MARCH 25, 2020

_________________

FEDERAL ELECTION COMMISSION 

Office of Inspector General

OFFICE OF INSPECTOR GENERAL

Review of Outstanding

Recommendations as of February 2020
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 2 | Page

Table of Contents

Report Objective ...........................................................................................................................................3

Report Revisions...........................................................................................................................................3

Report Highlights..........................................................................................................................................3

Table 1. Summary of Open Recommendations by Project.......................................................................4

Audit Follow-up Meetings/Communications................................................................................................5

Closed Audits/Inspections ........................................................................................................................5

Open Audits/Inspections...........................................................................................................................5

Background...................................................................................................................................................8

Corrective Action Plan Process.................................................................................................................8

Audit Follow-up Process...........................................................................................................................8

Recommendation Resolution Process.......................................................................................................9

Appendix A.................................................................................................................................................10

Figure 1. Recommendations Progress Report from August 2018 to February 2020 ..............................10

Appendix B.................................................................................................................................................11

Figure 2. Recommendations Activity by FEC Office From August 2018 to February 2020 .................11

Appendix C.................................................................................................................................................12

Figure 3. Age of Outstanding Recommendations...................................................................................12
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 3 | Page

Report Objective

Per Commission Directive 50: Audit Follow-up, the Office of Management and Budget’s 

Circulars A-50, Audit Follow Up, and A-123, Management’s Responsibility for Enterprise Risk 

Management and Internal Controls (as revised), FEC management is required to implement 

corrective actions to address findings identified in OIG reports in a timely manner. Since fiscal 

year (FY) 2012, the Office of Inspector General (OIG) has provided the FEC Commission with 

semiannual reports outlining the status of management’s corrective actions for deficiencies that 

have been outstanding for more than six months. The objective of issuing such reports is to 

provide governance with an understanding of the risks that exist in the FEC’s environment and 

ensure that management is held accountable for sufficiently addressing operational risk in a 

timely manner. 

Report Revisions

As reported in August 2018, the OIG revised the follow-up reporting process and as a result, the 

OIG publishes one report in March of each year. However, due to the lack of an Inspector 

General (IG) and Deputy IG from November 2018 to April 2019, the OIG did not issue an 

annual report in 2019. In March 2019, the OIG provided the FEC Commission with an informal 

status update on all open recommendations. As consistent in previous reports, this report will 

include the OIG’s review of FEC’s recommendations that have been outstanding for more than 

six months and identify any progress management has made in addressing the recommendations

to date. The OIG will continue to conduct an informal follow-up assessment on outstanding 

recommendations semiannually (or more frequently at a program managers’ request).

Report Highlights

The previous formal status report, Review of Outstanding Recommendations as of August 2018,

identified 50 outstanding recommendations from five audits and two inspections. The OIG 

acknowledges that the increased collaboration efforts by both the OIG and FEC management,

has resulted in significant progress in reducing 56% of the open recommendations since August 

2018. The complete details of the review are included in this report as well as graphical 

illustrations which include, an open recommendations progress report, recommendations activity 

by program office, and the age of outstanding recommendations (see appendices A-C).
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 4 | Page

Table 1. Summary of Open Recommendations by Project

OIG Audits/Inspections

Total Outstanding 

Recommendations 

as of August 2018

Total Closed 

since August 

2018 

Total Open 

as of 

February 28, 20201

2010 Follow-up Audit of Privacy 

and Data Protection 

9 years outstanding 

23 14 9

2010 Follow-up Audit of 

Procurement and Contract 

Management

7 years outstanding

1 1 0

Inspection of the FEC’s

Disaster Recovery Plan and

Continuity of Operations Plans

7 years outstanding

7 0 7

Audit of the FEC’s Office of Human 

Resources 

6.5 years outstanding

3 1 2

Inspection of FEC’s Compliance 

with FMFIA/OMB A-123 

5.5 years outstanding

4 4 0

Audit of the FEC Telework 

Programs 

3.5 years outstanding

9 8 1

2017 Required Review Under the 

DATA Act2

2 years outstanding

3 0 3

Totals 50 28 22

 1 Figures may include recommendations that management has disagreed with or has not adequately implemented; 

however, the OIG concludes that these recommendations remain open.

2 The three recommendations identified in the 2017 DATA Act audit were repeated and superseded in the 2019 

Data Act audit. As a result, we consider the recommendations from the 2017 DATA Act audit as open. 
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 5 | Page

Audit Follow-up Meetings/Communications

Closed Audits/Inspections3

The OIG closed the following audit and inspection recommendations this review period.

A. 2010 Follow-up Audit of Procurement and Contract Management

The 2010 Follow-up Audit of Procurement and Contract Management was issued in June 

2011. The OIG’s previous Review of Outstanding Recommendations as of August 2018 

report identified one (1) open recommendation related to updating Commission 

Directive 66, which is the overarching agency policy for procurement and acquisitions. 

Since then, the agency has updated all applicable procurement policies and standard 

operating procedures in efforts to comply with the Federal Acquisition Regulations 

(FAR). As a result, the OIG has closed this recommendation. 

B. Inspection of FEC’s Compliance with Federal Managers’ Financial Integrity Act 

(FMFIA)/OMB Circular A-123

The Inspection of FEC’s Compliance with FMFIA/OMB Circular A-123 (A-123 

Inspection) was released in June 2014. The OIG’s Review of Outstanding 

Recommendations as of August 2018 report identified four (4) open recommendations.

Since then, the OIG conducted follow-up inquiries with the Office of the Chief Financial 

Officer (OCFO) and reviewed the revised annual internal control review (ICR) process 

that was implemented in FY 2019. As a result, the OIG confirmed that the updated ICR 

process incorporates the applicable requirements included in the revised OMB A-123 

guidance issued in June 2016. Therefore, the OIG has closed all four (4) outstanding 

recommendations.

Open Audits/Inspections

C. The 2017 Required Review Under the Digital Accountability and Transparency 

(DATA) Act

The FEC OIG’s Required Review under the DATA Act (DATA Act Audit) was released 

in November 2017. The OIG’s Review of Outstanding Recommendations as of March 

2018 report identified three (3) open recommendations. Since the previous follow-up

report, the second mandated audit of FEC’s DATA Act program was completed in 

November 2019. Three (3) recommendations identified in the 2017 DATA Act Audit 

were repeated and superseded in the recent 2019 Data Act Audit. As a result, we consider 

 3 An audit or inspection is closed once the OIG determines that all applicable recommendations have been 

adequately addressed and/or management has determined that it will accept the risk of not implementing the 

recommendation. 
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 6 | Page

the recommendations from the 2017 DATA Act as revised but open and attached to the 

2019 DATA Act Audit.

4

D. 2010 Follow-up Audit of Privacy and Data Protection

For the 2010 Follow-up Audit of Privacy and Data Protection (Privacy Audit), the OIG’s 

Review of Outstanding Recommendations as of August 2018 report identified 23 open 

recommendations. Since the previous reporting period, the OIG met with the FEC’s

Office of General Counsel (OGC) Privacy Team on several occasions to collaborate and

address the outstanding recommendations. The OIG acknowledges the efforts of the 

Privacy Team Leader, who provided supporting documentation of corrective actions

implemented to date. As a result, we closed 14 of the 23 open recommendations. 

Therefore, nine (9) recommendations remain open for this reporting period. 

 

E. Inspection of the FEC’s Disaster Recovery Plan (DRP) and Continuity of Operations 

Plans (COOP)

The Inspection of the FEC’s Disaster Recovery Plan and Continuity of Operations Plans

(COOP Inspection) report was released in January 2013. The OIG’s Review of 

Outstanding Recommendations as of August 2018 report identified seven (7) outstanding 

recommendations. The OIG reviewed management’s May and November 2019

corrective action plan (CAP) and determined that all seven (7) recommendations remain

open. The Office of the Chief Information Officer (OCIO) has recently awarded a 

contract for COOP consulting services, which will include a review and update to the 

existing FEC DRP. Once the DRP is complete, the agency will develop a test plan for 

implementation. The estimated completion date is the end of the third quarter of FY 

2020. As a result, all seven (7) recommendations remain open for this reporting period. 

F. Audit of the FEC’s Office of Human Resources 

The Audit of the Federal Election Commission’s Office of Human Resources (OHR

Audit) report was issued in July 2013. The OIG’s Review of Outstanding 

Recommendations as of August 2018 report identified three (3) open recommendations 

related to this audit report. The Director of OHR resigned in October 2018. Since then, 

the OIG has worked with the Acting OHR Director to address the status of the open 

recommendations. The FEC OHR, in conjunction with the Office of Personnel 

Management HR Solutions Team, continues to make progress in updating, receding, and 

developing personnel-related policies and procedures for the agency. As a result, one (1) 

recommendation was closed for this reporting period.

FEC OHR has improved its response time to staff inquiries. However, it has not 

implemented an adequate mechanism to track and continuously monitor staff inquiries as 

 4 The 2019 DATA Act Audit is not included in this review as the review excludes recommendations that have been 

open for less than six months. 
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 7 | Page

recommended. Therefore, two (2) of the three (3) outstanding recommendations remain

open for this reporting period.

G. Audit of the FEC’s Telework Programs

The Audit of the FEC’s Telework Programs (Telework Audit) was released in June 2016. 

The OIG’s Review of Outstanding Recommendations as of August 2018 report identified 

nine (9) open recommendations related to this audit. Since the last reporting period, FEC 

management revised the Non-Bargaining Unit (NBU) Telework Policy, and in June 2019,

it implemented the annual telework control review policy and procedures. The telework

control review policy describes how the OHR will monitor the FEC telework programs 

for compliance and effectiveness. Telework control reviews (pilot) were conducted in 

June and December 2019. In February 2020, additional control procedures were 

implemented and incorporated into the annual telework control review process to ensure 

episodic telework is used for intended purposes. The OIG reviewed the applicable 

telework policies and procedures, the results of the telework control reviews, and as a 

result, closed eight (8) of the nine (9) open recommendations. 

Additionally, management has drafted NBU policy language to address the remaining 

recommendation related to the agency’s position and criteria for approving special 

telework accommodations. The OIG will close this recommendation once the policy is 

signed and finalized. Thus, there is one (1) outstanding recommendation attached to this 

audit for the reporting period.
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 8 | Page

Background

As required by the Inspector General Act of 1978, as amended, the OIG is responsible

for among other things, conducting and supervising audits, inspections, and special 

reviews of the FEC’s programs and operations. Additionally, the OIG has the

responsibility to perform follow-up assessments to ensure that management has 

effectively implemented OIG recommendations and provide guidance as required. FEC 

management is required to implement timely corrective actions as codified in the OMB

Circular A-50, Audit Follow-up, as revised, and FEC Directive 50: Audit Follow-up.

The audit follow-up process includes the following sub-processes:

Corrective Action Plan Process

At the conclusion of each OIG audit, inspection, or special review, it is management’s 

responsibility to develop a corrective action plan (CAP) within 30 days. The CAP provides

management’s plan to address the OIG’s findings and recommendations. The CAP should 

entail the following:

• Assignment of Audit Follow-up Official (the responsible party for overseeing the 

corrective action);

• OIG finding(s);

• OIG recommendation(s);

• Comprehensive corrective action required to implement and satisfy the OIG’s finding(s) 

and recommendation(s);

• FEC employee responsible for implementing each task; and

• Expected completion dates and timelines.

Once management drafts a CAP, the OIG reviews and provides comments to management 

regarding the adequacy of the scheduled corrective actions to address the findings and 

recommendations. Management then reviews the OIG’s comments, finalizes the CAP, and 

provides a final CAP to the Commission with a courtesy copy to the OIG.

Audit Follow-up Process

FEC Directive 50 requires management to:

(3) Conduct regular meetings with the Inspector General throughout the year to followup on outstanding findings and recommendations, and include reports of these meetings 

in the written corrective action plan and semi-annual reports required to be presented to 

the Commission...;
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 9 | Page

The OIG communicates with management no less than semiannually in February and August 

of each year to discuss the status of OIG recommendations that have been outstanding for 

more than six months. The purpose of such meetings is to:

• ensure continuous monitoring of open recommendations;

• ensure adequate and timely audit resolution; 

• collaborate and engage in a good faith effort to resolve any 

issues/disagreements; and 

• provide management with timely feedback prior to management’s CAP 

reporting requirements to the Commission in May and November of each year.

Once management implements corrective action(s), the OIG must subsequently review the 

supporting documentation (e.g., new/updated policies, procedures, reports, processes to improve

internal controls, etc.) to verify that management has adequately implemented the 

recommendation(s). The OIG will determine the official status (open or closed) of outstanding 

recommendations. Further, the OIG is required to report all outstanding recommendations in the 

OIG’s Semiannual Reports to Congress in April and November of each year.

Recommendation Resolution Process

In 2014, we implemented a formal recommendation resolution process as an alternative method to 

address outstanding recommendations where the OIG and FEC management disagree. The 

recommendation resolution process can be initiated at the discretion of the OIG if any of the 

following actions occur:

• Management disagrees with a reported finding or recommendation; 

• Management is consistently non-responsive to OIG follow-up inquiries; or

• OIG determines that corrective actions will not satisfy the intent of the reported 

finding and/or recommendation.

The recommendation resolution process can be executed in one of two methods:

1. Management can document a memorandum indicating that management is willing to accept 

the risk of not implementing a corrective action in efforts to officially close the 

recommendation. The memorandum shall explain where the program office disagrees with the 

OIG, why it disagrees, and the details to justify the decision to accept the risk. The 

memorandum must be signed by the appropriate senior leader; or

2. The OIG can consult directly with the Commission and request that the Commission make a 

final decision on whether management is required to implement a corrective action.
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 10 | Page

Appendix A

Figure 1. Recommendations Progress Report from August 2018 to February 2020

50

28

22

0

10

20

30

40

50

60

Total Open

Recommendations as of

August 2018

Total Closed

Recommendations

Current Open

Recommendations

# of 

Recommendations

Recommendations Progress Report from August 2018 to February 2020

The FEC and the OIG have worked to implement and close 28 outstanding recommendations in 

a 18 month time frame
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 11 | Page

Appendix B

Figure 2. Recommendations Activity by FEC Office From August 2018 to February 2020

14

9

5

9

3

3

7

23

12

8

7

0

5

10

15

20

25

OGC OHR OCFO OCIO

# of 

Recommendations

FEC Office

Recommendations Activity by FEC Office From August 2018 to 

February 2020

Total Closed Recommendations Since August 2018 Current Open Recommendations
Office of Inspector General’s Review of Outstanding Recommendations as of February 2020 12 | Page

Appendix C

Figure 3. Age of Outstanding Recommendations

3

1

9

9

Open Less Than 2 Years

Open 2 to 4 Years

Open 6 to 8 Years

Open 8 to 10 Years

Age of Outstanding Recommendations

18 (82%) of the 22 oustanding recommendations are more than six years old