GAO-10-63R Integrity Committee’s Process 

United States Government Accountability Office

Washington, DC 20548 

October 15, 2009 

The Honorable Charles E. Grassley 

Ranking Member 

Committee on Finance 

United States Senate 

The Honorable Bart Gordon 

Chairman 

Committee on Science and Technology 

House of Representatives 

The Honorable Brad Miller 

Chairman 

Subcommittee on Investigations and Oversight 

Committee on Science and Technology 

House of Representatives 

Subject: Integrity Committee’s Process to Address Allegations of Wrongdoing by 

Inspectors General 

This report responds to your request that we review the activities of the Integrity 

Committee (Committee) of the President’s Council on Integrity and Efficiency (PCIE) 

and the Executive Council on Integrity and Efficiency (ECIE) used to address 

allegations of wrongdoing by federal statutory inspectors general (IGs). Executive 

Order No. 12993, Administrative Allegations Against Inspectors General, signed by 

the President on March 21, 1996, provided the Integrity Committee of the PCIE and 

ECIE with the authority to receive, review, and refer for investigation allegations of 

wrongdoing against IGs and certain staff members of the IG offices. At the time of 

our review there were statutory IG offices in 67 federal agencies, departments, and 

entities. The Executive Order provides the Committee this authority over IG staff 

members whose activities are known to the IG or when the allegation against the 

staff person is related to an allegation against the IG. The IG Reform Act of 2008 

(Reform Act) superseded the Executive Order but maintains the functions of the 

Integrity Committee with additional authorities, reporting requirements, and 

responsibilities.1

 

 

1

Pub. L. No. 110-409, 122 Stat. 4302 (Oct. 14, 2008). The Reform Act, among other things, established the 

Council of the Inspectors General for Integrity and Efficiency (CIGIE), which replaced the PCIE and ECIE. The 

Integrity Committee is a part of CIGIE. 
 GAO-10-63R Integrity Committee’s Process Page 2

The IGs have a unique role within their agencies to identify areas for improved 

economy, efficiency, and effectiveness through independent and objective oversight; 

prevent and detect fraud, waste, abuse, and mismanagement; and recommend 

corrective actions. This role requires that IGs and their staff maintain the highest 

level of integrity and accountability within their own offices. Over the years, concerns 

have been raised about the transparency of the process for handling allegations of 

wrongdoing against IGs and their staff. As agreed with your offices, this report 

describes (1) the Committee’s process for addressing allegations of wrongdoing 

against IGs, (2) whether the Committee adhered to its process as described in 

Executive Order No. 12993 and implementing policy and procedures, and (3) the 

effect of the Reform Act on the Committee’s process. 

To describe the Integrity Committee’s process, we reviewed the requirements of 

Executive Order No. 12993 and the Committee’s November 2004 and February 2007 

implementing policy and procedures that were in effect at the time of our review. To 

determine whether the Committee adhered to the Executive Order and the policy and 

procedures, we obtained and reviewed the case files for all of the 165 allegations 

received and closed during the 3-year period of January 1, 2005, through December 

31, 2007. This period represents the last three full calendar years that the Integrity 

Committee addressed allegations under the requirements of the Executive Order. 

From the case files, we obtained information about the various allegations, including 

the sources, subjects, and nature of the allegations, and the actions taken by the 

Committee to resolve them and close the case files. We compared this information 

with the requirements of the Executive Order and the Integrity Committee’s 

implementing policy and procedures. During our review of these files, we also 

consulted with officials of the Integrity Committee to obtain explanations or 

additional documentation. We did not provide additional review of the merits of 

individual allegations brought before the Integrity Committee and therefore do not 

comment on the professional judgment applied by the Committee to address them. 

Finally, we analyzed the relevant provisions of the Reform Act to identify and assess 

any changes that affect the Committee’s responsibility to address allegations of 

wrongdoing by IGs and their staff. 

We conducted this performance audit from April 2008 through August 2009 in 

accordance with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate evidence 

to provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

Results In Brief 

The Integrity Committee is responsible for receiving, reviewing, and referring for 

investigation, allegations of wrongdoing by IGs and certain staff. The Committee 

receives allegations from government contractors, private citizens, IG employees, and 

those who remain anonymous through phone calls, e-mails, and letters. The Integrity 

Committee may refer the allegations it receives to the Public Integrity Section of the 
 GAO-10-63R Integrity Committee’s Process Page 3

Department of Justice (DOJ) to determine whether, if substantiated they would 

constitute a violation of federal criminal law. If a criminal investigation is warranted 

the Public Integrity Section refers the matter to the appropriate law enforcement 

agency. The Integrity Committee reviews all allegations of administrative misconduct 

that are not criminal in nature to determine if they fall within its jurisdiction, and if so 

the Committee may perform an administrative investigation or take steps to close the 

matters. 

We reviewed case files for 165 allegations that the Integrity Committee opened and 

closed during calendar years 2005 through 2007 and found that the Committee’s 

activities were consistent with the requirements of Executive Order No. 12993 and 

the Committee’s implementing policy and procedures. The Integrity Committee 

received allegations about IGs and their staff in 35 separate federal agencies and 

entities. The nature of the wrongdoing reported in the allegations involved seven 

areas of alleged misconduct that included the failure to investigate certain matters, 

and the mismanagement, waste, and abuse of government resources. DOJ determined 

that none of these allegations warranted a criminal investigation. The Integrity 

Committee reviewed the allegations for administrative misconduct and determined 

that 93 of the 165 allegations were within its jurisdiction because they alleged 

wrongdoing by an IG or an IG staff member acting with the knowledge of the IG. For 

those allegations within its jurisdiction, the Integrity Committee conducted 2 separate 

investigations that addressed 41 allegations. The Integrity Committee closed the 

remaining 52 allegations within its jurisdiction (1) because the matters were within 

the IG’s discretion to decide where to apply audit and investigative resources, 

(2) after additional information was obtained indicating a lack of evidence of 

wrongdoing, (3) after referral of allegations to the responsible IG for action when no 

indication of wrongdoing is determined, or (4) after referral of the allegations to an 

agency with jurisdiction. In addition, the Integrity Committee determined that 72 

allegations were outside its jurisdiction because they involved lower level IG staff or 

agency officials, and failed to demonstrate administrative misconduct against an IG 

or IG staff member acting with the knowledge of the IG. 

The Reform Act continues the functions carried out by the Integrity Committee under 

Executive Order No. 12993 but with the permanence of statute. In addition, the 

Reform Act provides new guidance and greater transparency over the Committee’s 

activities. Specifically, the Reform Act requires 

• IGs to annually designate the positions of staff subject to Integrity Committee 

review; 

• the Integrity Committee to establish policies and procedures necessary to 

ensure fairness and consistency in its investigations, such as providing the 

person under investigation the opportunity to respond, which may help to 

facilitate the Committee’s investigations; and 

• the Integrity Committee to provide the results of its investigations to 

congressional committees, agency heads, and the President shortly after 

completion, and to annually report by December 31 to Congress and the 

President on certain activities during the preceding fiscal year as specified by 

the act, which significantly enhances transparency of the Committee’s process. 
 GAO-10-63R Integrity Committee’s Process Page 4

 

In addition, the Integrity Committee has revised its policy and procedures to 

implement the Reform Act. Among other things, its revised policy changed the 

definition of administrative misconduct so that it includes the review of conduct so 

serious that it may undermine the independence or integrity reasonably expected of 

an IG or senior IG staff member. 

Background 

Prior to the Reform Act, the IGs established by the IG Act of 19782

 and subsequent 

amendments (IG Act) met and coordinated as two separate councils as provided by 

Executive Order No. 12805, Integrity and Efficiency in Federal Programs (May 11, 

1992). The IGs appointed by the President with Senate confirmation were part of 

PCIE and IGs appointed by their agency heads in designated federal entities defined 

by the IG Act were part of ECIE.3 The mission of the two councils was to coordinate 

and enhance the work of the IGs, and the Integrity Committee was part of these 

councils. The Deputy Director for Management of the Office of Management and 

Budget (OMB) chaired both councils and had responsibilities regarding the Integrity 

Committee’s investigations. 

Congress enacted the Reform Act to enhance IG independence and accountability. 

Congress maintained the existing framework and IG community and added 

authorities and requirements to help build a stronger, more independent, 

professional, and accountable IG community.4

 For example, the Reform Act 

combined the existing councils (PCIE and ECIE) into one IG Council (CIGIE), which 

continues to address integrity, economy, and effectiveness issues, but the act allows 

CIGIE to operate under statutory authority for the entire IG community and provides 

additional resources and authorities.5 Similarly, the Reform Act continues the 

Integrity Committee’s authority to address allegations of wrongdoing as part of an IG 

council and provides additional authorities and requirements. 

The Reform Act also maintains the OMB Deputy Director for Management’s 

responsibilities regarding the Integrity Committee’s activities. Under both the 

Executive Order and the Reform Act, the Integrity Committee consists of (1) an 

official of the Federal Bureau of Investigation (FBI) who serves as the Integrity 

Committee Chairperson; (2) the Special Counsel of the Office of Special Counsel; (3) 

the Director of the Office of Government Ethics; and (4) representative IGs. Further, 

the Chief of the Public Integrity Section of the Criminal Division of DOJ served as an 

advisor to the Integrity Committee under the Executive Order and continues as a 

legal advisor under the Reform Act. In addition, the Integrity Committee Chairperson 

appoints a Working Group that may be composed of FBI employees or the staff of 

CIGIE members to assist in the Chairperson’s responsibilities and to handle all 

correspondence. (See encls. I, II, and III for a current listing of the federal agencies, 

departments, and entities with statutory IG offices.) 

2

Pub. L. No. 95-452, 92 Stat. 1101 (Oct. 12, 1978) (codified, as amended, at 5 U.S.C. App.). 

3

 The first President’s Council on Integrity and Efficiency was established in 1981 under Executive Order No. 

12301, Integrity and Efficiency in Federal Programs (May 26, 1981). 4

 The IGs in the legislative branch were added as members of CIGIE. 

5

 S. Rep. No. 110-262 at 5 (Feb. 22, 2008). 
 GAO-10-63R Integrity Committee’s Process Page 5

 

During passage of the Reform Act bill, the House of Representatives Committee on 

Oversight and Government Reform noted that to preserve the credibility of an IG’s 

office, IGs must also perform their duties with integrity and apply the same standards 

of conduct and accountability to themselves as they apply to the agencies that they 

audit and investigate.6 The House Committee expressed concern that a lack of 

consistent and credible mechanisms for investigating and resolving allegations of 

misconduct by Inspectors General may threaten accountability and credibility.7 

Similarly, the Senate Committee on Homeland Security and Governmental Affairs 

noted that with greater IG autonomy there is a heightened risk of IGs abusing their 

power.8

 The Senate Committee recognized that the IGs are not immune from real or 

alleged misconduct or mismanagement and it is critical that there be an effective and 

credible mechanism to address complaints about IGs when they arise.9 

A combination of alleged troubling instances of IG misconduct, misunderstood 

procedures of the existing Integrity Committee, and a lack of transparency over the 

Committee’s actions and processes led Congress to provide additional authorities and 

requirements involving the Integrity Committee. For example, the Senate Committee 

on Homeland Security and Governmental Affairs reported that because Congress had 

no systematic or assured way to learn of serious allegations against an IG or to learn 

of the results of an investigation into those allegations, the Reform Act would require 

the Integrity Committee to notify Congress of its procedures, and prepare regular 

reports on the investigations it undertakes in hopes of providing an oversight process 

that is more transparent and more accountable than that under the Executive Order.10

The Integrity Committee Process 

The Integrity Committee process for addressing allegations of wrongdoing includes 

activities for the receipt, review, and referral for investigation of allegations leading 

to closure of the matters by the committee. (See fig. 1.) The Integrity Committee 

developed implementing policy and procedures to reflect the requirements in 

Executive Order No. 12993, and the Committee continues to carry out this basic 

process under the Reform Act using its revised implementing policy and procedures.

The Integrity Committee Working Group at FBI Headquarters receives allegations 

from government contractors, private citizens, IG employees, and those who remain 

anonymous through phone calls, e-mails, and letters. The Working Group opens case 

files for the allegations which are numbered to correspond with sources that often 

make multiple allegations. The Working Group conducts an initial review of each 

complaint to determine whether it is within the Integrity Committee’s jurisdiction, or 

may request additional information from the complainant if the complaint lacks 

sufficient detail. 

6

 H.R. Rep. 110-354 at 9 (Sept. 27, 2007). 

7

 Id. 

8

 S. Rep. No. 110-262 at 3 (Feb 22, 2008). 

9

 Id at 6. 

10 Id. 
 GAO-10-63R Integrity Committee’s Process Page 6

Figure 1: Activities of the Integrity Committee 

Source: GAO analysis of Executive Order No. 12993, the Reform Act, Integrity Committee case files and implementing policy and procedures.

Integrity Committee

Working Group receives

allegations from various

sources and opens

case files

Integrity Committee

reviews allegationsa

Public Integrity Section

of DOJ reviews

allegations for possible

criminal action

Law enforcement

agency receives

allegations if warrantedb

Integrity Committee

determines that

allegations are not

within its jurisdiction

Integrity Committee

determines that

allegations are within

its jurisdiction

Integrity Committee

determines that an

investigation will

be conducted

Integrity Committee closes cases based on

• Frivolous allegations lacking merit

• Matters within IG discretion

• Additional information lacking evidence

• Referral to the responsible IG

• Referral to an agency with jurisdiction

• Resolution of investigative matters by

 CIGIE Executive Chairperson

Executive Chairperson

of CIGIE reviews the

results of the

investigation and

resolves the mattersc

a

The Integrity Committee may request additional information from either the sources or the subjects of 

the allegations during their review. 

b

DOJ determined that none of the allegations in our review warranted criminal investigation. 

c

Under Executive Order No. 12993 this function was performed by the Chairperson of PCIE and ECIE. 

Under the Executive Order, complaints fell within the Integrity Committee’s 

jurisdiction when wrongdoing was alleged on the part of an IG or staff members of 

the IG’s office whose activities were known to the IG or when the allegation against a 

staff person was related to an allegation against the IG. The Reform Act also requires 

that allegations of wrongdoing by IGs be included in the Integrity Committee’s 

jurisdiction but defines IG staff to be any staff that report directly to the IG or are 

designated by the IG to be subject to Integrity Committee review.11 The Integrity 

Committee may close a case if it determines that the allegation is frivolous, not 

supported by meaningful documentation, and lacks potential merit. In addition, the 

Integrity Committee may determine that the matters in the allegation are within an 

IG’s discretion to decide, and therefore close the case. For example, the Integrity 

 

11The Reform Act requires each IG to annually submit to the Chairperson of the Integrity Committee a 

designation of positions whose holders are staff members subject to Integrity Committee review. 
 GAO-10-63R Integrity Committee’s Process Page 7

 

Committee has determined there is no wrongdoing by an IG who uses his or her 

discretion to decide where to apply limited audit and investigative resources even 

though the IG is alleged to have ignored an area of importance to the complainant. 

The Integrity Committee may also refer an allegation to another agency with the 

appropriate jurisdiction. For example, the Integrity Committee may refer equal 

employment opportunity complaints to the Equal Employment Opportunity Office of 

the affected agency, and refer allegations of illegal political activity, whistleblower 

retaliation, or prohibited personnel practices to the Office of Special Counsel or other 

agency as provided by law. 12 In addition, the Integrity Committee may close a case 

when the allegation is known to be incorrect and refer the allegation to the subject IG 

for disposition as deemed appropriate by the IG. Also, the Integrity Committee may 

close a case after additional information is obtained from the subject of the complaint 

which disproves the allegation. Where the source of the allegation is known, the 

Integrity Committee provides the complainant with information regarding the 

disposition of the allegation. 

The Integrity Committee Chairperson may refer any complaint containing allegations 

that present the possibility of criminal conduct to the Public Integrity Section of DOJ. 

The Public Integrity Section then determines whether the allegation, if substantiated, 

would constitute a violation of federal criminal law. If the Public Integrity Section 

determines that a criminal investigation is warranted, it will notify the Integrity 

Committee and refer the matter to the appropriate law enforcement agency. If the 

Public Integrity Section determines that a criminal investigation is not warranted, the 

matter is returned to the Working Group for further review. 

The Integrity Committee reviews each complaint within its jurisdiction to determine 

whether the allegation substantially involves administrative misconduct such as a 

violation of law, rule, or regulation; gross mismanagement; gross waste of funds; or 

abuse of authority in the exercise of official duties.13 For example, administrative 

misconduct may include allegations of questionable travel costs and contracting 

practices, promotions and appointments of IG office personnel, and conflicts of 

interest. 

The Integrity Committee determines whether to perform an investigation of 

allegations within its jurisdiction. Typically, allegations that the Integrity Committee 

accepts for investigation clearly identify the alleged wrongdoing by an IG or covered 

IG staff member and contain supporting documentation. If the allegation lacks 

sufficient information to proceed with an investigation, the Integrity Committee may 

choose to take no further action or direct the Working Group to make further 

inquiries to develop additional information for the Integrity Committee to consider in 

determining whether an investigation is warranted. If an allegation appears to have 

potential merit the Integrity Committee will submit the matter to the Integrity 

12The Reform Act requires that agency heads receiving allegations referred to them by the Integrity Committee 

provide a report containing the results of their investigation to the Integrity Committee. 

13In its revised policy and procedures to address changes in the Reform Act, the Integrity Committee added to 

its definition of administrative misconduct to include conduct so serious that it may undermine the 

independence or integrity reasonably expected of an IG or IG staff member. 
 GAO-10-63R Integrity Committee’s Process Page 8

 

Committee Chairperson who will cause an investigation of the allegation to be 

conducted. The Integrity Committee may request that the FBI conduct or assist in the 

investigation of allegations, or it may request an uninvolved IG office to perform the 

investigation under the control and direction of the Integrity Committee Chairperson. 

These investigations are to be conducted in accordance with the Quality Standards 

for Investigations14 using the investigative procedures of the investigating IG or as 

directed by the Integrity Committee Chairperson. 

At the conclusion of an investigation, the investigating team reports the facts and 

conclusions to the Integrity Committee. The Integrity Committee determines whether 

the allegations under investigation are substantiated and whether administrative 

misconduct has been established. If warranted, the Integrity Committee forwards the 

report of investigation along with a letter containing the findings, opinions, and 

recommendations, to the Executive Chairperson of CIGIE. The Executive 

Chairperson then notifies the Integrity Committee concerning the final disposition of 

the matters in the investigative report and the case file is closed. 

The Integrity Committee may determine that allegations are not under its jurisdiction 

because they do not allege wrongdoing by an IG or certain IG staff as described by 

the Executive Order for the allegations in the 3-year period we reviewed, or as 

indicated by the Reform Act for allegations currently received. The Integrity 

Committee may refer these allegations to another federal agency with appropriate 

jurisdiction over the matter or refer them to the concerned IG for disposition. For 

example, an allegation may allege wrongdoing by a lower level staff member of an 

IG’s office who acted without the knowledge of the IG and therefore not meet the 

conditions for Integrity Committee jurisdiction. Nevertheless, the Integrity 

Committee may refer this information to the IG for possible review and correction of 

the matter regarding the staff member. In addition, while determining whether 

allegations are within its jurisdiction, the Integrity Committee may obtain additional 

information that disproves the allegation or determine that the allegations address 

matters that are within the IG’s discretion to decide. 

The Integrity Committee’s Activities Were Consistent with Requirements of 

the Executive Order 

The Integrity Committee received and closed 165 allegations during calendar years 

2005 through 2007. Based on our review of these case files, the activities of the 

Integrity Committee were consistent with the requirements of the Executive Order 

and the Committee’s implementing policy and procedures. The documentation in the 

numbered case files at FBI Headquarters indicate that the Integrity Committee 

provided a copy of each allegation to the Pubic Integrity Section of DOJ for a 

determination as to whether the allegation, if proven, would constitute a prosecutable 

violation of federal criminal law. The Public Integrity Section returned each of the 

allegations in our 3-year sample to the Integrity Committee with its determination 

that a criminal investigation was not warranted. 

14Quality Standards for Investigations, PCIE and ECIE (Washington, D.C.: December 2003). 
 GAO-10-63R Integrity Committee’s Process Page 9

Out of a total of 67 federal agencies, departments, and entities with statutory IGs as 

of December 31, 2007, 35 had IGs or IG staff involved in allegations of wrongdoing 

over the 3-year period of our review. (See encl. IV.) The nature of the complaints 

made in the 165 allegations can be grouped into seven types of alleged misconduct, as 

shown in table 1. 

Table 1: Allegations Against IGs and Their Staff 

Nature of alleged 

misconduct 

Examples of specific allegations Number of 

allegations 

1. Alleged failure to 

investigate 

Allegations that IG investigations were not 

done on issues that appeared, to the 

complainant, to warrant them 

32 

2. Alleged 

mismanagement, 

waste, and abuse 

Allegations that IG auditors had done too 

much costly testing activity rather than 

sampling during an audit 

31 

3. Alleged improper 

personnel decisions 

Complaints regarding promotions, 

appointments, personnel records, and alleged 

racial discrimination 

29 

4. Alleged improper 

investigative activity

Alleged bias by an IG office for a specific 

outcome, lack of timeliness, and a disregard 

for evidence 

25 

5. Alleged independence 

issues 

Allegations of conflicts of interest and work as 

redirected away from sensitive issues 

22 

6. Alleged lack of 

compliance with laws 

and regulations 

Allegations of questionable travel costs and 

contracting practices subject to laws and 

regulations

13 

7. Other allegations Allegations included unprofessional behavior 

and making false statements 

13 

Total allegations 165 

Source: GAO analysis of Integrity Committee case files. 

The Integrity Committee determined that 93 allegations were against an IG or a 

Deputy IG and within its jurisdiction. The remaining 72 allegations were determined 

by the Integrity Committee to be outside its jurisdiction because they involved lower 

level IG staff or agency officials and failed to demonstrate administrative misconduct 

against an IG, or IG staff member acting with the knowledge of the IG. 

For the 93 allegations within its jurisdiction the Integrity Committee took the 

following actions to close the case files. 

• The Integrity Committee referred 41 allegations to other IG offices for 

investigation, as part of 2 separate administrative investigations the 

Committee conducted during the 3-year period of our review. One 

investigation of the National Aeronautics and Space Administration (NASA) IG 
 GAO-10-63R Integrity Committee’s Process Page 10

 

involved 35 allegations and another investigation of the Department of 

Defense (DOD) IG involved 6 allegations.15

 

o The Department of Housing and Urban Development (HUD) IG 

performed the investigation of the allegations made against the NASA 

IG and submitted the investigative results to the Integrity Committee on 

August 30, 2006. The Chairperson of PCIE and ECIE advised the NASA 

Administrator to determine the appropriate actions to address the 

investigation’s conclusions. The Integrity Committee stated that the 

matter was resolved within the terms of the Executive Order when the 

Chairperson of PCIE and ECIE informed them that he had accepted the 

actions recommended by the NASA Administrator, and accordingly, the 

case file was closed on April 26, 2007.16

 

o The U.S. Postal Service (USPS) IG performed the investigation of the 

allegations made against the DOD IG, from November 2, 2005, to April 

25, 2006, and reported the results to the Integrity Committee on June 9, 

2006. The Chairperson of PCIE and ECIE sent a letter to the Deputy 

Secretary of Defense to suggest that DOD consider taking appropriate 

steps to address observations made during the investigation and 

included in the investigative report. However, the Integrity Committee 

concluded that none of the allegations were substantiated by the 

investigation and closed the case file on September 19, 2006. 

• For 24 allegations, the Integrity Committee concluded that the IG or Deputy IG 

had exercised the discretion of their office and found no indications of 

administrative misconduct. For example, one complainant alleged that the IG 

failed to perform investigations of possible fraud at a medical school. The 

Integrity Committee closed the case file and concluded that such decisions 

were made within the IG’s discretion and that the IG must decide where best 

to apply resources for investigations. 

• IGs provided additional information for the Committee’s review on 17 of the 

allegations, and the Committee found that none of these allegations involved 

actions that violated any laws, regulations, or rules, and there were no 

instances of mismanagement, waste, or abuse of authority. For example, a 

complainant alleged that an IG had taken official travel not related to the 

duties of the office. The Integrity Committee contacted the subject IG and 

requested a response to justify the official travel. After reviewing the IG’s 

documentation, the Integrity Committee closed the case file. 

• The Integrity Committee referred seven allegations back to the IGs who were 

the subjects of the allegations for actions as deemed appropriate by the IGs. 

These allegations generally related to administrative complaints from IG staff 

and, as determined by the Integrity Committee, did not rise to the criteria 

15The DOD IG was the subject of 15 allegations during the 3-year period; 6 were closed after the Integrity 

Committee investigation and 9 were closed without an investigation. 

16For more information on the outcome of this Integrity Committee investigation refer to GAO, Inspectors 

General: Actions Needed to Improve Audit Coverage of NASA, GAO-09-88 (Washington, D.C.: Dec. 18, 2008). 
 GAO-10-63R Integrity Committee’s Process Page 11

provided by the implementing policy and procedures for administrative 

misconduct. For example, a complainant alleged the IG had failed to 

investigate the agency’s illegal use of subpoenas. The Integrity Committee 

provided clarification to the complainant to show the agency’s actions were 

allowed. In addition, the Integrity Committee determined that the IG had the 

discretion to determine whether an investigation of the matter was warranted. 

• The Committee referred four allegations to another agency with jurisdiction 

over the matters. Three of these allegations were referred to the appropriate 

equal employment opportunity office and one was referred to the Office of 

Special Counsel. Two of these allegations had responses provided back to the 

Integrity Committee and the case files were closed. The remaining two 

allegations were closed when the referrals were made and the Integrity 

Committee did not require a response. 

The Integrity Committee took the following actions regarding the 72 allegations that 

it determined were not within its jurisdiction. These allegations were either not 

directed at an IG or an IG staff member acting with the knowledge of the IG, or failed 

to demonstrate any administrative misconduct. 

• The Committee referred 51 allegations to the responsible IGs for action as 

deemed appropriate. For example, one complainant alleged that the IG’s office 

had failed to investigate allegations of fraud associated with the award of a 

contract. The Integrity Committee concluded that the allegation failed to show 

a substantial likelihood of a violation of a law, regulation, or rule, nor gross 

mismanagement, waste, or abuse of authority by the IG or the Deputy IG. The 

Integrity Committee closed the case file for this allegation and referred the 

complaint to the IG for action as deemed appropriate. 

• For the remaining 21 allegations the committee 

o requested additional information in 10 cases from either the subjects or 

the sources of the allegations before closing the case files due to a lack 

of evidence of wrongdoing, 

o referred 8 allegations to another agency with jurisdiction, and 

o determined that 3 of the allegations involved issues within the 

discretion of the IG, and alleged no misconduct. 

Reform Act Provides Additional Guidance and Increased Transparency for 

Integrity Committee Activities 

The Reform Act established a statutory basis for the Integrity Committee within 

CIGIE, and provided the Integrity Committee with generally the same functions as 

those under the Executive Order to receive, review, and refer for investigation 

allegations of wrongdoing made against IGs and certain staff members of the IG 

offices. The Reform Act also provides new guidance and greater transparency over 

Integrity Committee activities than called for in Executive Order No. 12993. 
 GAO-10-63R Integrity Committee’s Process Page 12

’s consideration. 

 

The Reform Act requires the IGs to annually submit a designation of positions within 

each IG’s office whose holders are staff members subject to review by the Integrity 

Committee. The Integrity Committee’s revised policy and procedures implementing 

the Reform Act state that positions reporting directly to an IG are to be included, 

such as the Deputy IG and the Counsel to the IG. In addition, other positions with 

significant responsibilities should normally be included where it is likely that an 

internal investigation regarding an allegation of wrongdoing on the part of that staff 

member would lack an appearance of objectivity. As an example, Assistant IGs may 

be specified for review by the Integrity Committee. This guidance encourages the IGs 

to provide a designation of positions beyond the IG and the Deputy IG. 

The Reform Act also requires the Integrity Committee to establish policies and 

procedures that ensure fairness and consistency in conducting investigations and 

reporting the results. The Integrity Committee’s revised policy and procedures 

include steps to provide a copy of the report of investigation to the IG or designated 

staff member before the final consideration of the report by the Integrity 

Committee.17 The IG or designated staff member has the opportunity for comment 

concerning the report’s accuracy and may submit additional statements or 

documents for the Integrity Committee

In addition, the Reform Act enhances the transparency of the Integrity Committee’s 

process by establishing additional reporting requirements to help ensure timely 

notification to Congress of its investigations and other activities. The Reform Act 

requires the Integrity Committee to provide an executive summary of any completed 

investigation along with its recommendations to congressional committees with 

jurisdiction within 30 days after the investigative results are provided to the 

Executive Chairperson of CIGIE.18 In addition, the report of investigation is to include 

any recommendations of the Integrity Committee, including those on disciplinary 

action. Notification to Congress of the investigative results with recommendations 

can allow for additional oversight and help to ensure that meaningful corrective 

actions will be taken on weaknesses identified by current and future Integrity 

Committee investigations. 

The Reform Act also requires the CIGIE to submit additional information to both 

Congress and the President by the end of each calendar year on the activities of the 

Integrity Committee for the preceding fiscal year. This provides an opportunity for 

additional oversight of Integrity Committee activities. The reported information is to 

include the number of allegations received, referred to other agencies, and referred 

for criminal investigation; as well as those allegations referred to the Chairperson of 

the Integrity Committee for investigation and those allegations closed without 

referral. In addition, the report is to include the date the Committee received and 

closed each allegation, the status of investigations, and a summary of the findings of 

the investigations completed during the preceding fiscal year. The first annual report, 

for fiscal year 2009, is due to Congress by December 31, 2009. 

17 Executive Order No. 12993 previously allowed the Integrity Committee the discretion to ask the subject IG 

for comments before disposition. 

18The Reform Act requires that the Executive Chairperson of CIGIE receive the report of investigation no later 

than 30 days after completion of the investigation. 
 GAO-10-63R Integrity Committee’s Process Page 13

In addition, the Integrity Committee’s policy and procedures that implemented the 

Executive Order included a definition of administrative misconduct used to review 

allegations of wrongdoing. The revised policy and procedures in response to the 

Reform Act include this definition but add to it the consideration of matters that 

potentially involve conduct so serious that it may undermine the independence or 

integrity reasonably expected of an IG or a senior staff member in an IG office. 

During our review, we suggested that the Committee update its policy and 

procedures to make them consistent with the requirements of the Reform Act. The 

Committee issued its revised policies and procedures, The Council of the Inspectors 

General of Integrity and Efficiency, Integrity Committee Policy and Procedures, in 

April 2009. We provided a draft of our report to the FBI to obtain comments from the 

Integrity Committee Chairperson, who is Assistant Director of the FBI’s Criminal 

Investigative Division. In response the FBI stated that it had reviewed the draft report 

and had no comments. 

- - - - - 

As agreed with your offices, unless you publicly announce the contents of this report 

earlier, we will not distribute it until 30 days from its date. At that time, we will send 

copies of the report to the Integrity Committee, OMB Deputy Director for 

Management, the Chairperson and Vice Chairperson of CIGIE, other congressional 

committees, and interested parties. This report will also be available at no charge on 

the GAO Web site at http://www.gao.gov. If you have any questions or would like to 

discuss this report please contact me at (202) 512-8486 or by e-mail at 

raglands@gao.gov. Major contributors to this report are listed in enclosure V. 

Susan Ragland 

Director 

Financial Management and Assurance 
 GAO-10-63R Integrity Committee’s Process Page 14

Enclosure I 

Federal Agencies and Departments with IGs Established by the IG Act and 

Appointed by the President 

Agency for International Development 

Corporation for National and Community Service 

Department of Agriculture 

Department of Commerce 

Department of Defense 

Department of Education 

Department of Energy 

Department of Health and Human Services 

Department of Homeland Security 

Department of Housing and Urban Development 

Department of the Interior 

Department of Justice 

Department of Labor 

Department of State 

Department of Transportation 

Department of the Treasury 

Department of Veterans Affairs 

Environmental Protection Agency 

Export–Import Bank 

Federal Deposit Insurance Corporation 

Federal Housing Finance Agency 

General Services Administration 

National Aeronautics and Space Administration 

Nuclear Regulatory Commission 

Office of Personnel Management 

Railroad Retirement Board 

Small Business Administration 

Social Security Administration 

Tennessee Valley Authority 

Treasury Inspector General for Tax Administration 

Source: CIGIE 
 GAO-10-63R Integrity Committee’s Process Page 15

Enclosure II 

Designated Federal Entity IGs Established by the IG Act, as Amended, with 

Appointment by Their Agency Heads 

Amtrak 

Appalachian Regional Commission 

Broadcasting Board of Governors 1

Commodity Futures Trading Commission 

Consumer Product Safety Commission 

Corporation for Public Broadcasting 

Denali Commission 

Election Assistance Commission 

Equal Employment Opportunity Commission 

Farm Credit Administration 

Federal Communications Commission 

Federal Election Commission 

Federal Labor Relations Authority 

Federal Maritime Commission 

Federal Reserve Board 

Federal Trade Commission 

Legal Services Corporation 

National Archives and Records Administration 

National Credit Union Administration 

National Endowment for the Arts 

National Endowment for the Humanities 

National Labor Relations Board 

National Science Foundation 

Peace Corps 

Pension Benefit Guaranty Corporation 

Postal Regulatory Commission 

Securities and Exchange Commission 

Smithsonian Institution 

United States International Trade Commission 

United States Postal Service 

Source: CIGIE 

1 The Broadcasting Board of Governors is a designated federal entity with oversight provided by the 

Department of State IG. 
 GAO-10-63R Integrity Committee’s Process Page 16

Enclosure III 

Agencies with Inspectors General Appointed under Statutes Other than the 

IG Act 

Architect of the Capitol 

Central Intelligence Agency 

Government Accountability Office 

Government Printing Office 

Library of Congress 

Office of Director of National Intelligence2 

Special IG for Afghanistan Reconstruction 

Special IG for Iraq Reconstruction 

Special IG for the Troubled Asset Relief Program 

United States Capitol Police 

Source: CIGIE

2

The IG Act authorizes the Director of National Intelligence to appoint an IG. 
 GAO-10-63R Integrity Committee’s Process Page 17

Enclosure IV 

Allegations Against IGs and Their Staff at Federal Departments, Agencies, 

and Entities during Calendar Years 2005 through 2007 

Federal entities 

Number of 

Allegations 

1 National Aeronautics and Space Administration 35 

2 Department of Defense 15 

3 Department of the Interior 9 

4 Department of Veterans Affairs 9 

5 Department of Homeland Security 8 

6 Department of Transportation 8 

7 Department of Agriculture 6 

8 Nuclear Regulatory Commission 6 

9 Department of State 6 

10 United States Postal Service 6 

11 Department of Education 5 

12 Department of Health and Human Services 5 

13 Environmental Protection Agency 4 

14 Federal Deposit Insurance Corporation 4 

15 Internal Revenue Service (TIGTA) 4 

16 Railroad Retirement Board 4 

17 Agency for International Development 3 

18 Amtrak 3 

19 Department of Commerce 3 

20 Securities and Exchange Commission 3 

21 Department of Energy 2 

22 Department of Housing and Urban Development 2 

23 General Service Administration 2 

24 Office of Personnel Management 2 

25 Appalachian Regional Commission 1 

26 Department of Labor 1 

27 Department of the Treasury 1 

28 Federal Housing Finance Board 1 

29 Legal Services Corporation 1 

30 National Science Foundation 1 

31 Office of Government Ethics 1 

32 Office of Special Counsel 1 

33 Peace Corps 1 

34 Social Security Administration 1 

35 Special Inspector General for Iraq Reconstruction 1 

Total 165 

Source: GAO analysis of Integrity Committee case files. 
 GAO-10-63R Integrity Committee’s Process Page 18

Enclosure V 

GAO Contact and Staff Acknowledgments 

GAO Contact Susan Ragland, Director, (202) 512-8486 

Acknowledgments Financial Management and Assurance 

 Jackson W. Hufnagle, Assistant Director 

 Clarence A. Whitt, Analyst-in-Charge 

 Bonnie L. Derby, Evaluator 

 

 Office of General Counsel 

 

 Francis Dymond, Assistant General Counsel 

 Jacquelyn Hamilton, Deputy Assistant General Counsel 

(194744) 
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