Inspection and Evaluation External Peer Review Final Report 

December 17, 2019 

To Wendy R. Laguarda, Inspector General, Farm Credit Administration 

This required external peer review was conducted in accordance with the Council of the 

Inspectors General on Integrity and Efficiency (CIGIE) Inspection and Evaluation (I&E) 

Committee guidance as contained in the CIGIE Guide for Conducting Peer Reviews of 

Inspection and Evaluation Organizations of Federal Offices of Inspector General. The peer 

review was conducted from September 11, 2019 through December 6, 2019. 

The CIGIE External Peer Review Team (Review Team) assessed the extent to which Farm 

Credit Administration (FCA) Office of Inspector General (OIG) met the seven CIGIE Quality 

Standards for Inspection and Evaluation (Blue Book) standards, specifically: Quality Control; 

Planning; Data Collection and Analysis; Evidence; Records Maintenance; Reporting; and 

Follow-up. This assessment included a review of the internal policies and procedures 

implementing the seven required Blue Book standards. It also included a review of two 

selected I&E reports issued between June 30, 2017 - June 30, 2019, to determine whether the 

reports complied with the covered Blue Book standards and the FCA OIG I&E internal policies 

and procedures. 

The Review Team determined that FCA OIG I&E policies and procedures met all seven Blue 

Book standards addressed in the external peer review. Each of the two reports reviewed met the 

Blue Book standards and complied with FCA OIG I&E internal policies and procedures. 

We have issued a letter dated December 17, 2019 (Enclosure 1) that sets forth the results of the 

peer review. FCA OIG provided a response to our letter (Enclosure 2). 

Milton A. Mayo, Jr., Inspector General, U.S. Equal Employment Opportunity Commission 

Enclosures 

As stated 
 

ENCLOSURE 1: Letter of Comments, 

Scope and Methodology 

The Review Team selected two reports for review. For the last three years, FCA OIG I&E 

predominately conducted physical security and benchmarking assessments. Therefore, it is 

appropriate to assess one of each, with the most recent being representative of how these 

projects are currently conducted. The two reports we reviewed: 

1. Office of Examination Structure and Organization Benchmarking Evaluation, March 

20, 2019, E-18-02 

2. Physical Security in the Farm Credit Administration’s Headquarters, December 7, 

2018, I‐18‐04 

The Review Team conducted on-site visits on September 30th and October 15th, 2019. In 

addition to reviewing FCA OIG information sent to us and reviewed on-site, we interviewed 

the Assistant Inspector General for Audits, Inspections, and Evaluations, Sonya Cerne. The 

review team experienced no constraints, limitations, or impairments in conducting our 

review. 

Results and Findings 

INTERNAL POLICIES AND PROCEDURES 

Based on the Review Team’s assessment, the FCA’s OIG I&E policies and procedures 

sufficiently address the seven required Blue Book standards. 

COMPLIANCE WITH STANDARDS 

The following is a summary of the Review Team’s assessment of the two FCA OIG reports 

against the seven Blue Book standards included in this review. 

QUALITY CONTROL 

The CIGIE standard for inspection work is: “Each OIG organization that conducts inspections 

should have appropriate internal quality controls for that work.” Key elements of this standard 

include establishing mechanisms for quality control, documenting those mechanisms, and 

ensuring adequate supervision. 

Finding: 

Each reviewed report met the Blue Book standards identified in the report’s scope section and 

complied with the organization’s associated internal policies and procedures. 

PLANNING 

The CIGIE standard for inspection work is: “Inspections are to be adequately planned.” Key 

elements of this standard include creating a work plan, coordination (both internal and external), 

and research. 

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Finding: 

Each reviewed report met the Blue Book planning standard and complied with the 

organization’s associated internal policies and procedures. 

DATA COLLECTION AND ANALYSIS 

The CIGIE standard for inspection work is: “The collection of information and data will be 

focused on the organization, program, activity, or function being inspected, consistent with 

the inspection objectives, and will be sufficient to provide a reasonable basis for reaching 

conclusions.” This standard requires covered I&E organizations to describe the project’s 

sources of data and information in the supporting documentation, ensure information is 

appropriately scoped, employ procedures to ensure data reliability and validity, and ensure 

that the confidentiality of sources and sensitive information is safeguarded. Key elements of 

the standard related to data analysis include ensuring that data is reviewed for accuracy and 

reliability, information is appropriately presented and documented, procedures provide for 

supervisory review, and findings satisfy objectives. 

Finding: 

Each reviewed report met the Blue Book data collection and analysis standard and complied 

with the organization’s associated internal policies and procedures. 

EVIDENCE 

The CIGIE standard for inspection work is: “Evidence supporting inspection findings, 

conclusions, and recommendations should be sufficient, competent, and relevant and should 

lead a reasonable person to sustain the findings, conclusions, and recommendations.” Key 

elements of this standard include ensuring that evidence is sufficient to persuade a 

knowledgeable person of the validity of the related Findings and Recommendations, is 

collected and evaluated using reasonable methods, and has a logical relationship to the 

issue(s) being addressed. 

Finding: 

Each reviewed report met the Blue Book evidence standard and complied with the 

organization’s associated internal policies and procedures. 

RECORDS MAINTENANCE 

The CIGIE standard for inspection work is: “All relevant documentation generated, 

obtained, and used in supporting inspection findings, conclusions, and recommendations 

should be retained for an appropriate period of time.” Key elements of this standard include 

ensuring that supporting information is effectively organized, provides a record of the nature 

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and scope of the inspection, and provides sufficient information for supervisors to manage 

and evaluate staff; and that the organization has policies and procedures for document 

retention. 

Finding: 

Each reviewed report met the Blue Book records maintenance standard and complied with 

the organization’s associated internal policies and procedures. 

Observation: 

We believe that the ongoing discussions with National Archives and Records 

Administration (NARA) regarding updating the FCA OIG records retention schedule 

demonstrate that FCA OIG is acting prudently to ensure it efficiently meets both CIGIE and 

NARA requirements. 

REPORTING 

The CIGIE standard for inspection work is: “Inspection reporting shall present factual data 

accurately, fairly, and objectively and present findings, conclusions, and recommendations 

in a persuasive manner.” Key elements of this standard include ensuring that reporting is 

timely, accurate, and objective; provides sufficient context, describes objectives, scope, and 

methods; uses clear and concise language; and includes a statement that the inspection was 

conducted in accordance with the standards. The standard also requires that findings are 

supported by evidence, conclusions are logical inferences, and recommendations describe 

what should be corrected. 

Finding: 

Each reviewed report met the Blue Book reporting standard and complied with the 

organization’s associated internal policies and procedures. 

FOLLOW-UP 

The CIGIE standard for inspection work is: “Appropriate follow-up will be performed to 

ensure that any inspection recommendations made to Department/Agency officials are 

adequately considered and appropriately addressed.” Key elements of this standard include 

that the I&E organization determines whether agency officials take action to correct 

problems, performs follow-up work as appropriate to verify management actions, and 

considers prior recommendations and need for follow-up when planning and conducting new 

inspections. 

Finding: 

Each reviewed report met the Blue Book follow-up standard and complied with the 

organization’s associated internal policies and procedures. 

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Suggestion: 

We suggest that FCA OIG work with FCA to improve the corrective action plans to ensure 

FCA includes adequate details on how and when FCA plans to complete recommendation 

implementation. 

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ENCLOSURE 2: Reviewed Organization 

Comments to Draft Report 

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