Oversight Review of the 

United States Coast Guard 

Investigative Service

June 23, 2017 

OIG-17-74-IQO
 DHS OIG HIGHLIGHTS

Oversight Review of the United States Coast 

Guard Investigative Service 

www.oig.dhs.gov OIG-17-74-IQO

What We Found 

We determined that significant issues with the 

agency’s case management system prevented 

us from making substantive observations 

about the quality of their investigations. We 

noted issues with outdated policies and the 

absence of a Privacy Impact Assessment for 

the case management system. Additionally, 

CGIS could not provide evidence to confirm 

whether employees complied with special 

agent training requirements. CGIS employees 

voiced concerns about trust in senior 

leadership and perceived questionable hiring 

practices. They also articulated a need for 

more resources. 

CGIS Response 

CGIS concurred with all 32 recommendations 

and took immediate action to resolve 3 

recommendations. Additionally, CGIS initiated 

corrective action on 19 of the 

recommendations that should improve 

operational management and investigations. 

CGIS needs to further develop a resolution for 

10 recommendations that remain open and 

unresolved. 

 

June 23, 2017 

Why We Did This 

Review 

We conducted this review as part 

of the planned periodic review of 

the Department of Homeland 

Security (DHS) component 

internal affairs offices by the 

DHS Office of Inspector General 

in keeping with the oversight 

responsibilities mandated by the 

Inspector General Act of 1978, 

as amended. 

What We 

Recommend 

We made 32 recommendations 

designed to improve operational 

management and help ensure 

investigative activities comply 

with applicable standards. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100 or email us at 

DHS-OIG.OfficeofPublicAffairs@oig.dhs.gov
UOQEP~"'\Fh

OFFICE OF INSPECTOR GENERAL

"~ tF` Department of Homeland Security

Washington, DC 20528 / www.oig.dhs.gov

June 23, 2017

MEMORANDUM FOR: Admiral Charles D. Michel

Vice Commandant

United States Coast Guard

FROM: John V. Kelly

Deputy Inspector General

SUBJECT: Oversight Review of the United States Coast Guard

Investigative Service

Attached for your action is our final report, Oversight Review of the United

States Coast Guard Investigative Service. We incorporated your formal

comments in the final report.

The report contains 32 recommendations aimed at improving the United States

Coast Guard Investigative Service. Your office concurred with all 32

recommendations. Based on information provided in your response to the draft

report, we consider recommendations 1, 10, 11, 12, 14, 16, 19, 21, 22, and 29

open and unresolved. As prescribed by the Department of Homeland Security

Directive 077-01, Follow-Up and Resolutions for the Office of Inspector General

Report Recommendations, within 90 days of the date of this memorandum,

please provide our office with a written response that includes your

(1) agreement or disagreement, (2) corrective action plan, and (3) target

completion date for each recommendation. Also, please include responsible

parties and any other supporting documentation necessary to inform us about

the current status of the recommendation. Until your response is received and

evaluated, the recommendations will be considered open and unresolved.

Based on information provided in your response to the draft report, we

consider recommendations 2, 3, 4, 5, 6, 7, 8, 13, 15, 17, 20, 23, 24, 25, 26, 27,

28, 31, and 32 open and resolved. Once your office has fully implemented the

recommendations, please submit a formal closeout letter to us within 30 days

so that we may close the recommendations. The memorandum should be

accompanied by evidence of completion of agreed-upon corrective actions.

Recommendations 9, 18, and 30 are resolved and closed.
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 2 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to appropriate congressional committees with 

oversight and appropriation responsibility over the Department of Homeland 

Security. We will post the report on our website for public dissemination. 

Please call me at (202) 254-4100 with any questions or your staff may contact 

Robert Greene at (202) 254-5429. You can also send your response to 

IQO@oig.dhs.gov. 

Attachment 
OFFICE OF INSPECTOR GENERAL 

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www.oig.dhs.gov 1 OIG-17-74-IQO 

Table of Contents

Summary ........................................................................................................ 2

Background .................................................................................................... 3

Results of Oversight Review............................................................................. 5

Operational Management ............................................................................. 5

Investigations ............................................................................................. 23 

Summary of Recommendations, CGIS Response, and OIG Analysis ............... 26

Appendixes 

 Appendix A: Objective, Scope, and Methodology ................................... 39

 Appendix B: CGIS Comments to the Draft Report ................................. 42

 Appendix C: Checklists and Questionnaires ......................................... 51

 Appendix D: Major Contributors to This Report .................................... 52

 Appendix E: Report Distribution .......................................................... 53

Abbreviations 

CGIS Coast Guard Investigative Service 

CIGIE Council of the Inspectors General on Integrity and Efficiency 

DEOCS Defense Equal Opportunity Management Institute 

Organizational Climate Survey 

FACTS Field Activity Case Tracking System 

FEVS Federal Employee Viewpoint Survey 

LEAP Law Enforcement Availability Pay 

MOU Memorandum of Understanding 

OMB Office of Management and Budget 

OIG Office of Inspector General 

PIA Privacy Impact Assessment 

PII personally identifiable information 

SAC special agent-in-charge 

SOP Standard Operating Procedure 

USC United States Code 
OFFICE OF INSPECTOR GENERAL 

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SUMMARY

The Office of Integrity and Quality Oversight, Investigations and Program 

Integrity Division conducted an oversight review of the United States Coast 

Guard (Coast Guard) Investigative Service (CGIS) from April 2016 through 

November 2016. The review covered CGIS activity from October 1, 2013, to 

March 31, 2016. We conducted this review as part of the planned periodic 

review of the Department of Homeland Security (DHS) component internal 

affairs offices by the DHS Office of Inspector General (OIG) in keeping with the 

oversight responsibilities mandated by the Inspector General Act of 1978, as 

amended. 

The review focused on two primary areas: organizational management and 

investigative work. In conducting the review, we assessed compliance with 

Coast Guard Commandant Instructions, the Memorandum of Understanding 

between the Coast Guard and DHS OIG, and referenced guidelines established 

by the Council of the Inspectors General on Integrity and Efficiency (CIGIE), as 

applicable. 

In most instances, we found CGIS conducted investigations expeditiously. 

However, significant issues with the agency’s case management system 

prevented us from making substantive observations about the quality of their 

investigations. We noted issues with outdated policies and the absence of a 

Privacy Impact Assessment for the case management system. Additionally, 

CGIS could not confirm whether employees complied with special agent 

training requirements. 

CGIS employees voiced concerns with trust in senior leadership as well as 

questionable hiring practices, and a need for more resources. While many 

employees voiced positive opinions, others expressed dissatisfaction with 

management; the CGIS case management system; the amount of training 

received; and policies and procedures. We made 32 recommendations designed 

to improve operational management and help ensure investigative activities 

comply with applicable standards. 

 
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BACKGROUND 

The United States Coast Guard Investigative Service is the component of the 

United States Coast Guard (Coast Guard) charged with conducting 

investigations related to Coast Guard personnel, assets, and operations. The 

CGIS Director reports directly to the Vice Commandant of the Coast Guard. 

CGIS is divided into eight regions, each headed by a special agent-in-charge 

(SAC). There are 35 Resident Agent offices within the eight CGIS regions. CGIS 

is staffed with a mix of active duty military special agents (enlisted, warrant 

officer and officer), civilian special agents (1811 series), and special agents who 

are members of the Coast Guard Reserve. 

CGIS derives its authority from Title 14 of the United States Code (USC). This 

authority provides for CGIS special agents to conduct investigations of criminal 

activity. In so doing, CGIS special agents have the authority to carry firearms, 

execute and serve warrants, and make arrests. 

CGIS does not operate a complaint hotline for receiving and handling 

allegations of wrongdoing. CGIS managers explained that they typically receive 

allegations through the various Coast Guard offices and through emails from 

DHS OIG. Because of this, and limitations with their case management system, 

CGIS could not provide requested information on the number or type of 

allegations reported for the inspected period. 

The DHS OIG Office of Investigations reported receiving 374 allegations related 

to the Coast Guard from fiscal year 2014 through the second quarter of FY 

2016 and initiated investigations on 33 of those allegations. The remaining 

allegations were referred to CGIS. Tables 1 and 2 depict the categorized subject 

matter of the allegations and initiated investigations, respectively. The data 

shows that a majority of the allegations reported to and investigated by DHS 

OIG related to the Coast Guard fell in the “Miscellaneous” category. 

TABLE 1: Complaints Related to the Coast Guard 

Received by DHS OIG by Allegation Category 

FY 2014 to Q2 FY 2016 

ALLEGATION CATEGORY QTY. % of TOTAL 

COMPLAINTS 

Employee Corruption 29 8% 

Civil Rights Civil Liberties 26 7% 

Program Fraud 52 14% 

Miscellaneous 267 71% 

TOTAL 374 

Source: Enterprise Data System, DHS OIG 
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TABLE 2: Investigations Related to the Coast 

Guard Initiated by DHS OIG by Allegation Category 

FY 2014 to Q2 FY 2016 

ALLEGATION CATEGORY QTY. % of INITATED 

Employee Corruption 3 9% 

Civil Rights Civil Liberties 1 3% 

Program Fraud 7 21% 

Miscellaneous 22 67% 

TOTAL 33 

Source: Enterprise Data System, DHS OIG 

A further analysis of the data provided by DHS OIG on allegations related to 

the Coast Guard revealed that the top five allegations received in the 

Miscellaneous category were classified as “management related,” “general 

employee misconduct,” “abuse of authority,” “prohibited personnel practices,” 

and “unspecified.” See table 3. 

TABLE 3: Most Prevalent Allegations Related to the Coast 

Guard Reported in Miscellaneous Categories 

FY 2014 to Q2 FY 2016

ALLEGATION # 

RECEIVED 

% OF TOTAL MISC. 

CATEGORY 

Management Related 39 15% 

Employee Misconduct, General 37 14% 

Abuse of Authority 31 12% 

Prohibited Personnel Practices 23 9% 

Unspecified / Miscellaneous 17 6% 

Harassment 15 6% 

Other Non-Criminal Activity 15 6% 

Abuse / Violence 12 4% 

General Fraud 12 4% 

False Statements 11 4% 

All Other Misc. Allegations 55 21% 

TOTAL 267 

Source: Enterprise Data System, DHS OIG 

 *percentage totals equal 101% due to rounding 
OFFICE OF INSPECTOR GENERAL 

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RESULTS OF OVERSIGHT REVIEW 

Operational Management 

Compliance with the 2003 Memorandum of Understanding with DHS OIG 

During our review, CGIS officials were not able to demonstrate whether they 

consistently referred required allegations to the OIG because they did not have 

a documented centralized process for receiving and referring allegations nor do 

they capture such information in their case management system. In addition, 

we found CGIS’ interpretation of allegations required for referral resulted in the 

OIG not receiving all the allegations mandated by the Memorandum of 

Understanding (MOU). 

The Coast Guard and DHS OIG entered into an MOU in 2003, pursuant to 

which CGIS agreed to forward to DHS OIG any “allegations of wrongful conduct 

in areas of OIG investigative responsibilities” received by the Coast Guard. 

Additionally, the agreement stipulated that the Director of CGIS would “refer to 

the OIG all allegations of suspected violations that constitute fraud, waste, 

mismanagement, or abuse relating to programs and operations of the Coast 

Guard or DHS.” The agreement provides several examples within the range of 

covered activities that are “not intended to represent an exhaustive or allinclusive” list. The agreement mandates that the referrals “shall be made 

immediately upon receipt of the allegation.”1

In our discussions with CGIS management, we found that CGIS management 

too narrowly interpreted the allegations mandated for OIG referral per the 

MOU. CGIS management maintained that only allegations involving financial 

wrongdoing required referral to the OIG. Although the MOU provides some 

examples of financial-based allegations, it also includes offenses such as 

corruption, civil rights, racial profiling, and those posing a serious danger to 

public health and safety. In reviewing the limited information available to us, 

we found that CGIS’ interpretation resulted in the OIG not receiving all the 

allegations mandated by the MOU. 

CGIS management told us that they typically receive allegations through Coast 

Guard Area Commanders or the OIG. When an Area Commander refers an 

allegation to CGIS, office personnel enter the allegations into CGIS’ case 

management system, the Field Activity Case Tracking System (FACTS). The 

OIG refers allegations to CGIS by email to a point of contact at CGIS 

headquarters. A CGIS employee then enters the allegation into FACTS and 

routes it to the appropriate CGIS SAC office. 



1 Memorandum of Understanding Between the United States Coast Guard and the Office of 

Inspector General of the Department of Homeland Security, Section VIII. Coordination of OIG 

External Field Investigations, Subsection (b).
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We found FACTS did not have a field in which users could document the 

referral of allegations to the OIG, and therefore, we could not verify whether the 

required referrals took place. While we were conducting our inspection, we 

observed an instance where a CGIS SAC called a DHS OIG SAC to discuss an 

allegation CGIS received. In discussing the referral process with several CGIS 

SACs, we were told that they often call OIG SACs directly when they receive an 

allegation within the MOU criteria. They informed us that they do not annotate 

the referral in FACTS. 

The MOU also requires the Director of CGIS to provide a quarterly report to the 

OIG “describing the status of all open [OIG referred] Hotline Complaint 

investigations.” In our discussions with CGIS and OIG management, we 

learned CGIS has not provided such reports to the OIG. Nevertheless, we also 

learned that the parties have discussed the issue and CGIS is working on 

complying with the requirement. CGIS maintains that FACTS’s limited 

statistical reporting capabilities are preventing them from immediately 

complying. 

Recommendations 

1. We recommend the CGIS Director issue policy to standardize and centralize 

the receipt and referral of allegations and ensure FACTS includes a field to 

capture when an allegation was referred to the OIG. 

2. We recommend the CGIS Director articulate in policy what constitutes an 

OIG-referable allegation, train all necessary staff accordingly, and ensure 

that CGIS refers the requisite allegations to the OIG. 

3. We recommend the CGIS Director provide a quarterly report to the OIG 

describing the status of all open Hotline Complaint investigations as 

mandated by the MOU. 

Employee Workforce Assessment 

As part of our oversight review, we conducted a workforce assessment of CGIS. 

The assessment included analysis of the results of in-person interviews; an 

electronic survey administered by the review team; the Defense Equal 

Opportunity Management Institute Organizational Climate Survey (DEOCS) 

administered by CGIS in July of 2013; and the Federal Employee Viewpoint 

Surveys for 2014, 2015, and 2016. Overall, our analysis showed that CGIS 

employees did not fully trust CGIS leadership, were suspicious of questionable 

hiring practices, and wanted more resources. We also noted prominent 

concerns with CGIS policies, the case management system, and training. We 

address these specific concerns in their corresponding sections of this report. 
OFFICE OF INSPECTOR GENERAL 

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Additionally, we found that the Director of CGIS has only administered the 

DEOCS once, in 2013, and not on an annual basis as required.2 The survey— 

assesses factors surrounding the command civil rights climate, 

such as sexual harassment, prohibited discrimination, differential 

command behavior to minorities, positive equal opportunity 

behaviors, religious discrimination, racist behavior, overall equal 

opportunity climate, age discrimination, disability discrimination, 

work group cohesion and effectiveness, leadership cohesion, job 

satisfaction, trust in the organization.

We also did not see that the Director of CGIS put a plan in place to address the 

items of concern identified in the July 2013 DEOCS. 

Leadership 

During our review, we spoke with employees at CGIS Headquarters and four 

field office locations. At all of the field offices visited, most employees reported 

positive morale. Some employees at two offices we visited spoke highly of the 

local leadership and described the work environment as positive and free of 

conflict. Employees reported feeling supported by their immediate managers 

and described a collaborative environment in which agents helped each other. 

These sentiments were echoed in the electronic survey responses where 74 

percent of respondents were reportedly satisfied with their immediate 

management team (SAC and Assistant SAC). Several employees communicated 

personal satisfaction with the work they do and reported positive sentiments 

about their colleagues. 

Conversely, only 37 percent of surveyed employees believed CGIS senior 

leaders generated high levels of motivation and commitment in the workforce. 

One employee expressed that some supervisors need leadership training. 

Another employee said that some supervisors use performance evaluations to 

hinder the careers of employees they do not like. Some employees claimed that 

CGIS leadership did not provide constructive feedback. Further, more than 60 

percent of the negative DEOCS responses appeared to reference CGIS 

Headquarters as opposed to regional level management. In addition, the survey 

identified serious concerns with trust in senior management. 

In our analysis of the Federal Employee Viewpoint Survey (FEVS) results, 

questions regarding the agency’s senior leadership consistently scored much 

lower than the overall Coast Guard results. For example, in 2016, on questions 

mentioning senior leadership, CGIS negative responses were an average of 24 

percentage points higher than Coast Guard. Another noticeable trend was that 

almost all CGIS responses regarding employee satisfaction were less positive 

than the overall Coast Guard averages for all 3 years of data. 



2 Commandant Instruction M5350.4C, Coast Guard Civil Rights Manual, Section 6. DEOMI 

Organizational Climate Survey, p. 3-A.16 
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Hiring and Promotions 

Numerous employees expressed concerns about perceived favoritism in 

promotions, transfers, and bonuses. These employees attributed low morale 

within the agency as being a direct result of favoritism and questionable 

decisions made by senior leadership. Only about 50 percent of survey 

respondents believed that arbitrary action and personal favoritism were not 

tolerated in their workplace. 

Some employees discussed difficulties in advancing within CGIS. These 

employees believed CGIS agents lack a defined career track and opportunities 

for promotion were elusive. In addition, some employees believed CGIS does not 

have grade parity with other component law enforcement agencies. For 

example, the assistant special agent-in-charge position in CGIS is not 

consistently graded at the GS-14 level as it is in other law enforcement 

agencies within DHS. In addition, the journeyman level for CGIS agents is 

lower (GS-12) than it is for other agents within DHS (GS-13). 

Employees also expressed frustration at the limited GS-13 opportunities 

available to them. Some employees explained that sometimes CGIS selected 

outside applicants, who were already at the GS-13 level, for promotions. CGIS 

employees opined that outside applicants are viewed as more qualified than 

internal candidates because they come from agencies with more resources and 

training. 

Several employees further expressed concern that the process for staffing CGIS 

agent vacancies effectively limits CGIS employees from getting promotions. 

Many vacancies are first announced internally as lateral-only positions — i.e., 

a CGIS applicant must already be at the vacancy’s grade level (e.g., GS-13) in 

order to apply. If the position is not filled, it is then announced governmentwide and those seeking promotions are eligible to apply. For example, a GS-12 

CGIS employee could not apply to the initial internal announcement for a GS13 CGIS position because it is deemed lateral-only. However, a GS-12 employee 

from a different agency could apply to the external announcement for a GS-13 

CGIS position and potentially receive a promotion. The CGIS employee could 

apply to the same external announcement as the employee from a different 

agency, but CGIS employees reported that this practice effectively prevents 

CGIS employees from attaining promotions because of the added competition. 

Resources 

Numerous employees expressed the need for more staff in administrative and 

agent roles and gave examples of how limited resources affected their work. 

Specifically, employees complained that limited resources resulted in: 

x difficulty in completing tasks without designated administrative and 

logistical support staff; 

x employees tasked with too many collateral duties; 
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x inability to obtain resources such as portable radios; 

x limited funding for informants and undercover operations; and 

x CGIS not having the resources needed to properly support the Coast 

Guard community. 

One employee described the situation in the field as trying to hold things 

together with “scotch-tape and tooth-picks.” Another employee said the “more 

with less philosophy” was not sustainable and it has negatively affected 

employee morale and commitment. In one employee’s view, CGIS was not 

included in the overall Coast Guard strategic plan and resources appear when 

there are problems but not “to sustain the general health of the organization.” 

The results of the DEOCS also identified a perceived need for additional 

resources (both administrative and equipment related). Similarly, more than 

half of CGIS respondents to the FEVS responded negatively to questions about 

whether they had sufficient resources (people, materials, and budget) to do 

their job. 

Some CGIS reservists expressed dissatisfaction with the fact they were unable 

to access Coast Guard email accounts and that they did not have Coast Guard 

issued cellular phones. They claimed that they are not assigned government 

phones and must use their personal devices to conduct business and access 

email. In addition, reservists complained about having difficulty accessing 

CGIS emails because they did not have assigned computers and the Coast 

Guard email system does not have compatibility with all types of devices. Some 

reservists opined that it was not appropriate for them to use personal devices 

to conduct business and believed the agency could benefit from them having 

access to their email accounts. 

Other Concerns 

The DEOCS identified a high percentage of unfavorable responses in regards to 

organizational processes and leadership, centered on inadequate funding and 

resources; lack of adequate policy; poor communications; and a perception of 

favoritism and/or unfair treatment. The FEVSs identified other areas of 

significant concern, such as the case management system; advancement 

opportunities; the case referral process; amount of training received; and 

policies and procedures. 

Recommendations 

4. We recommend the CGIS Director follow the requirements to administer the 

DEOCS on an annual basis. We further recommend the CGIS Director 

develop and implement a corrective action plan to address concerns learned 

through the DEOCS. 
OFFICE OF INSPECTOR GENERAL 

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5. We recommend the CGIS Director conduct an analysis to determine whether 

CGIS agents are compensated consistent with their peers within DHS and 

make changes as necessary. 

Policy 

We found that CGIS’ primary policy manual, the Coast Guard Investigations 

Manual, COMDTINST M5527.1B (Investigations Manual), was largely out of 

date. Yet, CGIS management was actively working to repeal the manual and 

replace it with current Standard Operating Procedures (SOP). As of the end of 

September 2016, CGIS had issued 15 of the approximately 93 planned SOPs. 

However, according to the Coast Guard Directives Systems Manual, M5215.6H 

(Systems Manual), SOPs are used to further explain existing policy and should 

not be used in place of policy. The Systems Manual presents several formats 

appropriate for memorializing policy. 

 

The Investigations Manual promulgates internal policy guidance, 

responsibilities, authority, and instructions for the administration of the 

investigations and personnel security programs within CGIS. CGIS 

implemented the manual in July 2001 and made a formal interim change to 

chapter 6 of the manual in September 2001. Reportedly, CGIS also made 

several interim changes through less formal methods, but has not formally 

reviewed the manual every 4 years, as required by the Systems Manual.3

CGIS management reported that up until mid-2015, adjustments to policy were 

made using “Director’s Notes”, which were emails or memorandums from the 

CGIS Director. According to CGIS management, CGIS communicated changes 

in policy in this manner, but did not formally incorporate these notes into the 

manual. In addition, CGIS did not consistently maintain policy changes in a 

central location available to all employees. This practice made it difficult for 

CGIS to ensure employees knew and followed requirements. 

Many CGIS employees expressed frustration with the lack of updated guidance, 

which has resulted in confusion over requirements. Several employees voiced 

the need for more extensive and clearer policies. Specifically, these employees 

were concerned with the lack of clear or updated policy regarding firearms and 

use of force. Employees suggested CGIS solicit feedback from the field and use 

working groups, made up of CGIS employees, to develop and draft policies. One 

employee recommended CGIS use committees based on subject matter 

expertise, such as firearms personnel working together to create the firearms 

policy. 

The inspection team observed that CGIS maintained completed SOPs in a 

SharePoint site accessible to applicable CGIS employees. In our discussions 

with staff, however, we learned that some employees were confused about 



3 Coast Guard Directives Systems Manual, M5215.6H, pp. 1-2
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whether the SOPs superseded the instructions in the Investigations Manual, 

simply augmented the instructions, or served another purpose. Some 

employees felt uneasy about adhering to the SOPs because they were not vetted 

and published through the Coast Guard Directives System and because CGIS 

did not formally repeal the Investigations Manual. 

The Coast Guard Directives and Publications Division, CG-612, is charged with 

overseeing the Coast Guard Directive’s System. In our consultation with them 

and review of the Systems Manual, we learned that CGIS is the sponsor of the 

Investigations Manual and therefore can cancel it as warranted. We also 

discovered that CGIS incorrectly used SOPs to replace the Investigations 

Manual. The Systems Manual defines SOPs as “a set of instructions covering 

those features of current operations that lend themselves to a definite or 

standardized procedure without a loss of effectiveness.” It further states that 

SOPs are developed “to ensure correct adherence to internal procedures.”4 CG612 explained that SOPs are used to further explain existing policy and should 

not be used in place of policy. The Systems Manual presents several formats 

appropriate for memorializing policy. 

In conducting interviews with CGIS management and employees, we noted that 

CGIS did not consistently consult with Coast Guard functional areas in 

drafting new policies. Specifically, we found minimal evidence that Coast Guard 

Judge Advocate attorneys evaluated SOPs prior to issuance. This practice could 

result in CGIS enacting policies that are inconsistent with laws and Coast 

Guard and DHS policy. The Systems Manual outlines a clearance process for 

policies to allow for coordination by organizational elements that have a 

substantial interest in the proposed policy. 

Recommendations 

6. We recommend the CGIS Director, in consultation with the Coast Guard 

Directives and Publications Division, CG-612, replace the existing Coast 

Guard Investigations Manual with a document that complies with Systems 

Manual requirements. 

7. We recommend the CGIS Director continue to update investigative policy 

and follow the Coast Guard clearance process outlined in M5215.6 prior to 

issuing new policy. 

Case Management System 

CGIS began using FACTS as their primary case management system on July 1, 

2014, and subsequently made several updates to the system. In conducting 

our review, we found that CGIS did not conduct a Privacy Impact Assessment 

(PIA) for FACTS prior to its implementation. Section 208 of the E-Government 



4 Coast Guard Directives Systems Manual, M5215.6H, pp. 1-2
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Act of 2002 requires all Federal Government agencies to conduct a PIA for all 

new or substantially changed technology that collects, maintains, or 

disseminates personally identifiable information (PII). Through discussions with 

CGIS and Coast Guard officials, we learned that CGIS is in the process of 

conducting the assessment. 

The DHS Privacy Office published its Privacy Impact Assessments Official 

Guidance in 2006 that explains that a PIA is used to demonstrate that system 

owners and developers have consciously incorporated privacy protections 

throughout the entire life cycle of a system. It further explains that a PIA 

analyzes how personal information is collected, used, stored, and protected by 

the Department and examines how the Department has incorporated privacy 

concerns throughout its development, design and deployment of the technology 

or rulemaking. 

The guidance also explains that PII is “information in a system, online 

collection, or technology: (i) that directly identifies an individual (e.g., name, 

address, social security number or other identifying number or code, telephone 

number, email address, etc.) or (ii) by which an agency intends to identify 

specific individuals in conjunction with other data elements, i.e., indirect 

identification.” It further explains, “As found in the Office of Management and 

Budget (OMB) Memorandum M-03-22, these data elements may include a 

combination of gender, race, birth date, geographic indicator, and other 

descriptors.”5 The information contained in FACTS includes PII (including 

names, dates of birth, and social security numbers) and, therefore, is subject to 

applicable rules. 

During our review, we assessed whether CGIS obtained the proper 

accreditation to operate FACTS. In consultation with Coast Guard, we learned 

that they accredited the system prior to implementation and continue to 

support its information technology needs. 

The DHS Certification and Accreditation process is used by DHS to assure its 

systems meet appropriate system and operating standards. The DHS Security 

Authorization Process Guide outlines the progression that DHS components 

must follow to secure authorization for an information system to operate within 

DHS. The guide mandates that all unclassified systems, including General 

Support Systems and Major Applications, in the DHS Federal Information 

Security Management Act inventory must be assessed and authorized in 

accordance with the process identified in this guide. In addition, all subsystems and minor applications must be documented in the security 

authorization package of an associated General Support Systems and Major 

Applications.6



5 Privacy Impact Assessments Official Guidance, Information Covered by PIA, pp. 10-11 6 DHS Security Authorization Process Guide, Section 1.3, p. 2
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FACTS was an area of significant dissatisfaction among many employees we 

interviewed and surveyed. One employee named FACTS “the single biggest 

morale issue within CGIS.” Many employees complained that CGIS did not 

conduct a needs-analysis or properly assess the system’s capabilities prior to 

its purchase. Numerous employees also complained that CGIS put FACTS into 

operation without defined policies on how to use it and there continues to be 

no comprehensive manual. 

CGIS management explained that prior to fielding FACTS they sent some 

criminal investigators to visit police departments around the country who were 

using the system. The investigators got the opportunity to see how different 

policing agencies used the system and then contributed to CGIS’ efforts to 

customize it to their needs. CGIS management also explained that they have 

routinely held working group meetings with key employees in order to solicit 

ideas for improving the system. They have worked with the FACTS contractor 

to make changes to the system and are working on a policy manual for FACTS. 

We found FACTS to be a robust system with the potential to serve its intended 

purpose. FACTS contained most, though not all, of the appropriate fields to 

capture basic information related to allegations and investigations. However, 

the use of FACTS between offices is not standardized, resulting in differences in 

what information was entered, where it was entered, and how it was 

structured. For example, the case narrative paragraph, the purpose of which is 

to provide a synopsis of the investigation, in some cases provided a complete 

summary of the investigation, but in other cases merely presented the 

allegation. The unstandardized usage of FACTS also resulted in problems with 

data captured within it. We found some fields were not consistently utilized 

which caused disparities in the data collected. Some employees reported that 

the statistical data extracted through FACTS was unreliable. One employee 

estimated that the statistical data pulled from FACTS was at best 60 percent 

reliable. 

We discussed our concerns with CGIS management who asserted that they 

were working to standardize the use of FACTS and improve the quality of data. 

While we were conducting our review, CGIS had a multi-day “stand-down” 

where FACTS users were instructed to update various fields in an attempt to 

standardize the collected information. Several CGIS employees reported that 

there had been other such days since FACTS was implemented. Unfortunately, 

some employees considered these “stand-downs” frustrating and time 

consuming. Some employees questioned the purpose and relevance of entering 

biographical information into closed cases, especially since in many instances, 

collecting such information would require re-contacting affected individuals. 

Despite the negative feedback regarding FACTS, some employees believed 

FACTS was a best practice and noted it was better than the previous CGIS case 

management system. Employees believed better guidance and more training 

with the system would improve usability. Other employee suggestions included 
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better oversight and coordination, more formal training, and using FACTS to 

track evidence. 

Recommendation 

8. We recommend the CGIS Director ensure that a Privacy Impact Assessment 

is conducted for FACTS and that all related requirements are properly 

addressed. 

9. We recommend the CGIS Director develop and publish a policy manual for 

FACTS to standardize, at a minimum, what fields must be completed and 

the type of information needed in each field. 

10. We recommend the CGIS Director provide training to FACTS users on 

navigating the system and policy requirements. 

Law Enforcement Availability Pay 

We found conflicting Law Enforcement Availability Pay (LEAP) records 

maintenance policies. As such, CGIS management does not consistently 

maintain LEAP records. We were therefore unable to determine whether all 

subject employees met the minimum LEAP requirements. We were also unable 

to determine, because of inconsistent record keeping, whether employees 

complied with LEAP certification standards. 

Specifically, section K-4 of the Investigations Manual instructs Regional SACs 

to maintain LEAP Worksheet and Certification forms for 3 years. Section F of 

the manual contradicts these instructions by stating that Regional SACs 

should maintain the records for only 1 year. One of the four field offices we 

visited could not provide any records regarding LEAP. Another field office was 

able to provide annual certifications for a single year, and average daily LEAP 

calculations for 3 years. Two of the field offices we visited were able to provide 

all LEAP records and certifications for the reviewed period. Some SACs told us 

that LEAP records were maintained in a shared intranet site, but no one was 

able to locate LEAP records on the site. 

Title 5 USC § 5545a(d)7 stipulates that a criminal investigator shall be paid 

availability pay, if the annual average of unscheduled duty hours worked by 

the investigator is equal to or greater than 2 hours per regular work day. The 

law requires that each criminal investigator receiving availability pay and the 

appropriate supervisory officer make an annual certification to the head of the 

agency that the investigator has met, and is expected to meet, the 



7 Title 5 USC § 5545a, Availability pay for criminal investigators
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requirement.8 CGIS could not provide documentation to show that all 

applicable employees consistently met either of these requirements. 

Recommendations 

11. We recommend the CGIS Director determine the appropriate amount of 

time for the maintenance of LEAP records and clarify contradictory policy 

regarding the same. 

12. We recommend the CGIS Director ensure that LEAP eligible employees 

maintain an annual average of unscheduled duty hours equal to or greater 

than 2 hours per regular work day. We further recommend that the CGIS 

Director ensure LEAP eligible employees certify initially and on an annual 

basis that they have met and will continue to meet the minimum LEAP 

requirements per Title 5 USC § 5545a(d). 

Training 

CGIS could not provide documentation showing that employees consistently 

met all training requirements during the reviewed period. The Investigations 

Manual makes multiple references to “agent’s headquarters training records,” 

but we were told that CGIS headquarters does not require field offices to report 

individual training to headquarters. CGIS headquarters provided some records 

from the Training Management Tool centralized system. However, CGIS field 

offices are not required to enter information into the system, making that data 

inconsistent and unreliable. 

In attempting to assess compliance with semi-annual pistol qualification 

requirements for the period inspected, we learned that CGIS does not maintain 

records in a centralized location. The records are instead maintained at 

individual SAC offices in varying formats and for varying periods. For example, 

some offices maintained records for multiple years while one office was only 

able to provide qualification records for 1 year. Although not able to assess full 

compliance with semi-annual pistol qualification requirements, we determined 

that firearms instructors in the offices we visited were vigilant in ensuring that 

applicable personnel met qualification requirements. For instance, firearms 

instructors maintained meticulous regular training schedules. 

We encountered similar challenges in assessing compliance with shotgun and 

rifle qualification requirements. CGIS staff informed us that criminal 

investigators could determine for themselves whether they wanted to qualify 

and use either weapon. The Investigations Manual states, “Special Agents will 

re-qualify semi-annually in order to remain eligible to utilize [12-gauge 

shotguns].” The manual does not set requirements for qualification with the 



8 5 USC § 5545a(e)(1)
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rifles that we observed in CGIS’ inventory. CGIS staff told us that they apply 

the same training requirements to both weapons. It was not clear to us, given 

the documentation available, that the agency had adequate controls over who 

qualified and was eligible to use these weapons. This may increase risk for 

CGIS when assigning roles and equipment for tactical law enforcement 

operations, such as search warrants, or responding to emergencies, such as an 

active threat situation. 

CGIS could not provide documentation showing that agents received periodic 

legal updates or defensive tactics training during the inspected period. Only 

one office had records of Federal Aviation Administration Flying Armed training 

and one office provided a memorandum verifying eight agents received use-offorce training in 2014. Similarly, we found no corresponding policies asserting 

that this training should be conducted on a recurring basis, contrary to 

common practice in DHS. The Investigations Manual mandates that “special 

agents receive training in the Coast Guard’s Use-of-Force policy prior to being 

issued a Coast Guard weapon...” but does not mandate periodic training.9

CGIS management reported that they have begun providing this training to 

agents on a recurring basis. They additionally informed us that they are writing 

policies associated with our observations. 

Although CGIS is not directly subject to CIGIE directives, it states on their 

website that CGIS follows CIGIE’s guidance on training. CIGIE’s Quality 

Standard for Investigations provides that firearms familiarization and 

qualification should be conducted on a quarterly basis and the guidelines 

recommend the following:10

Periodic Training Requirements—periodically train criminal Investigators 

on effective and appropriate use of force and constitutional law and other 

topics articulated in the Attorney General Guidelines or other 

authoritative guidelines. 

 Additional topics to consider are new laws and court decisions affecting 

 operations; technological improvements; and any changes in agency and 

 national level policies, procedures, rules, and regulations (e.g., 

 Transportation Security Administration (TSA) training on “flying while 

 armed”). 

All post-basic training should be part of a systematic, progressive, and 

documented plan to maintain the requisite knowledge, skills, and 

abilities. Deliver such training depending on the organization’s needs and 

mission requirements. The frequency and nature of such training may be 



9 Coast Guard Investigations Manual, COMDTINST M5527, Section 6-J-7, Use-of-Force Training 

Policy, pp. 6-21.

10 CIGIE Quality Standard for Investigations, Periodic Training Requirements, p. 6
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adjusted depending on whether the investigator is in a primary or 

secondary position. 

 

 Policies should determine the frequency of, and ensure compliance 

 with, its recurring and periodic training, which, absent unique 

 circumstances, should not exceed 3 years. 

While conducting the workforce assessment, we learned that most CGIS 

employees were satisfied with the quality of training they received. However, we 

heard mixed views on employee satisfaction with the amount of training they 

received. Some employees noted the need for agents to attend training in 

advanced investigative techniques or specialty areas. Several employees voiced 

concerns that limited training in specialty areas put them at a disadvantage for 

promotions. These employees stated that CGIS agents cannot compete with 

better-trained agents from other agencies. Some employees noted difficulty in 

getting access to training because of limited availability, especially for 

reservists. Other employees noted difficulties in obtaining approval for external 

training because of budget constraints. 

Recommendations 

13. We recommend the CGIS Director develop a structured training program to 

include:

x oversight to ensure appropriate compliance with all training 

requirements;

x policies and procedures to ensure all law enforcement personnel 

periodically qualify on all issued firearms and all weapons (shotguns, 

rifles) accessible through their posts of duty; 

x policies and procedures regarding the proper documentation of all 

training to ensure compliance with basic, post-basic, recurring, and 

periodic training requirements; and 

x policies and procedures regarding periodic training requirements for 

use of force, and essential law enforcement areas, such as legal 

updates, arrest techniques, defensive tactics, flying while armed, and 

intermediate weapons. 

Firearms and Ammunition 

We inspected the CGIS firearms and ammunition stored at the four field offices 

we visited as well as CGIS Headquarters. We also inspected 48 firearms 

assigned to personnel at those locations. We were able to match all but three 

inspected firearms to office inventory records. Two agents had weapons with 

serial numbers not listed on their offices’ inventory records because they were 
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newly assigned to the office. One agent showed us a weapon with a serial 

number that differed from what was on the office inventory. Additionally, we 

found an unassigned shotgun stored in the headquarters safe that belonged to 

a field office and two unassigned rifles. Although stored in a safe, the weapons 

were not assigned to an individual with oversight responsibility, and the safe 

was accessible to at least two people. This could pose a serious inventory 

control issue. 

We also learned from CGIS Headquarters staff that most special agents are 

assigned two pistols. Some of the agents we talked to elected to carry only one. 

Some opted not to take possession of the second weapon while others obtained 

the second weapon, secured it, but did not carry it. The practice of assigning a 

second weapon to agents who do not intend to carry them may lead to 

problems with accountability and is a waste of agency resources. 

Additionally, we observed instances where agents who were assigned two 

weapons only qualified with one of them. We found that CGIS did not have a 

policy in place to ensure that agents who were assigned two weapons qualified 

with them in accordance with agency policy. 

We also learned from CGIS senior management that three handguns had been 

lost over the inspected period. All three occurrences were documented 

appropriately. 

Ammunition 

We examined and verified inventories for the ammunition on-hand at each field 

office we visited. We were able to account for all ammunition assigned to the 

field offices. The office firearms instructor maintained the ammunition and 

inventory logs at each office. Each instructor inventoried the ammunition at 

least monthly; some conducting inventories after every use. 

A recurring issue we heard from the firearms instructors was that there was 

not enough ammunition provided to maintain quarterly training requirements. 

The Investigative Manual mandates that “regional SACs are to maintain a 

quarterly firearms training program.”11 CGIS staff reported they do not receive 

enough ammunition to conduct quarterly training and routinely do not have 

enough to rotate the ammunition carried by agents. Some agents reported 

being concerned that they have not been issued new ammunition in several 

years. CGIS senior management acknowledged that this was a problem that 

affected the field offices’ ability to complete required quarterly firearms training. 

Recommendations 



11 Coast Guard Investigations Manual, COMDTINST M5527, Section 6-J-5, Weapons Training 

and Qualifications, p. 6-20
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14. We recommend the CGIS Director ensure that all firearm inventories are 

updated as changes occur, and the appropriate firearms custodian secures 

all unassigned weapons. 

15. We recommend the CGIS Director evaluate the practice of assigning two 

handguns to every agent. We further recommend that if the CGIS Director 

continues to assign two handguns per agent, he implement policies to 

ensure that agents only carry weapons with which they have qualified. 

16. We recommend the CGIS Director ensure that agents have enough 

ammunition to comply with quarterly firearms training requirements, and 

to rotate ammunition carried in their duty weapons on at least a bi-annual 

basis. 

Property 

Overall, we found that the field offices we visited conducted the required 

property inventory but did not maintain property in an organized manner. 

Although we ultimately located most items, we noted uncertainty in each office 

as to where items were physically located. 

During our field office property inspections, we noted that each office had a 

designated property/technical equipment coordinator. Additionally, each of the 

offices had completed a property inventory in the past year, as required. One 

office noted that property was stolen, and the office appeared to have taken 

measures to appropriately report the issue. We also found minor security 

issues with storage. One of the field offices stored some accountable property in 

a closet that did not lock. 

The types of property and technical equipment we reviewed included law 

enforcement and information technology equipment. We inventoried items on 

hand and compared that with CGIS property reports. Overall, the offices 

maintained most of the property that appeared on the reports. There were 

instances where an inspected office transferred property, but the items 

remained on the inventory records. Although we ultimately located most items, 

in some cases, it took several days to find outstanding items. One office had 

several items that employees were unable to locate. Some of the inventory 

problems may have occurred due to a recent office move. 

Recommendations 

17. We recommend the CGIS Director ensure field offices maintain an 

organized and updated property inventory system that would support a 

timeline for updating inventory records once items have been transferred 

or removed from an office. 
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18. We recommend the CGIS Director require all equipment not assigned to 

individuals be stored in a locked area with limited access. 

Confidential Funds and Informants 

When discussing confidential funds with Headquarters personnel and field 

office staff, we learned that both are concerned with the small amount of 

funding for the program. In addition, CGIS uses an office debit card program 

that streamlines confidential fund payments, but it is costly to maintain. 

Although all field offices have a confidential funds custodian, not all offices had 

an alternate confidential funds custodian. Lastly, three of the four field offices 

we visited had active confidential informants during the inspected period, with 

two of those offices missing required paperwork for their informants. 

Confidential Funds 

CGIS management informed us that per current legislation, CGIS confidential 

funds are to be “no more than $45,000 of appropriated funds.” They explained 

that this is not enough to fund all of the confidential informant work that CGIS 

conducts and reported that they spend all of the allocated funds every year. 

CGIS senior management speculated that they could have spent the entire 

allocation in the first couple of months of 2015 and 2016 if it were not for their 

process of highly scrutinizing each fund request. CGIS management is 

attempting to increase the funding amount through a proposed legislative 

change. 

In 2015, CGIS implemented an electronic procedure for processing confidential 

fund requests and payments. We consider the procedure to be a best practice 

in that it eliminates the need to keep cash on hand and requires all 

transactions to be approved by two individuals at CGIS Headquarters. 

However, we found the bank fees incurred by the agency seemed excessive 

given the amount of money involved and number of transactions. We also 

found one office did not have an alternate confidential funds custodian as 

required. This position is important in the event confidential funds are needed 

and the primary custodian is not available. 

 

In addition, we found only one instance in the selected transactions we 

reviewed where confidential funds were expended during the inspected period. 

The funds expended were for a payment to a confidential informant; however, 

the transaction was not properly documented on the required form. Without 

proper documentation, we were not able to validate whether the payment was 

made. 

Confidential Informants 
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Of the four field offices we visited, three had active confidential informants 

during the inspected period. Two of the inspected offices did not maintain all 

the paperwork required for these informants, to include the semi-annual 

suitability updates, the CGIS Agreements to Provide Information Form, and the 

CGIS Confidential Informant Program Provision Form. 

Recommendations 

19. We recommend the CGIS Director research banking options for the 

confidential fund account that incur fewer fees. 

20. We recommend the CGIS Director ensure all offices have a confidential 

funds custodian as well as an alternate. 

21. We recommend the CGIS Director ensure all confidential fund 

transactions are properly documented. 

22. We recommend the CGIS Director ensure all paperwork is complete for all 

confidential informants. 

Evidence Review 

The inspection team found that at the four CGIS field offices visited, evidence 

was stored in secured and locked locations with limited access, as required by 

Chapter 11 of the Investigations Manual. Some CGIS field offices also 

maintained a large amount of evidence at off-site locations due to limited 

storage space at the office. At least two of the off-site locations were movable 

trailers that are not suitable for the storage of evidence, as they cannot be 

properly secured. 

CGIS utilizes two types of evidence custody logs, the Property Evidence 

Custody Log and the Narcotics (controlled substances) Evidence Custody Log. 

The Evidence Custody Logs were designed to establish the necessary control 

and maintenance of evidence while under the control of CGIS and in 

conjunction with the Evidence Custody Form. Required information for the 

Evidence Custody Form includes article name and number, storage location, 

and submitting agent’s name. While verifying physical evidence against 

Evidence Custody Logs, we found a few instances where the evidence article 

name or case number was not included in the form as required. 

 

One of the field offices we visited used the FACTS evidence module to process 

and maintain evidence inventories. We found that the evidence reports from 

FACTS were incomplete. Specifically, the FACTS evidence reports cut off the 

action number and did not include a field for storage location, case number, or 

the most recent inventory date. We learned that the FACTS evidence module is 

not being utilized across the agency because CGIS has not received clearance 
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from the Coast Guard. CGIS purchased the necessary equipment to use the 

capability, but it is not able to implement it. An employee explained the module 

would make maintenance of evidence inventory much easier. 

All offices visited had assigned evidence custodians and maintained a chain of 

custody as required by the Investigative Manual. We found CGIS field offices, in 

most instances, documented their evidence inventories. Nevertheless, we noted 

that one office went more than 2 years between conducting inventories, even 

though the CGIS manual requires an inventory of evidence every 6 months. In 

addition, we found two instances where custodians did not update the logs 

when transferring evidence. 

As part of our inspection, we selected a sample of evidence at each field office 

we visited and physically verified its existence. In our review, we found evidence 

custodians did not always verify the contents of sealed evidence bags. In 

addition, we found evidence in unsealed or ripped bags. Specifically, one field 

office had two pieces of evidence in ripped bags. In another instance, we found 

an unsealed bag of narcotics and, upon handling it, found that the narcotics 

were falling out of the bag. 

During our inspections, we learned that custodians did not periodically weigh 

narcotics evidence as part of inventories. “Controlled substances must be 

logged by weight,” according to the Investigations Manual12; and it is a law 

enforcement best practice to reweigh narcotics during evidence inventory. 

Recommendations 

23. We recommend the CGIS Director ensure that all evidence is inventoried 

every 6 months as required. 

24. We recommend the CGIS Director ensure the Evidence Custody Logs 

contain the required information. 

25. We recommend the CGIS Director ensure the FACTS system has the 

necessary fields to input and readily view the required and essential 

information for evidence. 

26. We recommend the CGIS Director establish a transition plan before 

requiring CGIS locations to enter evidence into FACTS and provide 

employees with clear instructions on how to use the system for logging 

inventory to ensure consistent and accurate evidence record keeping 

across CGIS. 



12 Coast Guard Investigations Manual, COMDTINST M5527, Section 11-F-1, Evidence Storage, 

Shipment and Accountability, pp. 11-18.
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27. We recommend the CGIS Director ensure evidence, including narcotics, is 

properly sealed to protect the integrity of evidence. 

28. We recommend the CGIS Director revise guidance to ensure evidence 

custodians verify contents of evidence bags and weigh narcotics as part of 

the periodic inventory of evidence. 

29. We recommend the CGIS Director ensure that all evidence is secured in 

structures suitable for the storage of evidence. 

Investigations

Issues with FACTS impeded our review of CGIS’ investigative work. CGIS could 

not provide us a list of investigations worked during the inspected period so 

that we could obtain a representative sample to review. The list provided by 

CGIS included instances where CGIS had performed non-investigative duties. 

We ultimately reviewed 60 closed investigations. See Appendix A: Objective, 

Scope, and Methodology, for a full description on our case sample selection 

process. Because of limitations with the data in FACTS, we were not always 

able to make conclusive determinations about the areas studied. 

Overall, CGIS conducted investigations in an expedient manner. The average 

investigation in our sample was completed and referred to a higher authority 

within 116 days of initiation. However, there was some confusion among the 

people we spoke to regarding when an investigation was actually closed. Prior 

to 2012, an investigation would remain “open” until adjudication by area 

commanders, courts, or other authority. In 2012, CGIS determined that they 

would consider an investigation “closed” when initial investigative work was 

complete. They reasoned that the investigation at that point was no longer 

under CGIS’ control, and therefore, they should not be accountable for the time 

it took to process the case further. They also argued that CGIS was frequently 

not told when a case was finally adjudicated, and therefore, investigations 

appeared in an open status when in fact they had been closed. CGIS 

management reported that they have proposed giving applicable Coast Guard 

entities access to FACTS so they could document when a case is closed. 

The current practice of labeling an investigation closed after the initial 

investigation is complete does not accurately account for all investigative work 

done on a case. Frequently, prosecutors and other appropriate authorities ask 

CGIS investigators to conduct investigative work after an investigation is 

referred to them. In fact, we observed such examples in the sample we 

reviewed. The current practice also does not account for time investigators may 

spend briefing prosecutors or testifying at trial or other hearings. Because of 

this practice and the fact that CGIS does not collect information on the final 
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adjudication of a case, we were unable to evaluate the true length of time it 

took to process an investigation. 

We found that CGIS management actively participated in most investigations 

and continually conducted reviews of agents’ work. We observed that periodic 

reviews of investigations occurred in 40 of the 43 applicable cases. We could 

not determine whether such reviews had occurred in 17 cases because the 

information was not available in FACTS. 

CGIS did not conduct any Title III investigations during the inspected period. 

They did participate in such investigations with other law enforcement 

agencies. 

Due to the significant lack of information and documentation within FACTS, we 

could not accurately determine whether rights advisements were given in every 

applicable instance. For example, in 15 instances we found indications that 

subject interviews were conducted, but found no mention of whether rights 

advisements were given. Similarly, we did not find an executed rights 

advisement form uploaded into FACTS for these cases. 

Recommendations 

30. We recommend the CGIS Director evaluate the policy on when 

investigations are deemed to be closed to ensure that all investigative 

activity is completed prior to closing the investigation. 

31. We recommend the CGIS Director ensure that the proper rights 

advisements are given in every applicable instance and that such actions 

be documented in FACTS. 

Investigative Reports 

The inspection team found that CGIS does not produce comprehensive 

investigative reports. This made it difficult to assess whether an investigation 

was conducted thoroughly and whether all allegations were properly explored. 

A case report simply consisted of a summary paragraph and a collection of 

activity reports. In our observation, the summary paragraph was not 

standardized and typically did not provide a detailed summation of the facts 

and findings of the case. Several summary paragraphs we saw were only one or 

two sentences long and did not annotate the final disposition of the 

investigation. 

As a best practice, CIGIE provides the following guidelines, in part, for 

investigative reports: 
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 1. In any report, the facts should be set forth to facilitate reader 

 comprehension. This should include a clear and concise statement of the 

 facts and applicable law, rule, or regulation that was allegedly violated or 

 that formed the basis for an investigation. 

 2. The principles of good report writing should be followed. A quality 

 report will be logically organized, accurate, complete, concise, impartial, 

 and clear and should be issued in a timely manner. 

 3. Reports should contain exculpatory evidence and relevant mitigating 

 information when discovered during any administrative investigation. 

 Exculpatory evidence in a criminal or civil investigation must be brought 

 to the attention of the assigned prosecutor. 

 4. Evidence outlined in a report should be supported by documentation 

 in the investigative case file. 

 5. In some cases, it may be appropriate to note specific allegations that 

 were not investigated to ensure that decision makers can take further 

 action as they deem appropriate. 

 6. The outcome or accomplishment (fines, savings, recoveries, 

 indictments, convictions, suspensions and debarments, or management 

 recommendations, etc.) should be documented in the file. 

Recommendation 

32. We recommend the CGIS Director ensure that comprehensive reports that 

comply with CIGIE guidelines are produced for each investigation. 
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Summary of Recommendations, CGIS Response, and OIG Analysis 

We recommend that the Director of CGIS: 

Recommendation #1: Issue policy to standardize and centralize the receipt 

and referral of allegations and ensure FACTS includes a field to capture when 

an allegation was referred to the OIG. 

CGIS Response: Concur. CGIS is reviewing [its] policies and allegation receipt 

processes to ensure that FACTS includes a field to indicate when an allegation 

has been referred to the OIG. The current business intelligence system built 

into the CGIS Records Management System (RMS) does provide ability to locate 

cases that either originated from the OIG (e.g., came into the OIG hotline and 

were referred to CGIS by the OIG) or originated within the USCG but require 

notification to the OIG because of their nature. [CGIS concurred] that the 

creation of a specific searchable field in the RMS would enhance the search 

function for these cases and CGIS will work to incorporate that function in the 

FACTS upgrade. Estimated Completion Date (ECD): September 30, 2017. 

OIG Analysis: CGIS’ response only partly addresses the recommendation. 

Although the recommendation adequately addresses the issue with FACTS, it 

does not explain what CGIS intends to do regarding standardizing the process 

of receiving and referring allegations. This recommendation is open and 

unresolved pending further action by CGIS. 

Recommendation #2: Articulate in policy what constitutes an OIG-referable 

allegation, train all necessary staff accordingly, and ensure that CGIS refers the 

requisite allegation to the OIG. 

CGIS Response: Concur. While CGIS works to closely follow the terms of the 

Memorandum of Understanding (MOU) with OIG, CGIS agrees to develop an 

appropriate policy statement implementing the guidance provided in the MOU 

and will conduct appropriate training on that policy. ECD: June 1, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. We will close this recommendation 

when CGIS provides evidence that they have issued appropriate policy and 

conducted training accordingly. 

Recommendation #3: Provide a quarterly report to the OIG describing the 

status of all open Hotline Complaint investigations as mandated by the MOU. 

CGIS Response: Concur. CGIS concurs that a quarterly report would improve 

the communications between CGIS and OIG regarding the status of Hotline 

Complaint investigations and will develop such a report. ECD: June 30, 2017. 
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OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. We will close this recommendation 

when CGIS provides evidence that they have developed the mandated report. 

Recommendation #4: Follow the requirements to administer the DEOCS on 

an annual basis. We further recommend the CGIS Director develop and 

implement a corrective action plan to address concerns learned through the 

DEOCS. 

CGIS Response: Concur. The CGIS Deputy Director of Mission Support has 

specifically requested a DEOCS survey and will encourage employee 

participation from [its] active duty, reserve, and civilian workforce. CGIS will 

develop and execute a corrective action plan as necessary based on the survey 

results. ECD: September 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. We will close this recommendation 

when CGIS provides evidence that they have administered the survey and 

developed a corrective action plan as necessary. 

Recommendation #5: Conduct an analysis to determine whether CGIS agents 

are compensated consistent with their peers within DHS and make changes as 

necessary. 

CGIS Response: Concur. Prior to the OIG inspection, CGIS requested an 

analysis to identify skill gaps, analyze compensation, and build staffing models 

to address this recommendation. CGIS is actively engaged with the Coast 

Guard Assistant Commandant for Human Resources (CG- I) to finalize this 

analysis and will implement corrective actions as necessary pending the 

results. ECD: October 31, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. We will close this recommendation 

when CGIS provides evidence of their analysis and subsequent action. 

Recommendation #6: Consult with the Coast Guard Directives and 

Publications Division, CG-612, and replace the existing Coast Guard 

Investigations Manual with a document that complies with Systems Manual 

requirements. 

CGIS Response: Concur. CGIS has assigned a senior special agent (GS-14) as 

the Assistant Director for Policy (ADP) to update the Investigations Manual. 

Since 2015, the ADP has periodically issued operating procedures which 

supersede various provisions of the Investigations Manual. This system of 

periodic updates, whether by Director's Note, Criminal Investigation Operating 

Procedure, or Mission Support Operating Procedure, is fully consistent with the 

Coast Guard's Directives and Publication System. To improve CGIS’ awareness 
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of the updates, the ADP intends to submit a Commandant's Change Notice 

informing subordinate CGIS commands of all changes that have occurred since 

2015. Additionally, CGIS intends to coordinate with CG-612 and Force 

Command (FORCECOM) to issue a revised Commandant Instruction Manual 

on Investigations and promulgate operating procedures as techniques, tactics, 

and procedures (TTP) in accordance with FORCECOM guidance. ECD: 

September 30, 2018. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. We will close this recommendation 

when CGIS provides evidence of their notification to CGIS commands and the 

publication of a revised manual. 

Recommendation #7: Continue to update investigative policy and follow the 

Coast Guard clearance process outlined in M5215.6 prior to issuing new 

policy. 

CGIS Response: Concur. As noted during the inspection, the CGIS 

Investigations Manual was last updated in 2001 and requires modernization. 

From 2001 until 2013 the manual was revised via "Director's Notes". Starting 

in 2014, CGIS committed significant resources to updating the manual and 

created a full-time Assistant Director for Policy (ADP) in 2015. The ADP is in 

the process of submitting a Commandant's Change Notice informing 

subordinate CGIS offices of all changes, Standard Operating Procedures (SOP) 

and Director's Notices (DN) that are in effect. The ADP also updates policies 

and SOPs in a deliberative and ongoing process in coordination with CG-612, 

Force Command (FORCECOM), and the CGIS embedded legal counsel. 

The ADP will issue a revised Investigations Manual and continue to promulgate 

operating procedures as techniques, tactics, and procedures (TTP) in 

accordance with FORCECOM guidance. ECD: September 30, 2018. 

OIG Analysis: Although CGIS’ response meets the intent of this 

recommendation, we caution that the continued practice of issuing Director’s 

Notes and Standard Operating Procedures without storing them in a central 

location will continue to cause confusion among staff. This recommendation is 

open and resolved. We will close this recommendation when CGIS provides 

evidence of their notification to CGIS commands, the publication of a revised 

manual, and communication with CG-612 and USCG (not CGIS) legal counsel. 

Recommendation #8: Ensure that a Privacy Impact Assessment is conducted 

for FACTS and that all related requirements are properly addressed. 

CGIS Response: Concur. Prior to the implementation of FACTS, a Privacy 

Impact Assessment (PIA) was conducted for MagNET, the information 

technology system that FACTS resides on. At that time it was not realized that 

an additional PIA was required for FACTS itself; however, prior to the DHS 
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OIG inspection, the Coast Guard Assistant Commandant for Intelligence (CG-2) 

and CGIS began to re-examine the privacy implications of FACTS as a database 

and have initiated a review, including a PIA to ensure all related privacy 

protections and requirements are properly addressed. ECD: June 21, 

2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. We 

urge CGIS to make fulfillment of this recommendation a top priority due to the 

sensitive nature of the information stored on FACTS. This recommendation is 

open and resolved. We will close this recommendation when CGIS provides 

evidence that a PIA was conducted for FACTS. 

Recommendation #9: Develop and publish a policy manual for FACTS to 

standardize, at a minimum, what fields must be completed and the type of 

information needed in each field. 

CGIS Response: Concur. CGIS has developed and published a FACTS User 

Manual which is now available to all FACTS users via a SharePoint website. 

CGIS continues to update and adjust the FACTS manual as changes to the 

system are implemented. The Coast Guard requests closure of this 

recommendation as the policy manual for FACTS was officially released on 

October 6, 2016. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is closed and resolved. 

Recommendation #10: Provide training to FACTS users on navigating the 

system and policy requirements. 

CGIS Response: Concur. CGIS conducted extensive training during the roll-out 

of the FACTS system in 2014 and continues to conduct regular refresher 

training. The FACTS system was implemented by CGIS field agents (the Core 

Team); they designed and implemented the requirements. Prior to the system 

going live, CGIS held train-the-trainer sessions with 10-15 agents per class on 

12-16 May 2014, 19-23 May 2014, 27-30 May 2014, 2 June 2014, and 9 June 

2014. Select agents from each region attended this course and then served as 

embedded trainers to visit/train reserve members as well as the various field 

officers within their regions. In addition, in October 2014, CGIS commenced inservice training for agents on a recurring basis. The in-service training 

program, which reaches one quarter of the total CGIS work force each year, 

includes a FACTS training element. ECD: October 31, 2017. 

OIG Analysis: CGIS’ response does not meet the intent of this recommendation. 

This recommendation stems from direct observations and conversations with 

FACTS users, and CGIS should consider conducting a skills assessment and 

then tailoring training accordingly. This recommendation is open and 
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unresolved. The recommendation will remain open until CGIS confirms that it 

has provided sufficient FACTS related training to all FACTS users. 

Recommendation #11: Determine the appropriate amount of time for the 

maintenance of LEAP records and clarify contradictory policy regarding the 

same. 

CGIS Response: Concur. CGIS policy, as directed in the Investigations Manual, 

COMDTINST M5527.lB, states that it is the responsibility of the Regional SACs 

to maintain accurate records of LEAP hours worked by civilian agents. Regional 

SACs are to maintain the LEAP Worksheet and Certification forms for three 

years, after which they may be destroyed. Deputy Director, CGIS shall 

maintain the LEAP Worksheet and Certification forms for civilian special agents 

assigned to CGIS Headquarters for the same time period. On 04 June 2014 

CGIS issued a clarification of the LEAP records documentation policy via 

Director's Note 2014-5. The Director will further clarify the three year retention 

policy via a 2017 Director's Note. ECD: April 1, 2017. 

OIG Analysis: CGIS’ response partially meets the intent of this 

recommendation; further clarification and instruction should be made to the 

Regional SACs regarding the records retention period for LEAP data. This 

recommendation is open and unresolved. The recommendation will remain 

open until CGIS provides evidence that they have issued a policy clarification 

and can demonstrate that CGIS management is maintaining LEAP data and 

certifications for all LEAP-eligible employees. In addition, we advise CGIS to 

update their estimated completion date for this recommendation, as it has not 

been fully implemented. 

Recommendation #12: Ensure that LEAP eligible employees maintain an 

annual average of unscheduled duty hours equal to or greater than 2 hours per 

regular work day. We further recommend that the CGIS Director ensure LEAP 

eligible employees certify initially and on an annual basis that they have met 

and will continue to meet the minimum LEAP requirements per title 

5 USC § 5545a(d). 

CGIS Response: Concur. CGIS LEAP-eligible employees maintain an annual 

average of unscheduled duty hours equal to or greater than two hours per 

regular work day. LEAP eligible employees certify initially and on an annual 

basis that they have met and will continue to meet the minimum LEAP 

requirements per Title 5 USC§ 5545a(d). On 04 June 2014, CGIS issued 

Director's Note 2014-5 clarifying that all civilian agents who are eligible to 

receive Law Enforcement Availability Pay (LEAP) are required to utilize the 

following documents for the administration of LEAP: 

 1) Initial Certification of Availability Pay, CGIS-7230-a 

 2) Availability Pay Bi-Weekly Time Sheet, CGIS-7230b 

 3) Annual Certification, CGIS-7230c 
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The Director will clarify the minimum two hours per regular workday 

requirement via a 2017 Director's Note. ECD: April 1, 2017. 

OIG Analysis: CGIS’ response generally meets the intent of this 

recommendation. However, in addition to clarifying the minimum two hours 

per regular workday requirement, the Director should also remind all 

applicable staff of their obligation to submit the required certifications. 

Throughout the course of our review, neither CGIS management nor field office 

management were able to provide documentation ensuring all LEAP-eligible 

employees were complying with all LEAP requirements. This recommendation 

is open and unresolved. The recommendation will remain open until CGIS 

provides evidence that they have issued a policy clarification. 

Recommendation #13: Develop a structured training program to include: 

x oversight to ensure appropriate compliance with all training 

requirements; 

x policies and procedures to ensure all law enforcement personnel 

periodically qualify on all issued firearms and all weapons 

(shotguns, rifles) accessible through their posts of duty; 

x policies and procedures regarding the proper documentation of all 

training to ensure compliance with basic, post-basic, recurring, 

and periodic training requirements; and 

x policies and procedures regarding periodic training requirements 

for use of force, and essential law enforcement areas, such as legal 

updates, arrest techniques, defensive tactics, flying while armed, 

and intermediate weapons. 

CGIS Response: Concur. CGIS concurs with the need for a well-structured, 

comprehensive training program for all CGIS law enforcement personnel. CGIS 

staff is currently drafting policy and procedures compliant with the Coast 

Guard Directives Systems Manual, COMDTINST M5215.6H, which are 

designed to address: 

x Define roles and responsibilities for CGIS required training and training 

records management. 

x Standardize and require the use of the Training Management Tool (TMT) 

for recording completion of all training. 

x Establish a standardized and centrally managed training program. 

x Establish standards for periodic inspection and evaluation of CGIS 

regional training program execution. 

x Ensure all required training is accomplished and recorded. 
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On 18 October 2016, CGIS Assistant Director for Training submitted a request 

for creation of a Special Agent competency in TMT. ECD: September 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they have created a structured training 

program. 

Recommendation #14: Ensure that all firearm inventories are updated as 

changes occur, and the appropriate firearms custodian secures all unassigned 

weapons. 

CGIS Response: Concur. CGIS is in the process of conducting the Annual 

Firearms Inventory required by Coast Guard regulations. This procedure 

ensures up to date inventories are recorded and verified. Additionally, per the 

Ordnance Manual, COMDTINST M8000.2E, local firearm custodians are 

required to conduct regular maintenance of local firearms inventories, to be 

verified via the Annual Firearms Inventory. All CGIS weapons (e.g., shotguns, 

rifles) that are unassigned are secured in appropriate controlled access 

containers. ECD: April 1, 2017. 

OIG Analysis: CGIS’ response partially meets the intent of this 

recommendation. As stated in the report, we found instances of firearms 

inventories that had not been updated as changes occurred. Thus, we 

recommend CGIS implement additional guidance, outside the annual firearms 

inventory verifications, to ensure firearms inventories are updated as needed. 

This recommendation is open and unresolved. The recommendation will remain 

open until CGIS provides evidence that they have conducted the annual 

firearms inventory, reconciled any discrepancies, and communicated a policy 

for updating firearms inventories on an as needed basis. 

Recommendation #15: Evaluate the practice of assigning two handguns to 

every agent. We further recommend that if the CGIS Director continues to 

assign two handguns per agent, he implement policies to ensure that agents 

only carry weapons with which they have qualified. 

CGIS Response: Concur. Prior to the onset of the inspection, CGIS chartered a 

working group to evaluate the practice of assigning two handguns to every 

agent and is in the process of identifying a single standard duty firearm. The 

working group is scheduled to report recommended Courses of Action 

(COA) to the Director by 31 March 2017. Until that process is complete, CGIS 

policy requires that agents only carry the weapons with which they have 

qualified. ECD: March 31, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 
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until CGIS provides evidence that they have evaluated the practice of assigning 

two handguns to every agent. 

Recommendation #16: Ensure that agents have enough ammunition to 

comply with quarterly firearms training requirements, and to rotate 

ammunition carried in their duty weapons on at least a bi-annual basis. 

CGIS Response: Concur. Unlike other DHS components, CGIS is not 

authorized to directly purchase ammunition. CGIS agents are issued sufficient 

ammunition (over 54,000 rounds in FY2017, approximately 140 rounds per 

agent per year) to comply with quarterly firearms training requirements. As a 

component of the Coast Guard, CGIS complies with ordnance inventory 

requirements imposed by the Department of Defense, known as the NonCombat Expenditure Allowance (NCEA) for ammunition. Each CGIS agent is 

allocated .40 caliber ball ammunition in order to maintain firearms 

qualifications and sufficient duty ammunition (.40 caliber, jacketed hollow 

point (JHP)) in order to rotate ammunition carried in their duty weapons on an 

annual basis. Duty ammunition is expended on a "first in/first out" basis as 

required to maintain weapon functionality and officer safety. Request closure 

as implemented. 

OIG Analysis: CGIS’ contention that they have sufficient ammunition to comply 

with quarterly firearms training requirements and rotate ammunition carried 

by investigators is contrary to what was reported to us by firearms instructors. 

Additionally, the calculations provided by CGIS in their response appear to 

show that CGIS has 386 employees who are assigned weapons (54,000/140), 

although records provided to us during the review suggest that 386 is the total 

number of all CGIS employees. At a minimum, to calculate the ammunition 

needed, CGIS should multiply the number of weapons assigned by the amount 

of bullets needed to satisfy quarterly training requirements. We recommend 

CGIS research the issue further and make adjustments as needed. This 

recommendation is open and unresolved. The recommendation will remain 

open until CGIS provides evidence that they have evaluated this issue further. 

Recommendation #17: Ensure field offices maintain an organized and 

updated property inventory system that would support a timeline for updating 

inventory records once items have been transferred or removed from an office. 

CGIS Response: Concur. In accordance with Coast Guard regulations, CGIS 

units are required to conduct annual inventories of all Coast Guard issued 

property and must account for any lost, transferred, or surveyed property and 

equipment. CGIS plans to implement routine, periodic inspections where 

SACs will review property inventories and equipment assigned within their 

respective Regional offices against maintained property lists. These inspections 

will augment the currently conducted annual inventories. Additionally, the 

CGIS Deputy for Mission Support will conduct random reviews of property, 
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evidence, and confidential informant records via on-site visits beginning 

Summer 2017. ECD: December 31, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they implemented the process described in 

their response. 

Recommendation #18: Require all equipment not assigned to individuals be 

stored in a locked area with limited access. 

CGIS Response: Concur. CGIS equipment that is not assigned to an 

accountable individual will be stored in locked areas with limited access. 

OIG Analysis: CGIS fully implemented this recommendation prior to our receipt 

of management comments to the report. Their actions meet the intent of our 

recommendation, and therefore, the recommendation is closed and resolved. 

Recommendation #19: Research banking options for the confidential fund 

account that incur fewer fees. 

CGIS Response: Concur. CGIS concurs with the recommendation's intent to 

use banking services that incur fewer fees; however, CGIS is not authorized to 

enter into a separate banking agreement because DHS recently entered into an 

interagency agreement directing the use of MetaBank for debit cards 

starting in June 2017. Request closure of this recommendation. 

OIG Analysis: We will evaluate the noted interagency agreement and make a 

determination as to the status of this recommendation at a later date. In the 

interim, we recommend that CGIS inquire of other law enforcement entities 

within DHS, to include DHS OIG, as to what banking methods they are using 

to maintain confidential fund accounts. This recommendation is open and 

unresolved. 

Recommendation #20: Ensure all offices have a confidential funds custodian 

as well as an alternate. 

CGIS Response: Concur. CGIS has designated a primary and alternate 

confidential funds custodian for all regional offices. Request closure as 

implemented. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they have assigned primary and alternate 

confidential funds custodians for all regions. 

Recommendation #21: Ensure all confidential fund transactions are properly 

documented. 
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Response: Concur. CGIS is in the process of hiring a dedicated Confidential 

Informant Program Manager (GS-1811-13, Secondary Law Enforcement 

Position). This individual will manage, train, and oversee the financial records 

and transactions of the CGIS Confidential Informant program. ECD: September 

30, 2017. 

OIG Analysis: Although hiring a dedicated confidential informant program 

manager will further the intent of this recommendation, CGIS can take 

immediate steps to ensure that all confidential fund transactions are 

documented according to policy. This recommendation is open and unresolved. 

The recommendation will remain open until CGIS presents a plan to ensure 

that all confidential fund transactions are properly documented. 

Recommendation #22: Ensure all paperwork is complete for all confidential 

informants. 

CGIS Response: Concur. CGIS is in the process of hiring a dedicated 

Confidential Informant Program Manager (GS-1811-13, Secondary Law 

Enforcement Position). This individual will manage, train, and oversee the CGIS 

Confidential Informant program in its entirety. ECD: September 30, 2017. 

OIG Analysis: Although hiring a dedicated confidential informant program 

manager will further the intent of this recommendation, CGIS can take 

immediate steps to ensure that all documentation is complete for all 

confidential informants. This recommendation is open and unresolved. The 

recommendation will remain open until CGIS presents a plan to ensure that all 

required documentation is complete for all confidential informants. 

Recommendation #23: Ensure that all evidence is inventoried every 6 months 

as required. 

Response: Concur. CGIS will institute policy requiring SACs to inspect and 

verify their respective region's compliance with evidence inventory 

requirements and Assistant Directors for Operations will ensure completion 

every 6 months. ECD: June 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they instituted the noted policy. 

Recommendation #24: Ensure the Evidence Custody Logs contain the 

required information. 
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CGIS Response: Concur. As part of the resolution to Recommendation #26, the 

FACTS working group will recommend corrective actions and CGIS will 

implement updates to FACTS that will ensure complete and standardized 

Evidence Custody Logs. ECD: September 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they implemented the requisite updates to 

FACTS. 

Recommendation #25: Ensure the FACTS system has the necessary fields to 

input and readily view the required and essential information for evidence. 

CGIS Response: Concur. As part of Recommendation #26, the FACTS system 

upgrade will address this recommendation. ECD: September 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they implemented the requisite updates to 

FACTS. 

Recommendation #26: Establish a transition plan before requiring CGIS 

locations to enter evidence into FACTS and provide employees with clear 

instructions on how to use the system for logging inventory to ensure 

consistent and accurate evidence record keeping across CGIS. 

CGIS Response: Concur. A FACTS working group was convened in September 

2016 to address policies, procedures, and proposed upgrades to FACTS. In 

addition, the group has been tasked with identifying best practices for 

processing evidence inventories to include resolution of incomplete data fields. 

ECD: September 30, 2018. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they implemented the requisite updates to 

FACTS. 

Recommendation #27: Ensure evidence, including narcotics, is properly 

sealed to protect the integrity of the evidence. 

CGIS Response: Concur. The discrepancies noted during the OIG review were 

addressed and corrected on site. In the future, all evidence inventories and 

policy compliance will be monitored by the Regional Special Agent in Charge 

during semi-annual Office Inspections. Regional Office policy compliance and 

evidence inventories will be further evaluated and verified during scheduled 

CGIS Headquarters site visits. Request closure as implemented. 
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OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they have instituted the policy noted in their 

response to recommendation 23. 

Recommendation #28: Revise guidance to ensure evidence custodians verify 

contents of evidence bags and weigh narcotics as part of the periodic inventory 

of evidence. 

CGIS Response: Concur. Additional guidance and clarification of proper 

custodial techniques and best practices identified during the inspection were 

shared with the TRADET staff to incorporate into future refresher training. All 

evidence inventories and policy compliance will be monitored by the 

Regional Special Agent in Charge during semi-annual Office Inspections. 

Regional Office policy compliance and evidence inventories will be further 

evaluated and verified during scheduled CGIS Headquarters site visits. Request 

closure as implemented. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that they have instituted the policy noted in their 

response to recommendation 23. 

Recommendation #29: Ensure that all evidence is secured in structures 

suitable for the storage of evidence. 

CGIS Response: Concur. All CGIS evidence is secured in locked enclosures 

with controlled access. There is one instance of evidence from an Oily Water 

Separator/illegal dumping case (e.g., plastic tubing and rubber hoses) that is 

stowed in a locked storage trailer due to the fact that the evidence is 

contaminated with volatile petroleum remnants. The items in this secured 

trailer relate to a case that has already been successfully prosecuted, and CGIS 

has sought to dispose of the property but has been directed by the USAO's 

office to maintain the property should the defendant violate the terms of his 

probation. This locked trailer is co-located with other CG storage trailers and 

containers guarded within the Coast Guard Yard, Baltimore, MD. Request 

closure as implemented. 

OIG Analysis: During our review, we found three offices that stored evidence in 

off-site locations. Two of the three locations were movable trailers that were not 

suitable for the storage of evidence. The fact that the USAO’s office directed 

CGIS to maintain the property reemphasizes the importance of storing it in a 

suitable manner. Also, the trailers being co-located with other CG trailers that 

are within the perimeter of a CG instillation does not mitigate the fact that they 

are movable containers and accessible to others. We recommend that CGIS find 

a secure location to store evidence. This recommendation is open and 

unresolved. 
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Recommendation #30: Evaluate the policy on when investigations are deemed 

to be closed to ensure that all investigative activity is completed prior to closing 

the investigation. 

CGIS Response: Concur. CGIS has reviewed the applicable FACTS policy, 

which makes a distinction between "Closed" and "Closed- Referred." A "Closed" 

case is the final closure with all CGIS investigative actions complete, while a 

"closed-referred" indicates that CGIS has completed all investigative actions 

and referred the case to the affected command. This allows CGIS to accurately 

account for the investigative time committed to each investigation, while not 

counting time during which a referred case is reviewed by either Legal or the 

individual Command. Request closure as implemented. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is closed and resolved. 

Recommendation #31: Ensure that the proper rights advisements are given in 

every applicable instance and that such actions are documented in FACTS. 

CGIS Response: Concur. CGIS policy directs that proper rights advisements be 

given and entered into FACTS. As part of the future FACTS upgrade, a separate 

data field will be included to specifically "flag" this requirement in the 

investigative record. ECD: September 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that the intended future FACTS upgrade was 

implemented. 

Recommendation #32: We recommend the CGIS Director ensure that 

comprehensive reports that comply with CIGIE guidelines are produced for 

each investigation. 

CGIS Response: Concur. The development of additional reporting capabilities 

and "one button" printing functionality in FACTS is ongoing and will fully 

address this recommendation when complete. ECD: September 30, 2017. 

OIG Analysis: CGIS’ response meets the intent of this recommendation. This 

recommendation is open and resolved. The recommendation will remain open 

until CGIS provides evidence that the noted enhancements to FACTS were 

made and provide details on what the comprehensive reports will include. 
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Appendix A 

Objective, Scope, and Methodology 

The DHS OIG Office of Integrity and Quality Oversight, Investigations and 

Program Integrity Division, in keeping with the oversight responsibilities 

mandated by the Inspector General Act of 1978, as amended, examined CGIS 

operations to assess overall compliance with relevant DHS and USCG policies. 

The OIG last reviewed CGIS in February 2010 and published a report of their 

findings. We conducted our most recent review from April 2016 through 

November 2016. We conducted the onsite portions of our review in the months 

of June, July, and August 2016. We visited CGIS Headquarters in Washington, 

DC as well as the Baltimore RAC Office, Washington Field Office, Portsmouth 

Field Office, and Seattle Field Office. The review covered activity from October 

1, 2013 through March 31, 2016 (fiscal year 2014 through the end of the 

second quarter of fiscal year 2016). 

Prior to the site visits, the inspection team sent a pre-inspection survey to the 

CGIS Director asking for background information and any additional 

information that he wanted to share with the inspection team. The preinspection survey is designed to help the inspection team understand the types 

of investigations initiated, how CGIS handles classified information, the 

complexity of operations, and collateral duty assignments. The survey also 

allowed the Director to identify any known deficiencies with the office and 

request a review of particular areas. Additionally, prior to the site visits, we 

requested policies governing CGIS operations, an explanation of the complaint 

intake process, the number of employees assigned, and operational statistics. 

During our review period, CGIS closed 2,135 cases. This figure includes 

administrative investigations, criminal investigations, intelligence operations, 

OIG investigations, other agency support, and task force operations. The CGIS 

employee responsible for providing this data informed the inspection team that 

the list of closed cases should not have included cases categorized as 

“intelligence operations” because they are not investigations. Therefore, 

intelligence operations were removed from our list, leaving a total population of 

2,041 cases. CGIS was not able to accurately determine how many criminal 

investigations were included in the total population. Our sample therefore was 

bound to include cases that did not meet our scope. 

In determining our sample size, we referenced the CIGIE standards for random 

sampling. These standards state that for a random sample where the universe 

is over 500 cases, the sample size should be 50 cases. CGIS provided the 

inspection team with data spanning 3 fiscal years, which, on average, 

amounted to over 500 cases per year. We decided to exceed the sample size 

recommended by CIGIE and review a random sample of 150 cases (50 cases 

per year). 
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However, after working through the FACTS system for several days, it became 

clear that reviewing 150 cases would not be possible or beneficial given our 

limited time and resources. We chose to decrease our sample to 72 cases. For 

the purpose of our review, we were only interested in criminal investigations, 

and not all case types included in the original population. However, not all 

cases were properly marked with the case type, and it was unclear, even after 

reading the details of some cases, whether the case was properly categorized. 

Therefore, the quantifiable information we were able to ascertain does not 

apply to all cases reviewed. We determined that, of the 72 cases in our sample, 

only 60 cases were criminal in nature. 

During our site visits, we reviewed several administrative areas using 

checklists based on CGIS policies and CIGIE standards. The full list of areas 

reviewed is in appendix C. 

In an effort to conduct our workforce assessment, we reviewed and analyzed 

four different tools. We conducted in-person workforce assessment interviews, 

administered an electronic survey to all CGIS personnel nationwide, and 

reviewed and analyzed the results of the 2014 Defense Equal Opportunity 

Management Institute survey and the Federal Employee Viewpoint Survey 

results from 2013, 2014, and 2015. 

We met with employees at CGIS Headquarters and four field office locations 

and conducted workforce assessment interviews with all available employees. 

Our interviews gave employees the opportunity to discuss morale, best 

practices, availability of training, equipment, and any other concerns they 

wished to bring to the OIG’s attention. In addition, we also administered an 

electronic survey to all 386 employees at CGIS’ 47 offices, asking similar 

questions to the in-person interviewees in an effort to reach as many employees 

as possible. There were 126 respondents to the electronic survey, 46 of which 

provided written responses. We used the OMB MAX survey capability in order 

to make all survey responses anonymous. The survey included 17 questions 

with answer options ranging from strongly disagree to strongly agree and one 

free-form comment box at the end for employees to elaborate on any issues. 

In 2014, CGIS employees were provided the opportunity to participate in the 

DEOMI Organizational Climate Survey. One hundred and ninety five CGIS 

employees completed the survey, which accounted for roughly half of the CGIS 

workforce at that time. 

OMB conducts the FEVS each year to identify key strengths and current 

challenges facing government agencies. OMB sends the surveys to a random 

sampling of federal employees across the executive branch to measure 

employee engagement and satisfaction. The inspection team reviewed the FEVS 

results for CGIS for the reporting years of 2014-2016. CGIS averaged 

approximately 32 respondents annually over that period. The survey is over 80 
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total questions designed to gauge employee perceptions of their work 

experience with the agency. 
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Appendix B 

CGIS Response to the Draft Report 
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Appendix C 

Checklists and Questionnaires

x Case File Review Checklist 

x Confidential Funds Review Checklist 

x Confidential Informant Checklist 

x Electronic Intercept Checklist 

x Evidence Review Checklist 

x Field Office Operations Survey 

x Firearms/Ammunition Checklist 

x Property Inventory Checklist 

x Undercover Operations Checklist 

 
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Appendix D 

Major Contributors to This Report

x Francisco da Rosa, Director, Office of Integrity and Quality Oversight, 

Investigations and Program Integrity Division, OIG, Headquarters 

x Thea Calder, Supervisory Program Analyst, Office of Integrity and Quality 

Oversight, Investigations and Program Integrity Division, OIG, 

Headquarters 

x Gwendolyn Schrade, Supervisory Program Analyst, Office of Integrity and 

Quality Oversight, Investigations and Program Integrity Division, OIG, 

Headquarters 

x Thad Brennan, Senior Criminal Investigator, Office of Integrity and Quality 

Oversight, Investigations and Program Integrity Division, OIG, 

Headquarters 

x Melissa Prunchak, Senior Program Analyst, Office of Integrity and Quality 

Oversight, Investigations and Program Integrity Division, OIG, 

Headquarters 

x Jim Lloyd, Referencer, Office of Integrity and Quality Oversight, 

Investigations and Program Integrity Division, OIG, Headquarters 
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Appendix E 

Report Distribution

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Coast Guard Audit Liaison 

DHS Program Accountability and Risk Management 

Chief Privacy Officer 

 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 
ADDITIONAL INFORMATION AND COPIES 

To view this and any of our other reports, please visit our website at: www.oig.dhs.gov. 

 

For further information or questions, please contact Office of Inspector General Public Affairs 

at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on Twitter at: @dhsoig. 

OIG HOTLINE 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click on the red 

"Hotline" tab. If you cannot access our website, call our hotline at (800) 323-8603, fax our 

hotline at (202) 254-4297, or write to us at: 

 Department of Homeland Security 

 Office of Inspector General, Mail Stop 0305 

 Attention: Hotline 

 245 Murray Drive, SW 

 Washington, DC 20528-0305