INSPECTORS 

GENERAL

Information on 

Vacancies and IG 

Community Views on 

Their Impact

Report to Congressional Addressees

March 2018

GAO-18-270

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-270, a report to 

congressional addressees

March 2018

INSPECTORS GENERAL

Information on Vacancies and IG Community Views 

on Their Impact

What GAO Found

As of September 30, 2017, 12 of the 64 active offices of inspector general (OIG)

established by the Inspector General Act of 1978, as amended (IG Act), had IG 

vacancies. Ten IG vacancies were in OIGs with presidentially appointed, Senate 

confirmed (PAS) IGs and two were in designated federal entities (DFE) with 

agency-appointed IGs. For the 10-year period covering fiscal years 2007 through 

2016, 53 of the 64 IG Act OIGs experienced one or more periods of IG vacancy 

with the cumulative durations ranging from about 2 weeks to 6 years. 

Cumulative Duration of Inspector General Vacancies, Fiscal Years 2007 through 2016

Legend: DFE = designated federal entity; IG= inspector general; PAS= presidentially appointed, Senate confirmed

Source: GAO analysis of IG vacancy data. | GAO-18-270

GAO’s survey of nine acting IGs and a stratified random sample of OIG

employees who worked under an acting IG, found both groups indicated that 

having acting IGs generally did not impact the OIGs’ ability to carry out their 

duties and responsibilities. However, responses varied in the following areas: 

• Plan and conduct work. Overall, at least eight of the nine acting IGs 

responded “no impact” for the questions in this area. The estimated 

percentage of OIG employees who believed that working under an acting IG 

has “no impact” ranged by question from 49 percent to 69 percent, “negative 

impact” ranged from about 8 percent to 24 percent, and “positive impact”

ranged from 6 percent to 13 percent.

• Interact with agency management. The responses of seven of the nine

acting IGs and 63 percent to 65 percent of OIG employees indicated that an 

acting IG position had no impact in this area. Approximately 16 percent of the 

OIG employees believed that there was a negative impact on timely access 

to documentation, while 7 percent believed that there was a positive impact.

• Managing OIG and personnel. Four of the nine acting IGs and about 36 

percent of OIG employees responded that an acting IG position had a 

negative impact on employee morale. An estimated 44 percent of employees

believed that working under an acting IG had no impact on employee morale 

while about 10 percent believed it had a positive impact. Four acting IGs also 

responded that it had a negative impact on office restructuring. 

With regard to independence, GAO’s survey of permanent IGs found that while 

the majority who responded did not think that acting IGs are inherently less 

independent, they did indicate by a similar majority that an acting IG is less 

independent in appearance than a permanent IG, especially when the acting IG

is applying for the IG position.

View GAO-18-270. For more information, 

contact Beryl H. Davis at (202) 512-2623 or 

davisbh@gao.gov.

Why GAO Did This Study

The IG Act established OIGs to

conduct and supervise audits and 

investigations; recommend policies to 

promote economy, efficiency, and 

effectiveness; and prevent and detect 

fraud and abuse. The Inspector 

General Empowerment Act of 2016 

included a provision for GAO to review 

prolonged IG vacancies during which a 

temporary appointee has served as the 

head of the office. This report 

addresses (1) the status of IG 

vacancies as of the end of fiscal year 

2017, and the number and duration of 

IG vacancies for fiscal years 2007 

through 2016, and (2) the IG 

community’s views about how IG 

vacancies impact the OIGs’ ability to 

carry out their duties effectively, 

including views on the impact on 

independence.

GAO analyzed data related to IG 

vacancies; interviewed officials from 

the Council of the Inspectors General 

on Integrity and Efficiency (CIGIE); and 

conducted a web-based survey to 

obtain the views of (1) the 52 

permanent IGs serving as of August 

22, 2017; (2) 9 acting IGs who had 

served in OIGs that had vacancies of 

over 365 days during fiscal years 2014 

through 2016; and (3) a stratified 

random sample of employees in OIGs 

with IG vacancies of over 365 days 

during fiscal years 2014 through 2016.

Survey response rates ranged from 71 

percent to 100 percent.

CIGIE and nine OIGs provided 

technical comments, which were 

incorporated as appropriate.
Page i GAO-18-270 Inspector General Vacancies

Letter 1

Background 4

IG Vacancies as of Fiscal Year 2017 and the Number and 

Duration of IG Vacancies for Fiscal Years 2007 through 2016 8

Acting IG, OIG Employee, and Permanent IG Views on the Impact 

of IG Vacancies, and Permanent IG Suggestions for Improving 

the Appointment Process 16

Agency Comments and Our Evaluation 43

Appendix I Objectives, Scope, and Methodology 45

Appendix II Comments from the Council of the Inspectors 

General on Integrity and Efficiency 49

Appendix III Comments from the National Credit Union 

Administration Office of Inspector General 50

Appendix IV Comments from the U.S. Election Assistance 

Commission Office of Inspector General 51

Appendix V GAO Contact and Staff Acknowledgments 52

Tables

Table 1: Presidentially Appointed, Senate Confirmed Inspector 

General Offices and Designated Federal Entity Inspector 

General Offices under the Inspector General Act, Active 

as of September 30, 2017 6

Table 2: Status of Inspector General Vacancies at Active OIGs 

Established by the IG Act, as of September 30, 2017 9

Table 3: Views of Acting Inspectors General on the Ability to Plan 

and Conduct Work in Offices with Acting Inspectors 

General 17

Contents
Page ii

Table 4: Views of Acting Inspectors General on the Ability to 

Interact with Agency Management in Offices with Acting 

Inspectors General 20

Table 5: Views of Acting Inspectors General on the Ability to 

Manage the Office of the Inspector General and 

Personnel in Offices with Acting Inspectors General 22

Figures

Figure 1: Number of IG Act Inspector General Vacancies at Fiscal 

Year-End for Fiscal Years 2007 through 2016 11

Figure 2: Cumulative Duration of IG Act Inspector General 

Vacancies for Fiscal Years 2007 through 2016 12

Figure 3: Presidentially Appointed, Senate Confirmed Inspector 

General Cumulative Vacancies of More Than 1 Year 

during Fiscal Years 2007 through 2016 at Offices of 

Inspector General Established by the IG Act 13

Figure 4: Designated Federal Entity Inspector General Cumulative 

Vacancies of More Than 1 Year during Fiscal Years 2007 

through 2016 15

Figure 5: Views of OIG Employees Who Worked under Acting 

Inspectors General on the Ability to Plan and Conduct 

Work in Offices with Acting Inspectors General 18

Figure 6: Views of Office of Inspector General Employees Who 

Worked under Acting Inspectors General on the Ability to 

Interact with Agency Management in Offices with Acting 

Inspectors General 21

Figure 7: Views of Office of Inspector General Employees Working 

under Acting Inspectors General on the Ability to Manage 

the Office of Inspector General and Personnel 23

Figure 8: Permanent Inspector General Views on Acting Inspector 

General Inherent Independence 29

Figure 9: Permanent Inspectors General Views on Acting 

Inspectors General Appearance of Independence 32

Figure 10: Office of Inspector General Employees’ Views on 

Acting Inspector General Inherent Independence 38

GAO-18-270 Inspector General Vacancies
Page iii GAO-18-270 Inspector General Vacancies

Abbreviations 

CIGIE Council of the Inspectors General on Integrity and 

Efficiency 

DFE designated federal entity 

IG inspector general 

IG Act Inspector General Act of 1978, as amended 

OIG office of inspector general 

OPP Office of Presidential Personnel 

PAS presidentially appointed, Senate confirmed 

SES Senior Executive Service 

USITC United States International Trade Commission 

Vacancies 

Act Federal Vacancies Reform Act of 1998

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Letter

Page 1 GAO-18-270 Inspector General Vacancies

441 G St. N.W.

Washington, DC 20548

March 9, 2018

The Honorable Ron Johnson

Chairman

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Charles E. Grassley

Chairman

Committee on the Judiciary

United States Senate

The Honorable Trey Gowdy

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

Inspectors general (IG) play a key role in federal agency oversight by 

enhancing government accountability and protecting the government’s 

resources. IGs have a unique oversight role under the Inspector General 

Act of 1978, as amended (IG Act), including identifying areas for 

improved economy, efficiency, and effectiveness through independent 

and objective oversight; preventing and detecting fraud, waste, abuse, 

and mismanagement; and recommending corrective actions.1 Among 

other things, each IG provides oversight through audits and investigations 

of the respective federal agency while maintaining an independent 

working relationship with the agency head and Congress. However, in 

recent years the number and length of IG vacancies have raised 

questions about the effect of these vacancies on the ability of the offices 

of inspector general (OIG) to carry out their statutory duties and 

responsibilities.

The Inspector General Empowerment Act of 2016 includes a provision for 

GAO to review prolonged IG vacancies during which a temporary 

1

Pub. L. No. 95-452, 92 Stat. 1101 (Oct. 12, 1978), codified, as amended, at 5 U.S.C. 

App.
Page 2 GAO-18-270 Inspector General Vacancies

appointee has served as the head of the office.2 This report addresses (1) 

the status of IG vacancies as of the end of fiscal year 2017, and the 

number and duration of IG vacancies from fiscal years 2007 through 

2016, and (2) the views of the IG community on the impacts, if any, of IG 

vacancies on the OIGs’ ability to effectively carry out their duties, 

including views on independence and permanent IG suggestions for 

improvements in the appointment process.3 To address these objectives 

we included in our scope the 64 active OIGs that were established under 

the IG Act. 4

 

To determine the status of IG vacancies as of the end of fiscal year 2017 

and the number and duration of IG vacancies from fiscal years 2007 

through 2016, we obtained vacancy data for fiscal years 2007 through 

2017 from the Council of the Inspectors General on Integrity and 

Efficiency (CIGIE)5 and a congressional website,6 and we confirmed that 

information with the respective OIGs. We also interviewed CIGIE officials 

to obtain an understanding of issues related to IG vacancies and discuss 

the reliability of IG vacancy data.7

 

2

Pub. L. No. 114-317, § 4(a), 130 Stat. 1595, 1599 (Dec. 16, 2016).

3

In this report, we refer to the official exercising the authority of an IG in lieu of an officially 

appointed IG as an “acting IG,” regardless of the title used by such official in practice. 

4

We did not include IG positions established by other statutes because of the variations in 

those authorizing statutes regarding the appointment, authorities, and duties of these IGs. 

IG positions established by statutes other than the IG Act include the IGs for the Central 

Intelligence Agency, the Intelligence Community, the Government Printing Office, the 

Library of Congress, the Architect of the Capitol, the U.S. Capitol Police, and GAO, as well 

as the Special IGs for Afghanistan Reconstruction and for the Troubled Asset Relief 

Program. Also, the IG Act includes authorization for some additional OIGs that are not 

presently active, many because of the termination of their associated agencies or the 

agencies’ integration into larger federal entities. 

5

CIGIE was established as an independent entity in 2008 to address integrity, economy, 

and effectiveness issues that transcend individual government agencies, and to increase 

the professionalism and effectiveness of OIG personnel by developing policies, standards, 

and approaches to aid in the establishment of well trained and highly skilled workforce in 

the OIGs. 

6

Congress.gov is the official website for U.S. federal legislative information. The site 

states that it provides access to accurate, timely, and complete legislative information for 

Members of Congress, legislative agencies, and the public. The website has a presidential 

nominations database that includes the date each nomination was received from the 

President, the committee(s) involved for the nomination, and the Senate actions related to 

the nomination.

7

We interviewed the CIGIE Executive Director, the current and former CIGIE Chair, and 

the current CIGIE Vice-Chair.
Page 3 GAO-18-270 Inspector General Vacancies

To obtain the views of the IG community—specifically, permanent IGs, 

acting IGs, and employees working under an acting IG—we conducted a 

web-based survey on the impact that a prolonged vacancy could have on 

the OIG’s ability to carry out its duties, including any impact on 

independence. These surveys included both multiple choice questions 

and open-ended questions for written responses to obtain the views of 

the IG community on the impacts of vacancies, if any, and views on

independence, challenges, and positive outcomes. We surveyed (1) 

permanent IGs serving as of August 22, 2017, to obtain their views on the 

impact that an IG vacancy could have on an OIG’s ability to conduct its 

oversight, including any independence issues presented by acting IGs;8

(2) acting IGs who had served in OIGs that had vacancies of over 365 

days during fiscal years 2014 through 2016 to obtain their views on the 

impact that a prolonged vacancy could have on an acting IG’s ability to 

carry out his or her duties, including any impact on independence;9 and 

(3) employees of OIGs headed by acting IGs. For our survey of OIG 

employees, we surveyed a stratified random sample of Senior Executive 

Service (SES) and non-SES employees working in offices with an IG 

vacancy that lasted over 365 consecutive days during fiscal years 2014 

through 2016. Views expressed in the open-ended questions may not be 

representative of all acting IGs, permanent IGs, or employees on given 

topics. We did not assess the merits of the individual comments or 

suggestions provided in response to the open-ended survey questions. 

See appendix I for further details on the survey and our scope and 

methodology.10 

We conducted this performance audit from February 2017 to March 2018 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

8

We provided our survey to 52 IGs who met our selection criteria, and 50 of them 

responded to the survey.

9

While 14 acting IGs met our selection criteria, 4 had either retired or left the government 

and were not surveyed. The National Reconnaissance Office acting IG was excluded 

because we did not survey the OIG personnel independently because of concerns 

regarding sensitive personally identifiable information. For the 9 remaining acting IGs, 2 

are now permanent IGs, but provided responses for their acting IG tenure, which we 

included with the acting IG responses.

10The National Reconnaissance Office was included in the IG vacancy status information 

but was excluded from our second objective about the impact of vacancies because of 

concerns regarding sensitive personally identifiable information.
Page 4 GAO-18-270 Inspector General Vacancies

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The IG Act establishes OIGs both at select major federal agencies, called 

establishments, and at some smaller agencies, called designated federal 

entities (DFE), to conduct oversight of their programs and operations.11

The IG Act also sets out, among other things, (1) the duties and 

responsibilities of each IG with respect to the entity within which its office 

is established; (2) how IGs are appointed, whether by the President with 

the advice and consent of the Senate, or by the head of the DFE; and (3) 

the processes for removing an IG.

The IG Act established OIGs to be independent and objective units to (1) 

conduct and supervise audits and investigations relating to the programs 

and operations of government establishments; (2) provide leadership and 

coordination and recommend policies for activities designed to promote 

economy, efficiency, and effectiveness in the administration of and to 

prevent and detect fraud and abuse in such programs and operations; 

and (3) provide a means for keeping the head of the agency and 

Congress fully and currently informed about problems and deficiencies 

relating to the administration of such programs and operations and the 

necessity for and progress of corrective action.

IGs covered by the IG Act have been granted broad oversight authority, 

including to

• conduct, supervise, and coordinate audits and investigations;

• directly access the records and information related to the applicable

agency’s programs and operations;

• request assistance from other federal, state, and local government

agencies;

11As originally enacted in 1978, the IG Act applied to 12 “establishments.” Other IGs were 

added over time. In particular, the Inspector General Act Amendments of 1988, Pub. L. 

No. 100-504, title I, 102 Stat. 2515 (Oct. 18, 1988), expanded the scope of the IG Act, 

providing, among other things, for agency-head-appointed IGs in DFEs. Section 12 of the 

IG Act includes the current list of establishments, and section 8G of the IG Act includes 

the current list of DFEs. 

Background

Duties, Responsibilities, 

and Authorities under the 

IG Act
Page 5 GAO-18-270 Inspector General Vacancies

• subpoena information and documents;

• administer oaths when conducting interviews;

• hire staff and manage their own resources; and

• receive and respond to complaints from agency employees, whose

identities are to be protected.

In addition to their duties, responsibilities, and authorities in conducting 

their oversight work, IGs derive independence through numerous 

provisions in the IG Act. These provisions include the following:

• the requirement that IGs be appointed without regard to political

affiliation and solely on the basis of integrity and demonstrated ability;

• the authority to select, appoint, and employ OIG officers and

employees, as noted above;

• the authority of IGs to report violations of law directly to the

Department of Justice;

• the requirement for agency heads to transmit the IGs’ semiannual

reports of their activities to Congress without alteration;

• the authority of IGs to perform any audit or investigation without

interference from the agency head or others except under certain

conditions specified by the act; and

• the requirement for the President or the agency head to communicate

to Congress the reasons for removing an IG.

The IG Act establishes the basis on which an IG is to be appointed; which 

OIGs are required to have presidentially appointed, Senate confirmed 

(PAS) IGs; and which are DFE OIGs, with IGs appointed by the heads of 

the agencies. For the purposes of the IG Act, subject to some specifically 

enumerated exceptions, the head of the DFE is the DFE’s board or 

commission, or if an entity does not have a board or commission, any 

person or persons designated by statute as the head of the DFE.

Of the 64 active IG offices established under the IG Act, 32 have PAS IGs 

and 32 have DFE IGs. Both PAS and DFE IGs are required to be 

appointed without regard to political affiliation and solely on the basis of 

integrity and demonstrated ability in accounting, auditing, financial 

analysis, law, management analysis, public administration, or 

investigations. See table 1 for a list of PAS and DFE agencies as 

designated by the IG Act.

IGs Established by the IG 

Act and the Appointment 

Process
Page 6 GAO-18-270 Inspector General Vacancies

Table 1: Presidentially Appointed, Senate Confirmed Inspector General Offices and Designated Federal Entity Inspector 

General Offices under the Inspector General Act, Active as of September 30, 2017

Presidentially appointed, Senate confirmed Designated federal entity (agency appointed)

Corporation for National and Community Service

Department of Agriculture

Department of Commerce

Department of Defense

Department of Education

Department of Energy

Department of Health and Human Services

Department of Homeland Security

Department of Housing and Urban Development

Department of the Interior

Department of Justice

Department of Labor

Department of State

Department of Transportation

Department of the Treasury 

Department of Veterans Affairs

Environmental Protection Agency

Export-Import Bank

Federal Deposit Insurance Corporation

Federal Housing Finance Agency

General Services Administration

National Aeronautics and Space Administration

National Reconnaissance Officea

National Security Agencya

Nuclear Regulatory Commission

Office of Personnel Management

Railroad Retirement Board

Small Business Administration

Social Security Administration

Tennessee Valley Authority

Treasury Inspector General for Tax Administration

U.S. Agency for International Development

Amtrak

Appalachian Regional Commission

Board of Governors of the Federal Reserve System and the 

Bureau of Consumer Financial Protectionb

Committee for Purchase From People Who Are Blind or Severely 

Disabled (AbilityOne Program)

Commodity Futures Trading Commission

Consumer Product Safety Commission

Corporation for Public Broadcasting

Defense Intelligence Agency

Denali Commission

Equal Employment Opportunity Commission

Farm Credit Administration

Federal Communications Commission

Federal Election Commission

Federal Labor Relations Authority

Federal Maritime Commission

Federal Trade Commission

Legal Services Corporation

National Archives and Records Administration

National Credit Union Administration

National Endowment for the Arts

National Endowment for the Humanities

National Geospatial-Intelligence Agency

National Labor Relations Board

National Science Foundation

Peace Corps

Pension Benefit Guaranty Corporation

Postal Regulatory Commission

Securities and Exchange Commission

Smithsonian Institution

U.S. Election Assistance Commission

U.S. International Trade Commission

U.S. Postal Service

Source: GAO analysis of the Inspector General Act of 1978, as amended, and related statutes. | GAO-18-270. 

a

In 2014, the inspector general (IG) appointment structure for the IGs of the National Security Agency 

and National Reconnaissance Office was changed from agency appointed to presidentially appointed, 

Senate confirmed.

b

In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act established the Bureau of 

Consumer Financial Protection within the Federal Reserve System, subject to the oversight of the IG 

for the Board of Governors of the Federal Reserve System. To reflect this expanded scope, the IG 

was retitled the IG of the Board of Governors of the Federal Reserve System and the Bureau of 

Consumer Financial Protection.
Page 7 GAO-18-270 Inspector General Vacancies

The process for appointing PAS IGs generally has three main steps: (1) 

President’s selection and nomination, (2) Senate’s evaluation and 

confirmation, and (3) President’s official appointment. CIGIE assists the 

White House Office of Presidential Personnel (OPP) in the vetting of

candidates for the IG nomination process. According to CIGIE officials, 

CIGIE’s Candidate Recommendations Panel receives résumés for 

potential candidates in various ways, including submissions from 

interested candidates through a link on the CIGIE website. The CIGIE 

panel also proactively reaches out to potential candidates who members 

of this panel believe would be good choices for IG positions. 

According to a CIGIE official, during the prior administration, the panel 

reviewed résumés from potential IG candidates and sent the résumés of 

those most qualified to the White House OPP for its process. Under the 

current administration, the CIGIE panel conducts interviews of potential 

IG candidates in addition to reviewing résumés, and then refers those 

candidates that the panel deems the most qualified to the White House

OPP. CIGIE’s panel assesses potential candidates’ leadership philosophy 

and skills, as well as their understanding of the independent, non-partisan 

role of an IG.

PAS IGs may be removed from office by the President, who must 

communicate the reasons for removal in writing to both Houses of 

Congress not later than 30 days before the removal. 

A DFE IG is appointed by the head of the entity in accordance with the 

applicable laws and regulations governing appointments within that entity. 

DFE IGs do not require presidential appointment or Senate confirmation. 

DFE IGs may be removed from office by the agency heads, or for an 

entity led by a board or a commission, removal requires written 

concurrence of a two-thirds majority of the board or commission. Similar 

to the President removing a PAS IG, the head of the entity must 

communicate the reasons for removal in writing to both Houses of 

Congress not later than 30 days before the removal.

After a PAS IG retires or otherwise leaves office, the Federal Vacancies 

Reform Act of 1998 (Vacancies Act) instructs the official previously

serving as first assistant to the vacant position to perform the duties of 
Page 8 GAO-18-270 Inspector General Vacancies

that position in an acting capacity, absent other action by the President.12

For DFE OIGs, acting IGs may be appointed according to laws, 

regulations, and policies governing appointments for each agency. 

Neither the IG Act nor the Vacancies Act places limits on the authority of 

acting IGs (relative to that of officially appointed IGs) to carry out the 

statutory responsibilities of the IG.13 However, the IG Act’s requirement 

for congressional notification prior to removal of a permanent IG does not 

apply to an acting IG.

As of September 30, 2017, there were 12 IG vacancies in the 64 IG Act 

offices. Over the 10-year period covering fiscal years 2007 through 2016, 

the total number of IG vacancies varied with a low of 6 total vacancies as 

of the end of fiscal year 2007 to a high of 11 vacancies as of the end of 

fiscal years 2009, 2014, and 2016. In addition, some OIGs experienced 

prolonged continuous vacancies ranging from over 1 year to 

approximately 6 years.

As of September 30, 2017, there were 12 IG vacancies consisting of 10 

vacancies in PAS IGs and 2 in DFE IGs, as shown in table 2. Two of 

these vacancies had presidential nominations that were awaiting Senate 

evaluation as of September 30, 2017. During fiscal year 2017, four OIGs 

had an IG position that became vacant: Small Business Administration, 

Federal Election Commission, Department of Housing and Urban 

Development, and Tennessee Valley Authority.

12Pub. L. No. 105-277, div. C, title I, §151, 112 Stat. 2681-611 (Oct. 21, 1998), codified at

5 U.S.C. §§ 3345-3349d. The President has the option of filling a vacancy either with a 

different officer or employee of the agency involved or with a person currently serving in a 

different office; such appointment requires presidential appointment and Senate 

confirmation.

13Although the Vacancies Act sets a time limit on the service of acting officials, the 

provision affecting the exercise of authority beyond that time limit explicitly exempts IGs. 

Thus, an official whose service exceeds the applicable time limit may continue to carry out 

the statutory responsibilities of the IG, even if he or she no longer uses the “acting IG” title. 

As mentioned above, this report uses “acting IG” to refer to all such officials, regardless of 

the Vacancies Act time limit or actual title used.

IG Vacancies as of 

Fiscal Year 2017 and 

the Number and 

Duration of IG 

Vacancies for Fiscal 

Years 2007 through 

2016

Twelve IG Positions Were 

Vacant as of September 

30, 2017
Page 9 GAO-18-270 Inspector General Vacancies

Table 2: Status of Inspector General Vacancies at Active OIGs Established by the IG Act, as of September 30, 2017

Federal entity

PAS or 

DFE

Vacancy 

start date

Duration of 

vacancy

Nomination 

status as of 

9/30/2017

Department of the Interior PAS 1/1/2012 5 years 273 days None

Export-Import Bank PAS 6/29/2014 3 years 94 days Nomination 

made on 

9/5/2017

Department of Energy PAS 10/4/2015 1 year 362 days None

Department of Defense PAS 1/10/2016 1 year 264 days None

Office of Personnel Management PAS 2/19/2016 1 year 224 days Nonea

United States Postal Service DFE 2/27/2016 1 year 216 days N/A

Social Security Administration PAS 5/29/2016 1 year 124 days Nonea

National Security Agencyb PAS 6/24/2016 1 year 98 days Nomination 

made on 

6/19/2017

Small Business Administration PAS 1/9/2017 264 days Nonea

Federal Election Commission DFE 3/3/2017 211 days N/A

Department of Housing and Urban Development PAS 6/10/2017 112 days None

Tennessee Valley Authority PAS 9/21/2017 9 days None

Legend:

DFE = designated federal entity

IG = inspector general

IG Act = Inspector General Act of 1978, as amended

N/A = Nomination status is not applicable because DFE IGs are selected by the agency heads and not through a presidential nomination process

OIG = office of inspector general

PAS = presidentially appointed, Senate confirmed

Source: GAO analysis of IG vacancy data. | GAO-18-270

a

Since September 30, 2017, there have been changes to this information. On October 16, 2017, the 

President nominated IG candidates for the Office of Personnel Management, Social Security 

Administration, and Small Business Administration.

b

The National Security Agency appointment structure changed in 2014 to PAS. However, by the 

terms of the amending statute, this change was not to apply until either the incumbent IG left office, or 

the President nominated a successor. This change was triggered when the incumbent IG left the IG 

position, initiating the vacancy noted here. The new IG was confirmed by the Senate on December 

21, 2017.
Page 10 GAO-18-270 Inspector General Vacancies

For the 10-year period from October 1, 2007, through September 30, 

2016, the total number of IG vacancies at the ends of the fiscal years 

ranged from 6 to 11 vacancies, as shown in figure 1.14 For the PAS IGs, 

the number of IG vacancies increased from 3 at the end of fiscal year 

2007 to 9 at the end of fiscal year 2016.15 For DFE IGs, the number of IG 

vacancies ranged from 0 to 4 vacancies at the ends of the fiscal years 

during the 10-year period.

14During this 10-year period, amendments to the IG Act increased the number of IGs from 

57 to 64. Specifically, the Federal Housing Finance Agency was added as a PAS IG in 

2008, and DFE IGs were added at the Postal Regulatory Commission in fiscal year 2007, 

the Defense Intelligence Agency in fiscal year 2010, the National Reconnaissance Office 

in fiscal year 2010, the National Security Agency in fiscal year 2010, the National 

Geospatial-Intelligence Agency in fiscal year 2010, and the Committee for Purchase From 

People Who Are Blind or Severely Disabled (AbilityOne Program) in fiscal year 2016.

15In 2014, the IG appointment structure for the IGs of the National Security Agency and 

National Reconnaissance Office was changed from DFE to PAS. During the 10-year 

period of our review, National Reconnaissance Office and National Security Agency OIGs 

experienced vacancies during both their agency appointed and presidentially appointed 

status. However, to avoid duplicating the OIG names, we only counted the number and 

length of vacancies for each OIG under the presidentially appointed IGs. Prior to the 

change in designation, the National Reconnaissance Office had two vacancies and the 

National Security Agency had one vacancy. All three vacancies were less than a year in 

duration.

Number of IG Vacancies 

Varied from Fiscal Years 

2007 through 2016
Page 11 GAO-18-270 Inspector General Vacancies

Figure 1: Number of IG Act Inspector General Vacancies at Fiscal Year-End for 

Fiscal Years 2007 through 2016

From October 1, 2006, through September 30, 2016, 53 of the 64 IG Act 

offices experienced vacancies, as shown in figure 2. Of the 32 PAS IGs, 

26 experienced at least one vacancy during the 10-year period with the 

cumulative duration ranging from 25 days to 5 years and 258 days. Of the 

32 DFE IGs, 27 experienced at least one vacancy during the 10-year 

period with the cumulative duration ranging from 13 days to 3 years and 

67 days.

The Cumulative Duration 

of IG Vacancies Ranged 

from Less Than 1 Month to 

Almost 6 Years for Fiscal 

Years 2007 through 2016
Page 12 GAO-18-270 Inspector General Vacancies

Figure 2: Cumulative Duration of IG Act Inspector General Vacancies for Fiscal Years 2007 through 2016

Of the 26 PAS IGs that had vacancies during the 10-year period from 

fiscal years 2007 through 2016, 20 experienced at least one vacancy with 

a cumulative duration of more than 1 year, and for 11 of these IGs the 

cumulative vacancy period was over 3 years, as shown in figure 3. In 

addition, 5 of the 20 agencies with a cumulative IG vacancy of 1 year or 

more were the result of the agency experiencing two or more periods of 

IG vacancy over the 10-year period.
Page 13 GAO-18-270 Inspector General Vacancies

Figure 3: Presidentially Appointed, Senate Confirmed Inspector General Cumulative Vacancies of More Than 1 Year during 

Fiscal Years 2007 through 2016 at Offices of Inspector General Established by the IG Act

The Department of State experienced the longest period of continuous 

PAS IG vacancy during the 10-year period, with 5 years and 258 days 

without a permanent IG. The Department of State IG vacancy began on 

January 16, 2008, and no nomination was made by the President until 

June 27, 2013. The nominee was confirmed by the Senate on September 

17, 2013, and the vacancy ended on September 30, 2013.

The Department of the Interior experienced the second longest PAS IG 

vacancy during the 10-year period, with 4 years and 273 days without a 

permanent IG as of the end of fiscal year 2016, and the vacancy 

remained as of the end of fiscal year 2017. The Department of the Interior 

IG vacancy began on January 1, 2012. The acting IG was nominated by 

the President on June 8, 2015. The nomination was received in the 

Senate and referred to the Committee on Energy and Natural Resources, 

which held a hearing on October 20, 2015. The nomination was returned 
Page 14 GAO-18-270 Inspector General Vacancies

to the President on January 3, 2017, under the provisions of a Senate 

rule that require nominations that are not confirmed or rejected during the 

congressional session be returned to the President.16 Once returned, the 

Senate will not consider the nomination until the President provides the 

Senate a new nominee.

Other PAS IGs experienced several vacancies throughout the 10-year 

period. For example, the Department of Defense OIG had four periods of 

vacancy from fiscal years 2007 through 2016, two of them 1 year or 

longer, and one that began in January 2016 and remained vacant as of 

September 30, 2016.17

Of the 27 DFE IG offices that experienced IG vacancies during the 10-

year period from fiscal years 2007 through 2016, 12 experienced at least 

one vacancy with a cumulative duration of more than 1 year as shown in 

figure 4. In addition, 5 of the 12 agencies with a cumulative IG vacancy of 

1 year or more were the result of the agency experiencing two or more 

periods of IG vacancy over the 10-year period.

16Standing Rules of the Senate, S. Doc. No. 113-18, Rule XXXI, ¶ 6 (Nov. 4, 2013).

17The Department of Defense IG position continued to be vacant as of September 30, 

2017.
Page 15 GAO-18-270 Inspector General Vacancies

Figure 4: Designated Federal Entity Inspector General Cumulative Vacancies of 

More Than 1 Year during Fiscal Years 2007 through 2016

The U.S. International Trade Commission (USITC) experienced the 

longest continuous DFE IG vacancy during the 10-year period, with 3 

years and 67 days without a permanent IG. The position was filled and 

the vacancy ended on December 6, 2009. In fiscal year 2011, we 

reported that the USITC OIG lacked an appointed IG and adequate 

budget and staff resources for fiscal years 2005 through 2009, which 

contributed significantly to the OIG’s limited oversight of USITC.18 We 

recommended that the Chairman of USITC revise formal orientation 

information provided to the commissioners to include sections on, among 

other things, the responsibilities of the Chairman to maintain an appointed 

IG. USITC implemented these recommendations. The National Archives 

18GAO, Inspectors General: Continued Actions Needed to Strengthen IG Oversight of the 

United States International Trade Commission, GAO-11-5 (Washington, D.C.: Oct. 22, 

2010).
Page 16 GAO-18-270 Inspector General Vacancies

and Records Administration experienced the second longest DFE IG 

vacancy during the 10-year period, with 2 years and 190 days without a 

permanent IG. The vacancy started when the IG was placed on 

administrative leave, which lasted from September 14, 2012, until August 

9, 2014. The National Archives and Records Administration was not able 

to replace the IG during this time. The position was eventually filled on 

March 23, 2015.

We surveyed the acting IGs and OIG employees who worked under an 

acting IG among the 64 active OIGs established under the IG Act and 

asked for their views on the impact that having an acting IG has on an 

OIG’s ability to carry out its duties and responsibilities.19 While overall the 

survey responses indicated that having an acting IG had no impact on the 

OIGs’ ability to perform their statutory functions, responses varied in 

areas related to (1) planning and conducting work, (2) interacting with 

agency management, and (3) managing the OIG and personnel. In 

addition, a number of survey responses also pointed to challenges or 

positive outcomes in their experiences of working under an acting IG, and 

certain permanent IGs provided suggestions for improvements in the IG 

appointment process. For details on our survey methodology, see 

appendix I.

Acting IGs: When asked whether, during their tenure as acting IGs, the 

vacancy had a positive impact, negative impact, or no impact on several 

areas related to the OIG’s ability to plan and conduct work, overall, at 

least eight of the nine acting IGs indicated that having an acting IG had 

no impact on the OIG’s ability to plan and conduct work.20 Table 3 

19We conducted a stratified random survey of 185 employees from the population of 1,218 

employees from 10 agencies with OIGs that had acting IGs for over 365 days during fiscal 

years 2014 through 2016. For further details on our survey methodology, see app. I.

20Our survey of the acting IGs included seven acting IGs and two permanent IGs who also 

met our criteria, having served as acting IGs for more than 1 year from October 1, 2013, 

through September 30, 2016.

Acting IG, OIG 

Employee, and 

Permanent IG Views 

on the Impact of IG 

Vacancies, and 

Permanent IG 

Suggestions for 

Improving the 

Appointment Process

Acting IG and OIG 

Employee Views on the 

Impact of IG Vacancies

Views on the Impact of IG 

Vacancies on the OIG’s Ability 

to Plan and Conduct Work
Page 17 GAO-18-270 Inspector General Vacancies

summarizes the responses from the acting IGs related to the OIG’s ability 

to plan and conduct audit work.

Table 3: Views of Acting Inspectors General on the Ability to Plan and Conduct Work in Offices with Acting Inspectors 

General

Source: GAO analysis of survey data. | GAO-18-270

One of the nine acting IGs reported that the vacancy had a positive 

impact on developing comprehensive work plans for audits, 

investigations, and other OIG work, as well as addressing high-risk and 

high-priority issues.

OIG employees: As shown in figure 5, the estimated percentage of OIG 

employees who worked under an acting IG who believe this has no 

impact ranged by question from 49 percent to 69 percent for the areas 

related to the OIG’s ability to plan and conduct audit work.21 In contrast, 

based on our survey results, almost a quarter of the OIG employees 

believed that working under an acting IG had a negative effect on their 

OIG’s ability to complete reports and other OIG work products in a timely 

fashion, issue high-visibility or high-risk reports, and address high-risk 

and high-priority issues. According to the survey results, from 6 percent to 

13 percent of the employees found a positive impact in these areas.

21Our survey of acting IGs included questions to obtain management-related views that 

were not included in our survey of OIG employees.

Area of impact

No

impact

Positive

impact

Negative

impact

No basis

For judgment

Timely completion of reports and other IG office work products 9 0 0 0

Conducting work in accordance with professional standards 9 0 0 0

Issuing high-visibility or high-risk reports 9 0 0 0

Addressing high-risk and high-priority issues 8 1 0 0

Processing IG office hotline complaints in accordance with established 

guidance

8 0 0 1

Developing comprehensive work plans for audits, investigations, and other 

IG office work

8 1 0 0
Page 18 GAO-18-270 Inspector General Vacancies

Figure 5: Views of OIG Employees Who Worked under Acting Inspectors General on the Ability to Plan and Conduct Work in 

Offices with Acting Inspectors General

We also asked OIG employees to identify any additional challenges, in 

written comments, that they experienced in relation to their work under an 
Page 19 GAO-18-270 Inspector General Vacancies

acting IG. Four OIG employees provided responses related to the ability 

to plan and conduct work, specifically, on the timely completion of reports 

and other OIG work products, as noted in the following examples of 

individual comments:22

• “However, [the acting IG] seemed to struggle to ‘see the forest

through the trees’ and the timeliness (and associated impact) of our

work suffered significantly.”

• “Sometimes it would take longer to get a report out because [staff]

were [waiting on] a review from the [acting] IG.”

We also asked OIG employees to identify any positive outcomes or 

improvements based on their experiences with working under an acting 

IG. The following are some OIG employee written responses that were 

received regarding positive outcomes or improvements, which were 

related to the acting IG’s ability to plan and conduct work.

The acting IG came from within the OIG. Thirteen OIG employees 

provided comments related to the acting IG coming from within the OIG 

ranks and having expertise in the agency issues, as noted in the following 

examples of individual comments:

• “Our acting IG was already a part of our OIG when appointed. Thus,

they were already invested in the mission, our offices, and staff.”

• “The acting Inspector General had significant experience with agency

management, and with our office processes and procedures, so

products were issued timely.”

• “A positive [aspect] is that the acting Inspector General usually comes

with a wealth of knowledge about the OIG’s current practices and can

hit the ground running to keep things moving along effectively.”

• “Because of the acting IG’s investigative background as well as his

lack of interest in further political appointment I think we actually got

more done than under the former and current IG.”

22In some cases, we edited responses for clarity or grammar or to remove identifying 

information. 
Page 20 GAO-18-270 Inspector General Vacancies

Acting IGs: When asked whether, during their tenure as acting IGs, the 

vacancy had a positive impact, negative impact, or no impact on the 

OIG’s ability to interact with agency management, seven of the nine 

acting IGs indicated that there was no impact on the OIG’s ability to 

interact with the agency. Other acting IGs indicated a positive impact in 

regard to responsiveness from agency management, meeting with senior 

agency leadership, responsiveness of agency to recommendations, and 

timely access to agency documentation. One of the nine acting IGs 

indicated a negative impact regarding responsiveness of the agency to 

recommendations, and another saw a negative impact in timely access to 

agency documentation, as summarized in table 4.

Table 4: Views of Acting Inspectors General on the Ability to Interact with Agency Management in Offices with Acting 

Inspectors General

Source: GAO analysis of survey data. | GAO-18-270

While the majority of the acting IGs responded that there was no impact 

in interactions with agency management, in commenting about 

challenges faced during their acting IG tenure that affected their ability to 

carry out their responsibilities, one acting IG commented that agency 

managers failed several times to disclose relevant information that 

affected both the results and timeliness of the OIG’s audit work. In 

addition, one acting IG found that agency officials were more open to 

recommendations and more supportive of the OIG during the acting IG’s 

tenure than under the previous permanent IG tenure.

OIG employees: As shown in figure 6, we estimate that 63 percent of the 

OIG’s employees working under an acting IG believed that there was no 

impact on the responsiveness from agency management and an 

estimated 65 percent believed that there is no impact on timely access to 

agency documentation. Based on our survey results, the estimates for 

positive impact ranged from 7 percent to 9 percent, and approximately 17 

percent of the OIG employees believed that working under an acting IG 

has a negative impact on these two areas.

Views on the Impact of IG 

Vacancies on the OIG’s Ability 

to Interact with Agency 

Management

Area of impact 

No

impact

Positive

impact

Negative

impact

No basis For 

judgment

Responsiveness from agency management 7 2 0 0

Meeting with senior agency leadership 7 2 0 0

Responsiveness of agency to recommendations 7 1 1 0

Timely access to agency documentation 7 1 1 0
Page 21 GAO-18-270 Inspector General Vacancies

Figure 6: Views of Office of Inspector General Employees Who Worked under Acting Inspectors General on the Ability to 

Interact with Agency Management in Offices with Acting Inspectors General

Acting IGs: Responses of the acting IGs regarding their ability to 

manage the OIG and employees varied by question, as summarized in 

table 5. For example, regarding employee morale, four of the nine acting 

IGs indicated that an acting IG leading the office had a negative impact, 

three indicated that the vacancy had a positive impact, and one indicated 

that the vacancy had no impact.

Views on the Impact of IG 

Vacancies on the Ability to 

Manage the OIG and 

Employees
Page 22 GAO-18-270 Inspector General Vacancies

Table 5: Views of Acting Inspectors General on the Ability to Manage the Office of the Inspector General and Personnel in 

Offices with Acting Inspectors General

Source: GAO analysis of survey data. | GAO-18-270

a

One of the nine acting IGs did not respond to this question.

In written comments included in the survey, three acting IGs provided 

additional information regarding restructuring the office and developing or 

changing office policy. Specifically, two acting IGs indicated a reluctance 

to make changes that could not be easily reversed by an incoming 

appointed IG or to “shake up the organization” only to experience further 

changes once an IG was in place. The third acting IG identified 

constraints as typical for acting officials in making personnel, policy, or 

organizational changes, especially when the length of the tenure as the 

acting official is unknown.

We also asked the acting IGs if they had faced any challenges during 

their tenure that affected their ability to carry out their statutory duties and 

responsibilities. Of the three acting IG respondents who answered “yes,” 

two provided written responses citing challenges in the area of OIG 

management and personnel, such as difficulty in promotions and hiring 

decisions and OIG employee resistance to changes. For example, one 

acting IG indicated that the acting IG needed to get a special delegation 

from the agency to approve certain office promotions and hiring 

decisions. Another acting IG indicated the agency’s Office of General 

Counsel had to resolve a matter involving an employee who refused to 

relinquish his or her duties after the acting IG’s decision to reassign the 

employee.

OIG employees: As shown in figure 7, just over 50 percent of the OIG 

employees working under an acting IG believe that an acting IG had no 

impact or a positive impact on these two areas. We also estimate that 

about 36 percent of the OIG employees believed that working for an 

acting IG negatively affected employee morale and about 23 percent 

Area of impact

No

impact

Positive

impact

Negative

impact

No basis for 

judgment

Employee morale 1 3 4 1

Restructuring the officea 2 2 4 0

Obtaining a sufficient budget 8 1 0 0

Developing or changing office policy 4 2 3 0

Leading IG staff 6 1 2 0
Page 23 GAO-18-270 Inspector General Vacancies

believed that it negatively affected the ability to attract and retain qualified 

employees.

Figure 7: Views of Office of Inspector General Employees Working under Acting Inspectors General on the Ability to Manage 

the Office of Inspector General and Personnel

We asked OIG employees to identify any additional challenges they have 

experienced in relation to their work under an acting IG. Eighty-three 

employees provided written responses, and 65 of those responses were 

related to areas that affect the ability to manage the OIG and its

personnel, which are summarized below.23

23Responses provided in the open-ended questions could apply to more than one 

category under the impact of IG vacancies. 
Page 24 GAO-18-270 Inspector General Vacancies

Strategic planning. Nineteen OIG employees provided comments 

related to difficulty in strategic planning, as noted in the following 

examples of individual comments:

• “An acting IG is a caretaker, someone internal who is expected to

maintain the status quo. Therefore, having an acting IG in place for an 

extended period may have delayed the implementation of reforms or 

bold changes that would normally be expected from new leadership.” 

• “Internal processes, which may need to be changed, may not change

in anticipation of the new leadership.”

• “Certain decisions such as ‘strategic vision’ or filling high-level

positions within the organization may be delayed pending

appointment of a permanent IG.”

• “[Acting IGs] are not as willing to make changes at the agency

because it may not be what the new [permanent] IG wants. [Acting

IGs] are more stewards of the organization until the new IG arrives.”

Uncertainty. Fifteen OIG employees provided comments related to the 

uncertainty within the OIG, as noted in the following examples of 

individual comments:

• “The ability to make long-term decisions is affected due to uncertainty

[about whether the] incoming Inspector General will support the

decisions made by the acting Inspector General.”

• “Waiting for a permanent selection and the uncertainty as to the future

impact of the person selected is disconcerting. It also negatively

affects employee morale and motivation.”

• “Working under an acting Inspector General creates a climate of

uncertainty within the organization . . . . They [i.e., OIG employees] 

hesitate to make a decision that would be contrary to the views and/or

opinions of the new IG and put them in what they perceive to be a bad

light.”

• “I think the biggest challenges we had were related to employee

morale and the direction of the organization as a whole. Employees

did not know who was going to permanently lead the organization, or

when the decision would be made on this.”

Staffing. Twelve OIG employees provided comments related to 

addressing staffing needs or issues with staffing, as noted in the following 

examples of individual comments:
Page 25 GAO-18-270 Inspector General Vacancies

• “There were several difficulties related to meeting human resource

needs without the proper authority to make decisions such as

removals, promotions and/or bonuses.”

• “Issues with staffing could not be finalized pending the appointment of

a new [permanent] IG.”

• “Everyone except a select few in the OIG senior staff was leaving.”

Morale. Eight OIG employees provided comments related to morale 

issues, as noted in the following examples of individual comments:

• “Promotions were unnecessarily delayed under the acting IG. Not

good for morale.”

• “Certain issues relating to personnel management were left

unaddressed or dismissed (i.e., problem managers) [causing] morale

to dip among staff members.”

• “The acting IG appeared to have the need to prove to the agency

what power they had. This, in effect, caused a great discord amongst

not only agency [senior] management and [the] OIG, but also between

the OIG and the rest of the agency that we are still working to

overcome.”

Lack of leadership and office structure. Eight OIG employees provided 

comments related to the lack of leadership and office structure, as noted 

in the following examples of individual comments:

• “[The] management organization was seemingly dysfunctional. In part,

because alliances [would be] likely to change once [a] permanent IG

[is appointed].”

• “There isn’t a sense of real structure without [a permanent] IG.”

• “Lack of guidance on ongoing audits at that time. The acting IG wore

too many hats: Acting IG, Assistant IG for Audits, and Assistant IG for

Investigations.”

Acting IGs are risk-averse pending permanent IG nomination. Two 

OIG employees provided the following comments related to the pending 

IG nomination:

• “I think it’s fair to say, although granted, it is a generalization, that an

acting IG is more likely to be tentative and risk-averse than a fully

confirmed IG. Also, within the OIG itself, senior staff may likewise be

tentative and risk-averse knowing that new leadership is in the wings.”
Page 26 GAO-18-270 Inspector General Vacancies

• “The acting IGs are always hesitant to make waves . . . . One of them

was in the process of being nominated, so [the acting IG] didn’t want 

to do anything that could be seen as controversial or unpopular with 

staff. It [results in] the status quo being continued until a new official is 

confirmed.” 

Negatively affects budget discussions. One employee provided the 

following comment related to budget discussions: “In budget discussions 

with Congress and the administration, there is no trust that the acting IG 

understands the will of Congress . . . or has administration support.” 

We also asked OIG employees to identify any additional positive 

outcomes or improvements, in written comments, based on their 

experience from having an acting IG. Sixty-five employees provided 

written responses, and 12 of those responses related to the acting IG’s 

ability to manage the OIG and personnel, which are summarized below.

Higher morale. Twelve OIG employees provided comments related to 

higher morale with an acting IG, as noted in the following examples of 

individual comments:

• “[Federal Employee Viewpoint Survey] scores [were] remarkably

higher under [the acting IG].”

• “The acting IG, a career civil servant, established trusting

relationships meant for the long haul with the leadership team and

staff, and also members of the overseen agency, and with the

Congress. Morale was high and productivity was exceptionally high.”

• “I believe that the morale and overall quality of work that I witnessed

at OIG offices during the tenures of the two acting IGs that I worked

for was superior to that of offices that I worked in under one or more

Senate-confirmed IGs.”
Page 27 GAO-18-270 Inspector General Vacancies

The following summarizes (1) responses from acting IGs, permanent IGs, 

and OIG employees regarding the impact, if any, of a prolonged vacancy 

on the OIG’s ability to maintain independence and (2) permanent IGs’ 

suggestions on how to improve independence.

We asked acting IGs if they felt that serving as an acting IG instead of a 

permanent IG created threats (such as self-interest threat or bias threat) 

to their independence of mind or independence in appearance, and eight 

responded “no” and one responded “yes.” 24 The eight acting IGs who 

responded “no” to independence threats provided additional written 

comments to explain their answers, as noted in the following examples of 

individual explanations:

• “Because I’d been in the office since inception . . . I understood the

importance of independence in all aspects.”

• “I was appointed to carry out the duties and functions of the IG and

that is what I did to the best of my abilities. As an OIG employee,

independence is always a factor, regardless of position and taking on

additional duties and responsibilities did not impact that.”

• “I stated clearly and repeatedly to agency management and to Capitol

Hill stakeholders that I was not interested in seeking the IG

nomination on a permanent basis, in order to mitigate any concerns

about independence or bias that could arise from seeking an

appointment from officials I was charged with auditing/investigating.”

• “I declined the position of permanent Inspector General, in part to

preserve my independence in the face of the potential conflict that

could be perceived were I seeking the appointment. Serving in an

24Government Auditing Standards define self-interest threat as the threat that a financial 

or other interest will inappropriately influence an auditor’s judgment or behavior and 

defines bias threat as the threat that an auditor will, as a result of political, ideological, 

social, or other convictions, take a position that is not objective. GAO, Government 

Auditing Standards: 2011 Revision, ¶ 3.14, GAO-12-331G (Washington, D.C.: 

December 2011).

Acting IG, Permanent IG, 

and OIG Employee Views 

on the Impact of IG 

Vacancies on the Ability to 

Maintain Independence 

and Permanent IG 

Suggestions regarding 

Independence

Acting IG Views on the Impact 

of IG Vacancies on the Ability 

to Maintain Independence
Page 28 GAO-18-270 Inspector General Vacancies

acting capacity per se creates no threat to independence in fact or in 

appearance insofar as I am concerned based on my experience.” 

• “Serving as acting IG had no threats to independence.”

The acting IG that responded “yes” commented that there may be an 

appearance of independence problem if the acting IG is lobbying for the 

permanent position.

We also asked the acting IGs if their independence was ever questioned 

by agency officials or others because of their role. Eight of the nine acting 

IGs answered “no,” while one acting IG answered “yes” and indicated that 

an external entity had questioned the independence of the acting IG. The 

acting IG further commented that certain Members of Congress had 

questioned the independence of acting IGs.

We asked 52 permanent IGs whether they felt that an acting IG is 

inherently less independent than a permanent IG and whether an acting 

IG is less independent in appearance. While the majority of permanent 

IGs who responded did not think that acting IGs are inherently less 

independent, they did indicate by a similar majority that an acting IG is 

less independent in appearance than a permanent IG, especially in 

situations when the acting IGs are applying for the IG positions. Of the 49 

IGs who responded to the question of whether an acting IG is inherently 

less independent, 13 said “yes,” 30 said “no,” and 6 responded that they 

had no basis for judgment, as shown in figure 8. 

Permanent IG Views on the 

Impact of IG Vacancies on the 

Ability to Maintain 

Independence
Page 29 GAO-18-270 Inspector General Vacancies

Figure 8: Permanent Inspector General Views on Acting Inspector General Inherent 

Independence

Of the13 permanent IGs that answered “yes” to the acting IG being 

inherently less independent, 12 provided written comments as noted in 

the following examples of individual explanations.

An acting IG who is a candidate for position. Six permanent IGs 

provided comments related to an acting IG who is seeking the permanent 

position, as noted in the following examples of individual comments:

• “If the selecting officials (or recommending officials) are also subject

to audit or investigation by the acting [IG], and the acting [IG] is

interested in the permanent position they may actually be influenced

to not report aggressively.”

• “They [the acting IG] could be perceived as less independent if they

are a candidate for the job and they often are.”

• “Generally speaking, the position of Inspector General would be a

desirable promotion for an acting IG (sometimes the Deputy IG). An
Page 30 GAO-18-270 Inspector General Vacancies

acting/Deputy IG, interested in the IG position and striving to impress 

the agency leadership/White House for consideration of the IG job, 

could be less aggressive (independent) in an effort to please the 

‘hiring official’ (agency head/White House). Agency leaders/White 

House understand this dynamic, so in order to avoid/minimize any 

negative reports by the OIG, the agency heads can delay filling IG 

positions in order to have more ‘control’ over their acting IG.” 

Lack of Senate confirmation. Three permanent IGs provided comments 

in this category related to an acting IG having less authority to deal with 

agency officials and Congress than a permanent IG as the acting IG 

lacked Senate confirmation, as noted in the following individual 

comments:

• “Not having the full backing of the President, nor confirmation of the

Senate, does not provide an even playing field when the IG negotiates

with PAS agency heads and other PAS or senior level officials.”

• “First, because the agency knows that the acting IG is only

temporarily in that position, the willingness of agency officials

(particularly middle management and component leadership) to

inappropriately respond to and challenge OIG oversight efforts

increases. Second, an acting PAS IG (unlike a confirmed PAS IG) has

not been approved for that position by the Senate and therefore

doesn’t have that stamp of approval if there is a need to respond to

inappropriate efforts by the agency to interfere with the OIG.”

• “In my experience, discussions between the Dept’s [agency’s] political

leaders and the ‘permanent,’ politically-appointed IG (as well as

between Congress and that IG) are different—more frank—in

substance and tone.”

Of the 30 permanent IGs that answered “no” to the acting IG being 

inherently less independent, 28 provided written comments as noted in 

the following examples of individual explanations.

An acting IG has the same statutory authority as a permanent IG. 

Eight permanent IGs provided responses related to the acting IG having 

the same statutory authority as a permanent IG and the OIG structure 

having independence safeguards, as noted in the following examples of 

individual comments:

• “Because of the inherent structure of an OIG, with the independence

safeguards that are derived from the IG Act, the Office of Inspector

General should continue to be independent even if headed by an

acting IG.”
Page 31 GAO-18-270 Inspector General Vacancies

• “An acting IG has the same independence protections as a

‘permanent IG’.”

• “[Acting IGs] have the same statutory powers as an appointed IG to

fulfill their role.”

Having a permanent title should not be a factor in independence.

Ten permanent IGs provided responses related to a permanent title not 

being a factor in independence as the acting IGs are held to the same 

standards and independence is driven by the acting IG’s character and 

background, as noted in the following examples of individual comments:

• “Independence is a matter of personal mindset and perceptions drawn

by others based on individual/Office actions. Having the permanent

title is not a key element required in order for the above to effectively

exist.”

• “An acting IG can carry out his/her responsibilities as independently

as a permanent IG; there are no inherent restrictions on their

ability/capacity due solely to [the acting] status. It boils down to the

individual involved and their willingness/ability to do so in the context

in which they operate.”

• “The independence resides in the position regardless of whether [it is]

being occupied by an acting or permanent IG.”

• “The independence of an IG is largely driven by his or her character,

background, and experience.”

• “Independence is obtained by the characteristics of the individual in

the position of Inspector General. Just because the person occupying

the position is ‘acting’ does not mean they are not independent.”

An acting IG is usually a career OIG employee. Five permanent IGs 

provided comments related to the acting IG being a career OIG employee 

and knowing the importance of independence, as noted in the following 

examples of individual comments:

• “Career OIG employees place a high value on the independence of

the office.”

• “Generally acting IGs come from within the OIG and have long service

in the community and an understanding of and commitment to the role

of the IG.”

We also asked permanent IGs whether they felt that an acting IG is less 

independent in appearance than a permanent IG. Thirty of the 49 IGs 
Page 32 GAO-18-270 Inspector General Vacancies

who responded to this question answered “yes” and 13 answered “no,” as 

shown in figure 9. 

Figure 9: Permanent Inspectors General Views on Acting Inspectors General 

Appearance of Independence

Of the 30 permanent IGs who answered “yes” to this question, 27 

provided written comments, some of which are summarized below.

An acting IG will be less independent in appearance if he or she is 

seeking the permanent position. Sixteen permanent IGs provided 

comments related to an acting IG being less independent in appearance if 

he or she is seeking the permanent position or perceived to be seeking 

the permanent IG position, as noted in the following examples of 

individual comments:

• “There will always be an appearance issue regarding the judgment of

an acting IG if that individual is seeking the permanent position.”

• “There may be an appearance that an acting IG is less independent

from the agency, particularly where he or she is seeking to become
Page 33 GAO-18-270 Inspector General Vacancies

the permanent IG and needs the endorsement of the agency to move 

forward. This scenario could create an appearance of, or an actual, 

conflict of interest.” 

• “If the incumbent aspires to the permanent appointment, I feel the

designation as acting Inspector General carries the inherent risk that

the incumbent may be vulnerable to political pressures, since the

incumbent’s chances of being appointed as the permanent Inspector

General may be adversely influenced by sensitive or controversial

decisions made during the period that he/she served as acting

Inspector General.”

• “An ‘acting’ [IG] may be reluctant to assert independence if the acting

[IG] believes that he or she may be in the running for the vacant IG

job. This may create a conflict under certain facts.”

• “Unfortunately, if an acting IG is interested in becoming the IG, people

who are looking for reasons to find fault with their work can make an

argument that they are pulling punches to better their chances of

being selected. I don’t think this is true in most cases, but the

argument is made.”

An acting IG is also perceived as less independent. Six permanent 

IGs provided comments related to an acting IG being perceived as less 

independent by Congress, the public, and other organizations, as noted in 

the following examples of individual comments:

• “I am aware of at least one instance where the press and certain

Members of Congress speculated or implied that an acting IG who

wanted to be considered for appointment as the IG was lenient toward

the agency.”

• “Congress and the public . . . have both expressed this concern.”

• “There is an inherent suspicion that the acting IG will pull his or her

punches on audits and inspections in order to get nominated by the

agency he is auditing.”

• “Some judge an acting IG for the actions they take or don’t take

through the prism of partisan politics and often unfairly ascribe

decisions to the acting IG’s interest in becoming an IG.”

Of the 13 permanent IGs who answered “no,” 11 provided written 

comments, some of which are summarized below.

Acting IGs have the same authority as permanent IGs. Three 

permanent IGs provided comments related to an acting IG having the 
Page 34 GAO-18-270 Inspector General Vacancies

same authority as a permanent IG, as noted in the following examples of 

individual comments:

• “The law doesn’t change and tenets such as independence are the

same regardless of whether you are acting or not.”

• “An acting IG still heads an independent Office of Inspector General

and as long as that office continues to act independently, there should

be no appearance issue.”

• “The acting Inspector General has the same authority as a permanent

IG.”

Acting IGs should be able to perform their work independently. One 

permanent IG provided the following comment related to an acting IG 

performing his or her work independently: “I don’t necessarily think an 

acting IG has an appearance of lack of independence per se. Again, I 

think it depends on the acting IG, the agency, and the relationship 

between the OIG and the agency.” 

We also asked permanent IGs for suggestions on how the independence 

of the acting IG role could be improved. Although the majority of 

permanent IGs did not provide specific suggestions, the following 

summarizes the 12 written responses received:

• Expedite the appointment process (7 respondents).

• Make acting IGs ineligible for the permanent position (1 respondent).

• Establish a legislative solution for filling positions quickly (1

respondent). Specifically, there should be requirements that (1) acting

IGs be named within 30 days of vacancy and the IG position filled

within a certain amount of time; (2) DFE IG positions be filled within

180 days of a vacancy, and if not, the agency head should be

required to report every 30 days to the agency’s oversight committees

on the reason for delay; and (3) for PAS IG positions, a candidate

should be nominated within 180 days.

• For visibility, make clear whether the acting IG is under consideration

for the permanent position (1 respondent). The administration should

do this for a PAS IG, and the agency should for a DFE IG.

• Extend statutory protection to acting IGs (1 respondent). “The

independence of the acting Inspector General role could be improved

by extending the same protections mandated for the Inspector

General position to the acting Inspector General (as appropriately

tailored for the temporary nature of the ‘acting’ role).”
Page 35 GAO-18-270 Inspector General Vacancies

• Rotate the individuals who will be in the acting IG position (1

respondent).

In addition to views on the acting IG’s independence, we asked 

permanent IGs to provide additional comments and identify any 

challenges related to the acting IG role and prolonged IG vacancies. 

Thirty-one written responses were provided for this question, some of 

which are summarized below.

Importance of permanent IGs. Six permanent IGs provided written 

comments related to the importance of the permanent IG and 

impediments in the role of acting IGs, as noted in the following examples 

of individual comments:

• “Prolonged IG vacancies are never good, and negatively impact the

entire IG community and CIGIE because we need fully engaged IGs

who can participate in IG and CIGIE business knowing that they will

be in the position for the long-term and without wondering when and

whether they will be replaced.”

• “IG vacancies [i.e., positions] have been allowed to be vacant for

years. While the role of an acting IG may be filled successfully, it is

important to each agency/department to have a permanent IG who is

appointed by the appropriate process.”

• “Extended vacancies undermine the system of checks and balances.”

• “I generally believe that it is detrimental for an OIG to have a

prolonged IG vacancy with an acting IG. I believe that acting IGs may

be disinclined to take necessary agency actions because of their

temporary status. In addition, the acting IG is vulnerable to attacks on

his or her independence, particularly where he or she is seeking a

permanent position and requires the agency’s endorsement.”

Effect on strategic planning. Eight respondents pointed out challenges 

acting IGs face in long-term planning, as noted in the following examples 

of individual comments:

• “One of the biggest challenges to an acting IG may be the ability to

make long-term plans for the organization.”

• “A prolonged vacancy creates a leadership gap for the OIG and the

entity.”

• “Acting IGs do not feel empowered to take on new initiatives or

projects on behalf of the office, and may feel inhibited in terms of

management issues, including hiring.”
Page 36 GAO-18-270 Inspector General Vacancies

Authority. Four respondents commented on the need for authority 

provided by permanent leadership, as noted in the following examples of 

individual comments:

• “Regardless of whether the discussion is focused on acting IG

positions or any acting leadership position (within Mission or

otherwise), there is some level of authority in terms of institutional

impact and ability to effect change that comes from knowing those

advancing mission have some level of anticipated continuity in service

and ability to see things through.”

• “The acting [IG] did a remarkable job at getting the office through a

very difficult time, but largely saw [the role] as a caretaker. [The acting

IG] did not feel comfortable doing the things that I immediately

recognized needed to be done. The Office’s work got little traction

while the acting [IG] was in charge, in part because the Office was

without a permanent leader and the agency did not feel compelled to

pay attention to OIG recommendations.”

• “I believe the greatest challenge to anyone in an acting role has more

to do with authority than it has to do with independence . . . . I believe 

it is often difficult for anyone in an acting position to think long-term 

and make decisions that have long-term implications because they (1) 

have no idea how long they will be acting and (2) may be overruled or 

have decisions reversed by a permanent appointee. So I think acting 

individuals tend to ‘keep the home fires burning’ as well as they can 

but don’t necessarily think in terms of leading the organization in the 

direction it needs to go in the future, especially since they don’t know 

what the future will bring.” 

OIG morale. Four respondents reported morale problems in OIGs without 

a permanent IG, as noted in the following examples of individual 

comments:

• “Prolonged vacancies in senior leadership positions, whether in an

OIG or other government offices, can lead career employees to lose

their focus and their dedication to fulfill the mission of the office. When

new leadership is finally put into place, it often encounters stiff

resistance to any changes because the employees have enjoyed

being ‘home alone’.”

• “The prolonged vacancy at the agency diminished the stature of the

office and did not make it an inviting place for experienced oversight

staff to want to work.”
Page 37 GAO-18-270 Inspector General Vacancies

IG vacancies seen as lack of support. Five respondents reported that 

prolonged vacancies are seen as a lack of congressional or agency 

support for the OIG, as noted in the following examples of individual 

comments:

• “Prolonged vacancies in the IG position . . . can be viewed by some

as a lack of support for the IG oversight mission on the part of the

Administration and Congress.”

• “Any individual serving in any position with the word ‘acting’ in front of

it inherently carries less authority than the same individual in the same

position serving in a permanent capacity. The longer an IG position is

left vacant the greater the appearance that the agency does not want

to have an IG providing oversight.”

OIG employees’ views on the inherent independence of an acting IG as 

compared to the independence of a permanent IG are summarized in 

figure 10. 

OIG Employees’ Views on the 

Impact of IG Vacancies on the 

Ability to Maintain 

Independence
Page 38 GAO-18-270 Inspector General Vacancies

Figure 10: Office of Inspector General Employees’ Views on Acting Inspector 

General Inherent Independence

Note: All percentages are estimates. The whiskers show the upper and lower bounds of the 

estimate’s 95 percent confidence interval.

Based on our survey, we estimate that 16 percent of the OIG employees 

believe that an acting IG is inherently less independent than a permanent 

IG. Of the employees who responded “yes,” 25 provided written 

explanations along with their answers, some of which are summarized 

below.

The acting IG may be seeking a permanent position. Eleven OIG 

employees provided comments related to the acting IG seeking a 

permanent position, as noted in the following examples of individual 

comments:

• “If interested in permanent appointment, there is a risk that [the] acting

IG becomes more interested in being liked by and pleasing the

agency, thus independence could be impaired.”
Page 39 GAO-18-270 Inspector General Vacancies

• “An acting Inspector General may be seeking an IG appointment.

He/she wants the agency to like him, to support his nomination, and

may kowtow [i.e., act subservient] to them. This dynamic may result in

a ‘don’t rock the boat’ mentality.”

• “If the acting IG is going to be a candidate for the IG position, and is

appointed by the head of the agency, they may stay away from

reviewing sensitive issue areas.”

The acting IG came from within the OIG. Three OIG employees 

provided comments related to the acting IG selected from within the OIG 

having preconceived notions, as noted in the following examples of 

individual comments:

• “Our acting Inspector General was previously the [Assistant] IG for

Audits and Evaluation. As such, [the acting IG] entered the position

with substantial preconceived notions about the other directorates. In

contrast, our permanent IG came to the position with limited

preconceived notions. In the future, it would be better if the Acting IG

came from another IG (as opposed to temporarily promoting from

within).”

• “I believe that an acting IG is inherently less independent because he

or she has no official term, may either receive an appointment as IG,

or be replaced at the discretion of the President.”

• “Bring in an acting IG from another agency for independence reasons

or [to] ensure other acting positions are filled and the acting IG is not

performing multiple roles.”

Based on our survey, we estimate that 52 percent of the OIG employees 

believe that an acting IG is not inherently less independent than a 

permanent IG. Of the 71 employees who responded “no” to this question, 

56 provided written explanations, some of which are summarized below.

There is no difference between the permanent IG and an acting IG.

Eighteen OIG employees provided comments related to the acting IG and 

permanent IG as having no difference, as noted in the following examples 

of individual comments:

• “We saw absolutely no difference in the independence of the acting IG

[versus] the appointed IG.”

• “The acting title (as compared to a permanent IG title) is irrelevant. It

ALL comes down to the specific individual occupying the position.”
Page 40 GAO-18-270 Inspector General Vacancies

• “The Inspector General is independent by law. The authority of the

position is the same, whether it is filled by an acting IG or a

permanent IG. . . . I have not encountered circumstances in which I

felt the acting IG was inherently less independent.”

• “The acting IG at [our agency] was the Deputy IG who is a strong

ethical and principled leader. There was no change to our mission,

focus, or independence, nor in our ability to conduct our work. To

suggest that, merely because there was an acting IG, independence

was inherently compromised is unfounded, bespeaks a lack of

understanding of OIG standards and ethics, and is just wrong.”

• “The acting IG served as any IG would be expected to in the area of

independence. No difference there.”

An acting IG is independent. Nineteen OIG employees provided 

comments related to the acting IG’s independence, as noted in the 

following examples of individual comments:

• “Based on my experience, both acting IGs were career OIG

employees [who] understood and embraced independence.”

• “I felt the acting IG was very independent and did a fantastic job.”

• “All persons within the OIG are to be objective and independent, no

matter their position.”

• “[The] acting IG [has] the same level of independence that is expected

of all IG employees.”

• “[The] acting IG is as independent as our previous [permanent IG] and

is not hesitant to report problems and weaknesses to Congress.”

An acting IG and permanent IG follow the same independence 

standards. Six OIG employees provided comments related to the acting 

IG and permanent IG as having the same independence standards, as 

noted in the following examples of individual comments:

• “The acting [IG] is subject to the same standards.”

• “The acting IG is just as important and they adhered to all the laws

and regulations as the [permanent] IG.”

• “Acting or permanent, they are held to the same standards of

independence.”

An acting IG position is not less independent. Six OIG employees 

provided comments related to the acting IG position not being less 
Page 41 GAO-18-270 Inspector General Vacancies

independent and depending on the individual in the role, as noted in the 

following examples of individual comments:

• “Whether an acting IG is able to maintain independence is dependent

upon the person holding the position and his or her confidence,

strength of character, leadership capabilities and subject matter

expertise. The same is true for [permanent] IGs.”

• “It depends on the individual. If a particular acting IG is a strong

person, who puts aside any desire to pander to the agency head in

the hope of being made permanent, there would be no effect on

his/her independence.”

We also asked OIG employees to identify any additional challenges they 

experienced in relation to working under an acting IG. Overall, 83 

employees provided written responses, and 4 of those responses were 

additional challenges related to OIG independence, as noted in the 

following examples of individual comments:

• “Having worked in [various] OIGs and [having] observed functioning in

other OIGs, the acting IG issue seems serious. There are subtle

pressures to go along with management. Few acting IGs deliberately

decide to compromise their principles, but many seem to wind up

doing so.”

• “Because the acting IG wanted to gain the support of others, [he] was

not independent.”

• “The one challenge I am concerned [about] with an acting IG is if that

person has applied for the IG position and will not commit to certain

decisions that will negatively impact their opportunity to obtain the

permanent position as IG.”

We also asked OIG employees to provide suggestions on how the 

independence of the acting IG role could be improved. The majority of the 

25 respondents who provided written comments to this question did not 

provide suggestions for improving the independence. The comments that 

provided suggestions are summarized below:

• Timely appoint an IG (4 respondents).

• Consult with other CIGIE IGs to help monitor and assess the acting IG

based on clear criteria and expectations (1 respondent).

• Limit the amount of time an acting IG can serve (1 respondent).
Page 42 GAO-18-270 Inspector General Vacancies

• Bring in an acting IG from another agency for independence reasons

or ensure that other acting positions are filled and the acting IG is not

performing multiple roles (1 respondent).

Prolonged IG vacancies have been the subject of congressional hearings 

because of the importance of these key oversight positions.25 Delays in 

the presidential nomination and Senate confirmation process for all 

positions filled by this process, including PAS OIGs, have also been the 

subject of recent academic studies.26 For example, a recent study that 

explored the failure of nominations and the delay in confirmation of 

successful nominations across recent administrations from 1981 to 2014, 

found that nominations for the IG position had about a 24 percent failure 

rate.27 Given that in recent years, certain OIGs have experienced 

prolonged IG vacancies, especially IGs that require presidential 

nomination and Senate confirmation, we asked the 52 surveyed 

permanent IGs to provide comments on their experience with the 

appointment process and any suggestions for improving the process and 

minimizing the duration of IG vacancies. Comments were provided by 45 

permanent IGs in these areas, including eight suggestions to minimize 

the duration of IG vacancies, as noted in the following individual 

comments:

• “One thing that could be improved [is] an agreement between the

[White House], Congress and [Office of Government Ethics] on a

[similar] format for [nominee required] information. I was required to

provide essentially the same information (with small variations) three

times. But the precise formatting and framing of the questions [asked

of the nominees] was different in each case, taking time and creating

the possibility of inconsistencies.”

25Watchdogs Needed: Top Government Investigator Positions Left Unfilled for Years, 

Before the Senate Committee on Homeland Security & Governmental Affairs, 114 Cong. 

7-9 (2015) (Michael Horowitz, Chair of the Council of the Inspectors General on Integrity 

and Efficiency), and Where Are All the Watchdogs? Addressing Inspector General 

Vacancies, Before the H. Comm. on Oversight and Government Reform, 112 Cong. 6-14 

(2012) (Phyllis K. Fong, Chair of the Council of the Inspectors General on Integrity and 

Efficiency).

26Paul Light, “Back to the Future on Presidential Appointments,” Duke Law Journal, vol. 

64, no. 8 (2015).This article covers a collection of other publications that have discussed 

presidential nomination process issues and past efforts to improve this process.

27Anne Joseph O’Connell, “Shortening Agency and Juridical Vacancies through Filibuster 

Reform – An Examination of Confirmation Rates and Delays from 1891 to 2014,” Duke 

Law Journal, vol. 64, no. 8 (2015). 

Suggestions from 

Permanent IGs for 

Improving the Appointment 

Process
Page 43 GAO-18-270 Inspector General Vacancies

• “A possible suggestion would be to improve the timeliness of the

selection, vetting, and confirmation process of IGs, particularly given

the current number of vacancies. IGs play a vital role in ensuring that

government programs and operations are functioning efficiently and

effectively, and greater emphasis on the part of the White House and

Congress to nominate and confirm IGs in a timely manner would

provide great benefit.”

• “I believe the process could be improved by streamlining the number

of committees involved so that each nominee need only obtain

approval from one committee.”

• “While I worked through the paperwork requirements efficiently, it was

a tremendous lift and I wonder if all that is required is necessary and

in the form it took. I found a good degree of duplication in what was

asked of [candidates] from the [White House] . . . and Senate. I think

there are opportunities to streamline with better coordination.”

• “[Establishing] a timeline from start to finish would be helpful. I also

recommend that Congress prioritize IG confirmations above most

other confirmations.”

• “Faster consideration and vote would be useful.”

• “The Senate [should] be required to act on IG candidates within 90

days of their nomination by the President.”

• “Although I think it is very important for any IG to have a strong

working relationship with the agency head, it seems inappropriate for

the agency head to have a strong voice in selecting the nominee for a

[p]residentially appointed, Senate-confirmed IG who is supposed to

provide independent oversight of the agency. I suggest changing the

process to omit the pre-selection interview with the agency head and

substitute instead [with] a pre-nomination courtesy meeting.”

We provided a draft of this report to CIGIE for comment and CIGIE 

shared the draft with the 64 OIGs active under the IG Act. CIGIE and the 

OIGs at the National Credit Union Administration and U.S. Election 

Assistance Commission provided written comments, which are discussed 

below and reprinted in appendixes II, III, and IV, respectively. 

• CIGIE expressed appreciation for the review and analysis efforts that

we conducted for the purposes of this report. CIGIE also noted some

information regarding the Central Intelligence Agency IG and the

Intelligence Community IG, which were outside the scope of our work.

Agency Comments 

and Our Evaluation
Page 44 GAO-18-270 Inspector General Vacancies

CIGIE stated that both IGs are PAS and that the Central Intelligence 

Agency IG position has been vacant for over 3 years. 

• The National Credit Union Administration OIG stated that while it did

not have a vacancy during the 10-year period we reviewed, it agreed

that looking at this area to reduce IG vacancies is an important

endeavor.

• The U.S. Election Assistance Commission OIG expressed

concurrence with the facts as they pertain to its office and stated that

the report will contribute to improving the appointment process for

IGs.

In addition, CIGIE and the OIGs at the Appalachian Regional 

Commission, Denali Commission, Department of Commerce, Department 

of Education, Department of Housing and Urban Development, Federal 

Deposit Insurance Corporation, General Services Administration, National 

Reconnaissance Office, and U.S. Election Assistance Commission

provided technical comments, which we incorporated as appropriate. The 

remaining OIGs did not provide comments.

We are sending copies of this report to the Executive Director of CIGIE

and to the 64 IG Act offices listed in this report as well as interested 

congressional committees. In addition, the report is available at no charge 

on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-2623 or davisbh@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix V. 

Beryl H. Davis

Director 

Financial Management and Assurance
Appendix I: Objectives, Scope, and

Methodology

Page 45 GAO-18-270 Inspector General Vacancies

The objectives of this report were to determine (1) the status of inspector 

general (IG) vacancies as of the end of fiscal year 2017, and the number 

and duration of the IG vacancies for fiscal years 2007 through 2016, and 

(2) the views of the IG community on the impacts, if any, of IG vacancies 

on the Offices of Inspector General’s (OIG) ability to effectively carry out 

their duties, including views on independence and permanent IG 

suggestions for improvements in the appointment process. To address 

these objectives we included in our scope the 64 active OIGs that were 

established under the IG Act of 1978, as amended (IG Act). 1

 

To determine the status of IG vacancies as of the end of fiscal year 2017, 

we obtained the vacancy data from the 64 OIGs active under the IG Act, 

and documented any changes for fiscal year 2017. To identify IG 

vacancies and changes for fiscal years 2007 through 2016, we first 

obtained vacancy data from the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE). We interviewed CIGIE personnel to 

obtain an understanding of issues related to IG vacancies and to discuss 

the reliability of the vacancy data.2 Data obtained from CIGIE included the 

resignation dates of the permanent IGs, vacancy start and end dates, 

names of the acting IGs, names of newly appointed IGs, and whether 

each IG was presidentially appointed, Senate confirmed (PAS) or 

appointed by the head of a designated federal entity (DFE). We also 

obtained nominations from Congress.gov, which included information on 

nominated IGs and the status of those nominations.3 As part of our data 

reliability procedures, we confirmed the vacancy data with the 64 OIGs 

established under the IG Act. We reviewed and summarized the IG 

1

We did not include IG positions established by other statutes because of the variations in 

those authorizing statutes regarding the appointment, authorities, and duties of these IGs. 

IG positions established by statutes other than the IG Act include the IGs for the Central 

Intelligence Agency, the Intelligence Community, the Government Printing Office, the 

Library of Congress, the Architect of the Capitol, the U.S. Capitol Police, and GAO, as well 

as the Special IGs for Afghanistan Reconstruction and for the Troubled Asset Relief 

Program. Also, the IG Act includes authorization for some additional OIGs that are not 

presently active, many because of the termination of their associated agencies or the 

agencies’ integration into larger federal entities. 

2

We interviewed the CIGIE Executive Director, the current and former CIGIE Chair, and 

the current CIGIE Vice-Chair.

3

Congress.gov is the official website for U.S. federal legislative information. The site 

states that it provides access to accurate, timely, and complete legislative information for 

Members of Congress, legislative agencies, and the public. The website has a presidential 

nominations database that includes the date each nomination was received from the 

President, the committee(s) involved for the nomination, and the Senate actions related to 

the nomination.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-18-270 Inspector General Vacancies

vacancy data and documented any changes in IG vacancies for fiscal 

years 2007 through 2016. In 2014, the IG appointment structure for the 

IGs of the National Security Agency and National Reconnaissance Office 

was changed from DFE to PAS. For the 10-year period under review, 

these two OIGs experienced vacancies during both their DFE and new 

PAS status. However, to avoid duplicating the agencies, we only counted 

the number and length of vacancies for each agency under the PAS IGs.

To obtain the views of the IG community—specifically, permanent IGs, 

acting IGs, and employees working under an acting IG—on the impact 

that a prolonged IG vacancy can have on the OIG’s ability to carry out its 

duties effectively, including any impact on independence, we conducted 

web-based surveys of 54 IG Act OIGs. These surveys included both 

multiple choice and open-ended questions for written responses to obtain 

the views of the IG community on the impacts of vacancies, if any, and 

views on independence, challenges, and positive outcomes. The 

surveyed groups were as follows:

• Fifty-two permanent IGs serving as of August 22, 2017.We used both

multiple choice questions and open-ended questions to obtain their

views on the impact that an IG vacancy could have on the OIG’s

ability to conduct its oversight, including any independence issues

presented by acting IG. We also asked the permanent IGs to provide

any suggestions for improvements in the appointment process. The

survey was administered on the web from August 22, 2017, through

September 29, 2017. The survey response rate of permanent IGs was

96 percent: 50 of the 52 permanent IGs completed the survey. Two

permanent IGs did not respond to the survey.

• Nine acting IGs who had served for over 365 days from fiscal years

2014 through 2016. We used both multiple choice questions and

open-ended questions to obtain their views on the impact that a

prolonged vacancy could have on the acting IG’s ability to carry out

his or her duties, including any impact on independence. The survey

was administered on the web from August 22, 2017, through

September 29, 2017. The survey response rate of acting IGs was 100

percent. While 14 acting IGs met our selection criteria, 4 have either

retired or have since left the government and were not surveyed. The

National Reconnaissance Office’s acting IG was excluded because of

concerns regarding sensitive personally identifiable information. Of

the 9 remaining acting IGs, 2 are now permanent IGs but provided

responses for their acting IG tenure, which were included with those

of the 7 acting IGs. In this report, we refer to all nine as acting IGs.
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-18-270 Inspector General Vacancies

• A stratified random sample of 185 OIG employees consisting of 39

Senior Executive Service (SES) employees and 146 non-SES OIG

employees, from OIGs with an acting IG in place for over 365 days

from fiscal years 2014 through 2016. We used both multiple choice

questions and open-ended questions to obtain the employee views

about challenges related to working under an acting IG as compared

to a permanent IG. The web-based survey was administered from

September 11, 2017, through September 29, 2017. We had a

weighted survey response rate of 71 percent; 133 of the sample of

185 employees completed the survey.

Because we followed a probability procedure based on random 

selections, our OIG employee sample is only one of a large number of 

samples that we might have drawn. Since each sample could have 

provided different estimates, we express our confidence in the precision 

of our particular sample’s results as a 95 percent confidence interval 

(e.g., plus or minus 10 percentage points). This is the interval that would 

contain the actual population value for 95 percent of the samples we 

could have drawn. Confidence intervals are provided along with each 

sample estimate in the report. Estimates from the employee survey are 

generalizable to the population of employees from OIGs that had an 

acting IG in place for over 365 days from fiscal years 2014 through 2016. 

To minimize nonsampling errors, and to enhance data quality, we 

employed recognized survey design practices in the development of the 

questionnaire and in the collection, processing, and analysis of the survey 

data. To minimize errors arising from differences in how questions might 

be interpreted and to reduce variability in responses that should be 

qualitatively the same, we conducted pretests with permanent IGs, acting 

IGs, and employees.

To ensure that we obtained a variety of perspectives on our survey 

questions, we randomly selected three permanent IGs, two acting IGs, 

and two employees for the pretests. Based on their feedback, we revised 

each survey in order to improve the clarity of the questions. An 

independent survey specialist within GAO also reviewed a draft of each 

survey prior to its administration. To reduce nonresponse, another source 

of nonsampling error, we followed up by e-mail or phone with the IGs, 

acting IGs, and employees who had not responded to encourage them to 

complete the survey.

We did not survey a total of 10 IG Act OIGs. Nine OIGs were not 

surveyed because there was no permanent IG in position or the acting IG 

at the time of our survey did not meet our criteria of serving for more than 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-18-270 Inspector General Vacancies

365 days from fiscal year 2014 through 2016. Those OIGs were at the 

U.S. Postal Service, Social Security Administration, Small Business 

Administration, Office of Personnel Management, National Security 

Agency, Federal Election Commission, Department of Housing and Urban 

Development, Department of Energy, and Department of Defense. In 

addition, one OIG, the National Reconnaissance Office, was not surveyed 

because of concerns regarding sensitive personally identifiable 

information.

We also performed a two-step content analysis on the open-ended survey 

responses to summarize key ideas. In the first step, analysts read the 

respondents’ comments and jointly developed categories for them. In the 

second step, each open-ended response was coded by one analyst, and 

then those codes were verified by another analyst. Any coding 

discrepancies were resolved by the analysts discussing the comments 

and then agreeing on the code. In some cases, we edited responses for 

clarity or grammar. Views expressed in the open-ended questions may 

not be representative of all acting IGs, permanent IGs, or employees on 

given topics. We did not assess the merits of the individual comments or 

suggestions provided in response to the open-ended survey questions.

We conducted this performance audit from February 2017 to March 2018 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 
Appendix I: Objectives, Scope, and

Methodology

Page 49 GAO-18-270 Inspector General Vacancies

Appendix II: Comments from the Council of 

the Inspectors General on Integrity and 

Efficiency
Appendix I: Objectives, Scope, and

Methodology

Page 50 GAO-18-270 Inspector General Vacancies

Appendix III: Comments from the National

Credit Union Administration Office of 

Inspector General
Appendix I: Objectives, Scope, and

Methodology

Page 51 GAO-18-270 Inspector General Vacancies

Appendix IV: Comments from the U.S. 

Election Assistance Commission Office of 

Inspector General
Appendix I: Objectives, Scope, and

Methodology

Page 52 GAO-18-270 Inspector General Vacancies

Beryl H. Davis, (202) 512-2623 or davisbh@gao.gov

In addition to the contact named above, Elizabeth Martinez (Assistant 

Director), Carl Barden, Jason Kirwan, Christopher Klemmer, Jill Lacey, 

Won Lee, Yvonne Moss, and Lisa Rowland made key contributions to this 

report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101676)
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