U.S. Department of Commerce 

Office of Inspector General 

Semiannual Report to Congress
 

March 2012 
OFFICE OF 

INSPECTOR GENERAL 

Inspector General 

Deputy 

Inspector General Office of 

Administration 

Office of Audit 

and Evaluation 

Office of 

Investigations 

Office of Counsel 

Oversight Areas 

Office of the Secretary 

Bureau of Economic Analysis 

Bureau of Industry and Security 

U.S. Census Bureau 

Economic Development Administration 

Economics and Statistics Administration 

International Trade Administration 

Minority Business Development Agency 

National Institute of Standards and Technology 

National Oceanic and Atmospheric Administration 

National Technical Information Service 

National Telecommunications and 

Information Administration 

United States Patent and Trademark Office 

OIG Main Number 

Inspector General. . . . . . . . . . . . . . . . . . . . . . . . . . .202.482.4661 

OIG Hotline 

Telephone. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .202.482.2495 

or 800.424.5197 

TDD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .202.482.5923 

or 800.854.8407 

E-mail. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .hotline@oig.doc.gov 

More Information 

Visit www.oig.doc.gov to learn more about our activities, 

download reports and testimony, and subscribe to 

our RSS feed for website updates. E-mail website 

comments to oigweb@oig.doc.gov. 
U.S. Department of Commerce 

Office of Inspector General 

Semiannual Report to Congress
 

March 2012 
4 Office of Inspector General | Semiannual Report to Congress | March 2012 

 

 

 

 

 

TABLE OF 


CONTENTS
 

01 FROM THE INSPECTOR GENERAL 

06 TOP MANAGEMENT CHALLENGES FACING THE DEPARTMENT 

12 WORK IN PROGRESS 

16 OVERSIGHT AREAS 

16 DEPARTMENT-WIDE MANAGEMENT 

24 ECONOMICS AND STATISTICS ADMINISTRATION 

26 NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION 

30 NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION 

32 UNITED STATES PATENT AND TRADEMARK OFFICE 

36 AMERICAN RECOVERY AND REINVESTMENT ACT 

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY 

NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION 

42 STATISTICAL DATA 

52 REPORTING REQUIREMENTS 

54 ACRONYMS AND ABBREVIATIONS 
5 

FROM THE 

INSPECTOR GENERAL 

I am pleased to present the Department of Commerce Office of Inspector General’s 

Semiannual Report to Congress for the 6 months ending March 31, 2012. 

This report summarizes work we initiated and completed during this semiannual 

period on a number of critical departmental activities. Over the past 6 months, our 

office issued 19 audit and evaluation reports addressing programs overseen by the 

National Institute of Standards and Technology, National Oceanic and Atmospheric 

Administration, National Telecommunications and Information Administration, United 

States Patent and Trademark Office, and the Department itself. 

Looking ahead, we will continue to prioritize our work consistent with the Top 

Management Challenges Facing the Department report we issued in October 

2011. For fiscal year 2012, we identified two new cross-cutting goals that focus 

on the President’s initiatives for economic recovery and job creation: (1) promote 

exports, stimulate economic growth, and create jobs and (2) reduce costs and 

improve operations to optimize resources in a period of constrained budgets. The 

remaining three challenges are long-standing departmental concerns: information 

technology security, acquisitions and contracting, and NOAA’s satellite program. We 

will work closely with the Department and with Congress in the months ahead to 

meet these and other challenges facing Commerce as it fulfills its complex mission. 

We welcome Secretary Bryson to the Department and look forward to a productive 

and collaborative association with him. We also thank senior officials throughout the 

Department and members of Congress and their staffs for their support of our work 

during this reporting period and for their receptiveness to our recommendations for 

improving Commerce operations. 

TODD J. ZINSER
 
 

 

6 Office of Inspector General | Semiannual Report to Congress | March 2012 

TOP MANAGEMENT 

CHALLENGES FACING 

THE DEPARTMENT 

The Reports Consolidation Act of 2000 requires inspectors general to 

identify the top management challenges facing their departments. In 

October 2011, the Department of Commerce OIG identified five challenges 

that require significant departmental attention in FY 2012 and beyond. OIG 

will issue updates to these challenges in a separate June 2012 publication. 

1. EFFECTIVELY PROMOTE EXPORTS, STIMULATE ECONOMIC GROWTH, 

AND CREATE JOBS 

The Department is at the center of the federal government’s efforts to promote exports and stimulate 

economic development while regulating imports and exports, marine fisheries, and patents and 

trademarks. Effective implementation of these initiatives requires the Secretary to work closely with 

interagency partners and integrate Department resources in order to: 

Implement Administration Initiatives with Effective Interagency Partnerships. 

More than 20 federal agencies perform trade-related functions. The Department plays a critical 

role in working with these partners to implement the administration’s three government-wide 

initiatives: promote U.S. exports, reform the export control system, and reorganize the federal 

government’s trade promotion responsibilities. The Department reported that, as of August 

2011, the joint efforts by Export Promotion Cabinet agencies have resulted in a 17 percent 

increase in exports since 2009. However, ongoing management attention will be necessary to 

promote continued progress in these areas. 

Enhance Commerce Unit Operations to Help Promote Trade and Job Creation. 

Various bureaus within the Department engage in trade-related functions. The Department 

began improving coordination among these units by launching “CommerceConnect” in 

2009—a website providing a portfolio of government assistance to businesses. The Department 

continues facing challenges: 

•	 repatriating manufacturing jobs in America; 

•	 allocating resources to support the President’s National Export Initiative; 

•	 reducing patent backlog, improving processing times, and implementing patent reform; 

•	 improving technical and financial assistance to promote domestic job growth; and 

•	 ensuring the elimination of social and economic surveys does not adversely affect vital 

national indicators. 

Correct Unfair Trade Practices and Protect Our National Security Through 

Enforcement Activities. 

While trade promotion is an essential part of its mission, the Department must also maintain 

strong trade enforcement programs, so that the United States can thrive in the global 

marketplace. Among the bureaus, BIS faces the greatest challenge as it helps to implement the 

long-term goals of the Export Control Reform initiatives. 
Top Management Challenges Facing the Department 7 

Improve Regulatory Reviews to Protect and Promote Public Interests. 

In addition to imports and exports, the Department is also responsible for regulating marine 

fisheries (to protect ocean resources) and patents and trademarks (to protect intellectual 

property). The Department should conduct adequate cost–benefit analyses and identify 

meaningful performance measures for regulatory activities to avoid overburdening affected 

industries. This is especially important for balancing NOAA’s goals of protecting the environment 

and supporting the fishing industry. 

2. REDUCE COSTS AND IMPROVE OPERATIONS TO OPTIMIZE RESOURCES FOR A 

DECADE OF CONSTRAINED BUDGETS 

As the government prepares for an extended period of tighter budgets and decreased spending, 

it is most important to target waste, reduce inefficiency, and ensure that taxpayers’ dollars 

are spent wisely. It will be difficult, but possible, to leverage savings to support investments in 

economic growth. Agencies should: 

Implement and Expand Initiatives to Improve Operational Efficiency and Economy. 

The Department has an initiative in place to save $143 million in administrative costs in 

FYs 2011 and 2012. About 60 percent of the target savings would derive from reduction 

in facilities, information technology (IT), and workforce. The remaining 40 percent would 

derive from more strategic sourcing and reducing the use of high-risk acquisition contracts. 

Relentless management attention and oversight of reported savings are critical to achieving the 

Department’s goal. 

Strengthen Oversight of Improper Payments for Additional Recoveries. 

The Department can increase efforts to implement the Improper Payments Elimination and 

Recovery Act of 2010—and maximize the dollars it recovers from improper payments. Adjusting 

payment testing practices and focusing on highest risk programs are key. 

Reduce the Risk of Misuse, Abuse, or Waste of Federal Funds Awarded to Grantees. 

In June 2011, the Department reported about $10 billion accumulative outstanding obligations, 

more than half of which were for grants. The diversity and duration of the Department’s 

grant programs further highlight the need to examine ways to standardize and streamline its 

management processes, such as consolidation of the Department’s three separate grants 

management systems and better use of OIG and single audit reports to detect emerging issues. 

With $4 billion in funding, the Broadband Technology Opportunities Program (BTOP) 

represents a significant investment of Recovery Act funds to develop and deploy broadband 

services nationwide. The success of BTOP depends on the coordinated efforts of NTIA and 

its grant management partners, NOAA and NIST. However, the uncertain funding for BTOP 

oversight in FY 2013 and beyond (i.e., to oversee the closeout of projects and the completion 

of projects that receive extensions) raises concerns about NTIA’s ability to adequately oversee 

the program’s future. 

Apply Lessons Learned from 2010 Decennial to Planning for the 2020 Census to 

Avoid Cost Overruns. 

Given projections of increasing life-cycle cost estimates to $22–30 billion, Census has to 

fundamentally change the design, implementation, and management of the 2020 decennial 

census. The decade’s early years are critical for deciding on a design and implementing 

changes to decennial operations. With funding constraints likely, the bureau needs to prioritize 

its research and testing to determine the feasibility, cost, and data-quality impacts of proposed 

census design changes. 
8 Office of Inspector General | Semiannual Report to Congress | March 2012 

3. STRENGTHEN DEPARTMENT-WIDE INFORMATION SECURITY TO PROTECT 

CRITICAL INFORMATION SYSTEMS AND DATA 

In recent years, the federal government—and the Department in particular—have increasingly 

taken advantage of Internet-based technologies to interconnect IT systems and conduct 

business with the public. As this trend continues, cyberattacks on Internet commerce, vital 

business sectors, and government agencies have grown exponentially. To address such threats, 

the Department plays a leading role in developing public policies and private-sector standards 

and practices. But the Department’s own IT systems are constantly exposed to increasingly 

numerous and sophisticated cyberattacks. We have recommended that the Department: 

Continue Working to Improve IT Security by Addressing Ongoing Security 

Weaknesses. 

For our FY 2010 Federal Information Security Management Act of 2002 report to the 

Department, we evaluated 18 Department IT systems and concluded that the Department’s 

information security program and practices have not adequately secured Department systems. 

In response to our recommendations, the Department developed an action plan to address the 

security weaknesses we identified—and, in the past year, the Department has taken several 

steps toward improving IT security. However, until the Department successfully implements the 

items in its action plan, we can expect to find recurring security weaknesses. Our FY 2012 work 

continues to find significant security weaknesses in Department and contractor systems that put 

the systems at risk of cyberattack. 

Implement Security Policy Effectively Through Consistent, Proactive Management. 

Our audits reaffirm the need for increased senior management attention to ensure security policy 

and practices are applied consistently and effectively across the Department. For example, we 

reviewed a sample of FY 2010 and FY 2011 performance plans for individuals holding critical 

IT security roles—and found that requirements for these roles are not consistently incorporated 

in some of the performance plans. Additional cyberinfrastructure challenges the Department 

faces include securing hundreds of Internet connection points on Departmental networks and 

establishing enterprise monitoring capability and a cybersecurity center. 

4. MANAGE ACQUISITION AND CONTRACT OPERATIONS MORE EFFECTIVELY TO 

OBTAIN QUALITY GOODS AND SERVICES IN A MANNER MOST BENEFICIAL TO 

TAXPAYERS 

In FY 2010, the Department obligated nearly $4 billion through more than 26,000 contract 

actions to acquire a wide range of goods and services to support mission-critical programs. 

While the Department has made some progress in this important area, it should continue to: 

Develop and Retain a Qualified Acquisition Workforce. 

Recruitment, training, and retention pose risks to the Department’s ability to meet its increasing 

acquisition workload. In FY 2010, the Department experienced a 15 percent attrition rate 

among contracting officers. Further, between FYs 2009 and 2019, 54 percent of the seniorlevel acquisition employees in the Department will be eligible to retire. The Department lacks a 

sufficient pipeline of entry- to mid-level professionals to sustain operations during the projected 

retirement wave. 
Top Management Challenges Facing the Department 9 

Ensure High Ethical Standards in the Acquisition Workforce and in Procurement 

Practices. 

Government contracting is risky by nature. Department employees in contract-related positions 

represent the front line of defense by promptly recognizing and reporting ethics violations 

and fraud indicators. The Department needs to take actions to prevent recurrence of OIG 

investigative findings—questionable sole sourcing practices against advice of counsel, steering 

contracts to acquaintances, splitting purchase card transactions to circumvent spending limits, 

and improper communications with unsuccessful contract bidders. The Department also needs 

to strengthen its suspension and debarment program, which would help to ensure it awards 

contracts and grants only to responsible parties. The Department’s current suspending and 

debarring official has begun to develop the processes and policies that form the foundation of 

a successful suspension and debarment program. Despite this recent progress, creating an 

efficient and durable program remains a challenge. 

Strengthen Processes to Govern the Appropriate Use of High-Risk Contracts and to 

Maximize Competition. 

High-risk contracts—including contracts awarded noncompetitively or in which only one 

bid was received, cost-reimbursement contracts, and time-and-materials and labor-hour 

contracts—comprised almost 40 percent of the total value of new contract awards in FY 2010. 

The Department needs to reduce high-risk contract awards and exercise strong oversight of 

performance-based contracts such as cost-plus-award-fee. Although designed to motivate 

excellence in contractor performance, without strong oversight, performance-based contracts 

can represent an additional risk to the Department. 

Achieve Efficiency and Savings in Acquiring Goods and Services, and Improve 

Oversight and Tracking of Contract Savings. 

The Office of Management and Budget (OMB) requires agencies to focus on cutting contract 

costs by using smarter buying practices. The Department has taken steps to improve its 

monitoring and verification of the cost savings reported by the bureaus’ procurement offices. 

While these efforts to improve reporting represent real progress, continued attention will be 

needed to meet the level of accountability called for by OMB. 

Deliver Cost Savings and Efficiency on Major IT Investments. 

The Department spends about 25 percent of its annual budget on IT investments—one of the 

highest percentages among federal agencies. Accordingly, the Department must watch for 

any opportunity to save money, improve efficiency, and prevent setbacks to these important 

investments. For instance, the Department reported serious cost and schedule problems 

concerning four NOAA IT investment projects, totaling $265 million. In addition, we have 

identified challenges and offered recommendations to improve USPTO’s Patent End-to-End 

acquisition initiative with an estimated cost of $130 million. 
10 Office of Inspector General | Semiannual Report to Congress | March 2012 

5. MANAGE THE DEVELOPMENT AND ACQUISITION OF NOAA’S ENVIRONMENTAL 

SATELLITE SYSTEMS TO AVOID LAUNCH DELAYS AND COVERAGE GAPS 

NOAA’s environmental satellite operations and weather forecasting are designated primary 

mission-essential functions of the Department of Commerce. But NOAA’s current constellation 

of polar and geostationary operational environmental satellites is aging, and its capabilities will 

degrade over time. As a result, the risk of gaps in critical satellite data is increasing. In February 

2010, the White House directed NOAA, in partnership with NASA, to establish the Joint Polar 

Satellite System (JPSS) program—after experiencing significant cost overruns and schedule 

delays with an earlier joint development effort among NOAA, NASA, and the Department of 

Defense. Given their histories, these critical satellite programs require strong management and 

close oversight to: 

Prevent a Near-Term Polar Satellite Coverage Gap Between NOAA-19 and NPP. 

Since the first JPSS satellite (JPSS-1) is not scheduled for launch until 2017, NOAA will 

use an interim satellite—the Suomi National Polar-orbiting Partnership (NPP), launched in 

October 2011, to bridge the gap between JPSS-1 and its current polar-orbiting operational 

environmental satellite (NOAA-19). NOAA projects NPP will reach operational readiness 18 to 

24 months after launch because of delays in completing activities to provide data for operational 

use. This extension could lead to a coverage gap in some data if NOAA-19 (or other satellite 

data sources) stops functioning at the end of its design life—approximately March 2013. NOAA 

needs to take effective steps to reduce the risk of such a data gap. 

Ensure Solid Program Management and Systems Engineering Principles Are Applied 

to Mitigate the Coverage Gap Between NPP and JPSS-1. 

Due to program and funding issues, NOAA expects a gap in weather and climate observations 

between NPP and JPSS-1. We project the gap could range from 9 to 21 months, or even 

longer, if NPP experiences a shorter-than-expected life. NOAA studies have found that its 

weather forecasting at 5, 4, and 3 days before an event could be significantly degraded during 

the coverage gap period. NOAA—in coordination with its line officers and in concert with 

Departmental and congressional decision-makers—must minimize the potential impact of this gap. 

Maintain Robust Program Management and Systems Engineering Disciplines to 

Prevent Geostationary Coverage Gaps. 

NOAA relies on another satellite system—the Geostationary Operational Environmental 

Satellite-R Series (GOES-R)—for uninterrupted short-range severe weather warning. This 

development program also experienced problems of cost changes and reduced capabilities. 

According to March 2012 program documentation, the GOES-R program’s overall schedule 

and technical development remain on track; however, the ground project’s development is being 

modified to control costs. The program is also revising the ground segment’s schedule to allow 

more flexibility. In light of these developments, NOAA needs to control costs, keep schedules on 

track, and maintain required technical performance. 
11
 

 

12 

Department-Wide 

Recovery Acta 

NOAA 

ESAb 

USPTO 

EDA 

ITA 

NTIA 

Office of Inspector General | Semiannual Report to Congress | March 2012 

WORK IN 

PROGRESS 

WORK IN PROGRESS (BY OVERSIGHT AREA) 

During this reporting period, 23 OIG audits and evaluations were initiated or under way. 

7 

5 

4 

2 2 

1 1 1 

a Of these five Recovery Act–related works in progress, three concern NTIA, one concerns NIST, and one concerns 

lessons learned across all Department bureaus receiving Recovery Act funds. 

b Both ESA works in progress concern the Census Bureau. 

DEPARTMENT-WIDE 

FY 2012 Financial Statement Audits 

Determine whether the financial statements are presented fairly, in all material respects, in 

accordance with generally accepted accounting principles (an independent accounting firm 

will perform these audits, under OIG oversight, in accordance with generally accepted auditing 

standards, Government Auditing Standards, and OMB requirements). 

Preview of FY 2013 Top Management Challenges 

Inform the Department, in advance, of the most significant upcoming management and 

performance challenges facing the Department in FY 2013. 

FY 2013 Top Management Challenges 

From an oversight perspective, identify the most significant management and performance 

issues facing the Department in the upcoming fiscal year, as required by law. 
Work In Progress 13 

IT Security 

Assess the effectiveness of the Department’s IT security program by determining whether key 

security measures adequately protect the Department’s systems and its information, as required 

by the Federal Information Security Management Act of 2002. 

Purchase Card Controls 

Determine whether the Department has adequate transaction-level internal controls over 

purchase card transactions by reviewing a sample of transactions from all bureaus during FY 

2011. During FY 2011, the Department had more than 4,500 purchase cards that processed 

approximately $118.6 million in purchase card transactions. 

Time-and-Materials and Labor-Hour (T&M/LH) Contracts 

Assess whether the Department properly awards and administers these contracts. For FY 2011, 

Commerce awarded 2,893 high-risk T&M/LH contract actions for $586 million. Both contract 

types provide for payment to contractors on the basis of fixed hourly billing rates, designed to 

recover the contractors’ direct salaries, overhead, general and administrative expenses, and 

profit. T&M contracts also provide for reimbursement of the contractors’ actual costs of supplies 

and materials. 

Unliquidated Obligations 

Evaluate controls over the management and closeout of unused or unneeded (unliquidated) 

obligations. It is essential that the Department perform timely reviews of contract, grant, and 

other unliquidated obligations and deobligate funds no longer needed. This could result in 

funding available for other purposes. 

ECONOMIC DEVELOPMENT ADMINISTRATION 

Review of Trade Adjustment Assistance Center (TAAC) Administrative Costs 

Provide the House Committee on Appropriations with information on the reasonableness of 

administrative costs charged by the TAACs as part of the Trade Adjustment Assistance for 

Firms program administered by EDA—as requested in the report accompanying the FY 2012 

Commerce, Justice, Science, and Related Agencies Appropriations Bill. 

ECONOMICS AND STATISTICS ADMINISTRATION 

2020 Census Planning 

Evaluate the Bureau’s efforts to improve the 2020 Census design, focusing on how the results 

of the Bureau’s evaluation plans will inform the new decennial design, as well as evaluate 

and monitor the implementation of Census’s management initiatives designed to enhance 

organizational change. 

Map and Address Database 

Review Census’s progress toward achieving the objectives of its $496 million 2010 geographic 

initiative (2010 MAF/TIGER Enhancement Program); evaluate the impact of various addressupdating operations on the address file and map database and identify trends that introduced 

error; and review Census’s procedures for updating the map and address files. 
14 Office of Inspector General | Semiannual Report to Congress | March 2012 

INTERNATIONAL TRADE ADMINISTRATION 

Review of U.S. Export Assistance Centers (USEAC) 

Determine the extent to which the level of coordination between the U.S. and Foreign 

Commercial Service’s (CS) and other federal government agencies is sufficient to meet the 

President’s priorities with respect to the National Export Initiative, evaluate whether the allocation 

of domestic resources meets its mission and goals, and assess CS’s level of cost recovery for its 

products and services. 

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION 

Fishery Management Councils (FMCs) and Rulemaking 

Review controls, processes, and operational best practices used by NOAA FMCs to develop 

rules for the industry. Evaluate the role of NOAA and the FMCs in the fishery rulemaking process 

and the transparency of the rulemaking process prescribed under the Magnuson-Stevens 

Fishery Conservation and Management Act. 

Geostationary Operational Environmental Satellite-R Series (GOES-R) Acquisition 

and Development 

Assess the adequacy of contract management and administration and the effectiveness of 

management’s direction, monitoring, and collaboration for development of select components in 

the GOES-R program. 

Joint Polar Satellite System (JPSS) Program Baseline Adequacy 

Assess JPSS formulation activities—including development of requirements, schedule, and cost 

baselines—against NASA standards, government/industry best practices, and individual projectlevel plans. Monitor the program’s efforts to maintain (1) near-term continuity of polar satellite 

data as Suomi National Polar-orbiting Partnership (NPP) on-orbit operations transition to NOAA 

and (2) continuity of data after NPP end-of-life. 

Management of Cost-Plus-Award-Fee and Award-Term Contracts 

Determine whether (1) NOAA’s decisions related to award-fee and award-term ratings are 

properly supported and (2) NOAA effectively monitors award-fee and award-term plans and 

contractor performance. 

NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION 

Public Safety Interoperable Communications (PSIC) Grant Program Costs 

and Equipment 

Determine whether (1) costs incurred by grantees receiving PSIC funds from the Department 

are allowable and in accordance with grant requirements; (2) grantees are meeting matching 

share requirements; (3) equipment acquired by the grantees has been tested and certified prior 

to deployment, operates effectively, and improves interoperability in the state; and (4) grantees 

are on schedule to complete interoperable communications investments by September 30, 

2011, or—with an approved extension—by September 30, 2012. 
Work In Progress 15 

UNITED STATES PATENT AND TRADEMARK OFFICE 

Efforts to Reduce Board of Patent Appeals and Interferences (BPAI) Backlog 

and Pendency 

Determine (1) whether BPAI’s staffing and resources have changed in relation to changes in 

its caseload and (2) to what extent implementation of the America Invests Act will affect BPAI 

operations and resources. 

FY 2012 Financial Statement Audits 

Determine whether the financial statements are presented fairly, in all material respects, in 

accordance with generally accepted accounting principles. An independent accounting firm 

will perform these audits, under OIG oversight, in accordance with generally accepted auditing 

standards, Government Auditing Standards, and OMB requirements. 

AMERICAN RECOVERY AND REINVESTMENT ACT 

NIST’s Oversight of Recovery Act Construction Contracts 

Audit of $176 million in Recovery Act contract funds awarded for the construction and 

renovation of research facilities on NIST locations. Determine whether NIST’s (1) policies and 

procedures were sufficient for evaluation of cost, specifications, and performance results; (2) 

contract award and administrative practices complied with applicable laws and regulations, 

including specific Recovery Act requirements; and (3) acquisition staff communicated problems 

with the projects to NIST management. 

NTIA’s Processes for Broadband Technology Opportunities Program (BTOP) 

Grantees’ Matching Share 

Determine whether NTIA has adequate processes in place to ensure that BTOP grantees’ 

matching shares of approximately $1.4 billion (1) come from nonfederal funds and (2) meet both 

administrative requirements and the terms and conditions of the individual awards (a sample of 

25 NTIA BTOP grantees was selected to determine reasonableness, allowability, and allocability 

of grantee match). 

BTOP Subrecipient Monitoring 

Assess whether all subrecipients have been identified and properly classified and determine 

whether adequate controls are in place to ensure effective subrecipient monitoring and 

compliance with award terms and conditions. 

Management and Oversight of the Booz Allen Hamilton BTOP Contract 

Determine (1) how NTIA ensures the receipt and quality of the goods and services it pays for; 

(2) what specific controls exist to verify invoices and payment processes; and (3) how NTIA 

mitigates risks associated with time-and-materials contracts and task orders. 

Recovery Act Lessons Learned 

As part of a federal government-wide Recovery Accountability and Transparency Board 

initiative, identify actions, mechanisms, and processes federal agencies used that were effective 

for implementing and administering Recovery Act programs—as well as those that were 

obstacles to successful Recovery Act programs (particularly relating to the overarching goals of 

transparency and accountability). 
16 Office of Inspector General | Semiannual Report to Congress | March 2012 

DEPARTMENT-WIDE MANAGEMENT
 

The U.S. Department of Commerce works to help American 

companies become more innovative and successful at home and more 

competitive abroad. It creates the conditions for economic growth and 

opportunity by promoting innovation, entrepreneurship, competitiveness, 

and stewardship. 

The Department accomplishes its mission by providing national and 

local weather services; developing key economic and demographic data 

(including the decennial census); advancing technological and scientific 

innovation; protecting and restoring environmental resources; promoting 

international trade; and supporting local, regional, and national economic 

development. These activities affect U.S. business and industry daily and 

play a critical role in the nation’s economic well-being. 
 

Department-Wide Management 17 

COMPLETED WORKS (BY OVERSIGHT AREA) 

During this reporting period, OIG completed 19 audits and evaluations and 2 congressional 

testimonies. 

4 

10 

1 

3 3

Department-Wide Recovery Acta NOAA USPTO NTIA 

a Of these four Recovery Act-related works in progress, two concerned NTIA; one concerned NIST; and one was IG 


testimony to the House Committee on Science, Space, and Technology.
 

COMMERCE’S OFFICE OF ACQUISITION MANAGEMENT MUST CONTINUE TO 

IMPROVE ITS ONGOING OVERSIGHT OF ACQUISITION SAVINGS INITIATIVES 

(OIG-12-001-A) 

In March 2009, the President directed federal agencies to take immediate steps to achieve real, 

sustainable improvements in contract processes. In November 2009, the Department submitted 

an acquisition savings improvement plan to the Office of Management and Budget (OMB). 

The Department’s Office of Acquisition Management (OAM) assumed oversight of the plan’s 

implementation—which entailed reducing contract spending costs by about $39.5 million per 

year in FYs 2010 and 2011 and decreasing the use of new high-risk contracts. 

While the Department has achieved some savings in its plan to improve contracts and 

acquisition practices, implementation problems and oversight challenges have limited the 

Department’s ability to produce desired results. Specifically, we found that (1) baseline costs 

were unsupportable and inaccurate, (2) the amount of cost savings was uncertain, and (3) 

while the percentage of high-risk contracts decreased in FY 2010, the dollar value of highrisk contracts increased from 2008 to 2010. Since June 2010, the Department has improved 

its acquisition savings oversight, documentation requirements, and validation processes. A 

new director of acquisition management—hired in February 2011—has further overhauled 

the review, validation, and reporting processes to ensure that savings are properly measured, 

verified, and documented. 
18 Office of Inspector General | Semiannual Report to Congress | March 2012 

We recommended that the director of acquisition management (1) implement adequate controls 

to ensure that future acquisition savings baselines and targets are established, as required by 

OMB; (2) prescribe minimum documentation standards required from the bureaus’ procurement 

offices to support claimed savings resulting from implementing initiatives for reducing contract 

spending and high-risk contracts; and (3) establish a process to verify the accuracy and 

reliability of data collected by the procurement offices and track ongoing and future initiatives 

with a primary objective of determining whether savings are actually realized. 

IMPROVEMENTS ARE NEEDED FOR EFFECTIVE WEB SECURITY MANAGEMENT 

(OIG-12-002-A) 

Our assessment of the Department’s web applications identified significant vulnerabilities 

resulting from inadequate software development practices, improper software configuration, 

and failure to install system updates in a timely manner. We found critical vulnerabilities in 12 

of 15 (or 80 percent of) web applications we reviewed. The majority of web applications have 

well-known website vulnerabilities, misconfigured back-end databases, and outdated software 

that support them. Combined, these security weaknesses put both web applications and users’ 

computers at greater risk of compromise, resulting in the potential disruption of services or 

unauthorized disclosure of sensitive information. 

We recommended that the Department’s Chief Information Officer work with bureau senior 

management to (1) ensure that bureaus take corrective action to mitigate vulnerabilities we 

found during our vulnerability scan assessments; (2) expand the Department’s vulnerability 

scanning practice to include application-level assessments, such as database and website 

scans; and (3) utilize security best practices for publicly accessible web applications, such as 

users’ input validation, to ensure that only legitimate information is accepted, as contained in 

NIST’s published guidelines. 

FY 2011 FISMA AUDIT: MORE WORK NEEDED TO STRENGTHEN IT SECURITY 

DEPARTMENT-WIDE (OIG-12-007-A) 

The Department’s 280 information technology systems process, store, and transmit census, 

economic, trade, satellite, and weather data, among others, in support of its varied missions. Our 

FY 2011 audit assessed the security of 10 information systems selected from three Department 

bureaus: 5 from NOAA, 3 from USPTO, and 2 from the Census Bureau. 

We identified deficiencies in fundamental aspects of security 

planning and significant security control weaknesses.

Overall, the entire Department needs to manage information

security with greater rigor and consistency. 

To make the Department’s information security program 

and practices more effective, the Department should (1)

complete actions planned in response to our FY 2010

FISMA audit recommendations, as quickly as possible; (2) 

develop a security planning checklist, or other planning tool, 

to help system owners and authorizing officials complete

and maintain comprehensive security plans; and (3) 

determine the feasibility of independent reviews at key steps

in the risk management framework to ensure greater rigor

and consistency in the security authorization process within 

the Department’s various bureaus. Consideration should be 

Federal Information Security Management Act 

of 2002 (Title III, P.L. 107-347) 

Information security program, evaluation, and reporting 

requirements for federal agencies were established by the 

Federal Information Security Management Act of 2002 

(FISMA). FISMA requires agencies to secure their information 

systems through the use of cost-effective management, 

operational, and technical controls. FISMA also requires 

inspectors general to evaluate agencies’ information security 

programs and practices by assessing a representative subset 

of agency systems and to report the results to OMB and 

Congress annually. 
Department-Wide Management 19 

given to creating independent review teams with representatives from different bureaus to share 

best practices and promote consistent application of Department policy and NIST guidance. 

FY 2011 CONSOLIDATED FINANCIAL STATEMENT AUDITS (OIG-12-004-A, OIG-12­

009-A, OIG-12-010-A) 

Independent auditor KPMG LLP found that the Department’s consolidated financial statements 

were fairly presented in all material respects and in conformity with U.S. generally accepted 

accounting principles. KPMG found no instances of reportable noncompliance with applicable 

laws, regulations, contracts, and grant agreements and no instances in which the Department’s 

financial management systems did not substantially comply with the requirements of the Federal 

Financial Management Improvement Act of 1996. 

KPMG identified one significant deficiency in internal control over financial reporting related 

to NOAA’s accounting for satellite construction costs. (A significant deficiency in internal 

control exists when the design or operation of a control does not allow management or 

employees, in the normal course of performing their assigned functions, to prevent, or detect 

and correct misstatements on a timely basis, and merits attention by those charged with 

governance.) It found that NOAA needs to make improvements in the effective accounting for 

satellite construction costs and in monitoring of significant events and transactions related 

to its satellite programs, to ensure that only capitalizable costs are included in construction 

work in progress (CWIP) and that the balances of satellites, including related CWIP, are fairly 

stated. The Department concurred that improvements and enhancements can be made in 

its accounting for satellite costs. The Department has developed corrective action plans to 

address KPMG’s recommendations. 

During the audit, KPMG also assessed the information technology controls supporting financial 

management systems. While KPMG noted significant positive steps taken to implement and 

maintain effective information security practices, the Department needs to make improvements 

in the areas of security management, access controls, configuration management, and 

contingency planning. However, these matters were not considered a significant deficiency. The 

Department agreed with these findings and has developed corrective actions plans to address 

KPMG’s recommendations. 

KPMG also audited the Department’s special-purpose financial statements and determined 

its compliance with financial reporting requirements in the Treasury Financial Manual. These 

statements are used to assist in preparing the Financial Report of the U.S. Government. 

In its unqualified opinion on these statements, KPMG reported no material weaknesses in 

internal control and no instances of noncompliance. (A material weakness is a deficiency, or a 

combination of deficiencies, in internal control such that there is a reasonable possibility that a 

material misstatement of the entity’s financial statements will not be prevented, or detected and 

corrected on a timely basis.) 

FURTHER ACTIONS NEEDED TO ENHANCE COMMERCE’S ACQUISITION HUMAN 

CAPITAL PLAN (OIG-12-015-A) 

The Department’s 5-year Acquisition Human Capital Plan (AHCP) for FYs 2010–2014, 

submitted to OMB in March 2010, discusses its challenges and the steps it has taken and 

plans to take to strengthen its workforce. While acknowledging the Office of Acquisition 

Management’s (OAM’s) challenges in developing this plan while experiencing turnover in its 

leadership, we found the plan lacks three critical program elements: (1) reconciled baseline 

staffing data identifying the agency’s entire acquisition workforce; (2) sufficient methodologies 
20 Office of Inspector General | Semiannual Report to Congress | March 2012 

for determining the size and composition of the 

future acquisition workforce; and (3) time frames

and milestones for action strategies. We also found 

that the requests for additional full-time equivalent 

staff identified in the plan did not match individual 

bureaus’ FY 2012 budget submissions. 

We recommended that the director of OAM: (1) 

establish formal guidance and procedures for 

determining baseline staffing levels; (2) prescribe 

minimum documentation standards required by the 

bureaus’ procurement offices and OAM to support 

facts and figures contained in subsequent AHCPs; (3) 

work with each bureau to establish acquisition human 

capital goals and measure progress toward meeting 

those goals; and (4) work with the Office of Budget 

to access Departmental acquisition workforce budget 

data during the budget formulation process. 

Duncan Hunter National Defense Authorization 

Act for FY 2009 (P.L. 110-417) 

Congress included provisions in the Duncan Hunter National 

Defense Authorization Act for FY 2009 (the Act) to help agencies 

develop plans to increase the size of their acquisition workforce. 

Enacted in 2008, the Act directed federal agencies other than the 

Department of Defense to develop a specific and actionable 5-year 

plan—an Acquisition Workforce Development Strategic Plan—to 

increase the acquisition workforce size and operate a governmentwide acquisition intern program. It also outlined a number of other 

plan requirements, such as the development of a sustainable funding 

model to support efforts to hire, retain, and train an appropriately 

sized and skilled acquisition workforce 

SINGLE AUDIT RESULTS FOR CALENDAR YEAR 2011 (OIG-12-021-M) 

Nonfederal entities (states, local governments, tribes, colleges and universities, and nonprofit 

organizations) that expend $500,000 or more in a year of federal awards are required by the 

Single Audit Act of 1984, and Amendments of 1996, to have an annual audit of their federal 

awards. The purpose of the Act is to set forth standards for obtaining consistency and uniformity 

among federal agencies with the audit of nonfederal entities expending federal awards. OIG is 

responsible for thoroughly reviewing the issued audit report and auditee responses, considering 

carefully each finding and recommendation, and determining whether the recommendations can 

and should be implemented. We conduct this review on an ongoing basis—and we intend to 

present summary analyses on a semiannual basis. 

For calendar year 2011, OIG reviewed 332 reports by recipients of grants from EDA, ITA, 

MBDA, NIST, NOAA, NTIA, and multiple bureaus. On February 13, 2012, we provided these 

bureaus with a detailed summary of our findings, which included $9.9 million in questioned costs 

for EDA, NOAA, and NTIA programs. The February 13 memo contained an analysis of findings 

identified in single audit reports, noted trends in the types of findings reported, and summarized 

findings by Departmental program. 

FY 2011 COMPLIANCE WITH IMPROPER PAYMENT REQUIREMENTS (OIG-12-022-I) 

Our review focused on determining whether the Department’s improper payment reporting 

in appendix F of its FY 2011 Performance and Accountability Report complied with the 

Improper Payments Information Act of 2002 (IPIA), as amended by IPERA. We also evaluated 

the accuracy and completeness of the Department’s reporting, as well as its performance in 

reducing and recapturing improper payments. Overall, we found that the Department was in 

compliance with IPIA requirements for FY 2011. 

However, we determined that the Department could improve its improper payment implementation 

strategy related to payments without sufficient documentation and payment recapture audits. We 

recommended that the Department (1) expand the scope of its review of grants and contracts 

to include those for which the period of performance ended and last payment was made, but 
Department-Wide Management 21 

for which the closeout process has not been completed and (2) research items identified in 

payment recapture audits as lacking sufficient documentation, and report amounts in its annual 

Performance and Accountability Report when unable to discern propriety of payment. 

AUDITS OF COMMERCE FUND RECIPIENTS BY INDEPENDENT AUDITORS 

In addition to undergoing OIG-performed 

audits, certain recipients of Department 

of Commerce financial assistance are 

periodically examined by state and local 

government auditors and by independent 

public accountants. OMB Circular A-133, 

Audits of States, Local Governments, and 

Non-Profit Organizations, sets forth audit 

requirements for most of these audits. Forprofit organizations, including those that 

receive Technology Innovation Program funds, 

are audited in accordance with Government 

Auditing Standards. In addition, organizations 

that received Advanced Technology Program 

Improper Payments Elimination and Recovery Act of 

2010 (IPERA) (P.L. 111-204) 

IPERA amended the Improper Payments Information Act of 2002 (P.L. 107­

300), by expanding on the previous requirements for identifying, estimating,

and reporting on programs and activities that were vulnerable to significant

improper payments and broadening recovery requirements for overpayments.

(Improper payments are those made by the federal government in the wrong

amount, to the wrong entity, or for the wrong reason.) 

(ATP) funds are audited in accordance with NIST Program-Specific Audit Guidelines for ATP 

Cooperative Agreements, and organizations that received Broadband Technology Opportunities 

Program funds are audited in accordance with the Program-Specific Audit Guidelines for the 

Broadband Technology Opportunities Program, issued by the Department. 

We examined 186 audit reports during this semiannual period to determine whether they 

contained audit findings related to Departmental programs. For 136 of these reports, the 

Department acts as an oversight agency and monitors the audited entity’s compliance with OMB 

Circular A-133, Government Auditing Standards, or program-specific reporting requirements. 

The other 50 reports cover entities for which other federal agencies have oversight responsibility. 

We identified 11 reports with material findings related to the Department of Commerce. 

Report Category OMB A-133 Audits Program-Specific Total
 

Audits
 

Pending (October 1, 2011) 19 67 86 

Received 107 46 153 

Examined 110 76 186 

Pending (March 31, 2012) 16 37 53 
22 Office of Inspector General | Semiannual Report to Congress | March 2012 

The following table shows a breakdown by bureau of approximately $392 million in Commerce 

funds audited. 

Agency Funds 

Economic Development Administration $ 49,326,727 

International Trade Administration 541,335 

National Institute of Standards and Technologya $71,333,776 

National Oceanic and Atmospheric Administration 56,797,030 

National Telecommunications and Information Administrationb 127,163,963 

Multi-bureau 86,587,638 

Total $391,750,469 

a Includes $45,272,865 in program-specific audits. A-133 audits account for the remaining amount of $26,060,911. 

b Includes $100,808,138 in program-specific audits. A-133 audits account for the remaining amount of $26,355,825. 

We identified a total of $609,669 in the federal share of questioned costs and $15,337 in 

funds to be put to better use. In most reports, the subject programs were not considered major 

programs; thus, the audits involved limited transaction and compliance testing against laws, 

regulations, and grant terms and conditions. The 11 reports with Commerce findings are listed in 

table 7-a on page 49. 

BODY ARMOR MANUFACTURER REACHES SETTLEMENT WITH UNITED STATES IN 

DEFECTIVE MERCHANDISE CASE 

In October 2011, Point Blank Solutions, Inc. (formerly DHB Industries, Inc.), Point Blank 

Body Armor, Inc., and Protective Apparel Corporation of America, Inc. (collectively, “Point 

Blank”) settled a civil false claims case for $1 million as the result of an investigation into the 

manufacture and sale of bulletproof vests containing Zylon®. This settlement was part of a 

larger U.S. Department of Justice (DOJ) investigation of the body armor industry’s use of Zylon® 

ballistic material in body armor. The companies manufactured and sold body armor comprised of 

Zylon® despite possessing information showing that the Zylon® materials degraded quickly over 

time and were not suitable for ballistic use. The Point Blank vests were purchased by the federal 

government and by various state, local, and tribal law enforcement agencies that were partially 

reimbursed by the United States under DOJ’s Bulletproof Vest Partnership Grant Program. This 

settlement was the result of a joint investigation involving DOJ and investigative units from nine 

federal departments and agencies, including our office. 
Department-Wide Management 23 

ADDITIONAL MULTI-MILLION-DOLLAR GUILTY PLEAS IN PRICE-FIXING CASE 

In the September 2011 Semiannual Report to Congress (page 9), we reported that six 

companies agreed to plead guilty to numerous counts of violating the Sherman Antitrust Act 

by conspiring to fix certain fees in the provision of freight forwarding services for air cargo 

shipments from Europe to the United States between 2002 and 2007. In November 2011, four 

companies—EGL Inc., Geologistics, Kuhne Nagel, and Panalpina—had their plea agreements 

accepted by a federal judge. The four agreed to pay criminal fines totaling $26,986,969 and 

special assessments totaling $4,400. In December 2011, two additional companies—BAX 

Global and Schenker AG, Inc.—had their plea agreements accepted by a federal judge and 

agreed to pay criminal fines totaling $23,281,441 and special assessments totaling $2,400. 

All of these plea agreements were the result of an ongoing joint investigation into the freight 

forwarding industry by DOJ’s Antitrust Division–National Criminal Enforcement Section, the FBI’s 

Washington Field Office, and our office. These agreements have now been accepted by the court 

and are finalized. Several other companies are in ongoing negotiations with the Antitrust Division. 
24 Office of Inspector General | Semiannual Report to Congress | March 2012 

ECONOMICS AND STATISTICS 

ADMINISTRATION 

The Economics and Statistics Administration analyzes economic 

activity, formulates policy options, and produces a major share of the 

U.S. government’s economic and demographic statistics. The chief 

economist monitors and analyzes economic developments and directs 

studies that have a bearing on the formulation of economic policy. ESA 

has two principal organizational units: 

Census Bureau—Publishes a wide variety of statistical data about the 

nation’s people and economy, conducting approximately 200 annual 

surveys in addition to the decennial census of the U.S. population and 

the quinquennial census of industry. 

Bureau of Economic Analysis—Prepares, develops, and interprets 

national income and product accounts (summarized by the gross 

domestic product) as well as aggregate measures of international, 

regional, and state economic activity. 
Economics and Statistics Administration 25 

FORMER BEA EMPLOYEE AND ACCOMPLICE SENTENCED 

In October 2010, a BEA employee and two other individuals were indicted on 20 criminal counts, 

including tax fraud, bank fraud, wire fraud, aggravated identity theft, and obstruction of justice. In 

October 2011, the BEA employee was sentenced by a federal judge to a 44-month prison term and 

8 months of probation and ordered to pay $253,978 in restitution and a $600 special assessment 

fee. In November 2011, an accomplice was also ordered to pay $253,978 in restitution. These 

sentences were the result of our investigation into allegations that the BEA employee was committing 

fraud in the commission of his outside occupation as a private accountant. The BEA employee retired 

from federal service, effective November 2010. 

CENSUS EMPLOYEE CONVICTED OF ATTEMPTED MURDER AND ASSAULT 

A Census employee was arrested by Montgomery County (Maryland) police in August 2011 

for the attempted murder of the husband of another Census employee. In October 2011, the 

employee was indicted by a Montgomery County grand jury on charges that included attempted 

first-degree murder and assault and placed on indefinite unpaid suspension the next month. 

OIG provided assistance, primarily in the form of computer forensics, at the request of the 

Montgomery County Police Department. The employee’s trial began in March 2012, and a guilty 

verdict was handed down on April 2. Sentencing is set for June. 

GEORGIA MAN INDICTED FOR ASSAULT OF CENSUS ENUMERATOR 

In January 2012, a Cook County (Georgia) grand jury indicted a Georgia man on misdemeanor 

charges of battery and criminal trespass related to an alleged altercation between him and a 

Census enumerator conducting a site visit during the 2010 decennial census. OIG assisted 

the Cook County District Attorney’s Office in conducting an investigation of the incident after 

local police investigators recused themselves from the matter. Our investigation substantiated 

allegations that the man assaulted the enumerator with a knife, resulting in injury to the 

enumerator, as well as damage to the enumerator’s vehicle. In January 2012, the man was 

arrested for failing to appear in court to answer the indictment. 

JOINT OIG–CENSUS LETTER ENLISTS LAW ENFORCEMENT PROFESSIONALS IN 

PROSECUTION OF CENSUS EMPLOYEE ASSAULTS 

During the 2010 decennial census, over 700 acts of violence against Census Bureau employees 

were reported throughout the United States. Prompted by these statistics and our findings 

that many of these incidents were not reported promptly or handled consistently by different 

jurisdictions, the Inspector General and Census Bureau Director Robert M. Groves authored a 

letter asking for “assistance in keeping our Census Bureau workers safe by aggressively pursuing 

prosecution of violent crimes against them and their property.” The letter will be distributed to 

police and sheriff’s departments across the country. A similar educational campaign is planned for 

the Census Bureau itself to encourage better and more consistent reporting of acts of violence. 
26 Office of Inspector General | Semiannual Report to Congress | March 2012 

NATIONAL OCEANIC AND 

ATMOSPHERIC ADMINISTRATION 

The National Oceanic and Atmospheric Administration mission 

is to understand and predict changes in Earth’s environment, as well as 

conserve and manage coastal and marine resources to meet our nation’s 

economic, social, and environmental needs. NOAA does this through six 

line offices. 

National Environmental Satellite, Data, and Information Service— 

Observes the environment by operating a national satellite system. 

National Marine Fisheries Service—Conducts a program of 

management, research, and services related to the protection and 

rational use of living marine resources. 

National Ocean Service—Provides products, services, and information 

to promote safe navigation, support coastal communities, sustain marine 

ecosystems, and mitigate coastal hazards. 

National Weather Service—Reports the weather of the United States 

and provides weather forecasts and warnings to the general public. 

Office of Oceanic and Atmospheric Research—Conducts research 

related to the oceans and Great Lakes, the lower and upper atmosphere, 

space environment, and the Earth. 

Office of Program Planning and Integration—Develops and 

coordinates NOAA’s strategic plan, supports organization-wide planning 

activities, guides managers and employees on program and performance 

management, and integrates policy analysis with decision making. 
National Oceanic and Atmospheric Administration 27 

FOLLOW-UP REVIEW OF NOAA FISHERIES ENFORCEMENT PROGRAMS AND 

OPERATIONS (OIG-12-017-I ) 

In response to our January 2010 Review of NOAA Fisheries 

Enforcement Programs and Operations (OIG-19887), NOAA 

identified activities planned or already taken to improve its Office 

of Law Enforcement (OLE), along with its Office of the General 

Counsel Enforcement Section (GCES), formerly known as 

General Counsel for Enforcement and Litigation. In a February 

2010 memo, a March 2010 response, and several public 

announcements, NOAA identified 47 immediate and long-term 

activities to address OIG findings and recommendations. 

OIG conducted this follow-up review, the scope of which 

was targeted to NOAA’s action plan, to (1) provide an interim 

assessment of NOAA’s corrective actions, (2) determine the 

effectiveness of actions already taken, and (3) identify constructive 

measures NOAA should consider going forward. We found that 

•	 NOAA made progress in completing many key action plan items. 

•	 Regional and national priorities for OLE have not been finalized. 

•	 NOAA’s placement of the compliance liaison within OLE raises 

independence concerns. 

•	 NOAA’s workforce analysis is one year behind schedule. 

•	 GCES case management system data integrity issues have 

not been resolved. 

•	 OLE and GCES policies and procedures manuals need to include 

a consistent method for handling prior violation information. 

•	 GCES participation in Fishery Management Council meetings 

has been limited and inconsistent. 

•	 E-hotline and “Complaints and Compliments” web page effectiveness is uncertain. 

OIG reviewed NOAA’s response and considered it in preparing the final report. We 

also modified the draft report based on information provided by NOAA in subsequent 

communications. NOAA’s response indicated general concurrence with our findings. The 

response provided additional updated information summarizing the steps NOAA had taken and 

plans to take to address the challenges we identified. The response also contained a clarification 

of NOAA’s position on the placement of a compliance liaison under the direct supervision of the 

OLE special agent in charge of the Northeast field office. OIG had no recommendations in this 

report; therefore, no action plan was necessary. However, we expect to continue a dialogue with 

NOAA on its progress in achieving the remaining action items. 

MORE ACTION NEEDED TO IMPROVE CONTROLS IN ASSET FORFEITURE FUND 

(OIG-12-019-I) 

In our January 2010 and July 2010 reports, OIG addressed concerns over NOAA’s Asset 

Forfeiture Fund (AFF), which contains proceeds from marine resource violations that are 

expendable under the guidelines of the Magnuson-Stevens Act section 311 (e)(1). Those 

reports revealed several weaknesses in NOAA’s management and internal controls over the 

AFF. The July 2010 report recommended 13 ways for NOAA to improve administration and 

oversight of the AFF. In response, NOAA developed specific corrective action plans and 

provided us with quarterly updates on progress to implement them. 

OIG Reviews of NOAA Fisheries 

Enforcement Programs and Operations 

In 2009, at the request of the NOAA Administrator and 

with the interest of numerous members of Congress,

OIG began a major assessment of the policies, 

practices, and operations of NOAA’s Office of Law 

Enforcement and Office of the General Counsel 

Enforcement Section. This investigation yielded the 

three 2010 reports listed below as well as two followup reports issued during this semiannual period and

summarized here. 

• Review of NOAA Fisheries Enforcement Programs 

and Operations (OIG-19887), January 2010 

• Review of NOAA Fisheries Enforcement Asset 

Forfeiture Fund (OIG-19887-1), July 2010 

• Final Report–Review of NOAA Fisheries Enforcement 

Programs and Operations (OIG-19887-2), 

September 2010 
 

 

GCES 

• Duties not adequately 

segregated 

• Debts not recorded 

accurately or in timely 

way 

• Lacks deposit account 

monitoring 

OLE 

• Duties not adequately 

segregated 

• Lacks deposit account 

monitoring 

• Lacks Enforcement 

Action Report (EAR) 

tracking 

• Law Enforcement 

Accessible Database 

System (LEADS) lacks 

data integrity controls 

NOAA Finance 

• Lacks deposit account 

monitoring 

• Fails to pursue 

collection of overdue 

fines 

28 Office of Inspector General | Semiannual Report to Congress | March 2012 

In this follow-up review, we reviewed NOAA’s approach to defining and reporting on the 

AFF and also examined controls over AFF collections and disbursements. We found that 

NOAA lacks controls to assure that all proceeds are received and accurately recorded. Also, 

NOAA has not accurately recorded or adequately pursued the total amount owed for fines 

and penalties. We recommended that the Under Secretary of Commerce for Oceans and 

Atmosphere require the following: 

•	 OLE and GCES develop policies and procedures that ensure that payments due to the 

government are recorded accurately and in a timely manner, and implement a segregationof-duties matrix identifying compatible and incompatible functions associated with the 

collection, recording, deposit, and reconciliation of fines, penalties, and forfeitures. 

•	 OLE train agents and enforcement technicians on collection procedures and policies. 

•	 GCES headquarters work with the Enforcement Section Northeast division to improve the 

timeliness of the division’s lockbox submissions. 

•	 OLE, GCES, and NOAA Finance implement a process to ensure that deposit account cases 

are periodically reviewed and that legally resolved cases are transferred from the deposit 

account or returned to a respondent in a timely manner. 

•	 OLE implement procedures to track and reconcile how Enforcement Action Reports are used 

and issued, including those issued to joint enforcement partners and the U.S. Coast Guard. 

•	 OLE evaluate the Law Enforcement Accessible Database System (LEADS) internal control 

weaknesses, develop specific protocol for recording information, and restrict LEADS user 

access to cases. 

•	 GCES develop policies and procedures to ensure that debts are recorded in the Commerce 

Business Systems (CBS) as soon as legally enforceable, which will include independent 

monitoring for amounts not yet recorded in CBS. 

•	 GCES standardize its case monitoring process and reinforce use of the JustWare system. 

•	 GCES and NOAA Finance develop policies and procedures to consistently pursue collection 

of fines and penalties in a manner that treats all respondents uniformly and in compliance 

with the Debt Collection Improvement Act of 1996. 

As required by House Report 112-169, we provided an interim status report of NOAA’s 

implementation of our recommendations (OIG-12-012-M) to the leadership of relevant House 

and Senate appropriations committees and subcommittees in December 2011. 

Breakdown of Issues by Office 
National Oceanic and Atmospheric Administration 29 

CONGRESSIONAL TESTIMONY (OIG-11-011-T) 

On November 16, 2011, the Inspector General testified about 

the challenges NOAA faces in its efforts to develop and launch 

its new environmental satellites while minimizing expected data 

gaps. His testimony included a brief history of the development 

and operation of polar and geostationary environmental satellite 

systems operated by NOAA, NASA, and the Department of 

Defense. He also described the new NOAA-NASA Joint Polar 

Satellite System (JPSS) partnership, and cost, scheduling, 

performance, and coverage issues associated with JPSS and 

a predecessor satellite, the Suomi National Polar-orbiting 

Partnership (NPP). 

Both NOAA and OIG, he said, have identified risks that, if not 

properly mitigated, could cause further delays in NPP operational 

readiness and degradation of NOAA’s weather and climate 

forecasting capability. Longer-term, OIG recommends that NOAA senior management prioritize 

all JPSS requirements, develop reliable cost estimates to support future funding requests, 

systematically communicate planned actions and progress with decision makers, and coordinate 

NOAA efforts, in case NPP does not live through its 5-year design life. The Inspector General 

conveyed his interest in NOAA’s action plan to address recommendations contained in OIG’s 

September 30, 2011, JPSS audit report, and his hope that NOAA finds innovative solutions to 

closing the looming satellite coverage gaps. 

NOAA EMPLOYEE COUNSELED AND NEW PROCEDURES INSTITUTED 

In October 2011, a NOAA employee was counseled and removed from serving as a source 

selection official/evaluator pending the completion of additional training. NOAA also advised that 

it intended to provide appropriate training in order to strengthen the contracting capabilities of 

the employee’s office. These actions were the result of our investigation into alleged violations 

of the Procurement Integrity Act involving the award of a National Weather Service contract. 

Our investigation established that a senior NOAA official made inappropriate disclosures to the 

losing bidder before that company was notified by the proper authorities. We determined this 

behavior fostered an appearance of violating the Procurement Integrity Act and also violated the 

Standards of Ethical Conduct for Employees of the Executive Branch. 

“NOAA’s current constellation of 

polar and geostationary operational 

environmental satellites is aging, and 

its capabilities will degrade over time. 

As a result, the risk increases for gaps 

in critical satellite data.” 

IG testimony before a U.S. Senate Commerce, 

Science, and Transportation Subcommittee, 

November 16, 2011 
30 Office of Inspector General | Semiannual Report to Congress | March 2012 

NATIONAL TELECOMMUNICATIONS 

AND INFORMATION ADMINISTRATION 

The National Telecommunications and Information 

Administration serves as the executive branch’s principal advisor 

to the President on domestic and international telecommunications 

and information policy issues. NTIA manages the federal use 

of the electromagnetic spectrum, provides grants for national 

information and public broadcasting infrastructure projects, and 

performs telecommunications research and engineering. It works to 

enhance citizens’ access to cable television, telephone, and other 

telecommunications services and educates state and local governments 

and other entities on ways to use information technology and 

telecommunications more effectively. 
National Telecommunications and Information Administration 31 

THIRD ANNUAL ASSESSMENT OF THE PSIC GRANT PROGRAM: NTIA AND FEMA 

NEED TO IMPROVE OVERSIGHT OF PSIC GRANTS (OIG-12-008-A) 

Our assessment found that neither NTIA nor the Federal Emergency Management Agency 

(FEMA) adequately monitored and addressed (1) PSIC equipment purchases and operating 

capability, (2) matching share issues, and (3) progress toward meeting program goals. We also 

found that certain grantees with low drawdowns may be at risk of not completing their projects 

by September 30, 2012. Although NTIA and FEMA intended to evaluate the success of the 

PSIC program by having grantees provide evidence of improvements in interoperability at the 

completion of (rather than during) each grant period, issues discovered after grant funds have 

been expended will be difficult to correct, decreasing the likelihood of the program’s success. 

We recommended that the Assistant Secretary for Communications and Information, in 

coordination with the Assistant Administrator, FEMA Grants Program Directorate (1) implement 

a plan that provides for the active monitoring of equipment and its operational capability; (2) 

develop a formal document for grantees that reconciles all existing guidance on proportionality 

and emphasize close monitoring to ensure that matching share requirements will be met; (3) 

actively monitor and document grantee progress toward achieving program goals, including the 

achievement of updated milestones for grantees that requested an extension until September 

2012; and (4) provide quarterly evidence to OIG that grantees with less than 50 percent 

drawdowns as of September 30, 2011, are being actively monitored through closeout. 

Public Safety Interoperable Communications Program 

The Digital Television Transition and Public Safety Act of 

2005 authorized NTIA, in consultation with the Department 

of Homeland Security (DHS), to implement the Public Safety 

Interoperable Communications (PSIC) program—a $1 billion 

one-time, formula-based matching grant program intended 

to enable public safety agencies to establish interoperable 

emergency communications systems using reallocated 

radio spectrum. 

DHS, in cooperation with NTIA, provides grants management 

services for the PSIC program; the Federal Emergency 

Management Agency (FEMA) handles the DHS responsibilities. 

PSIC program funding has been extended until expended—but 

not beyond September 30, 2012. 

The Implementing Recommendations of the 9/11 Commission 

Act of 2007 (P.L. 110-53) requires OIG to conduct financial 

audits, over 4 years, of a representative sample of at least 25 

states or territories receiving PSIC grants. The statute also 

requires OIG to annually assess the management of the program 

and report any findings and recommendations from that annual 

assessment to the relevant congressional committees. 
32 Office of Inspector General | Semiannual Report to Congress | March 2012 

UNITED STATES PATENT 

AND TRADEMARK OFFICE 

The United States Patent and Trademark Office administers the 

nation’s patent and trademark laws. Patents are granted and trademarks 

registered under a system intended to provide incentives to invent, 

invest in research, commercialize new technology, and draw attention 

to inventions that would otherwise go unnoticed. USPTO also collects, 

assembles, publishes, and disseminates technological information 

disclosed in patents. 
United States Patent and Trademark Office 33 

FY 2011 FINANCIAL STATEMENT AUDITS (OIG-12-005-A, OIG-12-006-A) 

Independent auditor KPMG LLP found that USPTO’s financial statements were fairly presented 

in all material respects and in conformity with U.S. generally accepted accounting principles. 

KPMG found no instances of reportable noncompliance with applicable laws, regulations, 

contracts, or grant agreements and no deficiencies in internal control over financial reporting 

that were considered to be a material weakness. (A material weakness is a deficiency, or a 

combination of deficiencies, in internal control such that there is a reasonable possibility that a 

material misstatement of the entity’s financial statements will not be prevented, or detected and 

corrected on a timely basis.) 

During the audit, KPMG also assessed the IT controls supporting financial management 

systems. While KPMG noted significant positive steps taken to implement and maintain 

effective information security practices, USPTO needs to make improvements in the areas 

of configuration management and contingency planning. However, these matters were not 

considered a significant deficiency. USPTO agreed with these findings and has developed 

corrective action plans to address KPMG’s recommendations. 

THE PATENT HOTELING PROGRAM IS SUCCEEDING AS A BUSINESS STRATEGY 

(OIG-12-018-A) 

USPTO offers a variety of telework options for its employees—from 1 to 5 days a week. The 

largest of these is the Patent Hoteling Program (PHP), where employees work from home at 

least 4 days a week and reserve office space for when they need to be present at USPTO. 

Goals of PHP include reducing space and cost requirements while improving employee 

retention and job satisfaction. Although considered one of the leading government telework 

programs, no comprehensive and independent review of PHP’s costs and benefits had ever 

been completed. Because, by law, participation in telework programs should not result in 

diminished federal employee performance, we specifically looked at the productivity of PHP 

participants. Also, because USPTO’s management challenges include addressing the backlog of 

about 700,000 patent applications, we sought to determine if PHP can help reduce this backlog 

in a cost-effective way. 

We found that the average PHP participant spends 66.3 more hours a year examining patents 

than does the average in-house examiner; this translates to reviewing about 3.5 more patent 

applications a year than examiners not in the program. Although PHP incurs additional costs, 

mainly for IT infrastructure and hoteling support services, these costs are significantly offset by 

avoided real estate costs—$16.84 million by our estimation—as well as revenue generated from 

the additional patent applications reviewed. 

We recommended that the Under Secretary of Commerce for Intellectual Property and Director, USPTO: 

•	 Conduct a more comprehensive calculation for costs and cost avoidance related to PHP in 

order to obtain more accurate estimates of the cost and benefits affiliated with this program. 

•	 Work with the Department to compare best practices from PHP, which could aid telework 

programs within the rest of the Department. 

•	 Ensure that internal controls are in place so that only eligible patent examiners participate in 

PHP and appropriate documentation is maintained. 
34 Office of Inspector General | Semiannual Report to Congress | March 2012 

Comparison of FY 2010 Costs per Patent Examiner for PHP and Non-PHP Participants 

First-Year SubsequentCost Category PHP Non-PHP 

(at USPTO) 

Difference 

(using PHP 

Year Difference 

(using PHP 

as base) as base) 

Real estate, taxes, 

utilities $1,075 $9,835 -$8,760 -$8,760 

IT setup 1,050 +1,050 n/a 

Equipmenta 4,880 4,255 +625 n/a 

Virtual 

infrastructureb 4,450 +4,500c +4,500 

Hoteling support 

servicesc 1,675 +1,675 +1,675 

Transit benefits 230 1,100 -870 -870 

ISP reimbursement 70 +70 +70 

Total $13,480 $15,225 -$1,710 -$3,385 

Source: OIG analysis of USPTO data 

a Equipment includes computer, dual monitors, printer, webcam, keyboard, speakers, and miscellaneous equipment. 

b Virtual infrastructure costs are dynamic and reported on as incurred in 2010; however, USPTO is currently 

transitioning to a universal laptop program that will decrease these costs in the future. 

c Hoteling support services include telework depot, engineer, VPN, storage, and backup. 
11
36 Office of Inspector General | Semiannual Report to Congress | March 2012 

AMERICAN RECOVERY 

AND REINVESTMENT ACT 

The Recovery Act—signed into law by President Barack Obama on 

February 17, 2009—has three immediate goals: (1) create new jobs 

and save existing ones, (2) spur economic activity and invest in longterm growth, and (3) foster unprecedented levels of transparency and 

accountability. 

Five Department of Commerce bureaus—the Census Bureau, EDA, 

NIST, NOAA, and NTIA—and OIG received $7.9 billion under the Act, 

with $1.2 billion ultimately rescinded or transferred to other agencies. 

As of March 31, 2012, the Department had obligated almost all of the 

approximately $6.7 billion remaining and had disbursed approximately 

$3.8 billion. (The disbursal amount includes funding for the nowcompleted NTIA Digital Television Converter Box Coupon Program.) 
American Recovery and Reinvestment Act 37 

COMMERCE BUREAUS’ RECOVERY ACT OBLIGATIONS AND DISBURSEMENTS 

AS OF MARCH 31, 2012 Dollars (in Millions)

$4,500 

$4,000 

$3,500 

$3,000 

$2,500 

$2,000 

$1,500 

$1,000 

$500 

$0 

$4,134 

38% 

65% 

76% 76% 

85% 

88% 

99% 

Total Obligations 

Total Disbursements 

Percent Disbursed 

$1,581 

$360 

$249 $189 $242 $185 $148 $126 

$231 $204 

$1,000 $995 

$235 

100% 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

Percent Disbursed 

NTIA NIST NOAA Procurment, NIST Research EDA NOAA Operations, Census 

Construction Acquisition, and and Services Research, and 

Construction Facilities 

OIG RECOVERY ACT OVERSIGHT, FEBRUARY 2009–MARCH 2012 

Funded by $16 million for proactive oversight of the Department’s Recovery Act programs and 

activities, OIG has been evaluating whether agencies are using Recovery Act funds efficiently 

and effectively and following up on complaints including whistleblower reprisal allegations. 

Key Activities Cumulative Results 

Published audit and evaluation reports 17 

Unpublished work products 4 

Audits/evaluations in progress 5 

OIG recommendations for action, correction, or improvement 63 

Recommendations implemented to take corrective action by making 

improvements, reducing risk, or preventing waste 29 

Investigations completed 3 

Investigations in progress 6 

Whistleblower reprisal allegations received 2 

Whistleblower reprisal allegations accepted 2 

Debarments and corporate compliance agreements implemented 0 

Proactive training and outreach sessions held 128 

Individuals trained 6,474 

Hours of training provided 8,109 
38 Office of Inspector General | Semiannual Report to Congress | March 2012 

NTIA HAS AN ESTABLISHED FOUNDATION TO 

OVERSEE BTOP AWARDS, BUT BETTER EXECUTION OF 

MONITORING IS NEEDED (OIG-12-013-A) 

NTIA’s FY 2011 BTOP Monitoring and Assessment Plan established 

guiding principles for monitoring and assessing BTOP awards. The 

plan explains the processes for establishing and revising monitoring 

levels—as well as for ensuring improved project performance and

compliance with grant terms and conditions—and the tools used to

monitor the award. Our review identified improvements to strengthen

(1) monitoring tools and the effectiveness of monitoring-level 

adjustments, (2) the recipient match review process, (3) tracking 

projects at risk of meeting the 3-year completion deadline and initiating 

a formal trend analysis, and (4) maximizing monitoring resources. 

The Recovery Act and Broadband 

The Recovery Act gave $4.7 billion to NTIA to 

establish BTOP, a competitive grant program 

intended to provide funds for deploying broadband 

infrastructure in the United States in order to enhance 

broadband capacity at public computer centers, 

improve access to broadband services for public 

safety agencies, promote sustainable broadband 

adoption projects, and develop an interactive map 

showing broadband capabilities and availability. 

We recommended that NTIA 

•	 strengthen the federal program officers’ monitoring efforts, 

•	 verify source documentation into its current monitoring efforts, 

•	 strengthen its monitoring tools’ internal control capabilities, 

•	 prepare recipient match documentation guidance for federal program officer use during site visits, 

•	 work with recipients at risk of not meeting award progress and completion requirements and 

develop an action plan and alternative strategies for those awards that will not satisfy award terms, 

•	 incorporate continuous trend analysis activities into its award monitoring process, and 

•	 identify oversight strategies for different funding levels. 

Overview of BTOP Monitoring Model 

Criteria 

Data and Report Reviews 

Monitoring Activities 

Results/Findings 

Federal policy (e.g., Department of Commerce grants 

manual) and regulations (e.g., Recovery Act, Notices of 

Funds Availability) 

NTIA creates policies and procedures based on 

established laws and regulations 

Various data (e.g., performance progress report, 

financial progress report, baseline reports) 

NTIA bases templates on procedural requirements and 

collects data, which it transmits and stores in systems 

that interface with Grants Management Information 

System and Grants Online 

Report reviews, desk reviews, and site visits NTIA staff review reports and conduct desk reviews 

and site visits to gather recipient financial and 

performance information 

Final site visit report NTIA staff generates reports based on observations 

made during recipient site visits 

Monitoring Level Adjustment

Adjustment or action plan NTIA adjusts monitoring levels, based on the results of 

site visits, and issues any needed corrective actions 
American Recovery and Reinvestment Act 39 

MISREPRESENTATIONS REGARDING PROJECT READINESS, GOVERNANCE 

STRUCTURE PUT AT RISK THE SUCCESS OF THE BAYWEB PROJECT (OIG-12-016-M) 

In November 2010, a San Francisco Bay–area county executive requested an investigation of the 

nearly $50.6 million BTOP grant awarded to Motorola Solutions, Inc. (formerly Motorola, Inc.) for 

the project known as the San Francisco Bay Area Wireless Enhanced Broadband (BayWEB). 

The letter claimed that the application contained misrepresentations and misinformation—and 

that the selection of Motorola as a grant applicant represented a conflict of interest. Allegations 

regarding the award had been previously sent to NTIA in September 2010, before the award was 

accepted by Motorola. In December 2010, OIG initiated a review of NTIA’s response to concerns 

expressed on the project. 

Our May 2011 review (OIG-11-024-I) contained recommendations for improving NTIA’s 

procedures for handling complaints. Our report also noted that we would undertake further 

review of the complaint to examine issues that were outside the scope of our initial review—and 

that NTIA declined to investigate further, because it viewed these issues as exceeding the scope 

of its program responsibilities. 

Our follow-on review (OIG-12-016-M) identified several areas of concern regarding the 

award to Motorola that revealed misrepresentations in the application and deficiencies in the 

due diligence—and also highlighted ongoing challenges facing the administration of BTOP. 

Specifically, the application, not attributable directly to the grantee in this case, misrepresented 

information regarding the status of a regional governance structure, the readiness of sites for 

broadband infrastructure, and the region’s authority to use the dedicated broadband spectrum. 

Although these concerns may not mandate termination of the grant, they have contributed to 

delays in the project that put at risk the successful completion of the project and the fulfillment 

of the grant’s purpose. The project, which no longer includes a public access component, 

continues to face challenges. As of March 31, 2012, progress has been limited, and several key 

issues must be addressed if the project is to be completed on schedule. For example, under 

recently enacted legislation, an independent authority established within NTIA will oversee the 

development of a nationwide public safety broadband network. The technical requirements and 

standards adopted under that program may affect BayWEB’s development. In addition, the 

project still needs to acquire access to existing network infrastructure and equipment. 

OVERSIGHT ACTIVITIES OF NIST’S RECOVERY ACT CONSTRUCTION GRANT 

AWARDS ARE GENERALLY EFFECTIVE BUT NEED IMPROVEMENTS (OIG-12-020-A) 

The Recovery Act appropriated $360 million to NIST to construct research facilities, including 

$180 million in competitive grants for the construction of research science buildings. By 

January 2010, NIST had awarded more than $179 million in Recovery Act funds to support 

the construction of new research science facilities at 15 universities and 1 nonprofit research 

organization. With grant recipients’ matching shares, the 16 projects were intended to launch 

more than $400 million in new laboratory construction projects in 2009 and 2010. 

Although NIST has established a generally effective construction grants program, program 

processes are still under development, and NIST risks not having appropriate and adequate 

monitoring processes in place. We found that inadequate internal controls led to award 

administration and oversight concerns, such as releasing funds without securing the government’s 

interest first. We also found violations of Recovery Act provisions, such as granting reprieves to 

use non-U.S.-made devices without official waivers. Finally, most of the 16 Recovery Act-funded 

construction projects are in jeopardy of not being completed on time. Further, five of these projects 

require immediate management attention because they are either scheduled for completion after, 
40 Office of Inspector General | Semiannual Report to Congress | March 2012 

or at risk of being extended beyond, September 30, 2013—the new OMB deadline for using 

Recovery Act funds. Our audit of postaward administration includes recommendations to the 

Under Secretary of Commerce for Standards and Technology that he direct 

•	 The NIST grants office to address federal fund drawdown issues, as well as the review and 

reconciliation of all required reports in official grant files. 

•	 The NIST program office to (a) develop plans to address projects at risk of missing the 

September 30, 2013, deadline; (b) require other grantees to meet grant-specified deadlines 

and/or submit proper extension requests to NIST; and (c) require grantees to submit all 

extension request elements before finalizing its decisions. 

•	 The program office to strengthen its construction grants procedures manual and develop 

a recipient handbook—as well as direct the grants office to instruct staff on the official role 

of the paper file used with their grants management system as it transitions to a new grants 

system (and strengthen internal controls on official file access). 

•	 The program office to ensure Buy American compliance—and direct the grants office to 

establish a firewall to prevent the use of Recovery Act funds (should they become available) 

on non–Recovery Act activities. 

National Institute of Standards and Technology 

The National institute of Standards and Technology promotes Baldrige Performance Excellence Program—Promotes 

U.S. innovation and industrial competitiveness by advancing performance excellence among U.S. manufacturers, service 

measurement science, standards, and technology in ways that companies, educational institutions, health care providers, and 

enhance economic security and improve our quality of life. NIST nonprofit organizations through outreach programs and the 

carries out its mission via four cooperative programs. annual Malcolm Baldrige National Quality Award. 

NIST Laboratories—Conduct research that advances the Technology Innovation Program—Provides cost-shared 

nation’s technology infrastructure and is needed by U.S. industry awards to industry, universities, and consortia for research 

to continually improve products and services. on potentially revolutionary technologies that address critical 

national and societal needs. 

Hollings Manufacturing Extension Partnership—Works 

with small- and mid-sized U.S. manufacturers through a 

nationwide network of 350 field offices to help them create and 

retain jobs, expand into new markets and new products, increase 

profits, and save time and money. 
American Recovery and Reinvestment Act 41 

CONGRESSIONAL TESTIMONY (OIG-12-012-T) 

On November 30, 2011, the Inspector General testified about OIG’s 

oversight of the Department’s implementation of science, technology, 

and other programs funded through the $7.9 billion in Recovery Act 

funding that the Department initially received. (Later, $1.2 billion was 

rescinded or transferred to other agencies.) 

He noted that among the issues the Department encountered in 

spending these funds were (1) slower spending that challenged 

agencies’ science, technology, and business development initiatives 

aimed at job creation; (2) newer programs that experienced slower 

disbursements than existing ones; and (3) the risk of not completing 

Recovery Act projects on time. OIG’s oversight activities identified 

the value of up-front planning and timely data analysis by agencies 

as important “lessons learned.” The Inspector General’s statement 

included an appendix listing nearly 30 completed, in-progress, 

and planned Recovery Act–related audits and reviews, as well as 

congressional testimony undertaken since March 2009. 

“More than two and a half years 

after passage of the Recovery Act, 

the twin challenges of setting up 

new programs and the long lead 

time to complete construction 

projects have resulted in much of 

the Department’s spending being 

incomplete.” 

IG testimony before a U.S. House of 

Representatives Science, Space, and 

Technology Subcommittee, 

November 30, 2011 
 

 

42 Office of Inspector General | Semiannual Report to Congress | March 2012 

STATISTICAL DATA 

The Inspector General Act Amendments of 1988 require us to present the statistical data 

contained in Tables 1–8. 

TABLES	 Page 

1. Office of Investigations Statistical Highlights for This Period	 42
 

2. Audit Resolution and Follow-up	 43
 

3. Audit and Evaluation Statistical Highlights for This Period	 44
 

4. Audits with Questioned Costs	 45
 

5. Audits with Recommendations That Funds Be Put to Better Use	 45
 

6. Report Types for This Period	 46
 

6-a. Performance Audits 47
 

6-b. Financial Statement Audits 48
 

6-c. Evaluations and Inspections 48
 

7. Single Audit and Program-Specific Audits	 49
 

7-a. Processed Reports with Audit Findings 49
 

8. Audits Unresolved for More Than 6 Months	 50
 

TABLE 1. OFFICE OF INVESTIGATIONS STATISTICAL HIGHLIGHTS FOR THIS PERIOD 

Investigative activities cover investigations opened and closed by OIG; arrests by OIG 

agents; indictments and other criminal charges filed against individuals or entities as a result of 

OIG investigations; convictions secured at trial or by guilty plea as a result of OIG investigations; 

and fines, restitution, and all other forms of financial recoveries achieved by OIG as a result of 

investigative action. 

Allegations processed presents the number of complaints from employees, stakeholders, 

and the general public that were handled by our Complaint Intake Unit. Of these, some resulted 

in the opening of investigations; others were referred to Commerce bureaus for internal 

administrative follow-up. Others were unrelated to Commerce activities or did not provide 

sufficient information for any investigative follow-up and so were not accepted for investigation 

or referral. Fines and other financial recoveries refer only to agreements that a judge accepted. 
 

Statistical Data 43 

Investigative Activities 

Investigations opened 21 

Investigations closed 26 

Arrests 0 

Indictments/Informations 4 

Convictions 6 

Fines and other financial recoveries $50,783,766a 

Allegations Processed 

Hotline complaints 625 

Total complaints, all sources 625 

Referrals to bureaus or non-Commerce agencies 310 

Evaluated but not accepted for investigation or referral 294 

a This total is derived solely from federal multi-agency investigations in which OIG secondarily participated (e.g., 

antitrust cases). It does not reflect actual monetary recoveries for the Department of Commerce. 

TABLE 2. AUDIT RESOLUTION AND FOLLOW-UP 

The Inspector General Act Amendments of 1988 require us to present (in this report) audits 

issued before the beginning of the reporting period (October 1, 2011) for which no management 

decision had been made by the end of the period (March 31, 2012). Six audit reports remain 

unresolved for this reporting period (see page 50). 

Audit resolution is the process by which the Department of Commerce reaches an effective 

management decision in response to audit reports. Management decision refers to 

management’s evaluation of the findings and recommendations included in the audit report and 

the issuance of a final decision by management concerning its response. 

Department Administrative Order 213-5, Audit Resolution and Follow-up, provides procedures 

for management to request a modification to an approved audit action plan or for a financial 

assistance recipient to appeal an audit resolution determination. The following table summarizes 

modification and appeal activity during the reporting period. 

Report Category Modifications Appeals 

Actions pending (October 1, 2011) 0 1 

Submissions 0 1 

Decisions 0 1 

Actions pending (March 31, 2012) 0 1 
 

 

 

 

44 Office of Inspector General | Semiannual Report to Congress | March 2012 

TABLE 3. AUDIT AND EVALUATION STATISTICAL HIGHLIGHTS FOR THIS PERIOD 

Audits comply with standards established by the Comptroller General of the United States for 

audits of federal establishments, organizations, programs, activities, and functions. 

Inspections include evaluations, inquiries, and similar types of reviews that do not constitute an 

audit or a criminal investigation. 

Questioned costsa $ 4,509,669 

Value of audit recommendations that funds be put to better useb 886,337 

Value of audit recommendations agreed to by managementc 17,477,647 

These amounts include costs questioned by state and local government auditors or independent 

public accountants. 

a Questioned cost: This is a cost questioned by OIG because of (1) an alleged violation of a 

provision of a law, regulation, contract, grant, cooperative agreement, or other agreement or 

document governing the expenditure of funds; (2) a finding that, at the time of the audit, such 

cost is not supported by adequate documentation; or (3) a finding that an expenditure of funds 

for the intended purpose is unnecessary or unreasonable. 

b Value of audit recommendations that funds be put to better use: This results from an 

OIG recommendation that funds could be used more efficiently if Commerce management 

took action to implement and complete the recommendation. Such actions may include (1) 

reductions in outlays; (2) deobligation of funds from programs or operations; (3) withdrawal of 

interest subsidy costs on loans or loan guarantees, insurance, or bonds; (4) costs not incurred 

by implementing recommended improvements related to Commerce, a contractor, or a grantee; 

(5) avoidance of unnecessary expenditures identified in preaward reviews of contracts or grant 

agreements; or (6) any other savings specifically identified. 

c Value of audit recommendations agreed to by management: This is the sum of (1) 

disallowed costs and (2) funds put to better use that are agreed to by management during 

resolution. Disallowed costs are the amount of costs that were questioned by the auditors 

or the agency action official and subsequently determined—during audit resolution, or during 

negotiations by a contracting officer—not to be charged to the government. 
 

 

 

Statistical Data 45 

TABLE 4. AUDITS WITH QUESTIONED COSTS 

See Table 3 for a definition of “questioned cost.” An unsupported cost is a cost that is not 

supported by adequate documentation at the time of the audit. Questioned costs include 

unsupported costs. 

Questioned Unsupported Report Category	 Number Costs Costs 

A.	 Reports for which no management 

decision had been made by the 12 $38,241,279 $17,364,511 

beginning of the reporting period 

B.	 Reports issued during the reporting 7 4,509,669 3,900,000 period 

Total reports (A+B) requiring a management 19 42,750,948 21,264,511 decision during the perioda 

C.	 Reports for which a management 

decision was made during the reporting 7 18,049,019 16,445,451 

periodb 

i. Value of disallowed costs	 17,386,692 16,427,853 

ii. Value of costs not disallowed 	 893,827 17,598 

D.	 Reports for which no management 

decision had been made by the end of 12 24,701,929 4,819,060 

the reporting period 

a Two audit reports included in this table are also included among reports with recommendations that funds be put 

to better use (see Table 5). However, the dollar amounts do not overlap. 

b In Category C, lines i and ii do not always equal the total line in C because resolution may result in values greater 

than the original recommendations. 

TABLE 5. AUDITS WITH RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE 

See Table 3 for a definition of “recommendation that funds be put to better use.” 

Report Category	 Number Value 

A.	 Reports for which no management decision had been 3 $1,262,853 made by the beginning of the reporting period 

B.	 Reports issued during the reporting period 2 886,337 

Total reports (A+B) requiring a management decision during 5 2,149,190 the perioda 

C.	 Reports for which a management decision was made 2 169,358 during the reporting period 

i. Value of recommendations agreed to by management	 90,955 

ii. Value of recommendations not agreed to by 78,403 management 

D.	 Reports for which no management decision had been 3 1,979,832 made by the end of the reporting period 

a Two audit reports included in this table are also included among reports with questioned costs (see Table 4). 

However, the dollar amounts do not overlap. 
46 Office of Inspector General | Semiannual Report to Congress | March 2012 

TABLE 6. REPORT TYPES FOR THIS PERIOD 

Performance audits are engagements that provide assurance or conclusions based on 

an evaluation of sufficient, appropriate evidence against stated criteria, such as specific 

requirements, measures, or defined business practices. Performance audits provide objective 

analysis so that management, and those charged with governance and oversight can use the 

information to improve program performance and operations, reduce costs, facilitate decision 

making by parties with responsibility to oversee or initiate corrective action, and contribute to 

public accountability. 

Financial statement audits provide reasonable assurance through an opinion (or disclaimer 

of an opinion) about whether an entity’s financial statements are presented fairly in all material 

respects in conformity with generally accepted accounting principles, or with a comprehensive 

basis of accounting other than these principles. 

Evaluations and inspections include evaluations, inquiries, and similar types of reviews that 

do not constitute an audit or a criminal investigation. An inspection is defined as a process that 

evaluates, reviews, studies, or analyzes the programs and activities of a department or agency to 

provide information to managers for decision making; make recommendations for improvements 

to programs, policies, or procedures; and identify where administrative action may be necessary. 

Type Number of Reports Table Number 

Performance audits 8 Table 6-a 

Financial statement audits 5 Table 6-b 

Evaluations and inspections 6 Table 6-c 

Total 19 
Statistical Data 47 

TABLE 6-A. PERFORMANCE AUDITS 

Report Title Report 

Number 

Date 

Issued 

Funds to Be Put 

to Better Use 

National Oceanic and Atmospheric Administration 

Oversight Activities of NIST’s Recovery Act 

Construction Grant Awards Are Generally 

Effective but Need Improvements 

OIG-12-020-A 02.14.2012 0 

National Telecommunications and Information Administration 

Third Annual Assessment of the Public Safety 

Interoperable Communications Grant Program OIG-12-008-A 11.10.2011 0 

NTIA Has an Established Foundation to 

Oversee BTOP Awards, But Better Execution 

of Monitoring is Needed 

OIG-12-013-A 11.17.2011 0 

Office of the Secretary 

Commerce’s Office of Acquisition Management 

Must Continue to Improve Its Ongoing Oversight 

of Acquisition Savings Initiatives 

OIG-12-001-A 10.06.2011 0 

Improvements Are Needed For Effective Web 

Security Management OIG-12-002-A 10.21.2011 0 

FY 2011 Federal Information Security 

Management Act Audit: More Work Needed 

to Strengthen IT Security Department-Wide 

OIG-12-007-A 11.10.2011 0 

Further Actions Needed to Enhance 

Commerce’s Acquisition Human Capital Plan OIG-12-015-A 12.21.2011 0 

U.S. Patent and Trademark Office 

The Patent Hoteling Program Is Succeeding 

as a Business Strategy OIG-12-018-A 02.01.2012 0 
48 Office of Inspector General | Semiannual Report to Congress | March 2012 

TABLE 6-B. FINANCIAL STATEMENT AUDITS 

Report Title Report 

Number 

Date 

Issued 

Funds to Be Put 

to Better Use 

Office of the Secretary 

FY 2011 Financial Statement Audit: 

Assessment of Information Technology 

Controls Supporting Financial 

Management Systems 

OIG-12-004-A 11.01.2011 0 

FY 2011 Consolidated Financial 

Statement Audit OIG-12-009-A 11.14.2011 0 

FY 2011 Special-Purpose Financial 

Statements OIG-12-010-A 11.15.2011 0 

U.S. Patent and Trademark Office 

FY 2011 Financial Statement Audit: 

Assessment of Information Technology 

Controls Supporting Financial 

Management Systems 

OIG-12-005-A 11.01.2011 0 

FY 2011 Financial Statement Audit OIG-12-006-A 11.09.2011 0 

TABLE 6-C. EVALUATIONS AND INSPECTIONS 

Report Title Report 

Number 

National Oceanic and Atmospheric Administration 

Date 

Issued 

Funds to 

Be Put to 

Better Use 

Amount 

Questioned 

Amount 

Unsupported 

Follow-up Review of NOAA 

Fisheries Enforcement Programs 

and Operations 

OIG-12-017-I 01.31.2012 0 0 0 

More Action Needed to Improve 

Controls in Asset Forfeiture Fund OIG-12-019-I 02.08.2012 $871,000 $3,900,000 $3,900,000 

National Telecommunications and Information Administration 

Misrepresentations Regarding Project 

Readiness, Governance Put at Risk 

the Success of the BayWEB Project 

OIG-12-016-M 01.10.2012 0 0 0 

Office of the Secretary 

Top Management Challenges Facing 

the Department of Commerce OIG-12-003-I 10.24.2011 0 0 0 

Single Audit Results for Calendar 

Year 2011 OIG-12-021-M 02.13.2012 0 0 0 

FY 2011 Compliance with Improper 

Payment Requirements OIG-12-022-M 03.15.2012 0 0 0 
Statistical Data 49 

TABLE 7. SINGLE AUDIT AND PROGRAM-SPECIFIC AUDITS 

OIG reviewed and accepted 186 audit reports prepared by independent public accountants 

and local, state, and other federal auditors. The reports processed with questioned costs, 

recommendations that funds be put to better use, and/or nonfinancial recommendations are 

listed in Table 7-a. 

Agency Audits 

Economic Development Administration 

International Trade Administration 

51 

2 

National Institute of Standards and Technology* 

National Oceanic and Atmospheric Administration 

National Telecommunications and Information Administration* 

44 

18 

48 

Multi-bureau 20 

No Commerce expenditures 3 

Total 186 

*Includes 37 program-specific audits for NIST and 39 program-specific audits for NTIA. 

TABLE 7-A. PROCESSED REPORTS WITH MATERIAL AUDIT FINDINGS 

Report Title Report 

Number 

Date 

Issued 

Funds to Be Put 

to Better Use 

Amount 

Questioned 

Amount 

Unsupported 

Economic Development Administration 

South Central Tennessee 

Development District ATL-09999-12-4398 03.02.12 

National Institute of Standards and Technology 

South Carolina Manufacturing 

Extension Partnership ATL-09999-12-3959 12.12.11 

South Carolina Manufacturing 

Extension Partnership ATL-09999-12-3962 12.12.11 

Anasys Instruments Corporation ATL-09999-12-4110 02.22.12 

SimQuest LLC ATL-09999-12-4263 02.22.12 

A 123 Systems Inc. ATL-09999-12-4213 03.29.12 

Ebert Composites Corporation ATL-09999-12-4269 03.29.12 

Pixelligent Technologies LLC ATL-09999-12-4196 03.29.12 

National Oceanic and Atmospheric Administration 

Virgin Islands Resource 

Conservation & Development 

Council, Inc. 

ATL-09999-12-4355 02.22.12 

National Telecommunications and Information Administration 

0 

0 

0 

0 

15,337 

0 

0 

0 

0 

$283,567 

0 

0 

118,809 

0 

27,213 

109,190 

38,387 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

One Economy Corporation, DC 

Vermont Telephone Company, Inc. 

ATL-09999-12-4328 

ATL-09999-12-4312 

11.23.11 

02.28.12 

0 

0 

0 

32,503 

0 

0 
50 Office of Inspector General | Semiannual Report to Congress | March 2012 

TABLE 8. AUDITS UNRESOLVED FOR MORE THAN 6 MONTHS 

Census Bureau Computer & High Tech Management, Inc. 

In our September 2005 Semiannual Report, we reported the results of 

audits of 2 of the 21 task orders for IT services that Computer & High 

Tech Management, Inc., was providing to Census. We sought to determine 

whether the firm had complied with contract terms and conditions 

and federal regulations and had billed Census for work performed in 

accordance with specifications of the task order. We found that the firm 

failed to comply with numerous contract and federal requirements, which 

caused us to question more than $10.7 million in direct labor and other 

reimbursable costs. We have suspended audit resolution on this contract 

audit pursuant to an agreement with Census. 

National Institute 

of Standards 

and Technology 

Manufacturing Extension Partnership Program 

NIST has not reached resolution on findings and questioned costs 

identified in OIG audit reports of the Hollings Manufacturing Extension 

Partnership (MEP) program in three states. We issued our audit reports 

covering the Massachusetts and Florida MEPs in March 2009 and our 

audit report covering California Manufacturing Technology Consulting in 

July 2010. We have reported the findings and questioned costs contained 

in these reports as unresolved in previous Semiannual Reports. NIST 

has been unable to review the associated resolution proposals due to 

insufficient staff in its Grants and Agreements Management Division and 

intends to resolve the three OIG MEP audits by May 31, 2012 (ATL18568, DEN-18135, DEN-18572). 

National Oceanic 

and Atmospheric 

Administration 

Alaska Eskimo Whaling Commission 

As reported in our March 2009 Semiannual Report, a single audit review 

of this NOAA grant questioned costs totaling $66,353 in expenditures 

that were not adequately documented. We have suspended audit 

resolution on this grant audit pursuant to an agreement with NOAA (ATL09999-8-3238). 
11
52 Office of Inspector General | Semiannual Report to Congress | March 2012 

REPORTING REQUIREMENTS
 

The Inspector General Act of 1978, as amended, specifies reporting requirements for 

semiannual reports. The requirements are listed below and indexed to the applicable pages of 

this report. 

Section Topic Page 

4(a)(2) Review of Legislation and Regulations 52 

5(a)(1) Significant Problems, Abuses, and Deficiencies 16-41 

5(a)(2) Significant Recommendations for Corrective Action 16-41 

5(a)(3) Prior Significant Recommendations Unimplemented 52 

5(a)(4) Matters Referred to Prosecutorial Authorities 43 

5(a)(5) and 6(b)(2) Information or Assistance Refused 53 

5(a)(6) Listing of Audit Reports 46-48 

5(a)(7) Summary of Significant Reports 16-41 

5(a)(8) Audit Reports—Questioned Costs 45 

5(a)(9) Audit Reports—Funds to Be Put to Better Use 45 

5(a)(10) Prior Audit Reports Unresolved 53 

5(a)(11) Significant Revised Management Decisions 53 

5(a)(12) Significant Management Decisions with Which OIG Disagreed 53 

5(a)(13) Results of Peer Review 53 

SECTION 4(a)(2): REVIEW OF LEGISLATION AND REGULATIONS 

This section requires the inspector general of each agency to review existing and proposed 

legislation and regulations relating to that agency’s programs and operations. Based on this 

review, the inspector general is required to make recommendations in the semiannual report 

concerning the impact of such legislation or regulations on (1) the economy and efficiency of 

the management of programs and operations administered or financed by the agency or (2) 

the prevention and detection of fraud and abuse in those programs and operations. Comments 

concerning legislative and regulatory initiatives affecting Commerce programs are discussed, as 

appropriate, in relevant sections of the report. 

SECTION 5(a)(3): PRIOR SIGNIFICANT RECOMMENDATIONS UNIMPLEMENTED 

This section requires identification of each significant recommendation described in previous 

semiannual reports for which corrective action has not been completed. Section 5(b) requires 

that the Secretary transmit to Congress statistical tables showing the number and value of audit 

reports for which no final action has been taken, plus an explanation of why recommended action 

has not occurred, except when the management decision was made within the preceding year. 

However, information on the status of any audit recommendations can be obtained through OIG 

upon request. 
Reporting Requirements 53 

SECTIONS 5(a)(5) AND 6(b)(2): INFORMATION OR ASSISTANCE REFUSED 

These sections require a summary of each report to the Secretary when access, information, 

or assistance has been unreasonably refused or not provided. There were no reports to the 

Secretary during this semiannual period. 

SECTION 5(a)(10): PRIOR AUDIT REPORTS UNRESOLVED 

This section requires (1) a summary of each audit report issued before the beginning of the 

reporting period for which no management decision has been made by the end of the reporting 

period (including the date and title of each such report); (2) an explanation of why a decision has 

not been made; and (3) a statement concerning the desired timetable for delivering a decision 

on each such report. There are one NOAA, three NIST, and two Census reports more than 6 

months old for which no management decision has been made. 

SECTION 5(a)(11): SIGNIFICANT REVISED MANAGEMENT DECISIONS 

This section requires an explanation of the reasons for any significant revision to a management 

decision made during the reporting period. Department Administrative Order 213-5, Audit 

Resolution and Follow-up, provides procedures for revising a management decision. For 

financial assistance audits, OIG must concur with any decision that would change the audit 

resolution proposal in response to an appeal by the recipient. There was one appeal this period. 

SECTION 5(a)(12): SIGNIFICANT MANAGEMENT DECISIONS WITH WHICH OIG 

DISAGREED 

This section requires information concerning any significant management decision with which 

the inspector general disagrees. Department Administrative Order 213-5 provides procedures 

for elevating unresolved audit recommendations to higher levels of Department and OIG 

management, including their consideration by an Audit Resolution Council. During this period, no 

audit issues were referred. 

SECTION 5(a)(13): RESULTS OF PEER REVIEW 

The most recent peer review of the Office of Audit and Evaluation was conducted in 2009 by 

the Federal Deposit Insurance Corporation’s (FDIC) Office of Inspector General. FDIC OIG’s 

System Review Report of our audit operations is available on our website. We received a pass 

rating, the highest available rating. We have implemented all of FDIC OIG’s recommendations 

for process and policy improvements. 

In 2009, we conducted our latest peer review, which examined the Small Business 

Administration (SBA) OIG’s audit operations. SBA’s OIG has informed us that it implemented 

the recommendation we made in our review. 

The most recent peer review of the Office of Investigations was conducted in October 2011 

by the Office of Personnel Management’s OIG. The final report on the peer review is expected 

during the next semiannual period. 
54 Office of Inspector General | Semiannual Report to Congress | March 2012 

ACRONYMS AND ABBREVIATIONS
 

AHCP Acquisition Human Capital Plan 

AFF Asset Forfeiture Fund 

ATP Advanced Technology Program 

BayWEB San Francisco Bay Area Wireless 

Enhanced Broadband 

BEA Bureau of Economic Analysis 

BIS Bureau of Industry and Security 

BPAI Board of Patent Appeals and 

Interferences (USPTO) 

BTOP Broadband Technology Opportunities 

Program 

CBS Commerce Business Systems 

CS Commercial Service (ITA) 

CWIP construction work in progress 

DHS Department of Homeland Security 

DOJ Department of Justice 

EDA Economic Development Administration 

ESA Economics and Statistics Administration 

FDIC Federal Deposit Insurance Corporation 

FEMA Federal Emergency Management Agency 

FISMA Federal Information Security 

Management Act of 2002 

FMC Fishery Management Council (NOAA) 

FY fiscal year 

GCES Office of the General Counsel 

Enforcement Section (NOAA) 

GOES Geostationary Operational Environmental 

Satellite 

IPERA Improper Payments Elimination and 

Recovery Act of 2020 

IPIA Improper Payments Information Act of 

2012 

IT information technology 

ITA International Trade Administration 

JPSS Joint Polar Satellite System 

LEADS Law Enforcement Accessible Database 

System 

MAF/TIGER Master Address File/Topologically 

Integrated Geographic Encoding and 

Referencing 

MEP Manufacturing Extension Partnership 

NIST National Institute of Standards and 

Technology 

NOAA National Oceanic and Atmospheric 

Administration 

NOFA Notice of Funds Availability 

NPP National Polar-orbiting Partnership 

NTIA National Telecommunications and 

Information Administration 

OAM Office of Acquisition Management 

(Commerce) 

OIG Office of Inspector General 

OLE Office of Law Enforcement (NOAA) 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

PHP Patent Hoteling Program 

PSIC Public Safety Interoperable 

Communications 

SBA Small Business Administration 

T&M/LH Time-and-Materials and Labor-Hour 

TAAC Trade Adjustment Assistance Center 

USEAC U.S. Export Assistance Centers 

USPTO U.S. Patent and Trademark Office 

U.S. Department of Commerce 

Office of Inspector General 

1401 Constitution Avenue, NW 

Washington, DC 20230 

www.oig.doc.gov 

OUR MISSION 

To improve the programs and operations of the 

Department of Commerce through independent 

and objective oversight.