OFFICE OF 

INSPECTOR GENERAL 

Audit of FCA’s 

Training and Conference Expenses 

September 22, 2014 

Audit Report 

FARM CREDIT ADMINISTRATION 

A-14-01 

Tammy Rapp 

Auditor-in-Charge 
 

 

 

 

     

               

             

   

       

  

                       

                              

                             

         

                           

                           

     

                 

                     

     

                              

                               

     

   

Memorandum	 Office of Inspector General 

1501 Farm Credit Drive 

McLean, Virginia 22102-5090 

September 22, 2014

The Honorable Jill Long Thompson, Board Chair

The Honorable Kenneth A. Spearman, Board Member

The Honorable Leland A. Strom, Board Member

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102‐5090

Dear Board Chair Long Thompson and FCA Board Members Spearman and Strom:

The Office of the Inspector General completed an audit of FCA’s Training and Conference Expenses.

The objectives of this audit were to determine the effectiveness of controlsrelated to training,

conferences, and related travel expenses.

The results of our evaluation revealed FCA has effective controls over training and conference

expenses. However, the Office of Management Services agreed to improve the Training Program in

the following areas:

1.	 Update policies and procedures governing training and conference expenses

2.	 Strengthen controls over the Training Program to ensure compliance with agency

policies and procedures.

We appreciate the courtesies and professionalism extended to OIG staff by FCA personnel. If you

have any questions about this audit, I would be pleased to meet with you at your convenience.

Respectfully, 

Elizabeth M. Dean
 

Inspector General
 

Enclosure
Farm Credit Administration 

Office of Inspector General 

September 
Executive Summary.........................................................................................................

Introduction and Background ..........................................................................................Objectives, Scope, and Methodology ...............................................................................Training Program - Facts and Findings:

1. Key Laws and Regulations - Training..............................................................................2. FCA Policies – Training Program....................................................................................

3. Training and Conference Expenses.................................................................................4. IDP Process and Budgeting.............................................................................................5. Comparison of IDP, Training Budget, and Actual Training Expenses .................................6. Training Budget............................................................................................................7. Training Expenses – Top 5 Vendors.................................................................................8. Employees with Training over $8,000..............................................................................9. Payments for Training over $5,000.................................................................................10. Internal Reporting.........................................................................................................

Conferences – Facts and Findings: 

1. Key Laws & Regulations – Conferences..............................................................................

2. FCA Sponsored Conferences .............................................................................................

Related Travel Expenses................................................................................................Agreed-upon Actions ...................................................................................................

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FCA’s mission as a financial regulator is to ensure a safe, sound, and depend

credit and related services for agriculture and rural America. FCA provides tropportunities to its employees to enhance the performance of their official duyear 2013, FCA reported training and conference expenses of $554,927 for itemployees. FCA has effective controls over training and conference expenses. Our audit of FCA’s Training Program revealed:  Policies and procedures issued are consistent with laws and regulations  FCA has multiple sources of training data  Actual expenses were significantly less than budgeted in FY 2010, 2011, and 2013  Actual expenses exceeded budget by approximately $12,000 in FY 2012  Training was consistent with job responsibilities and FCA’s mission  Most training was approved by 1st level supervisor and Training Officer on electronic C

Registration forms 

 FCA minimized expenses associated with agency sponsored conferences and training However, the Office of Management Services agreed to improve the Training Pfollowing areas:  Update policies and procedures governing training and conferences  Strengthen controls over the Training Program to ensure compliance with agency polic

procedures 

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Report #A-14-01 FCA’s Training and C
FCA’s mission as a financial regulator is to ensure a safe, sound, and de

source of credit and related services for agriculture and rural America. “FCA encourages the self-improvement and development of all FCA empsponsoring training and development opportunities to enhance the perftheir official duties and develop knowledge, skills, and abilities (KSAs) thenable them to successfully perform present or future responsibilities.” Procedures Manual (PPM) 843) FCA offers its employees a variety of training opportunities that include:  Examiner Commissioning Program 

◦ A multi-year program providing abilities, knowledge, and skills to plan and particip

and soundness examinations of FCS institutions 

 External conferences  Seminars  Higher education courses  Agency-wide training events 

◦ i.e. Retirement Planning, Leadership training 

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Objective: 

 Determine the effectiveness of controls related to training, conferences, an

travel expenses. 

Scope and Methodology:  Training and conference expenses 

◦ FY 2010 – FY 2013 ◦ Top 5 vendors with largest expenses paid by FCA (FY 2012, 2013) 

◦ Employee tuition exceeding $8,000 per year (FY 2012, 2013) ◦ Individual training courses exceeding $5,000 (FY 2012, 2013) 

◦ Did not review Examiner Commissioning Program 

 Limited review of related travel for training and conferences 

◦ Top 10 employees with greatest amount spent on travel to training or conferences 

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 Performed the following procedures: 

◦ Identified and reviewed related laws, regulations, and Agency policies and procedur◦ Conducted interviews with current Chief Human Capital Officer (CHCO)/Chief Finan

(CFO)/Director Office of Management Services (OMS), Deputy CFO, Training Officer, staff 

◦ Obtained broad overview of Individual Development Plans (IDP) process and training 

development 

◦ Obtained understanding of agency-wide training offered in FY 2012 and 2013 ◦ Identified training and conference expenses ◦ Reviewed databases supporting training data ◦ Identified and reviewed data for the top 5 vendors paid by FCA for training in FY 20◦ Identified employees with course registrations (completed course) over $8,000 in FY 

2013 

◦ Identified payments for external training over $5,000 in FY 2012 and FY 2013 

◦ Examined documentation supporting training for compliance with applicable policie

procedures

◦ Identified travel expenses related to training and conferences 

◦ Identified and performed limited review of related travel vouchers for top 10 emplo

greatest amount of travel expenses 

◦ Identified significant internal control processes and determined if they were operat

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We conducted this performance audit in accordance with generally accepted government a

standards. Those standards require that we plan and perform the audit to obtain sufficienevidence to provide a reasonable basis for our findings and conclusions based on our audbelieve the evidence obtained provides a reasonable basis for our findings and conclusionaudit objectives. Management is responsible for developing and maintaining effective internal controls. We internal controls identified as significant to the audit objectives. Additionally, we assessed computer processed data relevant to our audit objective and determined the data was sufffor purposes of this audit. Internal control weaknesses identified and respective recommepresented in this report. This audit was performed at the FCA Headquarters in McLean, Virginia, from March througthe conclusion of this audit, we provided management with a draft report of our observatioexit conference on August 28, 2014. 

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TRAINING PROGRAM 

FACTS & FINDINGS

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1 FCA’s Training and C
 5 United States Code (U.S.C.) § 4101(4) 

 Definition of Training:

◦ “the process of providing for and making available to an employee, and placing or e

employee in, a planned, prepared, and coordinated program, course, curriculum, suroutine of instruction or education, in scientific, professional, technical, mechanicafiscal, administrative, or other fields which will improve individual and organizationand assist in achieving the agency's mission and performance goals ...” 

 Chapters 41, 57 and 59 of title 5 U.S.C., and section 410 of title 

of Federal Regulations (CFR) are referenced in FCA’s policy.

◦ § 410.201 requires the head of the agency to establish and budget for a trai

employees. 

◦ § 410.302 directs the head of the agencies to submit training requests to OP

◦ § 410.306 directs agencies to establish criteria for fair and equitable selectio

◦ § 410.308 provides conditions for training leading to an academic degree 

◦ § 410.309 provides for continued service agreements ◦ § 410.403 provides for reimbursement of related travel expenses associated ◦ § 410.404 describes conferences that are considered training activities and s

requirements in order for a conference to be considered training 

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 FCA’s Training and C
PPM 843-Training, Development, Professional Certifications, Licenses an

Membership Fees  Provides policy and procedures for FCA’s Training Program 

Authority based on Title 5: CFR, Section 410 No significant differences identified between PPM 843 and Section 41

◦ Policy issued 9/13/2006; Implementing procedures issued 2/4/2012 

PPM 843 Attachment: FCA’s Agreement to Continue Service After Trainin Required service agreement when training exceeds defined threshold

◦ If exceeds 80 hours of training for one course, employee will “...serve the agency fo

length of the training.” 

◦ If exceeds $7,000 tuition for training on a particular subject matter in any given 12 

employee will “...agree to serve the agency for 1 year after the completion of the tr

 Note: Discrepancy identified in PPM 843 states threshold is $10,000. 

◦ Issued 5/14/2003 

Administrative Handbook #25  FCA Training Request and Training Tracking Procedures 

◦ Issued 10/18/2006 

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We identified the following differences within FCA’s policies and pro

See Agreed-Upon Action #1. 

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Differences within FCA policies and procedures 

PPM 843 PPM 843: 

Attachment 

AdministHandboo

Training requestsrequiring Chairmanapproval 

>$10,000 >$3,000 

Employee agrees to continue service with FCA for 1 year aftercompletion of training 

$10,000 tuition on a subject in a 12 month period 

Training expenses exceeding $7,000 on a subject in a 12 month period 

If employee voluntarily leaves FCA before completing serviceagreed 

Employee reimbursesFCA for tuition paid 

Employee reimbursesFCA for tuition and related fees, travel, and other special expenses 
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FCA provides training to its employees to support its mission and enhanknowledge, skills, and abilities needed to perform the job. FCA has multiple sources of training budget and expense data:  Individual Development Plans (IDP) 

◦ Used to document training needs identified by employee and supervisor 

 Budget 

◦ Summary of estimated training expenses budgeted by each office (9) 

 Course Registrations – Tuition 

◦ Used to document external training requests and approvals ◦ Data represents external tuition costs identified on Course Registrations completed and at

employee

◦ Not all courses attended or paid for by FCA had course registration forms ◦ Does not include agency-wide training ◦ Course registration records over a “couple years old” that did not have Training Officer ap

deleted by current Training Officer. Record retention policies do not specifically address t

 See Agreed-Upon Action #3 

 Actual Training Expenses and Obligations (see Slide 15) 

◦ Identified in accounting system ◦ Includes external and internal training expenses ◦ Data provided does not reflect items that were adjusted in a subsequent fiscal year 
Note: FCA does not routinely calculate or report training expenses. The above was identified for the purpose of this audit. 

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We compared the multiple sources of training data.

Fiscal 

Year 

2010 

FTE 

287 

IDP 

$883,675 

Budget 

$747,470 

Course 

Registrations 

$241,788 

2011 297 775,198 682,938 218,342 

2012 280 843,561 615,299 308,695 

2013 294 909,484 676,009 368,187 

More detail regarding this data presented in following slides.
408,969

436,131

627,663

554,927

 ‐

100,000200,000300,000400,000500,000600,000

FY 2010 FY 2011 FY 2012 FY 2013

700,000

Average Training 

per Employ

1,425 1,468

,000

500

2,001,50

00

FY 2010 FY 2011 

2,500

1

‐

Both charts contain items that were corrected in subsequent fiscal years and inflate dollars presented. Subsequent Adjustments:Data reflects report from Finance Team and does not reflect adjustments made in a subsequent fiscal year:

FY 2012 CIO Membership s/b consulting 47,320

FY 2012 OPM Survey s/b consulting ‐ 8,000

FY 2012 Duplicate OPM FEI purchase order ‐19,500

FY 2013 CIO Membership $91,557 will be adjusted 9/2014 ‐ amount tbd

 ‐

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 FCA had a formal process for IDPs 

◦ Used by most offices to document employee training and developmental needs ◦ Some offices did not complete IDP or used inconsistently 

 FCA is reevaluating the IDP process in conjunction with hiring a Learning O

◦ Tasked to “develop an integrated learning and performance management strategy 

retain a highly skilled workforce” 

 Agency budget for training 

◦ Based on each office’s annual budget ◦ Most offices used IDP as basis for budget ◦ Some offices used historical trends 

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1,000,000

900,000800,000700,000600,000500,000400,000300,000200,000100,000

Total FY 2010 Total FY 2011 Total FY 2012 Total FY 2013

IDP ‐ Tuition

Training ‐ Budget

Training ‐ Actual

 Significant differences between IDPs, training budget, and actual training 

◦ IDPs appear to be an overestimation of training needs identified by employees and ◦ Offices budgeted less than IDPs 

 Actual expenses were significantly less than budgeted in FY 2010, 2011, a

◦ Actual training expenses exceeded budgeted by approximately $12,000 in FY 2012 

‐

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1 FCA’s Training and C
Training Budget

Average Per Person

7

2,299

2,7002,6002,5002,4002,3002,2002,1002,0001,900

FY 2010 FY 2011 FY 2012 FY 2013

2,604

2,299

2,19

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400,000

350,000300,000250,000200,000150,000100,000

50,000

FY 2010FY 2011FY 2012FY 2013

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Report #A-14-01 FCA’s Training and C

 Office of Examination and OMS had largest training budget. 

◦ In FY 2013, FCA had 294 FTE. OE had 177 FTE. OMS had 50 FTE. 

In FY 2013, Office of Secondary Market Oversight accidentally combined $20,95expense with consulting, instead of budgeting separate for training. 



‐
Reviewed top 5 vendors with largest training expenses paid for by FCA i

and FY 2013  Course offerings consistent with FCA’s mission  Compared actual training expenses to course registrations 

Identified several variations with data Some differences accounted for: ◦ $47,320 in consulting was charged to training during FY 2012 and corrected in Decemb

◦ $19,500 for duplicate purchase order corrected in FY 2013 ◦ Agency-wide training courses and materials were not included in course registrations ◦ Some purchase orders not entirely used during the FY and carried over 

 Improvements need to be made to ensure accurate and reliable trai

expense data ◦ $8,000 for an OPM employee survey was charged to training during FY 2012 

◦ Some training expenses did not have course registration forms ◦ See Agreed-Upon Action #2 

FY 2013 data included $91,557 that should be partially charged to consplans to split this expense between training and consulting when the amdetermined at the end of FY 2014. See Slide 15 regarding subsequent adjustments. 

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

From our review of training expenses for employees with training $8,000 during FY 2012 and 2013: 

◦ External training was related to job responsibilities and FCA mission ◦ Most external training completed was identified on employee’s IDP ◦ Course registration form was created and approved by 1st level supervisor and Train

most external training 

◦ Payment documentation was available and traced back to accounting data ◦ Documentation of course attendance was limited to a self evaluation by the employ

Controls can be strengthened in a few areas: 

◦ Some course registration forms were missing, duplicate, or contained incorrect tuit◦ Some course registrations did not have approvals from Office Director and Chairma◦ No independent course documentation was provided to demonstrate attendance, ce

attendance and/or grades, when applicable 

◦ No service agreements were obtained ◦ Training leading to an academic degree did not have written approvals from Directo

Chairman 

◦ See Agreed-Upon Action #2 

Details of exceptions identified during audit follow on next two s

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◦ FY 2013 - 5 employees 

 Service agreements were not obtained for 4 employees who exceeded ann

$10,000 

 PPM 843: “Sign FCA Agreement to Continue Service After Training for 80 hours or more fo

$10,000 tuition for training on a subject in any given 12 month period” 

 PPM 843 Attachment: “Agreement must be signed when employee projected to receive m

training for one course or $7,000 on a subject matter in 12 month period” 

 2 employees working on masters degrees with job related courses paid by 

degree programs not approved by Chairman 

 PPM 843: “Director, OMS in consultation with CEO may authorize training leading to an aca

necessary to assist in recruitment or retention in occupations with existing or anticipated s

personnel” 

 No grades provided to verify employee successfully completed training 

 PPM 843: “Employee must reimburse FCA for full amount paid if employee fails to s

complete training (grade of “C” or better)” 

 1 course missing approval from Chairman ($19,875) 

 PPM 843: “Chairman reserves authority to prior approve all training requests for tuition tha

 1 course missing Office Director approval ($5,600) 

 PPM 843: Office Directors “Prior approve any training tuition over $5,000 and recom

tuition over $10,000” 

 2 duplicate course registrations ($1,900, $2,340) 

 These courses were not paid twice, but had duplicate registrations in the course re

database 

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◦ FY 2012 - 6 employees 



Service agreements were not obtained for 3 employees who exceeded annual tu$10,000 (2 additional employees exceeded annual tuition over $7,000)1 employee working on masters degree with job related courses paid by FCA; acprogram not approved by Chairman No grades provided to verify employee successfully completed training 1 course missing Office Director approval ($5,035) 1 missing course registration; approved on IDP ($2,260) 

 PPM 843 requires employees to complete Form 476, an electronic course registration fo

1 duplicate course registration ($5,035) 

 Course was not paid twice, but had duplicate registrations in the course registration da

1 course not attended due to scheduling conflict; course never rescheduled nor recovered to date ($1,220) 1 potential upward mobility program candidate; 

 PPM 811 – Upward Mobility Program; policy issued 10/9/1990, reassigned to OMS  Although OIG concluded this case did not meet specific criteria for upward mobility

consider whether significant training provided to an employee in conjunction with a 

reassignment, or change in series meets the intent of the Upward Mobility ProgramMobility Program was “to provide opportunities for employees to increase their skiltheir highest potential, and advance in accordance with their abilities in light of ava

opportunities.” 

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 FCA’s Training and C
 From our review of payments for training expenses over $5,000 d

year 2012 and 2013: 

◦ External training was related to job responsibilities and FCA mission ◦ Course registration form was created for external training ◦ Payments were traced to supporting documentation ◦ On 10 occasions, a cardholder exceed their purchase limit for training on the credit 

 Procurement Controls outlined by the CFO via email 5/25/2012: “...can purchase individual train

as approved by the training officer.” 

◦ 1st level supervisor and Training Officer approvals were obtained 

◦ Documentation of course attendance was limited to a self evaluation by the employ◦ A high ranking official attended an $8,000 course; OPM approval not obtained; no a

records retained 

 PPM 843: “Obtain approval from the Office of Personnel management for training for the Chairm

410.302(c)” 

 Controls can be strengthened in a few areas: 

◦ A cardholder exceeded their limit for training on the purchase card ◦ Written approval from the Office Director was not obtained for training exceeding $◦ OPM approval was not obtained for training attended by a high ranking official ◦ Independent course documentation to demonstrate attendance should be obtained 

a significant dollar amount 

◦ See Agreed-Upon Action #1 and #2 

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PPM 843 contains reporting requirements by the Director, OMS 



Quarterly - summary of training activities to each Office Director and CEO Annually - report on effectiveness of Training Program as a component of Capital Plan along with the measures of performance for the program “Provide an annual report on the analysis of IDPs, identified training needsaccomplishments, and plans to COO and Human Capital Steering Group” 

Facts and findings: 

No internal reports prepared for Chairman and CEO, Office Directors, COOCapital Steering Group Multiple Training Officers within past five years has caused gaps in the TraProgram See Agreed-Upon Action #2 

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CONFERENCES 

-

FACTS AND FINDING

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



Title 41: C.F.R. Part 300-3 

◦ Definition of conference ◦ A meeting, retreat, seminar, symposium or event that involves attendee travel ◦ Also applies to training activities that are considered to be conferences under Title 5: C.F.R

Title 41: C.F.R. Part 301-74 

◦ Provides guidance for planning conferences 

OMB Memorandum M-11-35, Eliminating Excess Conference SpendinPromoting Efficiency in Government 

◦ directs agencies, “...to conduct a thorough review of the policies and controls associated w

related activities and expenses.” 

OMB Memorandum M-12-12, Promoting Efficient Spending to SuppoOperations 

◦ requires agencies to focus on conference spending, and outlines new policies and practice

sponsorship, hosting, and attendance 

Consolidated and Further Continuing Appropriations Act 2013 and CoAppropriations Act of 2014 (§ 742(a)) 

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FCA minimized expenses associated with agency sponsored conferences and 

guidance to Office Directors Primarily to exchange information regarding the examination process and orinew employees 

◦ Travel greatest expense 

COO issued guidance regarding conference expenses in an email to Office Di7/15/2014 

◦ Defines “conference” ◦ Provides examples of conferences ◦ Provides examples of items not considered conferences ◦ Requires approval and reporting requirements by Office Directors if estimated trave

conference activity costs are $18,000-$100,000 in travel and conference activity c

 Developed Conference Request and Approval Form to facilitate reporting 

◦ Prohibits travel and conference activity costs exceeding $500,000 without a written 

Agency Head 

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 FCA’s Training and C
Contracts Desk Manual (OMS Directive #4) 

◦ Addresses conference planning ◦ Follow provisions of FTR to maximum extent possible ◦ All conferences must be approved by the Director, OMS 

OIG Reporting 

◦ OMS reported estimated costs of New Employee Orientation to the OIG in June 201

 Estimated costs were $19,320  Largest expense was travel  Other costs estimated at less than $5,000 

◦ Process was developed to ensure reporting to the OIG when applicable 

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Limited review of travel voucher summaries for selected employees 

reveal any inappropriate travel expenses related to training Identified travel expenses associated with training and conferences 

Purpose classified as training or conference attendance Non-local 

Although not a travel voucher audit, performed a limited review of ewith greatest amount of travel expenses related to training and con

Training related to employees’ duties and FCA mission Location appeared to be reasonable 

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1. OMS should update policies and procedures governing training and confe



Resolve inconsistencies identified in current policies and procedures Strengthen policies and procedures related to training leading to an academic deg

Consider higher level approvals for annual employee training exceeding a specific threshold Consider requiring independent course documentation for training exceeding a sthreshold Consider whether a cardholder’s purchase card limit for training needs to be incr

 Management Response: 

OMS agreed to determine appropriate thresholds, update policy and procedures

increased controls in the approval process for higher cost training. 

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01 FCA’s Training and C
2. OMS should identify and strengthen controls over the Training Program t

compliance with agency policies and procedures. 



Ensure all external training paid for by FCA has supporting Course Registration Ensure proper written approvals obtained from Office Director and Chairman wIdentify training potentially leading to an academic degree and obtain appropriObtain service agreements, when applicable Create flag in Course Registration database or process to track when an emplothreshold requiring service agreement or higher approvals 

Obtain course documentation to demonstrate attendance and grades, if applica

Seek OPM approval for training attended by the Head of the Agency 

Ensure purchase orders for vendors that provide training and consulting are pr

Develop a process to ensure required reports related to the Training Program a

 Management Response: 

OMS agreed to implement additional controls to ensure appropriate authorizatio

supporting documentation are obtained and maintained. OMS also agreed to im

additional controls to ensure training and consulting costs are appropriately allo

reporting requirements are met. 

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1 FCA’s Training and C
3. OMS should update policies and procedures related to record retention. 



Determine a record retention policy for training data and supporting documentInclude an independent verification process before any data or documentation Develop a process to ensure board members training records are included 

 Management Response: 

OMS agreed to update record retention policies and institute controls over the 

database to ensure independent verification is required before purging docume

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REPORT

Fraud | Waste | Abuse | Mismanagement

FARM CREDIT ADMINISTRATION

OFFICE OF INSPECTOR GENERAL

Phone: Toll Free (800) 437‐7322; (703) 883‐4316

Fax: (703) 883‐4059

E‐mail: fca‐ig‐hotline@rcn.com

Mail: Farm Credit Administration

Office of Inspector General

1501 Farm Credit Drive

McLean, VA 22102‐5090