Inspectors General: Improvements to IG Oversight Needed for Architect of the Capitol Operations
Released: 2016-11-04T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: The AOC OIG was established by statute in 2007, in part because of congressional concerns about time delays and cost overruns during construction of the Capitol Visitor Center. GAO was asked to assess the AOC OIG's oversight of AOC. This report describes AOC areas subject to OIG oversight and examines the extent to which the OIG developed plans and policies for AOC oversight for fiscal years 2012 through 2015 and the extent to which oversight was provided. GAO reviewed AOC's annual performance and accountability reports, the OIG's statutory requirements, the OIG's policies and procedures, and applicable CIGIE standards. GAO also interviewed AOC OIG officials, analyzed the OIG's plans and reports for the 4-year period, and compared these efforts with the AOC areas subject to oversight.

section_title: What GAO Found
paragraphs: During fiscal years 2012 through 2015—the 4-year period GAO reviewed—the Architect of the Capitol (AOC) Office of Inspector General (OIG) had responsibilities for independent audits and investigations of AOC's

10 jurisdictions with specific program responsibilities for the maintenance, operations, and preservation of the buildings and grounds across Capitol Hill;

Capitol Construction and Operations with central support offices; and

construction and restoration projects, including its four largest ongoing “mega projects,” with an estimated combined cost of over $1 billion.

The AOC OIG's audit planning during this period did not include either risk assessments or assigned priorities for conducting audits consistent with standards of the Council of the Inspectors General on Integrity and Efficiency (CIGIE). In addition, the OIG did not adopt these CIGIE standards in its policies and procedures. Instead, the current IG emphasized “continuous review” of mega projects, which he defined as an effort to alert AOC and the Congress of contract management issues as they occurred. This approach and the prior IG's efforts did not result in any audit reports of AOC's mega projects during fiscal years 2012 through 2015. The OIG also reported a decline in total audit reports and monetary accomplishments of potential dollar savings during fiscal years 2014 and 2015 (see table). Further, the OIG provided only one audit report of an AOC jurisdiction program during the 4-year period. Because of incomplete plans, a limited number of audit reports, and the lack of audit reports of AOC's mega projects, AOC and the Congress did not have the full benefit of OIG findings and recommendations and were not kept fully and currently informed of possible AOC problems and deficiencies during the 4-year period.

In fiscal year 2014, the IG rescinded the OIG's law enforcement authority and removed the OIG investigators' responsibility to complete criminal investigations. Instead, the OIG's investigators have responsibility for administrative investigations and rely primarily on the U.S. Capitol Police (USCP) to perform criminal investigations, and on occasion other AOC program offices perform their own investigations. USCP and AOC program offices are not subject to CIGIE standards. The OIG is required to follow CIGIE standards for investigations. These OIG changes contributed in part to a decline in investigative reports and monetary accomplishments. The OIG has volunteered to receive a peer review of its investigations that could be expanded to include consideration of investigations by these other entities.

section_title: What GAO Recommends
paragraphs: GAO is making two recommendations to the AOC OIG to (1) revise and implement policies and procedures to provide audit reports based on planning that includes risk assessment and assignment of priorities consistent with CIGIE standards and (2) obtain a peer review from another federal OIG of overall investigative operations, including consideration of the OIG's reliance on investigations performed by other entities, and to make any needed changes based on the results of such review. In comments on a draft of this report, the AOC OIG agreed with the two recommendations but raised concerns with some of GAO's findings. GAO continues to believe that its findings are valid, as discussed in the report.

section_title: Letter
paragraphs: The Architect of the Capitol (AOC) is responsible for the maintenance,  operation, and preservation of the buildings and grounds that make up  the U.S. Capitol complex, including the Capitol Building, the House and  Senate Office Buildings, the Library of Congress, the Supreme Court, and  U.S. Botanic Garden, among other facilities. Overall, AOC programs are  managed by 10 jurisdictions supported by its Capitol Construction and  Operations, which is made up of nine central offices. All of the  jurisdictions and offices report to the Architect. Contracting also plays a  central role in helping AOC achieve its mission. The AOC Office of  Inspector General (OIG) was established by the AOC Inspector General  Act of 2007 (AOC IG Act) as an independent and objective office to  conduct and supervise audits and investigations relating to AOC; to  provide leadership and coordination and to recommend policies to  promote economy, efficiency, and effectiveness; and to keep AOC and  the Congress fully and currently informed about problems and  deficiencies relating to the administration of programs and operations of  AOC. The AOC OIG was established in part because of congressional  concerns about time delays and cost overruns during the construction of  the Capitol Visitor Center, which was opened to the public in 2008.

You requested that we review the role of the OIG given the history  surrounding its creation and assess whether the OIG is performing at the  level the Congress directed and anticipated in its oversight of AOC. This  report addresses (1) the AOC jurisdictions, offices, and major contracts  subject to AOC OIG oversight during fiscal years 2012 through 2015;   (2) the statutory requirements, policies, and budgetary and staffing  resources of the AOC OIG during fiscal years 2012 through 2015; and   (3) the extent to which the AOC OIG developed plans and policies for  oversight of AOC’s jurisdictions, offices, and major contracts during fiscal  years 2012 through 2015, and the extent to which oversight was  provided.

To identify the jurisdictions, offices, and major contracts subject to OIG  oversight, we obtained information from AOC’s performance and  accountability reports for fiscal years 2012 through 2015. To determine  the statutory requirements of the AOC OIG, we reviewed the AOC IG Act  that established the office and relevant congressional reports. We  identified the OIG’s written policies and procedures during the 4-year  period through interviews with the Inspector General (IG) and his staff  and reviewed them to obtain an understanding of the intended oversight.  We obtained AOC OIG budget information for fiscal years 2012 through  2015 from the OIG that had been verified by AOC budget officials for data  reliability. We obtained AOC OIG staffing information for fiscal years 2012  through 2015 from the OIG, and AOC budget staff verified data reliability.  We determined that the data were reliable for the purposes of this report.

To examine the extent to which the AOC OIG developed plans and  policies for oversight of AOC’s jurisdictions, offices, and major contracts,  we reviewed the OIG’s strategic and annual audit plans for the 4-year  period and compared them with the jurisdictions, offices, and major  contracts subject to OIG oversight. We also compared the OIG’s audit  plans with requirements for OIG planning contained in the Council of the  Inspectors General on Integrity and Efficiency’s (CIGIE) Quality  Standards for Federal Offices of Inspector General. We examined the  extent of the AOC OIG’s oversight coverage for fiscal years 2012 through  2015 by reviewing the OIG’s semiannual reports, individual audit and  investigative reports, and other oversight efforts that addressed AOC’s  jurisdictions, offices, and major contracts. We also reviewed the OIG’s  monetary accomplishments reported in semiannual reports for fiscal  years 2012 through 2015 to determine any trends in the results of the  OIG’s oversight. In addition, we interviewed the IG and OIG staff to obtain  an understanding of the oversight provided. We determined the reliability  of the OIG’s semiannual report information and other OIG information by  comparing it with the source reports issued by the OIG. The data were  appropriate and reliable for meeting the report’s objectives. Additional  details on our scope and methodology are discussed in appendix I.

We conducted this performance audit from December 2014 to November  2016 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.
subsections: section_title: Background
paragraphs: The Capitol Visitor Center (CVC) was the largest construction project on  the Capitol Grounds in over 140 years. It was built to provide greater  security for all persons working in or visiting the U.S. Capitol and an  enhanced educational experience for visitors to learn about the Congress  and the Capitol Building. The construction contract for structural and  excavation work was awarded in June 2002. Subsequently, we reported  on delays in the construction of the CVC and uncertainties in the  estimated cost of the project until it opened in December 2008, at a total  cost of $600 million, well above the original project budget of   $265 million.

The House report accompanying the fiscal year 2008 Legislative Branch  Appropriations bill noted the long-standing and continuing lapses in AOC  management practices, including the delays and escalating costs of the  CVC; cost overruns and time delays on other projects; and with regard to  the Capitol Power Plant utility tunnels, complete management breakdown,  failure of appropriate oversight responsibilities, and total disregard for the  human element. That Legislative Branch Appropriations bill included language that would have created an OIG for AOC to provide an  independent office within AOC, and the AOC IG Act establishing the OIG  was enacted on December 26, 2007, as part of the Consolidated  Appropriations Act for fiscal year 2008. The Senate report that  accompanied this legislation called for a statutory inspector general for  AOC to promote integrity and efficiency in AOC programs and to detect  and prevent fraud, waste, and abuse. The related House report directed  that the new IG ensure that AOC is utilizing appropriate management  practices and budgetary and accounting standards within the limitations  of all laws applicable to AOC operations and auditing and reporting  semiannually on management, operational issues, and other issues as  outlined in an annual audit plan.

The first statutory AOC IG was the former Assistant IG for Audit at the  Corporation for National and Community Service and was appointed by  the Architect in August 2008. After the first IG’s retirement in August  2013, the Architect appointed AOC’s Deputy General Counsel to become  the current IG in September 2013. In addition to the IG, at the end of  fiscal year 2015, the AOC OIG consisted of a Deputy IG (who also serves  as the OIG’s legal counsel), Assistant IG for Audit, Assistant IG for  Investigations, two auditors, two investigators, a management analyst,  and an administrative officer. (See fig. 1.)

section_title: AOC Jurisdictions, Offices, and Major Contracts Subject to OIG Oversight
paragraphs: AOC is responsible for the maintenance, renovation, and construction of  the Capitol Hill buildings and grounds covering 17.4 million square feet of  facilities and more than 587 acres, and the AOC OIG is responsible for  the audit and investigative oversight of AOC. AOC carries out its mission  through 10 jurisdictions with specific program responsibilities and Capitol  Construction and Operations, which is made up of nine central offices,  including the independent OIG. (See fig. 2.)

AOC’s 10 jurisdictions manage AOC’s programs for the maintenance,  operations, and preservation of the grounds and structures across Capitol  Hill. (See app. II.) AOC’s Capitol Construction and Operations offices  have responsibilities that range from overall planning and project  management to financial and human capital in support of AOC’s mission  and programs. (See app. III.)

AOC’s responsibilities include the construction and restoration of key  facilities. AOC classifies its largest projects for construction and  restoration—those with an expected cost of over $50 million—as mega  projects. Mega projects are designed by external architecture and  engineering firms and constructed by external construction firms under  major contracts managed by AOC. AOC’s performance and accountability  reports highlight mega projects, including the Capitol Dome restoration  and the Cannon House Office Building renewal. According to AOC  officials, at the end of fiscal year 2015 AOC had four ongoing mega  projects estimated to cost in total approximately $1.1 billion. (See app.  IV.) According to AOC officials, the Cannon House Office Building  renewal project is estimated to cost approximately $752.7 million, and the  Capitol Dome restoration project is estimated to cost approximately   $96.7 million. In addition, AOC estimated that the Refrigeration Plant  Revitalization and the Capitol Power Plant Cogeneration projects will cost  approximately $183.2 million and $116.6 million, respectively.

section_title: Statutory Requirements, Policies, and Resources Related to the AOC OIG’s Work
subsections: section_title: Significant Statutory Requirements of the OIG
paragraphs: As established by statute in 2007, the stated purposes of the AOC OIG  are to (1) conduct and supervise audits and investigations relating to  AOC; (2) provide leadership and coordination and recommend policies to  promote economy, efficiency, and effectiveness; and (3) provide a means  of keeping the Architect and the Congress fully and currently informed  about problems and deficiencies related to the administration of programs  and operations of AOC. The AOC IG is appointed by the Architect, in  consultation with the Inspectors General of the Library of Congress, the  Government Publishing Office, the U.S. Capitol Police, and GAO, and is  to be selected without regard to political affiliation and solely based on  integrity and demonstrated ability in accounting, auditing, financial  analysis, law, management analysis, public administration, or  investigations. The IG reports to and is under the general supervision of  the Architect, who has no authority to prevent or prohibit the IG from  initiating or completing any audit or investigation, issuing any subpoena  during the course of an audit or investigation, issuing any report, or  carrying out any other statutory duty or responsibility of the IG. In addition, the IG may be removed from office by the Architect, who must  promptly communicate in writing the reasons for such removal to each  house of the Congress. Subject to the laws governing selection,  appointment, and employment by AOC, generally, the IG is authorized to  select, appoint, and employ such officers and employees, including  consultants, necessary to carry out the functions, powers, and duties of  the OIG.

The AOC IG Act also incorporates numerous provisions of the Inspector  General Act of 1978 (IG Act), as amended, imposing responsibilities and  providing authorities common among federal OIGs. Among those  responsibilities, the IG must comply with Government Auditing Standards,  which requires, among other things, that in all matters relating to audit  work, the audit organization and the individual auditor must be free from  personal, external, and organizational impairments to independence and  must avoid the appearance of such impairments. The IG must also take  appropriate steps to ensure that any work performed by nonfederal  auditors complies with these standards. In addition, whenever the IG has  reasonable grounds to believe there has been a violation of federal  criminal law, it is to be reported expeditiously to the Attorney General.  The IG is also required to prepare semiannual reports to inform the  Architect and the Congress of any significant problems found and  recommendations for corrective action made by the OIG during the  reporting period. The IG’s semiannual reports are to contain updates on  significant recommendations from previous reports that have not been  completed; a summary of matters referred to prosecutors and any  prosecutions that occurred; and monetary accomplishments for the  reporting period, including the dollar value of questioned costs and the  dollar value of recommendations that funds be put to better use.

section_title: AOC OIG Policies and Procedures
paragraphs: AOC Order 40-1, Order on the Office of Inspector General Authority and  Responsibilities and Architect of the Capitol Employee Responsibilities,  effective October 12, 2010, sets out the authority and responsibilities of  the AOC OIG in carrying out independent audits and investigations and  promoting the economy, efficiency, and effectiveness of AOC. The requirements are mostly derived from the statutory requirements and  authorities of the AOC IG. These include the IG’s direct access to the  Architect, as well as access to all records, reports, audits, reviews,  documents, papers, or other material available to the AOC. The order  also specifies the IG’s authority to undertake such investigations and  reports that are, in the judgment of the IG, necessary or desirable;  request information and assistance from any federal, state, or local  governmental agency; and administer or take from any person an oath,  affirmation, or affidavit, when necessary in performing OIG functions. In  addition, CIGIE’s Quality Standards for Federal Offices of Inspector  General provides requirements for OIGs when developing an appropriate  planning process and for managing, operating, and conducting oversight,  including audits and investigations.
subsections: section_title: Audit Policies and Procedures
paragraphs: AOC Order 40-1 includes the requirement for OIG audits to comply with  Government Auditing Standards and the responsibility to follow an audit  process, starting with an audit plan at the beginning of each fiscal year.  According to the order, the plans are to include audits based on risk and  materiality (significance or importance), legislatively mandated audits,  requests from the Congress and AOC, or other work selected for audit or  evaluation. The audit process is to include written notification to AOC  followed by an entrance conference with pertinent AOC representatives  before the audit begins. After the audit work is complete, an exit  conference is to be held with the AOC point of contact and AOC  management to discuss the results of the audit. The audit team is to issue  a draft audit report to AOC management for comment and then issue a  final audit report to present the results of the audit with the comments of  AOC management. The AOC OIG has also developed written policies in  its Audit Policies Manual and its Audit Standard Operating Procedures  Manual. Together, these two manuals provide general auditing policies as  well as specific audit procedures for planning and conducting audits and  reporting the results of audits to AOC and the Congress. They also  provide guidelines for using nonfederal auditors to audit AOC’s annual  financial statements.

section_title: Investigative Policies and Procedures
paragraphs: AOC Order 40-1 includes the requirement for OIG investigations to be  conducted in accordance with CIGIE Quality Standards for  Investigations. The order states generally that the OIG is responsible for  conducting and supervising investigations to find, remedy, or prevent  fraud, waste, and abuse. It also lists examples of subjects that the OIG  investigates, including fraud, waste, or abuse; bribes, kickbacks, and bid  rigging; conflicts of interest; credit or purchase card fraud; forgery or  thefts; improper use of AOC resources or property; violations of laws,  rules, or regulations; and reprisal for reporting allegations of fraud, waste,  or abuse to the OIG. The order also specifies that individual  discrimination or retaliation complaints, individual employee benefits and  compensation issues, individual grievances, individual workplace conflicts  or matters covered in the collective bargaining agreement, or complaints  regarding workplace safety and health or environmental issues are to be  referred to AOC offices rather than to the OIG.

Policies and procedures for OIG investigations are contained in the  Investigative Program Manual, which outlines the investigative conduct  policy, coordination procedures, and other policies on the administration  of investigations. These OIG policies also require that investigators  adhere to all applicable CIGIE Quality Standards for Investigations. The  CIGIE investigative standards include requirements for the qualifications  of investigative personnel and the independence of investigative  organizations and investigators from personal, external, and  organizational impairments. In addition, the standards require the use of  due professional care in the thoroughness of investigations, the  application of legal requirements, and the use of appropriate investigative  techniques. Due professional care also requires investigators to be  impartial and objective and to provide accurate and complete  documentation to support investigative reports. The CIGIE investigative  standards also provide guidance on conducting investigations; using  investigative plans with organizational and case-specific priorities;  accurately, completely, and objectively reporting all relevant aspects of  investigations; and managing investigative information.

section_title: OIG Budgetary and Staffing Resources
paragraphs: Funding for the AOC OIG is included in the appropriation available for  AOC’s general administration. The OIG submits its budget requests for  review to the AOC budget office, which then includes it as part of AOC’s  overall budget request submitted to the Congress. The OIG’s budgets  grew from approximately $2.0 million in fiscal year 2012 to approximately  $2.7 million in fiscal year 2015, while the OIG’s staffing remained  relatively constant, as shown in table 1.

The OIG’s budget increase occurred primarily in fiscal year 2015 when  the OIG was provided additional funding for support services. According  to the OIG, the additional funds were intended to hire individuals with  engineering expertise to assist in the audit oversight of the Capitol Dome  restoration and Cannon House Office renewal projects, but instead the  OIG returned $343,501 of the funds to AOC when the engineering  expertise was not obtained. The OIG ultimately hired a civil engineer in  fiscal year 2016.

section_title: OIG’s Insufficient Audit Planning and Changes to Investigative Operations Limited OIG Oversight
paragraphs: The OIG’s strategic and annual audit plans for the 4-year period we  reviewed did not include an assessment of AOC’s risks and did not  establish priorities for providing audit reports. In addition, the current IG  eliminated all criminal investigator positions, leaving the OIG investigators  with no responsibility to complete investigations of allegations of criminal  wrongdoing, which the OIG now refers to the U.S. Capitol Police (USCP)  for investigation. Also, although the OIG is responsible for addressing  fraud, waste, and abuse under AOC policy, we found instances where  other AOC offices investigated such allegations of wrongdoing within their  own offices, despite the potential for conflicts of interest. The OIG’s lack  of adequate audit planning, lack of criminal investigators, and reliance on  AOC program offices to conduct investigations of alleged wrongdoing  have contributed to a significant decline in its audit and investigative  reports and reported monetary accomplishments. As a result, AOC  management and the Congress may not be fully and currently informed  about potential problems and deficiencies relating to the administration of  programs and operations of AOC.
subsections: section_title: Insufficient Planning Limited Audit Oversight
subsections: section_title: OIG Planning Was Not Consistent with Policies and Did Not Apply CIGIE Standards
paragraphs: The AOC IG Act states that the OIG’s primary purposes are to conduct  and supervise audits and investigations; promote economy, efficiency,  and effectiveness; and keep AOC and the Congress fully and currently  informed about problems and deficiencies through semiannual reports  and other means. In addition, the act requires that OIG audits comply with  Government Auditing Standards, which requires audit reports to  communicate the results of audits. CIGIE’s Quality Standards for Federal  Offices of Inspector General provides requirements for OIGs when  developing an appropriate planning process and for managing, operating,  and conducting oversight, including audits. The CIGIE standards direct  OIGs to develop a methodology and process for identifying and  prioritizing agency programs and operations as potential subjects for  audits. In addition, the standards state that because resources are rarely  sufficient to meet all requirements, audit planning should include an  assessment of risk and an assignment of priorities to help ensure the  optimum use of OIG resources. The CIGIE standards also provide  guidance for OIGs on maintaining a planning system that assesses the  nature, scope, and inherent risks of agency programs and operations.  According to these standards, the annual performance planning process  is to identify the activities to audit and investigate, inspect, or evaluate  and translate these priorities into outcome-related goals, objectives, and  performance measures.

The OIG’s Audit Standard Operating Procedures Manual requires a risk  analysis—using input received from AOC management and the  Congress, as well as audit leads developed during the past year—to  identify the most viable audits based on risk and potential payback. The  OIG’s annual audit plans for fiscal years 2012 through 2015 included the  annual financial statement audits performed by an outside accounting  firm; audits from prior years that were not completed, such as those of the  Capitol Dome restoration and Cannon House Office Building  reconstruction mega projects; and new planned audits, such as the audit  of the Capitol Power Plant Cogeneration. However, the OIG’s strategic  and annual audit plans for the 4-year period we reviewed did not include  an assessment of risk. In addition, neither the OIG’s plans nor its policies  included the assignment of priorities to help ensure the effective use of  OIG resources in providing audit reports. While the OIG’s policies  included CIGIE’s standards for investigations, the OIG has not adopted  CIGIE’s Quality Standards for Federal Offices of Inspector General or  developed comparable policies and procedures on planning that include  both risk assessment and assigned priorities. In interviews with the IG, he  explained that instead of formal plans with an assessment of risk and an  assignment of priorities, the OIG relied on a process of “continuous  review” defined by the IG as an effort to alert AOC and the Congress to  cost overruns, delays, and other contract management issues as they  occurred.

section_title: OIG Provided No Audit Reports of AOC’s Mega Projects and Most Jurisdictions and Offices during Fiscal Years 2012 through 2015
paragraphs: In large part because of the OIG’s insufficient audit planning, the OIG  provided no audit reports of AOC’s mega projects with an estimated  combined cost of over $1.1 billion, and the OIG provided limited audit  oversight of AOC’s jurisdictions and offices during the 4-year period we  reviewed. According to OIG officials, the OIG staff performed  continuous review by attending AOC’s weekly progress meetings for both  the Capitol Dome restoration and Cannon House Office Building renewal  mega projects. However, without audit reports developed from plans  based on an independent assessment of AOC’s risks and with assigned  priorities, the OIG provided little assurance that AOC’s most critical  programs and contracts received adequate oversight, that audit resources  were being applied to the most critical areas, and that the OIG’s efforts  would fully inform AOC management and the Congress of any problems  or deficiencies.

In addition, the lack of sufficient planning contributed to the minimal audit  coverage of the jurisdictions and offices responsible for providing AOC’s  programs and support services during fiscal years 2012 through 2015. To  illustrate, the fiscal year 2015 audit report of CVC’s restaurant operations  was the only OIG audit of a program provided by an AOC jurisdiction  during the 4-year period we reviewed. However, this audit report was not  a result of the OIG’s annual audit plan for fiscal year 2015, but rather was  provided in response to a request from CVC management. Additional  audit reports issued by the OIG focused on procurement, human capital,  and other support services provided by three of AOC’s central offices in  Capitol Construction and Operations during the 4-year period. (See table  2.)

section_title: Insufficient OIG Planning Contributed to a Decline in OIG Audits and Monetary Accomplishments
paragraphs: Because of the current IG’s emphasis on performing continuous reviews  rather than planned audit reports, the audit accomplishments reported by  the AOC OIG have declined significantly in recent years. To illustrate,  under the prior IG, the OIG completed a total of nine audit reports and two  evaluations in fiscal years 2012 and 2013, with reported monetary  accomplishments of approximately $324,000. In fiscal years 2014 and  2015, the OIG, under the current IG, completed five audit reports and  three other reviews, with reported monetary accomplishments of  approximately $54,000, or approximately 14 percent of the 4-year total.  (See table 3.)

section_title: IG Changes to Investigative Operations Resulted in Limited Oversight
paragraphs: As a result of changes by the current IG to eliminate criminal investigator  positions, the OIG no longer has staff with the explicit responsibility to  complete investigations of potential criminal wrongdoing and refers such  cases to USCP for investigation. Also, we found instances where the OIG  referred certain allegations of wrongdoing involving potential fraud, waste,  and abuse to the AOC program offices for investigation. Neither USCP  nor AOC program offices are subject to CIGIE’s Quality Standards for  Investigations when performing investigations or AOC IG Act  requirements for protecting complainants’ identities. These changes of  investigative operations by the IG have contributed in part to a significant  decline in the investigative reports and monetary accomplishments  reported by the OIG. In addition, these changes have increased the risk  that (1) criminal and other improper activities may not be detected and   (2) potential cases of fraud, waste, and abuse may not be fully and  independently investigated and may not be reported to AOC management  and the Congress.
subsections: section_title: IG’s Rescinding of Law Enforcement Authority Led to Removal of Criminal Investigators
paragraphs: The OIG’s policies and procedures provide that the OIG receives  allegations of fraud, waste, or abuse and determines whether to initiate  investigations, which are to be conducted in accordance with CIGIE’s  Quality Standards for Investigations. In addition, the AOC IG Act states  that in carrying out the duties and responsibilities established under the  act, the IG shall report expeditiously to the Attorney General whenever  the IG has reasonable grounds to believe there has been a violation of  federal criminal law. The act also provides that the Attorney General may  provide the AOC IG with the necessary authority for law enforcement.  The prior AOC IG obtained law enforcement authority for the OIG  investigators through special deputation as authorized by the Attorney  General, which allowed investigators to seek and exercise warrants,  make arrests, and carry firearms when performing their investigative  duties.

After the current IG rescinded the OIG investigators’ law enforcement  authority in January 2014, the IG stated, in the OIG’s semiannual report  for the first half of fiscal year 2014, that the carrying of firearms created  AOC employee anxiety and was unnecessary to fulfill statutory OIG  obligations. Nevertheless, the OIG investigators had passed their most  recent peer review, which included a review by another OIG on the proper  use of firearms. In addition, the IG was unable to provide any specific  incident where the OIG investigators had exercised the inappropriate use  of their law enforcement authorities. The IG informed us that in his prior  position as the AOC’s Deputy General Counsel, he had become aware of  AOC management’s concerns with the OIG investigators’ authority to  carry firearms, and for this reason, he rescinded the OIG’s law  enforcement authority.

The OIG completed a job hazard analysis under the prior IG that was  provided to the AOC Director of Safety, Fire, and Environmental  Programs in June 2011. The OIG analysis concluded that OIG criminal  investigators experienced safety hazards when conducting investigations  of AOC personnel, programs, contracts, or funds when off the Capitol  complex. The hazards included the surveillance of suspects, serving  subpoenas, collecting physical evidence, and working with other law  enforcement officials. The carrying of firearms was included among the  personal protective equipment necessary to respond to these hazards.

Having removed their authority to carry firearms, rather than place the  OIG investigators into potentially unsafe conditions without the protection  of firearms, the current IG removed the staff’s responsibility to complete  criminal investigations altogether by revising the position descriptions of  the investigators. The IG stated in the second fiscal year 2014  semiannual report that carrying out law enforcement duties is  unnecessary to the OIG’s missions to serve AOC and the Congress. As a  result, the OIG’s criminal investigators were reclassified from Office of  Personnel Management (OPM) Criminal Investigating Series 1811, with  responsibilities for criminal investigations, to OPM General Investigating  Series 1810, which has no specified responsibilities for criminal  investigations.

section_title: OIG Relied on Investigations by Entities That Were Not Subject to Professional OIG Standards
paragraphs: Because it has no criminal investigators to complete investigations of  potential criminal allegations, the OIG refers such allegations to USCP for  investigation. According to USCP officials, USCP is the only law  enforcement agency with primary law enforcement authority for the U.S.  Capitol buildings and grounds. In addition, USCP statutory authority  extends to the protection of congressional members, officers, visitors, and  facilities, which includes performing criminal investigations relating to  AOC and other Capitol Hill entities. USCP officials confirmed that USCP  does not have access to AOC’s internal systems and therefore cannot  develop leads for proactive criminal investigations of fraud in AOC’s  program management and contracting areas without being granted such  access. Instead, USCP investigations are focused on criminal allegations  referred to it by the OIG. USCP officials stated that USCP personnel have  extensive training in performing criminal investigations. OIGs are required  to follow CIGIE’s Quality Standards for Investigations when they conduct  investigations, which contain, among other things, explicit requirements  for investigator independence, objectivity, and due professional care. As  mentioned previously, AOC OIG has incorporated these investigative  standards into its policies and procedures. Although USCP is not subject  to CIGIE’s investigative standards, USCP officials stated that the  requirements in CIGIE’s investigative standards are required for all of its  criminal investigations and are integral to USCP directives, processes,  policies, and procedures.

In addition to the IG’s elimination of the OIG investigators’ responsibility to  complete criminal investigations, the AOC OIG also changed its  investigative operations with respect to noncriminal investigations.  According to OIG investigators, shortly after the current IG took office,  they were told in a meeting with the IG that senior AOC leadership would  need to build its own investigative capabilities because the OIG would no  longer handle many issues it previously investigated. Also, in the  semiannual report for the period ending fiscal year 2014, the IG  emphasized that the OIG would defer to AOC supporting offices in the  absence of reasonable cause to believe complaints of alleged fraud,  waste, and abuse of government resources. Consequently, the OIG may  refer allegations of noncriminal wrongdoing to AOC’s program offices for  investigation and rely on the investigative capabilities developed by  AOC’s program offices. The review of allegations by other AOC offices is  often appropriate when administrative actions can address the issues  without OIG assistance. For example, AOC’s policies specify that  individual complaints of discrimination or retaliation, individual employee  benefits and compensation issues, individual grievances, individual  workplace conflicts, matters covered in the collective bargaining  agreement, or complaints regarding workplace safety and health or  environmental issues are addressed by AOC offices in association with  the Office of Compliance. The AOC IG Act allows the IG to exercise  judgment when determining whether to conduct an OIG investigation.  However, according to OIG investigators, the IG has also encouraged  AOC program offices to conduct their own investigations, which can result  in these offices addressing wrongdoing in areas outlined in the OIG’s  policies and procedures as OIG responsibilities regarding fraud, waste,  and abuse. The program offices are not subject to explicit policies  requiring independence, objectivity, and due professional care, which are  requirements under CIGIE’s investigative standards for OIGs.

To illustrate, the OIG under the prior IG conducted investigations of  alleged abuses of worker’s compensation benefits by employees who  filed potentially fraudulent claims. The OIG investigations conducted  under the prior IG found that these employees were not always potentially  eligible for worker’s compensation benefits. However, the AOC Human  Capital Management Division is responsible for investigations of worker’s  compensation issues. The Human Capital Management Division awarded  a 1-year contract for $150,000 in August 2015 to a private investigative  firm to perform the surveillance work once done by OIG investigators and  to determine whether AOC employees have filed false claims in order to  collect worker’s compensation or disability benefits. Since these  investigations are not being performed by the OIG, they are not subject to  CIGIE standards requiring independence, objectivity, or due professional  care, which are among the requirements for investigations performed by  the OIG. Human Capital Management Division officials stated that any  suspected criminal violations would be referred to the OIG; however,  under the IG’s current investigative operations, even if such criminal  referrals were made they would not be investigated by the OIG but rather  referred to USCP.

In another example, the OIG referred allegations of potential ethics  violations to the AOC Office of General Counsel for investigation, even  though such cases are consistent with the OIG’s responsibilities to  investigate fraud, waste, and abuse. By referring these allegations to the  Office of General Counsel for investigation, the resulting investigations  are subject to neither CIGIE investigative standards for independence,  objectivity, and due professional care nor the AOC IG Act, which requires  the OIG to safeguard the identity of complainants. The lack of a statutory  protection may hinder complainants from coming forward with information  about potential wrongdoing within AOC. To illustrate, we reviewed an  investigative case file provided by OIG investigators indicating that the  OIG had received an allegation about a potential violation of AOC orders  that prohibit using public office for private gain by the complainant’s  supervisor. Such violations of abuse are specified by OIG policies and  procedures as matters the OIG investigates. However, the IG determined  this allegation was an ethical matter to be investigated by the AOC Office  of General Counsel. Upon learning that the AOC Office of General  Counsel rather than the OIG would be performing the investigation,  according to the case file, the complainant withdrew the allegation  because of fear of possible repercussions for moving forward with the  case.

section_title: Investigative Changes Contributed to a Decline of Reports and Accomplishments
paragraphs: Although the OIG continues to perform investigations, the IG’s changes in  investigative operations have contributed in part to a significant decline in  the number of investigative reports and monetary accomplishments  reported by the OIG. To illustrate, under the prior IG, the OIG issued 53  investigative reports in fiscal years 2012 and 2013, compared to 23  reports in fiscal years 2014 and 2015 under the current IG, an almost 60  percent reduction. Also, as illustrated in table 4, since fiscal year 2013 the  reported monetary accomplishments from investigations have declined  from approximately $444,930 to approximately $7,260 in fiscal year 2015,  as the current IG’s changes to investigative operations gradually became  effective.

In fiscal year 2015, the OIG reported monetary accomplishments that  accounted for less than 1 percent of the 4-year total reported by both IGs.  In addition, the OIG had previously provided management advisories,  which reported internal control weaknesses identified by investigations;  however, it did not issue any management advisory reports in fiscal year  2015.

The AOC OIG has voluntarily agreed to be a part of the CIGIE peer  review process, which includes a review of its investigative operations by  another OIG. The primary purpose of CIGIE peer reviews is to determine  whether OIGs have consistently applied CIGIE’s Quality Standards for  Investigations. However, the OIG’s reliance on investigations by other  entities will not necessarily be included in CIGIE’s peer review process.  For example, the investigative operations of USCP when addressing  criminal allegations and the investigations performed by AOC’s program  offices, such as the Human Capital Management Division, would not be  included in a peer review of the AOC OIG’s investigations. We discussed  the objectives and scope of CIGIE’s investigative peer reviews with the  outside OIG scheduled to perform the AOC OIG’s next review. We  concluded that the issues raised in our report could be included within the  scope of a peer review if expanded to include consideration of the OIG’s  reliance on investigations provided by USCP, AOC’s Human Capital  Management Division, the Office of General Counsel, and any additional  AOC program offices that perform investigations of potential fraud, waste,  and abuse.

section_title: Conclusions
paragraphs: The Congress passed legislation establishing the AOC OIG, in part, to  address the cost overruns and time delays of AOC projects, such as  those found during the construction of the CVC, and the failure of  appropriate oversight responsibilities. In addition, the stated purposes of  the AOC OIG as established by the AOC IG Act include OIG audits and  investigations and for the OIG to keep the Architect and the Congress  fully and currently informed through semiannual reports and otherwise  concerning fraud and other serious problems, abuses, and deficiencies.  The Congress also intended the AOC OIG to promote economy and  efficiency in AOC programs and to detect and prevent fraud, waste, and  abuse.

During fiscal years 2012 through 2015, the AOC OIG issued no audit  reports of AOC’s mega projects, which have an estimated combined cost  of over $1 billion. In addition, the current IG’s emphasis on the continuous  review of specific mega projects since fiscal year 2014 contributed to this  outcome. During the same 4-year period, the OIG provided only one audit  report that addressed a single program among all the programs provided  by AOC’s 10 jurisdictions, and reported a declining number of other audit  reports accompanied by a corresponding decline in the reported amount  of monetary accomplishments. As a result of the OIG’s minimal audit  report coverage, the Architect and the Congress may not be fully and  currently informed about the operations of AOC’s jurisdictions, offices,  and major contracts. The OIG’s efforts during the 4-year period, including  its continuous review of mega projects, did not have audit plans that were  based on an assessment of risk or assignment of priorities. This is in part  because the OIG has not adopted CIGIE’s Quality Standards for Federal  Offices of Inspector General that includes these requirements for planning  audits, investigations, and evaluations based on an assessment of  agency risk and priority of efforts. Without policies and procedures for  complete OIG plans with an assessment of AOC’s risks and established  priorities to help direct its resources, the OIG can provide little assurance  that it will provide future audit reports that address AOC’s most critical  areas.

In addition, the current IG rescinded the OIG’s law enforcement authority  and removed its investigators’ responsibility to complete investigations of  potential criminal allegations, resulting in these allegations being referred  to USCP for investigation. Furthermore, under the IG’s changes, AOC  program offices can perform their own investigations of alleged  wrongdoing in areas that can include the OIG’s responsibilities under its  current policies regarding fraud, waste, and abuse. USCP and AOC  program offices are not subject to CIGIE’s Quality Standards for  Investigations. The OIG is subject to CIGIE’s standards that require  investigations to be objective, independent, and consistent with due  professional care, and to AOC IG Act requirements that complainants’  identities be protected. The current IG’s changes have contributed, at  least in part, to fewer investigative reports and monetary  accomplishments and may hinder potential complainants from coming  forward with allegations of wrongdoing. As a result, the OIG’s practices  raise questions about whether the OIG is carrying out its work in a way  that fulfills the Congress’s original intent regarding the oversight of AOC.

section_title: Recommendations for Executive Action
paragraphs: We are making two recommendations to the AOC OIG regarding its   (1) audit planning and (2) investigative operations.

To provide increased oversight of AOC and to keep the Architect and  the Congress fully and currently informed, we recommend that the  AOC OIG revise and implement policies and procedures to provide  audit reports that are based on planning that includes an assessment  of risk and the assignment of priorities, consistent with requirements  in CIGIE’s Quality Standards for Federal Offices of Inspector General.

To reduce the risk that fraud, waste, and abuse and criminal activities  are not detected or fully addressed, we recommend that (1) the AOC  OIG work with CIGIE to obtain a peer review from another federal OIG  of the AOC OIG’s overall investigative operations, including  consideration of the OIG’s reliance on investigations performed by  other entities, and (2) make any needed changes in its operating  procedures based on the results of the review to help ensure that  investigations of AOC are conducted in accordance with CIGIE  standards for investigations and AOC IG Act requirements.

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the AOC OIG for review and  comment. In written comments reprinted in appendix V, the AOC OIG  agreed with the two recommendations and stated that it would implement  them. The AOC OIG also provided information on changes made in late  2015 and 2016, which was after our review period. Although these  changes were outside the scope of our work, our report acknowledges  the hiring of a civil engineer in fiscal year 2016 and the issuance of two  reports on AOC mega projects, also in fiscal year 2016. The OIG  acknowledged our findings on audit planning and the number of audit  reports on AOC’s major construction projects and jurisdictions and stated  that the OIG has now moved away from an approach that appeared to  simply monitor projects and will incorporate a more formal risk  assessment and prioritization process into its audit planning. We also  received technical comments from the AOC OIG, which were addressed  as appropriate. However, the OIG disagreed with a number of the  statements and findings in the report related to its investigative  operations, as discussed below. The USCP General Counsel also  provided technical comments on behalf of USCP, which were addressed  as appropriate.

In its written response, the AOC OIG stated that a CIGIE investigative  program review had been scheduled to be completed in fiscal year 2016,  and that without advance notice to the AOC OIG, the GAO review team  requested that the designated CIGIE OIG peer review team suspend its  activities pending the completion of this GAO audit. As we state in our  report, our purpose in contacting the OIG peer reviewer was to determine  the extent to which the AOC OIG’s investigative operations would be  included in a peer review. The peer review had not yet begun when we  met with the OIG peer reviewer, who provided information on CIGIE’s  peer review process. We did not request that the peer review be  suspended or postponed. We also discussed the ability of the peer review  to include the OIG’s overall investigative operations, including  consideration of the OIG’s reliance on investigations performed by other  entities.

In its written comments, the AOC OIG also stated that the GAO draft  confuses program responsibilities with investigative responsibilities and  that the OIG does not rely on agency program offices to perform OIG  investigations. The OIG commented that AOC program offices do not  investigate any allegations of fraud, waste, or abuse for the OIG and that  the AOC OIG is the only office responsible for performing such  investigations pursuant to the IG Act. The OIG added that it is the only  AOC office that can guarantee confidentiality to employees and other  witnesses. The OIG concluded that GAO’s factual findings in this area are  mistaken and not supported. Our report discusses AOC’s policies  applicable to the OIG that specify the issues that program offices can and  should address, and the issues of fraud, waste, and abuse that are  specifically OIG responsibilities. Our report provides examples of AOC  program offices that have addressed wrongdoing in areas of OIG  responsibilities regarding fraud, waste, or abuse. These examples are  based on our review of documentation in the OIG’s case files.  Specifically, as noted in our report, we reviewed an investigative case file  provided by OIG investigators indicating that the OIG had received an  allegation about a supervisor’s potential violation of AOC orders that  prohibit using public office for private gain. Such violations of abuse are  specified by OIG policies and procedures as matters the OIG  investigates. However, the OIG determined that this allegation would be  investigated by the AOC Office of General Counsel. In another example,  we obtained documentation from the Human Capital Management  Division of its contract for $150,000 in August 2015 for a private  investigative firm to perform the surveillance work once done by OIG  investigators, to determine whether AOC employees have filed false  claims in order to collect worker’s compensation or disability benefits.  Based on these examples, AOC program offices may have investigated  matters of fraud, waste, and abuse, which are specifically OIG  responsibilities. The OIG agreed with our recommendation to work with  CIGIE to obtain a peer review of the AOC OIG’s investigative operations,  including consideration of the OIG’s reliance on investigations performed  by other entities.

The AOC OIG stated that our draft report rejects the OIG’s reliance on the  law enforcement authority of USCP and that this is contrary to law. Our  report does not assess and therefore provides no opinion on the law  enforcement authority of USCP and how these investigations were  handled or resolved. Contrary to the OIG’s assertion, our report  specifically addresses the OIG’s investigative process, including the  referral of matters for investigation, relative to CIGIE’s quality standards.  In addition, our report does not address whether the policies and  procedures of USCP align with CIGIE standards on how referrals are to  be handled. Also, as stated in our report, the AOC OIG had law  enforcement authority, which includes the authority to carry firearms,  already in place when the current IG entered office in September 2013,  which he rescinded based on reasons outlined in our report. In addition,  the Attorney General had previously determined under the criteria laid out  in Section 6 of the IG Act that law enforcement authority was appropriate  for the AOC OIG. We did not assess this determination.

The AOC OIG also provided several comments about the qualifications of  USCP, citing its accreditation by the Commission on Accreditation for Law  Enforcement Agencies, Inc. The OIG includes the attributes for  accreditation, which included among others, professionalism,  independence, and objectivity. As stated in our report, our focus was on  OIG investigations and specifically how OIG investigations follow quality  standards provided by CIGIE, which were established, in part, to help  ensure the independence of OIG investigative efforts. Based on technical  comments provided by the USCP General Counsel on behalf of USCP  officials, we added certain information regarding requirements of USCP’s  criminal investigations. However, we did not audit USCP or the policies  and procedures that apply to its investigations. AOC OIG has  responsibility for ensuring that its investigations comply with applicable  standards. It is for these reasons that we have recommended that the  AOC OIG work with CIGIE to obtain a peer review from another federal  OIG of the AOC OIG’s overall investigative operations, including  consideration of the OIG’s reliance on investigations performed by other  entities, and make any needed changes in its operating procedures  based on the results of the review to help ensure that investigations of  AOC are conducted in accordance with CIGIE standards for  investigations and AOC IG Act requirements. The AOC OIG agreed to  implement this recommendation.

We are sending copies of this report to the Architect, the Architect of the  Capitol Inspector General, and interested congressional committees. In  addition, the report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2623 or davisbh@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 who made key contributions to this report  are listed in appendix VI.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our audit objectives were to (1) identify the Architect of the Capitol’s  (AOC) jurisdictions, offices, and major contracts subject to AOC Office of  Inspector General (OIG) oversight during fiscal years 2012 through 2015;  (2) determine the statutory requirements, policies, and budgetary and  staffing resources of the AOC OIG during fiscal years 2012 through 2015;  and (3) examine the extent to which the AOC OIG developed plans and  policies for oversight of AOC’s jurisdictions, offices, and major contracts  during fiscal years 2012 through fiscal year 2015, and the extent to which  oversight was provided.

To identify the AOC jurisdictions, offices, and major contracts subject to  AOC OIG oversight during fiscal years 2012 through 2015, we obtained  the AOC’s performance and accountability reports for each fiscal year.  From these reports, we determined AOC’s priorities and the focus of  AOC’s efforts for matters that could be considered for OIG oversight. We  also obtained descriptions of AOC’s organizational units, including the  administrative offices that provide operational support and the 10  jurisdictions that provide the AOC’s programs for the maintenance,  renovation, and construction of the Capitol Hill buildings and grounds. We  identified the largest construction and renovation contracts as reported by  AOC that are classified as mega projects, with over $50 million each in  estimated cost.

To determine the statutory requirements of the AOC OIG, we reviewed  the AOC Inspector General Act of 2007 (AOC IG Act) and obtained the  associated legislative history of that law, including committee reports and  accompanying statements regarding the proposed bills leading to  enactment. We summarized the views of the congressional committees  as stated in reports and bills that led to the creation of the OIG to obtain  an understanding of where the OIG could focus its efforts and resources.  We also analyzed the statutory requirements from the Inspector General  Act of 1978, as amended, that apply to the AOC OIG to determine the full  range of requirements applicable to the office. We obtained the OIG’s  written policies and procedures that applied to the 4-year period we  reviewed. We summarized the guidance provided by the OIG’s policies  and procedures to help determine whether they included requirements for  audits and investigations and addressed the requirements of the AOC IG  Act.

We obtained AOC OIG budget information for fiscal years 2012 through  2015 from the OIG that had been verified by AOC budget officials for data  reliability. We obtained AOC OIG staffing information for fiscal years 2012  through 2015 from the OIG; AOC budget staff verified data reliability. We  determined that the data were reliable for the purposes of this report.

To examine the OIG’s oversight plans and policies, we obtained the  strategic plans and annual audit plans for the 4-year period we reviewed  from the OIG and discussed the focus and definition of continuous review  efforts with the Inspector General (IG). We also obtained the OIG policies  and procedures specific to OIG planning and compared these  requirements with the OIG’s plans. We also reviewed the OIG’s plans for  consistency with CIGIE’s Quality Standards for Federal Offices of  Inspector General regarding planning. In addition, we obtained and  summarized the requirements in the OIG’s policies and procedures for  audits and investigations. We obtained all OIG reports issued during the  4-year period we reviewed, which included audits, investigations,  evaluations, management advisories, and memorandums, and identified  the AOC programs addressed by the reports. We compared the subjects  addressed by OIG’s audit reports with AOC’s jurisdictions, offices, and  major contracts and noted any lack of audit coverage during the 4-year  period. We also obtained the monetary accomplishments from OIG audits  reported in the OIG’s semiannual reports to determine any trends and  changes over the period. We also summarized the content and results of  all investigative reports for the 4-year period to determine any changes in  the reported results and any trends and changes in reported monetary  accomplishments.

We interviewed all OIG investigative staff and the IG to obtain an  understanding of changes made to the OIG’s investigative operations. We  also interviewed an officer in the U.S. Capitol Police (USCP)  Investigations Division identified by the AOC OIG to obtain an  understanding of USCP’s mission and investigative procedures related to  allegations of criminal violations referred to it by the AOC OIG. In  addition, we obtained the assistance of AOC OIG investigators who  provided examples of OIG investigations for our review. We determined  the reliability of information in the OIG’s semiannual reports and other  reported information by comparing it with the source information in  individual reports issued by the OIG. The data we obtained were  appropriate and reliable for meeting the report’s objectives.

We conducted this performance audit from December 2014 to November  2016 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: Architect of the Capitol Jurisdictions Subject to Office of Inspector General Oversight
paragraphs: The Architect of the Capitol (AOC) Office of Inspector General (OIG) was  established, in part, to conduct and supervise audits and investigations  relating to AOC. This includes AOC’s jurisdictions, which are responsible  for AOC’s programs and are subject to OIG oversight (see table 5).

section_title: Appendix III: Architect of the Capitol Offices Subject to Office of Inspector General Oversight
paragraphs: The Architect of the Capitol (AOC) Office of Inspector General (OIG) was  established, in part, to conduct and supervise audits and investigations  relating to AOC. This includes AOC’s Capitol Construction and  Operations offices, which provide program support and are subject to OIG  oversight (see table 6).

section_title: Appendix IV: Architect of the Capitol Mega Projects Subject to Office of Inspector General Oversight
paragraphs: The Architect of the Capitol (AOC) Office of Inspector General (OIG) was  established, in part, to conduct and supervise audits and investigations  relating to AOC. This includes AOC’s mega projects, which are each  estimated to cost over $50 million and are subject to OIG oversight (see  table 7).

section_title: Appendix V: Comments from the Architect of the Capitol Office of Inspector General

section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Jackson Hufnagle (Assistant  Director), Lisa Boren, Jason Kirwan, Lisa Motley, Taya Tasse, and  Kenneth Thiry made key contributions to this report.


Question-summary annotations: questions: question: How was the AOC OIG's audit planning limited?
answer: The AOC OIG's audit planning during this period did not include either risk assessments or assigned priorities for conducting audits consistent with standards of the Council of the Inspectors General on Integrity and Efficiency (CIGIE).
child_questions: question: To what extent did the OIG use these CIGIE standards?
answer: In addition, the OIG did not adopt these CIGIE standards in its policies and procedures.
child_questions: question: What approach was taken in the place of the CIGIE standards?
answer: Instead, the current IG emphasized “continuous review” of mega projects, which he defined as an effort to alert AOC and the Congress of contract management issues as they occurred.
child_questions: question: What results have come from this auditing system?
answer: This approach and the prior IG's efforts did not result in any audit reports of AOC's mega projects during fiscal years 2012 through 2015. The OIG also reported a decline in total audit reports and monetary accomplishments of potential dollar savings during fiscal years 2014 and 2015 (see table). Further, the OIG provided only one audit report of an AOC jurisdiction program during the 4-year period.
child_questions: question: How did shortcomings in the audit process affect the results?
answer: Because of incomplete plans, a limited number of audit reports, and the lack of audit reports of AOC's mega projects, AOC and the Congress did not have the full benefit of OIG findings and recommendations and were not kept fully and currently informed of possible AOC problems and deficiencies during the 4-year period.

questions: question: What changes did the IG make concerning OIG in FY2014?
answer: In fiscal year 2014, the IG rescinded the OIG's law enforcement authority and removed the OIG investigators' responsibility to complete criminal investigations.
child_questions: question: How has this affected OIG's responsibilities?
answer: Instead, the OIG's investigators have responsibility for administrative investigations and rely primarily on the U.S. Capitol Police (USCP) to perform criminal investigations, and on occasion other AOC program offices perform their own investigations.
child_questions: question: What standards do USCP and AOC offices adhere to?
answer: USCP and AOC program offices are not subject to CIGIE standards. The OIG is required to follow CIGIE standards for investigations.
child_questions: question: How have these changes affected OIG investigative reports?
answer: These OIG changes contributed in part to a decline in investigative reports and monetary accomplishments.
child_questions: question: How has the OIG responded to these changes?
answer: The OIG has volunteered to receive a peer review of its investigations that could be expanded to include consideration of investigations by these other entities.

questions: question: Why was the AOC OIG established?
answer: The AOC OIG was established by statute in 2007, in part because of congressional concerns about time delays and cost overruns during construction of the Capitol Visitor Center.
child_questions: question: What was GAO'S role in this process?
answer: GAO was asked to assess the AOC OIG's oversight of AOC.

question: What does this report discuss?
answer: This report describes AOC areas subject to OIG oversight and examines the extent to which the OIG developed plans and policies for AOC oversight for fiscal years 2012 through 2015 and the extent to which oversight was provided.
child_questions: question: How did GAO collect data for this report?
answer: GAO reviewed AOC's annual performance and accountability reports, the OIG's statutory requirements, the OIG's policies and procedures, and applicable CIGIE standards. GAO also interviewed AOC OIG officials, analyzed the OIG's plans and reports for the 4-year period, and compared these efforts with the AOC areas subject to oversight.

questions: question: What recommendations did GAO make?
answer: GAO is making two recommendations to the AOC OIG to (1) revise and implement policies and procedures to provide audit reports based on planning that includes risk assessment and assignment of priorities consistent with CIGIE standards and (2) obtain a peer review from another federal OIG of overall investigative operations, including consideration of the OIG's reliance on investigations performed by other entities, and to make any needed changes based on the results of such review.
child_questions: question: How did the AOC OIG respond to GAO's recommendations?
answer: In comments on a draft of this report, the AOC OIG agreed with the two recommendations but raised concerns with some of GAO's findings.
child_questions: question: How has this affected GAO's findings?
answer: GAO continues to believe that its findings are valid, as discussed in the report.