Inspectors General: DHS OIG's Structure, Policies, and Procedures Are Consistent with Standards, but Areas for Improvement Exist
Published: 2014-09-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The DHS OIG plays a critical role in strengthening accountability throughout DHS. The OIG received about $141 million in fiscal year 2013 appropriations to carry out this oversight.
The joint explanatory statement to the Department of Homeland Security Appropriations Act, 2013, directed GAO to review the OIG and its organizational structure for meeting independence standards. This report examines (1) the coverage the OIG's audits and inspections provided of DHS's component agencies, management challenges, and high-risk areas; (2) the extent to which the OIG's organizational structure, roles, and responsibilities were consistent with the IG Act; and (3) the extent to which the design of the OIG's policies and procedures was consistent with applicable independence standards.
To address these objectives, GAO obtained relevant documentation, such as selected reports and OIG policies and procedures, and compared this information to the IG Act and independence standards. GAO also interviewed officials from the OIG, DHS components, and the FBI.
section_title: What GAO Found
paragraphs: During fiscal years 2012 and 2013, the Department of Homeland Security's (DHS) Office of Inspector General (OIG) issued 361 audit and inspection reports that collectively cover key components, management challenges identified by the OIG, and relevant high-risk areas identified by GAO. Of the 361 reports, 200 pertained solely to the Federal Emergency Management Agency (FEMA)—the DHS component with the largest budget. Of those FEMA reports, 118 reports involved audits of disaster assistance grants.
The OIG's organizational structure, roles, and responsibilities are generally consistent with the Inspector General (IG) Act of 1978, as amended (IG Act). In 2013, the OIG made changes to its structure to enhance independence and oversight, including establishing an Office of Integrity and Quality Oversight. However, areas for improvement exist for the OIG to better meet its responsibilities.
The OIG has not reached agreement with the Federal Bureau of Investigation (FBI) on coordinating and sharing border corruption information. The IG Act requires OIGs to recommend policies for and to conduct, supervise, or coordinate relationships with other federal agencies regarding cases of fraud or abuse. The Senate Appropriations Committee directed DHS to report jointly with the OIG and other DHS components on plans for working with the FBI.
The OIG lacks adequate controls to protect identities of employees filing complaints because its process for recording complaints involves significant manual procedures, without review, that can be subject to human error. The IG Act requires that OIGs not disclose the identity of an employee filing a complaint without the employee's consent unless such disclosure is unavoidable during the course of an investigation. The OIG is aware of these issues and is developing standard operating procedures.
The OIG does not have a policy for obtaining legal advice from its own counsel or guidelines specifying when it is appropriate to consult with the department's counsel. The former Acting IG requested legal help from a counsel at the department for 4 months, and it was not clear if this request was for appropriate matters. The IG Act requires the IG to obtain legal advice from a counsel reporting directly to the IG or another IG. The OIG Deputy Counsel has asked a working group to draft guidelines on consultations with the department's counsel.
The OIG's policies and procedures are consistent with independence standards. However, OIG senior executives did not always comply with the policy to annually complete certificates of independence. Because the OIG does not centrally maintain the certifications, management's ability to monitor compliance is hindered. For example, no certificate of independence could be found for the former Acting IG. As a result of an impairment to the former Acting IG's independence that was not identified in a timely manner, the OIG had to reissue six reports for fiscal year 2012 to add an explanatory statement about the impairment. External peer reviews of the OIG's audit function, completed in 2009 and 2012, also found that OIG staff, including senior executives, had not documented their independence as required.
section_title: What GAO Recommends
paragraphs: GAO is making three recommendations for improving controls over processing complaints, obtaining legal advice, and monitoring compliance with independence standards. The IG concurred with GAO's recommendations and described actions being taken to address them.

section_title: Letter
paragraphs: The Department of Homeland Security’s (DHS) Office of Inspector  General (OIG) has a critical role in strengthening accountability  throughout DHS and a responsibility to provide independent and objective  oversight of the department’s $91 billion in budgetary resources. To fulfill  its accountability and oversight responsibilities, the DHS OIG conducts  audits, inspections, and investigations of the department’s programs and  operations. The Department of Homeland Security Appropriations Act,  2013, provided DHS OIG approximately $145 million in fiscal year 2013  appropriations to fund these activities.
To help ensure that the OIG’s work is impartial and is viewed as such by  DHS components, Congress, and the public, it is vital that the OIG  maintain its independence, in fact and appearance. Moreover, the  Inspector General (IG) Act of 1978, as amended (IG Act), requires that  the OIG be independent and that it comply with Government Auditing  Standards, which includes specific standards on independence. The joint  explanatory statement accompanying the 2013 Department of Homeland  Security Appropriations Act directed GAO to review the OIG’s  organizational structure and whether its audit, inspection, and  investigation functions are organizationally structured to ensure that  independence standards are met.on November 8, 2013, we briefed your committee staffs on our  preliminary observations.
To meet the committees’ time frames,  This report provides the results of our review to determine (1) the  coverage that the OIG’s audits and inspections provided of DHS’s key  component agencies, management challenges, and high-risk areas;   (2) the extent to which the OIG’s organizational structure, roles, and  responsibilities were consistent with the IG Act; and (3) the extent to  which the design of the OIG’s policies and procedures for planning,  reviewing, and reporting on audit, inspection, and investigation results  were consistent with applicable independence standards. To address our  objectives, we reviewed the DHS agency financial report for fiscal years  2012 and 2013; the OIG’s annual performance plans and semiannual  reports for fiscal years 2012 and 2013, including major management  challenges identified; and GAO’s High-Risk Series for 2013. compared the subjects of DHS OIG reports issued during fiscal years  2012 and 2013 with the department’s key component agencies as well as  with the management challenges and high-risk areas that were identified  for the department. We reviewed the DHS OIG’s organization charts,  written policies and procedures, and internal inspection and peer review  reports. We compared the OIG’s organizational structure, roles, and  responsibilities with selected IG Act requirements. We also compared the  OIG’s written policies and procedures with independence standards  promulgated by Government Auditing Standards and the Council of the   We interviewed  Inspectors General on Integrity and Efficiency (CIGIE).
GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013). officials from the OIG, DHS components, and the Federal Bureau of  Investigation (FBI).
We conducted this performance audit from June 2013 to September 2014  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. A more detailed explanation of  our objectives, scope, and methodology can be found in appendix I.
subsections: section_title: Background
paragraphs: On November 25, 2002, President Bush signed the Homeland Security  Act of 2002, as amended, officially establishing DHS, with the primary  mission of protecting the American homeland. DHS became operational  on January 24, 2003. On March 1, 2003, under the President’s  reorganization plan, 22 agencies and approximately 181,000 employees  were transferred to the new department.
DHS is currently organized into the components shown in table 1, seven  of which are referred to as key operational components.
According to DHS, the seven key operational components lead the  department’s frontline activities to protect the nation. The other remaining  DHS components provide resources, analysis, equipment, research,  policy development, and support to ensure that the frontline organizations  have the tools and resources to accomplish the DHS mission. The  department’s five key mission areas are (1) preventing terrorism and  enhancing security, (2) securing and managing the nation’s borders,   (3) enforcing and administering the nation’s immigration laws,   (4) safeguarding and securing cyberspace, and (5) ensuring resilience to  disasters. In fiscal year 2013, DHS had about 226,000 full-time equivalent  staff, and its budgetary resources totaled approximately $91 billion.
subsections: section_title: DHS Office of Inspector General
paragraphs: Over three decades ago, Congress established independent IG offices  throughout the federal government as a result of growing reports of  serious and widespread internal control breakdowns resulting in monetary  losses and reduced effectiveness or efficiency in federal activities. The IG  Act established IG offices at major departments and agencies, including  DHS, to prevent and detect fraud, waste, abuse, and mismanagement in  their agencies’ programs and operations; to conduct and supervise  audits, inspections, and investigations; and to recommend policies to  promote economy, efficiency, and effectiveness. As required by the IG  Act, the DHS IG is presidentially appointed and confirmed by the  Senate. The DHS OIG consists of several different component offices,  as described in table 2.
section_title: IG Independence Requirements
paragraphs: The IG Act provides specific protections to IG independence that are  necessary largely because of the unusual reporting requirements of the  IGs, who are subject to the general supervision and budget processes of  the agencies they audit while at the same time being expected to provide  independent reports of their work to Congress. Protections to IG  independence include a prohibition on the ability of the agency head to  prevent or prohibit the IG from initiating, carrying out, or completing any  audit or investigation. This prohibition is directed at helping to protect the  OIG from external forces that could compromise its independence.  Although these protections apply to the DHS OIG, exceptions exist for the  Secretary of DHS when certain sensitive information or situations are  involved.independent to knowledgeable third parties is also critical when the IG  makes decisions related to the nature and scope of audit and  investigative work performed by the OIG.
The IG’s personal independence and the need to appear  An independent and reliable OIG structure firmly established at federal  agencies is important for ensuring effective oversight of programs and  operations. Auditors who work for OIGs are required to adhere to  independence standards included in Government Auditing Standards,  also known as generally accepted government auditing standards. Government Auditing Standards states that an audit organization and  individual auditor must be free from impairments to independence and  must avoid the appearance of an impairment. Auditors and audit  organizations must maintain independence so that their opinions,  findings, conclusions, judgments, and recommendations will be impartial  and be viewed as impartial by objective third parties with knowledge of  the relevant information. This requires staff to act with integrity, exercise  objectivity and professional skepticism, and avoid circumstances or  threats to independence that would cause a reasonable and informed  third party to believe that an OIG’s work had been compromised.
In addition, to the extent legally permitted and not inconsistent with  Government Auditing Standards, federal OIGs are required, as  appropriate, to adhere to the quality standards promulgated by CIGIE.  These standards include requirements for OIGs, including OIG  employees who work on investigations and inspections, to maintain their  independence. For additional information on quality and independence  standards for OIGs, see appendix II.
GAO-12-331G.
section_title: DHS OIG’s Audit and Inspection Reports Provided Coverage of Key Component Agencies, Management Challenges, and High-Risk Areas
paragraphs: During fiscal years 2012 and 2013, the DHS OIG issued 361 audit and  inspection reports. These reports provided coverage of all DHS key  operational components, management challenges, and high-risk areas.  According to the OIG, the majority of its audits and inspections were  performed in response to congressional mandates or requests, while  others were planned by the OIG based on factors such as the  department’s strategic plan, which identifies strategic missions and  priorities, and by the OIG’s annual performance plan and major  management challenges identified for the department.
subsections: section_title: OIG Reports Covered All DHS Key Components
paragraphs: Our review of issues addressed in the DHS OIG’s audit and inspection  reports issued during fiscal years 2012 and 2013 found that the OIG  provided oversight of all components that DHS has identified as its key  operational components. In addition, several OIG reports covered other  DHS components, multiple components, and department-wide issues, as  shown in table 3.
As table 3 illustrates, the majority of the OIG’s audit and inspection  reports issued in fiscal years 2012 and 2013 addressed issues at the  Federal Emergency Management Agency (FEMA). Specifically, 200 of  these reports (55 percent) pertained solely to FEMA. Of these 200  reports, 166 reports involved audits of FEMA grants, including 118 reports  on Disaster Assistance Grants. According to OIG officials, the large  number of FEMA audits can be attributed to a number of factors. For  example, the OIG has a statutory mandate to annually conduct audits of a  sample of states and high-risk urban areas that receive grants  administered by DHS to prevent, prepare for, protect against, or respond  to natural disasters, acts of terrorism, and other disasters.FEMA’s programs are considered to have a higher financial risk than  those of other DHS components because it distributes disaster relief  funds to so many communities nationwide—for example, as of May 2014,  over 135,000 applicants (e.g., local governments and nonprofit   In addition,  organizations to which public assistance funds are awarded) were  receiving disaster assistance. Moreover, FEMA has the largest budget of  all DHS components, with total budgetary resources of over $36 billion for  fiscal year 2013, or about 38 percent of the department’s total budget. In  addition, the OIG received $27 million from the Disaster Relief Fund in  fiscal year 2013 specifically for conducting audits and investigations  related to disasters.
section_title: OIG Reports Covered All Reported DHS Management Challenges and High-Risk Areas
paragraphs: Of the 361 audit and inspection reports issued during fiscal years 2012  and 2013, we found that 355 OIG reports pertained to the department’s  management challenges reported by the OIG. OIGs began annually  identifying management challenges (i.e., what the IG considers to be the  most serious management and performance challenges facing the  agency) for their respective departments or agencies in 1997 at the  request of Congress and continue to do so based on requirements of the  Reports Consolidation Act of 2000.to include their IGs’ lists of significant management challenges in their  annual performance and accountability reports to the President, the Office  of Management and Budget, and Congress. DHS reports this information  in its annual agency financial report. As shown in table 4, the OIG reports  issued during fiscal years 2012 and 2013 covered all nine management  challenges identified for that time period.
section_title: Structure of DHS OIG Is Consistent with the IG Act, but Certain Policies and Procedures Could Be Improved
paragraphs: The DHS OIG’s organizational structure includes all of the positions  required by the IG Act, as well as several nonstatutory positions that help  the OIG carry out its responsibilities. According to the OIG, changes to  the OIG’s structure made during fiscal year 2013 were intended to help  further strengthen its organizational independence. The OIG also has  policies and procedures designed to carry out most of the responsibilities  required by the IG Act. However, we identified three areas—coordinating  with the FBI, protecting employees’ identities, and obtaining legal  advice—in which the OIG’s policies and procedures could be improved to  better meet its responsibilities.
subsections: section_title: DHS OIG Organizational Structure Is Consistent with Provisions of the IG Act
paragraphs: The IG Act requires that each OIG have certain specific positions in its  organization. First, for cabinet departments and certain major agencies, it  requires that each OIG be headed by an IG appointed by the President  and confirmed by the Senate. The act also requires that each IG appoint  or designate certain other positions, including an Assistant IG (AIG) for Audits, an AIG for Investigations, and a Whistleblower Protection Ombudsman.
The IG Act also requires that each IG obtain legal advice from a counsel  either reporting directly to the IG or to another IG. In addition, a special  provision for the DHS OIG requires the IG to designate a senior official to  carry out responsibilities related to receiving and investigating complaints  that allege abuses of civil rights or civil liberties.
The DHS OIG has all of the positions required by the IG Act, which are  highlighted in the OIG’s organization chart in figure 1.
For example, the DHS OIG has its own Office of Counsel, which is  currently headed by a Deputy Counsel to the IG. Furthermore, in January  2012, the OIG issued a policy directive that designated the position of the  AIG for Investigations as the Civil Rights and Civil Liberties Coordinator  for investigative matters. In November 2012, the former Acting IG  designated an individual within the Office of Investigations as the acting  Whistleblower Protection Ombudsman with a goal of improving the  availability of whistleblower protection information to employees  throughout the department. In August 2013, after this function was  transferred to the Office of Integrity and Quality Oversight (IQO), the  same person became the permanent Whistleblower Protection  Ombudsman.
The DHS OIG has created several other senior positions in addition to  those required by the IG Act, which are also shown in figure 1. As of July  2014, these positions include the Deputy IG and Chief of Staff within the  OIG executive office, who provide executive leadership to the OIG. In  addition, the OIG has AIGs to lead its Offices of Emergency Management  Oversight, Information Technology Audits, Inspections, Integrity and  Quality Oversight, and Management. As discussed further below, the  Deputy IG position has been vacant since December 2013 and all of the  AIGs report directly to the IG as of July 2014.
section_title: Several Key OIG Positions Had Extended Vacancies
paragraphs: While the OIG’s organizational structure appears reasonable and includes  the positions required by the IG Act, at the time of our audit, several of its  key positions had not been filled with permanent employees for extended  periods of time or had only recently been filled. In November 2013, the  Senate held a hearing related to this issue in which the Ranking Member  of the Subcommittee on Efficiency and Effectiveness of Federal Programs  and the Federal Workforce, Committee on Homeland Security and  Governmental Affairs noted that vacancies in the IG and several key OIG   For example, the IG  positions left the agency without proper leadership.position was either occupied by an acting IG or vacant from February 27,  2011, through March 5, 2014. Specifically, with the former IG’s  resignation in February 2011, the Secretary designated the Deputy IG as  the Acting IG who served in that position until January 2013, when he  reached the statutory time limit for serving as an acting officer.point, the Acting IG reverted back to the title of Deputy IG, while still  remaining the de facto head of the OIG. Because the Deputy IG was the  head of the organization during that time, a Chief Operating Officer  position was created in March 2013 to assume the functions that would  otherwise be carried out by the Deputy IG when the IG position was filled.  The Deputy IG once again became Acting IG in November 2013, when an  IG was nominated, until his resignation in December 2013. Upon the  Acting IG’s resignation, the Chief Operating Officer served as the head of  the OIG until a new IG was confirmed by the Senate on March 6, 2014,  and assumed the post on March 10, 2014. The Chief Operating Officer  retired in April 2014 and the position was eliminated in July 2014.
Other executive positions within the OIG were also filled by acting staff for  extended periods, including the following:
The Counsel to the IG had been vacant and filled by an Acting  Counsel since December 2012 and remained so as of September  2014.
The AIG for Investigations was acting for 1 year before becoming  permanent in May 2013.
The Office of Inspections has had an Acting or vacant AIG position  since August 2012, except for approximately 2-½ months in early  2013 when it had an AIG.
section_title: Changes to Organizational Structure Are Intended to Improve OIG Independence
paragraphs: In January 2013, the OIG’s Office of Management evaluated the  organizational structure of the OIG in regard to critical issues it was  facing, including two situations that occurred in 2011 and 2012 that  potentially threatened the credibility and independence of the OIG. One  incident, which is detailed later in this report, arose from a conflict of  interest with the former Acting IG, who had a family member who worked  for a DHS unit associated with six audits or inspections, and required the  reissuance of the associated reports. As a result of the OIG’s Office of  Management’s study of this incident, the Chief Operating Officer position  was created, as previously mentioned, to take on the normal duties of the  second-in-command while either the Deputy IG or IG position was vacant.  This included reviewing reports from which the former Acting IG had  recused himself in order to avoid future conflicts of interest and to  improve OIG independence.
The second incident resulted from a lack of independence of an  inspection team from the Office of Investigations that was conducting an  internal inspection of an Office of Investigations field office in September  2011. The Department of Justice subsequently investigated this incident,  and a grand jury issued an indictment in April 2013 against two  employees in the Office of Investigations field office. The defendants were  accused of falsifying documents prior to the internal inspection in order to  impede, obstruct, and influence the inspection and conceal from the  inspectors severe lapses in the field office’s compliance with the OIG’s  investigative standards and internal policies. In March 2014, a federal  court found one of the employees guilty of conspiracy and five counts of  falsifying government documents. As a result of the OIG’s Office of  Management’s study related to this incident, the DHS OIG established  IQO in the summer of 2013 to enhance its organizational independence  and oversight of its operations. According to OIG officials, this office was  established to foster a more efficient and responsive OIG, revitalize  oversight efforts, and better serve employees. At the time of our review,  IQO was taking over various quality control functions previously carried  out by other OIG offices. Specifically, IQO was given responsibility for the  following functions:  Internal inspections of the OIG’s audit, inspection, and investigation  offices, which were previously conducted by the Offices of  Management and Investigations.
Quality review of draft audit and inspection reports, which was  previously done primarily by a report reviewer in the executive office.  The same individual will continue reviewing reports but is now part of  IQO.
Complaint intake, including the OIG hotline and whistleblower  protection functions, which was previously conducted by the Office of  Investigations.
Ombudsman for OIG employees, which was also previously under the  Office of Investigations and at that time was only set up to address  concerns of Office of Investigations personnel.
OIG officials indicated that the Hotline and Whistleblower Protection  functions would be in a better position to protect confidentiality and have  better visibility if they were separate from the Office of Investigations as is  the case in many similar organizations. In addition, IQO officials said that  they were taking steps to strengthen both the Ombudsman and  Whistleblower Protection functions by developing formal policies for these  positions and providing training about these functions to the entire  department. The establishment of IQO is a positive step toward improving  the OIG’s organizational independence for the reasons cited by the OIG  and because it provides a separation of duties where independence  problems previously existed.
section_title: DHS OIG’s Roles and Responsibilities Are Generally in Accordance with the IG Act
paragraphs: The DHS OIG’s policies and procedures contained in its manuals and  directives indicate that the OIG’s roles and responsibilities are generally  consistent with selected requirements of the IG Act. Provisions of the IG  Act include requirements that IGs carry out the following responsibilities,  among others:
Conduct audits and investigations related to department programs  and operations.
Receive and investigate complaints or information from DHS  employees regarding possible violations of law, rules, or regulations,  or mismanagement, waste, abuse, or substantial danger to public  health and safety.
Maintain oversight responsibility for internal investigations performed  by DHS components, such as the U.S. Secret Service, U.S.  Immigration and Customs Enforcement (ICE), and U.S. Customs and  Border Protection (CBP).
Establish and maintain a direct link on the home page of the OIG  website for individuals to report fraud, waste, and abuse.
Recommend policies for, and conduct, supervise, or coordinate  activities for, promoting economy, efficiency, and effectiveness in the  administration of the department’s programs and operations or  preventing and detecting fraud and abuse.
Report expeditiously to the Attorney General whenever the IG has  reasonable grounds to believe there has been a violation of federal  criminal law.
As discussed further in appendix III, we found that the DHS OIG had  established policies and procedures to carry out these and other selected  requirements of the IG Act. Specifically, the OIG had manuals containing  detailed policies and procedures to follow in carrying out its audits,  inspections, and investigations. For example, the manual for the Office of  Investigations—the Special Agent Handbook—included policies and  procedures for receiving and investigating complaints.
While most of the OIG’s roles and responsibilities are consistent with the  IG Act, we identified three areas—coordinating with the FBI, protecting  employees’ identities, and obtaining legal advice—in which the OIG could  improve its policies and procedures to be more effective in meeting the  OIG’s mission objectives.
subsections: section_title: OIG Lacks Agreement with the FBI for Coordination on Border Corruption Investigations
paragraphs: Although the OIG has a policy for notifying the FBI of any criminal  investigations that it or another DHS component opens, it does not have  an agreement with the FBI for sharing other information or otherwise  coordinating efforts with the FBI on tips or allegations related to border  corruption that are not under investigation. The IG Act requires OIGs to  recommend policies for, and to conduct, supervise, or coordinate  relationships between, the OIG and other federal agencies with respect to  the identification and prosecution of participants in fraud or abuse.  According to Attorney General Guidelines, OIGs have primary  responsibility for preventing and detecting waste and abuse and  concurrent responsibility with the FBI for preventing and detecting fraud  and other criminal activity within their agencies and their agencies’  programs.
Congress has repeatedly expressed concern about border corruption and  has held hearings on this issue. For example, in June 2011, the Senate  held a hearing on CBP and the OIG’s collaboration in the fight to prevent  border corruption. The hearing included a discussion of OIG efforts to  work with the FBI as well as CBP in preventing corruption among federal  employees involved in protecting the U.S. borders. To investigate  corruption among employees of agencies involved in protecting the U.S.  border, the FBI has established several local border corruption task  forces (BCTF), many of which operate along the southwest border. The  OIG participates in local BCTFs both in the southwest and other  locations. In addition, the FBI established the National BCTF to help  provide guidance and oversight of the local BCTFs. To facilitate the  operation of the National BCTF, in 2010, the FBI signed a memorandum  of understanding (MOU) with CBP and the Transportation Security  Administration. Although the OIG has agents assigned to the BCTFs, OIG  officials stated that they did not sign this MOU because the ongoing  dialogue has not yielded an agreement that recognizes the OIG’s  statutory authority and adequately delineates the roles and  responsibilities of all parties involved, including the DHS components.  OIG officials also stated that they could not reach agreement on sharing  information with the FBI because, in their view, the proposed agreement  was not sufficient to ensure mutual information sharing between the OIG  and the FBI.
Since at least 2010, the OIG and FBI have been working to reach  agreement on an MOU to describe how the parties would work together,  along with other DHS components, on the National BCTF. OIG officials  told us that since a permanent AIG for Investigations was designated in  May 2013, he has been making efforts to improve relationships. For  example, the AIG for Investigations has had more meetings with the FBI  and DHS components involved in the National BCTF, such as CBP and  ICE, to discuss coordination and information-sharing efforts as well as  ways to reach agreement on a BCTF MOU. The AIG for Investigations is  also in support of the National BCTF and is working diligently with the FBI  to reach an agreement, but stated that he believes that the information to  be shared needs to be clearly defined and that the FBI must also agree to  share information.
Until the OIG and FBI reach agreement on working collaboratively, they  are at risk of duplicating efforts or missing opportunities for taking  effective action against border corruption. Recognizing this risk, the  Senate Committee on Appropriations report for the DHS appropriations  bill, 2014, directed the DHS Deputy Secretary—jointly with the OIG, CBP,  and ICE—to report not later than March 17, 2014, on specific steps being  taken to further address the process for investigating cases of corruption  and the plan to work as a unified DHS with the FBI’s BCTF. In addition,  the Senate Committee on Appropriations report for the DHS  appropriations bill, 2015, directed the DHS Deputy Secretary—jointly with  the OIG, CBP, and ICE—to submit a status update report on the same  issues no later than 60 days after the enactment of the DHS  Appropriation Act, 2015.
section_title: OIG Lacks Adequate Controls to Protect Identities of Employees Filing Complaints
paragraphs: The OIG receives and reviews complaints filed by DHS employees and  the public regarding allegations of misconduct, including criminal  misconduct, by DHS employees. It receives these complaints both  directly from employees as well as through DHS components, where  some complaints are initially filed. However, the OIG’s process for  handling complaints that it receives directly from employees does not  include adequate internal controls to provide reasonable assurance that  the identities of employees who file complaints and request confidentiality  will be protected. The IG Act requires that IGs shall not, after receipt of a  complaint or information from an employee, disclose the identity of the  employee without his or her consent unless the IG determines that such  disclosure is unavoidable during the course of an investigation.  Consistent with the IG Act, OIG policy requires not disclosing the  identities of employees who file complaints. However, the OIG’s process  for recording complaints and forwarding them to DHS components when  necessary involves certain manual procedures usually carried out by only  one OIG complaint intake employee per complaint without supervisory  review. This process can be subject to human error; consequently, the  OIG is at higher risk of not being able to ensure that employees’ identities  will be protected.
During fiscal year 2013, according to OIG data provided to us, about 50  percent of the complaints received by the OIG came through the Joint  Intake Center run by CBP and ICE and another 6 percent were received  from other DHS components. The rest of the complaints were received  directly from complainants through the OIG’s website or by e-mail, fax, or  phone. Complaints received through the website (about 15 percent) are  automatically recorded into the OIG’s complaint database, the  Enforcement Data System, while complaints received through all other  means, including those from the Joint Intake Center, must be manually  recorded in the Enforcement Data System.
Although the transfer of complaint information from the OIG’s website into  the Enforcement Data System is more automated than complaints from  other sources, the website lacks certain controls that could result in the  inadvertent disclosure of employees’ identities. For example, when filing a  complaint on the website, if an employee does not want to allow full  disclosure of his or her identity, an employee can choose to be   (1) anonymous or (2) confidential. However, the website lacks certain  controls over these two categories. For example, see the following:
The anonymous category is intended to mean that the complainant  does not have to supply any identifying information. To select  anonymous, a complainant can check a box on the website. However,  after complainants make this selection, the website still allows  complainants to provide their names and other personal information,  which could potentially be disclosed.
The confidential category is intended to mean the employee provides  identifying information but does not want it released outside of the  OIG. If an employee wants confidentiality rather than anonymity, the  employee must write in the request for confidentiality on the website  form because the website does not have a box to check for this type  of complaint. As a result, even though the Enforcement Data System  includes a “complaint confidential” box, a request for confidentiality on  the website does not automatically record this request in the  Enforcement Data System. Therefore, requests for confidentiality  depend on the analyst who subsequently reviews the complaint  manually marking the correct box in the system.
Regardless of how a complaint is received, when a complaint is recorded  in the Enforcement Data System, it is initially reviewed by a complaint  intake analyst who determines if the complaint should be forwarded to a  field office of the OIG Office of Investigations in the complainant’s  jurisdiction. If it is forwarded, an OIG investigator in that office reviews the  complaint and decides whether to open an investigation on it. If the OIG  decides not to investigate the complaint, and the complaint was received  through the Joint Intake Center or another DHS component, a complaint  intake analyst will usually send it back to the component without first  notifying the complainant since the component has already had access to  the complaint information. However, if the complaint was received directly  from an employee rather than through a DHS component (e.g., OIG  website, e-mail, fax, or phone), the intake analyst will send an e-mail to  the employee requesting his or her consent to forward the complaint to  the DHS component. If the employee provides consent, the analyst  forwards the complaint to the component via e-mail. If an employee does  not provide consent, the complaint may still be sent to the component but  without any identifying information. However, there is no secondary check  of this manual process, such as a supervisory review. As a result, the  protection of an employee’s identity depends on the accuracy and  integrity of the individual processing the complaint. Without additional  controls, the OIG could inadvertently disclose employees’ identities  without their consent. Such disclosure can put employees at risk of  retaliation by the DHS components in which they work and could  discourage other employees from filing complaints. Officials in IQO said  that they were aware of these issues and that they were developing  standard operating procedures and considering improvements to the  website and the Enforcement Data System to better protect employees’  identities, but they did not indicate when these would be complete.
section_title: OIG Lacks Guidelines for Obtaining Legal Advice
paragraphs: While the OIG has its own Office of Counsel, it sometimes also obtains  advice or discusses legal issues with the department’s counsel. As  previously discussed, the IG Act requires that an IG obtain legal advice  from either a counsel reporting directly to the IG or a counsel reporting to  another IG. However, the act does not preclude an IG from obtaining  advice from its respective department’s counsel if appropriate. For  example, it may be appropriate for the IG to consult the department’s  counsel for legal advice regarding certain personnel practices if the OIG  is subject to the human capital laws or regulations of the department or  regarding ethics issues if the designated ethics official is a department  employee.
In its recent report on an investigation into allegations of misconduct by  the former Acting IG, the Subcommittee on Financial and Contracting  Oversight, Senate Committee on Homeland Security and Governmental  Affairs, reported that the former Acting IG inappropriately sought advice  from the department’s counsel, according to former OIG officials.interviewed former and current OIG officials and reviewed various e-mails  provided that indicated the former Acting IG sought legal advice from a  counsel at the department on several occasions. In general, we found the  consultations were likely acceptable and appropriate as the legal matter  appeared to be under the department’s purview. However, in one e-mail  the former Acting IG stated that he had lost confidence in his counsel and  wanted legal help from a counsel at the department for the next 4 months.  Because the former Acting IG’s request did not specify the type of legal  assistance needed, it was not clear whether his request or any  subsequent legal assistance received was for appropriate matters. The  OIG did not have a policy stating the legal requirement for the IG to obtain  legal advice from either the IG’s counsel or from counsel reporting to  another IG, nor did it have any guidelines specifying the circumstances in  which it would be appropriate for the OIG to consult with the department’s  counsel. Having such a policy and guidelines could help avoid any  potential impairment to independence when seeking legal advice. The  OIG’s Deputy Counsel stated that he was considering whether to develop  a policy and that he has asked a working group to draft guidelines on  consultations between the OIG and the department’s counsel.
section_title: DHS OIG’s Policies and Procedures Were Consistent with Applicable Independence Standards, but Effective Implementation Is Key
paragraphs: Independence is one of the most important elements of a strong OIG  function as it helps to ensure that an IG’s work is viewed as impartial by  agency personnel, Congress, and the public. The DHS OIG’s policies and  procedures indicated that the OIG staff were expected to comply with  both generally accepted government auditing standards (GAGAS) and  CIGIE independence standards. Each of the OIG’s oversight functions— audits, inspections, and investigations—had its own manual of policies  and procedures that was consistent with applicable independence  standards. However, the procedures for ensuring compliance with these  standards varied among the different functions.
subsections: section_title: Audit Policies and Procedures Were Consistent with Independence Standards but Have Not Been Consistently Followed
paragraphs: Three offices within the DHS OIG conduct audits—the Offices of Audits,  Information Technology Audits, and Emergency Management Oversight.  Officials from each of these offices said that their operations are guided  by DHS’s OIG Audit Manual, which refers to GAGAS and CIGIE  independence standards and provides guidance consistent with these  standards. In addition, each of their audit reports includes a statement  about the audit’s compliance with GAGAS.
The OIG Audit Manual describes the OIG’s quality assurance and control  system that, according to the manual, provides the controls necessary to  ensure that GAGAS audits are conducted in accordance with applicable  auditing standards and internal policies and guidance. For example, the  manual requires supervisory and management reviews of audit  documentation and resulting reports prior to issuance. The manual states  that the AIG for each audit office is responsible for ensuring  implementation of these controls. Other parts of the OIG’s quality control  system described in the manual include annual internal quality control  reviews of audit offices and reports, as well as external peer reviews of  audit operations by an independent federal OIG at least once every 3  years.
The OIG Audit Manual describes how OIG audit staff should document  their independence. For auditors at the director level and below, the  manual requires staff to document their independence biweekly in the  OIG’s Time and Tracking System. For senior executives, including the IG,  Deputy IG, Chief of Staff, AIGs, and others involved in reviewing audit  reports, the manual requires documentation of their independence once a  year when they complete ethics training and financial disclosure forms.  The manual further states that each office will maintain these annual  certifications of independence, but does not require the certifications to be  centrally maintained and monitored for compliance. Procedures for each  of the three audit offices regarding annual certificates varied. For  example, the Office of Audits said that it maintained annual independence  certificates for its division directors as well as senior executives, while the  Office of Emergency Management Oversight only maintained them for its  senior executives (the AIG and Deputy AIG). The Office of Information  Technology Audits said that instead of signing annual certifications, its  senior executives sign independence certifications for every audit they  work on, consistent with procedures for its audit staff. While the audit  offices told us they maintained independence certificates centrally within  each office, the OIG executive office, which consisted of four senior  executives at the time of our audit, indicated that it did not do so. In  response to our February 2014 request for copies of certificates for the  senior executives in the front office, an OIG official gathered certificates  from the individuals. Two of the certificates were signed after we  requested them, and according to the official, a certificate could not be  found for the Acting IG who had recently left the OIG. Similarly, both the  internal quality reviews and peer reviews conducted from 2009 through  2012 identified instances in which employees, including some senior  executives, had not documented their independence in accordance with  the OIG Audit Manual, although these instances were not deemed  significant enough to prevent the audit offices from passing these  reviews.
If senior officials do not comply with the OIG Audit Manual requirement to  sign annual certificates of independence or maintain them centrally in  order to monitor compliance, they might not be aware of potential threats  to independence or be as familiar with GAGAS or CIGIE independence  requirements as they should be. For example, as a result of an  impairment to the former Acting IG’s independence that was not identified  in a timely manner, several audits and inspections were affected in fiscal  year 2012. Specifically, a total of six reports from the Offices of Audits,  Information Technology Audits, and Inspections were reissued to include  a statement about an impairment of independence in appearance  resulting from a family member of the former Acting IG being employed  by an entity within DHS associated with these audits and inspections. In  addition, because of the same impairment, one other audit was  terminated without a report being issued. According to audit staff, they  inadvertently became aware of the former Acting IG’s impairment in July  2012 as a result of an audit official hearing about the employment of the  family member from a source outside of the OIG.
In addition, a number of other allegations of abuse of power and  misconduct were made against the former Acting IG, including failure to  uphold the independence and integrity of the DHS OIG office. These  issues, among others, were to be the subject of a Subcommittee on  Financial and Contracting Oversight, Senate Committee on Homeland  Security and Governmental Affairs, hearing scheduled for December  2013 that was canceled after the former Acting IG resigned on   December 16, 2013, and transferred to another office within DHS. In April  2014, the subcommittee issued a report on its investigation into the   This investigative  allegations of misconduct by the former Acting IG.report detailed the subcommittee’s findings of its investigation into the  allegations, including some actions that it said jeopardized OIG  independence. For example, the subcommittee found that the former  Acting IG had directed the alteration or delay of some reports at the  request of senior DHS officials and that he did not obtain independent  legal advice. Subsequent to the issuance of the subcommittee report, the  new DHS Secretary put the former Acting IG on administrative leave  pending other investigations.
While signing a certificate of independence might not have prevented  these independence issues, it could nevertheless serve as a reminder of  individual responsibilities and potential threats to independence. Further,  because certificates of independence are not maintained centrally,  management’s ability to monitor compliance with independence  requirements and obtain reasonable assurance that controls are in place  and operating as intended is hindered. However, as stated in Standards  for Internal Control in the Federal Government, no matter how well  designed and operated, internal control cannot provide absolute  assurance that all agency objectives will be met. Factors outside the  control or influence of management, such as human error or acts of  collusion to circumvent controls, can render policies and procedures  ineffective.
section_title: Inspection Policies and Procedures Were Consistent with Independence Standards
paragraphs: According to OIG officials, the DHS OIG’s Office of Inspections follows  guidance in CIGIE’s Quality Standards for Inspection and Evaluation. In  addition, DHS’s OIG Inspections Manual states that inspectors are  expected to be knowledgeable of, and to abide by, the performance  standards, including independence, described in CIGIE’s quality  standards. The OIG Inspections Manual includes guidance on  independence that is consistent with CIGIE standards although not as  detailed. For example, the manual states that while conducting an  inspection, all team members have a responsibility to maintain  independence so that opinions, conclusions, judgments, and  recommendations will be impartial and viewed as such by knowledgeable  third parties.
Neither CIGIE’s quality standards nor the OIG Inspections Manual  requires external peer reviews of OIG inspection activities. However,  CIGIE’s quality standards states that an OIG should have quality control  mechanisms that provide an independent assessment of inspection  processes and work. To help assess the inspection processes and work,  in 2006, the AIG for Inspections requested an independent external  review of three inspections. Each inspection was reviewed by a different  OIG, and the reviews focused on the quality of work performed for each  inspection. None of the reports from these external reviews identified any  independence concerns. More recently, in February 2014, the OIG  completed its first internal quality review of the Office of Inspections. The  resulting report indicated that the Office of Inspections materially  complied with CIGIE’s quality standards, and the report did not identify  any issues with respect to independence.
section_title: Investigation Policies and Procedures Were Consistent with Independence Standards
paragraphs: According to DHS OIG officials, OIG investigations are conducted in  accordance with CIGIE’s Quality Standards for Investigations. In addition,  the Office of Investigations has its own manual—the Special Agent  Handbook—which states that investigations will be conducted in  accordance with CIGIE’s standards as well as Attorney General  Guidelines for OIGs. CIGIE standards for investigations include  requirements on independence that are similar to those for audits. The  Special Agent Handbook includes guidance on ethical conduct and  conflicts of interest, specifically stating that if a special agent suspects  that a conflict of interest exists or that there might be an appearance of a  conflict of interest, the agent should notify the Special Agent in Charge as  soon as possible.
The DHS OIG Office of Investigations passed peer reviews by the Social  Security Administration OIG and the Department of Defense OIG in 2009  and 2013, respectively. Neither of these peer reviews included any issues  regarding independence or conflicts of interest. In addition, the Office of  Investigations conducted its own internal inspections in the past. None of  the internal inspection reports from fiscal years 2011 and 2012 identified  any issues with respect to independence. However, because of serious  concerns about the independence of the internal inspection function  carried out by the Office of Investigations as previously discussed, the  OIG decided to create IQO in 2013 and move this function to that office.  OIG officials told us that the Special Agent Handbook is being updated, in  part, as a result of the transfer of some functions, such as complaint  intake, to IQO.
section_title: Conclusions
paragraphs: The DHS OIG’s organizational structure has the positions required by the  IG Act to carry out its various responsibilities. However, the lack of an  appointed IG for 3 years may have contributed to a number of other  senior positions being filled with “acting” individuals for extended periods  of time. The OIG has made some meaningful changes to its structure to  try to address concerns about the integrity and independence of the OIG.  The establishment of IQO is intended to enhance the OIG’s ability to carry  out functions such as complaint intake and whistleblower protection,  including helping to ensure that these functions maintain their  independence. However, the DHS OIG process for recording and  referring complaints received directly from DHS employees does not  provide reasonable assurance that employees’ identities are protected, as  required by the IG Act. In addition, the important role that the OIG plays in  receiving and investigating allegations of criminal activity within the  department can be enhanced through better coordination and information  sharing with the FBI. OIG officials intend to continue working toward  improved coordination with the FBI and provided input to a DHS report  with their plans, as directed by the Senate. In light of the congressional  direction to DHS, we are not making a recommendation on this matter at  this time. Furthermore, although the IG has its own counsel as required  by the IG Act, the OIG did not have a policy to address the legal  requirements related to obtaining advice from legal counsel. While the  DHS OIG has appropriate policies and procedures in place to comply with  independence standards, even the best control procedures cannot always  guarantee that standards are being met. Although the former Acting IG  was required to sign an annual certificate of independence reminding him  of independence requirements, the OIG did not have a policy that these  certificates be collected and maintained centrally, which would improve  management’s ability to monitor compliance with independence  requirements.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the OIG take the following three actions:
To improve its intake and complaint processing function, we  recommend that the OIG design and implement additional controls,  which may include additional automated controls and supervisory  review, to provide reasonable assurance that employees’ identities  are not disclosed without their consent when forwarding complaints to  DHS components.
To help avoid any impairment to independence when seeking legal  advice, we recommend that the OIG develop a policy for obtaining  legal advice from counsel reporting either directly to the IG or another  IG and work with the IG’s counsel to establish guidelines for when it  would be appropriate for the OIG to consult with the department’s  counsel.
To help ensure that senior executives are aware of independence  requirements so that they are able to identify and mitigate any threats  to their independence, we recommend that the OIG revise its  guidance in the OIG Audit Manual to require signed annual certificates  of independence to be collected and maintained centrally in order to  monitor compliance.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the DHS Inspector General for review  and comment. In written comments, which are reprinted in appendix IV,  the OIG generally agreed with our conclusions and concurred with all of  our recommendations. In addition, the OIG provided technical comments  that we incorporated into the report as appropriate. We also provided the  FBI with an excerpt of the draft report related to its coordination with the  OIG on border corruption investigations. The FBI did not have any  comments.
The OIG described actions planned and under way to address each of  our recommendations. Specifically, the OIG stated that it is revising its  online allegation form to (1) ensure complainants do not inadvertently  provide personal data when their intent was to remain anonymous and   (2) simplify and clarify to complainants the distinctions between filing an  anonymous complaint versus filing a confidential complaint. The OIG  anticipates completing the changes to the online allegation form within 90  days of its letter. According to the OIG, it has also implemented  supervisory controls to provide oversight and quality control of intake  analysts’ work, including the movement or referral of complaints to DHS  components. The OIG also stated that it plans to develop policy and  guidelines within 90 days of its letter to describe the circumstances under  which the IG can obtain legal advice from DHS’s Office of Legal Counsel.  In addition, the OIG plans to revise its audit manual by October 31, 2014,  to require the Office of Integrity and Quality Oversight to collect and  maintain senior executives’ signed annual independence statements. If  implemented effectively, the OIG’s planned actions should address the  intent of our recommendations.
We are sending copies of this report to appropriate congressional  committees, the Secretary of Homeland Security, and the DHS Inspector  General. In addition, the report is available at no charge on the GAO  website at http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-9869 or khana@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff members who made key contributions to  this report are listed in appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The joint explanatory statement accompanying the Department of  Homeland Security (DHS) Appropriations Act, 2013, directed GAO to  review the Office of Inspector General’s (OIG) organizational structure  and whether its audit, investigation, and inspection functions are  organizationally structured to ensure that independence standards are  met. To meet the committee’s time frames established in the explanatory  statement, we briefed committee staffs on our preliminary observations in  November 2013. This report provides the results of our review to  determine (1) the coverage that the OIG’s audits and inspections  provided of DHS’s key component agencies, management challenges,  and high-risk areas; (2) the extent to which the OIG’s organizational  structure and roles and responsibilities were consistent with the Inspector  General Act of 1978, as amended (IG Act); and (3) the extent to which the  design of OIG’s policies and procedures for planning, reviewing, and  reporting on audit, inspection, and investigation results was consistent  with applicable independence standards.
To determine the coverage that DHS OIG’s audits and inspections  provided of DHS’s key component agencies, management challenges,  and high-risk areas, we reviewed the DHS agency financial reports for  fiscal years 2012 and 2013 to identify DHS’s key operational components.  To identify the department’s management challenges, we reviewed the  OIG’s annual performance plans for fiscal years 2012 and 2013. To  identify the high-risk areas for DHS, we reviewed GAO’s High-Risk Series  for 2013. To identify DHS OIG reports issued during fiscal years 2012 and  2013 and the subjects covered in those reports, we reviewed DHS OIG’s  semiannual reports. In conducting our analysis, we did not review the  coverage provided by investigations because they are generally  conducted based on specific allegations of misconduct received and are  not planned in advance as audits and inspections are. We compared the  agencies and subjects covered in these audit and inspection reports with  DHS’s key component agencies, management challenges, and high-risk  areas to determine DHS OIG’s oversight coverage of DHS. We also  interviewed knowledgeable DHS OIG officials to obtain their comments  about the results of our analysis.
To determine the extent to which the organizational structure, roles, and  responsibilities of the DHS OIG were consistent with the IG Act, we  reviewed DHS OIG’s organization chart, office descriptions, policies  related to its roles and responsibilities, memorandums of understanding,  and other relevant documents. We also interviewed former and current  DHS OIG officials, as well as officials from DHS components, including  officials from U.S. Customs and Border Protection, U.S. Immigration and  Customs Enforcement, and the Federal Emergency Management  Agency, and officials from the Federal Bureau of Investigation (FBI). We  analyzed the information from interviews and documentation to determine  whether there were any inconsistencies between the information and the  applicable IG Act requirements and the reasons for any such  inconsistencies. Our review focused primarily on OIG documentation and  discussions with OIG officials to assess the design of the OIG’s stated  roles and responsibilities. For the most part, we did not review the  implementation of these roles and responsibilities except for certain  issues that came to our attention—specifically, the lack of a memorandum  of understanding with the FBI, the procedures for protecting employee  confidentiality, and the nature of OIG consultations with the department’s  legal counsel.
To determine the extent to which the design of DHS OIG’s policies and  procedures for planning, reviewing, and reporting on audit, inspection,  and investigation results was consistent with applicable independence  standards, we interviewed DHS OIG officials and reviewed applicable  policy, procedure, and planning documents, such as the OIG Audit  Manual, OIG Inspections Manual, and Special Agent Handbook. We also  reviewed peer review reports of audit and investigative operations as well  as reports of internal inspections of investigative activities. We assessed  the design of the DHS OIG’s policies and procedures for planning,  reviewing, and reporting on audit, investigation, and inspection results  and determined whether the design was consistent with applicable  independence standards found in Government Auditing Standards and  the standards published by the Council of the Inspectors General on  Integrity and Efficiency that include Quality Standards for Federal Offices  of Inspector General, Quality Standards for Inspection and Evaluation,  and Quality Standards for Investigations. We also requested information  about which employees signed annual certifications of independence and  requested copies of these certifications for selected staff.
We conducted this performance audit from June 2013 to September 2014  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.
section_title: Appendix II: Inspector General Quality and Independence Standards
subsections: section_title: Quality Standards
paragraphs: Federal inspectors general (IG) have various quality standards to which  their offices must adhere in performing their work. The Quality Standards  for Federal Offices of Inspector General (referred to as the Silver Book),  adopted by Council of the Inspectors General on Integrity and Efficiency  (CIGIE), provides the overall quality framework for managing, operating,  and conducting the work of offices of inspector general (OIG) and covers  critical topics such as independence, ethics, and confidentiality. These  quality standards also address planning and coordinating work,  maintaining quality assurance, and ensuring internal control. In addition  to the Silver Book, federal OIGs have standards for specific types of work.  For audits, the Inspector General Act of 1978, as amended requires IGs  to carry out work in accordance with generally accepted government  auditing standards published in Government Auditing Standards. For  investigations and inspections, CIGIE has developed additional  standards: Quality Standards for Investigations and Quality Standards  for Inspection and Evaluation.
section_title: Independence Standards
paragraphs: Government Auditing Standards and CIGIE standards contain provisions  covering independence. Government Auditing Standards establishes a  conceptual framework that can be used to identify, evaluate, and apply  safeguards (such as removing an individual from an audit team or  consulting an independent third party) to eliminate the threats to  independence or reduce them to an acceptable level. Under Government  Auditing Standards, IGs should evaluate the following broad categories of  threats to independence:  1.  Self-interest: The threat that a financial or other interest will  inappropriately influence an auditor’s judgment or behavior.  2.  Self-review: The threat that an OIG employee or OIG that has  provided nonaudit services will not appropriately evaluate the results  of previous judgments made or services performed as part of the  nonaudit services when forming a judgment significant to an audit.  3.  Bias: The threat that an OIG employee will, as a result of political,  ideological, social, or other convictions, take a position that is not  objective.  4.  Familiarity: The threat that aspects of a relationship with management  or personnel of an audited entity, such as a close or long relationship  or that of an immediate or close family member, will lead an OIG  employee to take a position that is not objective.  5.  Undue influence: The threat that external influences or pressures will  affect an OIG employee’s ability to make independent and objective  judgments.  6.  Management participation: The threat that results from an auditor’s  taking on the role of management or otherwise performing  management functions on behalf of the entity undergoing an audit.  7.  Structural: The threat that an OIG’s placement within a government  entity, in combination with the structure of the government entity being  audited, will affect the OIG’s ability to perform work and report results  objectively.
CIGIE’s Quality Standards for Federal Offices of Inspector General  closely mirrors the independence language in Government Auditing  Standards. For example, it states that IGs and their staffs must be free  both in fact and in appearance from personal, external, and organizational  impairments to their independence. Further, the IGs and their staffs have  a responsibility to maintain independence so that opinions, conclusions,  judgments, and recommendations will be impartial and viewed as  impartial by knowledgeable third parties. CIGIE also addresses the same  seven categories of threats to independence as Government Auditing  Standards. CIGIE’s standards specifically for investigations and  inspections also include language about the importance of independence;  however, they contain far less detail about independence than the overall  standards.
section_title: Appendix III: DHS OIG’s Policies and Procedures to Address Selected IG Act Requirements
paragraphs: The Inspector General (IG) Act of 1978, as amended requires the  independent IGs at major departments and agencies, including  Department of Homeland Security (DHS), to carry out specific roles and  responsibilities. Table 6 summarizes selected requirements and the DHS  Office of Inspector General’s (OIG) procedures for carrying out these  requirements.
section_title: Appendix IV: Comments from the Department of Homeland Security Office of Inspector General
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Michael LaForge (Assistant  Director), Fred Evans, Latasha Freeman, Maxine Hattery, Colleen  Heywood, Jackson Hufnagle, Kristi Karls, and Laura Pacheco made  significant contributions to this work. Kathryn Bernet, Jacquelyn Hamilton,  and Helina Wong also contributed to this report.