OFFICE OF INSPECTOR GENERAL 

TABLE OF CONTENTS 

DESCRIPTION PAGE 

Executive Summary 1 
 

Background 5 

Objectives, Scope and Methodology 12 

Employee Survey Results 15 
 

Audit Findings and Recommendations 

1. Personal Communication Device Policy and Procedures Need Improvement 17 

2. Personal Communication Device Program Monitoring 25 

3. Tracking and Managing Personal Communication Devices 35 

4. Fleet Vehicles and Fleet Charge Card Program Controls 42 

5. Fleet Vehicle Driver Qualification and Verification 47 

Conclusions 51 
 

Attachment 1: Summary of Audit Findings and Recommendations and 

 Management’s Response 52 

Attachment 2: 5 CFR§ 930 Subpart A - Motor Vehicle Operators 66 

i 
 

EXECUTIVE SUMMARY 

Internal controls of FEC programs continue to be the focus of the Federal Election 

Commission (FEC) Office of Inspector General (OIG) audit activities. Programs for 

managing assets at highest risk for abuse, such as personal communication devices (PCDs) 

(Blackberry devices and cellular telephones), fleet vehicles, and fleet charge cards require 

adequate control processes to ensure they are not subject to fraud, waste and abuse. In fact, 

the FEC has documented instances of employee abuse of these programs and the agency has 

sustained additional expenses because of those abuses. 

The Federal Managers’ Financial Integrity Act of 1982 (FMFIA) requires the Government 

Accountability Office (GAO) to issue standards for internal control in government. Agency 

management is responsible for complying with the Standards for Internal Control in the 

Federal Government issued by GAO (November 1999) by establishing and maintaining a 

positive attitude and culture of internal control, assessing program risk, designing internal 

control activities linked to program directives and policies, and documenting program 

activity and management’s review of the activity. In general, we found that improved 

internal controls are required for PCDs, fleet vehicles and fleet charge cards to ensure the 

programs are not subject to fraud, waste and abuse. Additional controls are also required to 

ensure the agency minimizes program costs, maximizes program objectives, and complies 

with federal regulations governing those programs. 

In the November 2009 Baseline magazine article, Minding Your Mobile Assets1

, Samuel 

Greengard describes a number of best practices to ensure organizations receive the most 

value from their mobile technology (PCD) investments. Mr. Greengard acknowledges that 

while “software applications can handle the mechanics of keeping track of devices, they do 

nothing to help an organization develop a coherent strategy for purchasing, issuing, and 

overseeing the technology and the way it will be used.” The article provides sound advice 

that on first glance seems like basic common sense, but after further consideration, reads as a 

checklist for the FEC personal communication device program assessment. Some of the 

basic guidance includes: 

•	 “Consolidate if you can” but also “consider more than one cellular service provider 

to meet needs of users with different devices”; 

•	 “Make sure that employees don’t have phones they don’t need and features they don’t 

use. For example, not every worker requires an unlimited dialing plan or multimedia 

messaging service (MMS)”; 

•	 Management needs to “understand organizational roles and usage patterns so that 

the organization does not overspend on devices, calling plans and data plans”; and 

•	 “Too often organizations set up systems and then neglect to re-examine them or make 

needed changes.” 

1

 Greengard, Samuel. “The Fusion of Business and Technology: Minding Your Mobile Assets.” Baseline 

November 2009: 23+. 

1 
 

Mr. Greengard’s advice can be applied to both public and private sector organizations. The 

key to applying the guidance effectively lays in adopting a philosophy of program 

management with one individual responsible for managing and monitoring program 

performance. The OIG’s PCD audit testing results described below and in the body of this 

report indicate that the Information Technology Division (ITD) only takes responsibility for 

asset purchases, distribution, and destruction, but does not research and evaluate alternate 

service providers, assess employee needs, or evaluate agency PCD device usage levels. As a 

result, this reduces the potential benefits to the agency and increases program costs. The 

strongest internal control for this program would be to assign responsibility and 

accountability for overall program management to one individual in a single business area. It 

is understood that other business areas such as the Contracting Office, as well as managers 

requesting devices for their employees, and all employees issued devices, play a role in 

effectively managing the program to minimize costs and maximize value. 

The OIG documented five (5) findings and made 36 recommendations to address internal 

control weaknesses for FEC PCDs, fleet vehicles, and fleet charge cards. A table listing the 

findings and recommendations is included as Attachment 1 on page 52 of this report. The 

following sections describe audit scope and testing results for the two programs. 

Audit Scope 

The FEC OIG conducted an audit of the controls over FEC property, to include personal 

communication devices (PCDs) (Blackberry devices and cellular telephones), FEC vehicles 

and fleet charge cards. Selection of this audit was based upon an OIG developed strategic 

audit plan for the agency and previously reported abuse of FEC property. The audit was 

performed in accordance with generally accepted government auditing standards. 

The scope of this audit included a review of Commission internal controls over FEC property 

from fiscal year (FY) 2007 to 2010. The specific audit activities included documenting and 

reviewing the adequacy of: 

•	 policies and procedures for managing the assets; 

•	 business processes used to manage the assets; and 

•	 management control activities used to detect and correct potential fraud, waste and 

abuse of the assets. 

Personal Communication Device Testing Results 

Due to the limited availability of electronic PCD data, detailed audit testing was conducted 

for the period May 2008 to August 2009. Detailed testing of FEC employees’ Blackberry 

use was conducted on a sample of 56 employees to determine whether the employees 

complied with FEC policies and procedures. The testing results showed that some 

employees use agency issued Blackberry devices for personal use. In addition, an OIG 

survey of 116 FEC employees issued PCDs as of December 2009 was conducted to: 

2 
•	 verify which device models were issued to FEC employees; 

•	 gain an understanding of FEC employee use of PCDs; and 

•	 determine whether FEC employees were adequately informed about the service 

plan/costs associated with their PCD. 

The survey response rate was 97 percent and employees provided candid comments and 

suggestions to maximize benefits and minimize the costs of agency issued PCDs. A 

summary of the employee survey results is included on page 15 of this report. 

Audit fieldwork was conducted between September 1, 2009 and January 22, 2010. The audit 

results revealed that for PCDs, the agency has two different policies with conflicting 

standards on employee personal use of the devices. Further, the policies are not followed nor 

enforced, and neither incorporates Internal Revenue Service regulations governing personal 

use of devices by employees and the potential fringe benefit tax implications. Also, program 

management roles and responsibilities are not clearly defined in the policies. In addition, 

program management does not periodically review the service plans offered by their current 

provider or conduct market research of other potential vendors to decrease program costs. 

Audit testing of the internal controls of PCDs also highlighted that a better assessment of 

employee business needs, and more active program management and monitoring could lead 

to significant financial savings for the agency. For the audit testing period May 2008 through 

August 2009, the following potential cost savings were identified: 

•	 Researching other Blackberry service providers and selecting a similar service plan from 

a competitor could have saved up to $52,698 in FY 2010 compared to projected service 

costs of the FEC’s current provider, AT&T. Converting to another provider would also 

allow the agency to receive mobile devices at no cost to the agency; 

•	 Converting Blackberry users with little or no voice use to data only plans could have 

saved $32,359, or 22 percent of the total program service costs, for the 16 month period 

reviewed; 

•	 Terminating service plans in a more timely manner for employees who leave the agency 

could have saved $8,614; 

•	 Providing International add-on plans only to employees who travel internationally and 

limiting the add-on service to only the periods of travel could have saved $6,329; and 

•	 Eliminating spare devices with active service plans could have saved $643. The FEC 

currently has two spare devices that cost the agency $158 per month. 

Testing also showed that the Information Technology Division (ITD) is not in compliance 

with Commission Bulletin 2006-04 for tracking PCDs. ITD does not maintain inventory 

records of the PCDs in the FEC’s Fixed Asset System (FAS) and FEC property bar codes are 

not assigned to mobile devices, as required. Instead, ITD maintains asset listings in an Excel 

spreadsheet and the OIG’s comparison of the various asset listings provided by ITD during 

the audit showed the listings were incomplete and required updates to reflect FEC’s current 

3 
PCD inventory. Based on the asset listings, it appears some devices are missing or not 

accurately reflected in the asset schedules. For more information on PCDs, refer to the 

background section of this report, page 5, and the detailed findings and recommendations 

beginning on page 17. 

Fleet Vehicles and Fleet Charge Cards Testing Results 

Audit testing also showed there are insufficient management controls in place to detect or 

prevent employee fraud, waste and abuse of agency fleet vehicles and fleet charge cards, 

despite known prior abuse by one or more FEC employees. Further, the FEC lacks sufficient 

controls to detect and correct mileage reporting errors by agency staff or billing errors by the 

General Services Administration (GSA) Fleet Services. The FEC lacks policies and 

procedures to ensure proper internal controls and compliance with federal regulations for 

operating government leased vehicles and the use of fleet charge cards. The FEC also does 

not have business processes or written guidance in place to ensure that FEC’s drivers of FEC 

vehicles are both qualified and authorized to operate those vehicles in accordance with 

federal regulations. As a result, the FEC is not compliant with federal regulations and is 

exposed to an increased risk of litigation if an employee deemed unqualified operates an FEC 

vehicle and is involved in an accident. For more information on fleet vehicles and charge 

cards, refer to the background section of this report, page 5, and the detailed findings and 

recommendations beginning on page 42. 

4 
 

BACKGROUND 

Personal Communication Devices 

Annual Service Costs 

Beginning in fiscal year (FY) 2003, the agency began transitioning from standard cellular 

telephones and pagers to Blackberry communication devices which allowed employees to 

make and receive telephone calls as well as access their FEC e-mail. Since then, annual 

program service costs have increased from $29,017 in FY 2003 to $116,654 in FY 2009, an 

increase of more than 300 percent. The annual cost increases are attributed to the higher cost 

of service plans for Blackberry devices compared with standard cellular phones or pagers, as 

well as an increase in the number of employees issued Blackberry devices. For example, in 

FY 2006, FEC’s monthly invoices showed service charges for an average of 82 devices, 

compared to an average of 124 devices in FY 2009. The typical monthly cost for a 

Blackberry with voice and data was $43.252 in FY 2006, compared to $77.49 in FY 2009. 

The table below illustrates the actual annual service costs for each fiscal year. 

Annual Service Costs 

$-

$20,000 

$40,000 

$60,000 

$80,000 

$100,000 

$120,000 

2003 2004 2005 2006 2007 2008 2009 

Annual Service 

Costs 

For FY 2010, the FEC has obligated $152,000 to cover the monthly service fees and asset 

purchases of PCDs. The monthly cost of service plans for FY 2010 is $90 and some devices 

have service plans with special features that increase service costs to more than $102 per 

month. 

2

 Values are net of government discounts. 

5 
Annual Asset Costs 

In FY 2004, the FEC purchased and distributed Blackberry models 6280, 7280 and 7290. In 

FY 2005, the agency continued to transition employees with pagers to Blackberry devices. 

In February 2006, the agency purchased five (5) Palm Treos and associated monthly service 

plans for use by ITD staff. The Palm Treos were purchased in case Research in Motion 

(RIM), the maker of Blackberry mobile devices, lost a lawsuit on patent infringement and 

was forced to suspend service. The lawsuit, which was initiated in 2004, reached a tentative 

settlement agreement in March 2005 and final settlement on March 3, 2006. After the 

lawsuit was settled, another ten (10) Palm Treo devices were purchased for ITD staff 

member use and one of the ten devices was reserved as a spare. The Palm Treos were used 

by ITD staff members from February 2006 to February 2007. Total asset and service costs 

for the Palm Treo plan was $13,795. 

In FY 2007, the FEC began upgrading older devices with Blackberry 8100 and 8700c device 

models. Many of the 8700c models were received free of charge from AT&T under service 

plan upgrade options. In FY 2008, the agency continued to purchase devices for new users 

as well as mobile broadband air cards for laptop computers. The air cards allow select 

employees to connect their laptops to the internet when traveling within the AT&T network. 

In FY 2009, the agency received 28 Blackberry devices free of charge under service plan 

upgrades and purchased two (2) additional air cards. The effort to research and obtain 

devices free, under upgrade offers, saved the agency thousands of dollars in FY 2009. The 

table below shows the total annual spending for Blackberry and Palm devices, as well as air 

cards for fiscal years 2003 through 2009. 

Annual Asset Purchases 

$-

$2,000 

$4,000 

$6,000 

$8,000 

$10,000 

$12,000 

$14,000 

2003 2004 2005 2006 2007 2008 2009 

Assets 

Purchases 

According to ITD’s Blackberry asset listings, eleven (11) devices have been lost, four (4) 

were stolen, and forty-nine (49) have been destroyed. The FEC currently holds seventeen 

(17) devices as spares available to be issued to new users or as replacements for devices that 

break. There are fifty-two (52) devices held in storage, most of which ITD considers broken 

or obsolete, but many are still serviceable. 

6 
 

Program Management 

Two policies govern personal communication device management at the FEC. Commission 

Bulletin 2001-11A, Policies and Procedures for Issuance of Cell Phones and Pagers, updated 

March 20, 2002, details the policies and procedures for employee use of cellular telephones 

and pagers and FEC Policy 58-4.4, Personal Communication Devices Security Policy, 

updated July 11, 2008, which applies to all personal communication devices “to include 

personal digital assistants (PDA), cellular telephones, laptop wireless cards and pagers.” 

During the audit the OIG discussed the policy disparity with management and according to 

ITD staff members, Commission Bulletin 2001-11A has been superseded by FEC Policy 58-

4.4. Policy 58-4.4 restricts the issuance of PCDs “to personnel who need to conduct 

immediate, critical FEC business” taking into account that “distribution of the various 

technological devices must be limited to persons for whom the productivity gained is 

appropriate in relation to the costs incurred.” Section 2(b) of the policy identifies the 

following offices and personnel groups as the “core group”3

 users who may obtain personal 

communication devices or authorize their staff to receive devices: 

• Commissioners, 

• Commission Office staff, 

• Staff Director, 

• Deputy Staff Directors, 

• Office of Inspector General, 

• Office of the Chief Financial Officer, 

• General Counsel, and 

• Associate General Counsels. 

According to ITD’s policy, 

“All requests to obtain a FEC PCD from staff other than those specified in section 

2(a) must be submitted in writing to the appropriate Deputy Staff Director, or 

Associate General Counsel for approval. Employees of the Offices of Inspector 

General and Chief Financial Officer should submit their request to their appropriate 

manager. Any request must contain justification demonstrating how a FEC PCD is 

essential to performance of the requestor’s duties. Approved requests are to be 

submitted to the Chief Information Officer (CIO) for processing.” 

The actual business process observed during the audit involves a written PCD request sent to 

the Deputy Chief Information Officer for Operations by anyone identified as a core group 

user or an FEC supervisor. The requests that are sent to the Deputy Chief Information 

Officer do not always contain a business justification. Based on the request; the 

Management Assistant for the Configuration Management team updates the asset listing to 

reflect the employee’s name, as well as the model number and serial number of device 

3

 Program management has also used the term “base group” users when referring to this listing and makes a 

subtle distinction between base and core groups. Refer to Finding 1 on page 20 of this report. 

7 
assigned. The Management Assistant also updates the AT&T Premier on-line customer 

account records by inputting the employee’s name against the assigned telephone number. 

This process helps to ensure that the monthly review of AT&T invoices allows the 

Management Assistant to trace device usage and any overage charges to a specific employee. 

The device is then distributed to the employee by the Management Assistant. 

According to ITD, broken and obsolete PCD devices are destroyed locally by removing the 

subscriber identification module (SIM) card, breaking the asset with a hammer, and placing 

the broken pieces in a trash receptacle. 

Cingular/AT&T Service Plans 

The agency initially used Cingular as the mobile telephone service provider for standard 

cellular telephones and pagers. The FEC continued contracted services with Cingular when 

the agency transitioned to Blackberry devices in FY 2003. Other providers such as T-Mobile 

also offered Blackberry devices and service plans in 2003. AT&T and Cingular merged in 

October 2004; the agency continues to procure mobile telephone and data services from 

AT&T. 

When the FEC transitioned from the standard cellular telephones and pagers to Blackberry 

devices, progam management selected the Nation 450 plan. Under the plan, employees 

received 450 “anytime” minutes per month to be used between 6:00 am and 9:00 pm daily, 

unlimited nights and weekends, unlimited domestic messsaging and internet, and unlimited 

mobile to mobile minutes. In addition, the FEC purchased air cards with unlimited air card 

connectivity. If an employee used more than 450 minutes in a month (exlususive of nights 

and weekends use), the overage was charged at a maximum rate of $0.25 per minute. For 

each device, unused minutes were “rolled-over” to the next month and accrued for future use. 

Additional fees were charged for directory assistance ($1.79), roaming for areas with no 

Cingular/AT&T coverage, and texting ($0.20 per text). In April 2009, AT&T provided 

unlimited texting under the Nation 450 plan at no additional cost. 

In November 2009, the agency transitioned to new AT&T service plans, the GOV Nation 

Pooled plan 100 and 200. The GOV Nation Pooled plans reduced the number of minutes per 

device to either 100 or 200 minutes, but allowed the minutes for all devices to be pooled and 

shared among all users, totaling 12,900 shared minutes per month. The pooled minutes do 

not roll over at the end of each month for future use by employees. The GOV Nation Pooled 

plan provided either 100 or 200 anytime minutes per month, 5,000 minutes per user for 

nights and weekends, unlimited mobile to mobile, and unlimited data. Calls that exceed the 

pooled minutes for the agency in a month are charged at $0.25 per minute. The pooled plan 

did not include unlimited texting. The texting feature increases monthly charges by $20.00 

per user for unlimited texting. Immediately after changing to the pooled 100 and 200 plans, 

the FEC experienced unexpected service charges of $20 per user, per month, for texting. As 

a result, the agreement with AT&T was renegotiated and the agency converted all 100 

minute plans to the 200 minute plans in January 2010. This change now provides 23,800 

total pooled minutes per month while also providing unlimited texting. For the current GOV 

Nation Pooled plans and prior Nation 450 plan, the FEC has the ability to add or remove 

features and services. 

8 
Fleet Vehicles and Fuel Charge Cards 

In 2006, FEC maintained four government leased vehicles. During that time period, FEC 

Administrative Services Division (Admin) management was alerted to possible employee 

abuse of agency leased fleet vehicles. After conducting a review, program management 

determined an employee used agency vehicles for personal use. The employee subsequently 

resigned from the FEC. Two of the four leased vehicles were returned to General Services 

Administration (GSA) in October and November 2006, after management determined the 

vehicles were no longer needed. In addition, abuse of fleet charge cards was suspected but 

not proven because the abuse could not be directly associated with one or more individuals. 

The FEC currently leases two vehicles from GSA for official government use; a sedan 

primarily made available to the Office of General Counsel (OGC) investigators, and a van for 

Administrative Services use. The van is routinely used to make: 

•	 daily trips to various locations on Capitol Hill, such as the Senate and House of 

Representatives office buildings, Government Printing Office, Government 

Accountability Office, etc.; 

•	 twice monthly trips to the FEC’s contractor that supplies agency employee and 

contractor HSPD-12 security badges; 

•	 ad hoc trips to other federal locations such as the National Archives and Records 

Administration facilities in College Park and Suitland, Maryland; 

•	 trips to perform fleet vehicle maintenance and fueling; and 

•	 ad hoc trips to transport agency staff to local meetings and conferences. 

The sedan is available to the OGC investigators to conduct investigations or transport 

witnesses. When not used by the investigators, the sedan is made available to Admin 

Services staff to perform official FEC transportation duties. The table on the following page 

shows program costs and miles driven for FEC leased vehicles in the last five fiscal years. 

9 
Fleet Vehicle Program Data

AnnualProgramExpense MilesDriven

$13,187 $15,141

12,732 12,532

$6,475

$5,337 $5,187

2,888 2,443 3,220

2005 2006 2007 2008 2009

The agency returned one of four vehicles in September 2006. Another vehicle was returned November 2006. 

In FY 2005, the FEC was billed $1,562.26 by GSA for a transmission replacement on a 

vehicle. The cost of the transmission replacement was billed to the agency because the 

vehicle did not have transmission fluid levels adequately maintained. The FEC was also 

billed $3,439.75 in FY 2006 for vehicle repairs resulting from an automobile accident. The 

agency was billed for repair costs because the FEC employee was determined to be at fault4

. 

The repair costs are included in the annual program expenses reported in the table above. 

Returning the two vehicles in 2006 decreased total miles driven per year by approximately 75 

percent and reduced the annual program costs more than six thousand dollars per year, after 

reducing the two prior year’s annual costs for the additional accident and maintenance 

charges. 

GSA provides a fleet charge card for each vehicle leased. The charge card is used for: 

• fuel and routine maintenance, such as car washes and oil changes; 

• minor repairs and maintenance, such as wiper blades, flat tires, and alignments; and 

• major maintenance, such as brake replacement, engine, or transmission repair. 

Any maintenance or repairs over $100 require prior approval by GSA. Failure to receive 

approval may result in the agency being charged for the maintenance. Charges made on the 

fleet charge cards by FEC staff are paid directly by GSA. In turn, GSA recovers the costs of 

fleet vehicle fuel and maintenance through monthly lease charges to the agency. Fleet costs 

are based on a monthly fixed lease rate, plus fixed mileage rate times the miles driven per 

month. The monthly lease rate and mileage rates change annually. For FY 2010, the 

mileage rate decreased to 17 and 18.5 cents per mile and the monthly lease rates decreased 

from $233 to $224 (sedan) and $215 to $207 (van) per month. GSA also charges a fuel 

surcharge aimed at recovering the additional costs of fleet vehicles equipped for flexible 

 

4

 The federal government is self-insured with respect to automobile accident coverage. If a federal employee 

driving a government owned vehicle is involved in an accident and determined at fault, the cost of repairs is 

recovered from the agency. 

10 
 

fuels5

, and to adjust fleet costs during periods of fluctuating fuel prices. In periods of 

declining fuel prices, GSA does not impose a surcharge and may even provide fuel surcharge 

credits. The current fuel surcharge is a flat rate of $14 per month, per vehicle. FEC Admin 

Services staff provides GSA information on the miles driven each month for each vehicle, 

using the Dial-a-Mile telephone reporting system. Odometer readings for each vehicle are 

due by the 21st of each month so that invoices can be generated by GSA for payment. 

Because actual mileage data is required to generate the invoice, GSA bills agencies in 

arrears. For instance, the miles driven between September 22 and October 21 are included in 

the November monthly invoice. 

The FEC pays for fleet vehicle leases using the Intra-Governmental Payment and Collection 

System (IPAC). The IPAC system allows automatic electronic funds transfer between 

federal agencies. Payment is initiated by GSA Fleet Services by submitting an electronic 

invoice for payment to GSA Financial Services group, the FEC’s outsourced financial 

service provider. The invoice is submitted before mid-month and payment is made by 

journal entries and funds transferred between the FEC Treasury account and GSA Treasury 

account. The FEC Finance Office receives a paper invoice after the 21st of each month and 

provides the invoice to Admin Services for review and payment authorization, even though 

payment has already occurred. Any discrepancies in odometer reading or invoiced amounts 

must be corrected in a subsequent month, because payment is made to GSA prior to the FEC 

receiving the invoice. 

5

 Flexible fuel vehicles (FFVs) are designed to run on gasoline or a blend of up to 85% ethanol (E85). 

11 
 

 

OBJECTIVES, SCOPE AND METHODOLOGY 

The objectives of the audit of the Commission’s property management controls were to 

determine if the Federal Election Commission (FEC) has sufficient property management 

controls over the FEC’s: 1) personal communication devices (PCDs); 2) government leased 

vehicles; and 3) fleet charge cards. The scope of the audit included a review of the 

Commission’s internal controls over FEC property from fiscal year (FY) 2007 to 2010. The 

audit was performed in accordance with generally accepted government auditing standards. 

To accomplish the audit objectives, the OIG performed the following procedures: 

•	 Reviewed Commission Bulletins 2001-11A and 2004-06, and the Information 

Technology Division’s (ITD) Policy Number 58.4-4 regarding the policies and 

procedures for PCDs. Refer finding #1 on page 17, section Personal Communication 

Device Policies and Procedures Need Improvement. 

•	 Conducted interviews and held meetings with ITD program staff regarding PCDs in 

order to verify policies and procedures are consistently followed; document any 

program violations; ensure compliance with federal laws and regulations; gain an 

understanding of internal control procedures; and identify any internal control 

weaknesses. Refer findings #1, #2, and #3 relating to PCDs on pages 17, 25 and 35 

respectively. 

•	 Conducted telephone interviews with FEC’s AT&T service representative to gain an 

understanding of service plan details of FEC’s prior Nation 450 plan and current 

Government Pooled service plans. 

•	 Retrieved electronic billing information from the AT&T on-line Premier website to 

review detailed voice and data activity for FEC PCD users. However, due to the 

limited availability of electronic information, the OIG could only download the most 

recent 16 months of voice and data activity, May 2008 to August 2009. 

•	 Reviewed copies of FEC’s monthly AT&T summary invoices for the scope of the 

audit. Selected the summary invoices from May 2008 to August 2009 based on the 

available electronic data from AT&T and developed an Excel spreadsheet of all 

summary data to conduct detail testing. 

•	 Reviewed the detailed activity of 56 FEC PCD users to determine if the level of 

personal use of PCDs was in compliance with FEC’s policies and procedures. Refer 

finding #1 on page 23, section Personal Use & Internal Revenue Service Regulations. 

•	 Inquired with ITD staff if FEC adheres to Internal Revenue Service tax code 

regarding substantiation of personal use for cell phones provided by the agency to the 

12 


 

EMPLOYEE SURVEY RESULTS 

During the audit the OIG conducted an employee survey regarding Personnel 

Communication Devices (PCDs). The survey was provided to users who were issued a PCD 

based on agency records as of December 2009. The OIG also received an additional survey 

response from a PCD user who was not listed on agency records because their device was 

issued after December 2009. The purpose of the survey was to: 

•	 Identify all the devices currently issued to FEC employees; 

•	 gain an understanding of FEC employee use of mobile devices; and 

•	 determine whether FEC employees are adequately informed about the service plan 

associated with their FEC mobile device. 

The survey asked users to identify their name, mobile telephone number, device model (i.e. 

Blackberry 8700c, 8320 Curve, etc.), and all the features that they regularly use with their 

device (i.e. e-mail, voice, text messaging, etc.). The OIG added pictures of each mobile 

device next to their associated device model number and included instructions on how to 

locate the device model number on their mobile device. The users were also asked to 

identify if: a) they used their PCD; b) they believed the PCD is necessary to efficiently and 

effectively perform their FEC duties; and c) they were knowledgeable of the service plan 

details regarding their PCD. The survey also allowed users to provide additional comments 

on the survey form. The OIG received a 97 percent response rate from the PCD users. 

See the table below for the results of questions a, b, and c stated above. 

Survey Results 

PCD Users 

a) Employee does not use their FEC issued PCD 7 

b) Employee feels device is not necessary to efficiently and effectively perform FEC duties 10 

c) Employee is unaware of the service plan details 83 

When reviewing the responses to the survey questions, the OIG was able to gather additional 

information from the PCD users’ responses. For instance, when asked to identify their mobile 

telephone numbers, 10 PCD users could not provide their mobile number and some users 

provided responses such as: 

•	 “I really don’t know. I have never given that number to anyone. . . My supervisor 

contacts me on my personal cellphone when he needs to, which is what I prefer 

anyway.” 

15 
•	 “I was told not to use the phone part of the device and I was never given the phone 

number.” 

•	 “Rarely uses FEC device. Gives personal device number for office use, that is why 

does not know the FEC phone number assigned.” 

Also, when the PCD users identified their device model the OIG compared the PCD user 

responses to agency records and 20 PCD users’ device models were inaccurate. The OIG 

identified one active telephone account that was still assigned to a former employee who left 

the agency in October 2009. Another active telephone line was assigned to an employee who 

did not have an FEC issued PCD. However, the OIG conducted further analysis and noted 

the device was issued to another FEC employee. 

Additional Survey Information 

Through the additional comments provided by the PCD users on the survey, the OIG became 

aware of several user issues regarding PCDs. Three users indicated they would have liked to 

have been provided training on how to use their Blackberry device when the devices were 

issued. Users also wanted written details of the service plan such as limitations, features that 

incur additional costs, and any use prohibitions. ITD has purchased Quick Source for RIM 

Blackberry guides for Blackberry models 8700c and 8320 Curve. The guide gives detailed 

instructions on how to use the device along with all the associated features in a convenient, 

easy to read fold-out format. These resource guides however, are not provided to users when 

the device is issued. 

Several FEC PCD users also commented that they experience poor reception, device errors, 

and frequently have to trouble shoot their device. The OIG noted employees with these 

problems had older devices that may be near the end of their useful life. Based on a survey 

response provided orally by an FEC office manager, some of their staff who have the older 

Blackberry models would like to receive the upgraded devices that have been issued to some 

employees. Others have stated that they rarely used their PCDs, are not inclined to carry the 

device around, or would prefer to return their FEC issued PCD. 

16 
AUDIT FINDINGS AND RECOMMENDATIONS 

Personal Communication Devices 

1. Personal Communication Device Policy and Procedures Need Improvement 

The FEC currently has two documents that cover policies and procedures regarding FEC 

issued personal communication devices, Commission Bulletin 2001-11A, Policies and 

Procedures for Issuance of Cell Phones and Pagers, and the Information Technology 

Division’s Policy Number 58-4.4, Personal Communication Devices (PCD) Security Policy. 

Commission Bulletin 2001-11A has not been updated since 2002 and although Policy 58-4.4 

was last updated in July 2008, the policy requires substantial improvement. ITD has stated 

that Policy Number 58-4.4 was intended to supersede the Commission Bulletin 2001-11A; 

however, Policy Number 58-4.4 does not state that the policies and procedures are intended 

to supersede those in Commission Bulletin 2001-11A and further, Commission Bulletin 

2001-11A has not been removed from the FEC network to indicate that FEC employees 

should no longer adhere to its policies and procedures. 

The two documented policies have insufficient and conflicting policies and procedures 

regarding the following aspects of the PCD program: a) the process for requesting a PCD; b) 

the authority to request PCDs; c) approval of PCD requests; and d) the policy for personal 

use of FEC issued PCDs. In addition, the policies for PCDs do not incorporate the Internal 

Revenue Service (IRS) regulations governing cell phones as a taxable fringe benefit to the 

employee when used for personal use. 

Process for Requesting PCDs 

The policies, as written, are not followed or being enforced. The OIG found that some of the 

employees who sent requests to ITD are not authorized to request or approve a PCD, 

according to Policy Number 58-4.4. Despite Commission Bulletin 2001-11A, requiring a 

form to request a PCD, FEC has not implemented a standard PCD request form. Generally, 

ITD issues PCDs based on requests received via e-mail from managers in the agency. 

However, the e-mail requests for PCDs are not always retained for program records. The 

FEC currently has 122 active PCDs. Out of the 122 PCDs issued, only 21 e-mail requests 

were maintained by ITD documenting the request of a device. 

According to Policy 58-4.4, requests submitted for PCDs should contain adequate business 

justification to demonstrate how a PCD would be essential to the performance of the 

employee’s official duties. The OIG found that ITD does not require the requestor to provide 

adequate business justification when submitting a PCD request. The e-mail requests retained 

and submitted for audit rarely contained adequate business justification demonstrating how a 

PCD was necessary to support official duties of the employee. Only 10 of the 21 e-mail 

requests maintained by ITD contained business justifications for the PCD user, and some of 

the 10 justifications lacked sufficient detail to adequately document the business need for the 

PCD. There is also no documentation required to verify that a PCD was issued to an FEC 

17 
 

employee following the request. As such, the FEC may incur program costs for PCDs 

provided to employees with limited or no business need. 

Recommendations 

1a. Maintain one comprehensive personal communication device policy for all PCD users 

that clearly defines who has the authority to request PCD devices for other staff in 

their business area. 

Management Response 

“Agree with recommendation: Commission Bulletin 2001-11A is outdated and does 

not reflect updated technology and improvements in telecommunications pricing. 

This bulletin has been superseded by Policy 58-4.4 and Commission Bulletin 2001-

11A will be rescinded. Policy 58-4.4 will be updated to include many of the 

recommendations of this audit.” 

OIG Comment 

Management has agreed to have one comprehensive policy but has not indicated that 

the revised policy will define who has the authority to request PCD devices for other 

staff in their business area. We look forward to reviewing the revised policy to 

ensure it fully addresses this recommendation. 

1b. Develop and implement a Personal Communication Device Request Form for 

requesting PCDs that requires an adequate business justification for each PCD user 

and allows for increased flexibility for managers to select plan options (i.e. voice only 

or data only). 

Management Response 

“Disagree with recommendation. The request for the issuance of a PCD is at the 

discretion of the senior level managers, who will maintain the business justification 

for the personnel under their charge in accordance with Policy 58-4.4, and the 

requirements for disaster recovery and COOP. The method established for 

requesting is e-mail, no form will be established.” 

OIG Comment 

The OIG agrees with management that the issuance of the PCDs is at the discretion of 

the senior level managers. However, the OIG’s audit testing revealed that senior 

level management is not adequately informed about the PCD program costs and 

options in order to make an informed decision to justify and authorize PCDs. 

Therefore, the OIG continues to believe a standard form documenting the justification 

at the senior level, and then forwarded to the PCD program office for PCD issuance, 

is necessary. The form could also serve to inform managers about the PCD costs and 

options, which could be a factor in the justification process at the division level. 

1c. Require supervisors/managers to re-justify the business needs of current PCD users 

via a PCD request form. 

18 
Management Response 

“Disagree with recommendation: The PCD users do not justify their business needs. 

The senior management team determines which key personnel requires the use of a 

PCD. Policy 58-4.4 will be updated to require senior management to re-certify the 

assigned personnel annually.” 

OIG Comment 

Based on the documentation reviewed during the audit, we feel management would 

benefit from the use of a standard form, which could be sent and received 

electronically, to adequately and consistently document the annual re-certifications 

performed by senior managers. 

1d. Issue devices only after adequate justification and formal request has been provided 

 and approved. 

Management Response 

“Disagree with recommendation: The PCD users do not justify their business needs. 

The senior management team determines which key personnel requires the use of a 

PCD. Policy 58-4.4 will be updated to require senior management to re-certify the 

assigned personnel annually.” 

OIG Comment 

This recommendation relates to initial request and business justification receipt prior 

to ITD issuing a device. We recommend ITD issue devices only after adequate 

justification and formal request has been provided and approved. 

1e. Maintain all request forms for PCD users in the agency that includes (but not limited 

to) the make, model, issue date, and FEC property bar code number. 

Management Response 

“Disagree with recommendation. No request forms will be required, however the 

email request from senior managers authorized to make such requests shall be 

maintained on file, until replaced by the annual recertification emails. The 

assignment of a particular unit to a particular user will be maintained in the master 

PCD inventory tracking system.” 

OIG Comment 

The OIG continues to believe management should maintain all request forms to 

include the initial justification and annual re-certification. Further, we recommend 

the request for and assignment of a device is linked to physical documentation which 

indicates the device model, telephone number, and the date that the device was issued 

to the employee. That information can then be used to support and maintain the 

master PCD inventory tracking system. 

19 
Authority to Request PCDs 

The procedures in Commission Bulletin 2001-11A gives all employees the authority to 

request a PCD through the submission of a request form. However, according to Policy 

Number 58-4.4, the only individuals who are authorized to request PCDs for other staff are 

those identified as “base group” users. The base group users are individuals who are 

provided a personal communication device based on their position or job duties (no request 

needed), and have the authority to establish the core group of PCD users for their business 

area. 

The current list of base group users consists only of the following specific job titles and 

offices in the agency: 

• Commissioners; 

• Commission Office Staff; 

• Staff Director; 

• Deputy Staff Directors; 

• Office of Inspector General (OIG); 

• Office of the Chief Financial Officer (OCFO); 

• General Counsel; and 

• Associate General Counsels. 

Policy 58.4-4 fails to clearly distinguish between a) which specific employee positions 

and/or offices can receive an agency issued PCD without a formal request form and b) which 

employee positions in the agency have the authority to request PCD’s for other staff in their 

business area. 

Among the list of base group users is the entire Commission office staff. The latest revision 

to Policy 58-4.4 in July 2008 includes the OIG and the OCFO as part of the base group. 

When adding the offices as a whole (i.e. OCFO, OIG, Commission office staff) to the base 

group users, the policy indicates that all staff within those specified offices, to include 

individuals who are not management level or in supervisory positions has full authority to 

obtain and request PCDs. The policy does not indicate what specific positions in the OIG 

(i.e. Inspector General, Deputy IG) and OCFO (i.e. CFO, Deputy CFO) would have the 

ability to obtain a PCD without formal request due to their position and/or FEC duties. 

In some cases, the individuals that are requesting devices from ITD are listed as a base group 

user. In other cases, ITD accepts PCD requests from individuals who, according to the 

policy, do not have the authority to request devices for others in their business area. 

Some of the individuals who do not have authority to submit PCD requests are in 

supervisory positions. Although ITD allows these individuals in supervisory positions to 

submit PCD requests, the policy does not identify these individuals as a base group user, 

which provides authority to submit PCD requests for other staff. 

20 
Recommendation 

1f. Maintain one comprehensive personal communication device policy that clearly 

defines what positions and/or offices can receive PCDs without a formal request due 

to the employees’ position and/or required FEC duties (i.e. “base group”). 

Management Response: 

“Agree with recommendation: Commission Bulletin 2001-11A is outdated and does 

not reflect updated technology and improvements in telecommunications pricing. 

This bulletin has been superseded by Policy 58-4.4 Commission Bulletin 2001-11A 

will be rescinded. Policy 58-4.4 will be updated to include many of the 

recommendations of this audit.” 

OIG Comment 

Although management agrees with the recommendation, their response does not 

address the need for a policy that clearly defines what positions and/or offices can 

receive PCDs without a formal request. We look forward to reviewing the revised 

policy to ensure it fully addresses this recommendation. 

Approval Process 

FEC lacks a formalized approval process for PCD requests. The approval process in 

Commission Bulletin 2001-11A conflicts with the approval process in Policy Number 58-4.4. 

Commission Bulletin 2001-11A states: 

“After supervisory approval is obtained on the request form, employees will be given 

their new cell phone . . .” 

Policy Number 58-4.4 states: 

“All requests to obtain a FEC PCD from staff . . . must be submitted in writing to the 

appropriate Deputy Staff Director, or Associate General Counsel for approval. 

Employees of the Offices of Inspector General and Chief Financial Officer should 

submit their request to their appropriate manager.” 

The procedures in Commission Bulletin 2001-11A allow all supervisors in the agency to 

approve PCD requests for their staff. However, according to Policy Number 58-4.4, the only 

approving officials for PCD requests should be the Staff Director and Associate General 

Counsels, with the exception of the OIG and OCFO. Only 3 of the 21 PCD requests retained 

by ITD were properly approved to have PCDs according to ITD’s Policy Number 58-4.4. 

In addition to having conflicting approval processes, ITD has not documented their annual 

re-authorization process in their current policy. The re-authorization process consists of ITD 

providing an e-mail to managers in the agency to receive confirmation that the current PCD 

users in their business areas are still authorized to have a FEC issued PCD. Although ITD is 

21 
performing the reauthorization process, the process is not adequate and the most recent 

reauthorization was incomplete. During the most recent re-authorization of PCD users, ITD 

only confirmed reauthorization for 86 of 120 PCD users. Out of the 86 PCD users that were 

re-authorized, 33 were validated as individuals still authorized to be issued a PCD by an 

employee other than the Staff Director and Associate General Counsel, as required by Policy 

58.4-4. The authorizing employee was also not in a managerial or supervisory position as 

indicated in Commission Bulletin 2001-11A to approve a PCD request. 

Recommendations 

1g. Maintain one comprehensive personal communication device policy that clearly 

identifies those in the agency with authority to approve PCD requests. 

Management Response 

“Agree in part with recommendation: Commission Bulletin 2001-11A is outdated 

and does not reflect updated technology and improvements in telecommunications 

pricing. This bulletin has been superseded by Policy 58-4.4 Commission Bulletin 

2001-11A will be rescinded. Policy 58-4.4 will be updated to include many of the 

recommendations of this audit. The revised policy will have to be reviewed after the 

revision, it is agreed that the present policy must be revised. ” 

OIG Comment 

Although management agrees with the recommendation, their response does not 

address the need for a policy that clearly identifies those in the agency with the 

authority to approve PCD requests. We look forward to reviewing the revised policy 

to ensure it fully addresses this recommendation. 

1h.	 Document the ITD re-authorization process of PCD users in ITD’s Policy 58-4.4. 

Management Response 

“Agree with recommendation: Will be included in the update to Policy 58-4.4.” 

OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

1i. Identify who has authority to re-authorize PCD users in ITD’s Policy 58-4.4. 

Management Response 

“Agree with recommendation: Will be included in the update to Policy58-4.4.” 

OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

22 
 

 

Personal Use & Internal Revenue Service Regulations 

Currently, PCD users are allowed to adhere to the policy and procedures regarding personal 

use in Policy Number 58-4.4 Section 2.t which states: 

“PCD’s are issued for FEC business. Personal use should be limited to minimal and 

incidental use . . .Appropriate discipline may be taken if it is determined that the rule 

of minimal personal use has been abused.” [Emphasis added] 

However, the “rule of minimal personal use” has not been defined and is not communicated 

to all users to determine what level of personal use is allowed. Management also does not 

provide policies and procedures to users when issuing devices. 

Contrary to Policy Number 58-4.4 Section 2.t, the Commission Bulletin 2001-11A policy 

prohibits personal use of agency issued cell phones, as follows: 

“No personal calls are to be made on the agency cell phones. The cell phone is for 

 official use only.” 

The OIG identified through audit testing that several employees use their FEC issued PCDs 

for personal use and the level of personal use for some employees would not adhere to ITD’s 

“rule of minimal personal use.” 

In addition to the rule of personal use, the policies and procedures do not incorporate the 

Internal Revenue Service (IRS) regulations regarding taxable fringe benefits. The FEC was 

unaware that personal use of an FEC issued PCD should be included in employee wages as a 

taxable fringe benefit. Subsequently, the FEC is not compliant with Internal Revenue Code 

(IRC) 274(d)-Substantiation Requirements. 

The IRS tax code (Title 26) requires employees who are issued cell phones by their employer 

to clearly substantiate their business use from their personal use. The Internal Revenue Code 

(IRC) 274(d) explains that substantiation is required for any “listed property.” IRC 

280F(d)(4) identifies any cellular phone (or other similar telecommunications equipment) as 

a “listed property” which is taxable to the employee as a fringe benefit if the device is used 

for personal use. The cell phone device is taxable to the employee because “the nature of the 

property lends itself to personal use.” The (IRC) 132(d) explains that business use is 

excludable from the wages of the employee as a working condition fringe benefit; therefore, 

“employees are required to account for business and personal use.” 

IRC 274(d) notes that “records of business and personal use must be kept by the employee in 

order to determine whether the value of any of the use is included in the employee’s wages.” 

Further, if employees do not substantiate their business use from personal use, all use is 

included in the wages of the employee. 

Commission Bulletin 2001-11A Policy section, #2 states “Cell phone users must sign a 

receiving report indicating calls and charges incurred are valid and made for official use,” 

23 
 

however, this policy has not been enforced or incorporated into the PCD security policy and 

structured to incorporate IRS regulations. Commission Bulletin 2001-11A and Policy 

Number 58-4.4 also do not indicate who in the agency is responsible for enforcing and 

monitoring this IRS regulation. 

Currently, the IRS is exploring methods to simplify the procedures for substantiating 

employee’s business use of an employer provided cell phone. Until the legislation is 

changed, IRS tax rulings remain in effect and the FEC should implement reasonable 

measures to adhere to the requirements. 

Recommendations 

1j.	 FEC should adhere to the IRS regulations and revise program policies to reflect those 

regulations. 

Management Response 

“Disagree with recommendation: FEC senior management and Office of General 

Counsel will review IRS regulations to determine if any apply to the FEC policies 

regarding PCD use within the agency, and adjust our current policies to reflect 

current regulations. However, as discussed at the exit meeting, FEC management 

will hold in abeyance until further guidance issued by Commissioner of the IRS, in 

accordance with his statement dated 6/16/09”. 

OIG Comment 

Although the Commissioner of the IRS has “requested Congress act to make clear 

that there will be no tax consequences to employers or employees for personal use of 

work-related devices such as cell phones provided by employers,” the law is still in 

effect and management should take reasonable steps to adhere to current IRS 

requirements. These additional procedures and controls would also help ensure the 

program expenses were related to business activity rather than personal use. 

1k. Provide the policies and procedures for the use of PCDs to all PCD users when 

issuing a device. 

Management Response 

“Neither agree nor disagree here is what we will do: All policies and directives are 

maintained in a shared folder and is accessible to all FEC personnel. All users will 

be directed to that folder so they may review applicable directives.” 

OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

24 
 

2. Personal Communication Device Program Monitoring 

FEC does not effectively monitor and manage the Blackberry program to control and reduce 

program costs. AT&T has provided FEC with access to AT&T Premier Online Care, a 

website that allows ITD program staff to manage program costs and other features of the 

FEC’s AT&T service plan. By using the Premier website, FEC is able to: update individual 

user information; make service plan changes; add and remove phone features; manage addon plans; suspend/reinstate phones; and review billing information. Although the AT&T 

online tool is provided for effective and efficient management of FEC’s AT&T service plan, 

the overall lack of program monitoring and ineffectively managing the program results in 

inadequate records and additional cost to the agency. 

Excessive Service Plan Costs 

FEC incurs excessive monthly service charges for active spare PCDs and PCDs issued to 

FEC employees but are not being used. ITD does not suspend or terminate devices in a 

timely manner when an employee leaves the agency or when employees have been 

reassigned from a temporary position that required an FEC issued PCD. According to the 

FEC’s AT&T representative, FEC can suspend a phone with a code for “vacation 

suspension” and the monthly fee will be reduced to $10 for 180 days. If service is canceled, 

the AT&T representative can waive the termination fee for government users. 

Audit testing showed 19 devices were either not assigned to staff or were assigned to staff 

who had left the FEC and were inactive for a total of 107 months. If management had 

suspended the PCD’s service, FEC would have been charged a lesser rate of $10 per month. 

Instead, FEC retained service for the PCDs and paid full monthly service charges of 

$8,614.39 over a 16 month period for inactive accounts. If the service was canceled, FEC 

would have paid no additional fees as well as no termination fee. 

PCD program staff stated that ITD maintains active spare devices in cases of immediate 

need. However, AT&T’s telephone service can be activated within 24 hours of an activation 

request through the FEC’s AT&T representative. Under the FEC’s prior Nation 450 service 

plan from June 2009 through August 2009, FEC was charged $643.36 for four spare PCDs; 

these telephone lines were activated in June 2009. Under the current Government Pooled 

Plan, FEC maintains two active spare devices that are charged $158 a month collectively for 

services that are not being used. 

Recommendations 

2a. All unassigned devices should be suspended or service should be terminated if the 

device can not be immediately transferred to another user (no active spares kept in 

ITD). ITD retains a minimum of 10 inactive spare devices and a spare SIM. If 

required, a device could be activated within 24 hours. 

 Management Response 

“Disagree with recommendation. ITD has in the past allowed too many devices to be 

at the ready, however there is a real need to maintain a minimum number of devices 

25 
 

 

at the ready for immediate use in the event of a catastrophic or emergency situation 

and the non availability of personnel that has the authorization to activate a device. 

ITD will keep a minimum of three devices activated for use by any personnel 

designated by proper authority at a moments notice. This policy will be incorporated 

in the updated FEC PCD Policy.” 

OIG Comment 

The OIG continues to believe ITD should eliminate, or minimize to the maximum 

extent possible, the number of unassigned active devices. It is important to note the 

FEC’s recent roll-out of portable netbook computers should help alleviate the need to 

maintain unnecessary unassigned active devices. 

2b. Devices assigned to employees based on temporary roles should be recovered when 

the employee is no longer in the temporary position. 

Management Response 

“Agreed. Project management personnel will more closely monitor PDC’s that are 

no longer in use.” 

OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

Assessment of Business Needs 

Management does not assess the business needs of employees requesting PCD’s to provide 

the appropriate service plan features and reduce costs to the agency. Instead, employees are 

provided a device with no discussion or formal assessment of business needs compared to 

service plan options. Based on our audit testing of employee PCD usage, PCD users are 

assigned devices with plan features that are not aligned to their specific business needs. 

Consequently, the FEC pays monthly service charges for phone features that are not used. 

“It’s important for an organization to thoroughly understand . . . who is using the devices and 

how they are using them.”6

 OIG discussions with FEC’s AT&T representative revealed that 

management is able to adjust the standard service plan of voice and data to fit users specific 

business needs. Management has the ability to assign PCD users a data only plan (i.e. email), 

as opposed to the bundled data and voice service plan. If the user selects a data plan with no 

voice feature, AT&T adds a $5.00 fee to the monthly data plan. For instance, the cost of the 

standard data plan with a voice feature is $44.99 per month. When the monthly cost of the 

voice feature, $39.99 is included, the total monthly service charge is $84.987

. If the user only 

has a data plan, the total monthly service cost is only $5.00 additional to the standard data 

plan, a total monthly service charge of $49.99. The OIG’s review of PCD users’ monthly 

6 Greengard, Samuel. “The Fusion of Business and Technology: Minding Your Mobile Assets.” Baseline 

November 2009: 23+. 

7

 Total monthly service charge for the bundled plan does not include FEC’s government discount of $7.68. 

26 
activity showed that several users could reduce their plan to a data only plan and produce 

substantial cost savings to the agency. 

The OIG conducted detailed testing of PCD usage under the Nation 450 plan for the 16 

month period, May 2008 through August 2009. The OIG identified a total of 65 PCD users 

with minimal to no use of their devices. This includes users who had 0 voice minutes used 

and 0 data usage or only used 10 percent or less of their voice minutes during the time they 

were assigned the device. 

For the 16 month period, May 2008 to August 2009, FEC paid $77,362.73 or 52 percent of 

the total program service costs for the period for the 65 PCD users to have a combined data 

and voice plan. The monthly service charge for a standard bundled plan of voice and data 

under the Nation 450 plan was $77.30. When separating the PCD users in the categories of 

users with no voice or data usage, and users with less than 10 percent of voice minutes used 

over the 16 month period, FEC paid: 

•	 $6,909 for 5 users with no voice OR data usage for half or more of the 16 

month testing period; and 

•	 $70,453 for 60 users who only used 10% or less of their voice minutes. 

If the 65 users were only charged a data only plan, the monthly service fee would have been 

reduced to $49.99 per user and the potential savings to the agency would have been 

approximately $32,359 in program costs. 

The FEC structured their new Government Pooled plans to give the agency a monthly 

allowance of 12,900 minutes to be shared among all users. Although the Government Pooled 

plans are not structured where each individual is assigned to their own monthly minutes, 

management can still reduce cost to the agency. If management adjusted the service plans of 

the users with minimal or no voice use, to just a data plan, several service plans would 

decrease to $49.99 per month and program costs would be reduced. The employee survey 

results showed that out of 115 PCD users who responded to the survey, 49 do not use their 

voice feature, and 10 users feel that the PCD is not necessary to efficiently and effectively 

perform their FEC duties. Potentially these PCD users could do without the device. 

The OIG is aware there are PCD users who may not frequently use their voice feature, but 

due to their required FEC duties, the voice feature for their service plan is necessary. The 

OIG also recognizes that the users’ managers are ultimately responsible for identifying 

employees who should be assigned PCDs to effectively perform their job. However, audit 

testing shows that FEC could significantly reduce program costs by monitoring and 

providing services that fit users’ needs. 

Recommendations 

2c. Review the audit testing results for users with very limited or no usage and 

determine if an actual business need exists to retain the device. If a valid need exists, 

27 
ensure the employee still has the device, it is serviceable, and the employee 

understands how to use the device. 

Management Response 

“Disagree with recommendation. It has been determined by senior FEC management 

that in order to properly conduct continuous business, while both in the local FEC 

geographical area, or on travel in the conduct of official or non-official business, or 

in the event of a disaster, or emergency that certain key personnel are required to be 

in communication with FEC officials. These key personnel will be identified by the 

authorizing senior level FEC managers without question from ITD program 

administrators. Policy 58-4.4 will be updated to reflect the annual certification by 

senior level management will be used to determine that the persons assigned a PCD, 

are to continue to be authorized to use FEC PCD. The employees issued PCD’s will 

be issued them in accordance with Policy 58-4.4, it is up to the individual managers 

to ensure that the employees understand how to use the device, ITD training 

personnel are available to assist the managers in this endeavor. The authorization, 

use, care, and individual accountability for the devices is not the responsibility of the 

ITD.” 

OIG Comment 

The OIG recognizes management’s intention that some employees, no matter the 

level of use exhibited, will be issued a device based on business continuity need. We 

also recognize that management may wish to reevaluate the need for some employees 

based on past use. The OIG believes that a device that is powered off, not carried 

with employees at all times, or is not serviceable, will never meet FEC management’s 

intended business need and is a waste of government funds. We recommend 

management review the historical user activity reports for users with very limited or 

no usage and determine if an actual business need exists to retain the device. If a 

valid need exists, ensure the employee still has the device, it is serviceable, and the 

employee understands how to use the device. 

2d. Document the requestor’s expected need for a PCD (i.e. e-mail only, phone 

communication, e-mail and phone) through a request form to determine which plan 

feature(s) best fit the requestor’s business need (i.e. data only plan, voice only, or 

 bundled plan). 

Management Response 

Disagree with the recommendation. The FEC has one and only one plan based upon 

the desires from the senior level management, that all personnel issued a PCD have 

the capability for voice, data, and text communication. In order to accommodate 

these criteria, the ITD assisted the contracting officer in plan and device selection. It 

has been determined by FEC senior management that in order to be able to respond 

to any catastrophic or emergency situation, that all FEC PCD user’s are able to 

access or be accessed through voice, data transmission or texting. This approach to 

emergency preparedness as well as the efficient conduct of daily business 

28 
 

transactions has been deemed by senior FEC management to be the most effective use 

of the agency budget for this type of communication system. 

OIG Comment 

The OIG understands that management has one AT&T service plan, however; this 

plan can be adjusted to add or remove features to best fit the agency’s needs and also 

produce cost savings to the agency. The FEC currently has one PCD user whose plan 

has been adjusted to a data only plan. The OIG’s Employee Mobile Survey combined 

with the OIG’s audit testing indicates that the agency pays monthly service costs for 

several users who do not use their voice feature. We recommend that management 

provide managers/supervisors with the option to assign their staff with the plan 

features that best fit the business needs of the agency. 

2e. Notify managers during the reauthorization process of the ability to revise PCD plan 

options in the future to appropriately support the PCD user’s business need (i.e. if 

the user requests a data and voice plan but only uses data, their standard service can 

be reduced to a data only plan). 

Management Response 

“See response above. The FEC has one plan for all users.” 

OIG Comment 

The OIG understands that management has one AT&T service plan, however; this 

plan can be adjusted to add or remove features to best fit the agency’s needs and also 

produce cost savings to the agency. 

Inadequate Records 

FEC’s monthly invoices from AT&T do not always accurately reflect the name of FEC 

employees that are assigned PCD devices. Based on the OIG’s audit testing, ITD program 

staff continuously failed to update the AT&T Premier website in a timely manner to reflect 

new PCD users, or PCD users who had left the agency and their device and/or telephone line 

had been transferred to another user. The FEC has had the ability to access and update 

account details using the AT&T Premier website since June 2008. As a result of the ITD 

program staff’s failure to update the account details, FEC had 283 instances over the 16 

month period where several phone lines on the FEC billing invoices did not reflect the name 

of the FEC employee assigned to an active telephone line. Further, once ITD program staff 

was provided the ability to assign the names of PCD users in the AT&T Premier website in 

June 2008, FEC failed in 141 instances to record the correct FEC employee to their assigned 

telephone line in the AT&T billing system from June 2008 through August 2009. In addition, 

ITD’s Blackberry asset listing did not reflect four active spares that were obtained in June 

2009 in which only two of the four PCDs were then issued to users in October 2009. 

All active telephone lines should be recorded as spares or assigned to the correct PCD user 

for accurate record keeping. Also, adequate records are necessary to properly monitor PCD 

user’s usage for unusual activity levels and improper service charges. 

29 
Recommendation 

2f. PCD user information should be kept up to date and adjusted in a timely manner on 

the ITD master Blackberry listing and the AT&T Premier website for employee 

separations and new assignment of devices. 

Management Response 

“Agree. User information will be kept up to date in a timelier manner to include the 

AT&T website. The Policy 58-4.4 will be updated to reflect the monitoring of the 

information.” 

OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

Knowledge of Service Plan 

Throughout the 16 month testing period, FEC incurred extra usage charges. ITD fails to 

provide sufficient information to PCD users regarding plan details and device features that 

result in additional charges. As stated above in the Employee Survey Results, 83 PCD users 

out of 115 who responded to the survey are unaware of the FEC’s service plan details. 

Employees and managers are not notified of: 

•	 plan options that can reduce their standard monthly cost (i.e. data only or 

voice only plans); 

•	 phone features that incur additional cost to the agency (i.e. directory 

assistance, roaming); and 

•	 the ability to revise plan features in the future to best fit the FEC’s business 

needs. 

For the voice plans, FEC spent $1,615.63 during the 16 month testing period in usage 

charges. The usage charges related to directory assistance calls ($1.79 to $1.99 per call) and 

calls made during international travel and outside of AT&T’s network area. FEC’s data plan 

also incurred usage charges totaling $2,160.66. The data plan usage charges included texting 

(20 cents per text), data connectivity/transfer and roaming charges for international travel, or 

travel to locations not considered in AT&T’s network area. Prior to April 2009, FEC paid 20 

cents per text message. ITD program staff identified instances of contacting specific PCD 

users due to excessive use of the texting feature that caused high dollar service fees. 

Recommendation 

2g. Management should educate PCD users of all features that incur additional cost to the 

agency, such as roaming charges that result when employees place calls outside 

30 
AT&T service areas; texting; directory assistance; and voice use over the pooled plan 

 limits. 

Management Response 

“Agreed. Since the beginning of this fiscal year (FY10) the FEC has gone to an all 

inclusive billing that allows each user 200 minutes of voice, pooled to avoid overage 

charges, unlimited data and unlimited text. The users will be kept abreast of plan 

changes.” 

OIG Comment 

Although management agrees, it is important that management ensure the users are 

informed of plan features that incur additional charges, such as: roaming charges that 

result when employees place calls outside AT&T service areas; directory assistance; 

and voice use over the pooled plan limits. 

Add-on Service Features 

Device features that are not included in the standard service plan are not properly managed 

by ITD program staff. Some FEC employees have international add-on plans that cost an 

extra $20 per month. Other PCD users who travel internationally that do not have an 

international add-on plan are charged various extra fees per kilobyte for data (amount varies 

depending on location of travel), and anywhere from $0.09 to $3.49 per minute for voice 

while on international travel. International add-on plans are retained as part of the monthly 

service plan for several PCD users. The add-on plans are retained for several months after 

users have returned from travel. The OIG also identified a user who does not travel 

internationally for business as part of their FEC duties but is assigned an international add-on 

plan. During the scope of the audit, FEC paid $8,343.49 in international add-on plans for 15 

PCD users in which: 

•	 6 of the 15 users have no record of travel for the total number of months they 

were charged for an international add-on plan. This resulted in a total service 

charge of $2,620.23; 

•	 3 of the 15 users have no record of travel during the entire 16 month period 

reviewed, resulting in service charges totaling $955.11; and 

•	 the last 6 of the total 15 users where charged for an international add-on plan 

for several months before or after their actual travel dates which resulted in 

$2,754.38 in service charges. 

As a result of the above conditions, the FEC overpaid service costs by $6,329.72 for 

international add-on plans. 

31 
Recommendation 

2h. Provide the international add-on plan to the standard monthly service for users who 

 frequently travel internationally for business. Require written request for the 

international add-on plan for PCD users who do not frequently travel internationally 

for business. This request should include their beginning and ending date of travel. 

Based on the information, the international service option should be promptly 

activated and terminated. 

Management Response 

“Agree with recommendation. When an authorized user is performing international 

travel, an e-mail request is submitted to the Blackberry administrator with the period 

of international travel. The administrator then activates international add-on plan 

for the period requested. When the traveler returns, an email is sent to terminate the 

international add-on plan. The email communication is the only communication 

required, no form will be necessary.”

 OIG Comment 

ITD should ensure that the beginning and ending dates of travel are included in every 

PCD users’ e-mail requests to activate international add-on plans. Also, the 

Management Assistant who is responsible for activating the international add-on plan 

for users should establish a method that will ensure timely termination of the 

international add-on plan service when users return from travel. 

Managing Service Plan Features and Cost 

Based on the audit testing, the OIG determined there was insufficient communication 

regarding the details of the PCD contract between ITD and the Office of Procurement. The 

FEC Contracting Officer recently transitioned the agency from the AT&T Nation 450 plan to 

the Government Pooled 100 & 200 plans. The decision to change service plans was based 

solely on an assessment of the minutes used by FEC PCD users, an analysis conducted by an 

AT&T account representative. The AT&T account representative then provided a quote for 

the Government Pooled plans to the Contracting Officer based on the assessment. According 

to the Contracting Officer, the change to the new pooled plan was expected to reduce 

program costs by 10 to 20 percent annually. The Contracting Officer’s decision to switch 

plans was performed without consultation with the PCD program area staff knowledgeable of 

employee usage levels (minutes), as well as specific user needs and service features. The 

FEC’s monthly AT&T invoice increased an estimated $2,260 after changing to the 

Government Pooled Plan 100 & 200. The increase was due to 113 devices being charged an 

additional $20 per month for unlimited texting, a service feature included in the Nation 450 

plan at no additional cost. The additional cost for texting was not included in the quote 

provided by AT&T to the Contracting Officer prior to changing service plans. It is likely 

that consultation with the PCD program office would have highlighted the discrepancy that 

the quote for the Government Pooled Plans lacked information on texting, and whether the 

agency would incur additional charges for the texting feature. The PCD program office does 

not periodically review the service plans offered by their current provider or conduct market 

research of other potential vendors to decrease program costs. 

32 
During audit testing, the OIG selected T-Mobile and Verizon Wireless from the General 

Services Administration (GSA) contractor schedule to compare the cost and available 

minutes to the FEC’s AT&T Government Pooled plan. The FEC’s Government Pooled 100 

and 200 plans give FEC users 12,900 shared anytime minutes, 5,000 nights and weekend 

minutes, and unlimited mobile to mobile minutes. The FEC retained their unlimited 

domestic data plan, and unlimited domestic air card service under AT&T. The OIG 

downloaded T-Mobile and Verizon’s GSA pricing schedule and contacted sales 

representatives to receive cost information regarding their service plan options and hardware 

(i.e. mobile devices and air cards) that would closely mirror the FEC’s current AT&T 

Government Pooled Plans and hardware. 

T-Mobile provided the OIG with a detailed spreadsheet of the estimated annual costs based 

on the current number of PCDs issued to FEC employees. The OIG included one standard 

cell phone that is used by investigators, and 9 air cards that the FEC also has with AT&T 

which is included in the total annual fee of $114,465 for the AT&T Government Pooled 

Plans. The plan for T-Mobile that would closely mirror the current FEC AT&T plan would 

be the Nationwide Enterprise Plan 50 (GS-35F-0503M). Under the T-Mobile plan, the 

agency would receive 50,000 monthly pooled minutes, 50 free lines, free mobile to mobile, 

unlimited nights and weekends, and 400 text messages per user each month. The plan would 

also include free Blackberry devices for phone models 8220, 8820, 9700, or 8900, and free 

air cards. The estimated annual cost to the agency for the T-Mobile plan is $62,308, which is 

an annual savings of $52,158 compared to AT&T’s Government Pooled plans. For the 

Verizon Voice and Data bundle plan (GS-35F-0119P), FEC would receive 300 minutes per 

user each month that can be shared (38,700 pooled minutes), unlimited nights and weekends, 

unlimited mobile to mobile, and unlimited data and domestic text messaging. Verizon would 

provide all air cards and Blackberry curve 8830 devices at no cost to the agency. The 

estimated annual cost to the agency for the Verizon plan is $79,881, which is an annual 

savings of $34,585. 

The table on the following page is a summary table of the monthly service costs for 

comparable service by vendor: 

33 
 

 

 

 

 

 

General Services Administration Schedule Pricing 

Monthly Service Fees AT&T T-Mobile Verizon 

Voice & Data Plan (119 phones) $8,918.82 $4,566.21 $5,948.81 

Data Only Plan $50.00 $32.80 $34.99 

OGC standard cellular telephone $30.00 $24.59 $29.99 

Air Card Service (9 cards) $540.00 $369.00 $386.91 

Regulatory Charges Estimated 4% @ $199.70 $256.03 

Monthly Total $9,538.82 $5,192.30 $6,656.73 

Price quotes were obtained by the OIG for audit purposes only. The prices stated in the table above 

are not committed prices by the vendors. Final contract prices may vary. The OIG’s calculations for 

T-Mobile and Verizon reflect the current number of FEC PCD users and air cards as of October 2009. 

@ The AT&T rates listed in the table above include the regulatory charges in the monthly service fee. 

Recommendations 

2i. ITD’s Management Assistant should annually monitor monthly PCD usage to asses if 

the current plan should be adjusted to appropriately meet user needs. 

Management Response 

“Agreed. This action is performed by the contracting officer at the time of contract 

renewal.” 

OIG Comment 

Management’s response indicates the assessment is performed at the contract renewal 

by the contracting officer. The OIG continues to believe the ITD Management 

Assistant should monitor monthly PCD usage and annually assess if the current plan 

should be adjusted to appropriately meet agency needs. This person reviews the 

monthly invoices and is most familiar with the plan features and billing details. 

2j. Prior to renewing PCD services or switching service plans, the Contracting Office, in 

consultation with the PCD Program Office, should conduct and document analysis of 

service plans offered by the current provider and other potential vendors on the 

GSA schedule to achieve best value for the agency. Further, the Contracting Office 

should discuss actual plan details and agency use with the PCD program office and 

ensure any negotiated service options, such as free texting, are included in quotes 

from potential vendors. 

34 
 

Management Response 

“This action is the responsibility of the contracting officer and is conducted in 

accordance with the requirements of the FAR. The contracting officer routinely takes 

this action on each and every contract action he authorizes, as required by law.” 

OIG Comment 

The OIG continues to believe it is in the best interest of the agency for the program 

area (point of contact), working with the Procurement Office, to conduct market 

research and obtain additional quotes prior to awarding another blanket purchase 

agreement (BPA) contract for personal communication devices in FY 2011, the year 

the current contract is scheduled to expire. 

According to the FEC’s Procurement Office policies and procedures, “it is everyone’s 

responsibility to ensure that market research is performed for all actions that require 

the expenditure of appropriated funds.” According to the FEC Procurement 

Procedures 10, “the following BPA Review procedures will be coordinated via the 

Director of Procurement to the appropriate POCs/COTRs8

 through the CFO Internal 

Control Program on an annual basis. The contracting officer that entered into a BPA 

shallA. Ensure each BPA is reviewed annually and, if necessary updated any 

pertinent contract information at that time; and 

B. If the BPA is under a GSA schedule ensure that the most recent GSA 

Schedule for pricing has been distributed to the ordering officials and inserted 

in the file. 

C. Maintain awareness of changes in market conditions, sources of supply, 

and other pertinent factors that may warrant making new arrangements with 

different suppliers or modifying existing arrangements. 

3. Tracking and Managing Personal Communication Devices 

ITD does not keep adequate records regarding FEC PCDs and does not efficiently and 

effectively manage devices to prevent fraud, waste and abuse. Also, ITD is not in 

compliance with Commission Bulletin 2006-04 for tracking PCDs. Specifically, ITD does 

not maintain an inventory of PCDs in the Fixed Asset System (FAS) and FEC property bar 

codes are not assigned to mobile devices. 

Asset Tracking 

ITD maintains several Excel spreadsheets to keep inventory records of: 

•	 the names of PCD users issued PCDs, including the date the PCD was issued, model 

number, device serial number, and telephone number associated with the user/device; 

8

 Point of Contact (POC) and Contracting Officer’s Technical Representative (COTR) 

35 
 

•	 which devices are unassigned (spare devices); and 

•	 devices that have been lost, stolen, broken, or discarded. 

At the beginning of the audit, the OIG received an inventory listing of devices held by the 

agency. The listing provided on August 28, 2009 did not include: 

•	 PCDs no longer in use due to upgrade or breakage, but still retained by the agency in 

storage; 

•	 14 Palm Treo 650 models that are in near new condition; 

•	 devices that were lost or stolen; 

•	 devices that were destroyed and disposed of by ITD staff; 

•	 new devices held as spares; 

•	 four service plans that were activated in June 2009; and 

•	 complete details on the date devices were issued to employees. Nine (9) of the 116 

listed devices did not have the date issued field completed9

. 

In May 2009, a device was listed as assigned to an FEC employee who never accepted the 

FEC issued device. Further, the assignment of the device to the user’s name was listed on 

the AT&T monthly invoices through December 2009. In addition, the employee survey 

results revealed that 20 PCD models assigned to users on the ITD Blackberry listing were 

incorrect. This may indicate that employees were unable to correctly identify their model 

number or that the ITD asset listing requires update. 

A second PCD listing was provided on January 15, 2010 that included devices disposed of by 

ITD, older devices no longer in use, lost and stolen items. However, the listing did not 

include the date devices were issued to employees. Further, most items in the asset listing 

did not include the date returned by employees even though the asset listing contained a field 

to capture the data. None of the listings included a field to record the date an item was 

disposed by the agency. The second asset listing also did not include all devices that had 

been purchased, used by agency staff, but then replaced by newer devices, such as the Palm 

Treos procured in fiscal year 2006. 

Upon request, a third asset listing was provided on January 15, 2010 with detail of the 15 

Palm Treo’s purchased for ITD staff use in fiscal year 2006 and 2007. Finally, a fourth asset 

listing was provided January 20, 2010 by ITD’s Management Assistant who is responsible 

for maintaining the asset listings. 

The fourth listing was an Excel workbook with different worksheets for “in service,” 

“unassigned” and “out of service” but did not include older devices held in storage or all new 

devices received in 2009. The listing did not contain an accurate status of all new devices 

received prior to January 20, 2010. 

9

 The majority of items not containing a date related to PCDs issued to ITD staff members. 

36 
Recommendations 

3a. Adhere to Commission Bulletin 2006-04 and track personal communication devices 

in the Fixed Asset System and apply barcodes to all devices. 

Management Response 

“Since Commission Bulletin 2006-04 address mainly cell phone and pagers, and 

modern PCD’s it shall be rescinded and replaced with Policy58-4.4. Policy58-4.4 is 

in processed of being revised to include some of the recommendations contained in 

this audit, and to provide additional clarity.” 

OIG Comment 

Management’s response does not indicate whether they agree fully with the 

recommendation or provide explanation of their disagreement. 

PCD Status and Location 

The current method of tracking PCDs and their status using the Excel spreadsheet is not 

effective because the spreadsheet does not contain defined fields to document dates issued, 

returned, and location of assets that are not issued to employees. The current PCD listings 

reflect a point in time snapshot rather than the life-cycle for each asset. Review of the PCD 

listings showed 11 devices were reported lost, 4 were reported stolen and 38 are broken. Per 

ITD’s Policy Number 58.4-4, if a PCD is stolen, the PCD user is responsible for filing a 

police report as soon as possible. No police reports were available for the items listed as 

stolen. It is unclear if employees filed a police report but failed to provide a copy to the FEC, 

or the employee did not file a report as required by the policy. Of the devices listed as 

broken, one was returned to AT&T under warranty and replaced. Two of the devices listed 

as broken were not located in the boxes of broken devices provided for stocktaking during 

the audit. 

Obsolete and broken assets held by the FEC in storage were provided to the OIG for 

stocktaking, as were spare devices. Detail information regarding equipment purchases in 

monthly invoices show the FEC paid for 13 air cards at $49.99 each for wireless computer 

connectivity when employees are on business travel. Three cards were returned and the asset 

listing provided by ITD listed only 9 wireless devices as issued to FEC staff and no 

additional devices were presented for stock take or listed as spares. Therefore, the FEC 

could not account for 1 air card. 

The asset listings provided for the audit contained inaccuracies. For instance, one Blackberry 

8700c is listed as “out of service” due to a former employee’s failure to return the device 

when leaving the FEC. The person ceased to have access to an FEC issued communication 

device in September 2006, and at that time, the FEC only used Blackberry models 6290, 

7280, 7290 and Palm Treos. The OIG’s review of agency records show the employee had 

actually been issued a Blackberry 7290, which is now listed as “discarded” in the asset 

listings. The FEC upgraded existing telephone lines to Blackberry models 8100 and 8700c 

beginning in December 2007, more than a year after the employee had access to a device 

37 
 

removed and nine months after the employee resigned. The agency received PCD upgrades 

for telephone lines but did not always issue the upgraded devices to the person whose 

telephone line qualified for a free upgrade. In this case, it appears a Blackberry 8700c was 

received as an upgrade for the telephone line previously assigned to the employee. The loss 

of the 8700c is incorrectly attributed to the former employee who could not have been issued 

the device retaining it when he left. Review of monthly invoices showed FEC program 

management had the telephone assigned as “Supply room” and not to a particular employee. 

It is unclear whether the new device was ever issued to any FEC employee. The device was 

not noted among broken or spare devices during stocktaking. 

The OIG’s review of agency records showed that 15 ITD employees were issued Palm Treos 

in 2006, and service for those devices was terminated by March 2007. When the Palm Treos 

were purchased, new telephone numbers were obtained and those numbers were terminated 

when the service plans for the Palm Treo devices were canceled. New telephone numbers 

were assigned to the 15 ITD employees along with a new Blackberry 8100 or 8700c device 

procured as a replacement to the Palm Treos. The monthly invoices show program 

management reviewed the invoices and wrote the employees’ names next to the new 

telephone number assigned to employees with the Blackberry 8100 and 8700c device 

models. 

Procedures regarding the distribution of PCDs to users are not documented or enforced. 

According to the Administrative Assistant, who manages the device assignment and 

distribution processes, employees must return a device in order to receive another device. 

ITD provided an upgraded device to a user who was not required to return the previously 

issued device until nearly three (3) months after receiving the upgrade. Specifically, the 

initial PCD inventory listing provided to the OIG on August 28, 2009 showed an employee 

was assigned a Palm Treo. The Palm Treo’s service was canceled and the model had been 

replaced in March 2007 by a Blackberry model. The second inventory listing provided by 

ITD showed the employee had been issued a Blackberry 8700c which was now classified as 

spare10. The Palm Treo assigned to the employee was not located in the boxes of spares and 

broken devices provided to the OIG for stock take. Instead, the Palm Treo was returned by 

the employee within a few days of the OIG’s request during the audit. Based on the most 

recent asset listing, the OIG determined the employee received a Blackberry 8320 in October 

2009. The 8700c previously assigned to the employee, after the Palm Treo service was 

canceled, was not listed as assigned to another employee until January 2010. The Palm Treo 

should have been returned in March 2007, when a subsequent device was issued, or October 

2009 at the latest. Therefore, the OIG determined that some users were not required to return 

their old PCD device prior to obtaining an upgraded device. This practice conflicts with 

program management’s assertion that an employee must return a device in order to receive a 

new device. 

Recommendation 

3b. Document and enforce the policies and procedures for issuing a new or upgraded 

device to an FEC PCD user, including return of previously issued device(s). 

10 The date the 8700c was issued to the employee was not included in the asset listing. 

38 
Management Response 

“Policy 58-4.4 is in processed of being revised to include some of the 

recommendations contained in this audit, and to provide additional clarity.” 

OIG Comment 

Management’s response does not indicate whether they agree fully with the 

recommendation or provide explanation of their disagreement. 

Asset Disposal 

PCD inventory listings provided by program management showed 49 devices were rendered 

unserviceable and discarded by the FEC. Program management did not provide 

documentation to support when the PCDs were discarded, who performed the destruction, 

and whether a second person verified the destruction was performed. According to staff, 

devices are “wiped” prior to destruction to erase the memory and the subscriber identity 

module (SIM) card is removed. Devices are rendered unserviceable by striking the PCDs 

with a hammer and disposed of by placing the broken pieces in a trash receptacle. 

Program management does not attempt to dispose of working devices through GSA, where 

the PCDs might be used by other agencies or be sold to the public. We noted that 14 of the 

15 Palm devices appeared nearly new and could have been provided to GSA in March 2007 

for use by other agencies, or been offered to FEC employees as an option to their PCD. 

Instead, the Treo devices have remained unused and in storage. Further, while some 

Blackberry devices have cracked or blemished screens, many others listed as broken 

appeared serviceable and passed basic functionality tests. The inventory listings did not 

always include detail of the device malfunction. The OIG contacted one PCD user whose 

device was labeled broken and was issued an upgraded device, to identify what feature(s) of 

the device was broken that required a new device. The PCD user stated that the upgrade was 

not provided due to a broken device, but only because the user had an older model. 

Program management does not attempt to use GSA disposal channels to minimize 

environmental impact, recognizing the PCDs typically contain rechargeable batteries, even 

though the disposal channel is the same as that currently used for excess FEC computers and 

furniture. 

Recommendations 

3c. ITD staff coordinate with GSA and implement processes and procedures to ensure: 

•	 devices no longer needed are made available to other government agencies or 

non-profit organizations; and 

•	 obsolete or broken devices are disposed in a manner that is not detrimental to 

public health. 

39 
Management Response 

“Policy 58-4.4 shall be updated to reflect that all devices that are broken, obsolete, 

or have reached the end of the FEC service life shall be turned into GSA.” 

OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

3d. ITD should implement a form and process, such as the NIST Sample Sanitization 

Validation Form, to record sanitization (wiping) of devices, disposal and/or 

 destruction, as appropriate. 

Management Response 

“Preparation for disposal of all PCD’s shall be in accordance with existing 

provisions of Policy 58.” 

OIG Comment 

Management’s response does not indicate whether they agree fully with the 

recommendation or provide explanation of their disagreement. 

Segregation of Duties 

In the past, procurement of PCDs was done via the standard purchasing methods with the 

associated procurement controls: purchase order request; obligation of funds; subsequent 

management and budgetary approvals; billing by vendor; and approval for payment once 

goods were received. Now, however, the AT&T’s on-line client service website Premier 

allows customers to obtain goods and services directly from the vendor. Currently, the FEC 

obligates funds annually under a blanket purchase agreement to cover the AT&T monthly 

service costs and PCD purchases, as needed. 

Orders for PCDs are billed to an active account (telephone number) in the monthly AT&T 

invoices for services. It is not always clear that the monthly invoices include both monthly 

service costs and costs for PCDs. Only through close review of the summary invoices for an 

unusually high dollar amount in the “monthly service fee” or “credits, adjustments and other 

charges” categories, then a review of the detail transaction section of the bill for that 

telephone number, can a person determine whether a new device was ordered and billed. For 

PCDs requested and received free of charge under upgrade promotions, it is even more 

difficult to determine whether devices have been ordered and received. Only through 

detailed review for nominal shipping fees, retention of device requests (emails), order 

confirmations (online via the website) and shipping documentation (contained in the box 

with shipped devices), can it be determined that devices were ordered and received by the 

FEC. 

ITD does not ensure proper segregation of duties and oversight for managing PCDs. Since 

gaining access to the AT&T Premier website in June 2008, the ITD Management Assistant 

40 
 

 

who is responsible for managing PCDs, has obtained 60 PCDs, of which 40 were free under 

upgrade promotion, and purchased 10 air cards. On at least one occasion, the free devices 

were shipped directly to the ITD Management Assistant, who not only orders the devices, but 

also records the devices into the Excel spreadsheet used to manage the assets. The 

Management Assistant is also responsible for storing spare devices and distributing the PCDs 

to employees, as well as receiving broken or older devices from employees for disposal. 

According to the ITD Management Assistant, once a number of old or broken devices are 

accumulated, they are passed to another ITD staff member for destruction. The ITD 

Management Assistant also reviews and approves the monthly invoices for payment. The 

ITD Management Assistant’s direct supervisor does not review the monthly AT&T invoices 

to determine whether assets have been ordered, and does not access the Premier website to 

determine whether mobile devices have been shipped to the FEC. As such, there is 

inadequate segregation of duties and oversight of asset procurement, recording, distribution, 

storage and disposal. The lack of segregation of duties and insufficient management 

oversight creates a risk of asset fraud, waste and abuse. Assets could be obtained without 

management knowledge and removed from the agency for personal use and/or financial gain. 

Recommendation 

3e. Segregate the following program functions among three or more ITD staff: 

•	 Purchasing/ordering and recording assets; 

•	 Authorization for purchases, including devices received free under upgrade 

promotion; 

•	 Receipt, storage, and distributing of assets; and 

•	 Destruction or disposal of surplus PCDs. 

Management Response 

“ITD currently has three separate IT staff personnel involved in separate duties, one 

to authorize purchase, one for the recording of devices, and one to distribute the 

devices. Policy 58.4-4 will be updated to reflect the staff duties.” 

OIG Comment 

During the period of audit, the OIG identified weak internal controls regarding the 

proper segregation of duties for managing the PCDs. ITD’s Policy 58-4.4 should be 

updated to identify the ITD personnel who will be responsible for obtaining PCDs 

online with AT&T; authorizing purchases, to include free devices under upgrade 

promotions; receiving, storing, and distributing PCDs; and the disposal and 

destruction of surplus PCDs. 

41 
Fleet Vehicles and Fleet Charge Cards 

4. Fleet Vehicles and Fleet Charge Card Program Controls 

In 2006, FEC Admin management was alerted to possible employee abuse of agency leased 

fleet vehicles. After conducting a review, program management determined an employee 

used agency vehicles for personal use. The employee subsequently resigned from the FEC. 

Two of the four leased vehicles were returned to GSA after management determined the 

vehicles were no longer needed. In addition, abuse of fleet charge cards was suspected but 

not proven because the abuse could not be directly associated with one or more individuals. 

Currently, there are not sufficient management controls in place to detect or prevent 

employee fraud, waste and abuse of fleet vehicles and fleet charge cards. Further, there are 

not sufficient controls to detect and correct mileage reporting errors by agency staff, or 

billing errors by GSA Fleet Services. During the audit, the following control weaknesses 

were noted for the billing periods September 2006 through September 2009: 

•	 Admin staff tasked with driving fleet vehicles maintained trip logs from March to 

September 2006, but did not record mileage for each trip. Except for logs used for 

five days in September 2006, the forms used to log driving activity did not contain a 

field to record mileage per trip, therefore program management could not compare 

actual miles driven to expected mileage, to detect or prevent employee abuse. 

According to Admin staff, program management did not review the logs and vehicle 

trip logs are no longer created or maintained by Admin drivers. Further, the OGC 

Investigators maintain a trip log but do not record miles driven per trip. The OGC log 

documents vehicle sign-out by Admin staff who also use the vehicle occasionally to 

meet agency business needs, but not the trip detail. The OGC log is not provided to 

Admin management for use in building an expectation of monthly use and 

comparison to mileage reported to GSA for monthly billing. 

•	 Admin management does not monitor actual miles driven or fuel efficiency results, 

both of which could highlight employee vehicle abuse. Based on a review of 

standard driving patterns, expected use for the agency van is approximately 215 miles 

per month based on 22 business days. The table below shows the expected mpg 

return for city driving and actual results for the leased vehicles from November 2006 

through December 2009, for the period that the vehicle was leased by the agency. 

42 
 

 

 

 

Agency Leased 

Vehicle 

Date 

Leased 

Date 

Disposed 

Expected 

MPG City 

Unleaded 

Expected 

MPG City 

Flex Fuel 

Minimum 

MPG 

Maximum 

MPG 

Average 

MPG 

2001 Chevy 

Cavalier 

11 May-08 20 18 15.67 15.85 15.76 

2008 Chevy 

Impala 

May 

2008 in service 18 14 12.46 18.41 14.82 

2000 Dodge 

Caravan 11 Apr-09 18 n/a 5.18 16.99 11.32 

2009 Dodge 

Caravan 

April 

2009 in service 17 11 9.84 14.45 12.02 

As shown, mpg return varied significantly for the 2000 Dodge Caravan. 

•	 An Administrative staff member, who is also a driver, has responsibility for reporting 

the mileage driven each month to GSA. Fleet costs are based on a monthly fixed 

lease rate, plus fixed mileage rate times the miles driven per month, 19 and 20.5 cents 

per mile for the sedan and van respectively in FY 2009.12 Program management does 

not verify the accuracy of the mileage reported to GSA by the drivers or verify that 

miles reported and billed are within tolerance of expected vehicle use for legitimate 

business needs. Large errors in mileage reporting for one agency vehicle occurred in 

July, August and September 2006 as noted in the following table (Ford Taurus sedan 

tag G11 10857). 

Billing Period Ford Reported Miles 

Driven 

Ford Lease Cost 

For Month 

Total Invoiced All 

Vehicles 

July 2006 -8,697 ($ 1,550.91) ($ 476.54) 

August 2006 27 $ 262.37 $ 871.20 

September 2006 9,738 $ 1,798.80 $ 2,516.26 

Currently, agency staff uses the telephone to report starting and ending mileage for 

each vehicle to GSA monthly. Data is input using a telephone key pad and the 

method does not allow the employee to visually confirm the mileage details input for 

reasonableness. It is likely that keying errors produced the variances shown above. 

The reporting errors created billing variances that exceeded standard monthly lease 

charges by more than 200 percent. The FEC pays for the services under an IntraGovernmental Payment and Collections (IPAC) agreement. Generally, the funds are 

11 Specific dates vehicles were leased is not known and was not needed for audit testing.
 12 Fleet lease rates change annually. For FY 2010, the mileage rate decreased to .17 and .185 per mile, and the 

monthly lease rates decreased from $233 to $224 (sedan) and $215 to $207 (van) per month. The fuel surcharge 

changed to a flat rate of $14.00 per month per vehicle. 

43 
transferred to GSA two to three weeks before the FEC receives an invoice of services. 

Typically, mileage reporting errors are corrected in the next month when a correct 

closing mileage value is entered. However, in the 2006 case, the mileage and vehicle 

costs were not correctly reported until the third month, when the vehicle was returned 

by the FEC to GSA as a vehicle no longer needed by the agency. 

•	 Admin drivers sign out the fleet charge card and provide receipts for purchases to 

Admin staff for recordkeeping. OGC drivers maintain the fleet charge cards assigned 

to the sedan and maintain the receipts for charges. OGC staff does not provide a copy 

of receipts to Admin staff for recordkeeping, and instead OGC maintains their own 

file for the fleet vehicle under their control. Admin management does not obtain and 

review a report of fleet charge card activities from GSA to determine whether all 

charges to the fleet charge cards are reported by the drivers. Further, Admin 

management does not use the information available from the fleet charge report to 

compute mpg return on the vehicles and review for suspicious transactions, such as: 

 charges made at fueling stations far from standard locations in downtown DC, 

 short fueling or fueling vehicle when only half empty, 

 purchases for other than fuel, routine maintenance, or car washes, 

 purchases on nights, weekends or other than standard work hours. 

Through the OIG’s discussion with GSA account representatives, agencies have access to all 

fleet data through the GSA Drive-Thru on-line reporting system. Agency management can 

access data on charge card activity using the “Carry-out” downloadable report features of the 

GSA website. GSA transitioned from Voyager Fleet Card Services to Write-Express (WEX) 

as of November 1, 2008. The WEX data includes a field showing the mpg return calculated 

at each fueling. 

Ineffective operating controls increase the likelihood that employee abuse of fleet assets will 

not be detected and corrected immediately. The Federal Managers’ Financial Integrity Act 

of 1982 (FMFIA) requires the Government Accountability Office (GAO) to issue standards 

for internal control in government. According to the Standards for Internal Control in the 

Federal Government issued by GAO November 1999: 

•	 Management and employees should establish and maintain an environment throughout 

the organization that sets a positive and supportive attitude toward internal control and 

conscientious management. 

•	 Internal control should provide for an assessment of the risks the agency faces from 

both external and internal sources. 

•	 Internal control activities help ensure that management’s directives are carried out. 

The control activities should be effective and efficient in accomplishing the agency’s 

control objectives. 

•	 Internal control and all transactions and other significant events need to be clearly 

documented, and the documentation should be readily available for examination. The 

44 
 

 

 

documentation should appear in management directives, administrative policies, or 

operating manuals and may be in paper or electronic form. All documentation and 

records should be properly managed and maintained. 

There has been frequent change in program management for the Administrative Division, the 

business area responsible for managing leased vehicles and the associated fleet charge cards. 

Management has not implemented effective internal controls and lacks adequate policies and 

procedures. Current management may not be aware of past program weaknesses and the 

need to implement a strong control framework to prevent and detect potential abuse in the 

future. Without adequate internal controls, the program management may not detect fraud, 

waste and abuse of agency fleet charge cards or leased vehicles. 

Recommendations 

Admin management should implement the following controls to prevent and detect employee 

abuse of the fleet vehicles and fleet charge card programs and to ensure accurate vehicle and 

gas charge card activities. 

4a. Require drivers to document all use of vehicles through trip logs that record driver 

name, trip locations, and miles driven for each use of the vehicles, including OGC. 

Logs should be maintained for each vehicle and periodically reviewed by

 management. 

 Management Response 

“Agree with recommendation – Each vehicle will be outfitted with a trip log book to 

 record each trip.” 

 OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

4b. Establish an expectation of fleet vehicle use based on agency needs. Review and 

revise the estimate based on changes in standard routes and frequency of courier runs. 

 Management Response 

“Disagree with recommendation – It has been determined based upon past history, 

that 2 fulltime vehicles will satisfy the agency needs to transport VIP’s 

(Commissioners, Staff Director, OGC, and IG) and their staff in support of agency 

business needs. This transportation will offset local travel claims (cab expenses, 

metro fares, bus tokens, etc.). This transportation will also offset investigators local 

travel expenses, as well as local travel needs of the OIT. The Administrative Services 

Division will review the usage log books of each vehicle and reassess agency need 

based on actual usage.”

 OIG Comment 

The OIG does not disagree with the agency’s decision to have two full-time 

government vehicles to satisfy agency needs. Instead, the OIG’s recommendation 

45 
 

 

 

 

 

involves management developing an expectation of what the mileage driven each 

month should be compared to what drivers may report in the logs for each vehicle, in 

order to detect vehicle misuse. The process of establishing an expectation requires 

management to first have an understanding of the actual driving distances for 

standard FEC trips, such as the daily Capital Hill run and twice monthly trips to the 

FEC’s security contractor, and then also the expected number of occurrences per 

month. Then, based on the understanding of the expected number of occurrences and 

established actual driving distances, management can review the vehicle logs and 

determine whether the data reported by the drivers is reasonable and accurate. 

Without an expectation of what should be reported, management will not be able to 

detect abuse or inaccurate reporting by drivers. 

4c. Segregate responsibility for monthly mileage reporting to GSA from those 

responsible for driving and maintaining agency vehicles. 

 Management Response 

“Agree. The Administrative Services Division management analyst will be 

responsible for reporting monthly mileage to GSA, while the Office Services Branch 

will be primarily responsible for driving and maintaining agency assets.”

 OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

4d. Use the GSA on-line systems to report mileage each month. This would ensure 

values reported can be viewed and any errors corrected prior to submitting the final 

 mileage. 

 Management Response 

“Agree. The ASD will take advantage of the on-line GSA systems to report mileage.” 

 OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

4e. Require employees maintain and submit all documentation relating to fleet charge 

card use, including charges for fuel, routine and major maintenance. Review GSA 

activity reports to ensure all documentation relating to charges is provided by staff, 

 including OGC. 

 Management Response 

“Agree. The ASD will take responsibility to maintain and submit all receipts 

resulting from charges to the fleet charge card use.” 

46 
 

 

OIG Comment 

Management’s response reflects agreement on one portion of the recommendation. 

Comparison of charge card receipts to actual GSA activity reports is also necessary to 

ensure all documentation relating to charges is provided by staff, and that fleet charge 

cards have not been misused. 

4f. At least quarterly, access GSA systems, download fleet charge card activity reports, 

and monitor agency fleet activity for abnormal charges and fleet vehicle mpg results. 

Log-on and passwords are provided by GSA and a handbook on system use is also 

available on the GSA website. 

 Management Response 

“Agree. ASD will make full use of the GSA charge card system to complete all 

necessary records, and consistent management monitoring of use.” 

 OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

4g. Research and resolve unexpected or unusual fleet charge transactions, miles driven, 

or mpg results. Admin management should maintain the activity reports, driver logs 

and other records used to monitor program activity as evidence that adequate controls 

are in place and regular supervisory review occurs. 

 Management Response 

“See answer above.” 

 OIG Comment 

Agency’s planned actions are responsive to the audit issue identified and, when fully 

implemented, should satisfy the intent of the audit recommendation. 

5. Fleet Vehicle Driver Qualification and Verification 

The FEC does not have business processes or written guidance in place to ensure employees 

with access to fleet vehicles are both qualified and authorized to operate those vehicles, in 

accordance with federal regulations. Several employees with access to fleet vehicles do not 

have the requirement to possess and maintain a valid license included in their position 

descriptions. While most Admin employees with driving responsibilities have position 

descriptions defining that “the incumbent must have a valid driver’s license and maintain a 

good driving record,” position descriptions for other employees with access to fleet vehicles 

lack the necessary licensing requirement. Further, although the driving qualifications may 

have been verified when the employees were hired, no evidence of such verification was 

provided to the auditors. No subsequent verification that employee driver qualifications have 

been maintained was performed by the FEC. Specifically, program management was unable 

to locate evidence of driving qualification verification for three employees hired in 2003, 

2005, and 2009, respectively, who have access to fleet vehicles. 

47 
5 CFR§ 930.101-115 “governs agencies in authorizing employees to operate Governmentowned or leased (acquired for other than short term use for which the Government does not 

have full control and accountability) motor vehicles for official purposes within the States of 

the Union, the District of Columbia, Puerto Rico, and the territories and possessions of the 

United States.” The following bullets detail the regulatory requirement to ensure employees 

with access to Government owned or leased vehicles are qualified to drive the vehicles and 

periodically reviewed to ensure the qualification is maintained. The complete federal 

regulation is included as Attachment 2 to this report beginning on page 66. According to the 

regulations, agencies must: 

•	 establish an efficient and effective system to identify those federal employees who are 

qualified and authorized to operate Government-owned or -leased motor vehicles 

while on official government business; 

•	 periodically review the competence and physical qualifications of these federal 

employees to operate such vehicles safely; 

•	 ensure medical evaluations of employees who operate leased vehicles at least once 

every four years; 

•	 review each employee's authorization to operate Government-owned or -leased motor 

vehicles at least once every four years; 

•	 ensure applicants for motor vehicle operator positions must meet minimum 

requirements for positions to include: 

 possess a safe driving record; 

 possess a valid State license; 

 except as provided in §930.107, pass a road test; and 

 demonstrate that they are medically qualified to operate the appropriate motor 

vehicle safely. 

Based on interviews with Administrative Services staff, FEC program management is 

unaware of the federal requirement to verify qualifications of employees who use agency 

leased vehicles. Further, the agency lacks policies and procedures to ensure compliance with 

the federal regulations. The FEC is not compliant with federal regulations and is exposed to 

increased risk of litigation if an employee operating a leased vehicle is involved in an 

accident. 

Recommendations 

5a. Position descriptions for all employees who currently have access to agency leased 

vehicles should be evaluated and revised to include a clear requirement to possess and 

maintain a valid license to operate the vehicle and that the employee will be subject to 

regular qualification verification. 

Management Response 

“Disagree -- FEC personnel that have a need to operate a fleet vehicle are identified 

on an as needed basis. The requirement to operate a fleet vehicle is a valid state 

operator’s license and need. Not all PD’s can or will be specifically identified as the 

48 
 

 

only criteria to operate a fleet vehicle. Situations arise that are not previously 

identified in a PD.” 

OIG Comment 

According to the regulation, any employee given access to government owned or 

leased vehicle is subject to qualification verification. We do not feel it is reasonable 

to conduct driver qualification verification at the time an employee requests use of a 

vehicle, because the process requires obtaining information from a state licensing 

authority and may take days to obtain. In order to ensure employee qualification 

reviews are performed at least every four years as described in the regulation, 

management should include the element in the position descriptions and maintain a 

schedule of employees authorized to access agency vehicles, date last verification was 

performed, and the date next verification is due. The OIG recognizes situations arise 

that are not previously identified in a position description. In these cases, FEC must 

adhere to the regulation or provide alternate transportation. 

5b. FEC program management should ensure all employees who have access to fleet 

vehicles are currently qualified to operate the vehicles. Management may accomplish 

this in a number of ways. One option would be to require the employees obtain an 

official driving record from the Department of Motor Vehicles from the state in 

which they are licensed and/or the District of Columbia13. Management should 

research and contact various authorities to determine the best approach to ensure full 

verification is performed for all employees with access to fleet vehicles. 

Management Response 

“Disagree with recommendation – FEC operators will comply with existing 

regulations. Qualifications of driver's such as medical conditions and validity of 

driver's licenses will be monitored on a random basis. This monitoring will consist of 

asking driver's if they meet the qualifications and perhaps physical agency check if 

required.” 

OIG Comment 

The management response provided does not ensure compliance with 5 CFR§ 

930.101-115, and is therefore unresponsive. The regulation requires management to 

perform verification activity on all employees granted access to drive government 

owned or leased vehicles at specified intervals and also requires employees self report 

physical or legal impairments to operating a motor vehicle. The process should not 

be limited to a verbal request to view an employee’s license, or making a copy of the 

license presented by an employee as proof of driver qualifications. Program 

management is expected to request and receive evidence of driver qualification for 

each employee granted access to FEC leased vehicles by obtaining employee driving 

records from the Department of Motor Vehicles in the state in which the employee is 

licensed. Program management should maintain support that all driver qualification 

verification activities have been performed in accordance with the regulation. 

13 Program management should gain an understanding of licensing requirements and the inter relationship 

between the states and the District of Columbia. 

49 
5c. FEC program management should design and implement a process to ensure regular 

qualification verification is performed in accordance with the federal regulations and 

that employees report all matters that may impact their driving qualifications. 

Guidance is provided in the GSA Internal Fleet Handbook as on establishing 

qualification verification activities and defining operator requirements. 

Management Response 

“The FEC will comply with existing regulations.” 

OIG Comment 

The management response provided does not indicate whether management agrees to 

implement the recommendation. The OIG continues to believe FEC program 

management should design and implement a process to ensure regular qualification 

verification is performed in accordance with the federal regulations and that 

employees report all matters that may impact their driving qualifications. 

50 
 

 

CONCLUSIONS 

Audit testing shows management should review and consider revising the internal control 

system for personal communication devices (PCD), fleet vehicles, and fleet charge cards. The 

Standards for Internal Control in the Federal Government issued by GAO (November 1999) 

requires FEC management to maintain a positive attitude and culture of internal control, 

assess program risk, design internal control activities linked to program directives and 

policies, and document program activity and management’s review of the activity. For 

FEC’s PCDs, fleet vehicles, and fleet charge cards, management needs to establish, 

strengthen and improve these internal control standards. 

The strongest internal control for the PCD program would be to assign responsibility and 

accountability for overall program management to one individual in a single business area. 

This individual should be accountable for researching and evaluating service providers, 

assessing employee needs, evaluating PCD usage levels, and properly segregating the 

purchase; tracking; distribution; and destruction of PCDs to ensure they are not subject to 

fraud, waste or abuse. 

Also, the PCD program should be governed by one comprehensive policy for all PCD users. 

Program management should revise existing policies and procedures and amend the processes 

for requesting devices, documenting business justification, approving requests for devices, 

defining personal use standards, and incorporate Internal Revenue Service (IRS) regulations 

governing cell phones as a potential taxable fringe benefit to employees. 

Management should establish policies and procedures for the use of fleet vehicles and fleet 

charge cards. The policies and procedures should contain adequate internal controls to 

address the previous occurrences of abuse and reduce the risk for future employee fraud 

waste, or abuse. Management should also implement and document business processes that 

require FEC authorized drivers to be in compliance with federal regulations. OIG has 

provided management with the GSA Internal Fleet Handbook as sample guidance for 

establishing qualification verification activities and defining motor vehicle operator 

requirements. 

The OIG is confident that if management implements the recommendations of this audit, the 

agency will incur significant cost savings and the internal controls over PCDs, fleet vehicles, 

and fleet charge cards will substantially improve. Management should also take the steps 

necessary to ensure these properties are being used for their intended purpose. If all PCD 

program recommendations are implemented, the maximum cost savings to the agency is 

projected to be $49,784.64 annually14. The projected savings does not account for users who 

need bundled plans (i.e. voice feature and data feature) due to FEC duties and other 

requirements such as disaster recovery, Continuity of Operations Plan (COOP), and 

emergency contacts. Management should fully assess PCD usage levels and employee 

business needs to identify and achieve the cost savings to the agency. 

14 Amount includes 57 users with no voice use or only 10 percent or less voice use over the 16 month testing 

period. 

51 
Attachment 1 Summary of Audit Findings and Recommendations 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

1. Personal Communication Device Policy and Procedures Need Improvement 

1a. Maintain one comprehensive personal 

communication device policy for all PCD users that clearly defines who has the authority to request PCD devices for other staff in their business area. 

“Agree with recommendation: Commission Bulletin 2001-11A is outdated and does not reflect updated technology and improvements in telecommunications pricing. This bulletin has been superseded by Policy 58-4.4 and Commission Bulletin 2001-11A will be rescinded. Policy 58-4.4 will be updated to include many of the recommendations of this audit.” 

Management has comprehensive pthe revised policy authority to requetheir business arereviewing the revaddresses this rec

1b. Develop and implement a Personal 

Communication Device Request Form for requesting PCDs that requires an adequate business justification for each PCD user and allows for increased flexibility for managers to select plan options (i.e. voice only or data 

only). 

“Disagree with recommendation. The request for the issuance of a PCD is at the discretion of the senior level managers, who will maintain the business justification for the personnel under their charge in accordance with Policy 58-4.4, and the requirements for disaster recovery and COOP. The method established for requesting is e-mail, no form will be established.” 

The OIG agrees wissuance of the Psenior level manatesting revealed t

not adequately incosts and options decision to justify Therefore, the OIstandard form dosenior level, and program office foThe form could aabout the PCD coa factor in the juslevel. 

1c. Require supervisors/managers to re-justify the 

business needs of current PCD users via a PCD request form. 

“Disagree with recommendation: The PCD users do not justify their business needs. The senior management team determines which key personnel requires the use of a PCD. Policy 58-4.4 will be updated to require senior management to re-certify the assigned personnel annually.” 

Based on the docaudit, we feel mathe use of a standand received elecconsistently docuperformed by sen
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

1. Personal Communication Device Policy and Procedures Need Improvement 

1d. Issue devices only after adequate justification 

and formal request has been provided and approved. 

“Disagree with recommendation: The PCD users do not justify their business needs. The senior management team determines which key personnel requires the use of a PCD. Policy 58-4.4 will be updated to require senior management to re-certify the assigned personnel annually.” 

This recommendbusiness justificaa device. We recafter adequate jusbeen provided an

1e. Maintain all request forms for PCD users in the 

agency that includes (but not limited to) the make, model, issue date, and FEC property bar code number. 

“Disagree with recommendation. No request forms will be required, however the email request from senior managers authorized to make such requests shall be maintained on file, until replaced by the annual recertification emails. The assignment of a particular unit to a particular user will be maintained in the master PCD inventory tracking system.” 

The OIG continushould maintain ainitial justificatioFurther, we recomassignment of a ddocumentation wtelephone numbewas issued to the can then be used master PCD inve

1f. Maintain one comprehensive personal 

communication device policy that clearly defines what positions and/or offices can receive PCDs without a formal request due to the employees’ position and/or required FEC duties (i.e. “base group”). 

“Agree with recommendation: Commission Bulletin 2001-11A is outdated and does not reflect updated technology and improvements in telecommunications pricing. This bulletin has been superseded by Policy 58-4.4 Commission Bulletin 2001-11A will be rescinded. Policy 58-4.4 will be updated to include many of the recommendations of this audit.” 

Although managerecommendationthe need for a popositions and/or oa formal request. the revised policy recommendation
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

1. Personal Communication Device Policy and Procedures Need Improvement 

1g. Maintain one comprehensive personal 

communication device policy that clearly identifies those in the agency with authority to approve PCD requests. 

“Agree in part with recommendation: Commission Bulletin 2001-11A is outdated and does not reflect updated technology and improvements in telecommunications pricing. This bulletin has been superseded by Policy 58-4.4 Commission Bulletin 2001-11A will be rescinded. Policy 58-4.4 will be updated to include many of the recommendations of this audit. The 

revised policy will have to be reviewed after the revision, it is agreed that the present policy must be revised.” 

Although managerecommendationthe need for a poin the agency witrequests. We loorevised policy to recommendationAgency’s planne

1h. Document the ITD re-authorization process of “Agree with recommendation: Will be audit issue identi

PCD users in ITD’s Policy 58-4.4. included in the update to Policy 58-4.4.” implemented, sho

recommendationAgency’s planne

1i. Identify who has authority to re-authorize PCD “Agree with recommendation: Will be audit issue identi

users in ITD’s Policy 58-4.4. included in the update to Policy58-4.4.” implemented, sho

recommendation
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

1j. FEC should adhere to the IRS regulations and 

revise program policies to reflect those regulations. 

“Disagree with recommendation: FEC senior management and Office of General Counsel will review IRS regulations to determine if any apply to the FEC policies regarding PCD use within the agency, and adjust our current policies to reflect current regulations. However, as discussed at the exit meeting, FEC management will hold in abeyance until further guidance issued by Commissioner of the IRS, in accordance with his statement dated 6/16/09”. 

Although the Com“requested Congrwill be no tax conemployees for pedevices such as cemployers,” the lmanagement shoadhere to current additional procedhelp ensure the pbusiness activity 

1. Personal Communication Device Policy and Procedures Need Improvement 

1k. Provide the policies and procedures for the use 

of PCDs to all PCD users when issuing a device. 

“Neither agree nor disagree here is what we will do: All policies and directives are maintained in a shared folder and is accessible to all FEC personnel. All users will be directed to that folder so they may review applicable directives.” 

Agency’s planneaudit issue identiimplemented, shorecommendation

2. Personal Communication Device Program Monitoring 

2a. All unassigned devices should be suspended or 

service should be terminated if the device can not be immediately transferred to another user (no active spares kept in ITD). ITD retains a minimum of 10 inactive spare devices and a spare SIM. If required, a device could be activated within 24 hours. 

“Disagree with recommendation. ITD has in the past allowed too many devices to be at the ready, however there is a real need to maintain a minimum number of devices at the ready for immediate use in the event of a catastrophic or emergency situation and the non availability of personnel that has the authorization to activate a device. ITD will keep a minimum of three devices activated for use by any personnel designated by proper authority at a moments notice. This policy will be incorporated in the updated FEC PCD Policy.” 

The OIG continueliminate, or minpossible, the numdevices. It is improll-out of portabhelp alleviate the unassigned active 
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

2b. Devices assigned to employees based on 

temporary roles should be recovered when the employee is no longer in the temporary position. 

“Agreed. Project management personnel will more closely monitor PDC’s that are no longer in use.” 

Agency’s planneaudit issue identiimplemented, shorecommendation

2. Personal Communication Device Program Monitoring 

2c. Review the audit testing results for users with 

very limited or no usage and determine if an 

actual business need exists to retain the device. If a valid need exists, ensure the employee still has the device, it is serviceable, and the employee understands how to use the device. 

“Disagree with recommendation. It has been determined by senior FEC management that in order to properly conduct continuous business, while both in the local FEC geographical area, or on travel in the conduct of official or nonofficial business, or in the event of a disaster, or emergency that certain key 

personnel are required to be in communication with FEC officials. These key personnel will be identified by the authorizing senior level FEC managers without question from ITD program administrators. Policy 58-4.4 will be updated to reflect the annual certification by senior level management will be used to determine that the persons assigned a PCD, are to continue to be authorized to use FEC PCD. The employees issued PCD’s will be issued them in accordance with Policy 58-4.4, it is up to the individual managers to ensure that the employees understand how to use the device, ITD training personnel are available to assist the managers in this endeavor. The authorization, use, care, and individual accountability for the devices is not the responsibility of the ITD.” 

The OIG recognisome employees, exhibited, will be business continuimanagement may some employees believes that a decarried with empserviceable, will intended businesgovernment fundreview the historwith very limited actual business na valid need existthe device, it is seunderstands how 
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

2. Personal Communication Device Program Monitoring 

2d. Document the requestor’s expected need for a 

PCD (i.e. e-mail only, phone communication, e-mail and phone) through a request form to determine which plan feature(s) best fit the requestor’s business need (i.e. data only plan, voice only, or bundled plan). 

“Disagree with the recommendation. The FEC has one and only one plan based upon the desires from the senior level management, that all personnel issued a PCD have the capability for voice, data, and text communication. In order to accommodate these criteria, the ITD assisted the contracting officer in plan and device selection. It has been determined by FEC senior management that in order to be able to respond to any catastrophic or emergency situation, that all FEC PCD user’s are able to access or be accessed through voice, data transmission or texting. This approach to emergency preparedness as well as the efficient conduct of daily business transactions has been deemed by senior FEC management to be the most effective use of the agency budget for this type of communication system.” 

The OIG understAT&T service pladjusted to add oagency’s needs athe agency. The whose plan has bThe OIG’s Emplo

with the OIG’s auagency pays monusers who do not recommend that managers/supervtheir staff with thbusiness needs of 

2e. Notify managers during the reauthorization 

process of the ability to revise PCD plan options in the future to appropriately support the PCD user’s business need (i.e. if the user requests a data and voice plan but only uses data, their standard service can be reduced to a data only plan). 

“See response above. The FEC has one plan for all users.” 

The OIG understAT&T service pladjusted to add oagency’s needs athe agency. 

2f. PCD user information should be kept up to date 

and adjusted in a timely manner on the ITD master Blackberry listing and the AT&T Premier website for employee separations and 

new assignment of devices. 

“Agree. User information will be kept up to date in a timelier manner to include the AT&T website. The Policy 58-4.4 will be updated to reflect the monitoring of the information.” 

Agency’s planneaudit issue identiimplemented, shorecommendation
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

2. Personal Communication Device Program Monitoring 

2g. Management should educate PCD users of all 

features that incur additional cost to the agency, such as:  roaming charges that result when 

employees place calls outside AT&T service areas; 

 texting;  directory assistance; and  voice use over the pooled plan limits. 

“Agreed. Since the beginning of this fiscal year (FY10) the FEC has gone to an all inclusive billing that allows each user 200 minutes of voice, pooled to avoid overage charges, unlimited data and unlimited text. The users will be kept abreast of plan changes.” 

Although managemanagement ensuplan features that as: roaming chargplace calls outsidassistance; and vlimits. 

2h. Provide the international add-on plan to the 

standard monthly service for users who frequently travel internationally for business. Require written request for the international add-on plan for PCD users who do not frequently travel internationally for business. This request should include their beginning and ending date of travel. Based on the information, the international service option should be promptly activated and terminated. 

“Agree with recommendation. When an authorized user is performing international travel, an e-mail request is submitted to the Blackberry administrator with the period of international travel. The administrator then activates international add-on plan for the period requested. When the traveler returns, an email is sent to terminate the international add-on plan. The email communication is the only communication required, no form will be necessary.” 

ITD should ensurdates of travel are e-mail requests to plans. Also, the Mresponsible for acplan for users shoensure timely teradd-on plan servitravel. 

2i. ITD’s Management Assistant should annually 

monitor monthly PCD usage to asses if the current plan should be adjusted to appropriately meet user needs. 

“Agreed. This action is performed by the contracting officer at the time of contract renewal.” 

Management’s reis performed at thcontracting officethe ITD Managemmonthly PCD usacurrent plan shoumeet agency needmonthly invoices plan features and 
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

2. Personal Communication Device Program Monitoring 

2j. Prior to renewing PCD services or switching 

service plans, the Contracting Office, in consultation with the PCD Program Office, should conduct and document analysis of service plans offered by the current provider and other potential vendors on the GSA schedule to achieve best value for the agency. Further, the Contracting Office should discuss actual plan details and agency use with PCD program office and ensure any negotiated service options, such as free texting, are included in quotes from potential vendors. 

“This action is the responsibility of the contracting officer and is conducted in accordance with the requirements of the FAR. The contracting officer routinely takes this action on each and every contract action he authorizes, as required by law.” 

The OIG continuinterest of the ageof contact), workto conduct markequotes prior to awagreement (BPA) communication dcurrent contract iAccording to the policies and procresponsibility to performed for all expenditure of apto the FEC Procufollowing BPA Rcoordinated via tthe appropriate P

Internal Control The contracting oshallA. Ensure each Bnecessary updateinformation at thB. If the BPA is uthe most recent Gbeen distributed inserted in the filC. Maintain awaconditions, sourcfactors that may arrangements wimodifying existin

15 Point of Contact (POC) and Contracting Officer’s Technical Representative (COTR) 
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

3a. Adhere to Commission Bulletin 2006-04 and 

track personal communication devices in the Fixed Asset System and apply barcodes to all devices. 

“Since Commission Bulletin 2006-04 address mainly cell phone and pagers, and modern PCD’s it shall be rescinded and replaced with Policy58-4.4. Policy58-4.4 is in processed of being revised to include some of the recommendations contained in this audit, and to provide additional clarity.” 

Management’s rewhether they agrrecommendation disagreement. 

3b. Document and enforce the policies and “Policy 58-4.4 is in processed of being Management’s re

procedures for issuing a new or upgraded revised to include some of the whether they agr

device to an FEC PCD user, including return of recommendations contained in this audit, recommendation 

3. Tracking and Managing Personal Communication Devices 

previously issued device(s). and to provide additional clarity.” disagreement. 

3c. ITD staff coordinate with GSA and implement 

processes and procedures to ensure:  devices no longer needed are made 

available to other government agencies or non-profit organizations; and 

 obsolete or broken devices are disposed in 

a manner that is not detrimental to public health. 

“Policy 58-4.4 shall be updated to reflect that all devices that are broken, obsolete, or have reached the end of the FEC service life shall be turned into GSA.” 

Agency’s planneaudit issue identiimplemented, shorecommendation

3d. ITD should implement a form and process, Management’s re

such as the NIST Sample Sanitization “Preparation for disposal of all PCD’s whether they agr

Validation Form, to record sanitization shall be in accordance with existing recommendation 

(wiping) of devices, disposal and/or provisions of Policy 58.” disagreement. 

destruction, as appropriate. 
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

3. Tracking and Managing Personal Communication Devices 

3e. Segregate the following program functions 

among three or more ITD staff:  Purchasing/ordering and recording assets; 

 Authorization for purchases, including 

devices received free under upgrade promotion; 

 Receipt, storage, and distributing of assets; 

and 

 Destruction or disposal of surplus PCDs. 

“ITD currently has three separate IT staff personnel involved in separate duties, one to authorize purchase, one for the recording of devices, and one to distribute the devices. Policy 58.4-4 will be updated to reflect the staff duties.” 

During the period weak internal consegregation of duITD’s Policy 58-the ITD personneobtaining PCDs opurchases, to inclpromotions; recePCDs; and the diPCDs. 

4. Fleet Vehicles and Fleet Charge Card Program 4a. Require drivers to document all use of vehicles Controls through trip logs that record driver name, trip 

locations, and miles driven for each use of the vehicles, including OGC. Logs should be maintained for each vehicle and periodically reviewed by management. 

“Agree with recommendation – Each vehicle will be outfitted with a trip log book to record each trip.” 

Agency’s planneaudit issue identiimplemented, shorecommendation
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

4. Fleet Vehicles and Fleet Charge Card Program Controls 

4b. Establish an expectation of fleet vehicle use 

based on agency needs. Review and revise the estimate based on changes in standard routes and frequency of courier runs. 

“Disagree with recommendation – It has been determined based upon past history, that 2 fulltime vehicles will satisfy the agency needs to transport VIP’s (Commissioners, Staff Director, OGC, and IG) and their staff in support of agency business needs. This transportation will offset local travel claims (cab expenses, metro fares, bus tokens, etc.). This transportation will also offset investigators local travel expenses, as well as local travel needs of the OIT. The Administrative Services Division will review the usage log books of each vehicle and reassess agency need based on actual usage.” 

The OIG does nodecision to have vehicles to satisfy OIG’s recommendeveloping an exdriven each montdrivers may repoorder to detect veestablishing an exto first have an udriving distances the daily Capital to the FEC’s secuexpected number Then, based on thnumber of occurrdriving distancesvehicle logs and reported by the dWithout an expecreported, manageabuse or inaccura

4c. Segregate responsibility for monthly mileage 

reporting to GSA from those responsible for driving and maintaining agency vehicles. 

“Agree. The Administrative Services Division management analyst will be responsible for reporting monthly mileage to GSA, while the Office Services Branch will be primarily responsible for driving and maintaining agency assets.” 

Agency’s planneaudit issue identiimplemented, shorecommendation

4d. Use the GSA on-line systems to report mileage 

each month. This would ensure values reported can be viewed and any errors corrected prior to submitting the final mileage. 

“Agree. The ASD will take advantage of the on-line GSA systems to report mileage.” 

Agency’s planneaudit issue identiimplemented, shorecommendation
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

4. Fleet Vehicles and Fleet Charge Card Program Controls 

4e. Require employees maintain and submit all 

documentation relating to fleet charge card use, 

including charges for fuel, routine and major maintenance. Review GSA activity reports to ensure all documentation relating to charges is provided by staff, including OGC. 

“Agree. The ASD will take responsibility to maintain and submit all receipts resulting from charges to the fleet charge card use.” 

Management’s reone portion of the 

of charge card rereports is also nedocumentation restaff, and that flemisused. 

4f. At least quarterly, access GSA systems, 

download fleet charge card activity reports, and monitor agency fleet activity for abnormal charges and fleet vehicle mpg results. Log-on and passwords are provided by GSA and a handbook on system use is also available on the GSA website. 

Agree. ASD will make full use of the GSA charge card system to complete all necessary records, and consistent management monitoring of use.” 

Agency’s planneaudit issue identiimplemented, shorecommendation

4g. Research and resolve unexpected or unusual 

fleet charge transactions, miles driven, or mpg results. Admin management should maintain the activity reports, driver logs and other records used to monitor program activity as evidence that adequate controls are in place and regular supervisory review occurs. 

“See answer above.” 

Agency’s planneaudit issue identiimplemented, shorecommendation
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

5. Fleet Vehicle Driver Qualification and Verification 

5a. Position descriptions for all employees who 

currently have access to agency leased vehicles should be evaluated and revised to include a clear requirement to possess and maintain a valid license to operate the vehicle and that the employee will be subject to regular qualification verification. 

“Disagree -- FEC personnel that have a need to operate a fleet vehicle are identified on an as needed basis. The requirement to operate a fleet vehicle is a valid state operator’s license and need. Not all PD’s can or will be specifically identified as the only criteria to operate a fleet vehicle. Situations arise that are not previously identified in a PD.” 

According to the access to governmare subject to quanot feel it is reasoqualification verirequests use of a requires obtaininlicensing authoritIn order to ensure are performed at described in the rinclude the elemeand maintain a scto access agency was performed, adue. The OIG renot previously idIn these cases, FEor provide alterna
Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response 

5. Fleet Vehicle Driver Qualification and Verification 

5b. FEC program management should ensure all 

employees who have access to fleet vehicles are currently qualified to operate the vehicles. Management may accomplish this in a number of ways. One option would be to require the employees obtain an official driving record from the Department of Motor Vehicles from the state in which they are licensed and/or the District of Columbia. Management should research and contact various authorities to determine the best approach to ensure full verification is performed for all employees with access to fleet vehicles. 

“Disagree with recommendation – FEC operators will comply with existing regulations. Qualifications of driver's such as medical conditions and validity of driver's licenses will be monitored on a random basis. This monitoring will consist of asking driver's if they meet the qualifications and perhaps physical agency check if required.” 

The management ensure compliancand is therefore urequires managemactivity on all emgovernment ownintervals and also physical or legal motor vehicle. Tto a verbal requeor making a copy employee as prooProgram managereceive evidence employee granted by obtaining empDepartment of Mwhich the employ

management shodriver qualificatiobeen performed iregulation. 

5c. FEC program management should design and The management 

implement a process to ensure regular indicate whether qualification verification is performed in implement the reaccordance with the federal regulations and that employees report all matters that may impact their driving qualifications. Guidance is 

“The FEC will comply with existing regulations.” 

continues to belieshould design anregular qualificat

provided in the GSA Internal Fleet Handbook accordance with as on establishing qualification verification employees report 

activities and defining operator requirements. their driving qual
 

 

 

Attachment 2 5 CFR§ 930 Subpart A - Motor Vehicle Operators 

 Title 5: Administrative Personnel 

PART 930—PROGRAMS FOR SPECIFIC POSITIONS AND EXAMINATIONS (MISCELLANEOUS) 

Subpart A —Motor Vehicle Operators 

Authority: 5 U.S.C. 3301, 3320, 7301; 40 U.S.C. 491; E.O. 10577, 3 CFR, 1954–1958 Comp., p. 

218; E.O. 11222, 3 CFR, 1964–1965 Comp., p. 306. (Separate authority is listed under §930.107). 

Source: 50 FR 34669, Aug. 27, 1985, unless otherwise noted. 

§ 930.101 Purpose. 

This subpart governs agencies in authorizing employees to operate Government-owned or -leased (acquired for 

other than short term use for which the Government does not have full control and accountability) motor vehicles 

for official purposes within the States of the Union, the District of Columbia, Puerto Rico, and the territories and 

possessions of the United States. 

§ 930.102 Definitions. 

In this subpart: 

Agency means a department, independent establishment, or other unit of the executive branch of the Federal 

Government, including a wholly owned Government corporation, in the States of the Union, the District of 

Columbia, Puerto Rico, and the territories and possessions of the United States. 

Employee means an employee of an agency in either the competitive or excepted service or an enrollee of the 

Job Corps established by section 102 of the Economic Opportunity Act of 1964 (42 U.S.C. 2712). 

Identification card means the United States Government Motor Vehicle Operator's Identification Card, Optional 

Form 346, or an agency-issued identification card that names the types of Government-owned or -leased 

vehicles the holder is authorized to operate. 

Identification document means an official identification form issued by an agency that properly identifies the 

individual as a Federal employee of the agency. 

Incidental operator means an employee, other than one occupying a position officially classified as a motor 

vehicle operator, who is required to operate a Government-owned or -leased motor vehicle to properly carry out 

his or her assigned duties. 

Motor vehicle means a vehicle designed and operated principally for highway transportation of property or 

passengers, but does not include a vehicle (a) designed or used for military field training, combat, or tactical 

purposes; (b) used principally within the confines of a regularly established military post, camp, or depot; or (c) 

regularly used by an agency in the performance of investigative, law enforcement, or intelligence duties if the 

head of the agency determines that exclusive control of the vehicle is essential to the effective performance of 

those duties. 

Operator means an employee who is regularly required to operate Government-owned or -leased motor vehicles 

and is occupying a position officially classified as motor vehicle operator. 

Road test means OPM's Test No. 544 or similar road tests developed by Federal agencies to evaluate the 

competency of prospective operators. 

66 
State license means a valid driver's license that would be required for the operation of similar vehicles for other 

than official Government business by the States, District of Columbia, Puerto Rico, or territory or possession of 

the United States in which the employee is domiciled or principally employed. 

§ 930.103 Coverage. 

This subpart governs agencies in authorizing their employees to operate Government-owned or -leased motor 

vehicles for official purposes within the States of the Union, the District of Columbia, Puerto Rico, and the 

territories or possessions of the United States and establishes minimum procedures to ensure the safe and 

efficient operation of such vehicles. 

§ 930.104 Objectives. 

This subpart requires that agencies (a) establish an efficient and effective system to identify those Federal 

employees who are qualified and authorized to operate Government-owned or -leased motor vehicles while on 

official Government business; and (b) periodically review the competence and physical qualifications of these 

Federal employees to operate such vehicles safely. 

§ 930.105 Minimum requirements for competitive and excepted service positions. 

(a) An agency may fill motor vehicle operator positions in the competitive or excepted services by any of the 

methods normally authorized for filling positions. Applicants for motor vehicle operator positions and incidental 

operators must meet the following requirements for these positions: 

(1) Possess a safe driving record; 

(2) Possess a valid State license; 

(3) Except as provided in §930.107, pass a road test; and 

(4) Demonstrate that they are medically qualified to operate the appropriate motor vehicle safely in accordance 

with the standards and procedures established in this part. 

(b) Agencies may establish additional requirements to assure that the objectives of this subpart are met. 

[50 FR 34669, Aug. 27, 1985, as amended at 60 FR 3067, Jan. 13, 1995] 

§ 930.106 Details in the competitive service. 

An agency may detail an employee to an operator position in the competitive service for 30 days or less when 

the employee possesses a State license. For details exceeding 30 days, the employee must meet all the 

requirements of §930.105 and any applicable OPM and agency regulations governing such details. 

[60 FR 3067, Jan. 13, 1995] 

§ 930.107 Waiver of road test. 

Under the following conditions, OPM or an agency head or his or her designated representative may waive the 

road test: 

(a) OPM waives the road test requirement for operators of vehicles of one ton load capacity or less who possess 

a current driver's license from one of the 50 States, District of Columbia, or Puerto Rico, where the employee is 

domiciled or principally employed, except for operators of buses and vehicles used for: (1) Transportation of 

dangerous materials; (2) law enforcement; or (3) emergency services. 

67 
(b) OPM waives the road test for operators, and agencies may waive the road test for incidental operators of any 

class of vehicle, who possess a current driver's license for the specific type of vehicle to be operated from one of 

the 50 States, District of Columbia, or Puerto Rico, where the employee is domiciled or principally employed. 

(c) An agency head may waive the road test for operators and incidental operators not covered by paragraphs 

(a) and (b) of this section, but only when in his or her opinion it is impractical to apply it, and then only for an 

employee whose competence as a driver has been established by his or her past driving record. 

(5 U.S.C. 1104; Pub. L. 95–454, sec. 3(5)) 

§ 930.108 Periodic medical evaluation. 

At least once every 4 years, each agency will ensure that employees who operate Government-owned or leased 

vehicles are medically able to do so without undue risk to themselves or others. When there is a question about 

an employee's ability to operate a motor vehicle safely, the employee may be referred for a medical examination 

in accordance with the provisions of part 339 of this chapter. 

[60 FR 3067, Jan. 13, 1995] 

§ 930.109 Periodic review and renewal of authorization. 

(a) At least once every 4 years, each agency will review each employee's authorization to operate Governmentowned or -leased motor vehicles. 

(b) An agency may renew the employee's authorization only after the appropriate agency official has determined 

that the employee is medically qualified and continues to demonstrate competence to operate the type of motor 

vehicle to which assigned based on a continued safe driving record. 

[50 FR 34669, Aug. 27, 1985, as amended at 60 FR 3067, Jan. 13, 1995] 

§ 930.110 Identification of authorized operators and incidental operators. 

Agencies must have procedures to identify employees who are authorized to operate Government-owned or -

leased motor vehicles. Such procedures must provide for adequate control of access to vehicles and assure that 

the other requirements of this subpart are met. 

[50 FR 34669, Aug. 27, 1985, as amended at 66 FR 66712, Dec. 27, 2001] 

§ 930.111 State license in possession. 

An operator or incidental operator will have a State license in his or her possession at all times while driving a 

Government-owned or -leased motor vehicle on a public highway. 

§ 930.112 Identification card or document in possession. 

The operator or incidental operator will have a valid agency identification card or document (e.g., building pass or 

credential) in his or her possession at all times while driving a Government-owned or -leased motor vehicle. 

§ 930.113 Corrective action. 

An agency will take adverse, disciplinary, or other appropriate action against an operator or an incidental 

operator in accordance with applicable laws and regulations. Agency orders and directives will include the 

following reasons among those constituting sufficient cause for such action against an operator or an incidental 

operator: 

68 
(a) The employee is convicted of operating under the intoxicating influence of alcohol, narcotics, or pathogenic 

drugs. 

(b) The employee is convicted of leaving the scene of an accident without making his or her identity known. 

(c) The employee is not qualified to operate a Government-owned or -leased vehicle safely because of a 

physical or medical condition. In making such a determination, agencies should consult a Federal medical officer 

or other medical authority as appropriate. 

(d) The employee's State license is revoked. 

(e) The employee's State license is suspended. However, the agency may continue the employee in his or her 

position for operation of Government-owned or -leased motor vehicles on other than public highways for not to 

exceed 45 days from the date of suspension of the State license. 

§ 930.114 Reports required. 

An agency will submit to OPM, on request (a) a copy of agency orders and directives issued in compliance with 

this subpart; and (b) such other reports as OPM may require for adequate administration and evaluation of the 

motor vehicle operator program. 

§ 930.115 Requests for waiver of requirements. 

Agencies may request authority from OPM to waive requirements in this subpart. OPM may grant exceptions or 

waivers when it finds these waivers or exceptions are in the interest of good administration and meet the 

objectives of this program. 

[50 FR 34669, Aug. 27, 1985, as amended at 66 FR 66712, Dec. 27, 2001] 

69 
 

 

 

 

 

CONTACTING THE OFFICE OF INSPECTOR GENERAL 

The success of the OIG mission to prevent fraud, waste, and abuse depends on the

cooperation of FEC employees (and the public). There are several ways to report

questionable activity. 

Call us at 202-694-1015 (a confidential or anonymous message can be

left 24 hours a day/7 days a week) or toll-free at 1-800-424-9530 (press 0; 

then dial 1015 - Monday - Friday 8:30am – 5:00pm). 

Write or visit us - we are located at: Federal Election Commission 

 Office of Inspector General

 999 E Street, N.W., Suite 940

 Washington, D.C. 20463 

Mail is opened by OIG staff members only. 

You can also fax (202-501-8134) or contact us by e-mail at: oig@fec.gov. 

Website address: http://www.fec.gov/fecig/fecig.shtml 

Individuals may be subject to disciplinary or criminal action for knowingly making 

a false complaint or providing false information.