Farm Credit Administration

Office of Inspector General

 Inspection Report

The Farm Credit Administration’s 

Property Management Program

I-21-03 

December 7, 2021
1501 Farm Credit Drive, McLean, VA 22102 703-883-4030 www.fca.gov/about/inspector-general

December 7, 2021

The Honorable Glen R. Smith, Board Chairman 

The Honorable Jeffery S. Hall, Board Member

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102-5090

 

Dear Chairman Smith and Board Member Hall:

The Office of Inspector General (OIG) completed an inspection of the Farm Credit Administration’s (FCA) 

Property Management Program. The objective of this inspection was to determine if FCA has 

implemented an adequate process to ensure accuracy in the property management system and 

adherence to internal policies and procedures.

The inspection found that FCA had implemented a process to account for property and keep 

employees accountable and responsible for assigned property. We found the status of old laptops 

donated and sold was properly annotated in the property management system, and FCA had 

designated responsibility to persons with various roles in the property management process.

However, we identified opportunities to improve the property management process. We identified 

errors in property assignments and missing or incorrect information in the property system. We also 

found a piece of purchased property that was not entered into the property system, as required. We 

found that policies and procedures, accesses, and controls over the program needed to be reviewed, 

updated, and further defined. 

We made nine recommendations in the report to enhance the property management program and 

ensure accuracy in the property management process. The Office of Agency Services agreed or partially 

agreed with the recommendations, and we find the completed or planned actions responsive to 

our recommendations. Due to the corrective actions implemented, we also consider 

recommendations 3, 7, 8, and 9 closed.

We appreciate the courtesies and professionalism extended by FCA to our staff during the inspection. 

If you have any questions about this inspection, we would be pleased to meet with you at your 

convenience. 

Respectfully,

Sonya K. Cerne 

Assistant Inspector General for Audits, Inspections, and Evaluations
EXECUTIVE SUMMARY

FCA’s Property Management Program

Report No. I-21-03 December 7, 2021

Objective

The objective of this inspection was to

determine if FCA has implemented an 

adequate process to ensure accuracy in 

the property management system and 

adherence to internal policies and 

procedures. 

Recommendations 

The Office of Inspector General made 

nine recommendations to the Office 

of Agency Services to enhance the 

property management program and 

ensure accuracy in the property 

management process. The 

recommendations relate to 

documenting and implementing 

policies and procedures, developing 

additional controls over the program, 

and resolving the issues identified in 

the report.

Agency Response

Management provided responsive

corrective actions for the 

recommendations made in the report. 

Management agreed with 

recommendations 1, 3, 5, 6, 7, and 9. 

Although management only partially 

agreed with recommendations 2, 4, 

and 8, the actions completed or 

planned by the Office of Agency 

Services address the weaknesses 

found in our report and the 

recommendations. Further, due to the 

corrective actions implemented over 

the course of the inspection, we

consider recommendations 3, 7, 8, and 

9 closed.

Why We Did This Inspection

The Farm Credit Administration (FCA) invests in property to achieve its 

mission. Property represents a significant cost to FCA and includes 

information technology assets that are used to process and store

nonpublic information. For these reasons, property needs to be 

accurately acquired, tracked, and maintained to protect the investment

and keep the Agency’s nonpublic information secure. 

How We Did This Inspection

We reviewed FCA’s property inventory and tested information in the 

property system over the course of this inspection from June to 

September 2021. We tested property assignments for new employees 

and separations at FCA from June 1, 2019 to May 31, 2021, and we 

reviewed old laptop donation and sales information from April to June 

2021. We also reviewed expenses for noncapitalized assets from 

October 1, 2020 to August 20, 2021.

What We Found

FCA has implemented a process to account for property and keep 

employees accountable and responsible for assigned property. We 

found the status of old laptops donated or sold was properly annotated 

in the property management system, and FCA had designated 

responsibility to persons with various roles in the property 

management process.

However, we identified opportunities to improve the property 

management process. We identified errors in property assignments for 

new and separated employees and in the assignments of old laptops 

not donated or sold. When testing the accuracy of property system 

data, we identified missing or incorrect information and laptops that 

were incorrectly assigned to employees. We also identified a piece of 

purchased property that was not entered into the property system as 

required. We also identified concerns with policies and procedures, 

accesses, and controls over the program that need to be reviewed, 

updated, and further defined. 
Table of Contents

Background............................................................................................................................................................................................................ 1

Farm Credit Administration .................................................................................................................................................................. 1

Office of Agency Services...................................................................................................................................................................... 1

Others with Property Responsibilities............................................................................................................................................... 1

Property Tracking..................................................................................................................................................................................... 2

Annual Certification of Assigned Property...................................................................................................................................... 3

Inventory and Reconciliation of Accountable Property.............................................................................................................. 3

Related Policies and Procedures......................................................................................................................................................... 3

Prior OIG Reports Relating to Property Management................................................................................................................ 4

Objective, Scope, and Methodology ............................................................................................................................................................ 4

Objective...................................................................................................................................................................................................... 4

Scope ............................................................................................................................................................................................................ 4

Methodology ............................................................................................................................................................................................. 4

Inspection Results................................................................................................................................................................................................ 6

Property Assignments .................................................................................................................................................................................. 7

New Employees......................................................................................................................................................................................... 7

Separated Employees ............................................................................................................................................................................. 7

New Laptop Distribution ....................................................................................................................................................................... 8

Donation and Purchasing of Old Laptops....................................................................................................................................... 9

PMTS Accuracy ............................................................................................................................................................................................... 9

PMTS Testing ..........................................................................................................................................................................................10

Expense Testing .....................................................................................................................................................................................11

Other Property Management Processes ............................................................................................................................................11

Root Causes ..................................................................................................................................................................................................12

PPM 851....................................................................................................................................................................................................12

OAS Draft Procedures on Property Management.....................................................................................................................13

Remote Working Environment.........................................................................................................................................................13

Timing Issues...........................................................................................................................................................................................13

Lack of Follow-Up .................................................................................................................................................................................14

Additional Training ...............................................................................................................................................................................14

Impact .............................................................................................................................................................................................................14

Recommendations......................................................................................................................................................................................14

Management Comments ...............................................................................................................................................................................17

Acronyms.............................................................................................................................................................................................................19
1 

BACKGROUND

Farm Credit Administration

The Farm Credit Administration (FCA or Agency) is an independent federal agency responsible for 

regulating and supervising the Farm Credit System (System) and the Federal Agricultural 

Mortgage Corporation. The Agency ensures that all System institutions are safe, sound, and 

dependable sources of credit and related services for all creditworthy and eligible persons in 

agriculture and rural America. 

In the 2018-2023 Strategic Plan, FCA states that the people who work for and with FCA are a 

strategic priority and achieving the mission largely depends on its people, practices, and 

technology. In order to accomplish the mission, the Agency acquires, maintains, and disposes of

property such as laptops, mobile devices, monitors, information technology property, and 

televisions. 

Office of Agency Services

FCA’s Office of Agency Services (OAS) manages and delivers human capital and administrative 

services for the Agency. OAS consists of three teams: Human Resources Division, Operations 

Division, and Learning and Organizational Change Team. The responsibility for property 

management is included under the Operations Division and the OAS Associate Director for the 

Operations Division is responsible for overseeing the administration of the Agency’s property

management program.

Within OAS, the Property Management Officer (PMO) is responsible for the overall management, 

coordination, and control of the Agency’s property management program and reports to the 

Associate Director for the Operations Division. The PMO is responsible for establishing procedures 

necessary to track the acquisition, receipt, assignment, and disposition of accountable Agency 

property; maintaining accurate and reliable records; establishing custodial processes; and 

conducting physical inventories once every two years. 

Others with Property Responsibilities

Many of FCA’s offices also designate a Property Custodian who is responsible for handling the 

transfer of accountable property within their respective office or organizational unit. The Property 

Custodian serves as the primary contact with the PMO, updates property records, and assists the 

PMO with physical property inventories and with annual property certifications for their respective 

office or organizational unit. Property Custodians also inform the PMO of accountable property 

purchased at the field office level. 

Certain individuals within the Office of Information Technology (OIT) also have responsibilities for 

the property management process, including OIT personnel who are assigned inventory before 
2 

issuance to employees, are responsible for printers or computer servers, or that work on the OIT 

Helpline1

. 

Employees also play a crucial role in property management by ensuring that assets assigned to 

them are maintained, safeguarded, and used for official business. Employees are required to sign 

property assignment forms, arrange with the PMO or Property Custodian when assigned property 

needs to be reassigned, notify pertinent personnel when property is lost, stolen, or broken, and 

return property before departing from the Agency. 

There are also additional, important responsibilities related to information technology (IT) assets. 

FCA’s PPM 902, Information Technology Security and Privacy Policy, states the following, “All FCA 

employees must understand their role in protecting our IT assets in support of our mission, serving 

our customers, and protecting our employees and the public. We must remain diligent in 

preventing leaks or corruption of FCA information.” Employees are required to sign a rules of 

behavior agreement that outlines employee responsibilities for protecting information and 

equipment. The following outlines some of the property-related points in the rules of behavior 

agreement: 

• maintain physical control of my FCA laptop and mobile devices, and exercise due diligence 

to prevent loss and theft at all times;

• secure FCA-issued equipment from loss, theft, or damage, and use the equipment only in 

accordance with guidelines set forth by OIT;

• follow OIT guidance on the use of mobile devices and personal use of FCA IT equipment; 

and

• immediately report incidents that may involve the loss of, or unauthorized access to, data 

or information to the OIT Helpline. This includes reporting lost, damaged, stolen, or 

destroyed agency-issued devices or personal devices authorized to access sensitive FCA 

information. I will follow all instructions provided by OIT within the timeframes provided. 

In most cases the timeframe will be immediate.

Property Tracking

FCA established the Property Management Tracking System (PMTS) as the official database used 

for tracking FCA property. It is FCA’s policy that all accountable property will be recorded in PMTS 

upon receipt. Property is assigned in the system by the PMO or Property Custodian to those that 

have possession of, or are accountable for, the property. Each piece of property has a status and 

condition section in PMTS as well as other important information. FCA uses the following criteria 

to determine when property will be tracked in PMTS:

1 OIT Helpline is involved with property tracking and maintenance if employees are having issues with 

property that may need to be repaired or replaced. When property needs repairing, the assignment would 

need to be changed to whomever has possession of the property. In instances of replacing property, 

Helpline would need to notify the PMO or a Property Custodian to have the property reassigned.
3 

• the property costs more than $500 per unit; 

• consideration of whether the property is a complete unit and does not lose its identity or 

become a permanent part of a separate unit; or

• it does not meet the above criteria, but is designated as accountable property by the PMO, 

with concurrence of the Chief Financial Officer.

Annual Certification of Assigned Property

In addition, automated property forms are completed through an internal system that links to 

PMTS for assignments and certifications. Forms are initiated by the PMO or Property Custodian

and sent for electronic signature to the assignee of the property. Property forms must be signed 

by employees when the property is originally assigned, reassigned, or the status of the property 

changes. Employees can view their assigned property in PMTS and must annually certify their 

property. The annual certification form shows:

• employee data;

• property assigned with bar codes, descriptions, serial numbers, and condition; 

• a comment field from the property system; and,

• a section for employee notes.

During the certification process, employees certify that they have the property items listed on the 

form in their control. The certification form also states that all Agency employees with assigned

assets are responsible for ensuring that the assets are maintained, safeguarded, and used for 

official purposes. 

Inventory and Reconciliation of Accountable Property

In addition to the annual certification process, an Agency-wide inventory of accountable property 

is conducted every other year. The physical inventory is completed by the PMO in coordination 

with Property Custodians across the Agency using PMTS and procedures implemented by the 

PMO. The PMO oversees the inventory process and coordinates a reconciliation of the inventory 

results.

Related Policies and Procedures

The Agency’s primary guidance on property management and related property accountability

standards and responsibilities is set forth in Policies and Procedures Manual (PPM) 851, Property 

Management Program Procedures. PPM 851 states the property management program is 

implemented to ensure integrity, accuracy, and effective, timely accountability of property as it 

moves through its lifecycle.

Additional information on property can be found in PPM 834, Employee Separation Clearance, for 

property requirements with employee separations, and PPM 812, Contracting/Procurement Policy, 

for the acquisition process, which may involve property.
4 

Prior OIG Reports Relating to Property Management 

The OIG issued a report in August 2012, Information Technology Equipment Acquisition (I-12-01), 

to determine whether the Agency’s acquisition process for information technology property was 

being appropriately planned and administered. The inspection determined the acquisition process 

was effective in determining the best and most cost-effective information technology property

needed for the Agency’s operations; however, the inspection identified areas where improvements 

could be made to increase transparency, accountability, and efficiency. Management agreed with 

the four recommendations made, which related to the laptop evaluation and acquisition process. 

All recommendations were closed by September 2012. 

OBJECTIVE, SCOPE, AND METHODOLOGY

Objective 

The objective of this inspection was to determine if FCA has implemented an adequate process 

to ensure accuracy in the property management system and adherence to internal policies and 

procedures. 

Scope

The inspection was conducted at FCA from June 2021 through December 2021. The scope of the 

inspection was limited to FCA property and information captured in PMTS. We limited our testing 

to certain areas as noted below in the methodology section. 

Methodology

We took the following steps to accomplish the objective:

• Identified and reviewed applicable laws, regulations, guidance, and other background 

information applicable to the objective. 

• Identified and reviewed applicable internal FCA policies and procedures. 

• Reviewed prior FCA-OIG and other external reviews related to the inspection objective. 

• Interviewed selected OAS and OIT personnel responsible for property management and a 

Property Custodian. 

• Reviewed materials for the new employee orientation for information on employee 

responsibilities relating to property. 

Tests Performed

 Requested and reviewed a listing of employee separations from the Agency from June 1, 

2019 to May 31, 2021, and compared the listing to property information in PMTS. We 
5 

reviewed property assignments and documented any property assigned to the separated 

employees by number of pieces and type of property in PMTS. 

 Reviewed a listing for all employees starting with the Agency from June 1, 2019 to May 31, 

2021. We removed employees that also separated in the same period. We compared the 

listing to property assignments in PMTS by employee. We documented exceptions when 

employees did not have any property assigned or they had certain property, but no laptop 

assigned.

 Reviewed a listing of all working property as of July 2021 from OAS. We sampled oldermodel laptops by model type and compared the information to assignments in PMTS. We 

noted exceptions for employees assigned older model laptops and verified information 

with OAS. The sample was judgmental based on laptop model type and cannot be 

projected to the population. 

 Reviewed disposal documentation for older laptops donated after the Agency’s new 

laptop distribution in 2020. We analyzed four donations to various entities totaling 150 

laptops. We sampled 30 of the laptops based on barcodes, entity donated to, and dates 

of donation. We reviewed assignment and status information in PMTS to verify donations 

were properly annotated. The sample was judgmental and cannot be projected to the 

population. 

 Received a listing of all laptops sold to employees after the 2020 new laptop distribution, 

totaling 103 laptops. We sampled 19 laptops based on barcodes and employee office. We 

reviewed assignment and status information in PMTS to verify sales were properly 

annotated. The sample was judgmental and cannot be projected to the population. 

 Exported a listing of all property classified as working from PMTS, as of August 2021. There 

were 2,261 pieces of property in PMTS classified as working, and we reviewed the listing 

for missing cost information and model and/or serial numbers. We also reviewed the 

information for pieces of property annotated with a disposal date. Because the sample was 

judgmental, it cannot be projected to the population. 

 Sampled 11 laptops in the possession of a Property Custodian. The laptops were physically 

viewed at FCA headquarters in August 2021. The barcode for each laptop was recorded 

and then compared to assignment information in PMTS. Because of the COVID-19 

pandemic, in-person testing in this area was limited. The sample was based on the physical 

location of the laptops and because it was judgmental, it cannot be projected to the 

population.

 Reviewed a listing from the Office of the Chief Financial Officer of FCA expenses 

categorized as noncapitalized equipment from October 1, 2020 to August 9, 2021. We 

sampled eight transactions based on amounts over $500. We reviewed contract and 

purchase documentation for each transaction to determine if property was received from 

the purchase. One transaction contained property received and we searched PMTS for the 

item, which was not found. OAS personnel confirmed the piece of property was not 

entered into PMTS. Because the sample was judgmental, it cannot be projected to the 

population.
6 

 Reviewed the 2019 annual property certification for completeness. The Agency did not 

perform the 2020 annual property certification; therefore, it was not reviewed.2

 Analyzed accesses to PMTS by employee and access level based on a report given to us 

by OIT. We confirmed access and proper levels of access with the PMO. 

 Searched PMTS for assignments to the PMO to evaluate separation of duties and 

responsibilities relating to property management. Analyzed all assignments to the PMO 

and sorted property classified as accountable and working.

Quality Standards for Inspection and Evaluation

This inspection was performed in accordance with the Council of the Inspectors General on 

Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. These standards require 

that we plan and perform the inspection to obtain sufficient and appropriate evidence that 

provides a reasonable basis for our findings, conclusions, and recommendations. We assessed 

internal controls and compliance with laws and regulations to the extent necessary to satisfy the 

objective. Because our review was limited, it would not necessarily have disclosed all internal 

control deficiencies that may have existed at the time of our inspection. We assessed the 

information and data collected during the inspection and determined it was sufficiently reliable 

and valid for use in meeting the inspection objective. We assessed the risk of fraud related to our 

inspection objective while evaluating evidence and had no matters come to our attention 

indicating fraud or illegals acts were occurring; however, our review was limited to the inspection 

objective. Overall, we believe the evidence obtained is appropriate and sufficient to provide a 

reasonable basis for our findings and conclusions based on the inspection objective.

INSPECTION RESULTS

During the inspection, we found that FCA implemented a process to track property and keep 

employees accountable and responsible for assigned property. FCA also has a disposal process 

for property no longer needed and has designated responsibility to various FCA personnel for

roles in the property management process. 

However, there are opportunities to improve the property management process and implement 

additional controls over the program to ensure accuracy and adherence to policies and 

procedures. Based on our testing, the property assignment process needs to be improved for new 

and separating employees. We also identified inconsistences in the accuracy of PMTS entries and 

identified additional controls needed for the program.

2 The annual property certification was not performed in 2020 due to the fact that employees were working 

remotely during the COVID-19 pandemic and could not verify the property that remained in their offices.
7 

Property Assignments

We found a number of inconsistencies in the property assignment process that undermined an 

essential part of the property lifecycle—accountability for who is in possession of and using the 

property. 

New Employees

When an employee is hired, OIT personnel, or the PMO, complete a property form to electronically 

route property assignments to employees as part of in-processing. Employees are notified and 

asked to certify that they have received the property. Generally, employees are assigned laptops 

and monitors, and certain employees are also assigned mobile devices and tablets. 

To test the implementation of the assignment process, we requested a listing from Human 

Resources of all employees hired from June 1, 2019 to May 31, 2021. From the listing, there were 

63 employees that were hired and remained at the Agency during this timeframe. When we 

reviewed the employees’ property assignments in PMTS, the testing showed that 19 employees 

were not assigned a laptop in PMTS even though all new employees were given laptops to 

perform their jobs. The employees were either not assigned any property or had been assigned 

certain property, such as mobile devices and monitors. 

Properly assigning property is important in order for employees to have accountability for items 

in their possession or control and to ensure the Agency knows who is using assets and where they 

are located and stored. When new employees do not sign for their property, it creates inaccuracies 

in the tracking system as those items remain incorrectly assigned to Property Custodians, the 

PMO, or OIT personnel.

Separated Employees

When an employee leaves FCA, the Agency has established checkout procedures that include 

returning property before separating from the Agency. Property Custodians or the PMO must 

collect and confirm receipt of all property assigned to the employee, reassign property in PMTS, 

and sign-off on the employee’s checkout form. 

To test the implementation of the assignment process for separations, we requested a listing from 

Human Resources of all employees separated from June 1, 2019 to May 31, 2021. The separated

employees’ property assignments were reviewed in PMTS. The testing revealed that 8 of the 69 

employees that left the Agency during the selected timeframe still had property assigned to them 

in the property management system. 
8 

Separated Employees with Number and Types of Property Assigned

Employee Date 

Separated

Number of 

Pieces of 

Property

Property Type

1 7/31/2019 3 Two monitors, broken computer

2 9/25/2019 123 Ten monitors, television, laptop

3 9/28/2019 1 Monitor

4 1/5/2020 1 Monitor

5 1/31/20204 2 Mobile device, laptop 

6 2/1/2020 1 Tablet

7 8/14/2020 2 Two monitors 

8 4/23/2021 1 Laptop

Property reassignments for separated employees are especially important for tracking assets. 

When the controls in place are properly working, an employee should not be able to complete 

their out-process without all property accounted for physically and in PMTS. Further, property that 

is not recovered should be identified as lost or stolen and must be reported to the proper 

personnel based on Agency guidance. Agency personnel stated some of the items on the listing 

were accounted for but had not been reassigned. Other property on the listing was unaccounted 

for and steps needed to be taken to properly classify such status in PMTS. 

New Laptop Distribution

There were also challenges regarding assignment information with the recent laptop changeover. 

FCA began a new laptop distribution process in fiscal year 2020. Employees were directed to turn 

in their old property the same day they received their new laptop. The laptop rollout was generally 

conducted in August and September 2020. The old laptops were returned to the headquarters 

offices, with laptops from field offices also shipped to headquarters. The old laptops should have 

3 The employee was a Property Custodian for an office.

4 This employee separated and returned multiple times during the timeframe reviewed. 
9 

been reassigned to remove them from employees’ property assignments to those with possession 

of the old laptops.

In order to test whether old laptops were reassigned in PMTS, we reviewed a listing of all working 

property as of July 2021 from the PMO. The listing information was then compared to PMTS. The 

testing of assignments for new laptop distributions revealed that 51 old laptops were still assigned 

to employees who had returned them when they received their new laptops. Of the 51 old laptops

identified, 20 were reassigned between July and August 2021, almost a year after the distribution 

process, and 31 old laptops needed to be reassigned in PMTS. As of September 2021, OAS 

personnel stated reassignments had been initiated for most of these old laptops, with a few 

reassignments still remaining. 

Just as it is important for employees to sign for their property in a timely manner, it is equally 

important for the Agency to reassign old property returned by employees. Not reassigning 

property causes inaccuracies in PMTS as well as in the reconciliation of property inventories.

Donation and Purchasing of Old Laptops

To the Agency’s credit, we identified no exceptions in PMTS with status changes showing the 

donation and employee purchasing of old laptops. OAS and the Office of the Chief Financial 

Officer provided documentation showing FCA had donated, sold, or disposed of more than half 

of the old laptops. According to OAS documents, FCA donated 150 of the older-model laptops in

2021 to several entities. We reviewed the status of 30 of the 150 laptops in PMTS, and all 30 

laptops were properly noted as donated. OAS also provided documentation showing 103 laptops 

that were purchased by employees. The status of 19 of the 103 laptops were reviewed in PMTS, 

and all of the laptops tested were properly classified. 

PMTS Accuracy 

We also identified opportunities for improvement in the accuracy of information tracked in PMTS.

FCA’s policy is that all accountable property will be recorded in PMTS upon receipt. Property 

details are entered in PMTS for each item. The following is a snapshot of how each piece of 

property is tracked in PMTS:
10

PMTS Testing

In order to test the accuracy of information, we exported a listing of property with a “working” 

condition from PMTS. At the time of testing,

5

 there were 2,261 pieces of property in PMTS 

classified as working.

6 The testing of the working property revealed the following inaccuracies: 

• 8 pieces of property were noted as working but had a disposal date. Property that is 

classified as working should not have a disposal date as that would indicate the property 

is no longer working. 

• 505 pieces of property had no cost information, which is 22 percent of all property 

classified as working. 

• 27 pieces of property had missing model or serial numbers, and some had both numbers 

missing. 

5 The information was pulled from PMTS on August 9, 2021.

6 PMTS has multiple classifications of property for property status and condition. PMTS shows options for 

statuses as: Accountable, Defunct, Surplus, and Donation/Sale/Recycled. Condition options are: Sold, 

Disposed, Donated, Stolen, Replaced, Surplus, Broken, Working, Traded, Lost, Obsolete, and Spare. 
11

In addition, the OIG tested whether PMTS accurately reflected the correct assignments for laptops 

possessed by a Property Custodian.

7 We tested 11 laptops in the possession of a Property 

Custodian to verify whether the laptops had been correctly assigned in PMTS. However, 8 of the 

11 laptops were assigned to other people in PMTS, not the Property Custodian in possession of 

the laptops. 

Because the PMTS drives the property assignment and inventory processes, it is imperative that 

information in the system is accurate. In addition, while all information in PMTS is important, cost 

information is one of the more important elements in PMTS for identifying and prioritizing risks 

related to the management of assets. 

Expense Testing

To test whether the Agency was properly adding purchased property in the PMTS, the OIG 

requested all fiscal year 2021 expenses through August 20, 2021, under the noncapitalized 

equipment budget code from the Office of the Chief Financial Officer. This code was specifically 

selected due to its likelihood of capturing property purchases. 

During the period tested, 19 property purchases were listed in the selected budget code. We 

selected all transactions over the $500 threshold set by the Agency that requires property to be 

placed in PMTS. In total, 8 of the 19 transactions met the threshold. 

• The first two selections were purchases under contracts. Both of these purchases were not 

for physical property, but for licenses to continue to run or install software applications; 

therefore, no exceptions were noted for these transactions. 

• For the other six transactions sampled, the expenses were charged to a government 

purchase card. Only one of them contained physical property over the $500 threshold that 

was not in PMTS. The PMO stated the purchase was for a field office battery and the 

information was not communicated by the purchaser to the PMO in order to place the 

property in PMTS, as required.

While there was only one exception in the testing, the lack of communication on property acquired 

with a purchase card could lead to further inaccuracies in PMTS and noncompliance with internal 

policies and procedures. 

Other Property Management Processes

Certain processes relating to the property management program need to be improved. We found 

that the Agency communicated policies, procedures, and requirements regarding property 

management to employees, including new employees. OAS also identified property management 

as a review element for its portion of the Management Control Plan. In addition, OAS tracked and 

7 Due to the COVID-19 pandemic, in-person testing of laptops was limited. 
12

completed internal reviews for the property management program. However, there were two 

processes that need strengthening as noted below: the PMO’s property assignments and access 

to PMTS. 

Additional separation of duties or controls are needed to ensure the accuracy of the PMO’s 

property assignment tracking and inventory process. As of our review, the PMO had 1,281

property assignments in PMTS, with 337 of those classified as accountable, and 276 of those 

classified as accountable and working. In certain instances, such as property being prepared for 

donation, it may be necessary to assign property to the PMO in addition to the property needed 

to perform the job of the PMO. However, having such a large amount of property assigned to the 

PMO calls into question the control system in place because it is the PMO who also oversees the 

physical inventory of property and coordinates a reconciliation of the inventory. Property assigned 

to the PMO should be inventoried and reconciled by someone other than the PMO, and internal 

policies and procedures on the inventory process should include stronger internal checks and 

balances. 

We also found that OAS needs to review accesses to PMTS. As of our review, 31 people8 in the 

Agency had access to PMTS, 10 with read-only access and 21 with contribute access. Contribute 

access means the individuals are allowed to enter and change certain information in PMTS. Access

to PMTS is granted to the PMO, Property Custodians, and those employees in OAS, OIT, and the 

Office of the Chief Financial Officer with property management responsibilities. Out of the 31 

people with access to the PMTS, three individuals no longer had a need to access the system and 

one had a higher-level access than needed. In addition to these accesses that need to be resolved, 

a comprehensive review of PMTS accesses is needed to reconsider the large number of individuals 

with contribute access. Accountability for accurate property assignments and tracking may be

undermined when 21 individuals have the ability to enter and change information in PMTS.

Root Causes 

We identified several root causes of the inconsistencies and inaccuracies identified during our 

inspection. By addressing the causes, the property management system, including accurately 

tracking Agency property, will be improved.

PPM 851

PPM 851, Property Management Program Procedures, outlines the policies and procedures for the 

Agency’s property management system but does not explain the detailed PMTS process on how 

to classify property or address property management processes that may differ in the field offices. 

The Agency implemented a revised PPM 851 in 2018 that established important information and 

processes. However, there are unclear references that may cause confusion about the application 

of federal property regulations to FCA, which would be a cornerstone for policies and procedures. 

8 This includes one OIG person that gained read-only access to PMTS for this inspection.
13

PPM 851 provides, among its listed references, the Federal Property and Administrative Services 

Act of 1949, as amended, and the Federal Property Management Regulations System. While OAS 

received a legal review on the revisions to PPM 851, there are limitations on the applicability of

these authorities to FCA that are not noted in the PPM. Specifically, 40 U.S.C. § 113 limits the 

applicability of these authorities with respect to, “an official or entity under the Farm Credit Act of 

1971 (12 U.S.C. 2001 et seq.), with respect to the acquisition or disposal of property.” Therefore, 

given the limitation, the PPM 851 references could be misconstrued without specific guidance on 

what provisions of the property laws apply to FCA or what provisions the Agency follows as a 

matter of policy and practice.9

 

OAS Draft Procedures on Property Management

OAS has drafted, but not yet implemented, internal procedures for the property management 

program. While the procedures will clarify the process and the use of the PMTS, certain gaps 

remain. The draft procedures do not always clarify the respective roles of the PMO and the 

Property Custodians, such as when and who will be responsible for making changes in PMTS. The 

draft procedures also do not set forth how property management procedures may differ for the 

field offices. In addition, as noted earlier, the draft procedures do not contain controls in place for

property assigned to the PMO or ensure that entries in PMTS are complete and accurate. Finally, 

the draft procedures should comport to a revised PPM 851 that clearly delineates what property 

management laws apply to the Agency or are followed by the Agency as a matter of policy and 

practice.

Remote Working Environment

The COVID-19 pandemic has caused unique issues to property management. OAS elected not to 

perform the annual certification process in 2020 due to the Agency’s remote working status.

Personnel also stated that the COVID-19 pandemic and remote working environment changed 

how new employees were in-processed. The pandemic and the inability to work onsite also 

affected personnel’s ability to physically review old laptops when they were shipped back to 

headquarters.

Timing Issues

There were also several issues with the timing of property assignments that affected the 

assignment process. Specifically, property assignments for new hires were made before the 

employee records for such hires had been created by Human Resources. Without the new 

employee records in place, property assignments were not being processed. OAS personnel stated 

several new actions have been created to assist with the process, including an alert to property 

9 As an example of another PPM where the Agency has clarified what laws and regulations may not apply 

to FCA, PPM 812, Contracting/Procurement Policy, clarified that as a non-appropriated fund agency, FCA is 

not subject to the Office of Federal Procurement Policy Act or the Federal Acquisition Regulation.
14

personnel when new employee records are not in place to complete an action. However, these 

processes need to be documented to ensure that roles and responsibilities are clearly identified. 

Lack of Follow-Up

Property management personnel stated certain reassignments had been initiated in the system, 

but not completed by Agency personnel. While the PPM is clear on employee responsibilities for 

assignments, there are no procedures for when an employee does not complete required 

assignment or reassignment functions. OAS has not established processes that include timeframes 

on notifications to employees and supervisors if an employee is nonresponsive to required 

employee actions. For example, if an employee is nonresponsive to a property assignment form, 

the PMO could initiate contact within a certain number of days and involve the supervisor if it 

remains unresolved. 

Additional Training 

Lastly, for those with certain property responsibilities, additional training may be needed to clarify 

roles and responsibilities. For example, purchase card holders may need refresher training to 

ensure purchases that meet the requirements are entered into PMTS. By providing training, OAS 

could educate and remind these individuals of the requirements.

Impact 

The proper management of FCA property is important to ensure that employees have the tools 

they need to meet the Agency’s mission, protect the investment in the property, and protect the 

security of assets that are used to process and potentially store nonpublic information. The 

recommendations set forth below are aimed at strengthening property management policies and 

procedures to clarify and specify property management roles and responsibilities; enhance the 

accuracy of property assignments, tracking, and inventory reconciliation; and provide training 

needed to ensure that all accountable property is documented in PMTS. 

Recommendations 

In order to enhance the property management program and ensure accuracy in the property 

management process: 

1. The Office of Inspector General recommends the Office of Agency Services update Policies

and Procedures Manual 851 to clarify the applicability of legal references and steps to be 

taken if employees are nonresponsive to property requirements. 

2. The Office of Inspector General recommends the Office of Agency Services finalize the 

internal policies and procedures for the property management program.

3. The Office of Inspector General recommends the Office of Agency Services resolve 

property statuses of separated employees identified in the report. 
15

4. The Office of Inspector General recommends the Office of Agency Services document 

controls to ensure new employees are assigned their property.

5. The Office of Inspector General recommends the Office of Agency Services resolve 

incorrect assignments and errors identified in the report. 

6. The Office of Inspector General recommends the Office of Agency Services implement 

additional controls on the inventory process for, and property assigned to, the Property 

Management Officer. 

7. The Office of Inspector General recommends the Office of Agency Services designate 

someone other than the Property Management Officer to inventory and reconcile property 

assigned to the Property Management Officer.

8. The Office of Inspector General recommends the Office of Agency Services issue guidance 

to purchase card holders on property thresholds and requirements.

9. The Office of Inspector General recommends the Office of Agency Services review the 

access listing to the Property Management Tracking System for inaccuracies and consider 

reviewing the number and level of accesses of all users to the system.

FCA Response

FCA management agreed, or partially agreed, with the nine recommendations. Management will 

revise PPM 851. Management also stated implementing procedures will be included in the PPM 

that clarify roles and responsibilities, describe process controls, document controls on new 

employee assignments, and describe the new process for the PMO’s inventory.

OAS resolved the property status issues for the eight separated employees identified in the report. 

Management stated the other errors identified in the report will be resolved and a report showing 

correct assignments and the resolution of the errors will be provided to the OIG. OAS also directed 

the Associate Director of Operations to serve as the reviewing official for all property assigned to 

the PMO. In addition, the OAS Administrative Assistant will serve as the Property Custodian for 

OAS and the Office of the Chief Financial Officer. Management also stated the Administrative 

Assistant has been trained, received required accesses, and assigned property. 

OAS also worked in conjunction with the FCA Credit Card Program Coordinator to provide 

education to purchase cardholders on a new process in the requisition routing system to include 

an accountable assets field. The new process reminds cardholders that FCA is required to account 

for certain property purchased and notifies the PMO when the accountable property is purchased 

so it can be entered into PMTS. Specific instructions were given to cardholders for property over 

$500 and a training video was also included in the communication. Lastly, OAS coordinated with 

OIT to update accesses to PMTS and provided an updated access list to the OIG. 

Management estimated the remaining actions will be completed by January 2022.
16

OIG Response

The OIG finds the actions responsive to our recommendations. Management agreed with 

recommendations 1, 3, 5, 6, 7, and 9. Although management only partially agreed with 

recommendations 2, 4, and 8, the actions completed or planned by OAS address the weaknesses 

found in our report and the corresponding recommendations. Further, due to the corrective 

actions implemented over the course of our inspection, we consider recommendations 3, 7, 8, and 

9 closed.

Management comments can be found in the subsequent section of the report. The Agency waived 

an exit conference. 
17

MANAGEMENT COMMENTS
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19

ACRONYMS

Agency or FCA Farm Credit Administration

IT Information Technology

OAS Office of Agency Services

OIG Office of Inspector General

OIT Office of Information Technology

PMO Property Management Officer

PMTS Property Management Tracking System

PPM Policies and Procedures Manual

System Farm Credit System

U.S.C. United States Code
REPORT FRAUD, WASTE, ABUSE, &

MISMANAGEMENT

Fraud, waste, abuse, and mismanagement in government concerns 

everyone: Office of Inspector General staff, FCA employees, Congress, 

and the general public. We actively solicit allegations of any inefficient 

and wasteful practices, fraud, and mismanagement related to FCA 

programs and operations. You can report allegations to us in several 

ways:

Phone: (800) 437-7322 (Toll-Free)

(703) 883-4316

Fax: (703) 883-4059

Email: fca-ig-hotline@rcn.com

Mail: 1501 Farm Credit Drive

McLean, VA 22102-5090

To learn more about reporting wrongdoing to the OIG, please visit our 

website at https://www.fca.gov/about/inspector-general.