the 

USMS Headquarters reimburses for non-overtime related expenses.
17

local agencies. We generally selected our sample reimbursement for each district 

based upon the high-dollar amount.

We tested the remaining six regional task forces. Using UFMS data, we 

selected approximately six to eight state and local law enforcement agencies based 

on high annual reimbursements, which ultimately totaled $5.1 million.

For the district and regional testing, we requested the USMS to provide us 

with supporting documentation for each of the reimbursements mentioned above. 

Supporting documentation included but was not limited to timesheets invoices, 

obligation documents, and obligation modification documents.

We originally questioned $586,991 for unsupported overtime costs that the 

USMS reimbursed to state and local agencies. Subsequent to our exit briefing with 

the USMS on January 9, 2020, officials submitted to us timesheets not provided 

during our audit work but that supported $78,271 of previously unsupported 

overtime costs. We adjusted our original questioned costs to account for the 

timesheets provided, and reduced our questioned costs to $508,720 for 

unsupported overtime. However, because some of the timesheets provided lacked 

supervisory approval, we increased our calculation of tested transactions that were 

missing such approvals from $1,649,637 to $1,693,037. We made other minor 

adjustments throughout the report to account for these changes.
18

APPENDIX 2

SCHEDULE OF DOLLAR-RELATED FINDINGS

Description Amount Page

Questioned Costs:8

Unsupported Overtime Costs $508,720 6

 

8 Questioned Costs are expenditures that do not comply with legal, regulatory, or contractual 

requirements; are not supported by adequate documentation at the time of the audit, or are 

unnecessary or unreasonable. Questioned costs may be remedied by offset, waiver, recovery of 

funds, or provision of supporting documentation, where appropriate.
19

APPENDIX 3

REIMBURSEMENT TESTING RESULTS FOR

DISTRICT AND REGIONAL TASK FORCES

Task Force Amount Tested Amount Unsupported Amount with Missing 

Supervisory Approval

Alaska $646 $0 $0

Arizona 153,606 11,212 16,840

Delaware 967 0 0

S Iowa 703 0 0

E Michigan 480,012 9,577 0

E Missouri 6,077 0 0

W Missouri 179,676 6,147 22,604

New Hampshire 17,500 0 0

M North Carolina 5,131 0 0

North Dakota 414 414 0

E Pennsylvania 358,592 265,003 43,703

Puerto Rico 50,870 34 0

E Oklahoma 1,792 0 0

S Ohio 31,487 0 0

N Ohio 196,475 185 0

South Carolina 92,764 1,496 0

M Tennessee 696 0 0

N Texas 434,887 0 0

S Texas 525,008 0 0

W Texas 469,610 51,037 63,981

Vermont 3,033 0 0

S West Virginia 2,105 0 0

Wyoming 8,063 0 0

Guam 6,645 0 0

Sub-Total of 

Districts 3,026,759 345,105 147,128

Florida/Caribbean $668,258 $2,158 $0

Great Lakes 866,359 0 563,811

New York/New Jersey 919,820 0 557,000

Pacific Southwest 1,649,716 17,427 77,220

Gulf Coast 351,897 7,476 37,184

Capital Area 676,198 131,643 310,694

Southeast 272,888 4,911 0

Sub-Total of 

Regions 5,405,136 163,615 1,545,909

Total $8,431,895 508,720 $1,693,037
20

APPENDIX 4

USMS RESPONSE TO THE DRAFT REPORT
21
22

APPENDIX 5

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT

The Office of the Inspector General (OIG) provided a draft of this audit report 

to the United States Marshals Service (USMS). The USMS’s response is 

incorporated in Appendix 4 of this final report. In response to our draft audit 

report, the USMS did not state whether it agreed or disagreed with our 

recommendations but described its planned actions to address each 

recommendation. As a result, the status of this audit report is resolved. The 

following provides the OIG analysis of the response and summary of actions 

necessary to close the report.

Recommendations for the USMS:

1. Remedy the $508,720 in unsupported overtime costs.

Resolved. The USMS stated in its response that the Investigative Operations 

Division (IOD) is currently working with the districts and Regional Fugitive 

Task Forces (RFTF) on the remedy for unsupported overtime costs. The 

USMS expects to complete this by the end of the second quarter of FY 2020.

This recommendation can be closed when we receive documentation to

support that the $508,720 in overtime costs has been remedied.

2. Strengthen its monitoring of task forces by establishing a schedule 

sufficient to ensure that each task force is periodically reviewed 

within reasonable timeframes for compliance with JLEO 

requirements.

Resolved. The USMS stated that it will implement a quarterly review process 

of task forces to ensure that each task force is in compliance with JLEO 

requirements. The USMS plans to designate personnel from USMS 

Headquarters and USMS Districts along with contractor support to help 

facilitate this monitoring. The USMS expects to begin the quarterly review 

process in the fourth quarter of FY 2020.

This recommendation can be closed when we receive documentation 

supporting implementation of the quarterly review process.

3. Share with all task forces any information developed during its 

monitoring assessments—such as best practices or issues of common 

concern—that could assist the task forces in ensuring compliance 

with JLEO requirements.

Resolved. The USMS stated that it will leverage its intranet page, which is 

accessible by the Districts and RFTFs, to post best practices and frequently 

asked questions to help ensure JLEO compliance in the field. Furthermore, 
23

the USMS plans to incorporate any best practices into the periodic and sitespecific JLEO training conducted. IOD expects to begin posting information 

on the JLEO Intranet page in the third quarter of FY 2020.

This recommendation can be closed when we receive documentation to 

support that the USMS posted best practices and frequently asked questions 

to its intranet page and incorporated best practices into the periodic and sitespecific JLEO training.

4. Develop a policy that handwritten changes to timesheets must 

identify who made the change, when the change was made, and for 

what purpose.

Resolved. The USMS stated that it will update its JLEO policy and guidance 

to field offices to include when handwritten changes are made to the 

timesheets. The person making the changes will be required to initial any 

changes and to annotate on the invoice why the changes had been made. 

Further, the USMS plans to require that a justification memorandum be 

attached to the file. The USMS estimates updating the guidance in the fourth 

quarter of FY 2020.

This recommendation can be closed when we receive the updated JLEO policy 

and guidance concerning handwritten changes to timesheets.

5. Provide task forces with implementation guidance specifying the 

circumstances under which overtime rates may be reimbursed at 

greater than one and a half times the base hourly rate.

Resolved. The USMS stated that it recognizes that certain state and local 

agencies have different overtime rates and that it will develop specific 

guidance for the task forces, designating the circumstances requiring 

overtime rates to be reimbursed at greater than one and a half times the 

base hourly rate. The USMS estimates updating the guidance in the fourth 

quarter of FY 2020.

This recommendation can be closed when we receive the guidance to the 

task forces designating the circumstances requiring overtime rates to be 

reimbursed at greater than one and a half times the base hourly rate.
U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001

 

Also at Oversight.gov

The Department of Justice Office of the Inspector General (DOJ OIG) is a 

statutorily created independent entity whose mission is to detect and deter 

waste, fraud, abuse, and misconduct in the Department of Justice, and to 

promote economy and efficiency in the Department’s operations.

To report allegations of waste, fraud, abuse, or misconduct regarding DOJ 

programs, employees, contractors, grants, or contracts please visit or call the

DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

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