May 2021

Federal Election Commission

Office of the Inspector General

SEMIANNUAL

REPORT to

CONGRESS

October 1, 2020 – March 31, 2021
FEDERAL ELECTION COMMISSION

WASHINGTON, D.C. 20463

OFFICE OF THE CHAIR

May 28, 2021

The Honorable Nancy Pelosi The Honorable Kamala Harris

Speaker of the House of Representatives President of the Senate

H-232 Capitol Building S-212 Capitol Building

Washington, D.C. 20515 Washington, D.C. 20510

Dear Madam Speaker and Madam President:

Pursuant to the Inspector General Act of 1978, as amended, the Federal Election 

Commission submits the Office of Inspector General’s Semiannual Report to Congress. The 

report summarizes the activity of the FEC Office of Inspector General (“OIG”) from 

October 1, 2020 through March 31, 2021. 

During this reporting period, the FEC’s OIG completed, with the assistance of contract 

auditors, the annual audit of the FEC’s financial statements. We are pleased to report that the 

Commission received an unqualified opinion on the required statements: the FEC’s Balance 

Sheet as of September 30, 2020 and 2019, and the related Statements of Net Costs, Changes in 

Net Position, Budgetary Resources, and Custodial Activity for the years then ended. This marks 

the twelfth consecutive year with no material weaknesses identified. The auditors raised issues 

pertaining to Information Technology security that do not rise to the level of a material 

weakness, but nonetheless merit attention by the Commission. The response of FEC 

management to those issues appears in the report, which was issued on November 16, 2020. 

The Commission appreciates and shares the Office of Inspector General’s commitment to 

sound financial and management practices and looks forward to continuing its cooperative 

working relationship as management takes appropriate measures to improve operations of the 

Commission. Copies of the Semiannual Report to Congress are being provided to the Chairs and 

Ranking Members of the FEC’s oversight committees.

On behalf of the Commission,

Shana M. Broussard

Chair

Enclosure
FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

TABLE of CONTENTS

Message from the Inspector General ................................................................................................... 1

OIG Personnel Updates...................................................................................................................... 3

FEC Office of Inspector General Organization Chart....................................................................... 4

OIG Core Values.................................................................................................................................. 5

Executive Summary................................................................................................................................ 6

OIG Audit Activity ...................................................................................................................................9

Special Reviews .................................................................................................................................... 10

OIG Audit/Review Follow-up Activity .................................................................................................. 11

OIG Hotline Activity ............................................................................................................................. 14

OIG Investigative Summaries............................................................................................................... 16

Other Matters – Review of Legislation.................................................................................................18

Top Management Challenges...............................................................................................................20

Council of the Inspectors General on Integrity and Efficiency .......................................................... 21

List of Training, Meetings & Conferences ........................................................................................... 22

Reporting Requirements...................................................................................................................... 25

Table I: Inspector General Issued Reports with Questioned Costs................................................ 26

Table II: Inspector General Issued Reports with Recommended Actions

That Funds Be Spent to Better use............................................................................................... 27

Table III: Summary of Audit and Inspection Reports with Corrective Actions Outstanding......... 28

Table IV: Summary of Investigative Reports and Actions ............................................................... 29

Appendix A: Peer Review Results........................................................................................................ 30

Appendix B: Mission Statements ........................................................................................................ 32

Appendix C: FEC OIG Hotline.............................................................................................. Back Cover
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 1

Message from the Inspector General

I

t is with great pleasure that I present the Federal Election Commission 

(FEC) Office of Inspector General (OIG) Semiannual Report to 

Congress for the period of October 1, 2020 to March 31, 2021. This 

report reflects the exceptional work of the FEC OIG team and their 

commitment to the critical mission of the OIG. We are pleased to announce 

that Mr. Hung Huynh has joined the FEC OIG team as our investigator. 

We are pleased to have him on the team and trust that he will prove to be a 

great asset to the OIG and to the Commission. 

During the reporting period the OIG audit team completed and 

issued the agency’s FY20 Financial Statement audit report. Additionaly, 

we have initiated the FY21 Financial Statement and Digital Accountability 

and Transparency Act of 2014 (DATA Act) audits. The investigative team 

continues to respond to hotline complaints and investigate allegations of 

wrongdoing. Moreover, in accordance with the Inspector General Act 

of 1978, as amended (IG Act), OIG’s are required to report to Congress, as applicable, results of any peer reviews it 

received or conducted during the reporting period. Peer reviews are required for OIG audit operations, are voluntary 

for investigative operations, and are scheduled on three-year cycles. The Election Assistance Commission (EAC) OIG 

completed an audit peer review of our audit operations during the reporting period. Additionally, we have initiated an 

audit peer review of the Export-Import Bank of the United States (EXIM) OIG. 

The FEC OIG team developed its Strategic Plan for Fiscal Years 2021 through 2025, which articulates our 

vision for the next five years. We created this plan through a collaborative process, which included a candid internal 

assessment of our strengths and areas for improvement, as well as robust and candid discussions regarding the role of 

the OIG. This Strategic Plan provides the roadmap in building and supporting a high-performing team in providing 

oversight and recommending improvements to FEC programs and operations. 

During the reporting period, the President nominated, and the Senate confirmed, the appointment of three FEC 

Commissioners, ending a six-month period with no quorum. In addition, pending legislation before Congress would 

significantly modify the structure and authorities of the Commission. Accordingly, my team is closely monitoring that 

proposed legislation and its potential impacts on the economy and efficiency of FEC operations and programs.

Continued concern remains regarding the current state of the nation due to the COVID-19 pandemic. I’m 

exceptionally grateful to lead the FEC OIG team as they have adjusted to this crisis with professionalism and exuded 

a strong commitment to the mission. I look forward to continuing to work with the FEC OIG team, the Commission, 
2 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

members of Congress, and my IG colleagues to provide oversight to the FEC on behalf of the American taxpayers. 

This Semiannual Report reflects the exceptional work of the FEC OIG team and their commitment to the critical 

mission of the OIG.

Christopher Skinner

Inspector General
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 3

OIG Personnel Updates

Additions:

We are pleased to announce the addition of Mr. Hung Huynh to the FEC OIG team as our Inspector General 

Investigator. Mr. Huynh brings more than twenty years of federal government experience to the FEC OIG; ten of 

which were with other federal OIGs. Mr. Huynh completed his undergraduate degree at the University of Maryland 

at College Park and his master’s degree at the University of Maryland, University College. We are pleased to have him 

on the team and trust that he will prove to be a great asset to the OIG and to the Commission.

Farewells: 

None during this reporting period.

Vacancies:

The OIG currently has a vacant auditor position: This position will be a top priority to fill in FY 2022, pending availability 

of funding.
4 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

FEC Office of the Inspector General

Organization Chart

Filled Vacant

* Administrative Officer reports to the Deputy IG, supports all FEC OIG staff in administrative matters, and 

reports to the IG for purposes of managing the IG’s schedule and related items.

Updated: March 2021

Senior Auditor

Michael Mitchell

Senior Auditor

Shellie

Purnell-Brown

Investigator

Hung Huynh

Deputy Inspector

General

Dennis Phillips

Auditor

*Administrative

Officer

Brenda Bowie

Inspector General

Christopher Skinner

Senior Counsel

Carla Smith
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 5

Commitment

We are committed to continually seek personal 

and operational growth opportunities to 

preserve the positive reputation of the OIG. 

We pledge our dedication to persistently 

enhance our skillsets in efforts to uphold the 

integrity of the FEC.

Respect

We are devoted to creating a professional 

and positive work environment in which all 

colleagues and stakeholders are treated with 

the utmost respect. We welcome, value, and 

embrace the diversity of everyone and behave 

respectfully to all with whom we interact.

Service

We pride ourselves in providing a nonconfrontational, value-added service to 

customers through objective, accurate, and 

timely evaluations of OIG inquiries in support 

of FEC operations and procedures.

Honesty

We are honest, fair, and true to ourselves, 

to each other, and to our customers, which 

is reflected in our reputation. We behave 

with the highest levels of integrity, which is 

fundamental to who we are as a team.

Collaboration

We strive to collaborate and build key 

relationships within the OIG community 

and the FEC in order to improve program 

operations, efficiencies, and effectiveness. 

We universally work together to identify 

potential opportunities to partner with OIG 

stakeholders in efforts to resolve Government 

wide concerns and maximize the value to the 

citizens of the United States.

Balance

We aim to balance customer needs with the 

mission of the OIG and FEC while assuring 

all endeavors of our work reflect transparent 

and unbiased processes. We apply this 

practice through our application of due 

regard for our peers, our beliefs, our family, 

and our stakeholders.

Core Values
6 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Executive Summary

The Inspector General Act of 1978, as amended (IG Act), states that the Inspector General (IG) is responsible for 

conducting audits and investigations; recommending policies and procedures that promote economy, efficiency, 

and effectiveness of agency resources and programs; and preventing fraud, waste, abuse, and mismanagement. 

The IG Act requires that the IG provide a means for keeping the head of its respective establishment (i.e., the “FEC” or 

“Commission”) and the Congress fully and currently informed of problems relating to the administration of FEC programs 

and operations, through regular reports. Additionally, IG’s are required to report to their respective establishments 

particularly serious or flagrant problems, abuses, or deficiencies relating to the administration of agency programs and 

operations.

This semiannual report provides the major accomplishments of the FEC OIG, as well as relevant information 

regarding additional OIG activities. The executive summary highlights the most significant completed activities of 

the OIG from October 1, 2020 to March 31, 2021. Additional details pertaining to each activity (e.g., audits, hotline, 

investigations, and special reviews) can be found in subsequent sections of this report. The FEC OIG staff rely and act 

on its OIG Core Principles (honesty, collaboration, commitment, balance, service, and respect) and the Council of the 

Inspectors General on Integrity and Efficiency (CIGIE) standards to ensure the integrity of all FEC OIG work products.

Audits and Reviews

FY 2020 Financial Statement Audit

During this reporting period, the independent public accountants (IPA), Brown and Company completed final testing 

and issued the agency’s FY 2020 financial statement audit report. The IPA determined that the FEC’s financial 

statements were presented fairly, in all material respects. The IPA did not identify any material weaknesses that could 

have an impact on financial reporting. The report was issued on November 16, 2020. 

The IPA is required by the FEC OIG’s contract to conduct additional testing on information systems (IT) controls, 

as the FEC is exempt from the Federal Information Systems Management Act (FISMA) and is not required to perform 

the annual FISMA audit. As part of this engagement, the IPA also performs follow-up on outstanding recommendations 

related to IT controls. Based on the internal control and follow-up reviews, there are currently five control deficiencies 

(two new and three repeat findings) and six open recommendations. 

Travel Program Audit

The audit of the FEC’s travel program commenced during the previous reporting period. Due to the planned changes 

in the FEC travel procedures, specifically, the implementation of an online booking portal, the OIG has deferred this 

engagement until the new procedures are established.
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 7

Use of Transit Benefits Special Review

The report concluded that 30 employees used more than 20% of their January 2019 TRANServe benefits during a 

time when the federal government was shut down. The OIG issued a final report on July 31, 2020 with the following 

recommendations:

1. That the FEC regularly request, retrieve, and review monthly TRANServe subsidy benefit reports from 

the Department of Transportation in efforts to monitor benefit usage and prevent fraud, waste, and/or 

abuse of government funds.

2. That FEC management incorporate guidance into Commission Directive 54 that addresses transit benefits 

for furloughed and non-furloughed employees in the event of a government shutdown.

3. That FEC management include specific guidance related to the use of transit benefits during a government 

shutdown within the annual transit recertification application and within the agency PowerPoint training.

Currently, the OIG continues to follow up with management to address the three outstanding recommendations 

from this special review.

OIG Audit/Review Follow-up Activity

The OIG has the responsibility to perform follow-up assessments to ensure that management has effectively implemented 

OIG recommendations. The OIG follows up on all FEC recommendations that have been outstanding for more than 

six months and identifies the progress management has made in addressing such recommendations to date.

The OIG continues to follow up with management to address outstanding audit recommendations despite 

competing priorities and the current environment due to the COVID-19 pandemic. As a result, four recommendations 

were closed during this reporting period. There are five open audits and inspections, containing 17 outstanding 

recommendations as of March 2021 (see complete details in the OIG Audit Follow-up Activity section of this report).

Hotlines and Investigations

The OIG’s preferred method of managing its complaints is through the online hotline portal in which members of the 

public and agency employees may submit matters to the OIG. During this reporting period, the OIG received and 

closed 48 new hotline complaints, ending this reporting period with zero open hotline complaints. No outstanding 

hotline complaints remained from the prior reporting period.

All hotline complaints are evaluated to determine if an investigation is warranted. OIG investigations involve a 

detailed analysis of the issues presented. That analysis includes, but is not limited to, reviewing pertinent agency records, 

leveraging information technology resources, and interviewing witnesses and subjects. 

The OIG previously reported one investigation as of September 30, 2020. During the reporting period, three new 

investigations were opened, zero investigations were closed, and four investigations remain open.

Peer Reviews

The Election Assistance Commission (EAC) OIG conducted a modified peer review of the FEC OIG Audit Program 

for the reporting period ended September 30, 2019. The EAC OIG completed the modified peer review, which 

concluded that certain audit policies and procedures warranted updates to conform to the 2018 version of Generally 

Accepted Government Auditing Standards (Yellow Book). The OIG is actively revising its audit manual in accordance 

with the 2018 Yellow Book.

EXECUTIVE SUMMARY
8 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

EXECUTIVE SUMMARY

The FEC OIG plans to conduct a peer review of the Export-Import Bank (EXIM) OIG Audit Program for the 

reporting period ended March 31, 2020. The entrance conference was held on February 24, 2021. We are currently 

in the planning phase of the peer review. Based on preliminary planning, the FEC OIG will perform an External Peer 

Review of the EXIM OIG Audit Program.
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 9

OIG Audit Activity

Title: FY 2020 Financial Statement Audit

Assignment Number: OIG-20-01

Status: Complete

During this reporting period, the independent public accountants (IPA), Brown and Company completed final 

testing and issued the agency’s FY 2020 financial statement (FS) audit report. The exit conference was held 

on November 12, 2020 to discuss the draft report and audit findings. The IPA determined that the FEC’s 

financial statements (FS) were presented fairly, in all material respects. The IPA did not identify any material weaknesses 

that could have an impact on financial reporting. The report was issued on November 16, 2020. 

As in prior years, the IPA is required by the FEC OIG’s contract to conduct additional testing on information 

systems (IT) controls, as the FEC is exempt from the Federal Information Systems Management Act (FISMA) and 

is not required to perform the annual FISMA audit. As part of this engagement, the IPA also performs follow-up on 

outstanding recommendations related to IT controls. Based on the internal control and follow-up reviews, there are 

currently five (5) control deficiencies (two new and three repeat findings) and six (6) open recommendations. 

The IPA also issued a management letter on December 2, 2020. The management letter contained two matters 

and suggestions for improvement that where not consider to be material weaknesses or significant deficiencies. These 

matters did not affect the FY 2020 FS Audit report issued in November 2020.

Title: Travel Program Audit

Assignment Number: OIG-20-03

Status: Deferred

The audit of the FEC’s travel program commenced during the previous reporting period. The primary objectives 

of this audit are to: (1) assess travel card policies and procedures to ensure internal controls in place are adequate to 

comply with Federal Travel Regulations (FTR), OMB Circular A-123 – Appendix B, and the Government Charge Card 

Abuse Prevention Act of 2012; (2) test travel card reimbursements and charges to ensure compliance with the FTR, 

and determine if fraud, waste, abuse, or misuse has occurred; and (3) assess the travel card program and processes to 

determine if there are opportunities to improve the efficiency and effectiveness of the program. Due to the planned 

changes in the FEC travel procedures, specifically, the implementation of an online booking portal, the OIG has 

deferred this engagement until the new procedures are established.
10 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Special Reviews

Title: Use of TRANServe Benefits during the FY19 Government Shutdown 

(December 22, 2018 – January 25, 2019)

Assignment Number: SR 19-01

Status: Complete

The OIG received information via the OIG hotline that alleged FEC employees violated the FEC Transit 

(TRANServe) Program by utilizing their transit benefits for personal use during scheduled telework days. The 

OIG opened an investigation into the matter on May 22, 2019. Based on the documentary evidence obtained, 

the investigation did not determine whether the employees were using their TRANServe benefits for personal use; 

however, it identified irregularities in TRANServe benefit usage during the FY19 government shutdown (December 

22, 2018 through January 25, 2019). The 35-day shutdown consumed four out of five weeks in January 2019. Specifically, 

FEC employees were permitted to use their TRANServe benefits on four out of 21 (19%) working days in January 2019; 

thus, any TRANServe usage over 20% indicate potential abuse. Accordingly, the OIG conducted a special review of the 

program, which found that 30 employees used more than 20% of their January 2019 TRANServe benefits.

The OIG issued a final report on July 31, 2020 with the following recommendations:

1. That the FEC regularly request, retrieve, and review monthly TRANServe subsidy benefit reports from 

the Department of Transportation in efforts to monitor benefit usage and prevent fraud, waste, and/or 

abuse of government funds.

2. That FEC management incorporate guidance into Commission Directive 54 that addresses transit benefits 

for furloughed and non-furloughed employees in the event of a government shutdown.

3. That FEC management include specific guidance related to the use of transit benefits during a government 

shutdown within the annual transit recertification application and within the agency PowerPoint training.

Currently, the OIG continues to follow up with management to address the three outstanding recommendations 

from this special review.
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 11

OIG Audit/Review Follow-up Activity

Title: Audit Follow-Up

Assignment Number: N/A

Status: In progress

As required by the Inspector General Act of 1978, as amended, the OIG is responsible for among other things, 

conducting and supervising audits, inspections, and special reviews of the FEC’s programs and operations.

Additionally, the OIG has the responsibility to perform follow-up assessments to ensure that management 

has effectively implemented OIG recommendations. The OIG performs follows up on all recommendations that have 

been outstanding for more than six months and identifies the progress management has made in addressing such 

recommendations to date.

The previous reporting period identified 22 outstanding recommendations from five audits and inspections. Since 

the last reporting period, the OIG has added three recommendations identified in the TranServe Special Review 

and closed the remaining two open recommendations related to the FY 2019 DATA Act Audit. The OIG continues 

to follow-up with management to address outstanding audit recommendations despite competing priorities and the 

current environment due to the COVID-19 pandemic. Based on follow-up activity, a total of five recommendations 

were closed during this reporting period.

There are three audits and two inspections/special reviews containing 17 outstanding recommendations as of 

March 31, 2021. The list of audits, inspections, and special reviews is detailed below:

1. 2010 Follow-up Audit of Privacy and Data Protection (outstanding 10 years)

2. Inspection of the FEC’s Disaster Recovery Plan and Continuity of Operations Plans (outstanding 8 years)

3. Audit of the FEC’s Office of Human Resources (outstanding 7.8 years)

4. Audit of the FEC Telework Programs (outstanding 4.9 years)

5. TranServe Special Review (outstanding 8 months)
0

2

4

6

8

10

9 

5 

1 2 

3 

2 

9 

6 

2 

5 

OIG AUDIT/REVIEW FOLLOW-UP ACTIVITY

Age of Outstanding Recommendations

13 (76.5%) of the outstanding recommendations are more than eight years old

■ Open Less Than 2 Years

■ Open 2 to 5 Years

■ Open 6 to 8 Years

■ Open 8 to 10 Years

Number of Recommendations

Recommendations Activity by FEC Office from 

October 2020 to March 2021

■ Total Closed Recommendations Since October 2020

■ Current Open Recommendations

OGC OHR OCFO

FEC Office

OCIO

13

3

1

12 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL
OIG AUDIT/REVIEW FOLLOW-UP ACTIVITY

Progress Report from October 2020 to March 2021

22 

5 

17 

0

5

10

15

20

25

Total Open Recommendations

as of October 2020

Total Closed

Recommendations

Current Open

Recommendations

SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 13
14 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

OIG Hotline Activity

1 The OIG also receives communications that do not rise to the level of complaints because they are not OIG specific and/or fail to state a 

complaint; we classify those as OIG Contacts for reporting purposes. During the reporting period, the OIG received and responded to 78 OIG Contacts.

The OIG hotline provides a means for FEC employees, FEC contractors, and the public to communicate directly 

and confidentially with the OIG regarding allegations of fraud, waste, abuse, mismanagement, and misconduct. 

Additionally, the OIG may open a hotline complaint based on information received from members of Congress, 

FEC management, or the results of an audit or review.

Persons who seek to submit complaints have three methods of submitting their inquiry: (1) the hotline portal, 

which is accessible through the OIG webpage; (2) the OIG hotline form (which can be mailed to the OIG’s physical 

address); and (3) the OIG hotline telephone, which is actively monitored during business hours.

During this reporting period, the OIG received and closed 48 new hotline complaints, ending this reporting period 

with zero open hotline complaints. No outstanding hotline complaints remained from the prior reporting period.1

The OIG takes all matters received on the hotline seriously; as such, we carefully analyze all information received 

to determine the appropriate course of action. Those courses of action include but are not limited to:

■ Opened for investigation – Issue involves an FEC employee, program/process, and alleges a violation of 

an applicable law, rule, or regulation. 

■ OIG referral to management for action – Issue is more suitably handled by management; OIG refers to 

management via letter for action deemed appropriate.

■ OIG referral to another existing FEC program/process (i.e., OGC, EEO, HR) – Existing process exists to 

resolve the issue; OIG refers the matter via letter to relevant program/process for action deemed appropriate.

■ OIG referral to external agency – Issue is best handled by another agency that has cognizance over 

the matter and/or warrants criminal investigation/prosecution. OIG refers to relevant agency via letter for 

action deemed appropriate. 

■ OIG referral to the OIG audit or special review process – The issue identifies compliance or internal 

control concerns regarding specific agency operations but does not warrant OIG investigation. OIG refers 

internally for potential audit or review.

■ Assist complainant – OIG determines the complaint is best handled by an existing process and/or entity that 

is available to the complaint. OIG notifies the complainant via letter of that process.

■ Closed with no further action – Complainant is frivolous, has already been addressed, provides insufficient 

detail to act, or otherwise warrants no further OIG action. OIG advises complainant that the matter is not 

within the OIG’s cognizance, when appropriate.
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 15

OIG Course of Action - Hotlines Closed

Opened for investigation 3

OIG referral to FEC management 0

OIG referral to existing FEC program/process 4

OIG referral to external agency 6

OIG referral to OIG audit/special review 1

Assist complainant 17

Closed with no action 17

Total Hotlines Closed 48

OIG HOTLINE ACTIVITY
16 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

OIG Investigative Summaries 

OIG investigations gather and analyze facts to resolve allegations of wrongdoing. OIG investigations may address 

administrative, civil, and criminal violations of laws, regulations, and policies and issues concerning the economy 

and deficiency of FEC operations and programs.. The subject of an OIG investigation may include any agency 

employee, FEC contractor, consultant, or person or entity involved in alleged wrongdoing affecting FEC programs and 

operations.

As previously noted, the OIG evaluates all hotline complaints to determine if an investigation is warranted. 

OIG investigations involve a detailed analysis of the issues presented, as well as emerging issues identified by the 

OIG. That analysis includes, but is not limited to obtaining pertinent agency records, performing computer material 

examinations, and interviewing witnesses and subjects. Occasionally, open investigations may be closed without a 

Report of Investigation (ROI) due to among other things, refuting evidence or lack of evidence obtained, and/or the 

level of severity of the allegation(s). Additionally, competing priorities may indicate that an allegation of wrongdoing is 

better addressed by management than by OIG investigation.

If the OIG determines to proceed and prepare an ROI, that report will provide a summary of the complaint, 

document the specific allegation(s), the law(s) or regulation(s) associated with the allegation(s), the objective description 

of the case facts, and a conclusion of investigative findings (i.e., substantiated or not substantiated). In addition, where 

appropriate, the report addresses potential improvements to the economy and efficiency of FEC programs and 

operations. The OIG previously reported one investigation as of September 30, 2020. During the reporting period, 

three new investigations were opened, zero investigations were closed, and four investigations remain open.

1 0

3

4

5

4

3

2

1

0

FEC OIG Status of Investigations

(October 1, 2020 – March 31, 2021)

Open Investigations

as of September 30, 2020

Open Investigations

(October 1, 2020–

March 31, 2021)

Closed Investigations

(October 1, 2020–

March 31, 2021))

Open Investigations

as of March 31, 2021
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 17

In accordance with the IG Empowerment Act of 2016, OIG’s are required to report on each investigation conducted 

involving a senior government employee where allegations of misconduct were substantiated, including a detailed 

description of the facts and circumstances of the investigation and the status and disposition of the matter. Accordingly, 

the OIG reports this reporting period there were no investigation in which allegations of misconducted by a senior 

FEC employee were substantiated.

Closed Investigations - Courses of Action

(October 1, 2020 – March 31, 2021) # of Investigations

Investigations closed with ROI released to Commissioners 0

ROI completed and released to Commissioners and referred to local 

state authorities 0

Investigations closed with Management Alert Memorandum (requesting 

management to follow up with actions taken, if any) 0

Investigations closed with Closing Memorandum but not provided to 

management due to insufficient evidence 0

Investigations closed and referred to OIG audit/special review program 0

Referrals to DOJ for federal prosecution 0

Totals 0

OIG INVESTIGATIVE SUMMARIES
18 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Other Matters - Review of Legislation 

The IG Act directs each IG to, among other things, “review existing and proposed legislation and regulations 

relating to programs and operations” of their respective agencies and to make recommendations in their 

respective semiannual reports “concerning the impact of such legislation or regulations on the economy and 

efficiency in the administration of programs and operations administered or financed by such establishment or the 

prevention and detection of fraud and abuse in such programs and operations.”

Proposed Legislation

H.R. 1 / S. 1 (“For the People Act of 2021”)

Pending legislation before Congress proposes substantial changes to the structure of the Commission and to the 

laws it enforces. Among other things it would:

1. Modify the composition of the Commission from six to five members, with no more than two from a single 

political party.

2. Redefine “quorum” as a “majority of the number of members of the Commission who are serving at the 

time.”

3. Increase the authorities of the Chair to include, inter alia, appointing certain senior Commission personnel, 

establishing the Commission budget, and compelling testimony and the production of evidence by 

subpoena. 

4. Limit donations to presidential inaugural committees to $50,000 total per donor. 

5. Prohibit donations to presidential inaugural committees from entities that are not individuals and prohibit 

donations in the name of another person.

6. Prohibit indirect donations to inaugural committees by foreign nationals (current law prohibits donations by 

foreign nationals but makes no express distinction between direct and indirect donations). See 36 U.S.C. § 

510. 

7. Prohibit conversions of donations to inaugural committees to personal use.

8. Require that presidential inaugural committees report disbursements and otherwise heighten the reporting 

standards that apply to presidential inaugural committees. Current law does not impose disbursement 

reporting obligations on inaugural committees and imposes only limited reports concerning donations. See 

36 U.S.C. § 510. 

The foregoing proposed legislation would have significant potential impacts on the economy and efficiency of the 

administration of the Commission’s programs and operations. Specifically:
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 19

1. Modifying the composition of the Commission by reducing the number of Commissioners and redefining 

quorum may mitigate the potential for periods of Commission inactivity due to a lack of quorum, as has 

occurred on multiple occasions in the past, often for extended periods. The FEC OIG previously identified 

the lack of Commission quorum as a top management and performance challenge facing the Commission 

because a lack of quorum in the past has undermined the Commission’s ability to conduct essential 

business, including enforcement matters, rulemaking, and certain administrative matters. Among other 

things, Congress should consider whether a quorum should also require at least two Commissioners from 

different political parties (or one independent Commissioner) to preserve the bipartisan character of the 

Commission in the event the Commission ever consists of only two members from a single party.

2. Similarly, increasing the authorities of the Commission Chair may further mitigate the adverse impacts of 

any future periods without a quorum by allowing the Chair to conduct certain business unilaterally. While 

doing so would potentially improve the efficiency of Commission operations, Congress should carefully 

balance the benefits and risks of reallocating authorities normally reserved to the full Commission to its 

Chair.

3. Increasing the Commission’s oversight of presidential inaugural committees, requiring disbursement 

reports, and prohibiting certain donations would bring the oversight of inaugural committees more in line 

with that of political committees. Congress should also consider whether additional oversight measures 

warrant the appropriation of additional personnel, information technology, and other resources for the 

FEC in light of the strain already placed on the FEC staff by dramatic increases in campaign fundraising 

and spending and the largely static budget of the Commission over the past decade. The FEC OIG 

previously identified the foregoing concern as a top management and performance challenge facing the 

Commission. 

OTHER MATTERS – REVIEW OF LEGISLATION
20 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Top Management Challenges

I

n accordance with the Reports Consolidation Act of 2000, we identify the most serious management and performance 

challenges facing the Commission and provides a brief assessment of the Commission’s progress in addressing those 

challenges. Each challenge area is related to the FEC’s mission and reflects continuing vulnerabilities and emerging 

issues. The following summzarizes FEC’s most significant management and performance challenges in our latest report, 

which is based on our experience and observations from our oversight work: 

1. Growth of campaign spending - The FEC was established nearly fifty years ago to provide oversight 

of federal campaign finance. Since then, federal campaign fundraising and spending have increased 

dramatically, particularly after the U.S. Supreme Court’s decision in Citizens United v. FEC in 2010. 

Indeed, total spending on federal election campaigns has increased from $1.6 billion in 1998 to roughly 14 

billion in 2020. However, the FEC’s budget has remained largely static over the past decade or more (and 

even decreased when accounting for inflation). That dynamic has placed great strain on the FEC staff and 

creates significant risks to the FEC. 

2. Lack of quorum - During this reporting period, the Commission was restored with a quorum ending a 

6-month period with no quorum. Previous periods in which the Commission lacked a quorum undermined 

the ability of the Commission to engage in essential business. 

3. Coronavirus (COVID-19) pandemic - The ongoing COVID-19 pandemic has forced the FEC, and many 

other agencies, to operate in a remote status since March 2020. As Federal workers begin returning to 

their offices in more significant numbers, their health and safety remains a top concern. 

4. Lack of full-time support to Chief Information Officer (CIO) and General Counsel Positions - Currently, 

the senior leadership roles of the Staff Director and CIO are occupied by the same individual and have 

been since August 2011. Similarly, the Deputy General Counsel for Law is concurrently serving as the 

Acting General Counsel and has been doing so since September 2016. Filling the CIO and General 

Counsel Positions with full-time incumbents would help ensure the FEC is effectively and efficiently 

supporting its overall mission objectives.

5. Cybersecurity - Protecting data, systems, and networks from threats remains a top challenge. The FEC was 

established to protect the integrity of federal campaign finance by providing transparency and enforcing 

and administering federal campaign finance laws. In doing so, the FEC discloses campaign finance data 

to the public and as a result, encounters large volumes of webpage traffic from stakeholders and members 

of the public. In efforts to streamline transparency initiatives and improve business processes, the 

Commission is more technology reliant today, as is society; as such, it is imperative that the Commission 

continue to prioritize cybersecurity. 
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 21

Council of the Inspectors General on

Integrity and Efficiency

Mr. Christopher Skinner, the Inspector General, attended CIGIE monthly meetings as well as CIGIE sponsored 

Conferences and Professional Development Seminars. Mr. Skinner participates on the CIGIE Technology 

Committee meetings to stay abreast to the effective information technology (IT) audits, evaluations, and 

investigations by Inspectors General.

Mr. Dennis Phillips, the Deputy Inspector General, participates on recommended CIGIE meetings and trainings 

as a new senior leader in the CIGIE community.

Ms. Carla Smith, Senior Counsel, participates on the following recurring meetings: CIGIE Legislative Committee, 

Counsel to the OIG, Counsel to the small OIG, and Freedom of Information Act (FOIA).

Ms. Shellie Purnell-Brown, Senior Auditor, participates on the DATA Act and Enterprise Risk Management 

working groups.
22 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

List of Training, Meetings & Conferences

The chart below provides a list of trainings, meetings, programs, seminars, and/or conferences 

attended by the IG and the OIG staff for the period October 1, 2020 to March 31, 2021.

Trainings, Meetings, Conferences, Etc.

Host / Sponsor Topic / Subject

American University Oversight and Accountability Symposium

AINS 15th Annual User Conference

Association of Certified 

Fraud Examiners

2020 Government Anti-Fraud Conference

Washington Metro Chapter Fraud Risk Management via Enterprise Risk 

Management Training

Auditnet.org Adding Keyword Searches to Your Analytical Techniques and Are Your 

Audit Exceptions Agnostic

Center for Audit 

Excellence (CAE)

Reviewing Draft Reports and Providing Effective Feedback

Understanding and Assessing Internal Controls in Audit

Council of the Inspectors 

General on Integrity 

and Efficiency (CIGIE)

7th Annual Inspectors General Leadership Forum 

23rd Annual CIGIE Awards Ceremony

Audit Peer Review Training

Business Diversity Subgroup Meeting

CIGIE & Interagency Suspension and Debarment Committee 

Suspension & Debarment Workshop 

Congressional Meeting 

Congressional Update-New Congress Seminar

Convercent - Ethics and Compliance 

Council of the Inspectors General on Integrity and Efficiency (CIGIE)

2020 Annual IG Conference

FOIA Meeting 

GAO 2021 Coordination Meeting

Integrity Committee Policies and Procedures Meeting 

Investigations Committee / Assistant Inspector General for 

Investigations Committee (IC/AIGI) Quarterly Meeting 
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 23

LIST OF TRAINING, MEETINGS & CONFERENCES

Trainings, Meetings, Conferences, Etc.

Host / Sponsor Topic / Subject

Council of the Inspectors 

General on Integrity 

and Efficiency (CIGIE)

Investigative Writing Seminar

Maintaining Your Resilience, Leading, Inspiring, and Fostering Talent

Monthly Meeting Counsel 

Reviewing Draft Reports and Providing Effective Feedback

Small/Unique OIG Quarterly Meeting 

Technology Committee and PDC Meeting Town Hall

Understanding and Assessing Internal Controls in Audit

Department of Defense 

(DoD) Quarterly Hotline Working Group

Federal Acquisition 

Institute (FAI) Contracting Officer Representative

Federal Election 

Commission

2020 Annual Ethics Training

Administrative Liaison Meeting

Audit Touch Point 

Commissioner Update 

CWTSato Travel Arranger Training Workshop

CWTSato Travel Online Booking Tool

Director’s Meeting

Finance Committee Meeting

OIG New Hire Orientation

Workplace Wellness - CareFirst BCBS 101

Government Accounting 

Office (GAO) Data Act Working Group (DAWG) Coordination Meeting

Institute of Internal 

Auditors

2020 International Conference 

Fraud Awareness Training

KnowBe4

2020 Kevin Mitnick Security Awareness Training

2020 Mandatory Ethics Training

Basics of Phishing Fundamentals

Management Concepts COR Refresher

Skillsoft Compliance Considerations to Prepare for Returning to the Office
24 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

LIST OF TRAINING, MEETINGS & CONFERENCES

Trainings, Meetings, Conferences, Etc.

Host / Sponsor Topic / Subject

Wolters Kluwer Key Benefits of Agility in Auditing

TeamMate Analytics
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 25

Reporting Requirements

Reporting requirements required by the IG Act, as amended, are detailed below:

IG Act DESCRIPTION PAGE

Section 4(a)(2) Review of Legislation 18-19

Section 5(a)(1) Significant Problems, Abuses, and Deficiencies None

Section 5(a)(2) Recommendations with Respect to Significant Problems, Abuses, 

and Deficiencies None

Section 5(a)(3) Recommendations Included in Previous Reports on Which 

Corrective Action Has Not Been Completed (Table III) 28

Section 5(a)(4) Matters Referred to Prosecuting Authorities None

Section 5(a)(5) Summary of Instances Where Information was Refused- None

Section 5(a)(7) Summary of Significant Reports None

Section 5(a)(8) Questioned and Unsupported Costs (Table I) 26

Section 5(a)(9) Recommendations that Funds be Put To Better Use (Table II) 27

Section 5(a)(10)

(A)

Summary of Audit Reports issued before the start of the Reporting 

Period for which No Management Decision has been made None

Section 5(a)(10)

(B)

Summary of Audit Reports Issued Before the start of the 

Reporting Period for which No Management Comment was 

Returned Within 60 Days

None

Section 5(a)(10)

(C)

Summary of Audit Reports Issued Before the Start of 

the Reporting Period for which There Are Outstanding 

Unimplemented Recommendations

None

Section 5(a)(11) Significant Revised Management Decisions None

Section 5(a)(12) Management Decisions with which the Inspector General is in 

Disagreement None

Section 5(a)(14) Peer Review Recommendations 30
26 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

REPORTING REQUIREMENTS

IG Act DESCRIPTION PAGE

Section 5(a)(17), 

(18)

Investigative Reports Table and Metrics (Table IV) 14-17,

and 29

Section 5(a)(19) Investigations Involving a Senior Government Employee with 

Substantiated Misconduct None

Section 5(a)(20) Instances of Whistleblower Retaliation None

Section 5(a)(21) Attempts by the Agency to Interfere with OIG Independence None

Section 5(a)(22) Undisclosed Inspections, Evaluations, Audits, 

and Investigations

None

Table I: Inspector General Issued Reports with Questioned Costs

Required reporting Number of 

Reports

Questioned 

Costs

Unsupported 

Costs

A.

For which no management decision 

has been made by commencement 

of the reporting period 

0 0 0

B. Which were issued during the 

reporting period 0 0 0

Sub-Totals (A&B) 0 0 0

C.

For which a management decision 

was made during the reporting 

period 

0 0 0

(i) Dollar value of disallowed costs 0 0 0

(ii) Dollar value of costs not 

disallowed 0 0 0

D.

For which no management decision 

has been made by the end of the 

reporting period

0 0 0

E.

Reports for which no management 

decision was made within six 

months of issuance 

0 0 0

Reporting requirements required by the IG Act, as amended, continued:
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 27

REPORTING REQUIREMENTS

Table II: Inspector General Issued Reports with Recommended Actions 

That Funds Be Spent to Better use

Required Reporting Number of Rec’s Dollar Value 

(In Thousands)

A.

For which no management decision has 

been made by the commencement of 

the reporting period

0 0

B. Which were issued during the reporting 

period 0 0

C. For which a management decision was 

made during the reporting period 0 0

(i) dollar value of recommendations were 

agreed to by management 0 0

based on proposed management action 0 0

based on proposed legislative action 0 0

(ii) dollar value of recommendations that 

were not agreed to by management 0 0

D.

For which no management decision has 

been made by the end of the reporting 

period

0 0

E.

Reports for which no management 

decision was made within six months of 

issuance

0 0
28 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Table III: Summary of Audit and Inspection Reports with Corrective Actions Outstanding 

Report Title Report

Number

Date

Issued

Total

Rec’s Closed Open Cost Savings

2010 Follow-up Audit 

of Privacy and Data 

Protection

OIG-10-03 03/11 9 0 9 0

Inspection of the Federal 

Election Commission’s 

Disaster Recovery 

Plan and Continuity of 

Operations Plans

OIG-12-06 01/13 5 2 3 0

Audit of the Federal 

Election Commission’s 

Office of Human 

Resources 

OIG-12-05 07/13 2 1 1 0

Audit of the FEC’s

Telework Programs OIG-15-03 06/16 1 0 1 0

Required Review Under the 

DATA Act OIG-19-02 11/19 2 2 0 0

TranServe Special Review SR-19-01 07/21 3 0 3 0

Totals 22 5 17 0

REPORTING REQUIREMENTS
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 29

Table IV: Summary of Investigative Reports and Actions2

FEC OIG Investigations Courses of Action (Oct 1, 2020 – Mar 31, 2021) Number

Total number of investigative reports issued 0

Total number of persons referred to DOJ for criminal prosecution 0

Total number of persons referred to state and local prosecuting Authorities for 

criminal prosecution

0

Total number of indictments and criminal information resulting from any prior 

referral to prosecuting authorities

0

Total Investigations Closed 0

2 Metrics Used for Developing Data for Table IV: 

Total number of investigative reports issued - reflects the number of all Reports of Investigation (ROI) issued to FEC Commissioners, management 

alert memorandums, closing memorandums, and other referral memorandums during the reporting period;  

Total number of persons referred to DOJ for criminal prosecution and total number of persons referred to state and local prosecuting authorities 

for criminal prosecution - reflects the total number of referrals for criminal prosecution made by the FEC OIG to the respective criminal prosecuting 

authorities during the reporting period; and

Total number of indictments and criminal information resulting from any prior referral to prosecuting authorities - includes all indictments and 

information issued during the reporting period by Federal, State, or local criminal prosecuting authorities based upon any referral by the FEC OIG, 

whether the referral was made during this reporting period or a prior reporting period.

REPORTING REQUIREMENTS
30 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Appendix A: Peer Review Results

I

n accordance with the IG Act, OIGs are required to report to Congress, as applicable, results of any peer reviews 

it received or conducted during the reporting period. Specifically, OIGs are required to report any outstanding 

recommendations that resulted from the peer review.

OIG Peer Review Activity 

Title: Peer Review of the FEC OIG Audit Program

Assignment Number: N/A

Status: Complete

In accordance with the CIGIE Audit Peer Review schedule, the Election Assistance Commission (EAC) OIG was 

tasked to conduct a modified peer review of the FEC OIG Audit Program for the reporting period ended September 

30, 2019. Due to the unforeseen conditions related to the COVID-19 pandemic, an extension for this peer review 

period was granted to December 31, 2020. EAC OIG completed the modified peer review and issued the final report 

on December 30, 2020. A modified peer review does not express an opinion and does not issue a grade (i.e. pass, fail). 

The main purpose of a modified peer review is to assess whether policies and procedures submitted for review were 

current and consistent with applicable professional standards. The modified peer review report contained one finding 

and recommendation. The finding is related to the policies and procedures were not up to date to conform to the 2018 

version of Generally Accepted Government Auditing Standards (Yellow Book). It was recommended that the FEC OIG 

should perform a comprehensive review of its audit manual and revise its policies and procedures. Personnel turnover 

and the extended vacancies (since 2017) of several senior OIG positions, including the IG, the Deputy IG, and senior 

auditor, posed resource challenges to the OIG in recent years, including updating the OIG audit manual. Now that 

these key positions have been filled and workload demands are stabilizing, the OIG is currently working on revisions 

to the audit manual to conform to the 2018 Yellow Book.
SEMIANNUAL REPORT to CONGRESS | OCTOBER 1, 2020 – MARCH 31, 2021 31

Title: Peer Review of the EXIM OIG Audit Program

Assignment Number: N/A

Status: Ongoing

In accordance with the CIGIE Audit Peer Review schedule, the FEC OIG is tasked with conducting a peer review 

of the Export-Import Bank (EXIM) OIG Audit Program for the reporting period ended March 31, 2020. The EXIM 

OIG was granted an extension for this peer review until June 30, 2021. The entrance conference was held on February 

24, 2021. We are currently in the planning phase of the peer review and have issued the engagement letter and the 

Memorandum of Understanding. Based on preliminary planning, the FEC OIG will perform an External Peer Review 

which will be completed by the next reporting period.

APPENDIX A: PEER REVIEW
32 FEDERAL ELECTION COMMISSION | OFFICE of the INSPECTOR GENERAL

Appendix B: Mission Statements

The Federal Election Commission

The FEC is the independent regulatory agency charged with administering and enforcing the federal campaign 

finance law. The FEC has jurisdiction over the financing of campaigns for the U.S. House, Senate, Presidency 

and the Vice Presidency. Its mission is to protect the integrity of the Federal campaign finance process by 

providing transparency and fairly enforcing and administering Federal campaign finance laws.

In 1975, Congress created the FEC to administer and enforce the Federal Election Campaign Act of 1971, as 

amended. The duties of the FEC, an independent regulatory agency, are to disclose campaign finance information, 

enforce the provisions of the law, and oversee the public funding of Presidential elections.

The Commission consists of six members who are appointed by the President and confirmed by the Senate. 

Each member serves a six-year term, and two seats are subject to appointment every two years. By law, no more than 

three Commissioners can be members of the same political party, and at least four votes are required for any official 

Commission action. The Chairmanship of the Commission rotates among the members each year, with no member 

serving as Chairman more than once during his or her term.

Currently, the FEC has six Commissioners – Shana M. Broussard (Chair), Allen Dickerson (Vice Chair), James E. 

“Trey” Trainor, III, Steven T. Walther, Ellen L. Weintraub, and Sean J. Cooksey.

Office of Inspector General

The FEC OIG is committed to detecting and preventing fraud, waste, abuse, and other violations of law, and 

to promoting economy, efficiency and effectiveness in the operations of the FEC. The OIG strives to collaboratively 

promote improvements to FEC strategic operations, programs, and initiatives by independently conducting valueadded audits, reviews, and investigations. 

Our vision is to serve as trusted agents in driving positive change and promoting integrity in FEC programs and 

operations.
Federal Election Commission

Office of the Inspector General

OIG Hotline Portal

https://fecoig.ains.com

* Also accessible via: 

http://www.fec.gov/oig

OIG Hotline Phone

202-694-1015

* Available from 9:00 a.m. to 5:00 p.m. 

Eastern Standard Time, Monday through 

Friday, excluding federal holidays.

REPORT

FRAUD, WASTE, & ABUSE

Or you may call toll free at 1-800-424-9530 (press 0; then dial 1015). You may also file 

a complaint by completing the Hotline Complaint Form (http://www.fec.gov/oig) and 

mailing it to: 1050 First Street, N.E., Suite 1010, Washington DC 20463.

Individuals including FEC and FEC contractor employees are encouraged to alert the OIG to fraud, waste, abuse, and 

mismanagement of agency programs and operations. Individuals who contact the OIG can remain anonymous. However, 

persons who report allegations are encouraged to provide their contact information in the event additional questions 

arise as the OIG evaluates the allegations. Allegations with limited details or merit may be held in abeyance until further 

specific details are reported or obtained. Pursuant to the Inspector General Act of 1978, as amended, the Inspector 

General will not disclose the identity of an individual who provides information without the consent of that individual, 

unless the Inspector General determines that such disclosure is unavoidable during the course of an investigation. To 

learn more about the OIG, visit our Website at: http://www.fec.gov/oig. 

Together we can make a difference!