Office of the Inspector General: Review of Seven Offices by Michael Erbschloe - HTML preview

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U.S. Department of Agriculture OIG

The Office of Inspector General of the U.S, Department o Agriculture (USDA) was legislatively established in 1978 with the enactment of the Inspector General Act (Public Law 95-452). The act requires the Inspector General to independently and objectively:

  • Perform audits and investigations of the Department's programs and operations;
  • Work with the Department's management team in activities that promote economy, efficiency, and effectiveness or that prevent and detect fraud and abuse in programs and operations, both within USDA and in non-Federal entities that receive USDA assistance;
  • Report OIG activities to the Secretary and the U.S. Congress semiannually as of March 31 and September 30 each year;

 

This is accomplished by:

  • investigating allegations of fraud and abuse;
  • auditing the economy and efficiency of USDA programs and operations, including program results, the security of information technology, compliance with applicable laws and regulations, and the accuracy of financial reports;
  • applying predictive analytics, statistical modeling, computer matching, and data mining and warehousing to USDA programs and operations.

 

USDA OIG is headquartered in Washington, D.C., and has regional offices located in Atlanta, Georgia; Beltsville, Maryland; Kansas City, Missouri; Chicago, Illinois; New York, New York; Oakland, California; and Temple, Texas.

 

USDA OIG emphasizes service to management at all levels of the Department by briefing senior Department officials on major audits and investigations. They also work proactively with agency managers, as part of a united team, by directly encouraging management input into the audit and investigative process to help solve difficult problems impacting program management and operations. As a member of the Council of the Inspectors General on Integrity and Efficiency (CIGIE), they also participate with other Inspectors General in multi-agency projects where the issues are crosscutting and need to be addressed Government-wide. The strategic goals of the USDA OIG are:

  • Strengthen USDA’s ability to implement and improve safety and security measures to protect the public health, as well as agricultural and Departmental resources.
  • Reduce program vulnerabilities and strengthen program integrity in the delivery of program assistance.
  • Provide USDA with oversight to help it achieve results oriented performance.

 

USDA, much like other agencies and departments throughout the Government, faces challenges in overseeing its many programs. USDA employs nearly 100,000 employees in 17 agencies and 18 staff offices; in total, these employees operate approximately 300 programs responsible for delivering about $143 billion in public services annually. Overseeing these programs so every dollar spent accomplishes the intended results poses significant challenges to USDA program managers.

 

USDA has made some progress improving accountability for its programs when the Office of Inspector General (OIG) or other third parties, such as GAO, have identified deficiencies. For example, after OIG received a complaint concerning recent changes in how the Natural Resources Conservation Service (NRCS) makes determinations regarding whether a wetland exists on a given tract of land, OIG reviewed determinations made in the “prairie pothole region” (Iowa, Minnesota, North Dakota, and South Dakota). It was found that, to address a backlog of requests for wetland determinations, NRCS made significant changes in its process for wetland determinations that allowed producers to drain and farm more wetlands. However, the agency did not execute the process for making this change in a transparent manner. NRCS generally agreed with the finding and recommendations to issue official guidance reinforcing correct and current rules and clarifying procedures for making wetland determinations and certifications, including the status of pre-1996 determinations.

 

Similarly, USDA’s Office of Homeland Security and Emergency Coordination (OHSEC) has taken steps to improve oversight and management controls over handling of classified material. In 2013, OIG made 17 recommendations about the Department’s internal management controls over classified material. In a subsequent audit, it was found that OHSEC management did not supply adequate oversight to monitor audit follow-up activities performed by its staff, as OIG found that 11 recommendations were not addressed at the time of our fieldwork. Weaknesses existed in four other recommendations. Such weaknesses introduced a higher potential for misclassification, over-classification, and unauthorized release of national security information within USDA. OHSEC has stated that it completed implementation of previous recommendations and revised guidance and processes to improve management oversight, as was recommend in the most recent report.

 

OIG audits consistently show that USDA agencies need to strengthen oversight and accountability over their programs. For example, OIG recently reviewed OHSEC’s actions related to agroterrorism preparedness. Agroterrorism is a threat to national security and could result in increased human illnesses and deaths, widespread destruction of crops and livestock, and significant economic loss to the Nation’s farmers and ranchers. OIG found that OHSEC had not adequately overseen and coordinated USDA’s efforts to prevent, detect, and respond to agroterrorism. Also, OHSEC did not demonstrate that USDA was in compliance with Homeland Security Presidential Directive 9 requirements to defend the agriculture and food system against terrorist attacks, major disasters, and other emergencies.

 

The OIG has found that despite actions to improve information technology (IT) security, USDA continues to display weaknesses in planning, management, and oversight of its cybersecurity initiatives that affect the Department’s compliance with standards for safeguarding IT systems as directed in the Federal Information Security Modernization Act of 2014 (FISMA). The degree to which USDA complies with FISMA and other security guidance directly correlates to the security posture of each agency and office. USDA senior management needs to make sure agencies and offices understand how implementation of IT security directly impacts USDA’s overall security posture. For USDA to attain a security posture that is secure and sustainable, all 35 of its agencies and offices must consistently implement Departmental policy based on a standard methodology. When every agency and office is in compliance with USDA’s policies, USDA as a whole will be compliant with FISMA and, more importantly, have a sustainable security posture.

 

Due to prior outstanding recommendations and weaknesses related to IT and FISMA, OIG will continue to report a material weakness in USDA’s IT security that should be included in the Department’s annual Federal Managers Financial Integrity Act report. OIG concluded that the Department lacks an effective information security program.14 OCIO has not implemented corrective actions that the Department committed to in response to prior OIG recommendations. In a report released in 2016, OIG found that from FYs 2009 through 2015 they had made 61 recommendations for improving the overall security of USDA’s systems. OCIO implemented corrective action for 39 of those recommendations, but testing identified that security weaknesses still exist in 3 of those closed recommendations. OCIO should revisit these three areas. Also, a number of recommendations have exceeded the specified corrective action implementation dates. If the planned corrective actions to close out these recommendations are no longer achievable due to budget cuts or other reasons, then OCIO needs to update those corrective action plans and request a change in management decision in accordance with Departmental guidance.

 

In that report, OIG also found that policies and programs designed to address FISMA requirements have not been completed or fully implemented, and USDA has not fully developed an organizational perspective that includes a comprehensive governance structure and organization-wide risk management strategy. Governance is a set of processes that ensures the effective and efficient use of IT in enabling an organization to achieve its goals. A nonexistent governance structure will continue to leave USDA’s IT security program in a reactive state, continuously struggling to adapt to changing conditions. In order to resolve these far-reaching IT security problems, senior USDA management needs to develop a governance structure that will encourage compliance at both the agency and Departmental level. This should improve the Department’s overall security posture and FISMA score.

 

Designing, developing, and implementing programs that reliably achieve their intended results has been a recurring challenge for the Department. OIG has found that agencies do not have adequate reviews or controls in place to supply the metrics necessary to evaluate program performance. In some programs, the strategy for measuring performance is missing altogether. As a result, some agencies are using inaccurate or unreliable data in program performance reports.

 

Currently, USDA manages approximately 300 programs that provide a variety of services and financial assistance to the American public. This diverse portfolio of programs means that, for the Department to serve as a diligent steward of Federal funds, USDA must have well-designed programs with clear goals and performance measures.

 

The Government Performance and Results Modernization Act of 2010 set requirements for regular and recurring program performance assessment. In keeping with the law, an agency should have controls in place that allow it to regularly review a program’s performance, and then compile reports that allow it to measure that performance. These reports allow the Department to evaluate fairly its programs’ successes and failures.

 

Due to ongoing efforts to establish and develop outcome-based performance measures, the Department has made progress in measuring the actual success of its programs. In FY 2015, OIG found that USDA’s programs for supporting beginning farmers, funded by different agencies, could benefit from a thorough revision of how they report program results. Since FY 2015, USDA has developed an integrated, coordinated strategy to ensure that these programs help new farmers establish and sustain new farming operations. As part of this strategy, the Department provides direction to agencies for defining consistent and measurable outcomes, clearly articulates desired outcomes, develops milestone dates for goals, and creates a timeline to ensure agencies accomplished all mandated duties from the 2008 Farm Bill. This direction has helped agencies improve their coordination and more consistently define eligibility requirements for their programs for beginning farmers and ranchers.

 

USDA has emphasized its efforts to improve outreach to new and beginning farmers and ranchers, local and regional food producers, minorities, women, and veterans. As part of those efforts, the Department has stressed the importance of civil rights, highlighting that significant progress needs to be made in working with communities when addressing past civil rights issues. Due to a history of public attention concerning how USDA has treated members of socially disadvantaged groups, the Department faces challenges in earning those groups’ trust.

 

In recent years, OIG has completed audits intended to help resolve long-standing complaints against USDA. The Food, Conservation, and Energy Act of 2008 directed that all pending claims and class actions (for example, Pigford v. Glickman, Garcia v. Vilsack, and Love v. Vilsack) brought against USDA by socially disadvantaged farmers or ranchers, including Hispanics and women, based on racial, ethnic, or gender discrimination in farm program participation, be resolved in an expeditious and just manner. OIG reviews of the claims administration process for these class actions generally found that the process for resolving these complaints was strong, and appropriate payments were being made to eligible farmers.

 

OIG also performed audits designed to help the Department improve outreach to socially disadvantaged groups. For example, OIG evaluated the effectiveness of the Department’s activities related to providing assistance to beginning farmers and ranchers. USDA agencies have provided significant financial resources and technical support to beginning farmers to assist in the establishment and sustainability of farming operations. It was found, however, that the Department had not developed an integrated and coordinated strategy to ensure effective implementation. The Department also lacked sufficient performance goals, direction, coordination, and monitoring to ensure success. Since USDA spent $3.9 billion in beginning farmers’ assistance in FYs 2012 and 2013, it is critical that the Department ensure that these funds are benefiting those intended.

 

There are several recommendations outstanding related to a review we performed of FSA’s Microloan Program. The Microloan Program is intended to create new economic opportunities through farming. The Microloan Program offers flexible access to credit and serves as an attractive loan alternative for smaller farm operations, including nontraditional farm operations, which often face limited financing options. However, it was found that FSA could not demonstrate that it successfully reached out to some targeted audiences, such as specific underserved groups and veterans. The low percentage of participation by some targeted groups suggests FSA needs to increase its outreach to those underserved groups.

 

OIG concluded that the Food Safety and Inspection Service (FSIS) has taken action to improve food safety and the humane handling of animals at the plants FSIS inspects. However, it was found that FSIS continues to face challenges gathering reliable data to ensure safety verification tasks are completed, effective, and consistent. FSIS also continues to face challenges in training, documenting and tracking, overseeing, testing, and verifying that the Nation’s commercial supply of meat, poultry, and egg products complies with regulatory requirements.

 

Although FNS has endeavored to improve management controls for the Supplemental Nutrition Assistance Program (SNAP), weaknesses continue to exist in controls over administrative tasks, benefit distribution, and quality control (QC) processes. The potential exists for billions of dollars of taxpayer-funded assistance not to be delivered or used as intended.

 

As the largest benefit program within USDA and one of the largest in the Federal Government, SNAP presents a unique challenge for the program’s managers. In FY 2016, SNAP provided monthly food assistance for nearly 44 million low-income individuals and disbursed almost $67 billion in benefits. Given SNAP’s size and significance, fraud, waste, and abuse are critical concerns. OIG’s audit work focuses on improving the efficiency of program administration and maintaining the integrity of Federal funds. Further, USDA loses hundreds of millions of dollars every year to fraud and crime associated with SNAP and other FNS food assistance programs. OIG devotes significant investigative resources to recover that money and prosecute criminals. In the first half of FY 2017, OIG’s investigative efforts related to SNAP resulted in 171 indictments, 187 convictions, and 511 arrests, with a total dollar impact of $54.9 million.

 

In FY 2016, FNS made a number of improvements to SNAP management controls. In FY 2016, OIG found that FNS’ oversight of State agency controls over able-bodied adults without dependents (ABAWD) could be improved. FNS improved administrative oversight of ABAWD provisions by updating the Management Evaluation Management System (MEMS) to MEMS Next Generation in 2016. MEMS allowed FNS to track reports to States, including management evaluations and financial management reviews, and provided a central repository of schedules for all reviews and reports. However, it did not always contain complete information on ABAWD management evaluations due to confusion regarding data entry procedures. Prior to implementing MEMS Next Generation, FNS provided necessary training and training manuals to ensure employees used the system correctly. These improvements demonstrate FNS’ commitment to ensuring the effective and efficient delivery of services to eligible SNAP recipients.