FEDERAL ELECTION COMMISSION 

OFFICE OF INSPECTOR GENERAL 

FINAL REPORT 

AUDIT OF AGENCY 

CONTROLS GOVERNING THE PROCESS FOR 

PROCUREMENT 

OF VENDOR TRAINING SERVICES 

As of July 2000 

AUDIT ASSIGNMENT No. 00-01 
Final Audit Report 

Table of Contents 

Executive Summary .................................................................. i

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

Legal and Regulatory Foundation 1

Allocation of Agency Funds For Vendor Training Services 2

Audit Objective, Scope, Methodology 4

Statement on Management Controls 4

Audit Results ................................................................... 6

Federal Regulations and Management Controls 6

Written Policy and Procedures Needed to Establish Control 7

The Transaction Cycle for Requesting Vendor Training Services 10

Uniform Processing Procedures Need to be Established 12

Standard Form Needed for Initiating the Request 13

A Complete Record of Training Activities Needed 15

Stronger Controls Needed for Certifying Vendor Training 15

Travel and Related Training Expense Need to be Tracked 17

Processing of Information Should be Computerized 18

Appendix A Management Letter 22

Appendix B Management’s Comments 26

Appendix C OIG Response to Management’s Comments 31

Appendix D Article 24 of the Labor Management Agreement 33

Appendix E OPM Standard Training Form 182 35

Appendix F FEC Form 10-14, Inspection and Receiving Report 36 

Appendix G FEC Form 10-5, Official Travel Authorization 37 
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Executive Summary Section Final Audit Report No 00-01 

Executive Summary 

The fundamental objective of any staff training program, or portion thereof, should be to ensure 

that the right training is provided to the right people at the right time and at the right cost. In 

addition, the Director of the U.S. Office of Personnel Management has included: “And in the 

Federal government, we must always take care to add ‘and in the right way’ to ensure that the 

Federal civil service is managed in accordance with the Merit System principles” (Testimony by 

the Honorable Janice R. Lachance before the Senate Subcommittee on Management, 

Restructuring, and the District of Columbia, on March 9, 2000). In her testimony the Director 

indicated that in order to accomplish human capital objectives, the Office of the President has 

included strategic human resources management as a priority management objective in the fiscal 

year 2001 budget. In addition, the Director went on to say: 

“We must also continue to add value to the workforce that is already on board and 

find ways to promote the potential of our employees by making them more 

knowledgeable, more adaptable, and better able to meet changing needs. Part of 

every employee’s job will be to keep learning about the ever-changing work to be 

performed. The Clinton/Gore Administration realizes this and has made lifelong 

learning a priority for the Federal workforce. Continual learning and development 

are the keys here, with a focus on adding the skills and competencies that will 

improve results.” 

Audit Summary 

The Office of Inspector General (OIG) completed a limited-scope audit of the staff training 

program at the Federal Election Commission (FEC). We conducted our audit to assess the 

effectiveness and efficiency of management controls governing the process for procurement of 

training services obtained through outside vendors. Based on our audit, we conclude that agency 

controls governing that program are not effective or efficient. Our audit did not examine training 

developed “in-house,” which is training created and administered by agency staff, for agency 

staff. 

Furthermore, the Code of Federal Regulations requires Federal agencies to maintain a record of 

all agency training activities. However, based on our detailed examination of agency training 

records, we conclude that the FEC would not be capable of producing a complete record of 

training activities which would comply with Federal regulations. 

The procurement of vendor training services at the FEC is comprised of a set of operating 

practices which seem to have simply evolved over time without the aid of written administrative 

policy and procedures. From agency staff we interviewed during our audit, there is unanimous 

agreement that the current process for submitting and approving staff requests for vendor training 

services is a cumbersome, paper intensive process which is extremely costly; especially in terms 
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Executive Summary Section Final Audit Report No 00-01 

of the unnecessary expenditure in staff time. Moreover, this paper driven and labor intensive 

process results in excessive cycle time, needless duplication of work, misdirected and lost 

paperwork, and allows payments to vendors for services not received. Even so, the same 

procedures continue to be followed in the context of applying “past practice” to the process for 

requesting vendor training services. As a result, the FEC is also subject to the following risks: 

• Divisions and major FEC offices follow inconsistent policy and procedures. 

• Sound procurement decisions may be inhibited. 

• 	 Cost reductions associated with a uniform approach, monitored by an oversight entity, may 

not be obtained. 

• Services may be procured that are below expectations. 

• Services may have been purchased in excess of competitive prices. 

Audit Recommendations 

For the process to procure vendor training services, in the AUDIT RESULTS section of this 

report we recommend that the FEC: 

• develop policies and procedures that establish effective management controls; 

• design controls to ensure that each training request is properly routed through the agency; 

• require a standard form to be used for initiating a request; 

• maintain a complete record of all agency staff attending vendor training services; 

• require staff attending vendor training to certify that training services were received; 

• track related travel and other training expenses; and 

• replace the current paper-based system of records with an efficient electronic system. 

In addition to our audit recommendations, suggestions for improvement of management practices 

have been provided to the FEC in the form of a Management Letter, which is included as 

Appendix A. 

Summary of Management’s Response to Audit Results 

On June 13, 2000, agency management concurred with six of the seven audit findings and related 

recommendations contained in the draft audit report. According to their response, three of the 

seven audit recommendations have already been implemented. In addition, management 

indicates that other audit recommendations will be incorporated as standard operating procedures 

to be developed by the agency for processing transactions requesting vendor training services. 
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Executive Summary Section Final Audit Report No 00-01 

However, management chose to disagree with our audit recommendation to develop and 

implement a computer information system to replace the current paper based system of records. 

The complete text of management’s comments to our audit report can be found in this report in 

Appendix B. Our response to management’s comments is shown as Appendix C. 
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Background Section Final Audit Report No 00-01 

BACKGROUND 

Legal and Regulatory Foundation for Federal Training Programs 

The Government Employees Training Act of 1958 (GETA), created the framework for Federal 

department and agencies to plan, develop, establish, implement, evaluate, and fund training and 

development programs designed to improve the quality and performance of the workforce. 

Paragraphs (1), (2), and (3) of section 2 of GETA capture the purpose and intent of Federal 

public policy relating to the training of government staff. In part, GETA declares that such 

programs shall be designed to: 

• improve public service; 

• lead to dollar savings; 

•	 build and retain a permanent cadre of skilled and efficient government employees well 

abreast of scientific, professional, technical, and management developments; 

• lower turnover of personnel; 

•	 lead to reasonably uniform administration of training, consistent with the mission of the 

agency; and 

• fair and equitable treatment of Federal employees with respect to training. 

The GETA also provided the legal means for authorizing training expenditures, including the 

authorization for purchasing training from nongovernmental institutions. The GETA was 

codified into Title 5 of the United States Code (U.S.C.), section 41. The U.S.C. is a codification 

of those sections of legislative acts that prescribe action by Federal department and agencies. 

The U.S. Code of Federal Regulations (C.F.R.) is a codification of the general and permanent 

rules published in the Federal Register by the executive department and agencies of the Federal 

government. Federal regulations require agencies to maintain information concerning the general 

conduct of agency training activities for internal management purposes and for the President and 

the Congress to discharge effectively their respective responsibilities for supervision, control, and 

review of training activities. Agencies should maintain records on the following: 1) agency 

training plans (5 C.F.R., section 410.302(d); 2) training activities funded and individual staff 

trained (5 C.F.R., section 410.311); 3) payments made for travel, tuition, fees and other necessary 

training expenses (5 C.F.R., section 410.406); and 4) evaluations of the results of training and 

how well agency training activities met short and long-range needs (5 C.F.R., section 410.602). 

Executive Orders provide agency heads with additional Presidential direction on how the law is 

to be used. Executive Order No. 11348, as amended, delegates authority for training to the U.S. 

Office of Personnel Management (OPM), and directs OPM to provide assistance to Federal 

department and agencies. While OPM sets overall policy and provides general guidance, Federal 

agencies are free to develop their own plans, design their own programs, and allocate resources 

as they think is necessary to meet their needs. 
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Background Section Final Audit Report No 00-01 

In addition to OPM, three other key agencies impact the administration of Federal training 

programs: 1) the U.S. Office of Management and Budget (OMB), 2) U.S. General Services 

Administration (GSA), and 3) the U.S. General Accounting Office (GAO). 

The OMB issues various directives that influence the management of Federal programs. For 

example, OMB Circular A-123, Management Accountability and Control, provides guidance to 

Federal managers on improving the accountability and effectiveness of programs and operations 

by establishing, assessing, correcting, and reporting on management controls. In the same 

Circular, OMB states: “Management accountability is the expectation that managers are 

responsible for the quality and timeliness of program performance, increasing productivity, 

controlling costs and mitigating adverse aspects of agency operations, and assuring that programs 

are managed with integrity and in compliance with applicable law.” 

Finally, the GSA affects staff training and development through publication of procurement 

directives, while the GAO assists Federal department and agencies in the interpretation of laws 

governing the expenditure of public funds. 

As part of its effort to address the human capital crisis currently facing the Federal government; 

the Senate Subcommittee on Oversight of Government Management, Restructuring, and the 

District of Columbia asked the GAO to review selected Federal agencies’ training programs for 

Subcommittee hearings held on May 18, 2000. The GAO gathered information on how the 

selected Federal agencies design, implement, and evaluate their training programs. The Federal 

Election Commission (FEC) was not one of the agencies selected to participate in the GAO 

review. 

Allocation of FEC Funds for Staff Training 

According to the fiscal year 1998-2003 Strategic Plan developed and published by the FEC: “As 

a personnel intensive agency, over 70% of the Commission’s resources are staff costs, and the 

remaining 30% represents mainly rent and other direct support for that staff.” For fiscal years 

1989 through 2000, Exhibit No. 1 on page 3, shows the total annual agency budget; the 

expenditures for vendor training services as reported by the FEC; the percentage of expenditures 

as part of the annual budget; and the average number of agency staff reported as employed during 

the fiscal year. The fiscal year runs from the first of October through the end of September of the 

following year. Consequently, fiscal year 2000 training expenditures as well as the average 

number of staff are based on budget projections and subject to change prior to year end. 
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Background Section Final Audit Report No 00-01 

Exhibit No. 1 

Fiscal Year 

FEC 

Annual 

Budget 

Reported Vendor 

Training 

Expenditures 

Percentage 

of 

Budget 

Average 

Staff For 

Fiscal Year 

1989 $15,683,000 $83,200 0.53% 251.3 

1990 $15,330,000 $53,700 0.35% 241.7 

1991 $17,149,800 $77,900 0.45% 252.9 

1992 $18,808,000 $97,700 0.52% 266.2 

1993 $21,143,000 $66,100 0.31% 270.1 

1994 $23,564,000 $103,300 0.44% 293.3 

1995 $25,648,000 $99,400 0.39% 314.8 

1996 $26,521,000 $55,000 0.21% 308.5 

1997 $28,165,000 $62,000 0.22% 296.7 

1998 $31,650,000 $96,500 0.30% 302.7 

1999 $36,850,000 $208,000 0.56% 322.1 

2000 $38,278,000 $173,800 0.45% 351.5 

Source: Office of Inspector General / Federal Election Commission 

For the data shown in the table above, Exhibit No. 2 depicts the relationship between the total 

budget as shown by the steadily increasing line, and fiscal year expenditures for procurement of 

vendor training services. 

Exhibit No. 2:

$40,000,000 

$35,000,000 

$30,000,000 

$200,000 

$180,000 

2000 

Training Expense 

$160,000 

$140,000 

$25,000,000 

Budget 

1989 

$120,000 

$20,000,000 $100,000 

$80,000 $15,000,000 

$60,000 $10,000,000 $40,000 

$5,000,000 $20,000 

$0 $0 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 

Fiscal Year 

Each time that the FEC has been forced to cut expenses in the last ten years, staff training is one 

of the first items mentioned for reduction. The final FEC appropriation for fiscal year 1991 was 

the full amount requested; however, the agency reported that it was forced to make cuts in 

training to cover larger-than-anticipated pay increases for executives and staff. In fiscal year 

1995, the FEC froze hiring and most non-personnel spending (e.g., travel, training, printing). 

Again in fiscal year 1996, the FEC instituted a partial hiring freeze and reported cutting select 
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Background Section Final Audit Report No 00-01 

non-personnel expenses, such as training and outreach programs. Viewing staff training 

programs as discretionary spending is consistent with conclusions reached by the GAO. In recent 

testimony before Congress, the GAO states, “little data exists on the overall Federal 

expenditures on training, but the anecdotal evidence is that, in trying to save on workforcerelated costs, agencies cut back on the training investments needed.” (Managing Human Capital 

in the Twenty-first Century, GAO/T-GGD-00-77, March 9, 2000) 

In her testimony before the same Senate Subcommittee, the Director of OPM stated: 

“OPM recognizes that without continuous learning and a real investment in training 

and development, worker ‘empowerment’ is an empty phrase. Each day brings fresh 

examples of how a better trained workforce correlates with reduced costs, improved 

services, and increased customer and employee satisfaction. Up-to-date knowledge, 

skills, and abilities are critical for both organizational performance and individual 

employee success.” (Statement of Janice R. Lachance, Director Office of Personnel 

Management, March 9, 2000) 

OIG Audit Objectives, Scope and Methodology 

The primary purpose of our audit was to assess the efficiency and effectiveness of management 

controls governing the process for procurement of vendor training services at the FEC. Federal 

regulations require Federal agencies to adopt specific practices for managing the training of 

agency staff. A key provision of Federal regulations require maintaining a complete record of 

staff training activities. 

To accomplish our audit objectives, we used various methods of data collection including staff 

interviews, document reviews, and the examination of individual training records for fiscal year 

1999. We did not examine training developed “in-house;” which is training created and 

administered by agency staff, for agency staff. 

We conducted our audit survey and fieldwork from December 1999 through May 2000, in 

accordance with generally accepted government auditing standards appropriate to the scope of 

the audit described above. 

Statement on Management Controls 

As part of our audit, we assessed the system of management controls and operational practices 

relating to the process for procurement of outside vendor training services. Our assessment was 

performed to determine whether the FEC has put in place management controls required by 

OMB directives and Federal regulations. In general, these controls include the policies and 

procedures the FEC has designed and implemented to establish a process for training agency 

staff. 
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Background Section Final Audit Report No 00-01 

Due to inherent limitations, an evaluation made for the limited scope purposes described above, 

would not necessarily disclose every reportable condition in the staff training program at the 

FEC. The term reportable condition refers to significant weakness in the design or operation of a 

management control causing deficient performance. However, we did identify reportable 

conditions as a result of our audit, and these conditions and their effect on the FEC staff training 

program are fully described in the AUDIT RESULTS section of this report. 
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Audit Results Section Final Audit Report No 00-01 

Audit Results 

The Office of Inspector General (OIG) completed a limited-scope audit of the staff training 

program at the Federal Election Commission (FEC). We conducted our audit to assess the 

effectiveness and efficiency of management controls governing the process for procurement of 

training services for agency staff obtained through outside vendors. By conducting our audit in 

accordance with generally accepted government auditing standards, we are also required to 

evaluate agency compliance with applicable Federal laws and regulations. Throughout the audit, 

we regularly updated management on program risk which we identified in the conduct of our 

audit work. In this report, we have provided audit recommendations which we believe will 

improve program performance and reduce risk inherent in any agency operation. In addition to 

our audit recommendations, suggestions for improvement of management practices have been 

provided to the FEC in the form of a Management Letter, which is shown in this report as 

Appendix A. 

Initially, the focus of our audit was the training file maintained by the FEC Office of Personnel. 

Because those training records were found to be incomplete for the period under review, we 

expanded the scope of our audit. Ultimately, our examination of records pertaining to the 

procurement of vendor training services became agency-wide. Therefore, an agency-wide 

approach will be needed to implement the recommendations contained within this audit report. 

Based on our audit work, we conclude that agency controls governing the process for 

procurement of vendor training services are neither effective nor efficient. Our audit also found 

that the FEC would not be capable of producing a complete record of all staff training activities 

which would comply with existing Federal laws and regulations. However, from our detailed 

examination of training records, we noted no specific instances of either fraud or abuse. 

As described below, Federal regulations specifically require that the FEC maintain evidence of 

training activities in four general areas. Our audit primarily concentrated on the regulation 

provisions contained within numbers two and three. We did not attempt an in-depth review of 

agency training plans required by provision number one, and we found no evidence to indicate 

that the agency evaluated the effectiveness of vendor training services, as required by provision 

number four. 

Federal Regulations and Management Controls 

Federal regulations require agencies to maintain information concerning the general conduct of 

agency training activities for internal management purposes and for the President and the 

Congress to discharge effectively their respective responsibilities for supervision, control, and 

review of training activities. Specifically, Federal regulations require evidence of: 1) agency 

training plans (5 C.F.R., section 410.302(d); 2) training activities funded and individual staff 

trained (5 C.F.R., section 410.311); 3) payments made for travel, tuition, fees and other necessary 

training expenses (5 C.F.R., section 410.406); and 4) evaluations of the results of training and 

how well agency training activities met short and long-range needs (5 C.F.R., section 410.602). 
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Audit Results Section Final Audit Report No 00-01 

In addition to the requirement imposed on the agency of maintaining an adequate record on 

agency training activities, the U.S. Office of Management and Budget (OMB) in Circular A-123, 

Management Accountability and Control, states: 

“Agencies and individual Federal managers must take systematic and proactive 

measures to (i) develop and implement appropriate, cost-effective management 

controls for results-oriented management; (ii) assess the adequacy of management 

controls in Federal programs and operations; (iii) identify needed improvements; (iv) 

take corresponding corrective action; and (v) report annually on management 

controls. OMB Circular A-123 defines management controls as “the organization, 

policies, and procedures used to reasonably ensure that (i) programs achieve their 

intended results; (ii) resources are used consistent with agency mission; (iii) 

programs and resources are protected from waste, fraud, and mismanagement; (iv) 

laws and regulations are followed; and (v) reliable and timely information is 

obtained, maintained, reported and used for decision making.” 

According to OMB Circular A-123, a subset of management controls are the following four 

internal controls: 

1. Delegation of Authority and Organization 

2. Separation of Duties and Supervision 

3. Access to and Accountability for Resources, to include that custody and use of 

resources should be assigned and maintained. 

4. Recording and Documentation - the documentation for transactions, management 

controls, and other significant events must be clear and readily available for 

examination. 

The following explicit example of an effective management control is contained in OMB 

Circular A-123: “the management control standard of organization would align staff and 

authority with the program responsibilities.” Conversely, our audit revealed that because the 

FEC has not developed written policy and procedures for the process to procure vendor training 

services, no management control standard of organization has been established or documented. 

Consequently, as described below, this prevents proper alignment of staff authority with official 

responsibilities. 

Written Policy and Procedures Needed to Establish Control 

The FEC Office of Personnel is a conduit for connecting the administration of the agency’s 

training programs with administrative guidance issued by the U.S. Office of Personnel 

Management, as well as other Federal entities. To carry out their responsibilities, management 

staff in the FEC Office of Personnel must have access to information on agency training 

activities. Over time, the function of training agency staff has evolved to become solely the 

responsibility of the division/office manager. Hence, justification for training is often not 

included in a training request. This was not consistent with training procedures experienced by 
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Audit Results Section Final Audit Report No 00-01 

the new personnel staff while working at other Federal agencies. Without documented policy 

and procedures, misunderstanding of program responsibilities between parties with overlapping 

authority can occur. 

The only written provisions identified during our audit, relating to policy and procedures for 

agency staff requesting vendor training services, reside within Article 24 of the Labor 

Management Agreement between the FEC and the National Treasury Employees Union (see 

Appendix D). While the Labor Management Agreement may provide equality to union 

members in the application of agency practices, it is not an adequate substitute for ensuring that a 

program adheres to Federal laws, regulations, and directives. 

As mentioned earlier in the BACKGROUND section of this report, a Senate Subcommittee 

asked the GAO to review selected Federal agencies’ training programs for Subcommittee 

hearings held on May 18, 2000. In preparation for its testimony, the GAO sent a data collection 

document to select Federal agencies with a list of policy issues to be evaluated. The following 

bullets identify policy issues targeted by the GAO: 

• 	 Who or what office within the agency is accountable for evaluating the agency’s training 

program? 

• How does the agency track the specific training completed by individual employees? 

• 	 How does the agency measure the extent to which training programs contribute to improved 

performance of agency mission and strategic goals? 

• 	 How does the agency determine the cost of providing training? What cost components are 

included? 

• How does the agency determine its training budget? 

• 	 How does the agency ensure that sufficient training slots are available to meet employees’ 

needs? 

• Does the agency require that staff meet certain training requirements? 

• 	 What criteria does the agency use in deciding whether to develop internal versus external 

sources of training? 

• What priorities has the agency established? 

• 	 How does the agency identify the skills needed by its employees to successfully perform the 

agency’s mission and strategic goals? 

• 	 How does the agency measure the extent to which its employees have the skills identified as 

necessary? 

• 	 How does the agency plan to use training to address any gaps between needed and existing 

levels of employees’ skills? 

In addition to the issues listed by the GAO, to aid management in developing written policy and 

procedures; throughout this report we will be looking at the agency’s process to acquire vendor 

training services, identify program shortcomings, and offer our recommendations for 

improvement. 
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Audit Results Section Final Audit Report No 00-01 

Without documented administrative policy and procedures, front-line managers cannot properly 

administer or monitor program operations. Our audit provided strong evidence demonstrating 

the adverse effect that an absence of administrative guidance has on agency operations. For 

example, during our detailed examination of staff training records we found the following: 

• 	 When we were able to confirm changes were made to an original training request, 

documentation detailing the change was consistently missing from agency-wide training 

files. Without a complete record of all related transactions affecting each individual 

training request, funds can be disbursed for training services not received. For example, 

if training is canceled after being requested; this event needs to be recorded and processed 

expeditiously to the Finance Office. 

• 	 The agency appears to have purchased training at substantially higher prices than rates 

charged by other vendors providing similar training. Two instances were of particular 

significance: 

⇒	 The first instance involved paying $1,145 for one member of the agency to attend 

training entitled, The Grammar Course. Ironically, during the year the same 

division purchased similar training for staff at a much lower rate. For example, for 

courses entitled Professional’s Grammar Review and Grammar Skills for Federal 

Employees, the cost of training was $139 and $295, respectively. 

⇒	 The second instance involved paying $8,900 for one member of the agency to 

attend approximately two weeks of training entitled, Senior Managers in 

Government. 

While cost is not the sole determining factor in selecting training, the lack of 

administrative guidance may cause a higher expenditure of funds than is necessary. 

We believe the first priority should be for the FEC to establish and document program policy and 

procedures. OMB Circular A-123, Management Accountability and Control, requires Federal 

agencies to implement management controls to ensure reliable and timely program information is 

obtained, maintained, reported and used for decision making. In addition, OMB Circular A-123 

requires that the documentation for management controls, and other significant events must be 

clear and readily available for examination. 

Audit Recommendation No 1: We recommend the FEC develop written policies and 

procedures that establish and document effective management controls for the procurement of 

vendor training services consistent with OMB Circular A-123. 

Management’s Comments to Audit Recommendation No. 1: “We concur. The improvement 

in the procurement of vendor training has begun. Since April 1, 2000, the Office of Personnel 

has required that all requests for vendor training be submitted on a SF-182, and since October 

1, 1999, the Office of Personnel has maintained a file, by office, of each employee’s training. In 
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Audit Results Section Final Audit Report No 00-01 

addition, the Office of Personnel will draft policies and procedures for the procurement of 

vendor training, establishing effective management controls in conformance with the 

requirements of OMB Circular A-123. The procedures also will conform to the negotiated 

policies established through the collective bargaining process with the National Treasury 

Employee Union. The Office of Personnel plans to implement the full set of policies and 

procedures in October 2000.” 

OIG Response to Management’s Comments on Audit Recommendation No. 1: The agency’s 

completed and planned actions are responsive to the audit issues identified. The planned actions, 

when fully implemented, should satisfy the intent of the audit recommendation. Furthermore, the 

milestone date provided for implementing corrective action, appears to be reasonable. 

The Transaction Cycle for Requesting Vendor Training Services 

The procurement of vendor training services at the FEC is comprised of a set of operating 

practices which seem to have simply evolved over time without the aid of documented guidance. 

From agency staff we interviewed during our audit, there is unanimous agreement that the current 

process for submitting and approving staff requests for vendor training services is a cumbersome 

paper intensive process, which is extremely costly especially in terms of unnecessary expenditure 

in staff time. Even so, the same ineffective and inefficient procedures continue to be followed in 

the context of applying “past practice” to the request process. 

The typical flow of information and documentation for requesting vendor training services is 

depicted in Exhibit No. 3, on page 11. Starting at the bottom left hand corner of the chart, an 

individual submits a request for training to the division/office manager. If the request is 

approved, the division/office will prepare and forward a written training request to the FEC 

Office of Personnel. At the Office of Personnel a personnel specialist will transfer the 

information received in the original training request into an electronic version of a Standard 

Form - 182 (see Appendix E). The SF-182 was developed by the U.S. Office of Personnel 

Management to capture all the necessary information for the request, authorization, agreement, 

and certification of staff training. The electronic version of the SF-182 is maintained in a 

computer software program at the FEC, which can be accessed using the agency’s computer 

network. After completing the SF-182, the Office of Personnel will send it to the originating 

division/office for review and approval. 
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Audit Results Section Final Audit Report No 00-01

Exhibit No. 3

FEC Staff Member

$ $

Office of Planning and Management

FEC Office of Personnel

Finance Office

Overview of Current Transaction Cycle

for Requesting Vendor Training Services

Approval of Budgeted

Funds

Copy of Form SF - 182

Procurement

Number

Forward

Procurement

Documentation

SF-182

FEC Administration

Training Request

Division/Office

Manager

Register Staff

for Training

Vendor Training

Vendor Services 

Certified as 

Received 

Notify Staff 

Invoice 

Original Training 

Request 

Training 

Approved 

Source: Office of Inspector General / Federal Election Commission 
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Audit Results Section Final Audit Report No 00-01 

When the signed SF-182 returns from the division/office, the Office of Personnel submits the 

original copy to the Director, Planning and Management. The role of the Director is to determine 

whether the division/office has enough funds remaining in their training budget to acquire the 

requested training. Provided the funds are available the Director, Planning and Management 

initials the SF-182 and returns it to the Office of Personnel for further processing. 

The Office of Personnel next sends the SF-182 to the Office of Administration, so funds can be 

committed from agency appropriations to pay for the requested training. The Administrative 

Officer assigns a sequential purchase order number and enters it onto the SF-182, retaining a 

copy of the form for the file. The Office of Administration returns the original SF-182 to the 

Office of Personnel and sends a copy to the Finance Office for obligation of agency funds. Upon 

receiving the purchase order number, the administrative specialist in the Office of Personnel will 

contact the vendor to register the employee, and also notify the appropriate division/office 

confirming the reservation for training. 

Uniform Processing Procedures Need to be Established 

Based on our examination of agency training records, we found that not all training transactions 

requesting vendor services are being routed uniformly throughout the agency. For fiscal year 

1999, the FEC Office of Administration committed a total of $216,679 for vendor training 

services. Records on file for those same services at the division/office level only showed agency 

staff requesting a total of $192,166. Furthermore, records for the same services over the same 

period at the Office of Personnel only totaled $93,768. Conspicuously absent from the training 

file maintained by the Office of Personnel were records relating to training for groups of staff. A 

training request may be a transaction requesting training for only one employee, or it may be a 

single request for training a group of thirty or more staff in one particular subject matter. 

According to our audit, a total of $117,011 was committed by the Office of Administration to 

procure group training using outside vendor services. From this total, we calculated that $98,019 

or approximately 84 percent, was missing from the training records on file in the FEC Office of 

Personnel. 

To carry out their official duties, staff responsible for training activities must have access to 

reliable program information. As previously stated, OMB Circular A-123, requires Federal 

agencies to implement management controls to ensure reliable and timely program information is 

obtained, maintained, reported and used for decision making. 

Audit Recommendation No. 2: We recommend that the FEC design and implement 

management controls to ensure that each training request is uniformly processed through the 

agency. 

Management’s Comments to Audit Recommendation No. 2: “We concur. The policies and 

procedures for the procurement of vendor training described in our response to 

Recommendation 1 will establish a uniform process so that all training requests are handled in 

the same manner.” 
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Audit Results Section Final Audit Report No 00-01 

OIG Response to Management’s Comments on Audit Recommendation No. 2: The agency’s 

planned actions are responsive to the audit issues identified, and when fully implemented, should 

satisfy the intent of the audit recommendation. 

The following bar chart summarizes the results of our audit findings relating to funds requested 

and committed for vendor training services for fiscal year 1999. In addition, the fourth and fifth 

columns report funds obligated and expended, respectively. Agency financial reports dated 

March 31, 2000 showed total funds obligated for vendor training services as $217,088 and total 

funds expended as $207,957. At the time of this audit report, not all vendor invoices for fiscal 

year 1999 training services had been received by the Finance Office. When these outstanding 

invoices are processed, and the accounting system is closed out for the period, funds obligated 

should agree with funds expended. 

Exhibit No. 4: 

$217,088

$207,957

$93,768

$216,679

$192,166

$0

$50,000

$100,000

$150,000

$200,000

$250,000

Personnel FileCommittedDivisions' FileObligatedExpended

Source: Office of Inspector General / Federal Election Commission 

Standard Form Needed For Initiating the Request 

There is no standard form used at the division/office level to initiate a request for vendor training 

services. Consequently, the initial training request is generated in many different formats, often 

lacking critical information needed to complete the processing of the training transaction. To 

compensate for these shortcomings, as described earlier, a practice began in the Office of 

Personnel to copy the information from the original training request onto a SF-182. The Office 

of Personnel will contact the division/office regarding any missing information and after 

completing the SF-182, send it to the originating division/office for review and approval. 
14 

Audit Results Section Final Audit Report No 00-01 

Through past practice, staff in the division/office know to return the paper copy SF-182 to the 

Office of Personnel for further processing. The Office of Personnel often does not keep a copy 

of the original training request; and just as often, the division/office does not retain a copy of the 

SF-182. 

One obvious way to improve the current process is to have each division/office submit a SF-182 

when requesting vendor training services. Information could be initially entered onto the 

computerized version of the SF-182; a paper copy could be printed, approved, and submitted to 

the Office of Personnel. This procedure would immediately improve the current process by: 1) 

ensuring all information necessary to process the training transaction is entered before initially 

submitting the request, 2) reducing unnecessary burden on staff in the Office of Personnel, 3) 

eliminating the unnecessary practice of returning the paper copy SF-182 to the originating office, 

4) eliminating retention of different versions of the same request for training, and 5) speed up the 

entire training request process, while at the same time reducing waste. 

The current process to initiate a request for vendor training services at the FEC does not adhere 

to Federal policy statements for minimizing waste in government programs. For instance, OMB 

Circular A-123 states: 

“The proper stewardship of Federal resources is a fundamental responsibility of 

agency managers and staff. Federal employees must ensure that government 

resources are used efficiently and effectively to achieve intended program results. 

Resources must be used consistent with agency mission, in compliance with law and 

regulations, and with minimal potential for waste, fraud, and mismanagement.” 

Audit Recommendation No. 3: We recommend the division/office use only the SF-182 for 

generating a request to the Office of Personnel for vendor training services. 

Management’s Comments to Audit Recommendation No. 3: “We concur, and this 

recommendation has been implemented. Since April 1, 2000, the Office of Personnel has 

required that all requests for vendor training be submitted on a SF-182. Requests for training 

submitted in any other format are returned unprocessed, and the Office of Personnel no longer 

prepares SF-182s for other offices. We see no need to accept only computer-generated SF-182s. 

Any properly completed, legible SF-182 is acceptable and will be processed. The policies and 

procedures for the procurement of vendor training described in our response to 

Recommendation 1 will require the use of the SF-182 for all training requests.” 

OIG Response to Management’s Comments on Audit Recommendation No. 3: The agency’s 

reported actions are responsive to the audit issues identified. Based on a subsequent review of 

training records on file in the Personnel Office, this audit recommendation is considered closed. 
15 

Audit Results Section Final Audit Report No 00-01 

A Complete Record of Training Activities Needed 

As stated previously, Title 5 of the CFR, section 410.311 requires Federal agencies to maintain a 

record of “training activities funded and individual staff trained.” However, the FEC does not 

maintain a record of all agency staff attending training. This was especially evident when a 

division/office would request that vendor services be purchased so that a large group of staff 

could attend a training event. As previously explained, a training request may be a transaction 

requesting training for only one employee, or it may be a single request for training a group of 

thirty or more staff in one particular subject. Although, the anticipated cost of the vendor 

services might be included on the training request to indicate the maximum number of staff 

allowed to attend the training; according to our audit, in most instances the agency had no record 

of who actually went to the group training exercise. 

Audit Recommendation No. 4: We recommend the FEC establish management controls 

ensuring that a complete record is maintained of all staff attending vendor training 

services sponsored by the agency. 

Management’s Comments to Audit Recommendation No. 4: “We concur, and this 

recommendation has been implemented. Since October 1, 1999, the Office of Personnel 

has maintained a file, by office, of each employee’s training, and the official record of 

training will be maintained by fiscal year by the Office of Personnel. The policies and 

procedures for the procurement of vendor training described in our response to 

Recommendation 1 will require all participants attending training, individual or group, 

to have a record of their training documented using the SF-182 maintained in the Office 

of Personnel.” 

OIG Response to Management’s Comments on Audit Recommendation No. 4: The agency’s 

reported actions are responsive to the audit issues identified. Based on a subsequent review of 

training records on file in the Personnel Office, this audit recommendation is considered closed. 

Stronger Controls Needed For Certifying Training Services Received 

During our examination of records on file in the FEC Finance Office, we came across 

documentation showing a payment made for vendor training services before notice was received 

that the employee initially requesting the training contacted the vendor and canceled. Following 

up on this issue, we identified a management control that should have detected this condition 

prior to payment being made. After training is received, but before payment is made, the Finance 

Office sends a FEC Form 10-14 to staff attending vendor training (see Appendix F). This 

standard form was developed by the FEC to serve the function of a receiving report. The form is 

designed to be signed to certify that training services were actually received, a debt has been 
16 

Audit Results Section Final Audit Report No 00-01 

incurred, and payment should be approved. After being signed, the FEC Form 10-14 is sent back 

to the Finance Office and attached to the vendor invoice. 

During our audit, we found no agency directive which required the individual actually attending 

the training to certify that training services were received. Regarding the particular incident cited 

above, a special assistant signed the FEC Form 10-14 certifying that training was received which 

released the payment. Our examination of training records showed that out of 171 vendor 

invoices on file in the Finance Office, 167 invoices were approved for payment. Although all 

167 disbursements were supported with a signed FEC Form 10-14; only 23 forms, or 

approximately 14 percent were signed by the individual actually attending the training. 

Consequently, in one of the few instances where we were able to establish that a management 

control existed and was applied to every record in the file when applicable, the control was found 

to be ineffective. As stated earlier, according to OMB Circular A-123, Management 

Accountability and Control, the third objective for establishing effective management controls is 

to ensure that policies and procedures protect programs and resources from “waste, fraud, and 

mismanagement.” If the staff attending agency training were required to sign a form certifying 

that training services were received; not only would it aid in preventing inappropriate payment to 

vendors, but also attest to the fact that the individual actually attended the training. Without a 

control of this type, it would be difficult to establish evidence of an action committed in error 

versus an act of program fraud. 

Audit Recommendation No. 5: We recommend the FEC require all staff attending training to 

sign a form certifying that the vendor training services have been received. 

Management’s Comments to Audit Recommendation No. 5: “We concur, and this 

recommendation has been implemented. As of April 1, 2000, the Personnel Office has required 

employees attending training to sign the original SF-182 after they have attended the training in 

order to certify their attendance and completion of the training. This requirement will be 

incorporated in the policies and procedures for the procurement of vendor training described in 

our response to Recommendation 1. We, however, will continue to require that all receiving 

reports, FEC Form 10-14, for training be signed by designated staff authorized to approve 

payments.” 

OIG Response to Management’s Comments on Audit Recommendation No. 5: The agency’s 

reported actions are responsive to the audit issues identified. The OIG would like to reemphasize 

the importance of communication between the management official who signs the receiving 

report: FEC Form 10-14, with the employee attending the training. Specifically, it is important 

for the employee to confirm in writing to the authorizing official (by signing the SF-182 after 

completing the training) that in fact the vendor services were received. Based on a subsequent 

review of training records on file in the Personnel Office, this audit recommendation is 

considered closed. 
17 

Audit Results Section Final Audit Report No 00-01 

Travel and Related Training Expense Need to be Tracked 

During our audit, we were also monitoring the accuracy and completeness of other financial 

information required to be maintained by Federal regulations. As previously stated, Title 5 of the 

CFR section 410, requires a record of payments made for travel, tuition, fees and other necessary 

training expenses. 

Based on agency documentation, the FEC could not identify all travel and related training 

expenses as required by Federal regulations. We asked the agency to identify travel and related 

expenses associated with staff attending vendor training activities for fiscal year 1999. The 

agency provided a report listing funds disbursed for travel expense which proved to be 

incomplete. For example, our audit found that no travel expense was listed on the agency’s 

report for staff attending vendor training in the following major cities: San Francisco, New 

Orleans, Chicago, San Antonio, and Tampa. 

At the FEC, all travel related expense is recorded and reported on a FEC Form 10-5, the Official 

Travel Authorization (see Appendix G). This form is completed by staff when traveling outside 

the local commuting area on official duties, including attending approved training. For financial 

accounting purposes, travel expense is identified using a unique and distinct account 

classification code different from the account classification code used to identify staff training 

activities. Furthermore, purchase order numbers assigned to travel authorization requests also 

use a unique and distinct alpha/numeric code. Consequently, there appears to be no primary 

identifier to tie travel and other training expense with a related request for vendor training. 

Although space is provided on the SF-182 for estimating the entire cost of training, including 

travel and miscellaneous expense; that box is not currently used at the FEC. 

Audit Recommendation No. 6: We recommend the FEC include all cost of training on the 

request for training (SF-182), including related expenses estimated and reported on the travel 

authorization form. 

Management’s Comments to Audit Recommendation No. 6: “We do not object to this 

recommendation. The policies and procedures for the procurement of vendor training described 

in our response to Recommendation 1 will require that the estimated cost of travel, for out-oftown training, be included on the SF-182. The actual cost of training will not be included on the 

SF-182. We note that 5 CFR 410.406 states that “agencies shall retain in such form and 

manner as the agency head considers appropriate, a record of payments made for travel, tuition, 

fees and other necessary training expenses for a reasonable period of time". It does not appear 

that Section 410 requires that training and travel expenses be linked. In conformance with OMB 

Directive A-11, the directive that establishes federal budgeting and reporting standards, we 

record and track training and travel expenses in their separately defined object classes. Thus, 

while we do not object to this recommendation, we are not aware of a requirement that training 

and travel expenses be linked for each training course.” 

OIG Response to Management’s Comments on Audit Recommendation No. 6: The primary 

intent of this audit recommendation is to ensure an audit trail exists to identify all training related 
18 

Audit Results Section Final Audit Report No 00-01 

expense. While the agency’s planned actions are responsive to the audit issue, to fully satisfy the 

intent of the audit recommendation; the agency should in fact be capable of linking travel and 

related expenses with the corresponding training course. This type of internal control would 

ensure that the program is in alignment with guidelines established in OMB Circular A-123, 

which requires Federal agencies to implement management controls to ensure reliable program 

information is reported. 

The Processing of Information Should be Computerized 

While the discussion thus far has addressed improvement in the current paper processing system, 

we believe that the long term solution is in the design and implementation of a computer 

information system to store agency records relating to the procurement of vendor training 

services. The FEC has developed and implemented a computerized planning and budgeting 

system driven by program based workloads and activity data; however, agency training records 

are not maintained as part of that system. 

The policy section of OMB Circular A-130, Management of Federal Information Resources, 

directs Federal agencies to plan in an integrated manner for managing information throughout its 

life cycle. Circular A-130 states that agencies shall record, preserve, and make accessible 

sufficient information to ensure the management and accountability of agency programs, and to 

protect the legal and financial rights of the Federal Government; and incorporate records 

management and archival functions into the design, development, and implementation of 

information systems. Furthermore, OMB directs Federal agencies to use electronic collection 

techniques where such techniques reduce burden on the public, increase efficiency of government 

programs, reduce costs to the government and the public, and/or provide better service to the 

public. 

The FEC could substantially increase the efficiency of processing agency information relating to 

the procurement of vendor training services by using computer technology already existing 

within the agency. The FEC has acquired a network based version of a computer software 

application, referred to as FormFlow. This software allows the computer user to enter data into 

an electronic copy of any standard form stored within the application. For example, at the FEC 

one of the standard forms stored on the FormFlow application is a copy of the SF-182, developed 

by the U.S. Office of Personnel Management for requesting training services. The electronic 

version of the form is a template, that when attached to a computer database allows information 

entered onto the form to be saved to a central repository. Storing all the vendor training records 

in one computer database would allow for easy access to information and ensure that an accurate 

repository of data is available for administrators making training related decisions and for 

reporting on program results. 

In addition, the FormFlow software has the capability to send electronic copies of the SF-182 

across the internal computer network. If this capability was combined with advanced digital 

signature technology, transferring the training request throughout the agency would become 

simply a matter of pushing a button on the computer keyboard. An electronic signature is a data 

authentication process which provides assurance that data associated with the signature has not 
19 

Audit Results Section Final Audit Report No 00-01 

been altered or changed. Electronic transfer of training records would substantially reduce 

unnecessary staff hours along with the risk currently associated with processing excessive 

amounts of paperwork. During our audit, we found that the single use of the FormFlow 

application, as applied to activities for procurement of vendor training services, was limited to 

staff in the FEC Office of Personnel entering data into the computerized version of the SF-182, 

in order to replace the original paper training request. 

In our research for this audit, we obtained information regarding a computer system developed at 

another Federal agency for recording and tracking staff training activities. The FEC has the 

computer technology available to develop a system which could emulate the major attributes of 

that computer system, which include: 

• On-line entry of training requests by employees or others. 

• On-line approvals by supervisors, funding officials, human resources staff. 

• On-line transfer/commitment of funds. 

• On-line catalog of in-house courses. 

• On-line tracking of status of approvals. 

• On-line communication capability between all offices. 

• On-line certification of the status of course completion. 

• Hard copy reports and training requests. 

• 	 Interface with e-mail to provide automated messages to employees and approving officials 

that action is required, or that action has been taken. 

Audit Recommendation No. 7: We recommend the FEC develop and implement a computer 

information system to replace the paper based system of records currently maintained for 

requesting and acquiring vendor training services. 

Management’s Comments to Audit Recommendation No. 7: “We disagree. As discussed 

above, with an annual training budget of approximately $200,000, less than .6% of the annual 

Commission budget, and with no indication that automation of the training request process will 

create more efficiencies than the implementation of procedures incorporating IG Draft Report 

Recommendations 1 through 6, we do not believe that an automated vendor training request 

process would be cost effective. OMB Circular A-130 does not require federal agencies to 

automate all processes, and OMB Circular A-123 instructs agencies “to develop and implement 

appropriate, cost-effective management controls.” (emphasis added) 

The IG draft report provides an example of an agency that has implemented an 

automated system to record and track training activities. We understand that the agency is the 

National Science Foundation (NSF). NSF hired a contractor to develop a custom system to 

support an annual training budget of $1.4 million (FY 1999) for 1,150 FTE. While this 

expenditure may have been cost effective for the NSF with its large training budget and large 

staff, we believe the costs outweigh the benefits for the Commission with a $200,000 training 

budget and approximately 350 FTE. 
20 

Audit Results Section Final Audit Report No 00-01 

In addition, as described above, the Commission has a number of high priority IT 

projects that must be implemented. Because of this we cannot expend resources on the 

evaluation and development of a system of lesser priority. One of the pending projects is the 

implementation and conversion to new accounting software. After the conversion to the new 

software, we plan to incorporate, in stages, the automation of the procurement process.” 

OIG Response to Management’s Comments on Audit Recommendation No. 7: As stated, 

management does not believe that an automated vendor training request process would be cost 

effective. Management supports their position by citing the small percentage of the agency’s 

annual budget expended on training courses procured from outside vendors. One of the things 

management fails to take into account is that while those expenditures may be a small percentage 

of the overall budget, there is a substantial investment in staff resources in order to process 

training requests through the agency. This transaction flow is documented in detail in Exhibit 

No. 3 of our audit report. As shown, paper copies of training requests along with related 

documentation are transferred and kept on file in at least four different agency locations: the 

individual division/office, the Office of Personnel, the Office of Administration, and the Finance 

Office. Agency staff in each of these offices have a reoccurring need for the information 

provided on the paper forms used to request procurement of vendor training services. 

Consequently, maintaining the paper based transaction process consumes a significant amount of 

agency staff time, which could be put to better use provided a central repository of information 

was available upon demand. 

To further support their position in this regard, management takes an example used in our audit 

report discussion which describes an automated training request system successfully 

implemented at another Federal agency. Management reasons that because that Federal agency is 

three times larger than the FEC, implementation of an automated training request system may be 

cost effective for them; but not for a smaller agency, such as the FEC. We believe that this 

conclusion needs further analysis before being accepted. 

Management also identifies a number of information technology projects at the FEC with a 

higher priority than computerizing the process for agency staff to request vendor training 

services. While we acknowledge the importance of first implementing systems with a higher 

priority, we do not believe those efforts should mutually exclude the development of internal 

systems which increase the agency’s efficiency. As stated in the body of our audit finding, the 

FEC currently has the necessary computer technology to develop a central database, as well as 

the ability to transfer vendor training requests electronically through the agency. As such, not 

only would the conversion from paper forms to electronic medium be a net savings, but also in 

alignment with the initiative to transition to an electronic Federal government. The intent of that 

government-wide transformation is to ensure that automatic data processing and other 

information technologies are acquired and used to improve service delivery and program 

management, increases productivity, improve the quality of decision making, reduces waste and 

fraud, and wherever practicable and appropriate, reduce the information processing burden for 

the Federal government and for persons who provide information to and for the Federal 

government. 
21 

Audit Results Section Final Audit Report No 00-01 

Considering the proposed development initiatives at the FEC, the audit recommendation to have 

the agency develop a computer-based repository of records for requesting procurement of vendor 

training services; is modified as follows: We recommend the FEC develop and implement a 

computer information system to replace the current paper based system of records for 

requesting and acquiring vendor training services, to coincide with the planned automation 

of the agency’s procurement process. 

Summary 

During our audit, we identified a substantial number of anomalies as a result of ineffective and 

inefficient controls governing the process for procurement of vendor training services. If the 

FEC would design formal administrative policies and procedures, as well as adopt our other audit 

recommendations, significant weaknesses in the current program could be eliminated. We also 

believe that during the design stage for developing policy and procedures, the FEC will identify 

other methods to streamline and improve the current process. Ultimately, the paper process 

should be reengineered to take advantage of existing agency resources and the efficiencies 

offered by advances in computer technology. 
22 

Final Audit Report 

Appendix A - Management Letter 
23 

Final Audit Report 

Appendix A - Management Letter 
24 

Final Audit Report 

Appendix A - Management Letter 
25 

Final Audit Report 

Appendix A - Management Letter 
26 

Final Audit Report 

Appendix B - Management’s Comments 
27 

Final Audit Report 

Appendix B - Management’s Comments 
28 

Final Audit Report 

Appendix B - Management’s Comments 
29 

Final Audit Report 

Appendix B - Management’s Comments 
30 

Final Audit Report 

Appendix B - Management’s Comments 
31 

Final Audit Report 

Appendix C - OIG Response 

OIG Response To Management’s Comments 

on the Audit Report Findings and Recommendations 

Agency management agreed with six of the seven findings and related recommendations contained in our 

audit report (see Appendix A for agency comments). Management states that three of the audit 

recommendations have already have been implemented. In addition, management in their written 

comments recognizes that “the implementation of Commission-wide procedures for the procurement of 

training services will streamline the process and will result in the maintenance of more complete 

training records.” We likewise believe many of the identified systemic weaknesses in agency controls 

could be eliminated with the design and development of formal policies, along with the enforcement of 

agency-wide standard operating procedures. 

However, management chose to disagree with one of our audit recommendations. In audit 

recommendation number seven, we recommended the agency develop and implement a computer 

information system to replace the current paper based system for processing transactions to procure 

vendor training services. Management’s opposition to this audit recommendation seems to be two fold: 

First, management believes the development of an automated training request process would not be cost 

effective. Second, management takes the position that the agency cannot expend resources on the 

evaluation and implementation of a system with “lessor priority,” when more important computer 

information technology projects await development and implementation. 

In their response, management states: “we do not believe that an automated vendor training request 

process would be cost effective.” They support their position by citing the small percentage of the 

agency’s annual budget expended on training courses acquired from outside vendors. However, 

management fails to take into account that while those expenditures may be a small percentage of the 

overall budget, there is a substantial investment in staff resources in order to process training requests 

through the agency. This transaction flow is documented in detail in Exhibit No. 3 of our audit report. 

As shown, paper copies of training requests along with related documentation are transferred and kept on 

file in at least four different agency locations: the individual division/office, the Office of Personnel, the 

Office of Administration, and the Finance Office. Agency staff in each of these offices have a 

reoccurring need for the information provided on the paper forms used to request procurement of vendor 

training services. Consequently, maintaining the paper based transaction process consumes a significant 

amount of agency staff time, which could be put to better use provided a central repository of information 

was available upon demand. 

To further support their position in this regard, management uses an example taken from our audit report 

which illustrates an automated training request system successfully implemented at another Federal 

agency. Management reasons that because that Federal agency is three times larger than the FEC, 

implementation of an automated training request system may be cost effective for them; but not for a 

smaller agency, such as the FEC. We believe this conclusion needs further analysis before being 

accepted. 
32 

Final Audit Report 

Appendix C - OIG Response 

Management also identifies a number of information technology projects at the FEC with a higher 

priority than computerizing the process for agency staff to request vendor training services. While we 

acknowledge the importance of first implementing systems with a higher priority, we do not believe those 

efforts should mutually exclude the development of internal systems which increase the agency’s 

efficiency. As stated in the body of our audit finding, the FEC currently has the necessary computer 

technology to develop a central database, as well as the ability to transfer vendor training requests 

electronically through the agency. As such, not only would the conversion from paper forms to 

electronic medium be a net savings, but also in alignment with the initiative to transition to an electronic 

Federal government. The intent of that government-wide transformation is to ensure that automatic data 

processing and other information technologies are acquired and used to improve service delivery and 

program management, increases productivity, improve the quality of decision making, reduces waste and 

fraud, and wherever practicable and appropriate, reduce the information processing burden for the 

Federal government and for persons who provide information to and for the Federal government. 

In their response, management describes the planned implementation and conversion to a new accounting 

software; after which, management plans to automate the agency’s procurement process. In light of these 

proposed internal development initiatives, our audit recommendation is modified as follows: We 

recommend the FEC develop and implement a computer information system to replace the current 

paper based system of records for requesting and acquiring vendor training services, to coincide 

with the planned automation of the agency’s procurement process. 
33 

Final Audit Report 

Appendix D - Labor Management Agreement 
34 

Final Audit Report 

Appendix D - Labor Management Agreement 
35 

Final Audit Report 

Appendix E - OPM SF-182 
36 

Final Audit Report 

Appendix F - FEC Form 10-14 
37 

Final Audit Report 

Appendix G - FEC Form 10-5