General skills for inspectors

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    TABLE OF C ONTENTS

    PREFACE i

    STANDARDS

    A. Competency 1B. Independence 3C. Professional Judgment 9D. Quality Control 11E. Planning 12F. Data Collection and Analysis 15G. Evidence 17H. Records Maintenance 19I. Timeliness 20J. Fraud, Other Illegal Acts, and Abuse 21K. Reporting 23L. Follow-up 25

    M. Performance Measurement 26N. Working Relationships and Communication 26

    APPENDICES

    1. Guide for Core Competencies for InspectionOrganizations and Inspectors 29

    2. Guide for General Skill Levels for Inspectors 32

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    P REFACE

    W ithin the Inspector General community, inspections havelong afforded organizations a flexible mechanism foroptimizing resources by utilizing a multidisciplinary staff,expanding Department/Agency coverage, and using alternative reviewmethods and techniques. An inspection is defined as a process thatevaluates, reviews, studies, and/or analyzes the programs and activitiesof a Department/Agency for the purposes of providing information tomanagers for decisionmaking; making recommendations forimprovements to programs, policies, or procedures; and identifying

    where administrative action may be necessary. Inspections may beused to provide factual and analytical information; monitor compliance;measure performance; assess the efficiency and effectiveness of programs and operations; share best practices; and inquire intoallegations of fraud, waste, abuse, and mismanagement. The inspectionfunction at each Department/Agency is tailored to the unique missionof the respective Department/Agency. For example, at the Departmentof State, inspections primarily focus on the adequacy of managementof programs and activities in each of the U.S. embassies and consulatesoverseas, as well as in each bureau or major operating unit of theDepartment; whereas at the Department of Veterans Affairs,inspections primarily focus on evaluating the quality of patient careprovided to our Nations veterans. As another example, at theDepartment of Health and Human Services, the majority of inspectionsfocus on preventing fraud, waste, and abuse in the Medicare andMedicaid programs.

    Thus, to be responsive to the needs of the Inspector Generalcommunity, it is important that the standards established for conductinginspections not be overly prescriptive. Otherwise, the very flexibilitythat makes an inspection such a valuable tool is lost. With that in

    mind, these standards have been developed as a framework forperforming inspection work. These standards are broad enough to

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    take into consideration the wide variety of inspections that existthroughout the Inspector General community, as well as therequirements of the various offices that perform inspections, whileremaining precise enough to provide assurances that all inspectionprocesses and products are subject to basic general and qualitativestandards. It is the responsibility of each Office of Inspector Generalto develop internal written procedures to guide the actual conduct of inspection work. These procedures should include the appropriatecontrols necessary to ensure compliance with the Quality Standardsfor Inspections, as well as the Inspector General Act of 1978, asamended, and any other legislation or regulations applicable to anorganizations operations.

    The Presidents Council on Integrity and Efficiency and the ExecutiveCouncil on Integrity and Efficiency endorse the need for QualityStandards for Inspections and encourage the consistent applicationof these standards throughout the Inspector General community. Thestandards are reviewed periodically to ensure their continuing relevancyand sufficiency.

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    Q UALITY STANDARDS FOR INSPECTORS

    Inspection organizations should strive to conduct their operations inthe most efficient and effective manner possible, which serves toenhance the credibility of the organizations. The following standardsare established by the Presidents Council on Integrity and Efficiency(PCIE) and the Executive Council on Integrity and Efficiency (ECIE)to guide the conduct of all inspection work performed by Offices of Inspector General (OIGs). As used throughout these standards, theterm inspection includes evaluations, inquiries, and similar types of reviews that do not constitute an audit or a criminal investigation. The

    term inspector is used generically to refer to the individual conductingsuch work.

    A. C OMPETENCY

    The standard for inspection work is:

    The inspection organization needs to ensure that the personnelconducting an inspection collectively have the knowledge,skills, abilities, and experience necessary for the assignment,which should include the following:

    1. Knowledge of evaluation methodologies; familiaritywith the concepts, processes, and assumptions of the

    program or activity being inspected; the capacity toconduct a broad interdisciplinary inquiry; knowledgeof qualitative and quantitative analysis; writing and oral

    The staff assigned to performinspection work should collectively

    possess adequate professionalcompetency for the tasks required.

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    briefing skills; information technology relatedcapabilities; and knowledge of Inspector Generalstatutory requirements and directives.

    2. The ability to develop a working familiarity with theorganizations, programs, activities, and/or functionsidentified for inspection. When reviewing technicalor scientific topics, it may be appropriate to use theservices of a subject matter expert. Expertise maybe determined by the individual having a relateddegree, license, certification, experience, etc.

    3. Managerial skills for supervisors, team leaders, andlead inspectors.

    The Inspector General community has developed a guideregarding core competencies for inspection organizations andinspectors, as well as a guide for general skill levels forinspectors, which are included as appendices to this document.Inspection organizations should have a process for recruitment,hiring, continuous development, and evaluation of staff to assistthe organization in maintaining a workforce that has adequatecompetency. The nature, extent, and formality of the processwill depend on various factors, such as the size of the inspectionorganization, its work, and its structure. These factors willalso affect the staffing needs of an organization. For example,an inspection organization may need to employ personnel orhire specialists who are knowledgeable, skilled, or experiencedin such areas as accounting, statistics, law, engineering,information technology, public administration, economics, orsocial sciences.

    OIGs should strive to provide inspectors with 80 hours of

    training biennially, but should minimally provide 40 hours of training biennially. Appropriate training may include evaluation/

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    inspection training, such as program analysis, writing, technicaltraining; and career development training, such as in managerialskills.

    OIGs should have internal policies and procedures for issuanceand utilization of credentials.

    B. INDEPENDENCE

    The standard for inspection work is:

    Inspectors and inspection organizations have a responsibilityto maintain independence so that opinions, conclusions,

    judgments, and recommendations will be impartial and will beviewed as impartial by knowledgeable third parties. Theindependence standard should be applied to anyone in theorganization who may directly influence the outcome of aninspection and includes both Government and private personsperforming inspection work for an OIG .

    Inspection organizations and inspectors should be alert topossible impairments to independence and should avoidsituations that could lead reasonable third parties withknowledge of the relevant facts and circumstances to conclude

    that the inspection organization or inspectors are not

    In all matters relating to inspectionwork, the inspection organization and

    each individual inspector should be free both in fact and appearance from personal, external, and organizational

    impairments to independence.

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    independent and, thus, are not capable of exercising objectiveand impartial judgment in conducting and reporting on aninspection. Impairments to independence, either in fact orappearance, need to be resolved in a timely manner. Theactions of OIG staff should adhere to the Standards forEthical Conduct for Employees of the Executive Branch andFederal conflict of interest laws. Inspection organizationsshould have internal policies and procedures for reporting andresolving real or perceived impairments to independence.

    Inspection organizations that provide other professionalservices should consider whether providing these services

    creates an independence impairment either in fact orappearance that adversely affects their independence forconducting inspections. Inspection organizations should not(1) provide noninspection services that involve performingmanagement functions or making management decisions and(2) inspect their own work or provide noninspection servicesin situations where the noninspection services are significant/ material to the subject matter of inspections. Inspectionorganizations that provide other professional services shouldrefer to the Government Auditing Standards issued by theUnited States Government Accountability Office, which,although specific to auditing, provides detailed guidancerelevant to handling the provision of such services.

    Inspection organizations and inspectors need to consider threegeneral types of impairments to independencepersonal,external, and organizational. If one or more of theseimpairments affect an inspection organizations or aninspectors capability to perform work and report resultsimpartially, that organization or inspector should either declineto perform the work or, if the situation necessitates that the

    work cannot be declined, the impairment(s) should be reportedin the scope section of the inspection report.

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    1. Personal Impairments

    Personal impairments of staff members result fromrelationships and beliefs that might cause inspectorsto limit the extent of an inquiry, limit disclosure, orweaken or slant inspection findings in any way.Inspectors are responsible for notifying the appropriateofficials within their respective inspection organizationsif they have any personal impairment to independence.It is impossible to identify every situation that couldresult in a personal impairment, but the following areexamples of personal impairments:

    (a) Having an immediate or close family memberwho is a director or officer of the entity beinginspected or is in a position with the entity toexert direct and significant influence over theentity or the program being inspected.Immediate or close family members includespouses, spouse equivalents, dependents(whether or not related), parents, siblings, andnondependent children.

    (b) Having direct or significant/material indirectfinancial interest in the entity or program beinginspected.

    (c) Having responsibility for managing an entityor decisionmaking that could affect operationsof the entity or program being inspected; forexample, as a director, officer, or other seniormember of the entity, activity, or programbeing inspected or as a member of

    management in any decisionmaking,supervisory, or ongoing monitoring function

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    for the entity, activity, or program underinspection.

    (d) Having involvement with the preparation,maintenance, or authorization of officialrecords/documents associated with the entity,activity, or program under inspection.

    (e) Having preconceived ideas towardindividuals, groups, organizations, orobjectives of a particular program that couldbias the inspection.

    (f) Having biases, including those induced bypolitical, ideological, or social convictions, thatresult from employment in or loyalty to aparticular type of policy, group, organization,or level of government.

    (g) Seeking employment with an inspectedorganization during the conduct of theinspection.

    2. External Impairments

    Factors external to the OIG may restrict work orinterfere with an inspectors ability to formindependent and objective opinions and conclusions.External impairments to independence occur wheninspectors are deterred from acting objectively andexercising professional skepticism by pressures, actualor perceived, from management or employees of theinspected entity or oversight organizations. For

    example, if any of the following conditions exist, theOIG would not have complete freedom to make an

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    independent and objective judgment, which couldadversely affect the work:

    (a) External interference or influence that couldimproperly or imprudently limit or modify thescope of an inspection or threaten to do so,including pressure to reduce inappropriately theextent of work performed in order to reducecosts or fees.

    (b) External interference with the selection orapplication of inspection procedures or in the

    selection of transactions to be examined.

    (c) Unreasonable restrictions on the time allowedto complete an inspection or issue a report.

    (d) External interference in the assignment,appointment, or promotion of inspectionpersonnel.

    (e) Restrictions on funds or other resources providedto the inspection organization that adverselyaffect the inspection organizations ability tocarry out its responsibilities.

    (f) Authority to inappropriately overrule orinfluence an inspectors judgment as to theappropriate content of the report.

    (g) Threat of replacement over a disagreement withthe contents of an inspection report, aninspectors conclusions, or the application of

    criteria.

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    (h) Influences that jeopardize an inspectors continuedemployment for reasons other than incompetence,misconduct, or the need for inspection services.

    When external factors restrict an inspection or interferewith an inspectors ability to form objective opinionsand conclusions and the inspector cannot remove thelimitation, the inspector should report the limitation inaccordance with the respective OIGs internal policiesand procedures.

    3. Organizational Impairments

    Inspection organizations need to be free fromorganizational impairments to independence. Anorganizations ability to perform work and report theresults impartially can be affected by its place within aDepartment/Agency and the structure of theDepartment/ Agency. Inspection organizations withinOIGs established by the Inspector General Act of 1978, as amended, derive organizationalindependence from the statutory safeguards toindependence established by the Act.

    However, if an inspector believes there is anorganizational impairment that could affect his/herinspection work, he/she should report the matter inaccordance with the respective OIGs internal policiesand procedures.

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    C. P ROFESSIONAL J UDGMENT

    The standard for inspection work is:

    This standard requires inspectors to exercise reasonable careand diligence and to observe the principles of serving the publicinterest and maintaining the highest degree of integrity,

    objectivity, and independence in applying professional judgment to all aspects of their work. Due professional judgment requires that:

    1. OIGs follow professional, Department/Agency, andorganizational standards and that inspection work be inaccordance with all applicable laws, rules, and regulations;

    2. Inspections are conducted in a timely, diligent, andcomplete manner, using appropriate methods andtechniques;

    3. Evidence is gathered and reported in a fair, unbiased, andindependent manner and report findings, conclusions, andrecommendations are valid and supported by adequatedocumentation;

    4. At all times the actions of OIG staff conform to highstandards of conduct, including adherence with theStandards for Ethical Conduct for Employees of theExecutive Branch and Federal conflict of interest laws;

    and

    5. OIG staff coordinates inspection results with appropriateofficials.

    Due professional judgment should beused in planning and performing

    inspections and in reporting the results.

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    Inspectors should use professional judgment in selecting thetype of work to be performed and the standards that apply tothe work; defining the scope of work; selecting the inspectionmethodology; determining the type and amount of evidenceto be gathered; and choosing the tests and procedures fortheir work. Professional judgment also should be appliedwhen actually performing the tests and procedures and whenevaluating and reporting the results of the work.

    In conducting an inspection, inspectors may employ themethods of inquiry most appropriate for the object of study.They may rely on the work of others after satisfying themselves

    regarding the quality of the work by appropriate means. Suchwork may include work performed by other OIG units, theGovernment Accountability Office, Department/Agencyinternal studies, Department/Agency contracted studies, orstudies by private research and academic organizations.

    Professional judgment requires inspectors to exerciseprofessional skepticism, e.g., questioning and criticallyassessing evidence, throughout the inspection. Inspectorsshould use the knowledge, skills, and experience called forby their profession to diligently gather evidence and objectivelyevaluate its sufficiency, competency, and relevancy. Inspectorsshould seek persuasive evidence and should not presumehonesty or dishonesty on the part of those who are providingevidence.

    The exercise of professional judgment allows inspectors toobtain reasonable assurance that material misstatements orsignificant inaccuracies in data will likely be detected if theyexist. However, absolute assurance is not attainable becauseof the nature of evidence and the characteristics of fraud.

    Therefore, while this standard places responsibility on eachinspector and inspection organization to exercise professional judgment in planning and performing an assignment, it does

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    not imply unlimited responsibility or infallibility on the part of either the individual inspector or the inspection organization.

    D. Q UALITY C ONTROL

    The standard for inspection work is:

    Each OIG organization that conducts inspections shoulddevelop and implement written policies and procedures forinternal controls over its inspection processes/work to providereasonable assurance of conformance with organizationalpolicies and procedures, the Quality Standards forInspections, and other applicable policies and procedures.The nature and extent of these internal controls and theirassociated documentation will be dependent on a number of factors, such as the size and structure of the organization andcost-benefit considerations. As appropriate, organizationsshould seek to have quality control mechanisms that providean independent assessment of inspection processes/work.Documentation of the execution of quality control mechanismsshould be retained for a sufficient period of time to allow forevaluation and use in conjunction with other quality controlmechanisms.

    A key aspect of inspection quality control is adequatesupervision. Supervision provides important judgment andan additional level of oversight to the work done bysubordinate, often less experienced, staff. Supervisors should

    work with inspection team members to reach agreement as tothe work the team will do and how they are to proceed. Theteam also should have a clear understanding of the purpose of

    Each OIG organization that conductsinspections should have appropriate

    internal quality controls for that work.

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    the inspection and what it is expected to accomplish.Supervisory reviews help ensure that:

    1. The inspection is adequately planned;

    2. The inspection work plan is followed, unlessdeviation is justified and authorized;

    3. The inspection objectives are met; and

    4. The inspection findings, conclusions, andrecommendations are adequately supported

    by the evidence.

    E. P LANNING

    The standard for inspection work is:

    The standard for inspection planning is intended to ensurethat appropriate care is given to selecting inspection topicsand preparing to conduct each inspection, to includecoordinating inspection work and avoiding duplication. Theselection of an inspection topic should consider the relevancyof the topic and the significance/impact of potential outcomes,and these points should be of continuing considerationthroughout the inspection. Department/Agency and othercustomers needs also should be a consideration in selectinginspection topics.

    The planning standard is also intended to ensure that inspectiontopics are appropriately researched and that the objective(s)of the inspection are clearly understood. Research, work

    Inspections are to be adequately planned.

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    planning, and coordination should be thorough enough, withinthe time constraints of the inspection, to ensure that theinspection objectives are met. In pursuing this standard, thefollowing should be appropriately addressed:

    1. CoordinationInspection planning includescoordinating planned activities with other inspection,audit, and investigative entities, as well as appropriateorganizations that could be affected by the activities.Internal and external constraints should be consideredwhen planning inspection activities. Inspectors shouldbe flexible in their plans, within reasonable limits. Any

    internal reviews performed by the entity to be inspectedor by outside professional organizations should beconsidered and reviewed to determine applicabilityto the inspection. In addition, when an inspectionaddresses a topic that is cross-cutting or affects othergovernmental organizations, the OIG may considerconducting a joint or coordinated review with thoseother organizations OIGs.

    2. ResearchConsistent with the inspection objectives,inspection research includes a review of existing data,discussions with program and other appropriateofficials, literature research, and a review of pertinentwebsites and other internet accessible materials togather information that will facilitate understanding of the program or activity to be inspected. Researchshould help to identify the criteria applicable to theevaluation of the program or activity. Examples of possible criteria include: laws, regulations, policies,procedures, technically developed standards or norms,expert opinions, prior periods performance,

    performance of similar entities, performance in theprivate sector, and best practices of leadingorganizations. Research should attempt to identify

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    the results of previous reviews that may be relevantto the inspection, and inspectors should follow up onknown significant findings and recommendations thatdirectly relate to the current inspection. Inspectorsneed to assess the validity and reliability of the datagathered.

    3. Work planAn inspection work plan should bedeveloped that clearly defines the inspectionobjective(s), scope, and methodology. It may alsoinclude inspection time frames and work assignments.Adequate planning also entails ensuring that sufficient

    staff with the appropriate collective knowledge, skills,abilities, and experience is assigned to the inspectioneffort. As work on an inspection progresses, the work plan may need revision to address new information.

    During inspection planning, consideration should also be givento whether the inspection is likely to involve sensitive orclassified information. If an inspection will or may involvesensitive or classified information, appropriate steps must betaken to ensure the proper protection of that information. Thepotential sensitivity or classification of information needs tobe a consideration throughout the inspection process.

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    F. D ATA C OLLECTION AND ANALYSIS

    The standard for inspection work is:

    With regard to collecting data, the following guidance shouldbe addressed whenever appropriate:

    1. The sources of information should be described inthe supporting documentation in sufficient detail sothat the adequacy of the information, as a basis forreaching conclusions, can be assessed.

    2. Information should be of such scope and selected in

    such ways as to address pertinent questions aboutthe objectives of the inspection and be responsive tothe informational needs and interests of specifiedaudiences.

    3. The procedures and mechanisms used to gatherinformation should ensure that the information issufficiently reliable and valid for use in meeting theinspection objectives. For example, inspectors needto ensure the validity and reliability of data obtainedfrom computer-based systems that is significant to the

    inspectors findings. Inspectors will use professional judgment in determining whether information issufficiently reliable and valid.

    The collection of information and datawill be focused on the organization,

    program, activity, or function beinginspected, consistent with the inspection

    objectives, and will be sufficient to provide a reasonable basis for reaching

    conclusions.

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    4. Confidentiality, as appropriate, should be afforded tosources of information consistent with the InspectorGeneral Act of 1978, as amended; the internal policiesof each OIG; and other applicable laws and statutes.The Inspector General Act of 1978, as amended,states that the Inspector General shall not, withoutthe consent of the employee or unless the InspectorGeneral determines that such a disclosure isunavoidable, disclose the identity of a Department/ Agency employee providing a complaint orinformation concerning the possible existence of anactivity constituting a violation of law, rules, or

    regulations; mismanagement; waste of funds; abuseof authority; or a substantial and specific danger tothe public health or safety. OIGs should develop andimplement procedures for maintaining theconfidentiality of individuals providing information.Inspectors must carefully monitor their actions andwords to not inappropriately reveal the source of information.

    5. Appropriate safeguards should be provided forsensitive information, such as personal and proprietarydata, as well as classified information. InspectorsGeneral should ensure they have appropriateprocedures for handling such information.

    In analyzing data, the following guidance should be considered:

    1. Data should be reviewed for accuracy and reliability;and, if necessary, the techniques used to collect,process, and report the data should be reviewed andrevised to ensure the accuracy and reliability of

    inspection results.

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    2. Qualitative and quantitative information gathered inan inspection should be appropriately and logicallypresented and documented in work papers, to ensuresupportable interpretations.

    3. Inspection procedures should provide for supervisoryreview and other safeguards to protect the inspectionfindings and reports against distortion by the personalfeelings and biases of any party to the inspection.

    4. Findings often have been regarded as containing theelements of criteria, condition, effect, and, when

    problems are found, cause. However, the elementsneeded for a finding depend entirely on the objectivesof the inspection. Thus, a finding or set of findings iscomplete to the extent that the inspection objectivesare satisfied and the report clearly relates thoseobjectives to the applicable elements of a finding.

    G. E VIDENCE

    The standard for inspection work is:

    Evidence may take many forms, including physical, testimonial,documentary, and analytical. Physical evidence is obtained

    Evidence supporting inspection findings,conclusions, and recommendations

    should be sufficient, competent, and relevant and should lead a reasonable

    person to sustain the findings,conclusions, and recommendations.

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    by an inspectors direct review or observation of people,property, or events and should be appropriately documented.Testimonial evidence is obtained through inquiries, interviews,or questionnaires. Documentary evidence consists of createdinformation, such as letters, contracts, grants, memorandums,and files. Analytical evidence includes computations,benchmarking, trending, comparisons, and rational arguments.

    The following guidelines should be considered regardingevidence:

    1. Evidence should be sufficient to support the inspection

    findings. In determining the sufficiency of evidence,inspectors should ensure that enough evidence existsto persuade a knowledgeable person of the validityof the findings.

    2. To be competent, evidence should be reliable and thebest obtainable by using reasonable collection andevaluation methods. The following presumptions areuseful in judging the competency of evidence:

    (a) Evidence obtained from an independent sourcemay be more reliable than that secured from anorganization being inspected.

    (b) Evidence developed under an effective systemof internal controls generally is more reliable thanthat obtained where such controls are lacking orunsatisfactory.

    (c) Evidence obtained through direct physicalexamination, observation, or computation may be

    more reliable than evidence obtained through lessdirect means.

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    (d) Original documents generally are more reliablethan copies.

    (e) Testimonial evidence obtained from an individualwho is not biased or who has complete knowledgeabout the area usually is more competent thantestimonial evidence obtained from an individualwho is biased or has only partial knowledge aboutthe area.

    3. Relevance refers to the relationship of evidence to itsuse. The information used to prove or disprove an

    issue must have a logical relationship with, andimportance to, the issue being addressed.

    H. R ECORDS MAINTENANCE

    The standard for inspection work is:

    Supporting documentation is the material generated andcollected as part of an inspection that, when effectivelyorganized, provides an efficient tool for data analysis and asound basis for findings, conclusions, and recommendationsthat address the inspection objectives. Supportingdocumentation should also provide:

    All relevant documentation generated,obtained, and used in supporting

    inspection findings, conclusions, and recommendations should be retained for

    an appropriate period of time .

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    1. A record of the nature and scope of inspection work performed; and

    2. Information to supervisors and team leaders enablingthem to properly manage inspections and evaluate theperformance of their staff. Supervisory and teamleader review should be evidenced in the inspectiondocumentation.

    Inspection organizations should establish policies andprocedures for the safe custody and retention of inspectiondocumentation. Inspection documentation should be retained

    and disposed of in accordance with applicable legal andadministrative requirements and schedules, e.g., thoseestablished by the National Archives and RecordsAdministration and the respective Department/Agency.Documentation generated by the Department/Agency and usedto support inspection findings, such as lengthy reports, couldbe retained by the Department/Agency so long as the OIGfully references these documents and is confident that thedocumentation in question could not be lost, destroyed, oraltered.

    I. T IMELINESS

    The standard for inspection work is:

    Inspections should strive to deliver significant information to appropriate

    management officials and other customers in a timely manner.

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    To be of maximum use, inspections need to be conductedand reporting needs to be completed in a timely manner. Thishelps to ensure the work is current and relevant. During aninspection, it may be appropriate to provide interim reportingof significant matters to appropriate officials. Such reportingis not a substitute for a final report, but it does serve to alertthe appropriate officials to matters needing immediate attention,so corrective action may be initiated. The following guidanceshould be considered regarding timeliness:

    1. Time frames should be flexible in response to changingpriorities.

    2. Time frames established during planning are subjectto change due to unforeseen circumstances, such asthe need to expand the scope of an inspection or theneed to add additional objectives.

    J. F RAUD , O THER ILLEGAL ACTS , AND ABUSE

    The standard for inspection work is:

    In conducting inspection work,inspectors should be alert to possible fraud, other illegal acts, and abuseand should appropriately follow up

    on any indicators of such activity and promptly present associated

    information to their supervisors for review and possible referral to theappropriate investigative office.

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    During an inspection, inspectors should be alert to anyindicators of fraud, other illegal acts, or abuse (behavior thatis deficient or improper when compared with behavior that aprudent person would consider reasonable and necessarybusiness practice given the facts and circumstances). Whilethe identification of such activities is not usually an objectiveof an inspection, it is necessary to have a clear understandingof the action required if such circumstances are discovered.

    Inspectors should be aware of vulnerabilities to fraud and abuseassociated with the area under review in order to be able toidentify possible or actual illegal acts or abuse that may have

    occurred. In some circumstances, conditions such as thefollowing might indicate a heightened risk of fraud:

    1. The absence of internal controls.

    2. Inadequate separation of duties, especiallythose that relate to controlling andsafeguarding resources.

    3. Transactions that are out of the ordinary andare not satisfactorily explained ordocumented, such as unexplained adjustmentsin inventories or other resources.

    4. Missing or altered documents or unexplaineddelays in providing information.

    5. False or misleading information.

    6. A history of impropriety, such as past reviewswith findings of questionable or criminal

    activity.

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    In pursuing indications of possible illegal acts or abuse,inspectors should exercise professional judgment so as toensure they do not interfere with potential investigations and/ or legal proceedings. If possible illegal behavior arises,inspectors should promptly present such information to theirsupervisors for review and possible referral to the appropriateinvestigative office.

    K. R EPORTING

    The standard for inspection work is:

    Various means may be used to report on the results of inspection work, e.g., written reports, oral presentations,videos, or slide presentations. Regardless of the means used,there should be retrievable documentation of the reporting.The content of the reporting will be affected by the specificmeans used and the purpose it is serving. Reporting shouldbe timely, complete, accurate, objective, convincing, clear,and concise.

    Inspection reporting normally should describe the objective(s),scope, and methodology of the inspection and state that theinspection was conducted in accordance with the QualityStandards for Inspections. Also, inspection reporting should

    provide the reader with the context in which the subject matterbeing inspected should be viewed, such as the impact orsignificance of the program/activity being reviewed, to help

    Inspection reporting shall present factual data accurately, fairly, and

    objectively and present findings,conclusions, and recommendations in a

    persuasive manner.

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    ensure the focus is not too narrowly drawn and to give clearerunderstanding of the impact of any report recommendations.Reporting language should be clear and concise and, whilerecognizing that some inspections deal with highly technicalmaterial, should be written in terms intelligible to the intendedrecipients and informed professionals.

    Inspection reporting frequently is structured in terms of findings,conclusions, and recommendations. Findings should besupported by sufficient, competent, and relevant evidence.Conclusions should be logical inferences about the inspectedprogram or activity based on the inspection findings. Typically,

    each finding requiring corrective action should be addressedby one or more recommendations directed to the managementofficial(s) who have the authority to act on them.Recommendations normally should not be prescriptive innature; rather, they should be crafted in a manner that lays outwhat needs to be corrected or achieved. When appropriate,inspectors should solicit advance review and comments fromresponsible officials regarding the content of the report andshould include the comments or a summary thereof in thereport.

    Care must be taken to ensure that, as applicable, theconfidentiality of individuals providing information isappropriately maintained in the inspection reporting process.

    Written inspection reports should be distributed to theappropriate officials responsible for taking action on the findingsand recommendations. Further distribution will be subject tothe internal policies of each OIG and fully comply with allrequirements contained in the Privacy Act; the Freedom of Information Act; and security and other applicable laws,

    regulations, and policies.

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    January 2005/Quality Standards for Inspections 25

    L. F OLLOW -UP

    The standard for inspection work is:

    Ultimate inspection success depends on whether necessarycorrective actions are actually completed. Therefore, eachOIG should take steps, as necessary, to determine whetherofficials take timely, complete, and reasonable actions tocorrect problems identified in inspection reports and agreedon by management. Specific follow-up actions shall be guidedby the follow-up and resolution policies of each OIG, inaccordance with Office of Management and Budget CircularNo. A-50, as amended.

    Follow-up helps ensure actions are undertaken and completedwithin a reasonable time. Management notification that anaction has been completed within the agreed-on timeconstitutes reasonable assurance and can be the basis forclosing an action for follow-up purposes. However, theOIG should perform, as appropriate, follow-up work to verifywhether agreed-on corrective actions were fully and properlyimplemented. When planning follow-up activities, OIGsshould assess whether the work would be most effectivelyaccomplished utilizing the staff that conducted the originalwork or other staff members. Also, in planning and conducting

    new inspections, prior recommendations that relate to the newinspection should be considered and followed up on to theextent practicable.

    Appropriate follow-up will be performed to assure that any

    inspection recommendations made to Department/Agency officials are

    adequately considered and appropriately addressed.

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    M. P ERFORMANCE M EASUREMENT

    The standard for inspection work is:

    Consistent with the intent of the Government Performanceand Results Act of 1993, it is important to be able to

    demonstrate the positive results that inspections contribute tothe more effective management and operation of Federalprograms. The nature and extent of performance measurementwill be affected by a number of factors, such as the size andstructure of the organization performing inspections. Forexample, measures may be established that capture inspectionresults collectively with other OIG activities, such as a measurethat addresses both audit and inspection reportrecommendations. Performance measurement should focuson the outputs and the resultant outcomes from inspectionwork. Optimum performance measurement captures theimpact of an inspection and may include such things asmonetary savings, enforcement of laws, or legislative change.

    N. W ORKING RELATIONSHIPS AND C OMMUNICATION

    The standard for inspection work is:

    Mechanisms should be in place tomeasure the effectiveness of inspection

    work.

    Each inspection organization should seek to facilitate positive working

    relationships and effectivecommunication with those entities beinginspected and other interested parties.

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    January 2005/Quality Standards for Inspections 27

    The OIG and the Department/Agency should strive to do thefollowing:

    1. Foster open communication at all levels. With limitedexceptions, primarily related to investigative-typework, the OIG should keep the Department/Agencyadvised of its work and its findings on a timely basisand strive to provide information helpful to theDepartment/Agency at the earliest possible stage.Surprises are to be avoided.

    2. Interact with professionalism and respect. OIGs should

    act in good faith.

    3. Recognize and respect the mission and priorities of the Department/Agency. Each OIG should work tocarry out its functions with a minimum of disruption tothe primary work of the Department/Agency.

    4. Be thorough, objective, and fair. The OIG mustperform its work thoroughly, objectively, and withconsideration to the Departments/Agencys point of view and should recognize Department/Agencysuccesses in addressing challenges or issues.

    5. Be engaged. While maintaining OIG statutoryindependence of operations and recognizing thatOIGs need to conduct work that is self-initiated,congressionally requested, or mandated by law, OIGsshould interact with Department/Agency managementto identify any specific needs or priorities managementmay have regarding the reviews to be conducted bythe respective OIG.

    6. Be knowledgeable. The OIG will continually striveto keep abreast of Department/Agency programs and

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    PCIE/ECIE Inspection and Evaluation Committee28

    operations, and Department/Agency managementshould be kept appropriately informed of OIGactivities and concerns being raised in the course of OIG work.

    7. Provide feedback. OIGs should implementmechanisms, both formal and informal, to ensureprompt and regular feedback.

    Specific to inspection work, inspectors should appropriatelycommunicate information about the inspection process andthe nature of the inspection to the various parties involved in

    the inspection to help them understand such things as theinspection objective(s), time frames, data needs, and reportingprocess. Inspectors should use their professional judgmentand comply with their respective organizations policies andprocedures to determine the form, content, and frequency of communication. Communication should be appropriatelydocumented in the associated inspection records.

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    January 2005/Quality Standards for Inspections 29

    G UIDE FOR C ORE C OMPETENCIES FOR

    INSPECTION O RGANIZATIONS AND INSPECTORS

    This guide was developed by the Inspector General community toidentify the core competencies that each inspection organization shouldstrive to have as an organization, as well as the competencies that aredesirable for a journeyman inspector and senior management.

    Organizational Competencies

    Leadership

    Vision Continual Learning Results Orientation Integrity

    Team Skills

    Team Problem Solving Time Management

    Management

    Accountability Customer Service Strategic Thinking

    Occupational Mastery

    Department/Agency and Mission Knowledge Oral Communication

    Written Communication

    APPENDIX 1

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    Journeyman Level Competencies

    Leadership

    Results Orientation Integrity

    Team Skills

    Team Problem Solving Time Management

    Management

    Project Management Strategic Thinking

    Occupational Mastery

    Department/Agency and Mission Knowledge Evaluation Methods and Techniques Oral Communication Written Communication

    Senior Management Competencies

    Leadership

    Vision Political Skills Influencing/Negotiation with External Groups Results Orientation Leading People

    Integrity

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    January 2005/Quality Standards for Inspections 31

    Team Skills

    Team Problem Solving Time Management

    Management

    Accountability Decisiveness Strategic Thinking

    Occupational Mastery

    Department/Agency and Mission Knowledge Oral Communication

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    PCIE/ECIE Inspection and Evaluation Committee32

    GUIDE FOR

    GENERAL SKILL L EVELS FOR INSPECTORS *

    APPENDIX 2

    GS NumberSkills 5 7 9 11 12 13 14

    1. OIG statutes, regulations,policies, & procedures X X X X X X X

    2. Ethics code of conduct X X X X X X X3. Basic research X X X X X X X4. Computer applications X X X X X X X5. Data collection techniques X X X X X X X

    6. Data analysis X X X X X X X7. Use of computers X X X X X X X8. Disclosure & Privacy Act X X X X X X X9. Fraudulent, abusive & illegal acts X X X X X X X10. Documenting support X X X X X X X11. Interviewing X X X X X X12. Basic report writing X X X X X13. Administrative process X X X X X14. Inspection work plans X X X X X15. Designing survey instruments X X X X16. Statistical sampling X X X X17. Site selection and approving

    records for field work X X X X18. Advanced report writing X X X X19. Packaging inspection reports X X X X20. Training inspection team members X X X21. Briefings X X X22. Marketing inspection products X X X23. Legislative process X X X24. Departmental budget process X X X25. Managing & coordinating

    inspection team activity X X26. Preparing congressional testimony X X27. Dealing with the media, public,

    & industry X X

    *This appendix is intended as a guide only. It is recognized that, among other things, gradestructure and position descriptions for staff vary between OIGs, which can affect the applicabilityof the guidance contained herein.

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