INSPECTORS' HANDBOOK
INSPECTORS HANDBOOK
This handbook provides policies, standards, and guidance for inspectors in the Office of Inspections, Office of Inspector General (OIG/ISP), Department of State and Broadcasting Board of Governors. It describes the authority, mission, scope, and procedures of OIG/ISP. Inspectors are expected to be conversant with its contents and will be evaluated upon its standards. This edition is identified as 2006. Subsequent versions will carry succeeding numbers and dates.
Appendices include inspection guidelines and other materials.
1 - INTRODUCTION
1A. AUTHORITIES
Established in 1986, the Department of State’s Office of Inspector General (OIG) is the successor to an inspection corps and tradition dating from the Consular Service Reorganization Act of 1906, the Rogers Act of 1924, and the Foreign Service Act of 1946. Additional information is available on the Office of Inspector General home page on the Department of State Intranet Central, and in 2 FAM 030.
The Inspector General Act of 1978, as amended, established the requirement for inspectors general at 12 federal agencies. It also authorized inspectors general to conduct and supervise audits and investigations relating to programs and operations of the cognizant agency, including documentary subpoena power. In addition, it mandated the inspector general’s dual reporting responsibilities to the Congress and the head of the0 cognizant agency, and required an annual report to Congress.
The Foreign Service Act of 1980, as amended, established the requirement for an inspector general of the Department of State and the Foreign Service, with similar responsibilities and the same authorities as granted in the Inspector General Act of 1978. It required the inspector general (IG) to audit and inspect periodically each Department of State post, bureau, and other operating unit. The 1980 Act established a mandate for OIG to assess the implementation of foreign policy by reviewing activities and operations performed under the direction of chiefs of mission for consonance with U.S. foreign policy (Section 209 (g)).[1]
The Foreign Relations Authorization Act, FY 1986-87, amended the Inspector General Act of 1978 to include the requirement for an independent IG at the Department of State.
The Omnibus Diplomatic Security and Antiterrorism Act of 1986, as amended, assigned additional duties to the IG. This required the establishment of an independent Office of Inspector General at the Department of State by October 1, 1986. It also authorized the IG to perform all duties and responsibilities of Section 209 of the Foreign Service Act of 1980 and the Inspector General Act of 1978. The 1986 act also specified that the IG cannot be a career member of the Foreign Service.
The 1999 Omnibus Consolidated and Emergency Supplemental Appropriations for Fiscal Year 1999 (H.R. 4328) provided for the consolidation of the State Department, the U.S. Arms Control and Disarmament Agency, and the United States Information Agency.
The 1999 Omnibus bill also states that the IG of the Department of State and the Foreign Service shall exercise the same authorities with respect to the Broadcasting Board of Governors and the International Broadcasting Bureau as the IG exercises under the Inspector General Act of 1978 and section 209 of the Foreign Service Act of 1980 with respect to the Department of State. The bill stipulates that the IG shall respect the journalistic integrity of all the broadcasters covered and may not evaluate the philosophical or political perspectives reflected in the content of broadcasts.
Subsequent amendments to the Act of 1987 instituted semiannual reports to Congress and gave limited testimonial subpoena power to OIG. Executive Orders 12863 and 12333 establish the authority for the Office of Inspector General to conduct intelligence oversight reviews of U.S. missions overseas.
The President appoints the IG, with the advice and consent of the Senate. The President can remove the IG and must communicate the reasons for removal to both houses of Congress. The IG reports directly to the Secretary of State and has additional reporting responsibilities to the Congress. The IG must report semiannually to the Secretary, which in turn must transmit this report to the Congress. Recommendations made by the IG carry extensive authority under law.
OIG maintains a system of records, separate and distinct from the Department of State’s, in accordance with the Privacy Act notice published in the Federal Register February 21, 1991. Absent extraordinary circumstances, OIG operations and records are not subject to the jurisdiction of the Department of State nor to grievance procedures for mandatory records disclosure.
1B. VISION, MISSION, AND GOALS OF OIG
OIG Vision
To be a world-class organization promoting effective management, accountability, and positive change in the Department of State, the Broadcasting Board of Governors, and the foreign affairs community.
OIG Mission
The Office of Inspector General conducts independent audits, inspections, and investigations that advance the missions of the Department of State and the Broadcasting Board of Governors. OIG provides leadership to:
• promote integrity, efficiency, effectiveness, and economy;
• prevent and detect waste, fraud, abuse, and mismanagement;
• identify vulnerabilities and recommend constructive solutions;
• offer expert assistance to improve Department and BBG operations;
• communicate timely, useful information that facilitates decision-making and achieves measurable gains; and
• keep the Department, BBG, and the Congress fully and currently informed.
CORE Values
• Credibility. OIG is committed to the highest standards of accountability, independence, integrity, and professionalism.
• Objectivity. OIG’s reports and other products are factual, accurate, informative, and reliable.
• Relevance. An independent agent for positive change, OIG provides valuable and timely service.
• Effectiveness. OIG makes a difference. OIG’s impact is enhanced by working cooperatively, in a spirit of teamwork, internally and with other organizations.
1C. ETHICS
It is important, especially when on an inspection trip, to be mindful of regulations, avoiding anything that has a hint of impropriety. Here are some things that have caused us concern in the past:
• Avoid intellectual property rights or piracy violations
• Avoid black market currency purchases
• Do not ask staff to do favors for you or your unofficial traveling companion
• Abide by the travel regulations (business class travel only for continuous travel over 14 hours, etc.)
• Deduct costs for meals covered by representational events
• Pay government credit card balances promptly
• Pay or make arrangements for payment for telephone bills, medical bills, and other personal bills before leaving the inspected post
• Pay for spousal travel and use of mission resources
• Avoid appearances of favoritism
• Don’t allow previous relationships to impair objectivity (be mindful of the need to recuse oneself from working in areas where you were recently involved in programs or operations or are close friends or adversaries with someone)
• Avoid discussing employment opportunities in the areas we inspect
• Avoid discussions about other specific OIG work.
1D. ORGANIZATIONAL STRUCTURE
OIG carries out its work under authority provided in the Inspector General Act of 1978, as amended, the Foreign Service Act of 1980, as amended, and other statutes. OIG consists of six offices and two advisory units that serve particular functions. This section includes a description of each office/unit and its work.
Office of Audits
The Office of Audits evaluates management and financial operations within the Department and BBG, as well as finance-related external activities funded by the Department or BBG through contracts or financial assistance. It assesses whether established goals and objectives are achieved, whether resources are used economically and efficiently, and whether results and operations are consistent with laws, regulations, and good business practices. It also tests financial accountability and the reliability of financial statements.
The Office of Audits has six divisions: financial management; procurement and property; security and intelligence; contracts and grants; international programs; and policy, planning, and quality assurance.
• The Financial Management Division audits internal financial management functions. The Department accounts for over $13.5 billion in annual appropriations used, and over $35.7 billion in assets. The division assists the Department in achieving effective financial management of its programs and adequate accountability over its resources.
• The Security and Intelligence Division audits the security and intelligence activities of the Department and BBG to improve their personnel, facilities, and information programs. The Department’s security and intelligence programs annually exceed $1.4 billion and $50 million, respectively. The division identifies ways to enhance operations and promote greater economy and efficiency.
• The Procurement and Property Division audits real property, personal property, transportation, and procurements. The Department annually contracts for over $1.2 billion in supplies, equipment, local guard force services, construction projects, and architecture and engineering services.
• The Contracts and Grants Division audits external organizations such as grantees, contractors, Fulbright foundations, and commissions. In FY 2005, the Department reported that Federal financial assistance for the year, including grants, cooperative agreements, loans, and certain types of contributions, was projected to exceed $5 billion. These audits ensure that resources are accurately accounted for and that the dollars are spent in accordance with their intended purposes.
• The International Programs Division evaluates major Department programs, including those related to export controls, drug control funding, human resources, and support services. These reviews help ensure that Department programs are effective and efficient, and that adequate controls are in place to protect resources.
• The Policy, Planning, and Quality Assurance Division reviews selected audit projects; performs and hosts peer reviews with other federal entities; ensures independent referencing of draft audit reports; maintains the Audit Manual; implements and maintains an electronic work paper capability (TeamMate); tracks the status of Department and BBG compliance with OIG recommendations; and provides technical, editorial, and administrative support to other divisions and offices within OIG.
Office of Inspections
The Office of Inspections evaluates the operations of the Department and BBG, their posts abroad, and related activities. Inspections cover broad areas such as: executive direction, implementation of U.S. policy, resource management, management controls, and security oversight.
Executive Direction: Inspections provide mission, bureau and broadcasting leadership with advice and consultation to improve the management, coordination, and oversight of foreign affairs programs and operations. Inspection teams prepare Inspectors’ Evaluation Reports on each Ambassador, Deputy Chief of Mission, principal officer, Assistant Secretary of State and Deputy Assistant Secretary. A large part of each inspection involves consultation with staff at all levels to improve management of their programs and operations.
Policy and Program Implementation: Inspections review policy and program goals and objectives to determine whether they are being effectively achieved,
whether diplomatic mission operations are in accordance with U.S. foreign policy, whether U.S. interests are being accurately and effectively represented and whether all elements of an office or mission are being adequately coordinated.
Resource Management: Inspections review resources for staffing, facilities, equipment, real personal property, and funding to determine whether they are used, located, and managed with maximum efficiency, effectiveness, and economy, and whether financial transactions and accounts are properly conducted, maintained, and reported.
Management Controls: Inspections evaluate management controls to determine whether activities and operations are administered in accordance with applicable laws and regulations, whether internal management controls have been instituted to ensure quality of performance and reduce the likelihood of mismanagement, whether instances of fraud, waste, or abuse exist, and whether adequate steps for prevention, detection, and correction have been taken.
Security Management: Inspections evaluate the overall management of operations and programs to deter, detect, and respond to threats from terrorism, political violence, intelligence penetration, or crime against personnel, facilities, and information, including electronic information. The inspections also review whether the chiefs of mission sufficiently oversee and coordinate all security activities.
The Office of Inspections conducts Compliance Follow-Up Reviews each year on select posts, offices, and bureaus inspected. These reviews occur six months or more after the full inspection and are designed to revisit key issues to ensure implementation of recommendations and provide quality control of the inspection process.
OIG uses the results of these inspections to address systemic deficiencies and identify remedies, or to plan further reviews of Department and BBG operations and programs. Inspections focus on areas of emphasis relevant to the Department, the Congress, and OMB, and the President’s Management Agenda.
Office of Investigations
The Office of Investigations conducts criminal, civil, and administrative investigations related to ensuring the efficient and effective operation of organizational programs and operations. It works with other law enforcement agencies on criminal and administrative matters, protecting the interests of the Department and BBG. The Office of Investigations is comprised of the Operations Division, which is responsible for the overall investigative operations, conducting specific proactive investigations, and the OIG Hotline; and the Fraud Division, which is responsible for conducting fraud investigations related to the Department’s programs and activities worldwide.
Information regarding Department personnel suspected of misconduct (e.g. prohibited employment practices, sexual harassment, workplace violence, inappropriate internet activity, etc) is submitted to the Office of Investigations for review and analysis. This information may be referred to other bureaus within the Department for further action. For example, administrative violations may be referred to Department or BBG bureaus handling human resource management or resource management, or, they may be referred to the Department's Bureau of Diplomatic Security (DS) for investigation, possible disciplinary, or administrative action.
Similarly, suspected violations or activity involving fraud, waste, abuse and mismanagement by Department personnel, its contractors or special category employees are referred to the Office of Investigations for review, analysis and investigation. The Office of Investigations may conduct an investigation jointly with other law enforcement entities or refer to DS for follow-up and administrative action. The Office of Investigations refers all criminal violations to the appropriate local, state or federal Office or Department for prosecution.
The Office of Investigations provides the Department and BBG with fraud awareness and prevention briefings; conducts proactive investigations to support the Department and BBG’s high risk, high dollar programs and operations; and the OIG Hotline is a confidential channel for reporting fraud, waste, abuse, mismanagement, other wrongdoing or a substantial and specific danger to public health and safety.
Office of Information Technology
The Office of Information Technology conducts inspections, reviews, and evaluations of the Department's information management and information security programs and initiatives. It is comprised of the following three units:
Compliance and Standards, which addresses issues related to the Department's efforts to protect its global information technology infrastructure. This includes annual reviews of the Department's compliance with the Federal Information Security Management Act (2002) and other related statutes. This unit also supports broader OIG initiatives by providing in-depth reviews of Department IT programs and initiatives and by supporting IT systems audit initiatives as required.
Inspections and Evaluations, which conducts comprehensive reviews of the effectiveness of information security and information management programs at bureaus and overseas posts, in support of broader OIG inspection initiatives.
Technology and Security, which reviews issues related to the cost effective acquisition, development, implementation and management of major IT systems, telecommunications networks, and other technologies across the Department. This unit also supports the larger OIG with internal IT modernization and technology refresh efforts.
Office of the Executive Director
The Office of the Executive Director (EX) promotes OIG operational effectiveness and efficiency by providing reliable and timely support and services. The Office of the Executive Director is comprised of two divisions: Management Services and Policy, Planning, and Reports.
The Management Services Division provides a full range of administrative support services, including operations and logistical support, budget and fiscal operations, human resources management (HRM), and OIG’s information technology operations and security, as well as long-term planning to ensure that OIG’s information technology systems are current with emerging technology and meet user needs.
The Policy, Planning, and Reports Division is responsible for OIG policy and planning activities, including strategic, performance, and annual work plans; preparation of the annual performance budget; performance measurement and reporting; workforce planning; design, publishing and distribution services for all OIG reports and publications; and development and review of policies and directives. The division keeps other government entities informed and supports the Inspector General’s participation in the President’s Council on Integrity and Efficiency, the Iraq Inspectors General Council, the Intelligence Community Inspectors General Forum, the Homeland Security Roundtable and other Department and Inspector General community groups.
Office of Counsel
The Office of Counsel provides legal advice to the Inspector General, his senior staff, and others in OIG on the full range of activities within OIG, including inspections, investigations and audits. The Office of Counsel is responsible for managing OIG's Freedom of Information Act (FOIA) and Privacy Act programs. The Counsel to the Inspector General reports to the Inspector General, and is independent from the Department’s Legal Adviser and BBG's General Counsel.
Assistant for Iraq and Afghanistan Matters
The magnitude and complexity of programs in Iraq and Afghanistan engage all elements of OIG. OIG’s work in both countries follows a focused and topical pattern (e.g. program assessments of matters such as police training, rule-of-law, and counter-narcotics). Targeted audits are conducted both by OIG staff and through contracts. OIG collaborates closely with other IGs (notably those in the Department of Defense and the Special Inspector General for Iraq Reconstruction – SIGIR.) The Assistant for Iraq and Afghanistan Matters proposes, designs, and (on occasion) participates in OIG projects relative to these two critical venues.
Security and Intelligence Advisor’s Unit
The Security and Intelligence Advisor’s Unit provides guidance related to security and intelligence oversight programs, acting as a liaison between OIG and the intelligence community. It keeps the Inspector General and Deputy Inspectors General advised on current and emerging security and intelligence issues, especially those that could warrant OIG review. When review is deemed appropriate, the Security and Intelligence Advisor leads the effort. It also examines OIG’s security and intelligence oversight findings and recommendations to ensure sound, consistent application of security/intelligence policy.
Congressional and Public Affairs Unit
The Congressional and Public Affairs Unit (CPA), headed by the Legislative Advisor, provides support to the Inspector General with respect to liaison with the U.S. Congress and the media. CPA ensures that OIG speaks with one voice to all audiences, including the Department, BBG, the Congress, the media, and the general public.
CPA ensures that Congress is fully informed about the Department’s and BBG’s programs and operations. It also responds to congressional oversight committees. The Legislative Advisor serves as OIG’s official spokesperson and CPA maintains contact with news organizations to respond to media inquiries and keep the press and public informed.
CPA identifies and tracks legislation affecting OIG, the Department, and BBG, and makes recommendations to the Department and the Congress concerning such legislation. CPA also coordinates the content of OIG’s website.
The Legislative Advisor’s staff is also responsible for coordinating briefings of foreign delegations with OIG staff as well as coordinating OIG’s presentations to seminars that educate Department of State staff on the role and function of OIG.
FIGURE 1. OIG MANAGEMENT CHART
CHAPTER II - THE INSPECTION PROCESS
2A. THE PCIE AND INSPECTION STANDARDS
The President's Council on Integrity and Efficiency (PCIE) was established in March 1981 to, as its mission statement says, “promote effective inspection and evaluation practices and information sharing among OIGs, develop innovative ways to address issues that impact numerous or all federal agencies, faster improved inspection and evaluation methodologies, and provide or develop training to enhance the skills of inspectors and evaluators.” The PCIE provides a forum for its members, who include the presidentially-appointed inspectors general, including that of the Department of State, and other senior federal officials, to discuss common concerns and to propose solutions to problems. Through its committees and other activities, the PCIE initiates procedures for detecting and preventing waste, fraud, and mismanagement; identifies systemic weaknesses in federal programs; and works with the administration to recommend corrective actions.
ISP staff may be called upon to draft reports to PCIE and otherwise support IG activities as a member of the council.
In the performance of inspections, OIG/ISP uses “Quality Standards for Inspections” issued by the PCIE in January 2005 (“blue book” standards). The following PCIE standards are general in nature but relevant for all federal agency OIGs, including that of the Department of State. The Standards are available in the “CD-Rom [FY]” folder on the common ”S” drive, and include both explanations of the Standards and examples of their application. The comments under “2. Independence” below are specific to the Department of State OIG. The remainder of this Handbook sets forth the ways in which OIG/ISP implements these general standards.
1. Competency
“The staff assigned to perform inspection work should collectively possess adequate professional competency for the tasks required.”
2. Independence
“In all matters relating to inspection work, the inspection organization and
each individual inspector should be free both in fact and appearance from
personal, external, and organizational impairments to independence.”
Former chiefs of mission or principal officers shall not participate in inspections at posts where they have held the positions of ambassador, deputy chief of mission (DCM), or principal officer.
Additionally, inspectors should inform the DAIG/ISP and the team leader if the following occur. These officials will determine whether the circumstances impair the inspector’s independence, and whether the inspector’s reassignment is appropriate.
• If they have served in the inspected entity during the past ten years
• If they have written an Employee Evaluation Report (EER) on an ambassador, DCM, principal officer, assistant secretary, deputy assistant secretary (DAS), or equivalent who is assigned to the inspected entity at the time of the inspection, or where such officer has written an EER on them.
• If they had or have a personal or professional relationship with anyone in the entity to be inspected whose work they will directly inspect and which might influence the objectivity of the inspection.
3. Professional Judgment
“Due professional care should be used in planning and performing
inspections and in reporting the results.”
4. Quality Control
“Each OIG organization that conducts inspections should have appropriate
internal quality controls for that work.”
5. Planning
“Inspections are to be adequately planned.”
6. Data Collection and Analysis
“The collection of information and data will be focused on the organization, program, activity, or function being inspected, consistent with the inspection objectives, and will be sufficient to provide a reasonable basis for reaching conclusions.”
7. Evidence
“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.”
8. Records Maintenance
“All relevant documentation generated, obtained, and used in supporting
inspection findings, conclusions, and recommendations should be retained
for an appropriate period of time.”
9. Timeliness
“Inspections should strive to deliver significant information to appropriate
management officials and other customers in a timely manner.”
10. Fraud, Other Illegal Acts, and Abuse
“In conducting inspection work, inspectors should be alert to possible
fraud, other illegal acts, and abuse and should appropriately follow up on
any indicators of such activity and promptly present associated information
to their supervisors for review and possible referral to the appropriate
investigative office.
11. Reporting
“Inspection reporting shall present factual data accurately, fairly, and
objectively and present findings, conclusions, and recommendations in a
persuasive manner.”
12. Follow-Up
“Appropriate follow-up will be performed to assure that any inspection
recommendations made to Department/Agency officials are adequately
considered and appropriately addressed.”
13. Performance Measurement
“Mechanisms should be in place to measure the effectiveness of inspection
work.”
14. Working Relationships and Communication
“Each inspection organization should seek to facilitate positive working
relationships and effective communication with those entities being
inspected and other interested parties.”
2B. TYPES OF INSPECTIONS
OIG/ISP conducts four types of inspections:
1. Inspections of Foreign Service posts, including missions and constituent posts, which examine:
• The effective formulation, coordination, and implementation of U.S. policies and programs.
• The accurate and effective representation of U.S. interests.
• The efficient and economic management of resources.
• The establishment and operation of management controls to prevent fraud, abuse, or other deficiencies.
• The oversight of intelligence operations at post.
•
2. Inspections of domestic bureaus and agencies, which examine:
• The effective and economic implementation of Department of State policies and goals.
• Bureau or operating unit impact on the Department of State.
• The efficient and economic management of resources.
• The existence and use of management controls.
• The management of overseas posts or regional offices.
3. Special inspections or evaluations, including thematic inspections, which examine specific activities, programs, problems, or issues.
4. Broadcasting Board of Governors inspections, which examine the same elements as domestic and overseas inspections of the Department of State BBG inspections and reviews.
2C. INSPECTION SCHEDULING AND COORDINATION
In the spring of each year, and after consultations with the regional and functional bureaus and others, and after examining a number of critical factors (including the time since the last inspection), OIG leadership decides which overseas missions and domestic bureaus or agencies will be inspected in the next fiscal year, as well as the cycles in which they will be inspected. In May or June this information is formally transmitted in an announcement cable or memorandum, as appropriate, to the mission and domestic entities involved.
On occasion posts or offices request scheduling changes (e.g., to be first or last in the cycle, or to be moved to another cycle). ISP considers the requests and sends notification of any revisions. A request for the deferral of a planned inspection is permitted in only the rarest of circumstances. Decisions regarding deferrals normally are made by the AIG for Inspections in coordination with the team leader and the DAIG for Inspections.
OIG/ISP coordinates its inspection activities with other OIG offices and some other offices of the Department to avoid scheduling conflicts or, in the case of other OIG offices, to permit reciprocal support.
2D. INSPECTION CYCLES
There are three main inspection cycles each year: fall (September-November), winter (January-March) and spring (April-June). There are usually five or six inspection teams working each cycle, and each cycle typically includes a mix of overseas and domestic inspections. Dependent on need, budget and staffing, there may also be inspections during the summer months. A cycle for one team might include inspections of one to three posts, bureaus, or parts of bureaus, depending on the size and complexity of the inspected organizations.
Each regular cycle consists of three parts:
■ a Washington survey phase of approximately one month;
■ the on-site inspection, whether overseas or in Washington; and
■ Washington briefings and report review and dissemination
In addition, the inspection process includes a compliance phase, in which ISP measures whether and how the inspected entity has complied with the recommendations made in the final inspection report. These four elements of the inspection process are discussed in greater detail at [ ] below.
Approximately two months (i.e., in July, November and February) before the beginning of the inspection cycle, ISP sends a notification cable (for overseas mission inspections) or memorandum (for domestic inspections) that advises the entities being inspected to consult the OIG web site () for instructions on how to prepare for the inspection. The cable or memorandum also requests the mission/bureau to name a control officer for the inspection, and gives the date by which material needed for the survey phase is due.
2E. INSPECTION TEAMS
Inspection team members are identified as either senior inspectors or inspectors. An inspector's status is determined by grade: Foreign service officers at the FE-OC level and higher, and Civil Service officers at GS-15 level and higher are senior inspectors. Other officers are inspectors. Generally, the team leader, deputy team leader, and lead inspectors are senior inspectors. The team and deputy team leaders determine the best use of personnel assigned to the group. The team leadership considers the experience, talents, and career specialties of all members, and has considerable latitude in allocating resources.
Each inspection team receives administrative support from the ISP Compliance, Coordination and Support (CCS) Unit. Each CCS staffer has assigned duties that they perform for all teams: they
■ assist with requests for appointments, visas, team calendars, travel orders and other administrative arrangements;
■ manage data and files, including the reception, electronic filing and retention of survey materials, questionnaires, and draft reports; and
■ retain and archive records
Team Composition and Duties: Overseas Mission Inspections
A typical team for an overseas mission inspection consists of a team leader (of ambassadorial rank), a deputy team leader, and inspectors responsible for the political/economic, consular, public diplomacy, management, information technology and security elements of the report, supported by CCS personnel. The team size is dependent on the size and complexity of the mission being inspected, and can range from several individuals to a dozen or more. If the mission is large, there may be two or more inspectors for a particular area (e.g., management, consular affairs, or security), with one designated the “senior inspector” for that subject.
Members of the inspection team each have specific assigned duties, but on occasion (for instance, if a team member becomes ill or needs to leave the on-site inspection) may have to assume others. All inspectors are expected to contribute to the overall assessment of the policy, management, and resource aspects of an inspection and to the development of inspection reports. In some cases, inspectors may travel before or after other team members to meet particular work requirements; for reasons of economy, the team leadership may decide to send some inspectors home before the inspection is entirely completed.
For missions that have constituent posts (consulates), or when the inspection covers not only the bilateral mission but also the U.S. missions to international organizations (e.g., the embassy in Paris and USOECD and USUNESCO), the inspection team may be divided on occasion into sub-teams. The TL may designate the DTL or another experienced inspector to head a sub-team to inspect one consulate, for instance, while the TL and other team members either remain at the embassy or are themselves inspecting another consulate.
All team members have inspection and drafting responsibilities in their specific areas of competence; several have additional responsibilities.
■ Team Leader (TL) – directs the team, inspects mission management and its coordination of other U.S. agencies at post under COM authority, writes inspector evaluation reports on mission management, with the assistance of the deputy team leader ensures that all OIG inspection standards are met, and that the workload is equitably distributed among team members, is final arbiter for the draft report and annex.
■ Deputy Team Leader (DTL) – acts as the primary contact point with the post on inspection-related issues, supervises administrative arrangements for the team both in Washington and overseas, inspects one or more substantive elements for the report, organizes and edits the draft report, incorporates changes and corrections to produce the final report, certifies the team electronic archives.
■ Archivist – appointed by the deputy team leader from the team, ensures that the electronic archives for the inspection are complete.
Other duties fall to team members, sometimes because of their particular expertise. The IT inspector, for instance, acts as the liaison with post on information technology issues, including the provision of adequate IT resources for the team. He or she also usually handles the collection and shipment of paper records (notes, back-up documentation for recommendations and the report narrative) from the inspection back to Washington. The management inspector may be asked to be responsible for accommodation and transportation issues, and/or iron out problems that occur with the team workspace. The DTL may ask any team member to assist with writing thank you letters to individuals who have provided particular assistance to the team during the on-site inspection. Team members usually share responsibility for the destruction of questionnaires and other reference materials at the end of the inspection.
Team Composition and Duties: Domestic Inspections
Domestic inspections range from those of full functional and regional bureaus to those of technical and administrative offices, sometimes including regional agencies or facilities. Because many of these inspections require particular expertise, and not all require the entire range of subject specialties, there is no one pattern for domestic inspection teams. For instance, a domestic inspection team may consist primarily of inspectors with particular experience and expertise in the areas of management, consular affairs, security and/or information technology, but not necessarily public diplomacy or political/economic affairs.
Each team has a team leader, deputy team leader and archivist, with duties essentially the same as those on an overseas mission inspection. The size and arrangement of the inspected entity helps determine how the work of the inspection is divided. For example, if a team of ten is inspecting a bureau that has eight offices, the TL and DTL may have oversight responsibility, with each of the remaining eight members given primary responsibility for the inspection of one office. As in the overseas mission inspection teams, the DTL may request that individual team members, in addition to responsibility for one subject area or organizational element of the bureau, also assist with miscellaneous duties such as the collection and disposition of questionnaires and reference materials.
2F. COMMUNICATION BETWEEN ISP/INSPECTION TEAM AND MISSION/BUREAU
As noted in Section IIC above, the first formal communication between OIG and both the overseas missions and domestic bureaus to be inspected occurs in the announcement cable sent in May or June of each year that announces the inspection schedule for the next fiscal year. It is followed, approximately two months before the beginning of the inspection [i.e., in July for the fall cycle, November for the winter cycle, and February for the spring cycle], by a short notification cable (or, in the case of domestic inspections, a memorandum to the appropriate Assistant Secretary, that:
a) refers them to the OIG Intranet web site () and the parallel CLASSNET web site () for general information and specific instructions concerning the inspection;
b) requests the name of the mission/bureau control officer for the inspection; and
c) gives the deadline for the submission of material needed for the survey phase.
OIG/ISP encourages the team leader, early in the inspection process, to establish personal contact with the leadership of the mission or bureau to be inspected. This might be in the form of an e-mail or telephone call from the team leader that reviews inspection activities and requests further information on any unusual circumstances that might affect the inspection.
Hereafter, most of the formal communication between the inspection team and the mission/bureau is between the DTL and the control officer. It is the DTL’s responsibility, in coordination with the TL, to:
■ determine whether there are any factors (e.g., local holidays, planned VIP visits, training or meetings involving high-level staff, extraordinary workloads) that could effect the precise scheduling or duration of the inspection;
■ in the case of overseas inspections, and in consultation with the posts involved, determine the order in which the missions will be inspected and the provisional dates for each inspection;
■ provide the mission/bureau with the names and, in the case of overseas inspections, subject responsibilities of the team members;
■ in the case of overseas inspections, solicit the mission’s views on accommodations and transportation arrangements for the team, and request hotel reservations for the team [or delegate another team member to communicate with the mission and arrange these elements]; and
■ be the primary conduit for all questions about the inspection, including the instructions given on the web site.
It is important that the DTL, acting for the team, make contact with the mission/bureau as soon as possible. The earlier the exact dates of the inspection are determined, for instance, the easier it is for the mission/bureau to make decisions on leave requests, scheduling training, etc.
2G. SPECIAL ISSUES: OVERSEAS MISSION INSPECTIONS
Accommodations and Transportation
The TL is responsible for determining and directing the team’s accommodation and transportation arrangements. The DTL or delegate will usually ask for the mission’s recommendations for hotels within per diem rates: in some cases the mission may be able to secure lower rates for long-term stays, therefore broadening the choice of hotels from which the team can choose.
Except for the largest cities and/or those with safe and easily accessible public transportation, most often the mission will offer to transport the inspection team daily to and from the mission. If that is the case, choosing a hotel close to the mission minimizes the commute and any overtime payments to drivers.
In some instances there is little choice about either. Security and safety concerns and/or the lack of public transportation may dictate that the team stay in one hotel and use mission transportation for not only hotel-mission transport, but even activities outside working hours (e.g., eating at restaurants in the evening, or participating in mission outreach and representational events.)
In the case of inspections in major capitals with well-developed public transportation alternatives, the team leader may allow individual team members to make their own accommodations arrangements. In most instances, however, the team will stay together in one hotel, and usually travel together to and from the chancery.
Clearances
For each overseas inspection, the OIG/ISP Office Manager prepares a draft and transmits a cable to the inspected mission giving the security clearances of the team members.
Family Members/Traveling Companions
Spouses and other companions may accompany inspectors on overseas inspections, or join them en route. Such persons travel as private citizens and do not have diplomatic immunity; they are responsible for securing their own visas (if required), transportation, and accommodations. Missions may not, and should not be asked to, incur expenses on their behalf or provide services not available to other non-U.S. government citizens. Team leaders must make it clear that such persons have no role in the inspection process.
2H. SPECIAL ISSUES: DOMESTIC INSPECTIONS
Domestic inspections may be on a Department bureau or part of a bureau located in the Harry S Truman building and/or State annexes. They may also include elements (such as regional passport, financial or logistics offices) outside of Washington. Administrative arrangements for domestic inspections, including access to computers, accommodation reservations, etc., thus vary widely, depend on the locations of the inspected entity, its physical and equipment resources and, to some degree, team wishes. The DTL and/or management and information technology inspectors on the team share responsibility for working with the affected bureau or office to ensure that team support requests are reasonable and appropriate to the circumstances.
3. INFORMATION RESOURCES
The main sources of information for inspections are:
■ the OIG web sites, which provide an outline and time line of the inspection process, and instructions and links to questionnaires for the post/bureau involved;
■ the survey phase (including written submissions from the post/bureau, other Department offices and other federal agencies, and interviews conducted in Washington, both within and outside the Department);
■ interviews with, and questionnaires completed by, employees of the post/bureau;
■ electronic and paper files of the post/bureau, documenting post/bureau activities, performance and management controls;
■ the inspectors’ eyewitness judgments on the management, programs, coordination and morale at the post; and
■ feedback on the draft report from the post/bureau and other Department entities
These various sources are discussed both in this section and in “IV. Inspection Phases” below.
3A. THE OIG WEB SITES
The OIG Intranet unclassified web site (), and the parallel classified web site (), provide all the general information, instructions, and questionnaires a post or bureau needs to prepare for an inspection. They also provide a relatively succinct overview of the entire inspection process, and are therefore good introductions to the process, especially for new inspectors.
3B. QUESTIONNAIRES
OIG/ISP uses four questionnaires to elicit information and comment from employees of the post/bureau, and one additional questionnaire that is prepared, in the case of an overseas mission inspection, by the country desk. Some of this information helps to shape the preparation for the on-site phase of the inspection; the remainder is used during the on-site phase itself. The questionnaires themselves, or a link to them, are available on the OIG web sites.
Functional Questionnaire (FQ). The FQs are to be filled in by the post/bureau before the survey period begins, and serve three main functions. They give a snapshot, by functional area or program (e.g., policy advocacy, information security, BBG operations), of the post. The responses to the questions help indicate problem areas, and therefore the FQs help shape the survey period (e.g., in the case of post inspections, the Department offices to consult). Finally, they can act for the post/bureau itself as a checklist for their operations, and help the post prepare for the inspection itself and for proper post operations in general.
There are 27 functional questionnaires for post (embassy) inspections; posts are instructed to review them all, but need only complete those that apply (e.g., the labor FQ if there is a dedicated labor officer at post.) When the inspection involves a non-embassy mission (e.g., USOECD in Paris), many of the questions on the FQs may not apply, and the team may decide to either create targeted questionnaires for the mission or indicate which of the embassy-oriented FQs to complete.
As the majority of constituent posts are relatively small, and the amount of time inspectors spend at them limited, there are special, shorter FQs designed for them. If, however, the constituent post is itself large (e.g., Frankfurt, Sao Paulo, Shanghai), the team may ask the post to complete any of the longer, detailed questionnaires normally completed only by embassies.
There is only one FQ for domestic inspections, dealing with the administrative support and operations of the bureau or office.
Workplace and Quality of Life Questionnaire (WQLQ). The WQLQ is an on-line questionnaire that is to be completed by all direct-hire State employees (and, in the case of overseas mission inspections, the heads of other agencies at post) by the beginning of the survey period. While it focuses on administrative services at post/in the bureau, the WQLQ also has several questions dealing with post/bureau leadership. Both kinds of questions help to point out the degree of overall satisfaction with post management, and are thus good indicators of post/bureau morale and potential problem areas.
WQLQ scores are computed electronically, and are available both in the order of the questions asked and in rank order, from highest to lowest average score.
Personal Questionnaire (PQ). Personal questionnaires solicit frank observations on the quality of post/bureau executive leadership and management, morale, and operations, and also give the respondents an opportunity to indicate possible issues of fraud, waste, or abuse. The information solicited is privileged and private, and may be used solely by OIG. Persons completing the questionnaire are afforded protection by federal legislation against reprisal or adverse action.
PQs have two parts: a numerical rating, on a scale of 1 to 5, of the chief of mission and deputy on a number of leadership and management issues, and a section soliciting comments on a range of issues, from administrative support to intra-mission/bureau coordination. Using a program provided by ISP, a team member, usually the DTL, is responsible for calculating the average executive management scores, and for transmitting them to ISP. ISP adds these scores to a matrix, and provides context for the scores by comparing them with those in recent inspections. These scores are an indicator not only of the post/bureau’s judgment on performance, but also help to indicate where the individuals stand when compared to peers holding the same positions. The TL conveys the scores to the individuals graded during one of their meetings in the course of the on-site inspection, and may use the scores in counseling the leadership team. In overseas inspections, the heads of other agencies at post are asked to complete only the first part of the PQ: their scores help indicate how other agencies view post leadership.
The PQ is available online at the OIG Intranet web site. To ensure currency, the inspection instructions ask that all State personnel download the questionnaire and complete it two weeks before the on-site inspection begins. Respondents are asked to place their completed questionnaires in sealed envelopes addressed to the inspection team, which are either given to the inspection control officer for holding in a safe until the inspection team arrives, or handed directly to a team member on the first day of the on-site inspection.
All inspection team members should read the PQs as soon as they are collected as, together, they provide an overview of post morale, point out problem areas, and help put the information gathered later in individual section interviews in the context of a wide sample of post/bureau employees. Inspectors also use the PQs as starting points in their one-on-one interviews with post/bureau personnel.
OIG/ISP takes several steps to guard the information contained in the personal questionnaires and to ensure that it is available only to team members. Once the team takes possession of the personal questionnaires, they are locked in file cabinets and available only to team members. The DTL or a designated inspector individually numbers the PQs, and at the end of the inspection is responsible for ensuring that all PQs are accounted for, and that all are destroyed, usually by shredding. This is to ensure that at no point, during or after the on-site inspection, do other individuals at post have access to the questionnaires.
Local-Hire Questionnaire (LHQ). At overseas inspections, all State local-hire employees are given the opportunity to complete the LHQ that solicits their views on a range of topics and that, along with the WQLQs, provides a 360-degree analysis of post leadership, operations and programs. Answers to translations of the LHQ are of limited use to the inspection team, so those employees with limited English language ability and/or no access to a computer should be urged to bring any concerns to the post FSN or local-hire committee, which in turn can raise the issues when the committee or its representatives meet with the management inspector(s) and other inspection team members. LHQs are treated as privileged communications, and are destroyed at the end of the on-site inspection.
3C. CHIEF OF MISSION/BUREAU STATEMENT
For overseas inspections, the Chief of Mission prepares a memorandum with information on:
□ The state of relations with the host government
□ The embassy’s principal goals and objectives, and the plan for achieving them
□ The extent to which each goal is being accomplished
□ Specific problems that inhibit achievement of post objectives
□ The performance of each operating section of the mission and of any constituent posts
□ Problems that merit special attention during the inspection
For domestic inspections, the Assistant Secretary prepares a similar memorandum. Both are due at the beginning of the survey period. Both memoranda necessarily contain some historical and policy elements. The main focus, however, should be on how the post or bureau actually functions, and on a candid explanation of the areas where it needs attention and/or additional resources.
3D. INFORMATION FROM DEPARTMENT OF STATE SOURCES
One to two months before the survey period begins, OIG/ISP requests information and comments from various Department bureaus and offices that deal with the post/bureau. In the case of overseas inspections, these requests always include those to the country desk and executive office of the post’s parent bureau.
The country desk is requested to provide:
(1) A list of major Washington contacts for issues involving the mission, both Department contacts and those in other U.S. government agencies, including name, position and telephone/email. The contact list, which can be provided by the desk officer, saves valuable survey time by identifying for the inspection team major sources for information on the mission’s performance.
(2) A Country Directorate Questionnaire, which is available on the OIG Intranet web site, has questions concerning interactions between the directorate and the posts.
(3) A Country Directorate Memorandum, addressed to the Deputy Assistant Inspector General for Inspections, that briefly summarizes policy and program issues as well as any problems facing the mission to be inspected. (If the inspection involves more than one mission, the directorate should prepare a separate memorandum for each.) The memorandum should include the following elements:
■ A general description of the state of U.S. relations with the host country and government;
■ A statement of the mission’s principal policy and program goals, and its progress in achieving them;
■ A review of the major policy and operational problems encountered by the mission, and the steps taken to resolve them; and
■ Brief assessments of performance in each of the key functional areas – political, economic, consular, public diplomacy, etc. – and country directorate interaction with the mission and individual sections.
The executive office is asked to provide a concise memorandum, addressed to the Deputy Assistant Inspector General for Inspections, that summarizes the administrative goals, program issues and problems that the mission to be inspected faces. The memorandum should include:
■ A review of the administrative goals and objectives given in the Mission Strategic Plan or other mission planning document, and an assessment of progress made;
■ A listing of administrative problems, especially those with implementing internal management controls, and
■ A general assessment of the performance of each major subunit of the administrative section (financial management, general services, etc.)
In addition, OIG/ISP requests information on the post to be inspected by other bureaus and offices that often interact with the post, including the Office of Overseas Buildings Operations, the Bureau of Human Resources, and the Office of Overseas Schools. All of the above memoranda are to be completed and sent electronically to OIG/ISP; a designated employee of CCS transfers them, when received, to the appropriate team folder. Most overseas inspections ……
3E. INFORMATION FROM OTHER GOVERNMENT AGENCIES
During the pre-survey period, OIG/ISP also informs other U.S. Government departments and agencies of the upcoming overseas and domestic inspections. For overseas inspections, the focus is on those non-State agencies with personnel assigned to the post being inspected. The notification elicits information: formal memoranda written in response to the OIG/ISP memorandum are, however, relatively rare. The notification also serves to inform these agencies that, in the course of the on-site inspection, team members will ask to interview the heads of other agencies, and will make every attempt to meet with any other American employee of those agencies at post who requests such a meeting.
The Department of State and International Broadcasting Bureau OIG is not, however, authorized to review the operations of other agencies at an overseas post, except as noted in the footnote on page 2 of this Handbook.
3F. INFORMATION FROM OTHER SOURCES
In some cases, most often in the survey phase of domestic inspections, it may be necessary and desirable to contact and request interviews or written information from nongovernmental organizations or individuals who work, and/or have a contractual relationship with, the bureau in question. Examples could include refugee resettlement agencies (for the Bureau of Population, Refugees and Migration), UN advocacy organizations (for the Bureau of International Organizations, USUNESCO, etc.), and World Affairs Councils (for the Bureau of Educational and Cultural Affairs.)
3G. INTERVIEWS
Interviews, both during the survey and on-site phases of the inspection, are critically important elements of the process. They are helpful in gauging the overall management and morale of the post/bureau and in amplifying and clarifying responses to written questionnaires, and often in bring to light sensitive issues. Most often they are done in face-to-face encounters, although during the survey phase a telephone call or e-mail exchange may suffice (or be all that is possible.) While ideally at least the major points in each conversation or exchange should be documented in a memorandum of conversation (memcon), there is not always time to do this. It is very important, however, to document any exchange that contains information to back up a finding, and either a formal or informal recommendation. Memcons that directly relate to a finding/recommendation become part of the formal inspection record.
Each inspector should make every effort to interview every State direct-hire person in their section(s). On overseas inspections, it is also desirable to interview as many local-hire employees in the section(s) as possible. Management inspectors often chose to meet with groups of employees (e.g., the drivers, or HR staff) but at a minimum should interview at least representatives of the local-hire employee association able to represent the interests and concerns of their fellow employees.
In domestic inspections, a parallel effort should be made to interview at least a representative number of contract or other non-direct hire employees, particularly if they represent a significant portion of the bureau/office work force.
3H. TEAM CD-ROM
Shortly before beginning the on-site inspection phase, CCS personnel prepare several identical team-specific CD-ROMs that contain both general information for all inspectors, and whatever is already in the team’s electronic files as of that date.
The CD-ROM thus contains not only the Inspector Handbook and Guidelines, editorial and administrative materials, forms, and the software “shell” which will contain the report, but also the completed functional questionnaires, Chief of Mission statement, and memcons written and information gathered during the survey phase. The CD-ROMs enable the inspection team access to materials it may need during the on-site inspection, and significantly reduce the amount of paper inspectors need to carry with them to post.
4. INSPECTION PHASES: OVERVIEW
The inspection process has four phases:
a) Survey. The inspection team solicits and evaluates information from the post/bureau, from the relevant regional and/or functional bureaus, from other U.S. government agencies that have personnel at post or particular interest in post/bureau operations and, occasionally, non-governmental sources.
b) On-site Inspection. On overseas inspections, the inspection team conducts interviews with post leadership, American and locally employed staff, and the heads of other agencies represented at post; evaluates documents; and writes its findings. Elements of the inspection team also visit constituent posts (see Instructions for Constituent Posts), and include the evaluations of those posts in the main report. The inspection team generally writes an SBU report on the mission’s performance in implementing U.S. policies and positions, administering post resources, and maintaining effective management controls, and a classified annex that covers more sensitive issues including the post’s oversight and management of the security program and its ability to detect, deter, and respond to security threats. Before leaving post the team provides the chief of mission with drafts of the report and annex, and drafts of the completed IERs are given to the individuals reviewed.
On domestic inspections, the inspection team interviews bureau personnel, evaluates documents, and writes its findings. The report is usually SBU, but can include a classified annex if appropriate. At the end of the phase, the team provides the Assistant Secretary or appropriate senior officer the draft report, along with any IERs written on his/her performance.
c) Briefings and Report Review/Dissemination. Upon its return to Washington, or at the end of a domestic inspection, the inspection team meets with relevant bureaus and offices to review inspection findings. Bureaus and offices provide comments on the draft reports, and the report may be modified as a result. The final draft report is edited and then vetted and cleared by OIG principals. Once the IG clears the final inspection report it is published and provided to the post, Department officials, Congress, and the Office of Management and Budget.
d) Compliance. The COM or Assistant Secretary, under the provisions of 2 FAM 037, is obligated to provide OIG with compliance reports for any formal recommendations contained in the published inspection report(s) within 30 days of the receipt of the final report and any classified annex.
In terms of time, the survey phase lasts approximately one month; the on-site inspection, whether of overseas post or domestic bureau and dependent on the size of the post/bureau and the complexity of its work, can take from approximately two weeks to two months; and the briefings and report review phase typically lasts approximately one month. OIG/ISP aims to have the report finalized and distributed as soon as possible after the end of the on-site inspection – ideally, within three months or so.
5. THE SURVEY PHASE
The survey phase usually begins approximately one month before the team begins the on-site inspection, i.e., in September (fall cycle), January (winter cycle) and April (spring cycle). During this phase, inspectors gather and review general information provided by the post/bureau and other sources, as outlined in Section IV (above), and begin to identify significant problems and issues. For domestic inspections, the survey is completed for the most part before the on-site inspection phase begins, but may become intermixed as the inspection progresses.
In most instances the inspection team meets for the first time early in the survey phase, and continues to meet periodically – usually weekly – during this period. They provide opportunities to clarify individual team responsibilities, exchange new information discovered from documentary sources and from interviews, and help to create a well-coordinated and informed team.
In accordance with the inspection instructions available on-line, certain documentary submissions are due by the beginning of the survey, including the functional questionnaires, the COM/Assistant Secretary memorandum, and memoranda from the other Department (e.g., staffing pattern and budget figures) and U.S. government agencies contacted earlier. CCS personnel place these submissions in the team e-file archives; reviewing these documents is usually the first step in amassing background and information on the inspected post/bureau.
Team members should also review information about the post/bureau readily available from Department sources on-line. These include:
■ the previous post/bureau inspection report (located in the folder “Reports, Historical” in the “S” drive, and any follow-up compliance reports;
■ the post/bureau Program Plan/strategic planning document;
■ for overseas inspections, the Background Notes, Post Report, and Post Profile available on the Intranet, and the post Internet web site; and
■ for domestic inspections, the bureau/office home page
For overseas inspections, an important survey element is the series of team briefings with Department and U.S. government offices that interact with the post. These typically include meetings with the Assistant Secretary (or Deputy Assistant Secretary) of the post’s regional bureau; the head of the country desk and desk officer(s); the regional bureau’s executive office; and the Office of Overseas Buildings Operations. The entire team should attend the meetings with EX and OBO, as both deal with a range of issues impacting on every section in the mission. Often only a portion of the team (typically the TL, DTL, political/economic, and occasionally the public diplomacy and/or consular officer) meets with the Assistant Secretary and country desk, as these meetings focus on the political/economic background in which the mission operates, and on policy advocacy. As these meetings effectively constitute the “core” interviews of the survey period, one of the team members participating should write a memcon on the meeting to be placed in the team’s e-file so that all team members have access to at least a summary of the discussion.
Beyond these meetings, each inspector is responsible for scheduling and documenting interviews of individuals and offices that work with his or her area of responsibility. It is particularly important to document, via memcons that are shared via the team’s e-file, interviews that contain information of potential value to other inspectors.
For domestic inspections, there are no “set” meetings, such as the list given above for overseas inspections. Since domestic inspections vary widely (e.g., bureau v. office, regional bureau v. functional and administrative support bureaus), the appropriate other bureaus and offices to see also vary widely, and need to be determined by the team early in the survey phase. As noted above, in some cases the on-site inspection will suggest other Department entities to contact, thereby merging, to some degree, the survey and on-site inspection phases.
All inspections look at certain core issues, including leadership, management controls, clarity and prioritization of goals, adequacy of human and material resources, and success in advancing Department priorities. In some cases, there may not be any readily apparent problem areas. But each post/bureau usually uncovers one or more areas of concern that help shape the inspection itself.
A review of all the survey elements – public information, post/bureau submissions, interviews – should help team members begin to focus on these specific areas of concern, both on the overall mission/bureau level and on that of individual sections. In some cases a focus will be very clear (e.g., overcrowded/unsafe working conditions) even in the survey phase. In other cases, only the on-site inspection itself will uncover a problem or concern.
The last team activity during the survey phase is the creation of a work plan, and subsequently a work plan meeting with the IG or the DIG. The DTL is responsible for drafting a work plan document that indicates, based on team information from the survey period, important and problematic issues the team believes will be the focus of the inspection. The work plan meeting is generally scheduled for several days before the team departs for its overseas inspection.
During the survey phase each inspector is also responsible for all the personal administrative tasks associated with the inspection and their absence from Washington, including as appropriate to:
■ request a travel authorization
■ make appropriate travel reservations (observing Department regulations on premium travel)
■ if desired, secure a travel advance against the inspection trip
■ obtain confirmation of e-tickets and/or secure paper tickets
■ complete OTS submission through the end of the inspection
■ ensure that the CCS administrative assistant has up-do-date emergency contact information, and a copy of the travel itinerary
■ obtain an approved leave slip, if the inspector intends to take the customary administrative leave days (one for every three weeks out of the country) immediately following the team’s return to Washington
■ take any requisite information security test, and obtain a certificate certifying that the test has been passed
■ on the winter inspection cycle, if applicable execute an OGE-450, the Confidential Financial Disclosure Report, that is now due by February 15 of each year
■ create voice and email “out-of-office” statements concerning the absence from Washington
■ ensure that no classified or sensitive material is left in the workspace
6. THE ON-SITE INSPECTION: OVERSEAS IMISSION INSPECTIONS
The First Day
In most instances, the inspection team travels to post together, is met on arrival by the mission control officer and/or a management officer, and taken to the team’s hotel, with the rest of the day free.
The first full inspection day is planned to introduce the team to the mission community, to orient it to the chancery and workspace, and to ensure that the administrative and computer support is adequate for the team’s needs.
This first inspection day usually includes:
■ An introductory meeting for the whole team with the chief of mission and deputy
■ A visit to the team working spaces
■ A short security briefing, limited to the topics (e.g., local crime and other personal safety issues) covered in briefings for TDY personnel and, if mission practice, the creation of badges
■ Provision of logons to SBU and classified computers, and Cable Express
■ An introductory meeting to explain the purpose and procedures of the inspection for all direct-hire American staff, including interested eligible family members (the chief of mission or deputy should introduce the team leader and then depart)
■ An introductory meeting to explain the purpose and procedures of the inspection for all local-hire staff (the deputy chief of mission or management officer should introduce the team leader and then depart); and
■ A quick walk-through of all the offices housed in the chancery and any nearby annexes, so that the entire inspection team can have a general orientation, an overview of the physical plant, and a chance to view staff working conditions.
As soon as computer accounts are established, the DTL or designated team member e-mails the Deputy Assistant Inspector General for Inspections and the ISP administrative assistant to confirm that the team arrived at the post safely and is now in e-mail contact.
Inspection Elements
Guidelines
The checklists in Appendix 2 of this Handbook suggest the kinds of questions that should be asked for each section. Not all will apply to every post/bureau, but all indicate the areas necessary to examine for a full and complete inspection.
Questionnaires
If possible on this first day, the DTL and team members should obtain the PQs and LHQs that have been given to the inspection control officer and combine them with any received during the two introductory meetings with American and local staff. As noted in IIIB above, the PQs then are individually numbered in order to guarantee that all are accounted for and destroyed at the end of the inspection, and placed in a safe or other secure cabinet accessible only to team members. As soon as possible the DTL or designated team member computes the management scores in Part A of the PQ, and conveys them to the CCS administrative assistant. All team members should read the PQs early in the on-site inspection: they provide a good overview of overall post management and morale.
Conducting Interviews
Personal interviews form the core of the information gathering when at post. In general the TL requests the office manager assigned to the team to make appointments with the COM, the deputy, heads of other agencies and others. Other team members may request similar assistance, but most often make their own appointments, often by contacting their section’s office manager, giving available times, and allowing the section employees to choose an appointment that does not disrupt their work schedule. As noted in IIIG above, each inspector is responsible for writing memcons on their interviews, in particular for those that provide support for formal and informal recommendations, and for those that provide information about other sections that may help other inspectors in their work.
Observation
Whenever possible, team members should attempt to view their section “in action,” performing a range of professional activities. These occasions include country team, section and other scheduled meetings; public diplomacy and related events, including press conferences and mission-sponsored cultural events; the provision of visa and consular services; and receptions and other representational events where mission employees interact with host government and other contacts. Such occasions help provide a rounded picture of the working dynamics within the mission staff, its organizational ability, and its degree of involvement with representatives of the host country.
Team Meetings
Just as in the survey period, periodic team meetings are useful in bringing the team – which may be working in various buildings – together to exchange information, including information for follow-up, and to coordinate activities. Some TLs favor brief, daily meetings (often at the beginning or end of the day), others less frequent gatherings. If information and impressions are exchanged continually, it increases the chance that the individual drafts of section reports, without excessive editing, will mesh in terms of both substance and tone.
This interchange is particularly important in regard to formal recommendations. Team members should use the meetings to report on issues that they believe will result in these recommendations as soon as they arise. In some cases the resulting discussion will help craft the recommendation or, in some cases, lead to its being dropped (or changed to an informal recommendation.) Early discussion can help avoid a team member putting significant time into developing and documenting a finding that is later dropped from the report. At a minimum the TL and DTL should be informed of proposed formal recommendations as soon as possible, rather than see them for the first time when inspectors turn in their draft section texts.
Information Analysis
It is sometimes difficult, but very important, for each inspector to try to allow time between the interview/observation and writing phases of the on-site inspection to step back and analyze the various strands of information collected. A good section report is not a listing of every activity of the section being inspected: it is a sifting of a great deal of information and the presentation of the most salient facts bound together with a narrative that paints a picture of section management and dynamics. The emphasis is on problem areas, on the one hand: on the other, the things the section does uniquely well or in an innovative fashion. The former sometimes lead to recommendations, both formal and informal; the latter can be written as a “best practice” that could be adopted by other missions.
Recommendations
Each inspector must determine when an issue merits a recommendation and, if so, what kind. Formal recommendations are numbered serially and, accompanied by sufficient prefatory text, included in the body of the report. Informal recommendations include a brief (one or two sentence) explanation of the problem plus the recommendation itself, and are appended at the end of the report.
Formal recommendations address such matters as serious deficiencies (e.g., working space or staff), actions contrary to Department regulations (e.g., not performing mandatory cash counts, allowing unwarranted premium travel), and substandard performance (e.g., insufficient attention to orienting and training new employees, inadequate attention to health and safety issues). Informal recommendations address less serious matters and/or make suggestions on how mission performance could be improved. Formal recommendations can assign action to the post itself and/or appropriate bureaus/offices in the Department; informal recommendations are limited to issues where action is for the post itself only.
While informal recommendations suggest action, formal recommendations require it. Formal recommendations must be supported by adequate documentation of the problem and proposed solution in the form of a well-reasoned and researched worksheet written by the inspector proposing the recommendation. In addition, formal recommendations trigger a compliance process: the post must respond, either with at least its initial efforts at compliance or a formal reclama, within 30 days of receiving an electronic copy of the final inspection report. If there are very serious issues, or ones on which post response appears inadequate, ISP may also send a team to monitor the post’s compliance and report on it. At the end of the entire inspection process, CSS staff must determine whether all the formal recommendations made in a report have been resolved, either by completing the recommended action, securing agreement for an alternate solution, or agreement to rescind the recommendation.
Even though they deal with less critical issues, and do not require the same formal backup or compliance procedure as formal recommendations, Informal recommendations require the same analysis and thoughtful drafting as formal ones. They may, but do not need to be, be alluded to in the section narrative. The succinct statement of the problem, and the recommendation itself, should be sufficiently clear to stand on their own.
Counseling
An important part of the on-site inspection process is synthesizing the information received in interviews and direct observation and, where appropriate, providing counsel. In some cases, those interviewed ask for counsel. Recently hired officers may want career guidance; other officers may want an outside opinion on their work, a clarification of a regulation, or a chance to discuss problems with their supervisor, colleagues, or subordinates. Ambassadors and DCMs are often reluctant to expose their uncertainties to subordinates, and may turn to the TL or DTL for advice. In other cases, it may be clear from interviews and direct observation that there are leadership or management problems at the section or post level that have not been aired and or addressed.
Inspectors are not trained psychological counselors, social workers, or mental health professionals. In the course of interviews or other discussions, inspectors may become aware that an employee or family member is in need of professional assistance. In these cases, inspectors should consult as soon as practicable with the team leader, and should bring the situation to the attention of appropriate medical authorities, either at post or in the Department of State.
Having an informed, experienced, and impartial outside source of information and guidance can be helpful to individuals and the post. While counseling may be beneficial, it should only be undertaken when the inspector has sufficient knowledge and/or experience to provide authoritative answers or propose sensible solutions. However, counseling can become an all-absorbing function, and inspectors must use their time wisely. Inspectors should remember that at the close of the inspection, the team must be able to deliver a well-documented report.
Producing the Draft Report
Time Line
The TL and DTL are responsible for establishing a team time line that will result in production of a draft report that is well-written, internally consistent, well-argued, and free of avoidable form and grammar errors. It is easiest to think of this process as working back from the date of the departure from post. A typical time-line is:
Day of departure from post
-1 day Team exit meeting with COM
-2 days Transmission of draft report (three copies) to COM
(at least 24 hours before the exit meeting)
-3 days Transmission of draft report to AIG and DAIG for
comment; reception of comments and their
incorporation into text of report
-4 days Final editing of draft report
-5/6 days Section submissions due; TL/DTL review for content
Depending on the length of time at post, adherence to the time-line, the quality of the section submissions and other factors, this time-line is sometimes compressed even further. It may also change if a weekend intervenes somewhere. If you count in the day of arrival, and the first day’s set activities and add the 4/5/6 days of the writing and editing phase in, it is clear that there may be only a very few days to actually accomplish the interviews, document checks, etc. of the inspection – rarely more than 5-6 days and, in short (two week) inspections, even less.
Writing the Section Draft
Each inspector is responsible for the content, form, and basic editing of the section they write. The basic rules of good writing apply. Paragraphs should address one main topic. The first sentence should summarize and contain the most important issue, and the following sentences should elaborate on it. For long sections, appropriate subheadings should be used to break up the text and enable the reader to locate important subjects.
CCS staff has created a number of checklists of the most common grammar and punctuation errors it encounters in the editing process. These guidelines are available on the team CD-ROM and should be consulted and followed before the draft section text is given to the DTL, who is the general editor for the entire report. The draft section text should also be spell-checked, and then re-read to catch additional errors before it is submitted. The DTL should not have to correct elementary errors or do any major rewriting of any of the section submissions: it is each inspector’s responsibility to ensure that their copy is as close as possible to print-read – that it is well-reasoned; clear, concise, and objective; and free of easily observable and correctable errors.
There should be nothing major in the draft report that comes as a surprise to the mission staff. Each inspector, therefore, has the responsibility to discuss the draft text he or she has written with the head of the section and/or the relevant individual concerned. In most cases this means providing and discussing the draft text itself. This should be done before the text is given to the DTL.
Editing/Producing the Draft Report
The DTL is responsible for collating the section texts and producing the draft report. This involves an initial reading for content of the individual sections; a secondary editing for grammar, language, uniformity of terms, and use of acronyms; creating the lists of acronyms and the list of post officers; putting the parts of the report together, and in order, in the report “shell;” a final reading for continuity; and a final spell check/reading.
The report is stronger when team members are part of the review process and have the opportunity to comment on the draft report, and note errors and inconsistencies. As the report has many audiences, it also helps for nonspecialists to review the text language for clarity. Whenever possible, then, and once the parts of the report have been united in the report shell, as many team members as possible should read the entire report and, where appropriate, suggest changes and corrections that the DTL can consider and institute. In the end the TL and DTL share responsibility for ensuring that the draft report that goes forward is as clear, concise, objective, and error-free as possible.
During this period, the DTL may ask other team members to assist with finalizing the appendices to the report, including the preparation of the acronyms list and the list of principal mission officers. The latter is usually the responsibility of the management inspectors, who in turn request the information from the post’s human resources unit.
When completed, the DTL sends the draft report by e-mail to the AIG and the DAIG for their review and comment. Taking into account Washington hours (and the time difference between OIG and the post), at least half a working day should be allowed to receive a response.
Once any suggested changes have been made, three copies of the entire draft report are presented to the COM (who usually gives the second and third copies to the DCM and the management officer) no later than 24 hours before the time set for the formal exit meeting on the last day of the inspection. The submission also includes a cover letter and separate instructions for compliance, both of which are accessible on the Team CD-ROM.
The Exit Meeting
Exit meetings vary widely, ranging from the ceremonial to serious (and sometimes contentious) discussions of the reports findings and specific recommendations. The meetings also vary widely in length, ranging from the short, essentially courtesy type to those lasting hours and involving a review of virtually every report element, from substance to word choice to typographical errors. The COM designates other attendees from the post side: most often it is the DCM and management officer only, but it may also be other section heads, particularly if there are major recommendations involving them. All of the inspection team members attend so that they are available to clarify points and provide background for their sections of the text and recommendations.
The exit meeting is not meant to be a negotiating session: except for obvious factual errors, post comments should be recorded and considered, but in the end the TL/team has the final say on the text it will present for wider consideration in Washington. The DTL and/or or a designated team member takes notes on the discussion, particularly any agreed changes in the text. As soon as possible –ideally, before leaving post – the DTL makes any agreed changes in the draft text, dates it, and e-mails it to the AIG and DAIG with the stipulation that it is ready for Washington review.
Inspector Evaluation Reports
IERs are prepared in all regular inspections of overseas posts and domestic bureaus. The inspection team leaders or other designated senior inspectors, drawing on the observations of all members of the inspecting team, write IERs on chiefs of mission, deputy chiefs of mission, and principal officers at overseas posts. In domestic inspections, the inspection team writes IERs on assistant secretaries and deputy assistant secretaries.
Although the team leader usually writes IERs, there will be occasions (such as split teams) when a senior inspector who is not team leader will temporarily head a team. The senior inspector should, if practical, share the draft IER with the team leader. If a negative IER appears probable, the senior inspector must consult with the team leader, who should try to visit the post personally. The team leader has the option of including a paragraph in any IER to express confirming or qualifying views.
The IER pays special attention to the rated officer’s skills and abilities to manage programs, personnel, budgets, and other resources. This focus does not exclude comments on the conduct of relations between a post and host country, or between the bureau and its embassies and other agencies of the U.S. government. The IER should include not only conclusions, but also details and examples on how the officer manages or leads. IERs of the chief of mission and the DCM should be consistent with each other and with the inspection report.
IERs are not usually written on employees who transferred from the post before the inspection. If the team believes that a report is necessary on such an officer, it should be written in conformity with regulations (3 FAM 521.3b (2)). Such an IER will be based solely on a review of the documentation and information available at post.
Both career officers and non-career managers who have been in position for at least 120 days receive IERs. Officers who have not been at post for at least 90 days at the start of an inspection will not receive IERs, except under unusual circumstances, and with the approval of the AIG/ISP. The team leader decides whether those persons at post at least 90 days, but less than 120 days, receive IERs.
The IG may bring IERs to the attention of the Department of State’s committees for the selection of candidates for nomination as chiefs of mission, DCMs, and other senior positions.
The inspectors may prepare IERs on other employees of the inspected entity, for the reasons stated in 3 FAM 521.3(b), which include:
□ To record outstanding or substandard performance that, in an inspector’s opinion, needs additional documentation.
□ To correct an injustice.
□ To record performance, as observed during the inspection, that differs markedly from that reported in the prior EER.
□ To document certifiable incidents of failure to comply with approved inspection recommendations.
If an employee assigned to an inspected unit believes that an EER prepared by the post or bureau is incomplete or inaccurate, the team leader shall designate an inspector to investigate the facts and circumstances. If the inspector and the team’s managers conclude that the report is incomplete or inaccurate, the team will prepare an IER and submit it to the IG. If the complaint is without merit, the inspector will prepare a memorandum to that effect. The result and circumstances of the complaint will be recorded in the inspection archives. The inspector shall notify the complainant of the action taken and the reasons thereof.
If an inspector discovers a serious deficiency during an inspection, concludes that it was the responsibility of an employee who has departed post, and believes that the deficiency was not adequately documented in the employee’s EER, the inspector will investigate the facts and circumstances. If the available information is not adequate for an IER in accordance with the above criteria, the inspector will forward a memorandum to the IG. The IG will consider what further action may be required.
Circumstances that merit the preparation of an IER should clearly relate to the performance of the employee and to that employee’s suitability for advancement to greater responsibilities. An example of such circumstances might be an officer’s abusive treatment of subordinates, unrecorded or inadequately recorded in EERs, which is of such a nature that it should have an effect on promotion or placement. Unrecorded outstanding performance might also warrant an IER. These procedures can right wrongs and injustices and inform the Office of Performance Evaluation (M/DGP/PER/PE) of unusual circumstances that have not been reported in normal personnel evaluation channels.
Personnel officials (M/DGP/PER) may be aware of the existence of any of the above conditions about an employee and consequently ask OIG to investigate the matter. At the IG’s discretion, inspectors may be tasked to look into the matter for M/DGP/PER. If appropriate, the inspectors will prepare an IER on the employee.
The length of the IER is limited to the form. Inspectors should discuss with and show the draft IER to the rated officer. The IER must be completed, signed by the rating inspector and the rated officer, and given to the rated officer before the team departs post. The signature of the rated officer on the form indicates only that the officer has received the IER and does not constitute his/her agreement with the IER.
The inspection team should pouch the IER to OIG/ISP, and the rating inspector should hand-carry other copies. The rated officer has ten working days to make written comments to the IER. Inspectors should encourage the rated officer to make comments, but they are not required. There is no limit to the length of the rated officer’s statement.
If the rated officer cannot finish the statement before the departure of the inspection team, the rated officer should forward the report with his or her comments to the IG by classified pouch, or telegraphically, using the OIG channel, “Eyes Only for the Assistant Inspector General for Inspections.” If there is no response within ten days, the OIG/ISP Operations Support Unit will cable up to two requests for the rated officer’s comments. If no comments are provided, this will be noted in the file.
If an inspector believes that a rated officer’s medical, family, or other circumstances should be considered when preparing an IER, he/she should discuss the matter, in advance, with the AIG for Inspections.
The IG, upon receipt of an IER, will appoint a panel of three senior inspectors (retired or active duty) to review the report. This panel will ensure the adequacy of documentation for the IER, consistency, and conformity with the regulations. If the reviewers judge an IER to be poorly prepared or insufficiently documented, they will return it to the drafting inspector for revision.
On completion of the process, the panel sends the IER to the IG for review. If the rated officer is a career employee, the IER is sent to the Director General with a request that it be placed in the rated officer’s personnel file. IERs for non-career employees are sent to the deputy secretary of State and then to the White House personnel office.
IERs are not used to document suspected illegal activities. Instances of such a nature are the subject of a separate review within OIG by the Office of Investigations. Although an IER can and should document a serious deficiency in overall performance, it must not refer to alleged illegal activity, ongoing or anticipated investigations, or to information learned as part of an ongoing criminal or administrative review.
Administrative Tasks
During the days before the exit meeting, and often in the hours before and after it, team members share various tasks that help complete the inspection. These include:
■ writing thank you notes to those who have been of particular assistance during the on-site inspection. This always includes the OMS assigned to the team, and may include the medical unit, the CLO and others. The team CD-ROM includes the template for these notes that the team may use, or choose to write an original note. The DTL assigns this responsibility to one of the team members, who often creates and notes while the DTL is working on producing the draft report
■ accounting for, and shredding the PQs as well as the LHQs. This is often done after the exit meeting
■ erasing any documents or other materials on the computers used
■ gathering any reference or other official materials needed for the archives or future use for transmission to Washington (the information management inspector is usually responsible for boxing these team materials and sending them back by certified pouch)
■ ensuring the team workspace is clean, and supplies used during the inspection are gathered for easy collection
7. AFTER THE ON-SITE INSPECTION
Team Activities in Washington
After the team returns to Washington, there are usually one or two weeks of activities, including a “hot wash” meeting with the IG, team debriefs and administrative tasks. Activities shared by all team members include:
■ completing any work papers, including memcons, not already done at post
■ completing and submitting a travel voucher (appending a copy of the ticket or reservation that contains the routing and cost)
■ scheduling out briefs on significant findings in their sections with Department (and, if appropriate, other agency) offices
The team archivist must ensure that the team electronic file includes all necessary documents, including complete work papers for formal recommendations.
The DTL’s responsibilities include:
■ scheduling the major out briefs that involve the entire the team. In most cases this includes out briefs with the relevant regional bureau’s front office and executive office, with the Office of Overseas Buildings Operations, and with the IG for the hot wash (formal debrief on the inspection trip and report) meeting. These meetings are generally scheduled one to two weeks after the team returns
■ writing an issues memorandum for the hot wash meeting
■ collating all the responses, comments and corrections received from OIG offices (particularly the Office of Counsel) and those of other departments sent the draft report, and amending the text of the draft report as appropriate
■ certifying that the team electronic archives are complete
The IG, the DIG, the AIG, the DAIG and the entire team usually attend the hot wash meeting, and takes place as soon as practicable after the draft report has been sent out for comment. The meeting may produce additional changes to the draft report that must be incorporated into the final report.
Production and Distribution of the Final Report
Once the DTL has considered all comments from the OIG and other Department sources and the hot wash, and incorporated them in the draft text as necessary, the DTL transmits the text to the editors. The editors review the draft text for form and other errors and, when finished, transmit it to the DAIG for Inspections for a final review. When that is completed, the text is transmitted to the AIG, who send it through the front office review process including the Office of Counsel and the DIG. After the DIG clears, the report is given to the IG for final review and approval.
Once the IG has approved the report and it has been formatted, the text is conveyed electronically to the COM. The hard copy of the report is sent later and that initiates the compliance phase of the inspection. The post has 30 days from receipt of the hard copy to respond to OIG/ISP on the initial steps the post has taken to comply with the formal recommendations contained in the report.
Copies of the report are sent to Congress, to Department bureaus and offices, to other U.S. Government agencies, and to the front office and section heads of the post. Further distribution of the text may be made after a formal request to OIG/ISP, and at the discretion of the DAIG for Inspections.
8. THE ON-SITE INSPECTION: DOMESTIC INSPECTIONS
Most of the information given in section V, above, on overseas mission inspections, applies to domestic inspections as well. The largest differences deal with timing and administrative arrangements.
Unless travel to satellite offices (e.g., passport agencies) is involved, inspection teams on domestic inspections are not generally under the same tight time restrictions as teams on overseas mission inspections, particularly those involving more than one post where changing travel dates is problematic. The survey period on domestic inspections may be shorter as well. That said, domestic inspections must still be completed within the cycle initiated.
Administrative arrangements generally are simpler in domestic inspections as well. In some cases, if the bureau has adequate swing space, the inspection team may request and obtain the full complement of computer support needed in an overseas mission inspection, and rooms to meet as a team and conduct interviews. If the bureau being inspected is located in the Harry S Truman building, or in annexes with no or limited swing space, this is less likely. In those cases, team members may travel to HST or the annex for interviews, but do their writing at ISP. In either case, the DTL or designated team member should, as soon as possible during the survey phase, clarify what the teamwork space options are.
9. THE COMPLIANCE AND RESOLUTION PROCESS
Compliance follow-up reviews provide senior managers of the Department of State and the International Broadcasting Bureau with evaluations and progress reports on the status of implementation of recommendations made as a result of earlier inspections. They also provide the IG with an evaluation of the quality of an inspection and help to identify any particular or systemic weaknesses in the inspection system.
Although compliance with the informal recommendations is expected, a written compliance report on informal recommendations is not required. Informal recommendations left with the inspected entities are not part of the resolution process. The only exception is that CFR teams may track informal recommendations on follow-up visits to the inspected entities.
Compliance Procedures
OIG provides copies of reports to the senior manager of posts, bureaus, or offices that are charged with action on the recommendations. Under the FAM guidelines, senior managers have 45 days to provide OIG/ISP with initial compliance status reports on each recommendation. It is OIG policy to reply promptly to compliance responses with an analysis of the response and a decision on the status of the recommendation. The mutual objective is to obtain resolution within six months of the date of issuance of the inspection report. OIG is required to report to the Secretary of State and the Congress on recommendations without a management decision for periods longer than six months.
A compliance response is a written reply from the post, bureau or unit to which a recommendation has been assigned informing OIG of agreement or disagreement with the recommendation. Comments indicating agreement include planned corrective actions, and, if appropriate, dates for achieving these actions. The reasons for any disagreement must be explained fully.
OIG/ISP classifies the status of recommendations as closed, resolved/open, or unresolved. These designations are explained below.
1. Closed – Final action on a recommendation has been presented and accepted by ISP, or impasse procedures have led to a final management decision, either positive or negative.
2. Resolved/open – A recommendation is resolved/open when: (a) the designated action office concurs in the recommendation, but has not presented satisfactory evidence that it has implemented the recommendation; or (b) the action office disagrees with all or part of the recommendation, and ISP agrees to accept partial compliance or non compliance pending final action.
3. Unresolved – A recommendation is unresolved when (a) the designated action office has not responded or has failed to obtain clearance of its response by the offices identified by ISP as participants in the compliance process; (b) the action office has failed to address the recommendation in a manner satisfactory to OIG; or (c) the action office has indicated its disagreement with the recommendation in whole or in part, OIG has pressed the issue to impasse, and an impasse decision has not yet been issued.
An impasse is invoked when the designated action office rejects an ISP recommendation or makes no response to it, and OIG/ISP, after a reasonable effort to achieve agreement, seeks resolution of the issue at higher management levels. The Under Secretary for Management is the Department of State’s designated official for impasse resolution.
OIG/ISP is responsible for maintaining an accurate record of the status of each recommendation through the entire process of compliance and implementation of corrective action. This responsibility includes tracking actions, keeping records of these actions, acknowledging incoming correspondence from tasked entities, and preparing reports regarding resolution matters. OIG/ISP follows guidelines developed to meet the PCIE Quality Standards for Inspections.
OIG/PPM is the central repository for all inspection reports and follow-up reviews issued by OIG/ISP. OIG/ISP provides copies of all incoming and outgoing correspondence to OIG/PPM.
The ISP compliance inspectors will, when possible and appropriate, consult with the inspection team on the resolution of recommendations. As inspectors prepare for an inspection, they should consult with the compliance staff on the status of the prior inspection reports. If there are still open recommendations from the prior report, they should either be closed or carried forward in the new report. In either event, the new inspection report should state that it closes the prior report.
Special Procedures
As outlined in 2 FAM 037.1-2, OIG has special procedures (i.e., “fast track”) to hasten reporting on and resolution of recommendations involving significant cost savings and personnel positions.
ISP handles recommendations involving Foreign Service or Civil Service positions as follows:
□ ISP notifies the bureau and M/DGP. Primary action is assigned to the bureau, which is asked to coordinate its response with M/DGP and the inspected entity. M/DGP is requested to place a hold on the position.
□ The action office has 45 days from the date of receipt of the memorandum to respond to ISP, upon which a dialogue is begun with the inspected entity aimed at mutual resolution.
□ If the action office does not reply within 45 days, ISP asks PER to remove the positions from the affected bureau’s and post’s staffing levels. If ISP receives a negative response, it may take the issue immediately to impasse.
The same procedure is followed for recommendations involving cost savings, cost avoidance, or safety issues that require “fast track” handling. In these cases, action bureaus are asked to report decisions to ISP within 30 days. If the bureau does not accept the recommendation, ISP seeks early resolution under the impasse procedures.
Compliance Follow-Up Review (CFR) Visits
ISP/PPC visits as many inspected entities as resources permit. These visits are normally conducted between six months and one year after the full inspection. Information gathered during these visits provides Department of State and IBB management with evaluations and progress reports on the implementation of recommendations made during earlier inspections. The visits also provide an opportunity to appraise the appropriateness of the findings and recommendations.
OIG/ISP announces CFRs by cable to the posts and by memorandum to domestic Department of State and IBB offices. While the IG has reserved the right to conduct unannounced CFRs, notice is normally given.
CFR inspectors operate in teams of two or three, and spend one to two weeks at overseas posts, and two to three weeks in Department of State offices. The CFR teams interview members of the previous inspection team (when possible) and persons from appropriate offices within the Department of State and IBB before performing the CFR. They review inspection and compliance files.
The CFR team, when possible, verifies the actual status of all reported resolution actions. At posts for which the inspection led to numerous recommendations, and where there has been a good faith effort at resolution demonstrated in the post’s responses, the CFR team concentrates its available time on the more complex and important issues and employs sampling techniques for the remaining recommendations. Provided the CFR team finds no deficiencies in post resolution on the complex and important issues, those recommendations not reviewed can be closed on the basis of overall good faith resolution.
A CFR focuses on resolution of previous inspection recommendations. The CFR team does not normally conduct new evaluations of post, unit, or program operations. If the CFR inspectors find a serious problem not reviewed by the original inspection team, or if a new issue is reported to them by members of the inspected entity, the CFR inspectors may conduct a review, and make new findings and recommendations. Such CFR recommendations will be handled by the CFR team and by OIG/ISP/PPC in the same manner as original recommendations.
A CFR report evaluates the overall quality of implementation of the previous inspection team’s recommendations. It also cites any significant changes of circumstances that affect the inspected entity’s ability to comply with the recommendations. It may recommend modification or cancellation of certain recommendations. The CFR report also informs the OIG/ISP of any major issues that have arisen since the inspection and may recommend to the OIG an investigation, audit, or an accelerated re-inspection of the post or function.
The CFR report closes the prior inspection report. It will contain the status of recommendations from that report, including those already closed. If resolution has not been satisfactory, or if action has not been completed, the recommendation is reissued. CFR inspectors can modify original recommendations and issue them as new CFR recommendations.
Quality Assurance Reviews
The CFR team may evaluate, for the benefit of the AIG and DAIG for Inspections, the quality of the previous inspection in a Quality Assurance Report (QAR). The basic guidance used is the material contained in this Handbook. The team also elicits the views of the management and staff of the inspected entity on the conduct and quality of the last inspection. Resources permitting, each inspection team will be subject to a QAR each fiscal year.
This QAR, at a minimum, includes reviews of:
□ The prior team’s adherence to the guidelines set forth in the Inspectors’ Handbook.
□ The adequacy of work papers.
□ The verifiability of findings.
□ The compliability of the inspection team’s recommendations.
□ The number of recommendations the CFR team modified or closed based on acceptable non-resolution.
□ The adequacy of the compliance process.
The CFR team provides the draft QAR to the original team leader for review and comment. The CFR team will consider comments from the original team leader or other inspectors and may make changes to its draft report. The original team leader may provide written comments that will be attached to the QAR.
On completing the QAR, the CFR team sends it to the AIG and DAIG for Inspections. The QAR is treated confidentially, and there is no distribution beyond the OIG/ISP. The head of OIG/ISP/PPC will retain one record copy in a personal file with the CFR inspection work papers.
OIG/PPC prepares an annual QAR, based on all the QARs for the previous year. This report may identify trends that suggest improvements in ISP inspection procedures. In such cases, OIG/ISP management will review the report and institute appropriate improvements.
10. OTHER OIG/ISP PRODUCTS
OIG/ISP provides a variety of products, as shown in Figure 4. Inspection reports, compliance follow-up review reports, and quality assurance reviews are described elsewhere in this Handbook.
The three types of reports discussed below – assessment, thematic, and summary reports – are prepared for and distributed to the same general audience as are inspection reports. The OIG/ISP also prepares special memoranda, which are distributed to a limited readership outside of OIG, and internal memoranda, which are not distributed outside of OIG.
Assessment Reports
Resource limitations may preclude the conduct of full inspections of overseas posts and domestic offices. In such cases, one or more inspectors may conduct limited reviews during visits of shorter duration than a normal inspection. OIG senior management and the inspection team will determine in advance the areas to be covered and the procedures to be followed, using a modified version of the general guidelines set forth in this Inspectors’ Handbook.
The result of such a review will be an assessment report and will be a limited version of a full inspection report. OIG senior management and the inspection team will decide in advance the format of the assessment report and which topics will be covered. It is not necessary that all topics in the outline for the inspection report be included. See Figure 2 in this Handbook.
Assessment reports are numbered and published in the normal OIG manner. If recommendations are prepared, they are numbered and treated in the same way as are formal recommendations from a regular inspection. OIG/ISP/PPC will track the recommendations for compliance. Archive material and documentation for recommendations will follow the guidelines for inspections as described in this Handbook.
Thematic Reports
Thematic reviews and the resulting reports may arise from inquiries by the IG, from global issues raised during inspections, from Washington reviews, or from other sources. As noted in Section II.H.10, inspectors are asked to be alert to systemic issues, which, if sufficiently important, may be addressed through thematic or summary reports. The consideration of these issues may involve on-site visits to posts outside of the regular inspection cycle. In the past, OIG/ISP has prepared thematic reports on, among other topics, the border biometrics program (laser visa program), the adequacy of disciplinary actions in the Department of State, the training and development of unconed junior officers, and management controls for small embassies.
Thematic reports are numbered and published in the normal OIG manner. If recommendations are prepared, they are numbered and treated in the same way as are formal recommendations from a regular inspection. OIG/ISP/PPC tracks the recommendations for compliance. Archive material and documentation for recommendations should be prepared following the guidelines for inspections as described in this Handbook.
Summary Reports
Summary reports are similar to thematic reports, but are prepared based only on information gathered from past inspection reports and other OIG documents. They address systemic issues found in a series of inspections, and are used to bring to the attention of Department of State managers situations that are affecting many bureaus or posts.
Summary reports are numbered and published in the normal OIG manner. If recommendations are prepared, they are numbered and treated in the same way as are formal recommendations from a regular inspection. OIG/ISP/PPC tracks the recommendations for compliance. Archive material and documentation for recommendations should be prepared following the guidelines for inspections as described in this Handbook.
Special Memoranda
There are many occasions on which the IG may wish to present a specific issue to a defined audience outside of OIG. Special memoranda are used for this purpose, and they might include action memos to Department of State bureaus, briefing memos, Congressional testimony, etc. The topics covered in special memorandum can arise during inspections, assessments, or reviews, or from outside requests, IG inquiries, etc. The format for special memoranda is flexible, and the length of the memos might range from one to several pages.
While special memoranda are treated as formal OIG products, they do not necessarily include formal recommendations. If formal recommendations are included, however, then full supporting documentation and archiving procedures must be followed.
Internal Memoranda
Internal memoranda provide a means of communicating within OIG. They might include reports on special visits to posts at the request of the IG, or on other matters on which the IG requests information. Internal memoranda are not intended to be vehicles for formal recommendations. If formal recommendations are needed, ISP should prepare a thematic, summary, or assessment report.
Semiannual Report
As required by the Inspector General Act of 1978, as amended, OIG prepares a semiannual report to Congress that covers the work during the period. The report documents OIG’s progress in meeting its strategic goals, and describes the activities of each of its offices. For the inspections conducted during the period, the semiannual reports contain synopses of the inspection findings. Each team prepares a summary (200 to 300 words) outlining the most important findings from the inspection.
The semiannual report may also contain synopses of other types of ISP reports, including assessment, thematic, summary, and compliance follow-up review reports.
APPENDIX 1
Acronyms
AIG Assistant Inspector General
BBG Broadcasting Board of Governors
CCS Compliance, Coordination and Support (unit)
DAIG Deputy Assistant Inspector General (for Inspections)
DIG Deputy Inspector General
DTL Deputy team leader
FQ Functional questionnaire
IG Inspector General
ISP Office of Inspections
LHQ Local hire questionnaire
OIG Office of Inspector General
PCIE President’s Council on Integrity and Efficiency
PQ Personal Questionnaire
TL Team leader
WQLQ Workplace and quality of life questionnaire
Appendix 2
Inspection Guidelines
GUIDELINES FOR INSPECTING ADMINISTRATIVE OPERATIONS
OBJECTIVE: To evaluate the efficiency and effectiveness of the administrative operation.
REFERENCES: 3 FAH, 3 FAM, 2 FAM, 6 FAM
CRITERIA
Administrative section practices and procedures are conducted effectively, efficiently, and according to Department of State and U.S. government standards.
• Personnel practices and procedures are conducted effectively, efficiently, and according to Department of State and U.S. government standards.
• Financial management operations are conducted effectively, efficiently, and according to Department of State and U.S. government standards.
• General services operations are conducted effectively, efficiently, and according to Department of State and U.S. government standards.
• Effective safety procedures are in place.
Administrative section practices and procedures are conducted effectively, efficiently, and according to Department of State and U.S. government standards.
• The MPP process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
• Management is using resources in the most effective and efficient way to achieve policy objectives.
• In addition to the general criteria set forth in Section I.B., the administrative counselor plays a central role in resource management issues and decisions throughout the mission.
• The administrative counselor places a high priority on employee development throughout the mission, and plays a lead oversight role in this area.
• Management is guarding against waste, fraud, and misappropriation of public property.
• In addition to the general criteria set forth in Section I.C., the post has designated an accountable officer to control the procurement, stock, distribution, and accountability for Form SF-1169, U.S. Government Transportation Request (GTR). (6 FAM 117.4; 6 FAM 113, Exhibit 113; 6 FAM 128.4-4)
• In addition to the general criteria set forth in Section I.B., the post has designated an accountable officer for the control and accountability of Form SF-1103, U.S. Government Bill of Lading (GBL), in accordance with 6 FAM 169 and 6 FAM 117.4.
• The administrative section has an effective service orientation that supports and promotes the functioning of ICASS.
• ICASS service standards have been set and are being monitored.
• ICASS agreements are current and signed by all parties.
• The inspected entity is making efforts to achieve cost savings under ICASS.
• ICASS council functions are helpful in improving ICASS services.
• The administrative section maintains current and appropriate duty officer materials.
• The administrative section effectively and efficiently coordinates activities among its units.
• Procurement and contracting activities are coordinated among the procurement/contracting unit, the general services office, and the financial management office, with effective arrangements for determining funds availability, monitoring, follow-up, and deobligation of unneeded funds.
• Payroll activities are coordinated both within the administrative section and throughout the mission. (Specific guidelines for the inspection of payroll activities are found in Section III.D.3.9.)
• Travel activities are managed effectively, efficiently, and in accordance with Department of State regulations.
• Travel is authorized in writing before travel begins and any travel expenses are incurred. (6 FAM 122.1)
• Upon the completion of travel, the traveler submits a voucher within seven days. Settlement of outstanding travel advances is also accomplished within seven days. (6 FAM 117.1a)
• Administrative approval of travel vouchers is completed within two working days of submission by the traveler. (6 FAM 117.1c)
• Unused tickets are turned in by travelers immediately after arrival at post. (6 FAM 117.2)
• The post requires receipts for each allowable cash expenditure in excess of $75. (6 FAM 117.3)
• If limited open authorizations are provided for employees, they contain limitations on the purpose of travel, the geographic areas that may be visited, trip costs, and the period of time in which travel is authorized, and are revalidated no less often than quarterly. (6 FAM 123.2-2, 6 FAM 123.3)
• Travel advances in conjunction with travel authorizations are issued only to employees who do not hold government travel cards, and the amount is limited to 80 percent of the out-of-pocket expenses that the employee is expected to incur. (6 FAM 124.1)
• In the absence of valid travel authorizations, before any obligation of U.S. government funds is incurred, the employee is required to execute a repayment agreement. (6 FAM 126.2-4)
• The post requires that employees make repayment for travel expenses borne by the U.S. government if the employee fails to complete the service period, or if there is a change of status that cancels the eligibility of family members for travel. (6 FAM 126.2-5)
• The post uses contract air carriers offering discount (city-pair) fares for authorized air travel between the city-pair. (6 FAM 128.3)
• U.S.-flag air carrier service is used for all U.S. government-financed commercial foreign air travel if service provided by such carriers is available. (6 FAM 135.3)
• If premium class air accommodations are used, the employee certifies on the travel voucher the reasons for their use. (6 FAM 147.2-2b)
• The post submits to A/LM no later than 30 days after the end of the fiscal year, a report of all first-class travel authorized during the fiscal year. (6 FAM 147.2-3c)
• Any deviations from the lodgings-plus per diem system are authorized in advance on the travel authorization. (6 FAM 152.2-4)
Suggested inspection techniques:
✓ Review the duty officer notebook and other materials. Determine how recently they have been updated.
✓ Review the ICASS meeting minutes and agreements.
✓ Discuss ICASS issues with the ICASS chairperson.
✓ Review the ICASS service standards for consistency with post operations. Note whether they have been created with the idea of cutting costs and streamlining activities or to reflect ongoing operations.
✓ Discuss with the administrative officer what steps have been taken to reduce ICASS costs and identify alternative service providers.
✓ Review the handling procedures for GTRs, including who has responsibility, the maintenance of logbooks, and how they are controlled.
✓ Determine which office prepares travel orders, and whether there is adequate coordination between that office and the financial management office, which will process travel vouchers.
✓ Review a few travel orders for standard wording, completeness, etc.
✓ Review the length of time required for completion of travel orders and processing of vouchers. Compare these times to the ICASS standards.
GUIDELINES FOR INSPECTING THE COMMUNITY LIAISON OFFICE
OBJECTIVE: To assess the operations of the community liaison office (CLO)
CRITERIA:
The eligibility and selection of the employee in the CLO coordinator position meet Department of State guidelines.
• The CLO coordinator is provided with the resources and support to carry out the CLO responsibilities and is performing successfully.
• The CLO program is appropriately designed to meet the needs of the inspected entity.
• There is adequate input into CLO activities.
• CLO reporting to the Department of State is up to date.
• The eligibility and selection of the employee(s) in the CLO coordinator position meet Department of State guidelines.
• The CLO coordinator occupies a sensitive PIT position and had a full Top Secret security clearance. (2 FAM 048.3b)
• The CLO coordinator is an American citizen and the family member of a U.S. government employee with a Top Secret security clearance assigned to that post. (2 FAM 048.3-1)
• There are no nepotism or conflict of interest issues associated with the employment of the individual(s) hired as CLO coordinator(s). (2 FAM 048.3-1)
• The CLO coordinator position is a renewable one-year PIT appointment. (2 FAM 048.3-2)
• The CLO coordinator is supervised by an American citizen officer (usually the administrative officer). (2 FAM 048.3-2)
• The post employment committee selected the CLO coordinator from a list of qualified candidates, and the chief of mission approved the selection. (2 FAM 048.3-3)
The CLO coordinator is provided with the resources and support to carry out the CLO responsibilities and is performing successfully.
• The CLO coordinator is included in the country team, attends administrative staff meetings, and has an advisory board.
• The CLO coordinator is a member of the emergency action committee and has a defined role in the emergency action plan, with emphasis on communication and rumor control. (2 FAM 048.4(6))
• The number of hours of the position and the budget are sufficient to perform the duties expected.
The CLO program is appropriately designed to meet the needs of the inspected entity.
• The CLO coordinator has established program objectives in line with 2 FAM 048.4 responsibilities and Department of State guidance, and is successful in achieving those objectives.
There is adequate input into CLO activities.
CLO reporting to the Department of State is up to date.
• The CLO coordinator submits quarterly CLO activity reports to DGHR/FLO. (2 FAM 048.4(4))
• The CLO coordinator contributes to the Family Member Employment Report. (2 FAM 048.4 (4))
Suggested inspection techniques:
✓ Review the files in the human resources office on the selection procedure for the current CLO coordinator (and if necessary, the previous incumbent). The file should contain original applications, notes from the meeting(s) of the post employment committee indicating how the selection was made, written approval from the chief of mission for the individual(s) selected, and copies of letters to the successful and unsuccessful candidates.
✓ Confirm the security clearance of the CLO coordinator with the RSO/PSO.
✓ Discuss with the CLO coordinator attendance at EAC, staff, and other meetings, and involvement in the post decision-making process for matters related to CLO areas.
✓ Determine if the CLO has an active advisory board, and if so, the functions of the board and how often it meets.
✓ Review recent CLO reports submitted to Washington for content, relevance, accuracy, etc.
✓ Discuss with the CLO coordinator the handling of money for various cultural and recreational activities. The CLO coordinator is not allowed to have a slush fund. (Management of funds for CLO activities is often arranged through the employee association.)
GUIDELINES FOR INSPECTING CONSULAR MANAGEMENT AND OPERATIONS
OBJECTIVE: To determine whether the consular section is an integral part of the U.S. mission, is managed and operated in compliance with the Department of State’s regulatory guidelines and U.S. government statutes, and has effective internal controls.
REFERENCES: Consular Management Handbook (CMH) (Currently being rewritten and incorporated into 7 FAM with several sections currently unavailable on line), 7 FAM, 9 FAM, 5 Foreign Affairs Handbook (FAH), Consular and Management Control Functional Questionnaires, Consular Package, AC Systems User’s Manual, Management Controls Handbook, Immigration and Nationality Act, Consular Systems Manual, Self-Instructional Guides (SIGS): Detecting Imposters. Note: because of the significant revisions currently underway, specific references have been omitted from the following guidelines.
CRITERIA:
The Mission Strategic Plan (MSP) process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
• Management is using resources in the most effective and efficient way to achieve policy objectives.
• Management is guarding against waste, fraud, and misappropriation of public property.
• The consular section is in compliance with Department of State regulatory guidelines with respect to visa operations, American citizens services, emergency preparedness, the Visas Viper program, and the consular package.
• If there are constituent posts or consular agencies, the inspected entity has implemented standard operating procedures for country-wide application of consular policies.
• Consular outreach programs, if they exist, meet the goals set by the inspected entity.
• In addition to the general criteria set forth in Section I.A., the consular section’s participation in setting and implementing mission policy and planning goals is represented in the post reporting, travel, and representational plans, as well as the MSP.
• The level of consular participation in the MSP development and implementation process is readily apparent.
• The section meets the mission’s management objectives and contributes, as necessary, to reporting in all nontraditional areas in which consular activities intersect, such as international crime, diplomatic activities, and public diplomacy.
• All consular staff, including ELOs and junior LE staff are aware of and take part in planning goals and objectives for the mission and the consular section.
• The post has either achieved the MSP goals or has established plans to accomplish these goals. Performance measures are included in the “specific objectives” area of each employee’s work requirements statement
• The consular section is involved in any demarche to the host government that deals with consular issues such as migration, children’s issues, or alien smuggling.
• The consular section is represented at all country team and emergency action committee meetings. There is consular representation at the DCM-chaired Visas Viper committee meetings and law enforcement group meetings
Management is using resources in the most effective and efficient way to achieve policy objectives.
• In addition to the general criteria set forth in Section I.B., there is an organizational chain of command.
• Consular management has a plan for alleviating any sustained reserve of untouched or incomplete work or accumulation of unprocessed materials (also known as a workload backlog).
• Shortcuts, such as form letters, merged documents, e-mail addresses, or local language documents exist to shorten the length of response time to routine queries and congressional correspondence.
• The section has an orientation plan specifically including post-specific anti-fraud training and standard operating procedures for all employees.
• Passport and visa equipment are up-to-date (modernized), and everyone is trained on the effective use of consular automation software and can operate the equipment efficiently.
• The duty officer handbook is sufficiently comprehensive concerning consular problems after hours. )
• The section has a staff development plan that includes cross training, staff job rotations, completion of the consular correspondence course and refresher training.
• Staffing is adequate or management has taken remedial action to compensate, including requesting more positions, reprogramming positions or adjusting the workload.
• There is a working internal consular rotation plan for junior officers.
• All employees have accurate position descriptions, timely performance counseling and written performance evaluations.
• Work responsibilities are evenly distributed, including the judicious management of overtime.
• The section holds regular staff meetings, not just for American employees, to set objectives including the section’s participation in nontraditional areas of the mission reporting plan, to contribute to the mission’s orientation program, and to report on section activities.
• Consular facilities, equipment, and physical layout are adequate for the consular workload.
Management is guarding against waste, fraud, and misappropriation of public property.
• In addition to the general criteria set forth in Section I.C., areas of vulnerability are assessed and opportunities for misconduct, mismanagement, and abuse are reduced or eliminated.
• Cashiering operations, particularly at the opening of business, during lunch breaks, and at the close of business, including the storage of cash during and after hours, meet FAM guidelines. (
• Reports and accountable forms logs are being reconciled.)
• Supervisors perform spot checks on internal controls and operating procedures.
• Visa and passport clearance procedures conform to law and regulations.
• Receipt procedures for gifts and gratuities are in compliance with regulations.
• Internal controls for all automated consular systems are in compliance with management handbook guidelines.
• Supervisors have appropriate physical oversight of visa and passport production areas.
• Standard operating procedures for dealing with allegations of fraud/malfeasance are in place.
• A program for regular antifraud training/orientation for new employees including staff awareness of fraudulent local documents and U.S. passports exists.
• With each change of accountable consular officer (ACO), an inventory and reconciliation of accountable property is completed.
• Consular records and files are be maintained according to guidelines.
The consular section is in compliance with Department of State regulatory guidelines with respect to visa operations, American citizens services, emergency preparedness, the Visas Viper program, and the consular package.
• The visa referral system process is explained to the mission through an administrative notice, updated annually, and complies with Bureau of Consular Affairs guidelines.
• Use of EVAF is mandatory. There are procedures to expedite student and business visas.
• The special immigrant visa program[2] is routinely administered using a process that is transparent and fair.
• The Visas Viper program is in compliance with 9 FAM 40.32.
• The consular package workload production figures and workload projections are based on systematic data collection procedures and show the efficient management of consular resources.
• Services provided to American citizens abroad, including the handling of arrests and deaths, registration of American citizens, issuance of passports, and management of federal benefits, are efficient, procedurally accurate, and customer oriented.
• The emergency warden system procedures are clearly shown in the duty handbook and the emergency action plan, and include how and under what conditions the system is activated and whether a back-up activation system is in place.
If there are constituent posts or consular agencies, the inspected entity has implemented standard operating procedures for country-wide application of consular policies.
• If applicable, consular policy throughout the host country is coordinated by the chief consul or country coordinating consular officer and oversight is provided for consular agencies. (8CMH)
Consular outreach programs, if they exist, meet the goals set by the inspected entity.
Suggested inspection techniques:
General:
✓ Early in the inspection, set up interview appointments with all American officers and senior foreign national employee unit supervisors, at 15 to 20 minute intervals. Prepare memcons or keep reference notes.
✓ MSP Process: Read the MSP, noting issues for which the consular section is responsible.
✓ Determine what goals of the MPP have been met or whether there is a planned completion date.
✓ When interviewing employees, ask about the MSP process and how they believe its implementation is progressing.
✓ Review each employee’s work requirements statement to determine if the MSP is a part of the specific objectives for each employee.
✓ Ask who attends the law enforcement group and Visas Viper committee meetings from the consular section and whether the section receives feedback.
Space Requirements:
✓ Review how the waiting room is set up. Is there counter space for completing forms? Are there clean rest rooms? Is there sufficient seating for immigrant and nonimmigrant visa customers? Is the American citizens services section clearly marked?
✓ Review accommodations for physically or mentally challenged applicants.
✓ Determine whether the section has space for confidential interviews.
✓ Review the work areas for crowded or cramped conditions. Discuss with consular staff how conditions might be improved.
✓ Are interview booths outdated?
✓ Is there room for digital photo and fingerprint equipment to do biometric visa processing?
✓ Determine whether unit chiefs have line of sight supervision of their units. If not, suggest alternatives to mitigate or eliminate vulnerabilities.
✓ Does each employee have access to a PC workstation, and is there enough space for terminals at the interview windows?
✓ Review controls for access to the consular workspace.
✓ Look for security vulnerabilities, particularly if the section is physically removed from the chancery or consulate.
✓ Discuss renovation requests or projects related to physical space.
Management:
✓ Review the time and attendance files for overtime use. Specifically ask junior officers about unreported or uncompensated overtime.
✓ Attend a staff meeting as an observer.
✓ Observe interviews in each consular unit.
✓ Review orientation materials and standard operating procedures.
✓ Determine whether supervisory foreign national employees write or contribute to the performance evaluations of subordinates.
Operations:
✓ Walk-through the consular facility as if you were: a] a visa applicant; b] an American citizen with a visa question; c] an American citizen picking up a social security check; d] a section visitor with special physical or language needs; e] anyone with a general question or f] someone returning to present additional documents to qualify for a visa.
✓ Evaluate customer service including the set up of the waiting room; signage; microphones; availability of information; accommodations for physically or mentally challenged applicants; and treatment of applicants by mission employees and other visitors.
✓ Review the handouts provided to customers. Are they responsive to frequently asked questions?
✓ Review the wait time for NIV appointments, is it excessively long?
✓ Observe public access controls to the consular waiting room(s) and nonconsular personnel’s internal access to the section’s work areas to determine if there may be problems with security or internal controls
Consular Outreach Programs:
✓ Review with the consul whether he/she gives informative speeches, publishes a consular newsletter for wardens and American visitors, or, in cooperation with the public affairs section, publicizes success in the prosecution of fraudulent document vendors or alien smugglers.
✓ Determine whether the consular section hosts warden meetings. Who attends? How often are the meetings held?
✓ Determine whether the consular section is included in the representational and travel plans.
✓ Discuss required prison visits.
GUIDELINES FOR INSPECTING ECONOMIC, COMMERCIAL AND TRADE PROMOTION ACTIVITIES
OBJECTIVE: to assess the efficiency and effectiveness of economic/commercial programs.
CRITERIA:
The MPP process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
• In addition to the general criteria set forth in Section I.A., the MPP quantitatively addresses ways the mission can attract and aid new-to-market companies or assist companies currently in the market to build market share.
Management is using resources in the most effective and efficient way to achieve policy objectives
• In addition to the general criteria set forth above, the economic and commercial functions are coordinated to be effective in carrying out the objectives of both programs.
• Officers in the section allocate their time appropriately among reporting, meetings, contacts and representation, visitors, and other tasks.
• There is a cooperative working relationship between the economic section and FCS and/or FAS offices when FCS and FAS representatives are present. When there is no FCS or FAS presence, the coordination of commercial and agricultural work within the economic section will be evaluated.
• Other sections/agencies are involved in promoting U.S. exports and business interests, when appropriate.
• In a location without FCS staff, the inspected entity uses EB and the regional bureau’s commercial coordinator for support/advice, and assistance or backstopping in developing its commercial program.
Management is guarding against waste, fraud, and misappropriation of public property.
Reporting and analysis functions are well coordinated, and reporting is serving the needs of those with responsibility for directing and conducting the foreign relations of the United States at operational and policy levels.
Contact, protocol, and representation activities are well organized and are being used effectively to advocate policies, coordinate activities, and negotiate agreements.
• In addition to the general criteria set forth above, multilateral economic organizations (World Bank, IMF, UNDP, and key NGOs, etc.) active in the host country have been identified and the inspected entity has ongoing contacts with them.
• The section’s contacts complement senior management’s contacts and support the representation plan. The section takes active steps in a planned way toward developing new, useful contacts, representative of a broad range of the relevant economic and commercial spectrum.
• Advocacy, coordination, and negotiation activities further mission goals and objectives.
The inspected entity is effectively performing functions related to trade dispute resolution and the reduction of trade barriers.
• The mission has sought to gain changes in host country legislation, implementing regulations and ground rules that are applied in the conduct of international trade so that those rules are fair and nondiscriminatory.
• The major host country trade and investment barriers that impact unfavorably on U.S. business have been identified, and appropriate actions are being taken under the MPP to reduce these impediments.
• Other factors that affect trade, e.g., corruption, lack of transparency, monopolies, parastatals, lack of capital or foreign exchange, etc., have been identified and reported and are being dealt with in an appropriate manner.
• Previously negotiated rules and agreements are being enforced.
The inspected entity is conducting effective and appropriate trade promotion activities.
• The front office provides appropriate attention to export and trade promotion.
• Senior managers have made assistance to U.S. business and the expansion of exports a priority goal.
• The chief of mission and DCM are directly involved in export promotion and have personally taken the initiative to spur host country interest in U.S. goods and services in keeping with Section 207c of the Foreign Service Act.
• The chief of mission allocates an appropriate amount of time to outreach activities.
• The chief of mission and DCM make representations on behalf of U.S. firms to the host country government to encourage the use of U.S. suppliers and to possible U.S. exporters to encourage them to enter the market.
• Commercial operations effectively support export promotion goals and objectives.
• Contributions toward the achievement of the mission’s economic and commercial objectives are well coordinated.
The resident American business community is provided with opportunities or avenues through which their views are heard and considered on foreign policy issues that affect their interest.
• Section officers know and have regular contact with the major U.S. firms represented in the host country.
• Officers regularly hold scheduled meetings with resident U.S. business people to discuss matters of commercial interest and to brief them on the current political and economic situation.
• A good sampling of U.S. business representatives is included in the Fourth of July reception, visits of Congressional delegations, and other functions as appropriate.
• Officers of the inspected entity have a close working relationship with the local American Chamber of Commerce, if any.
At non-FCS posts, the embassy and constituent posts provide assistance to American business people with well-trained and knowledgeable trade specialists.
• Foreign national employees have been trained using USDOC correspondence courses.
• Foreign national employees are creative and aggressive in support of export promotion goals. If not, action is being taken to rectify the situation.
• The inspected entity encourages and guides foreign national employees to develop contacts in government and the private sector.
• At FCS posts, the Foreign Commercial Service (FCS) will be responsible for the foreign national performance mentioned above.
Sound professional advice and analysis on the local political and business environment is provided by appropriate members of the mission and constituent posts to U.S. business representatives (both resident and visiting) in a way that also allows them easy access in a timely manner.
• Officers meet with U.S. business representatives upon request.
• Relevant unclassified material is available for distribution to interested U.S. business representatives.
• The mission offers assistance to U.S. business people who wish to meet with key public and private sector decision makers. When major and important contracts are under consideration, officers accompany U.S. business people to demonstrate USG interest and support.
• U.S. firms, when bidding on host country government contracts, are actively supported by the mission.
• When a major project is of interest to one or more U.S. companies, the chief of mission is active in showing direct support.
• The embassy provides this assistance in an evenhanded fashion when more than one U.S. firm is involved.
• The level of support is as assertive when two or more U.S. companies are bidding as it would be if only one were pursuing the project.
• U.S. companies are receiving assistance in achieving an amicable and equitable settlement of investment and trade disputes. In the case of expropriation or similar actions, direct, sufficient, and appropriate representations are being made in support of U.S. business to a degree that concerned companies receive prompt, adequate, and effective compensation.
Strategies for export and import promotion are relevant and reasonable.
• Investment promotion does not divert resources away from export promotion.
• The inspected entity has a strategy to attract new-to-market (NTM) companies, or as appropriate, new-to-export (NTE) companies.
• Time spent on reactive activities such as appointments for visiting businessmen does not limit attention to proactive activities such as supporting efforts of U.S. companies to win host country contracts.
• The chief of mission or DCM makes representations on behalf of U.S. firms to the host government to encourage the use of U.S. suppliers and to possible U.S. exporters to encourage them to enter the market.
• The economic section participates in the writing of the country commercial guide.
• If the FCS is not represented, the inspected entity receives adequate assistance from the Department of Commerce in supporting American business; communicates directly with DOC; and has made appropriate use of Business Facilitation Incentive Funds.
• Unclassified information of interest to the U.S. business community is transmitted under a KTDB tag for inclusion in the National Trade Database.
• International Marketing Insight (IMI) reports are submitted at least annually, with contributions not restricted to the commercial section.
• Staff members are monitoring the activities of multilateral development banks to identify major projects in which U.S. companies could secure contracts, and have reported on the major investment projects for which American companies might compete.
• The inspected entity supports trade promotion events, and uses appropriate means to measure the success of these events.
• If applicable, the trade information center (TIC) in the Department of Commerce has been alerted to the inspected entity’s web page.
• The TIC receives relevant economic/commercial reporting from the inspected entity.
Where applicable, participation in the international trade fair supports export promotion objectives.
• Time devoted to the international trade fair, such as for recruiting U.S. companies to participate or collecting money to finance the U.S. exhibit, is appropriate and reasonable.
• Participation in the trade fair is self-sustaining.
• The U.S. presence is a vehicle to gain markets for U.S. exports, and NTM companies are represented in the U.S. pavilion.
• Consideration has been given to whether it would be more appropriate to make the pavilion a public diplomacy activity rather than a trade promotion activity.
The Country Commercial Plan (CCP) is practical and consistent with the MPP.
• The CCP is practical in light of the host country’s market potential.
• The CCP relates to the MPP and has been used in formulating the MPP.
• If there are no FCS personnel, or if there are only FCS foreign national staff, State Department officers draft the CCP. Officers use EB and the regional bureau’s commercial coordinator for support, advice, and assistance in drafting the plan if there is no FCS staff.
Commercial library activities are well managed and effective.
• The size of the market for U.S. products justifies a commercial library.
• The number of visitors to the library justifies the number of hours it is open.
• The objective of those using the library is to find U.S. suppliers, not to find export markets in the U.S.
• The library is used to make new trade contacts and to develop lists of invitees to trade shows.
The inspected entity is effectively performing its responsibilities with regard to munitions control.
• The inspected entity has designated a “Blue Lantern” officer and has reported the name of the officer to Washington.
Suggested inspection techniques:
✓ Review the number of economic reports, including Foreign Economic trends and the annual oil report, which are sold, distributed at no cost, or posted on a web site. This is one indication of the value placed on these reports by other entities. Do other embassies, journalists, and businesspeople come to the mission for information?
✓ Determine how often embassy economic and commercial officers are used as sources or quoted by the media. How many times are the officers asked to do background briefings (either on or off the record)?
✓ Review the number of economic topic speaking engagements fulfilled by economic and commercial officers.
GUIDELINES FOR INSPECTING EMPLOYEE ASSOCIATIONS
OBJECTIVE: to assess the employee association’s adherence to Department of State regulations and general viability.
REFERENCES: 6 FAM 500
CRITERIA:
The employee association operates under a charter approved by its board of directors and the Department of State.
• The employee association has a charter approved by the Department of State. (6 FAM 512, 551)
The employee association has a functioning board of directors.
• The charter clearly describes all services provided by the association. (6 FAM 551a)
• The employee association has sent a copy of its bylaws to A/OPR/ST/CR.
The chief of mission or principal officer is fulfilling her/his responsibilities with regard to the employee association.
• The chief of mission originally determined the need for and the economic feasibility of each type of service provided by the employee association, and periodically reviews the continuing need for existing facilities. (6 FAM 521)
• The chief of mission or principal officer monitors the activities of the employee association and certifies that its operations are managed prudently and in accordance with the Department of State’s regulations. (6 FAM 522, 554). See also Section I.C.4 of the inspection guidelines.
• The chief of mission or principal officer has ensured that the employee association’s activities and facilities do not adversely affect public relations with the host country, that they do not cause financial embarrassment in the local business community, and that local customs and labor laws are not violated. (6 FAM 523)
• In determining whether any charges or fees should be assessed for U.S. government facilities and services made available to the association, the chief of mission or principal officer has taken into consideration the cost incurred by the U.S. government. The post is not unduly subsidizing the employee association. (6 FAM 524)
• The employee association is paying directly or reimbursing the post for the cost of utilities such as electric, water, telephone, and heating/cooling services. (6 FAM 524)\
• The chief of mission or principal officer has ensured that, whenever feasible, employee association facilities are located on U.S. government-held property. (6 FAM 525)
• Whenever employee association facilities are located on U.S. government-held property, the post and the association have signed a memorandum of understanding (MOU) to identify the facilities made available to the association and the types and amounts of support provided by the post. (6 FAM 525)
The employee association meets financial, insurance, bonding, and other requirements set by the Department of State.
• The employee association is maintaining financial records in accordance with U.S. generally accepted accounting principles. (6 FAM 531c)
• The chief of mission or principal officer has authorized the post financial management office to receive and hold funds of the employee association and make payments for the association. (6 FAM 531.1)
• The employee association is not investing excess money in speculative enterprises or institutions, offshore banks, or currency speculation. (6 FAM 531.2)
• The employee association has a clearly identified fund to provide for severance pay, retirement, and other benefits, as applicable, for foreign national employees. In lieu of establishing such funds, the employee association may purchase endowment policies, subscribe to a host-government provident fund, or provide some other practical and safe means to provide for these liabilities. (6 FAM 531.3)
• The employee association maintains insurance adequate to cover its assets, including public liability, fire, wind, water, and theft. These policies are reviewed on an annual basis by the association board to ensure their adequacy. (6 FAM 532)
• The employee association maintains sufficient blanket or individual bond coverage to cover all potential losses resulting from actions by association employees who handle cash or readily convertible assets, or who have authority to bind the association contractually. (6 FAM 533) If there is no bond coverage, the association has an exception from A/OPR/ST/CR, and the association and its members understand that they are accountable for all losses that would have been covered by a blanket or individual bond coverage. (6 FAM 533)
• The post and the employee association do not provide support to private American clubs or other private clubs. (6 FAM 534)
• Any charges levied by any unit of the employee association are at the same rates for all American personnel (including TDY employees) and their family members. (6 FAM 535)
• Employees of the association are extended comparable human resources benefits, where possible and consistent with local laws and practices, to those provided by the U.S. government. (6 FAM 536)
• The post administrative officer and the regional security officer have determined the extent of pre-employment suitability investigations for association employees. These are generally the same as for locally hired employees of the post. (6 FAM 537)
• The employee association is not copying or duplicating any copyrighted material (including videotapes and computer software) for the purpose of resale, rental, or providing public performances to association members or to other parties. (6 FAM 538)
• Only U.S. government employees who are American citizens resident at post and their family members over the age of 16 have voting rights in the employee association, with a majority of the voting membership being U.S. government employees. (6 FAM 539)
• The board of directors of the employee association is limited to this same group, with the proviso that a majority of the board of directors are direct-hire, American citizen, U.S. government employees. (6 FAM 539)
The inspected entity monitors the use of employee association facilities.
• Access to the purchase of packaged duty-free goods is limited to U.S. government employees as defined in 6 FAM 540.
• Opportunities for the illegal purchase and resale of duty-free imported goods to local and unauthorized third-country nationals have been eliminated. (6 FAM 541b)
• If applicable and not inconsistent with the laws and customs of the host country, the chief of mission or principal officer has approved the use of association facilities, other than the purchase of packaged duty-free goods, by foreign national employees. (6 FAM 543)
• If applicable and not inconsistent with the laws and customs of the host country, the chief of mission or principal officer has approved the use of association facilities by third-country national direct-hire and contractor personnel. (6 FAM 544)
• If applicable and not inconsistent with the laws and customs of the host country, the chief of mission or principal officer has approved the use of association facilities, other than the purchase of packaged duty-free goods, by third country diplomats. The chief of mission or principal officer’s approval is in writing and is kept on file and updated as necessary. (6 FAM 545a)
• If third-country diplomats have access to the purchase of packaged duty-free goods, the employee association and post are participating in the Commissary Support Program. (6 FAM 545b, 545.1)
• The chief of mission or principal officer, on a selective basis and in accordance with local laws and customs of the host government, grants access to recreational facilities to invited guests subject to the rules of the association and such fees as may be appropriate. If this practice is in place, the principal officer is providing the regional security officer with a list of guests on a regular basis for review. (6 FAM 546)
The employee association meets Department of State reporting requirements.
• The employee association submits timely responses to the Department of State’s annual questionnaire on association operations in the standard format. (6 FAM 553)
• The annual questionnaire contains an annual certification statement approved by the chief of mission or principal officer, and a remittance statement pertaining to the annual assessment. (6 FAM 553b)
• If there is no certification, the chief of mission or principal officer has identified which operations are not in conformance, and has provided a plan and schedule for remedying the non-conformance. (6 FAM 554b)
• The employee association has remitted an annual assessment payment to the Central Commissary and Recreation Fund in an amount based on gross revenues determined by the Central Commissary and Recreation Fund Board. (6 FAM 555)
• The employee association is meeting appropriate U.S. tax withholding requirements for U.S. citizen employees. (6 FAM 556)
• The association submits a balance sheet and income statement to its board of directors monthly. (6 FAM 557a)
• The association submits a balance sheet and income statement, certified by the board treasurer, to A/OPR/ST/CR by August 15 and May 1 of each year. (6 FAM 557a)
• The association submits an annual audit report to A/OPR/ST/CR by May 1 of each year. (6 FAM 557b)
The employee association has a sound system of management controls.
• If the annual audit report contains management control suggestions, the association has implemented these guidelines.
• The post periodically tests the association’s management controls and has found them to be satisfactory. Records of these assessments are kept on file.
• There are adequate controls on association-managed items susceptible to black marketing or pilferage, and board members conduct spot checks of such items on an irregular basis.
• The chief of mission or principal officer has designated in writing an officer to monitor the operations of the association. See Section III.L.2.2.
• Association employee duties are segregated to reduce the potential for collusion.
• The amount of cash on hand does not exceed weekly disbursements.
• Unannounced cash counts are conducted on an irregular basis by board members.
• Cash deposits are made on a daily basis.
• If the association extends credit to members, the system of collection is adequate and is working.
• The revenues of each unit of the association do not exceed expenses.
• There are controls or limits placed on the amount of liquor that can be purchased by an individual.
Suggested inspection techniques:
✓ Review the charter and bylaws. Have they been approved by A/OPR/ST/CR? Are all services provided by the association included in the charter and bylaws?
✓ Look at the most recent annual audit. Is the employee association financially viable? Are any services losing money? If so, is corrective action being taken by the association or post? If the audit included management recommendations, are these being implemented?
✓ Review the semi-annual reports. Are they being submitted in a timely manner?
✓ If there is a commissary, the inspector should review inventory records and stock control procedures. See Sections III.D.4.5 through III.D.4.8. Are inventories performed at least annually on stock? Are the inventories performed by American or foreign national staff? Using the most recent stock control records, select a sample of five to ten items in the commissary and compare the number on the shelf with the number on the stock control record/inventory.
✓ Review procedures for handling cash accepted by any association service provider. Are there sufficient controls? Is cash deposited daily with either the post or a local bank? If not, why not?
✓ If the commissary is handling items that are difficult to find on the local market or are much cheaper in the commissary (e.g., liquor), what procedures are in place to ensure adequate controls? If items being sold have been brought into the country duty free, how is the post or association ensuring that only individuals entitled to duty free privileges have access to these items?
✓ Is the chief of mission or principal officer monitoring the activities of the employee association?
✓ If the association employs American citizens, is it withholding appropriate U.S. taxes from their salary payments?
✓ Review arrangements for severance pay and retirement benefits for association foreign national personnel. Are they logical, appropriate, and sufficient?
✓ Is the insurance coverage for the association up to date? Is it sufficient for the value of the operations?
✓ Who monitors access to each of the association’s service centers (commissary, club, etc)? Are persons who are not entitled gaining access to facilities?
✓ If the association is providing any services to the mission, do its prices reflect arms-length transactions, or is the mission, through appropriated funds, subsidizing the association by paying inflated prices for association’s goods and services? Typical examples might include an association providing gasoline for official vehicles or cleaning TDY rooms and other (oftentimes U.S. government-owned or -leased) facilities. Negotiated prices with an association should be based on the association’s cost for providing the goods or services plus a reasonable (i.e. 10-15%) profit margin.
GUIDELINES FOR INSPECTING
EQUAL EMPLOYMENT OPPORTUNITY
OBJECTIVE: To assess the inspected entity’s adherence to Department of State and federal government Equal Employment Opportunity (EEO) criteria and regulations.
CRITERIA
The front office is attentive to and supports EEO matters.
• All senior officers, including the chief of mission, are aware of and provide active support to Department policy (3 FAM 1511) and the Secretary’s messages of equal employment opportunity and diversity.
• The EEO counselors and the FWP coordinator have access to top management, and they are encouraged to use it for discussion of EEO and related matters.
• Whenever policies and practices are considered or implemented that might have special impact on minority or female employees, the EEO counselors and the FWP coordinator are consulted.
• The chief of mission had discussed EEO and fairness policies and issues at a country team meeting within the past six months.
• The inspected entity has established either a formal or informal EEO program for locally hired employees (foreign national and American) with the support of the front office.
• The inspected entity regularly reminds American and foreign national supervisors of their responsibilities for fair treatment of locally hired American and foreign national personnel.
The inspected entity is in compliance with Department of State policy on EEO and FWP issues.
• All supervisors of American personnel have met the Department of State’s EEO training requirements.
• The chief of mission has designated and publicized the designation of one or more EEO counselors and has reported the names to the Department of State (S/EEOCR). (3 FAM 1514.2a)
• The chief of mission has designated and publicized the designation of an FWP coordinator, depending on the size of the mission (at least six American female employees). The name of the FWP coordinator has been reported to the Department of State (S/EEOCR). (3 FAM 1514.2a)
• These counselors and coordinators are aware of their responsibilities for receiving and attempting to resolve, on an informal basis, any matter of alleged discrimination. (3 FAM 1514.2b)
• The inspected entity makes written materials available to all employees and applicants informing them of the variety EEO programs and administrative and judicial remedial procedures available to them, and prominently posts such written materials throughout the workplace. (29 CFR 1614.102(b)(4))
• Full cooperation is provided by all agency employees to EEO counselors in the processing and resolution of precomplaint matters and complaints. (29 CFR 1614.102(b) (5))
• The inspected entity has publicized to all employees and posted at all times the names of the EEO counselors and the FWP coordinator, and a notice of the time limits and necessity of contacting a counselor before filing a complaint. These materials are kept current. (29 CFR 1614.102(b)(6))
• The inspected entity conducts precomplaint counseling in accordance with 29 CRF 1614.105.
• The inspected entity is making reasonable efforts to settle voluntarily complaints of discrimination as early as possible in, and throughout, the administrative processing of complaints, including the precomplaint counseling stage. Any settlement reached is put in writing and signed by both parties and identifies the allegations resolved. (29 CFR 1614.603)
• Complainants who are employees are allowed a reasonable amount of official time, if otherwise on duty, to prepare the complaint and to respond to requests for information. (29 CFR 1614.605)
• EEO counselors and the FWP coordinator at the inspected entity have received updated EEO and FWP program materials.
• The administrative office maintains a permanent set of EEO and FWP program materials.
The inspected entity has integrated women and minorities into post committees, representational functions, etc.
• When appropriate, minorities and/or women sit on post or unit performance evaluation review panels, family member employment committees, and other committees that affect human resources issues.
• Minorities and/or women are integrated into representational social functions under the same standards as nonminority and/or male personnel.
Procedures involving training, assignment of responsibilities, disciplinary measures, evaluations, etc., are fair and equitable.
• The use of language that excludes women is avoided in post communications, such as the use of only the male pronoun when reference is not to males only.
• Evaluation review panels challenge inadmissible comments in performance evaluations.
• Discriminatory measures are applied fairly and appropriately, without discrimination for or against minorities and women.
• The inspected entity encourages women and minorities to apply for training and grants requests for training submitted by these persons as frequently as it does requests submitted by nonminority male employees.
Suggested inspection techniques:
✓ Meet with the EEO counselor(s) and the FWP coordinator to discuss issues that have been brought to their attention. Ask the counselors what materials they have been given to carry out their functions. Discuss the role of the front office.
✓ Review cables to the posts that note any American officers who have not taken the Department of State’s EEO training.
✓ Observe the posting of EEO information, which is normally on a bulletin board in an easily accessible location.
✓ Review the set of EEO and FWP materials in the administrative office to determine if it is up to date.
✓ Physically review administrative notices and other written documents that have been distributed to Americans at post regarding EEO and FWP issues. These should be reissued at least annually.
✓ Review written materials the post has distributed to remind American and foreign national supervisors of their responsibilities for the fair treatment of locally hired personnel.
✓ Determine whether the post has conducted any training sessions for foreign national supervisors regarding appropriate treatment of all staff, particularly for male supervisors of female employees. (These are not required, but may be helpful in some countries.)
✓ Discuss with employees whether they have concerns or complaints about their treatment.
GUIDELINES FOR INSPECTING EXECUTIVE DIRECTION (FRONT OFFICE)
OBJECTIVE: To assess the leadership, management, and policy direction of the front office.
CRITERIA
• The MPP process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
• Management is using resources in the most effective and efficient way to achieve policy objectives.
• Management is guarding against waste, fraud, and misappropriation of public property.
• Reporting and analysis functions are well coordinated, and reporting is serving the needs of those with responsibility for directing and conducting the foreign relations of the United States at operational and policy levels.
• Contact, protocol, and representational activities are well organized and are being used effectively to advocate policies, coordinate activities, and negotiate agreements.
• Advocacy, coordination, and negotiation activities further mission goals and objectives.
Country team and interagency relations are collegial and professional, and are conducive to the achievement of U.S. foreign policy goals.
• Senior managers play an effective role in the ICASS process.
• Senior managers convey to their staff the importance of good relations among all agencies at post.
• Heads of other agencies are supporting MPP goals.
• Law enforcement and narcotics programs are well coordinated.
• Senior managers are briefed on activities occurring in country.
• If there are multiple law enforcement and/or narcotics agencies at post, senior management is effective in coordinating their activities.
• Senior managers are effective in resolving conflicts, if any, between the conduct of foreign policy, and law enforcement and narcotics operations.
• Senior management meets as required with heads of agencies to review and ensure that activities are well coordinated.
• Senior managers are effective in their oversight of intelligence activities.
Senior managers have in place and exercise appropriate leadership to develop, decide, communicate, and implement foreign policy decisions
• Senior managers are knowledgeable of post operations and post personnel.
• Senior managers are knowledgeable of U.S. policy issues.
Policies, programs, operations, and other activities carried out by the mission are effective in promoting U.S. strategic goals
Senior managers exercise the executive and program skills and authorities necessary to ensure effective and efficient operation of resources and activities in support of U.S. strategic goals.
Senior managers set high ethical standards of conduct, including prompt payment of personal financial obligations incurred, and restriction of the demand for personal services (notably from the GSO).
• Senior managers provide feedback to employees, and are accessible to employees who desire further guidance.
• Senior managers are able to delegate effectively, to prioritize, to apportion time, and to communicate requirements.
• Senior managers are tolerant of the needs of staff and are judicious in monitoring overtime demands, leave policies (written or unwritten), and family concerns.
• Senior managers are perceptive and sensible in relating to others.
• Senior managers are aware of the importance of evaluations and onward assignments to Foreign Service officers, and take effective steps to assist officers in these areas.
NSDD-38 procedures are conducted appropriately.
• The approval of the chief of mission is obtained for any proposed changes in the size, composition, or mandate of agencies with staffs operating under the authority of the COM.
• Approvals are not granted until the COM has determined that the mission can absorb the additional workload or can obtain additional resources.
• The inspected entity has a junior officer program that is effective in promoting the experience, training, and interests of junior officers.
• Junior officers receive adequate guidance and attention from supervisors and the DCM. (3 FAM 2216.2)
• Performance evaluations are prepared in a timely manner for rotational junior officers.
• Rating and reviewing officers are evaluated based on supervision and guidance provided to junior officers.
• Junior officers are involved and included in country team meetings, reporting, representation, travel, and training.
The inspected entity is constructively involved in the operations of constituent posts and provides resources in an equitable manner.
• Officers and foreign national staff from the embassy make frequent visits to the constituent posts for oversight, counseling, and assistance.
• Staff from the constituent posts makes frequent visits to the embassy for training and counseling.
• Resources are equitably distributed among all functions of all posts.
• Constituent posts receive clear information on how resources are allocated and are given the information in a timely manner for planning purposes.
• The embassy communicates full and clear information to constituent posts on the provision of ICASS services.
• Oversight by the embassy is neither too little nor too much – constituent posts are allowed sufficient freedom to conduct operations in an effective manner in the section of the host country in which they are located.
• Constituent posts support embassy activities related to the host country government.
Appropriate attention is given to security and emergency preparedness.
• Appropriate attention is given to the morale of the official American community.
• The official visitor workload is well managed.
Suggested inspection techniques:
✓ Discuss with front office personnel and country team members the coordination of mission operations.
✓ Determine how knowledgeable the chief of mission and DCM or principal officer are regarding operations and issues for each embassy section and each agency.
✓ Determine how frequently senior management visit individual sections or agencies. Discuss with section and agency leadership the accessibility of senior management and the guidance provided by senior management in conducting their operations.
✓ Review how the NSDD-38 process is managed and who reviews the outgoing cables. How is senior management assessing the additional workload that new staff might create?
✓ Meet with junior officers as a group, if time permits, to discuss their experiences and concerns. Review the evaluations written for junior officers. Determine whether all junior officers have up-to-date work requirements statements and whether the DCM is designated as the reviewing officer.
✓ If there are constituent posts, discuss with all parties the effectiveness of communication. How much oversight is provided to the constituent posts? How are resources distributed?
GUIDELINES FOR INSPECTING FINANCIAL MANAGEMENT OPERATIONS
OBJECTIVE: To evaluate the efficiency and effectiveness of the financial management operation.
REFERENCES: 4 FAM, 4 FAH, STR 300, STR 400
CRITERIA
The MPP process (or replacement process) is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
Management is using resources in the most effective and efficient way to achieve policy objectives.
Management is guarding against waste, fraud, and misappropriation of public property.
Department of State procedures with respect to cashiering services are followed. Cashier operations are properly conducted and accounts are properly maintained and reported.
• The class B cashier and alternate class B cashier are officially designated (4 FAH-3 H-392h, j)
• The financial management officer or cashier’s supervisor is correctly conducting monthly unannounced cash verifications and audits of the cashier’s funds and records (4 FAH-3 H-393.3-2).
• Subcashiers are officially designated. (4 FAH-3 H-397.2-1)
• The subcashier supervisor is correctly conducting monthly unannounced verifications of the subcashier’s funds. (4 FAH-3 H-397.2-3)
• Cash payments made by cashiers and subcashiers are not in excess of $500 or equivalent, except in emergencies. (4 FAH-3 H-394.2)
• The class B cashier and subcashiers safeguard the funds entrusted to them.
• The inspected entity has established procedures for approving the exchange of local currency for U.S. dollars from the sale of automobiles and personal property for personnel departing post.
• Money collected by the consular subcashier is turned over daily to the class B cashier. (4 FAH-3 H-321.3c)
• Employees designated to handle funds are safeguarding them. (4 FAH-3 H-317)
• The inspected entity conducts a quarterly review of suspense deposits abroad (SDA) account balances to determine if there are unclaimed balances that may be refunded to the depositor. (4 FAH-3 H-322.2-6)
• The inspected entity is using the SDA account only for the purposes authorized.
• The amount of the cashier advance is appropriate. (4 FAH-3 H-393)
• The inspected organization has arranged adequate security to protect the cashier when the cashier makes trips to the bank to cash replenishment checks or to deposit collections, or the post has arranged with a local bank for the transport of funds. (4 FAH-3 H-393.4-6)
The inspected organization is following Department of State procedures for maintaining and monitoring post accounts through the obligation and liquidation process. Financial transactions and accounts are properly conducted, maintained, and reported. Financial resources are managed effectively and in accordance with Department of State procedures.
• There are no large unjustified liquidated balances of prior year funds, overliquidations, and large year-end spending (July through September).
• The inspected entity adjusts differences in the amount obligated and the actual payments in accordance with Department of State procedures. (4 FAH-3 H-052.2a)
• The inspected organization prepares financial plans for its various allotments with justifications for the data.
• The inspected entity uses, accounts for, and reports public diplomacy funds, including representation and grants in accordance with Department of State standards.
• The inspected entity collects, documents, and uses proceeds of sale in accordance with Department of State standards. (4 FAH-3 H-323.2)
The inspected organization is following Department of State procedures for processing payments for goods and services and employee claims. Vouchers are prepared and processed legally, accurately, and properly.
• The inspected entity has implemented separation of duties. (4 FAH-3 H-416.3-4b)
• An invoice is required before processing payment to a vendor or contractor. (4 FAM 422a)
• The designated billing office dates (stamped or otherwise annotated) invoices upon receipt. (4 FAH-3 H-422.2)
• The inspected entity makes payment on original invoices only. (4 FAH-3 H-422.6)
• Funds are obligated in advance of a procurement.(4 FAH-3 H-433)
• Payments are made only when authorized by a certifying officer. (4 FAM 432a)
• The inspected entity makes payments in a timely manner, thereby avoiding late payment penalties. (4 FAM 434c)
The inspected organization is following Department of State procedures for use of representational funds and for assessing and reimbursing official residence expenses (ORE).
• The inspected entity expends representational funds in accordance with standard regulations. (STR 320)
• Representational events have the proper mix between U.S. presence and others. (STR 320).
• Applicable employees properly contribute five percent of their gross annual salary for ORE expenses. (STR 440)
• The inspected entity charges applicable expenses to the ORE account (STR 454).
The inspected organization is following Department of State procedures in administering the allowance program.
• Allowances paid are valid and authorized by the employing agency.
• The inspected entity uses the Standard Form 1190 Foreign Allowances Application, Grant, and Report (or other procedure where applicable) for requesting (commencement or termination), granting, and paying allowances. (STR 073.4)
The inspected organization maintains payroll operations in accordance with Department of State procedures. Leave and attendance records are properly maintained.
• The inspected entity segregates key duties and responsibilities in authorizing, processing, recording, and reviewing transactions. (4 FAM 511b)
• Only authorized staff has the ability to transact or access data. (4 FAM 511b)
• Time and attendance processes are correctly administered for reporting hours worked, overtime, holiday pay, compensatory time, and differentials. (3 FAM 3131-3143, 3 FAH-1 H-3130, 3 FAM 7352)
• The inspected entity has procedures in place to ensure that the timekeeping function is carried out effectively and accurately. (4 FAH-3 H 519.3-5)
• Authorizing officials approve overtime before it is taken. (4 FAH-3 H-523.2)
• The inspected entity maintains complete, accurate, and proper documentation of time and attendance data, leave, and premium pay. (4 FAH-3 H-523.3)
• Supervisors approve leave for the employees for whom they are responsible prior to being taken. (4 FAH-3 H-525.2-4)
Suggested inspection techniques:
Cashiering:
✓ Observe a cash verification by the class B cashier supervisor. Note whether the supervisor seems familiar with the process. Check delays of items in transit, extra cash in the cashier’s drawer or safe, etc. Observe the organization of the cashier’s records, and the ease with which he or she can locate documents.
✓ Determine who has access to the cashier’s safe or drawer and how often the combination is changed.
✓ Observe the security of the cashier operations, including whether the cashier has a locked room/area in which to operate. Observe who has access to the cashier area when the safe is open.
✓ Review the records of verifications for subcashiers, which should be maintained by the class B cashier.
✓ Review the records for consular receipts, including the frequency of deposits. Have the cashier and the consular subcashier arranged a set time each day for the deposits?
✓ Determine how cash is transported to the bank and whether this is done by the inspected entity or the bank.
✓ Look at the records for cash operations, including who is receiving the cash, and whether receipts are being returned within 24 hours for the payment of goods or services. Determine whether cash is being picked up by unauthorized persons (such as drivers).
Time and Attendance:
✓ Walk through the time and attendance procedures with the staff performing this function. Select a random pay period during the last year and, for a sample of employees, compare the information on the time cards with that on the consolidated sheet. Review time cards to determine if they are being signed by the supervisor. For overtime, look for prior supervisory approval. Check the timekeeper’s determination of which hours should be considered overtime, Sunday differential, etc.
Funds Management:
✓ Review status of funds and status of obligations reports to ensure that unneeded funds have been deobligated and to identify unliquidated obligations. Look for large open balances of prior year funds and, if such exist, determine the reasons. Look for large obligations during the last quarter of the fiscal year and, if such exist, determine the validity of year-end spending.
✓ Trace the payment procedures for a random sample of five to ten invoices. Note the date the invoice was received by the financial management office, the approval process for payment, and the length of time required to effect payment.
✓ Review the plans for the use of discretionary ICASS and program funds. Is there an organized process, or is spending based on day-to-day demands? Have offices been asked for “wish lists” and are these kept on file for use when funds become available?
✓ If an FSN certifies vouchers, review a sample of his/her certifications. Were the vouchers within the FSN’s monetary limit and adequately supported? Does the FMO review FSN certifications regularly and maintain records of these reviews?
✓ Select a sample of non-post held allotments (such as those for School Grants, INL contracts or other bureau-funded grants or contacts) and ensure that adequate supporting documentation exists.
Travel vouchers:
✓ Review the procedures to identify, track and redeem unused airline tickets.
✓ Obtain copies of airline or travel management center invoices for the last year. Select a sample of the plant ticket charges and ensure that the charges were traced back to the individual traveler’s obligation in RFMS and charged to the same strip code. Ask the office what they do if they cannot trace the charge back to a traveler’s obligation.
✓ Ask the office to identify, on the airline or travel management center invoices, all premium class airline tickets. Trace a sample of the highest cost tickets back to travel authorizations supported with either a letter from M or a DS-4087.
✓ Review a sample of travel vouchers. Note whether travelers are completing the vouchers correctly and whether required documentation is attached.
✓ Observe whether travelers are using travel cards.
Disposal of Official Property:
✓ Review the procedures connected to sale of government property by the GSO, including the handling, documentation, and use of funds collected. The office should maintain files for each sale.
General:
✓ Determine which funds are in SDA accounts, the purposes of the funds, how long they have been held, and whether the post should clear the accounts.
✓ Look at the representation and ORE vouchers for information on the use of the funds, and whether this use is according to Department of State standards. Ensure that required documentation is attached.
✓ Review the automated systems used by the financial management office and note which ones are working well and which may be handicapping staff in the completion of their duties.
✓ Review ICASS standards for financial management services and spot check the services to determine whether these standards are met.
✓ Observe the operations of the financial management section to ensure that key duties such as authorizing, approving, performing, processing, recording, and reviewing transactions are assigned to different individuals or that compensating controls exist.
GUIDELINES FOR INSPECTING GENERAL SERVICES OPERATIONS
OBJECTIVE: To evaluate the efficiency and effectiveness of the general services operation.
REFERENCES: 14 FAM, 14 FAH
CRITERIA
Resources are used in effectively and efficiently to achieve policy objectives.
Management is guarding against waste, fraud, abuse and misappropriation of property.
• Acquisition and procurement procedures are conducted according to laws and regulations.
• Department procedures are followed in receiving property.
• Department procedures are followed in managing personal property.
• The warehouse program is efficient and economical with written procedures for handling and storing property.
• Physical inventory and reconciliation procedures meet Department standards.
• The inspected entity meets Department personal property reporting requirements.
• Appropriate procedures are used to manage expendable property.
• Internal requisitioning procedures meet Department standards.
• Property disposal procedures meet Department standards.
• The inspected entity controls official vehicles and fuel usage.
• The official vehicle fleet and usage meet Department standards.
• The management of real property meets Department requirements.
• Funding responsibilities for agencies occupying U.S. government held property are managed according to Department guidelines.
• Reporting and record-keeping responsibilities for U.S. government owned and leased property are managed according to Department guidelines.
• The interagency housing board functions in accordance with Department guidelines.
• The mission’ housing profile meets OBO guidelines.
• U.S. government-owned real property is maintained and improved efficiently in accordance with Department standards.
• Marine Security Guard quarters are managed in accordance with the agreement between the Department and the U.S. Marine Corps.
• Furniture, furnishings, appliances, and equipment are provided and maintained according to Department requirements.
• Shipping and transportation activities are managed effectively, efficiently, in accordance with Department requirements.
• The general services office is monitoring performance against the ICASS standards and is taking steps to improve performance.
• Acquisition and procurement procedures are conducted appropriately.
✓ Contracting officer(s) have warrants specifying the individual’s authority (time and dollar threshold). (14 FAM 214)
✓ The inspected entity has an annual acquisition plan, and acquisition planning occurs concurrently with budget planning. (14 6 FAM 232)
✓ The inspected organization has access to and is using:
✓ Overseas Contracting and Simplified Acquisitions Handbook
✓ Federal Acquisition Regulation
✓ Department of State Acquisition Regulation
✓ Bureau of Administration’s Office of Procurement Executive procurement information bulletins and directives
✓ U.S. General Services Administrations’s supply catalogues and federal supply schedules
• The procurement unit has access to electronic commerce.
• The inspected entity is using the government-wide commercial purchase card program to the extent possible, and has decreased the use of blanket purchase agreements accordingly.
• The contracting officer(s) promote and provide for full and open competition in soliciting offers and awarding contracts. (14 FAM 212, 213)
• The inspected organization obtains Department approval for procurement actions with other than full and open competition (that may cite standardization of technical equipment as justification to restrict competition). (14 FAM 212)
• Simplified acquisition procedures are being used for the procurement of supplies, services, and construction costing $50,000 or less.
• Blanket Purchase Agreements have been established in accordance with applicable federal and Department regulations. The inspected entity tracks their usage, amount of funds obligated, and conducts an annual internal review to ensure that authorized procedures are being followed.
• The inspected entity does not pay for goods or services delivered in the absence of a legal contract until the unauthorized commitment is ratified by the Procurement Executive.
• The inspected organization submits quarterly procurement data through the worldwide procurement database to the Office of the Procurement Executive. (14 FAM 222)
• Contract files are maintained in accordance with the Overseas Procurement and Contracting Handbook. All relevant documentation is included in the contract file.
• The inspected entity practices full and comprehensive contract administration, including monitoring technical performance and deliverables under the terms of the contract and control of government property. (14 FAM 220)
• Upon completion of a contract, the contracting officer verifies that all work has been completed, obtains the contraction officer representative’s assessment of the contractor’s performance, conducts a review to determine if funds should be deobligated, obtains a release of claims from the contractor, verifies that all relevant documentation is in the contract file, sends a final payment memorandum to the financial management office, and closes the files in accordance with the schedule in FAR 4.805. (DOSAR 604.804-70)
Department procedures are followed for receiving property.
• The inspected entity has designated in writing an employee to serve as receiving clerk. (14 FAM 413.1)
• Receiving activities are centralized, and there are written operating procedures that are followed when items are received at other areas. (14 FAM 413.2)
• The receiving clerk physically inspects and accepts property, and compares property received with the terms and specifications of the acquisition document. (14 FAM 413.3)
• Property numbers and serial numbers are recorded on the acquisition document. (14 FAM 413.5)
• Receiving reports are prepared in English with costs indicated in U.S. currency. (14 FAM 413.5)
• Damages or discrepancies are noted on the receiving document, and prompt action is taken. (14 FAM 413.5-6)
• If the non-expendable supply application is used, bar code labels with property numbers are attached in standard locations before the property is moved from the receiving area. (14 FAM 413.5)
• Department procedures are followed in managing personal property.
Agencies receiving property management support are specified in the ICASS agreement.
• Property management responsibilities are included in the job and work requirements of employees involved in these functions.
• The inspected entity has appropriate separation of duties.
• The property management officer (PMO), accountable property officer (APO), and property disposal officer (PDO) are designated in writing. (14 FAM 411.2)
• In the absence of desired separation of duties, the accountable property officer conducts reviews at least semi-annually to ensure that no single individual can control all aspects of any transaction affecting the receipt, storage, or disposition of expendable and nonexpendable personal property. (14 FAM 411.3)
• The accountable property officer conducts periodic, unannounced spot counts of expendable and nonexpendable property to verify property records and reconciles discrepancies found.
• The inspected entity maintains cost data for repair of property with an acquisition cost in excess of $25,000.
• The inspected organization has established maximum and minimum stock levels for expendable and non-expendable property and tracks these numbers on stock records. Replenishment orders are made in a timely manner.
The inspected entity has efficient and economical warehousing with written procedures for handling and storage of property.
• Property records are maintained on all non-expendable property with an acquisition cost of $1000 or more; on all serially-numbered equipment with an acquisition cost of $100 or more; on all property being held in the warehouse regardless of acquisition cost; on all residential furniture and equipment. (14 FAM 414)
• The inspected entity is maintaining property records using the non-expendable property application, the stock control system for expendable supplies, or a card system in compliance with Department requirements. (14 FAM 413.3)
• The inspected entity documents the issuance of specialty personal property to an employee for the individual’s exclusive use in the performance of official duties.
• Property belonging to different agencies is properly marked by agency. (14 FAM 413.7)
Physical inventory and reconciliation procedures are performed to meet Department requirements.
• A physical inventory of all non-residential personal property and supplies is taken annually and reconciled with the property records. (14 FAM 416) Inventory reconciliation procedures include action to resolve discrepancies between the physical inventory count and the property record balances.
• The individual responsible for property records maintenance does not participate in the physical inventory count.
• Complete physical inventory and reconciliation files are kept in the property office for three complete fiscal years. These files include physical inventory worksheets and spreadsheets, copies of OF-127 forms covering inventory overages, copies of OF-132 forms covering inventory shortages, inventory log sheets (FS-587), and copies of the certificates of inventory reconciliation. In addition, if NEPA is used, the files include copies of the comprehensive report, the visual report, the inventory coverage report, the missing property report, and the automatic adjustment report.
• A separate inventory file is maintained for each residence until the resident departs and is then placed in the inactive files.
• Physical inventories of residential furniture, furnishings, and equipment are taken at the time of change of occupancy and immediately reconciled with the residential custodial file.
• Residential inventories are signed by all parties participating in the count. Signed documents for all subsequent transactions are maintained in the inventory file for each residence.
• Inventory overages are documented and recorded in the property records.
• Inventory shortages involving missing, damaged, or destroyed property are recorded on OF-132, Property Disposal Authorization and Survey Report, and recorded in the property records. (14 FAM 416.5)
• If the acquisition cost of lost or damaged property is under $1000 per item, the PMO makes a determination of employee liability, determines the corrective actions necessary, and authorizes adjustment of inventory records.
• All cases of missing property contested by an employee, for which theft is suspected (regardless of cost), which result from civil disturbance or acts of God, or involving property with an acquisition cost of $1000 or more, are referred to the property survey board.
• The property survey board is constituted and takes action according to Department guidelines. (14 FAM 416.5)
The inspected entity meets Department reporting requirements for personal property.
• The property management report form (FS-582) is submitted by November 1 of each year, signed by the accountable property officer. (14 FAM 419)
Appropriate procedures are in place for managing expendable property.
• Inventory records are maintained on all expendable property in stock including bulk fuels, vehicle repair parts and supplies, medical supplies and drugs, and maintenance parts and supplies. (14 FAM 414)\
• Records are periodically reviewed to identify slow moving and obsolete supplies, and these items are eliminated from stock holdings. (14 FAH-1 H-414)
Internal requisitioning procedures meet Department requirements.
• Requisitions, signed by an authorized employee, are used to request property; to return property to stock; and to debit or credit stock control and property accountability records. (14 FAM 416)
• The accountable property officer approves all requests for items issued from stock and for procurement actions, except that the facilities maintenance officer can approve requests for maintenance spare parts. (14 FAM 416)
• Residents sign requests for residential personal property and sign for receipt of such property.
• Employees receiving office property sign for the receipt of property delivered to that location.
• Copies of completed requisitions are maintained on file to support stock control and property accountability records.
• Property is not removed from a U.S. government building without authorization by the accountable property officer or a designated employee, with documents verifying the individual removing the property and with a description of the property.
Property disposal procedures meet Department requirements.
• All property disposal actions are documented on OF-132 and subjected to a formal disposal process. (14 FAM 417.3)
• The inspected entity is using one or more of the six acceptable methods of property disposal: redistribution to establishments within the parent agency, transfer to another agency or recreation association, sale/exchange, donation, abandonment/destruction, and (for USAID property) grant-in-aid or project contribution. (14 FAM 417.3-4)
• Sales are sealed bid, spot bid, auction, or negotiated, and except in unusual circumstances, all sales are advertised. (14 FAM 417.3-3)
• The post disposal officer is a witness to key disposal activities on the sale day.
• For sales involving sealed bids, appropriate procedures are taken to secure the bids until the announced bid opening time.
The inspected entity has established procedures for the control of official vehicles and fuel.
• Motor pool vehicles are maintained at a central point during office hours and dispatched for each trip. (14 FAM 418.6)
• The OF-108, Daily Vehicle Usage Record, is maintained for all official vehicles, including those assigned to employees or offices for various purposes.
• Strict controls have been placed on the distribution of fuel or fuel coupons, and a record is made of all vehicles and persons having access to the fuel and coupons.
• Accountability, use, and maintenance records, including records of fuels and lubricants used, are being kept for all official vehicles, are on file, and are regularly monitored for effective fleet management and internal control purposes. (14 FAM 418.7)
The official vehicle fleet and its usage meet Department requirements.
• The size and composition of the official vehicle fleet is appropriate. (14 FAM 418) The mission conducts annual reviews of fleet use and composition to ensure vehicles are assigned and used properly.
• The vehicle inventory is accurate and includes all official vehicles.
• All operators of official vehicles possess valid driver’s documents.
• The chief of mission has prescribed country wide policies for business and other authorized use of vehicles, which are set forth in a current vehicle policy memorandum. Vehicles assigned for exclusive use are clearly identified and meet the guidelines of 14 FAM 418.3-1.
• Other authorized use” of official vehicles is clearly defined and charges are being collected for all “other authorized use” purposes, except those specified in 14 FAM 418.2-4.
• The rate established for authorized, non-business use of official vehicles is appropriate.
• The rate charged for home-to-office transportation does not exceed $2.70 per person per one-way trip.
• Adequate liability insurance coverage has been obtained, particularly for other than business usage of official vehicles.
• Accidents involving official vehicles are reported in accordance with requirements.
• An OF-132 for is completed and submitted to the Department for vehicles lost, stolen, or damaged beyond repair, after survey action has been completed. (14 FAM 418.5)
• Vehicles that are replaced are disposed of promptly (within six weeks) and proceeds handled in accordance with Department guidance.
• Acquisition of vehicles is in accordance with Department guidance.
•
The management of real property meets Department requirements.
• The chief of mission has designated a single real property manager to be responsible for the implementation of policies and procedures of the real property program. (15 FAM 240 et.al.)
• The real property manager is a nonvoting, ex officio member of the interagency housing board. (15 FAM)
• The single real property manager has issued a housing guide that is current and is in accordance with relevant policies, procedures, and regulations. (15 FAM 110, 120, 140, 170, 240, 720)
• Prior Office of Building Operations approval is obtained for leases that exceed $25,000 annually, and/or are not within the approved housing profile, and/or are not within the space standards, and/or require advance payments exceeding 12 months, and/or involve offshore payments, and/or involve substantial alteration to leased premises, and/or contain nonstandard clauses, and/or involve a time period between lease execution and occupancy exceeding three months, and/or for other circumstances described in 15 FAM OBO.
Funding responsibilities for agencies occupying U.S. government held property are managed according to Department requirements.
• Costs for leases, building operating expenses, improvements, and other activities associated with real property are funded according to 15 FAM OBO 210
• No more than $5000 per residence from D&CP funds is expended to prepare leased property for occupancy by Department employees. For all other agencies, the occupying agency pays make-ready expenses. Justification and accounting documentation are contained in lease files. (15 FAM OBO 210)
• The costs of utilities for U.S. government-held residences are carefully controlled and held to reasonable levels. (15 FAM)
Reporting and record keeping responsibilities for U.S. government held property are managed according to Department requirements.
• The inspected entity is using the automated real estate management system and submitting quarterly reports to the Office of Building Operations. (15 FAM )
• The property manager prepares an annual certification to the chief of mission that all housing acquired and/or assigned during the fiscal year complies with all regulations, procedures, and policies. (15 FAM )
• The chief of mission certifies annually that the housing program complies with 15 FAM, noting any deviations from established policies and procedures, and indicating what actions will be undertaken to correct them.
The interagency housing board functions in accordance with Department guidelines.
• The inspected entity has established an interagency housing board (IAHB), representing all U.G. government agencies at post. (15 FAM 720)
• The allocation of residential space is in accordance with Department regulations. (15 FAM 720)
• The inspected entity maintains written records of IAHB meetings, including justifications for decisions.
• An annual housing market survey is conducted.
The inspected entity has established a housing profile that meets Office of Building Operations requirements.
• Except for locations with Local Quarters Allowance programs and for a few other situations, the inspected entity has a housing profile that has been approved by the Office of Building Operations. (15 FAM 720)
• With or without a housing profile, short-term leased housing reflects Office of Building Operations space standards and housing requirements.
• Where possible, residential leases are for period of five years or more.
The maintenance and improvement of U.S. government real property is managed efficiently in accordance with Department requirements.
• The inspected entity has established and implemented a comprehensive preventive, routine, and special maintenance program covering all facilities and major support systems using the Office of Building Operations’ facility maintenance handbook.
• The inspected organization surveys and inspects each building and its support systems annually documenting and maintaining on file the findings.
• The inspected entity prepares an annual inspection summary report and uses it to substantiate budget requests for routine and special maintenance funding.
• The single real property manager determines that work is necessary, clears proposed special work and minor improvement projects before work commences. For work in short term leased properties, the property manager obtains approval and funding from the regional bureau and written permission from the landlord.
• Memoranda of understanding between tenant agencies and the Department have been completed and signed.
• The chief of mission ensures that construction, renovation, or upgrade work covered by a memorandum of understanding is not undertaken without Department approval.
• Construction security plans are prepared for construction projects occurring at facilities used for the storage of classified materials or the conduct of classified activities. These plans are approved by the regional security officer and forwarded to the Bureau of Diplomatic Security.
Marine Security Guard quarters are managed in accordance with the agreement between the Department and the U.S. Marine Corps.
• Marine Security Guard housing meets the guidelines set forth in 15 FAM 110 OBO.
• The quarters for MSG watchstanders are furnished in accordance with the Memorandum of Understanding between the Department and the U.S. Marine Corps.
• The inspected entity provides most custodial and maintenance and repair activities for Marine Security Guard residential quarters that are not otherwise covered in lease agreements, including maintenance of air conditioning systems, performance of repairs due to fair wear and tear, and performing yard work and seasonal care of walks, driveways, and swimming pools. The detachment is responsible for daily housekeeping and maintenance of the quarters.
Furniture, furnishings, appliances, and equipment for residences and office space are funded, provided, and maintained according to Department directions.
• The inspected entity funds furnishings etc., in accordance with 15 FAM requirements and does not provide furnishings for household staff.
• Annual inventories of all U.S. government owned property in certain representational residences are submitted to the Office of Building Operations, including furniture and furnishings, representational items, and antique/high value items.
• The inspected entity and the chief of mission follow the exact instructions of the insurer and the Office of Building Operations regarding the care, handling, and safekeeping of Art in Embassies artwork. (15 FAM 790)
Shipping and transportation activities are managed effectively, efficiently, and in accordance with Department requirements.
• If the inspected entity has a consumables weight allowance, it submits a new justification every two years, no later than September 30 of the reporting year. (3 FAM 3210)
• There is a current standard cable providing specific instructions to losing posts regarding limitations of size and shipping containers, port of discharge, marking instructions, suggested routings, designation of consignees, and import restrictions. (14 FAM 612)
• Solicitations for packing, crating, and shipping services are competitive and consistent with the requirements of FAR 13.106(b) for small purchases, and FAR Subpart 6.1 for procurements exceeding $25,000. (14 FAM 612)
The inspected entity is providing other services effectively and efficiently.
• Trash collection, pest control, the cleaning of offices and common spaces, and other services are being performed effectively and appropriately.
Suggested inspection techniques
ICASS:
Review the ICASS service standards for GSO activities. Spot check conformance with the ICASS standards throughout the inspection of GSO functions.
✓ Review the ICASS agreements to determine which agencies have enrolled for relevant ICASS services. Spot check conformance with the ICASS agreements.
Separation of Duties:
✓ Review the list of assigned responsibilities, noting separation of duties.
Personal Property Mangement:
✓ Review warehouse controls with staff. How are items entering and leaving the warehouse/compound? Who checks the lots and signs the delivery document? Are spot checks being made? When items leave residences for return to the warehouse, what controls are in place to ensure that items are actually returned to the warehouse?
✓ Observe the receiving process and/or review the steps staff take to receive property. Determine if there are controls for assuring that property is not misplaced before it is recorded. Determine if the receiving clerk actually sees the received items before signing the acquisition document, and if not, who does?
✓ Check a sample of receiving documents for nonexpenable property application numbers (where applicable), and signatures. Trace the current location of the property, check physically to see if it is there, check the records to determine if the items appear in the system.
✓ For each type of expendable property, check a sample of inventory records. Note whether all expendable property is being monitored, including bulk fuels, vehicle repair parts and supplies, medical supplies and drugs, maintenance parts and supplies, etc.
✓ Walk through the supply storage area noting the presence of slow-moving items, outdated forms, obsolete items, etc. Determine how often the inspected entity reviews these holdings and eliminates those that are not useful.
✓ Review the requisition records. How are items distributed? Are signatures obtained?
✓ Discuss with the accountable property office how often records are checked against property in stock. The inspector should perform some spot checks of five to ten randomly selected items, comparing numbers on the inventory records with the actual counts of items in stock in the warehouse. If possible, the officer should accompany the inspector during this process.
✓ Review the minimum replacement standards and the repair cost data. If there are no programs in place for these activities, discuss how they might be implemented.
✓ Review with staff how they determine which items should be recorded on NEPA, and whether other items (ordinarily those that cost less than $1000) are recorded as expendable property.
✓ Review whether property held by individual offices is recorded, inventoried, and reconciled annually.
✓ Review the most recent annual inventory record. Determine if the inspected entity successfully counted all property, whether the reconciliation was completed, and what the results were.
✓ Discuss with staff the problems they encountered and how they resolved them. Look at the records for shortages and overages for systematic occurrences (e.g., many items of the same type missing). Spot check a sample of overage and shortage items to determine if inventory records were adjusted accordingly following the reconciliation.
✓ Review the annual property management report (FS-582).
✓ Review a sample of residence inventory files for dates, occupant signatures, delivery and pick-up of items, etc.
✓ Discuss with staff whether the property survey board has met in the last year and the issues that were covered.
✓ Determine what procedures are used for the disposal of property, how they are monitored, whether there are controls on which items are sold, whether there are accountability procedures for funds collected, etc.
Motor Vehicles and Fuel:
✓ Review the controls on fuel supplies or the purchase of fuel for vehicles and generators. If fuel is stored by the inspected entity, look at delivery and issuance records, and the reconciliation. If fuel is purchased for official vehicles at local stations, review the system for payments, assessing whether controls are adequate.
✓ Review a sample of Daily Vehicle Usage Reports for completeness. Determine how the inspected entity is using these records and if the total number of reports submitted each month is being monitored and checked. Look at the back of the report for information on fuel usage. From a sample of five to ten reports, compare the numbers (mileage, gasoline usage) with those on the monthly report.
✓ Review the most recent administrative memorandum regarding use of official vehicles. For other than official use of vehicles, determine how payment is derived. For home-to-office use of official vehicles, review payment procedures.
✓ Review the vehicle files for accident reports.
Contracting and Procurement:
✓ Ask to see the contract warrants for any officers performing contract duties.
✓ Review a sample of large dollar value contract files. Look for adequate documentation regarding open competition. Determine how the inspected organization is monitoring the contract and who is responsible for deliverables under the contract. Check for appropriate coordination between the contracting/procurement staff and the office of the contracting officer’s representative. Has the contracting officer’s representative had training? Should not be the GSO. If reports are due from the contractor, are they in the file? How is government furnished equipment being monitored?
✓ Review the contract completion process.
✓ If there is a computerized or handwritten list of procurement actions, review it for patterns of procurement that are questionable. If the names of individuals appear, determine whether these persons are performing personal services under purchase orders.
✓ Look at the Blanket Purchase Agreement (BPA) process. Is there adequate competition?
✓ Review the coordination between the procurement/contracting staff and the financial management office. Before procurement or contracting is done, does the procurement/contracting staff obtain written assurance that funds are available? How are funds set aside for BPAs? Who tracks the funds available for BPAs?
✓ Review the procedure for tracking the completion of purchase orders. Are there a large number of purchase orders outstanding? How frequently are follow-up messages sent regarding these Purchase Orders? What method is used by the procurement/contracting unit and the financial management office for determining when a purchase order has been completed and when unused funds can be deobligated?
Housing and Real Property Management:
✓ Read the minutes from housing board meetings. Discuss with the management officer the issues that the housing board is facing.
✓ Review lease files for a sample of properties. Determine whether there is documentation of approval when leases are over $25,000, when space standards are exceeded, etc.
✓ Review two or three randomly selected leases for standard language.
✓ Look at a sample of three to five real property files to note whether they are in accordance with 15 FAM OBO.
✓ Review the housing handbook to determine if it is up-to-date and complete.
✓ If there is an approved housing profile, discuss with staff how they keep track of residences that are within the profile.
Maintenance of Real Property:
✓ Spot check a sample of recent work orders. Determine the approval process. Review the completion times for conformance with ICASS standards.
✓ Discuss with the facilities maintenance officer or general service staff the funded projects and those that will be proposed. Assess performance in completing funded projects. Review Office of Building Operations’ funding cables from to determine the use specified for the funds and check the actual use of the funds.
✓ Discuss with staff the definitions of routine maintenance and repair, special maintenance and repair, and minor improvements and assess whether they are managing projects and funding appropriately.
✓ Assess the overall condition of real property, including office and residential quarters, leased and U.S. government-owned. Visit a sample of properties including executive mid-level and junior officer quarters; houses and apartments. Coordinate with security inspectors.
Marine Security Guard quarters:
✓ If there is a Marine Security Guard, discuss the condition of the residence with the regional security officer and the U.S. Marine Corps sergeant. Coordinate a visit with the security inspectors.
Customs and Shipping:
✓ Review the current standard cable providing specific instructions to losing posts regarding shipments to the gaining post. Is it clear and up-to-date?
✓ Review procedures for packing, crating and shipping services. If contracts are used, review the contract files.
GUIDELINES FOR INSPECTING HUMAN RESOURCES OPERATIONS
OBJECTIVE: To evaluate the efficiency and effectiveness of the human resources operation.
REFERENCES: 3 FAM, 3 FAH
CRITERIA
Management is monitoring progress in achieving Human Resources (HR) strategic planning goals and objectives.
Management is using resources in the most effective and efficient way to support mission requirements.
Management is guarding against waste, fraud, and misappropriation of resources.
The inspected organization is following Department of State procedures for performance evaluation of direct hire and locally employed staff.
• Work requirements statements are prepared within 45 days of the start of the rating period for American direct-hire employees. (3 FAH-1 H-2815)
• Performance evaluations are completed annually and within the required time frame for all American direct-hire employees, eligible family members, and locally employed staff, including local-hire Americans. (3 FAM 2813, 3 FAH-1 H-2800, 3 FAM 7610, 3 FAM 8217, 3 FAH-2 H-135)
• Within grade increases for locally employed staff are processed promptly and performance evaluations are completed before within grade increases are authorized. (3 FAM 7580, 3 FAM 8210, 3 FAH-2 H-312)
The inspected organization is following Department of State hiring practices and procedures for all locally employed staff and the hiring process is viewed as fair.
• The local employment program for eligible family members, American citizens, and foreign national employees is equitable and fair. All positions are widely announced both within and outside the organization being inspected. Employment decisions and selection procedures follow established principles. (3 FAM 4100, 3 FAM 8200, 3 FAH-2 Chapter 3)
• Individuals are not performing personal services under purchase orders. All personal service contracts are established under appropriate agency authority and proper procedures. (3 FAM 7261, 98 State 184657, FAR 37.101)
• Guidelines are developed for the post employment committee and coordinated among agencies, particularly for American family members and American local hires. (3 FAM 8200, Appendix A)
• Security and medical clearances are obtained for all local-hire employees before appointment. (3 FAM 7222-7223, 3 FAM 8219)
• Security clearances of local employees are re-certified every 5 years. (3 FAM 7222.1)
• Any required nepotism waivers are obtained and on file especially for family members of the chief of mission, DCM, or principal officer. (3 FAM 8310, 3 FAH-1 H-8310)
• The staffing pattern and post employment committee records show no appearance of or actual conflict of interest in the employment process or line of supervision.
The inspected organization is following prevailing practice to establish salary and benefits for locally employed staff and the compensation plan is current.
• The inspected organization complies with host-country law with regard to employment of locally employed staff. (3 FAM 7224)
• The local compensation plan is based on prevailing salary rates and compensation practices. The results of the latest compensation review have been implemented. (3 FAM 7300, 3 FAH-2 H-200)
• The retirement plan for locally employed staff is adequate and viable. (3 FAM 7345)
• The local leave plan and the separation plan follow prevailing benefits and have been approved by the Department of State. (3 FAM 7432, 3 FAM 7730)
The inspected organization is using appropriate job evaluation procedures for all local-hire positions and position descriptions accurately state the work to be performed.
• Position descriptions are current, complete, properly classified, dated, and signed. The incumbent and the supervisor have copies of the position descriptions. (3 FAM 7512, 3-FAH-2 H-440)
• The original signed copy of the position description with the job evaluation report to support the position grade determination is on file in the human resources office.
• The inspected organization conducts an annual review of locally employed staff position descriptions to determine that the position description accurately reflects the work to be performed. (3 FAM-2 H-443)
Documents and reports related to human resources operations are accurate and up to date.
• The locally employed staff handbook is current and clearly explains conditions of employment, ethical standards, EEO principles, grievance, and disciplinary processes. (3 FAM 7224)
• The inspected organization has developed a training plan that reflects priorities as defined in the strategic plan. (3 FAM 2710, 3 FAM 7630)
• The post report, allowances and differential reports are completed, up to date and reflect the living conditions at post. (2 FAM 170, SR 070)
Time and attendance and the use of overtime are managed in accordance with Department of State regulations. Reasonable attempts are made to keep overtime to a minimum.
• Time and attendance is correctly administered. (3 FAM 3130, 3 FAM 3150, 3 FAH-2 H-134, 4 FAH-3 H-519-520)
• Alternative methods, such as revised work schedules, are being used to reduce overtime.
Management communicates information on human resources issues effectively.
• Human resources policies and procedures are coordinated with all agencies at the inspected organization and with constituent posts. (3 FAH-2 H-315)
• Orientation programs are provided for newly arrived American employees, eligible family members, and newly hired local staff. (2 FAM 113, 3 FAM 7244)
• There are regular meetings and open lines of communication between the front office and all American and locally employed staff. (3 FAM 7293)
The inspected organization has an incentive awards program that is effective and equitable.
• The incentive awards program is active and announcements soliciting award nominations are issued regularly. The awards committee is proactive in encouraging supervisors to submit nominations. (3 FAM 4800, 3 FAM 7120)
• Awards are administered properly, the awards nomination review process is equitable, and awards are well distributed across all sections and agencies at the inspected organization, and conform to Department of State guidelines. (3 FAH-1 H-4810)
• The supervisor has certified in writing that the employee’s performance is at the fully successful level or better before an award nomination is accepted.
Department of State guidelines for the maintenance and retirement of human resources records are being followed.
• Records are protected and destroyed according to the Records Management Handbook and Records Disposition Schedule. (3 FAM 2355, 3 FAM 7140, 3 FAH-1 H-2350, 5 FAH-4)
The language program is being conducted in accordance with Department of State standards.
• The language program is funded and administered to meet the language requirements and needs of personnel in language-designated positions. (3 FAM 2732, 3 FAH-1 H-2735)
Suggested inspection techniques:
American Direct-Hire Employee Procedures:
✓ Depending on the size of the American direct-hire staff, review either a random sample of or all work requirements statements, noting if the statements were signed within 45 days of the start of the rating period.
✓ Look at the performance evaluation files for American direct-hire staff to confirm:
• all performance evaluations are completed annually,
• if any evaluations were late and why,
• if a system is in place to track evaluations during the performance review cycle,
• if the employee evaluation review panels are briefed on their responsibilities, and
• if rating and reviewing officers are appropriately designated.
Locally Employed Staff Procedures and Files:
✓ Review a random sample of FSN, PSA, FMA, and local hire American personnel files, looking for:
• Valid security and medical clearances
• Current PSA agreements signed by both the employee and an official of the embassy
• Completed performance evaluations
• Promptness in processing within-grade increases (WGI)
• Performance evaluation completed by the supervisor before the WGI was processed
• Current position descriptions and job evaluation reports to document position classification
✓ Determine whether there are employment policies and procedures in place to recruit and fill all locally hired positions. Review the recruitment process and files to make sure:
the position description was certified correct and current by the supervisor before the position was announced,
• the model vacancy announcement is being used,
• applications are received and properly rated for qualified candidates,
• the post employment committee follows established guidelines and keeps minutes of the selection process,
• proper selection procedures were followed and the selecting official is given applications of all qualified candidates.
✓ Review the local compensation plan and the date salary increases or changes to benefits were last reviewed and implemented. Make sure there are Department approved local leave and separation notice plans in place.
✓ Discuss with locally employed staff the adequacy of compensation, benefits, retirement, medical, life, local leave and separation notice plans.
✓ Review the locally employed staff handbook to determine if it is current and the contents consistent with the compensation, local leave, and separation plans. Look for clear explanations of the conditions of employment, ethical standards, EEO policies, grievance and disciplinary processes.
Eligible Family Member (EFM) Procedures:
✓ Review recruitment files to determine if the hiring official made the selections or the post employment committee and if appropriate selection procedures were followed. The files should include notes from the employment committee or hiring official on how the successful candidate was selected. Unsuccessful candidates should have been sent written notification.
✓ Make sure Family Member Appointment (FMA) or temporary appointment procedures are used to hire eligible family members.
✓ Determine if nepotism or conflict of interest issues were addressed when selecting an EFM and nepotism waivers were obtained and on file.
General Procedures:
✓ Review a selection of purchase orders (in the GSO procurement office) to determine whether individuals are being “hired” under purchase orders.
✓ Look for conflict of interest and nepotism issues in the staffing charts. Discuss these issues with the DCM (for American employees) and the human resources staff (for locally employed staff).
✓ Determine how individuals are selected for training and how these selections coordinate with meeting priorities in the inspected organization’s strategic plan.
✓ Review the use of overtime and discuss with management officials whether revised work schedules could be used to reduce overtime.
✓ Review the incentive awards files to determine whether awards are being given at least once a year, supervisors are being solicited for awards nominations and all sections are participating in the awards process. Make sure a fully successful performance evaluation was completed on every employee nominated for an award. Read a sample of award nominations for consistency and adherence to award criteria.
✓ Review the most recent allowance and differential reports to include the retail price survey, post differential report, danger pay, education allowance, and consumables allowance to determine if the reports are up to date and accurate.
✓ Determine how many orientation sessions have been held in the previous year for new American direct-hires and locally employed staff. Get feedback from participants on the effectiveness of the orientation programs.
✓ Review the language program to determine if it is being managed equitably, or if only some officers receive language training.
GUIDELINES FOR INSPECTING THE INTERNATIONAL BROADCASTING BUREAU
NOTE: IBB overseas programs within a host country may include transmitting facilities, VOA correspondents, and/or regional affiliate support offices.
OBJECTIVE: To assess the efficiency and effectiveness of International Broadcasting Bureau programs at overseas locations, to evaluate the support provided to these programs by U.S. missions, and to review the relationship between the IBB program and the U.S. mission.
REFERENCES: United States International Broadcasting Act of 1994 (Public Law 103-236); Foreign Affairs Consolidation Act of 1998
CRITERIA
Management is using resources in the most effective and efficient way to achieve policy objectives
Management is guarding against waste, fraud, and misappropriation of public property.
IBB activities are relevant to U.S. foreign policy objectives, and are being conducted according to U.S. government standards.
IBB regional affiliate programs (either support offices or agreements with local commercial broadcast stations) are effective and appropriately carried out.
• If there is a regional affiliate support office in country, criteria III.P.1 through III.P.5 are met.
• If the IBB has established affiliate agreements in country, the mission is aware of which local commercial stations participate in the agreements or programs.
• Affiliate agreements are being conducted according to the letter of agreement between IBB and the affiliate station.
IBB technical monitoring programs are providing high quality data on the audibility of broadcast signals in designated areas.
• Where applicable, IBB contractors monitoring and reporting on VOA signals in country provide timely and useful information, as specified in their contracts.
Senior IBB facility personnel have an appropriate relationship with the embassy front office and participate in the country team.
• The relationship between IBB personnel in the country and the chief of mission and DCM is congenial and productive.
• The senior IBB representative is considered a member of the country team, and regularly attends country team meetings.
• The embassy and the IBB program(s) have an effective coordination process. Post management is attentive to IBB security and emergency preparedness, whether for transmitting facilities, regional affiliate programs, or VOA correspondents.
• There is regular communication between the IBB program office and the post. Post officials make regular visits to IBB transmitting sites.
Administrative services, whether provided by the IBB program office or the embassy, are effective and efficient.
• If services are provided by the embassy, there is a current ICASS agreement. (Note: This issue should be considered for each IBB entity, including VOA correspondents, transmission facilities, and regional affiliate support offices.)
• A representative of the IBB program office is a member of the post ICASS council.
Support from BBG Washington and/or other IBB facilities are appropriate and adequate.
For IBB transmitting stations, training is being provided to appropriate personnel to maintain proficiency in contracts, ICASS, imprest fund, budgeting, property management, ethics, safety, and other specialized areas.
Suggested inspection techniques:
✓ Look at affiliate agreements, if any. Are the affiliates performing the responsibilities stated in the agreements?
✓ Review any IBB contracts for monitoring and reporting on VOA signals. Is the post monitoring the contracts? See Section III.D.4.4 on acquisition and contracting procedures.)
✓ Who is performing administrative services for the IBB facility? If the facility is providing its own services, is it meeting the guidelines set forth in Section III.D? The inspector should review IBB administrative services using those guidelines.
✓ If IBB administrative services are being provided under ICASS, review with post and IBB staff the adequacy of the services. Follow the guidelines set forth in Section III.D.
GUIDELINES FOR INSPECTING INFORMATION RESOURCE MANAGEMENT OPERATIONS
OBJECTIVE: To determine whether information resource management operations are conducted effectively, efficiently, and according to Department of State and U.S. government standards.
CRITERIA
The MPP process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
Management is using resources in the most effective and efficient way to achieve policy objectives.
Management is guarding against waste, fraud, and misappropriation of public property.
There are sound management procedures to assure that automated information systems operate effectively and accurately.
• The inspected entity has designated LAN administrator(s) for classified and unclassified systems. (5 FAM 831d)
• Employees have received training for the systems they use.
• There are effective help desk and/or trouble-shooting procedures to provide system users with assistance within a reasonable time period.
• The inspected entity has sufficient automated equipment to achieve MPP goals, and has developed a strategic information plan including life cycle management. (Clinger-Cohen Act requirement)
• Access controls for classified and sensitive systems are in place.
• The inspected entity maintains standard operating procedures with detailed descriptions of site-specific procedures and activities. (5 FAH-2 H-113)
• The inspected entity has implemented a plan for backups that includes daily back-up and off-site storage. (5 FAM 841.1, 842.5a)
• The Department of State’s anti-virus policies for personal computers have been implemented. (5 FAM 841.2)
• Documentation required by the Department of State is being maintained. (5 FAM 816)
• The information officer or system manager submits a quarterly telegraphic report to A/IM/SO/FO/FD identifying outstanding or unresolved issues. (5 FAM 815)
• The inspected entity maintains current inventories of unclassified ADP equipment on the NEPA system. (5 FAM 841.3)
• At least once a year, the system manager reconciles the recorded inventory to the physical inventory, assigning accountability for any missing parts and strengthening controls to reduce further exposure to loss. (5 FAM 842.6)
• At least once a year, the system manager inventories all tapes and disks on hand to ensure that there is an adequate supply to meet operational needs. (5 FAM 842.7)
• The inspected entity maintains records of every copy of commercial software installed on PCs. (5 FAM 841.4)
• There is a designated information systems security officer (ISSO) who is trained in the requirements, reads the reports, and whose responsibilities are not in conflict with separation of duties.
• Cryptographic equipment is being properly maintained, and an officer has been assigned accountability for cryptographic requirements.
The inspected entity is following Department of State telecommunications policies and procedures for telephone, fax, voice radio, network, and satellite television operations.
• If telephone and fax services are being used for personal purposes, the uses fall within the guidelines set by the Department of State. (Official business includes emergency calls and other calls determined to be necessary in the interest of the government. (5 FAM 513.1, 514.b) See also 00 State 48743.
• There are procedures in place to monitor unreasonable use of office telephones for personal calls during business hours.
• The inspected entity monitors usage of official telephones and fax machines to identify charges that should be paid for personal use.
• Employees are using personal calling cards to make personal calls to locations outside the local area. (5 FAM 513.2)
• If an answering machine is being used, the recording provides an alternate telephone number to call in emergency situations. (5 FAM 513.4)
• The regional information management center (RIMC) approves all procurement orders for telephone equipment before they are submitted. (5 FAM 513.6b)
• Cellular telephones are being used in accordance with 5 FAM 513.6-2.
• The telephone system meets communication requirements for all users, including high volume areas such as the consular section.
• The residential telephone program is managed in accordance with local conditions and Department of State regulations.
• The inspected entity has secured host country consent before installing and using a wireless transmitter. (5 FAM 515.1c)
• If A/IRM-funded emergency action plan radio systems are being used to provide protection and security to U.S. government personnel and property, requirements have been submitted to the RIMC. (5 FA 515.6-1, 5 FAM 522.1)
• Radio testing and exercise programs have been established consistent with needs and the net operating instruction (NOI) published by RIMC. (5 FAM 622.6a)
• All emergency action plan radio systems are tested weekly or as directed by the chief of mission. (5 FAM 522.6b)
• Radio systems for administrative functions are provided by the inspected entity or bureau, and are approved by A/IRM. (5 FAM 515.6-2, 5 FAM 522.1)
• The inspected entity has preventive maintenance, repair, and replacement programs for radios.
• Electronic mail transmission (e-mail) meets the guidelines set forth in 5 FAM 516.
• Accurate and up-to-date inventories of official radio equipment are being maintained.
• Where satellite television dish antennas are in use, the inspected entity has obtained written documentation that the installation is in conformance with applicable host country laws and regulations, as well as approval from the Department of State. (5 FAM 518).
Department of State procedures are followed for diplomatic mail and pouch service.
• The inspected entity has appointed a pouch control officer (PCO) to oversee pouch operations. (5 FAM 331d)
• Only individuals and organizations specifically authorized to use the pouch may do so. (5 FAM 331b, 5 FAM 343)
• Senior management has developed specific procedures to control employee use of the pouch to send and receive mail. (5 FAM 342b(2))
• The diplomatic pouch is not being used to ship household items to circumvent the weight limitations of unaccompanied airfreight. (5 FAM 331k).
• Senior management has established criteria based on 5 FAM 300 and 5 FAH-10 for what constitutes pouch abuse. (5 FAM 342b(2))
• Senior management has implemented procedures established in 5 FAH-10 to ensure that all authorized pouch users understand pouch limitations and the consequences of abusing pouch privileges. (5 FAM 342b(3))
Cable traffic is managed to ensure that vital information is properly distributed.
• If Cable Express has been implemented, the inspected entity is distributing cables electronically and is not providing hard copies except to users without access.
• There are procedures in place for distribution of cable traffic (unclassified and classified).
The inspected organization has established an effective, economical and efficient records management system.
• The information management officer (IMO) has been designated as the post records officer to perform the duties prescribed in 5 FAM 413.8.
• The administrative section has implemented procedures to remind all employees who leave the Department of State of the laws and regulations pertaining to the disposition of personal papers and official records. (5 FAM 413.9, 5 FAM 421.4, 5 FAM 423, 5 FAM 430)
• The inspected entity notifies the Department of State records officer (A/IRM/IPS) to report emergency or accidental destruction of records. (5 FAM 414)
• All official files are organized as described in the TAGS Handbook, 5 FAH-3. (5 FAM 421.1)
• Records Management Handbook procedures (5 FAH-4 H-317) are being followed when transferring records. (5 FAM 432.1b)
• The inspected entity has established an active, continuing records retirement program that covers classified documents, inactive Foreign Service national employee official personnel folders, and inactive personal services contracts for Department of State employees. (5 FAM 433)
• Records are not destroyed except in accordance with records disposition schedules. (5 FAM 434)
Electronic records are managed in accordance with 5 FAM 441.
• Departmental telegrams (not electronic mail) are being used to convey policy decisions or instructions from posts, to commit or request the commitment of resources, and for official reporting by the post. (5 FAM 443.1)
• For those electronic mail (e-mail) messages and attachments that meet the statutory definition of records, the inspected entity ensures that record documentation and preservation steps are taken. (5 FAM 443.2-3)
Suggested inspection techniques:
✓ Physically review the inventory lists for at least some of the various equipment, determine the date of the most recent inventory and whether reconciliation was done with the previous inventory. (Inventories should be performed at least annually by either information resource management or GSO personnel.)
✓ Check the accuracy of the inventory list by randomly sampling from four to eight different items on the list. Physically observe the items in place and compare the results with the written inventory. Pick some of the same type of items at random and check to determine if they are included on the written inventory.
✓ Review reports submitted to Washington.
✓ Review the life cycle plans for ADP equipment and discuss issues with systems managers.
✓ Observe storage location of back-ups. Discuss frequency of back-ups.
✓ Observe access and virus controls. Review administrative notices or other communication regarding these matters.
✓ Review telephone bills from local and cell telephone companies. Observe if employees are certifying which calls are official. Determine whether costs of personal calls are being reimbursed.
✓ Many cell telephone companies do not yet have the capability of billing for individual calls, but charge on a usage basis. Determine how this situation is being handled with respect to the use of cell phones for personal calls.
✓ Review records of weekly radio tests.
✓ Review administrative memoranda regarding use of pouch and mail services.
✓ Ask how records holdings are being managed and determine if the inspected entity is regularly scouring holdings for records that can be destroyed or retired.
GUIDELINES FOR INSPECTING LAW ENFORCEMENT AND NARCOTICS AFFAIRS ACTIVITIES
OBJECTIVE: To assess the effectiveness of law enforcement and narcotics affairs activities.
CRITERIA
FOR ALL POSTS
The MPP process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
• The major U.S. objectives in the host country relating to international crime, narcotics, and terrorism are clearly defined.
• They are reflected in the mission strategic plan (MSP).
• The major U.S. government expenditures in the host country related to law enforcement and narcotics control are clearly identified.
• They match MPP objectives.
• The post is achieving the law enforcement and narcotics control objectives in the MPP.
• Efforts are made to identify ways to improve performance.
The objectives and priorities of the law enforcement program are appropriate.
• The mission assigns appropriate priority to international narcotics control objectives.
• International narcotics control and other high priority objectives do not work at cross-purposes.
• The ambassador and DCM are appropriately involved in the mission's narcotics control committee.
• The DEA representative, if any, has access to the ambassador and DCM.
• The main obstacles are known.
• The front office has undertaken diplomatic initiatives with high-level host government officials in support of narcotics control objectives.
• The host government is cooperative in law enforcement and narcotics matters.
• The host government has the institutional ability to act.
• The host government is sensitive to human rights concerns.
Law enforcement and narcotics issues are well coordinated.
• The ambassador plays an appropriate role in coordinating law enforcement and narcotics issues, as does the DCM.
• A State Department officer has been assigned primary responsibility for law enforcement and narcotics matters.
• The coordinator for narcotics affairs (CNA) is normally the principal adviser to the ambassador on narcotics-related matters and coordinates the efforts of all mission components in attaining international narcotics control goals. This officer sits on the country team. (At posts with larger programs, the CNA may be the DCM.)
• The CNA has sufficient rank to coordinate and provide policy oversight to law enforcement agencies, and has ready access to the COM and other key mission officials.
• The duties of the CNA and other key narcotics personnel are clearly defined and understood.
• The CNA spends sufficient time on narcotics matters.
• The CNA has the necessary authority over international narcotics control personnel in the mission including those from other agencies.
• The coordinator receives adequate support from all components of the mission in carrying out CNA responsibilities.
• In a country with a large narcotics program, the coordinator for narcotics affairs may be assisted by a narcotics assistance unit (NAU). There is (is not) a law enforcement section (LES) or narcotics affairs section (NAS) at post.
• The law enforcement agencies represented at the post are (list here).
• Describe changes planned with regard to the agencies represented or the staffing of existing agencies.
• Identify law enforcement agencies not represented at post that regularly visit the host country (list).
• The issues of international crime/narcotics control are coordinated with those elements of the embassy that have either direct or indirect interest/responsibility.
• As appropriate, the post coordinates law enforcement operations and reporting with agencies not represented at post.
• As appropriate, the post coordinates with international organizations and other governments active in narcotics and law enforcement in the host country.
• The post coordinates law enforcement/narcotics issues with other U.S. embassies in the region.
• There is a mechanism to resolve disagreements regarding problems or approaches on these issues.
• Describe the main coordination problems, if any.
• Washington guidance and feedback on international crime/narcotics issues are useful.
FOR POSTS WITH NARCOTICS AFFAIRS SECTIONS/UNITS:
Documentation required by INL is maintained.
• Reports are submitted to the Department as required. Examples of required regular reports are: Flash Reports, due monthly; Status of Funds Reports, due monthly; Narcotics Report, may be monthly or quarterly; Financial Management Activity Report, due quarterly; Annual Budget Proposal, due October 1; and End Use Monitoring Report, due January 31.
• The Financial Management Activity Report (FMAR) is submitted monthly to the Narcotics Coordinator or NAS Chief, and quarterly to INL.
• The mission's Letters of Agreement (LOA):
• clearly describe and explain the goals of projects;
• establish performance measures;
• describe the responsibilities and action to be carried out by each party;
• include the standard provisions in accordance with the INL Program and Policy Guide (1997); and,
• include the Leahy Amendment requirements relating to human rights and other appropriate legislation.
The post conducts end-use monitoring (EUM) annually for all INL-funded resources.
• Reports are prepared and sent to INL on executive observation trips to the United States.
• The post reports as required in the INL Program and Policy Guide (1997).
• The post monitors and evaluates contractor performance.
• The mission has fully complied with all recent GAO, OIG, AID, and other-agency audit recommendations relating to narcotics matters.
The international narcotics programs are relevant, appropriate agreements have been reached with the host country, and interaction with the host country is good.
The mission's International Narcotics Control Strategy Report:
• provides a current and clearly understood analysis of the country narcotics situation;
• clearly outlines a strategy for carrying out the narcotics control program; and,
• identifies economic, social, and political forces in the host nation that may impede goal achievement.
The mission's annual budget submission:
• clearly states what is to be accomplished within an estimated time and at an estimated cost;
• identifies all U.S. resources and describes how they will be used to achieve project goals;
• contains a realistic implementation plan;
• contains a narrative statement which clearly explains why the project was selected, why it is likely to help achieve country objectives, and how it will be supported by the host country; and,
• specifies criteria for measuring goal achievement.
Each project agreement, letter of agreement, or other bilateral obligating document clearly describes:
• the scope of the project;
• the specific results to be achieved;
• the responsibilities and actions to be carried out by each party; and,
• the resources to be provided by each party to the agreement.
The views of DEA are considered as the country program is developed and implemented.
• DEA and Customs training programs respond to the country's need.
• Host country nationals, such as local government officials, were given the opportunity to play a role in the development of projects.
• Each project is directed at the host country institution most able to achieve program goals.
• The host country has committed sufficient personnel and other resources to the project.
Management and monitoring of personnel, commodities, contracts, and funds are performed according to Department of State standards.
PERSONNEL:
• The mix of Foreign Service and other personnel appears optimal.
• Personnel are motivated and fully utilized.
• The duties of all personnel are clearly defined.
COMMODITIES:
• The mission has an adequate system for tracking, receiving, and inspecting commodities on order.
• Mission narcotics personnel maintain a detailed inventory of all commodities currently in country.
• Mission narcotics personnel have a system for tracking the current status of the commodities that indicates to whom they are assigned, for what they are being used, and the extent to which they are being used. This status is verified.
• The mission guards against any abuse, misuse or underutilization of commodities.
• The mission has the expertise to adequately assess the requirements for such high cost commodities as aircraft and communications equipment.
• The host country has people trained in operating and maintaining international narcotics control-funded equipment.
TRAINING
• The post has established clear criteria for the selection of training participants aimed at ensuring that skills learned will be utilized in narcotics control activities.
• The mission has determined whether those who have been trained are utilizing the skills required.
• Program trainees are training others in their newly acquired skills.
PROGRAM EVALUATION
• Project achievements are clearly identified.
• Achievements have been validated.
• The project is likely to achieve its goals.
• The project is likely to have the expected impact on the overall country objective.
• Appropriate/necessary changes to project plans are considered as required.
REPORTING
Reports adequately address:
• the country narcotics profile and the host nation's perception of its narcotics program;
• U.S. narcotics interests in the country;
• program efforts, successes, problems and setbacks; and,
• other bilateral and multilateral activities which affect the country
narcotics situation.
TECHNICAL SERVICE CONTRACTS
• All service contracts contain well-defined performance criteria and cost data.
• Financial audits are performed regularly.
• The post and INL have responded to audit recommendations.
• Contractor performance is monitored and evaluated to determine that contract provisions are met.
INTERNATIONAL NARCOTICS CONTROL ACCOUNTING PROCEDURES
• Proper accounting procedures are being followed.
GUIDELINES FOR INSPECTING OVERSEAS MEDICAL PROGRAMS
OBJECTIVE: To review the provision of medical care to American citizen employees and their eligible family members at overseas posts.
REFERENCES: 3 FAM 1900 (old 3 FAM 680)
CRITERIA
Mnagement is using resources in the most effective and efficient way to achieve policy objectives.
Management is guarding against waste, fraud, and misappropriation of public property.
• In addition to the general criteria set forth is Section I.C., the post controls expendable medical supplies and nonexpendable medical equipment according to the procedures set forth in Section III.D.4 of these guidelines. (old 3 FAM 687.3)
• Medical supplies are stored in secure locations to which only authorized personnel have access. (old 3 FAM 687.4)
• Controlled substances are properly maintained and administered, and a log is kept showing supplies and dispositions.
• Perishable medical supplies are disposed of appropriately on date of expiration. (old 3 FAM 687.6)
• Only authorized personnel dispense prescription drugs. (old 3 FAM 687.7-2)
• Medical insurance benefits for medical services received at government expense are recovered and deposited against the authorizing document account ID number.
• Authorizations for medical evacuations are requested from the Department of State in advance, except in emergency situations.
The post provides current, accurate health and medical care and information to American citizen employees and their families, with adequate provisions for the protection of privacy.
• Employees receive information on preventive health measures and health care before arriving at post.
• Medical information, including the role of various medical personnel, is covered in the post orientation briefing or material.
• The post maintains a Health and Medical Information Report and provides each employee with a copy. (old 3 FAM 682.2-5)
• The Health and Medical Information Report is updated annually and submitted to M/MED by January 31. (old 3 FAM 682.2-5d)
• Serious illnesses or injuries of American employees or their family members are reported in “MED Channel” telegrams to the Department of State using ICD codes for procedures and diagnosis.
• Individual medical records are stored in a locked cabinet.
• The post has an adequate number of first aid kits for emergency use. All official vehicles have first aid kits. (old 3 FAM 687.5)
• The safe haven is provided with an adequate first aid kit, and the contents are kept current. (old 3 FAM 687.5)
• If there is no RMO or nurse practitioner at post, the chief of mission has designated an officer with appropriate signing authority to initiate, receive, and control “MED Channel” message. (old 3 FAM 682.2-7)
• The post has current mass casualty plans, and the medical portions of the post emergency action plan (EAC) are updated at least annually.
The post has an active family advocacy program.
• The chief of mission has designated a family advocacy officer (FAO), usually the DCM or regional medical officer (RMO). (old 3 FAM 683.2b)
• The FAO publicizes the family advocacy program at post.
• The FAO investigates suspected cases of abuse/neglect, provides counseling and medical treatment, as appropriate, and determines the disposition of the cases. (old 3 FAM 683.3-3)
• Family advocacy case files are maintained and disposed of in accordance with old 3 FAM 683.5.
The medical unit receives adequate support from the post, the Department of State, and the regional medical office(s).
• Regional medical and psychiatric personnel visit post at least quarterly.
• The post supports and funds locally engaged nurse attendance at regional continuing nursing education conferences.
• All nurses, physicians, and lab technicians working at the post have been approved by the RMO.
Suggested inspection techniques:
✓ Physically review the storage of medical supplies. Check the expiration dates of a random sample of perhaps five to ten items to see if there are items with expired shelf life.
✓ Determine whether the medical unit is keeping a running total of supplies (either electronically or manually). Check the accuracy of the counts by randomly sampling from four to eight different items. (Count the items on the shelf and compare the outcome to the number on the inventory list.)
✓ Review the logbook for controlled substances to determine whether records are being maintained and are current.
✓ Review with medical staff how often orders for medical supplies are placed, the time required to receive the items, and the sufficiency of the number of supplies on hand. Procedures will vary depending on whether medical supplies can be obtained locally.
✓ Observe the locations in which medical records are stored and determine whether the files are locked when authorized medical personnel are not present.
✓ Physically review the inventory of nonexpendable medical equipment, determine the date of the most recent inventory and whether a reconciliation was done with the previous inventory. (Inventories should be performed at least annually by either medical or GSO personnel.)
✓ Determine how many medevacs have occurred in the past year and for what reasons.
✓ If possible, speak with the regional medical officer and psychiatrist, particularly if these persons are not stationed at the post being inspected.
✓ Review the Health and Medical Information Report, and based on inspection observations, judge how relevant and current it is.
✓ Discuss family advocacy issues with the DCM/RMO.
✓ Ask the financial management office about medical insurance benefits received.
✓ Spot check the contents of first aid kits in safe havens and vehicles.
✓ Review the medical portions of the EAP and mass casualty plan.
✓ From discussions with employees during the course of the inspection, obtain a sampling of opinions on the quality of medical care provided at the post.
✓ Determine whether there are medical issues at post that should be brought to the attention of M/MED, either in a report or in discussions.
GUIDELINES FOR INSPECTING OVERSEAS SCHOOLS
These guidelines apply only to overseas schools participating in the Department of States’ Consolidated Overseas Schools Assistance Program. The inspector should review other schooling opportunities for dependent children only in a general sense (i.e., availability, need, quality, etc.).
OBJECTIVE: To review the quality of educational opportunities for dependent children at overseas posts and to review the handling of overseas school grant funds.
REFERENCES: 2 FAM 600, the Foreign Assistance Act of 1961, as amended
CRITERIA:
The post and the school are fulfilling their responsibilities under the Consolidated Overseas School Assistance Program.
• The chief of mission or principal officer has designated an officer to be responsible for coordinating the post’s interest in school activities. (2 FAM 613)
• The administrative officer ensures that payments to the school, including advance payments, are in accordance with the provisions of the grant(s). (2 FAM 613.1b)
• Grant funds are used only for reimbursement of direct costs.
• The post has reviewed grant expenditures and determined that they were used in accordance with the grant agreement.
• Expenditures have been charged to the proper grant.
• All completed/expired grants have been closed out.
• The school has adequate insurance coverage. (2 FAM 613.1)
• The person signing grants on behalf of the school is duly authorized to do so. (2 FAM 613.1)
• The school undergoes an annual audit of funds provided under U.S. grants. (2 FAM 613.1)
• The public affairs officer is monitoring school assistance activities to ensure that they are in consonance with the Mutual Educational and Cultural Exchange Act of 1961. (2 FAM 613.2)
• The USAID mission director is monitoring school assistance activities to ensure that they are in consonance with the Foreign Assistance Act of 1961. (2 FAM 613.3)
• The post maintains a file of school grant documents and regularly reviews them.
• All post endorsements of school grant requests are based on knowledge of actual needs.
• The school keeps grant funds in a separate bank account. (2 FAM 615.1-7)
• The school submits semiannually an Overseas Schools Grant Status Report (JF-61) for each grant received. (2 FAM 615.1-8)
• If the post has donated personal property to the school, such property meets the criteria of 2 FAM 615.4d.
• If the school is receiving on OS grant, the tuition charged American students is not more than that charged other students.
The post and the school maintain a professional, congenial relationship that promotes the educational capabilities of the school.
• Employees or adult family members of post employees serve on the school board.
• The administrative officer does not serve on the school board if he/she is responsible for the administration of the grant(s).
• The chief of mission or principal officer has an official representative on the school board.
• Assistance provided to the school by the post is reimbursed, including security guards, real property, medical support, housing assistance for staff, transportation for students, commissary use, APO/FPO, importation and customs assistance, etc.
• The post and the school solicit feedback from official American parents regarding satisfaction or dissatisfaction with the school and suggestions for improvement.
• The regional education officer (REO) has visited the school within the past two years and left a written report.
Suggested inspection techniques:
✓ Review the grant files (usually located in the administrative office). Determine whether completed grants have been closed, and whether the post and the school are submitting reports to Washington in a timely manner. Does the school submit information to allow the post to certify that expenditures from grant funds are in accordance with the grant agreement?
✓ Review the school’s annual audit report. If the auditor made management suggestions, were these implemented? Were there irregularities cited in the audit report? Have they been corrected? Is the school financially sound? If not, what plans is the school making to become more financially stable?
✓ Look at the school’s insurance coverage. Does it appear to be appropriate?
✓ Determine the date of the last visit by a representative of the Office of Overseas Schools. If there is a written report from that visit, what were the findings? Have issues needing correction been addressed?
✓ Discuss school issues with the administrative officer. Does the administrative officer have an understanding of school issues, plans, and needs?
✓ If time permits, meet with school representatives to discuss post support and interaction. Also, as time permits, visit the school to view the facilities.
✓ Review the membership of the school board. Are there official Americans on the board? Have they been effective in presenting the post’s and Department of State’s views?
✓ Review reimbursement by the school of any services provided by the post, including guards, real property, etc. The financial management office will have records of payments from the school. Are services provided that are not reimbursed? If so, why?
✓ Do the post and school regularly solicit feedback from official American parents and students? What is the opinion of the official American community of the school’s programs, discipline, and educational excellence?
GUIDELINES FOR INSPECTING POLITICAL SECTION OPERATIONS
OBJECTIVE: To assess the effectiveness and efficiency of the political program.
CRITERIA:
The inspected entity is carrying out a well-directed and well-managed program of political work to achieve the objectives outlined in its mission planning documents and meet Department and U.S. Government needs.
Section managers use resources in the most effective and efficient way to achieve policy objectives.
• Officers in the section allocate their time appropriately among reporting, meetings, contacts and representation, grants management, visitors, and other tasks.
• Section management is guarding against waste, fraud, and misappropriation of public property.
Reporting and analysis functions are well-coordinated; add significant value through their information, insights and interpretation; and meet the needs of those with responsibility for directing and conducting the foreign relations of the United States.
• The inspected entity reports promptly and accurately on diplomatic issues, using foreign ministries and other embassies to follow multilateral developments and high-level, foreign bilateral visits and agreements. Reports enable Washington consumers to compare what is said to the United States and others.
• The inspected entity reports insightfully and selectively on domestic political issues, using a representative range of government and private contacts to interpret trends and link developments to U.S. interests. Reporting enables Washington consumers to understand, predict and analyze developments by providing facts and analysis to place events in context. Much of the information rests on first-hand contacts and is not available more easily through public sources.
• The inspected entity reports promptly and carefully on bilateral issues, both responding to instructions and alerting Washington to new developments. Reports advance bilateral agendas by conveying nuanced positions with precision and correctly analyzing interests and intentions of host governments.
• The inspected entity’s reporting program is appropriately balanced between spot and analytical reporting and includes input from all constituent posts.
Contact, protocol, and representation activities are being used effectively to advocate policies, coordinate activities, build and maintain contacts, develop information and negotiate agreements.
• The section’s contacts complement senior management’s contacts and support the representation plan.
• The section takes active steps in a planned way to develop new and useful contacts that are representative of a broad range of the relevant political and labor spectrum.
• The section’s work is not constrained by inappropriate restrictions on contacting certain groups.
Travel activities are being used effectively to develop information, build and maintain contacts, and support appropriate events.
• Funds are allocated in a fair and appropriate manner among individuals and goals.
• Travel is conducted in a well-planned manner to achieve objectives outlined in strategic planning documents.
• Travel results in coverage of all relevant sections of the country.
The inspected entity is effectively discharging its human rights responsibilities.
• The inspected entity has designated a human rights officer whose duties include the preparation of the annual human rights, religious freedom, and TIP report, selective reporting on significant human rights matters, and the explanation of U.S. human rights policy.
• Human rights reporting draws on contributions from all elements of the mission, including the front office and other agencies.
• The inspected entity submits timely, accurate, and well-substantiated drafts of required annual reports on human rights and other related issues.
The inspected entity is effectively discharging its labor reporting responsibilities.
• The inspected entity has designated a labor reporting officer and is submitting labor reports to Washington as required.
• The inspected entity is effectively discharging its leadership analysis responsibilities.
The inspected entity has designated a biographics officer who is coordinating an effective program of leadership reporting that involves all elements of the mission.
• Biographic reporting is significantly based on first-hand contacts, identifies potential leaders, and provides insightful information on political prospects and affiliations, negotiating styles, and other issues useful to U.S. policymakers.
The inspected entity is effectively discharging its responsibilities in science, refugee, political/military, nonproliferation, counter-terrorism and other areas in response to clearly defined priorities and needs.
The inspected entity is effectively advocating U.S. policies to the host government and assisting as appropriate with policy advocacy to the public.
• The section delivers all demarches promptly and reports reactions, following up as necessary to ensure responsiveness.
• The inspected entity adds value to demarches by shaping them to circumstances and identifying the most effective ways in which to approach host governments.
• The political section advocates as appropriate to support the needs of other mission elements, including export promotion.
• All approaches to the host government are well coordinated to ensure consistency among all agencies.
The inspected entity maintains appropriate records of its work.
• The section makes effective use of paper or electronic files to support reporting, biographic, and other activities. Files maintained by individuals are interoperable and accessible to duty officers.
• The section meets records management requirements, maintaining records of key actions, minimizing other records, and retiring files regularly.
The inspected entity effectively carries out its responsibilities for oversight of assistance programs.
• Grants or contracts to support political objectives (such as grants to human rights or other NGOs) meet relevant requirements.
• Assistance projects carried out by the section are reviewed for effectiveness upon completion.
• Political officers report as directed on programs funded by the State Department in narcotics, human rights and other areas.
GUIDELINES FOR INSPECTING PUBLIC DIPLOMACY OPERATIONS
OBJECTIVE: To assess the efficiency and effectiveness of the public diplomacy
function.
CRITERIA
The MPP process is a well-managed, mission-wide operation resulting in an accurate document that is used for internal management purposes. Progress in achieving the goals and objectives is monitored.
• In addition to the general criteria, the PAO participates in drafting of MPP to ensure public diplomacy support for a broad range of mission’s activities.
• MPP activities carried out by the Department, USAID, and other mission agencies.
• The MPP contains goals and objectives with measurable outcomes for exchanges, speakers, information, cultural, English-teaching, media activities and other programs and activities.
Management is using resources in the most effective and efficient way to achieve policy objectives.
• The PAO meets with the front office regularly.
• The chief of mission seeks the PAO’s advice on how best to achieve policy
objectives on a variety of issues, including media relations.
• The PAO proactively informs the chief of mission and other country team members and
coordinates with them on ongoing and future activities and programs through which public diplomacy programs can advance their MPP and U.S. objectives.
• The PAO is at ease with the language and knowledgeable about and sensitive to the intellectual and cultural environment in which the mission is operating.
• The PAS section is well structured administratively with American and FSN job responsibilities clearly delineated.
• The PAS Information section, cultural section, and Information Resource Center work cooperatively on MPP programs.
• PAS equipment and staff are not used routinely to support in-house or non-PAS functions that are more appropriately carried out through the ICASS process.
• Management is guarding against waste, fraud, and misappropriation of public property.
In addition to the general criteria, the inspected entity has established appropriate and effective controls for the accountability of funds collected from the IRC services, student advising, direct English teaching programs and/or English-teaching materials sales, if there are such programs at post.
Note: A post may legally and officially retain non-appropriated monies from English-teaching activities, the sale of teaching materials fees collected for test administration, and library fees. Authority for recycling such funds comes from Public Law 241.
• The inspected entity has specific approval from the appropriate Washington authority for any types of funds that are being recycled. (There must be a separate approval for each fund type.)
• Proceeds are itemized and recorded by source and deposited with the embassy Class B cashier in an expeditious manner.
• For any recycled funds being used, the inspected organization has requested and received approval from Washington.
• Recycled funds are being used only for the purposes authorized, i.e., English teaching funds are used solely to support the post’s English language activity.
• The inspected entity maintains records of the exact sums of money recycled, how it is spent, the amount asked for transfer to the following fiscal year, and the exact amount actually transferred to the next year.
• The PAO monitors the status of the post’s recycling accounts.
• There are appropriate and effective controls for the accountability of all funds collected.
The inspected entity is following established procedures to maintain control over grant procedures. (The authority for these are found in Grant Policy Directives (GPDs) found at .)
• The PAO has a current grant warrant from A/OPE.
• Each grant contains a clause (Article II) to enable an inspector/auditor to determine the objective of the grant and a cost breakdown of the use of the funds.
• Reports, as specified, have been submitted by the grantees and are maintained by the post on how the funds were spent and the programs carried out.
• The post is following up on grants awarded and maintaining appropriate records.
• The public diplomacy program budget is used solely for public diplomacy program activities.
Reporting and analysis functions are well coordinated, and reporting is serving the needs of those with responsibility for directing and conducting the foreign relations of the United States at operational and policy levels.
• In addition to the general criteria, the PAO is included in the mission reporting plan, and mission reporting officers use the PAO as a resource.
• The PAO analyzes and reports host country media attitudes and trends to
Washington, and receives feedback from Washington offices.
• The PAO is encouraged to report on substantive issues aside from the media
environment and academia.
• PAS sends editorial excerpts to INR/R/MR for its Media Reaction reports, if designated per 10 FAM 415.
• Contact, protocol, and representation activities are well organized and are being used effectively to advocate policies, coordinate activities, and negotiate agreements.
• In addition to the general criteria, the section’s contacts complement senior management’s contacts and support the representation plan.
• The section takes active steps in a planned way toward developing new and useful contacts that are representative of a broad range of the relevant political, economic, social, cultural, and educational spectrum.
• The post has effective working relationships with international, U.S., and host country media.
• The PAO has contacts in think tanks, the government, the media, universities, and the intellectual and artistic communities; and shares these contacts with other country team members.
• The distributed record system (DRS) focuses on contacts and institutions important to MPP goals and includes contacts from all mission elements.
Advocacy, coordination, and negotiation activities further mission goals and objectives.
• In addition to the general criteria, the PAO and/or information officer is the embassy spokesperson and coordinator for the public dissemination of all official information and public affairs statements.
• The PAO attends the country team meetings.
• The public affairs spokesman attends the country team meeting.
• Chief of mission and other country team media contacts are coordinated through the PAO/IO.
• Public diplomacy activities are coordinated when appropriate with all sections to enhance the mission’s contact with key audiences to promote U.S. policies.
Note: The public affairs spokesperson may be the PAO or IO depending upon the staffing of the mission. Although the Ambassador generally decides who attends his meetings, OIG/ISP feels that the attendance of the public affairs spokesmen in the country team meeting is essential for good media relations management.
Post supports BBG activities per State-BBG MOUs
• In addition to the criteria, the post is working with BBG to facilitate the establishment of regional and satellite affiliate offices. (03 State 096188)
• BBG marketing offices are full participants in ICASS and are subject to chief of mission authority. (03 State 096188)
• The post is using the appropriate ICASS agency codes for BBG activities. (9860.0 for IBB-News, 9568.1 for IBB Programs, and 9568.2 for IBB Correspondents.) (99 State 234777)
• The post is providing periodic contact with affiliates, advice and guidance to the BBG affiliates office, limited facilitative support to BBG affiliate office visitors, and inclusion of the BBG affiliates office in distribution of reporting on general media issues.
• The inspected entity is using public diplomacy in mission strategy and functions to promote U.S. political and economic objectives.
• The front office uses a mission public diplomacy strategy based on the MPP to carry out public diplomacy activities.
• The PAO coordinates public affairs activities with the defense attaché and other military groups, USAID, law enforcement, DEA, Department of Justice, the Peace Corps, and other USG entities.
• All mission elements coordinate public affairs strategies for ongoing activities and VIP visitors with the PAO and the public diplomacy section.
• Mission officers, particularly the duty officers, promptly apprise the PAO of
potential public affairs problems.
The inspected entity’s educational, cultural, and professional exchange programs are designed to promote U.S. foreign policy.
• Exchange programs are designed to support medium and longer-term mission
objectives, such as promoting mutual understanding, as well as to provide
tactical support for current policy.
• The public affairs section effectively coordinates Fulbright and other scholarship exchange programs. (See the Manual for Binational Commissions and Foundations)
• The chief of mission and other country team members are actively involved in exchange participant selections and follow-up programs.
• Exchange programs in both directions include speakers and professional experts closely coordinated with the mission.
• Candidates for the International Visitor Leadership Program are nominated by
elements throughout the mission and selected through a mission-wide selection committee.
• The Voluntary Visitors program provides substantive professional/cultural programs for targeted host country individuals.
• The mission has a mechanism, such as an exchanges committee to coordinate program nominations by mission elements to minimize conflicting, or counterproductive program demands upon host-country institutions and contacts.
• The inspected entity is using expert speakers from a variety of sources and in live and electronic program formats to support MPP goals and objectives.
• PAS takes advantage of speaker program opportunities using IIP Bureau-arranged speakers, U.S. experts in-country on Fulbright or other scholarships, VIP visitors, and American private sector individuals visiting or living in the country.
• PAS takes advantage of the electronic speaker program opportunities using digital video conferences, on-line Internet chats or discussions, telephone conference calls, and special broadcast programs produced by the Office of Broadcast Services upon mission request.
• Non-public diplomacy officers are rated upon their participation in PAS outreach speaker programs.
The PAO/IO carries out press/media activities to support U.S. foreign policy and activities of all mission elements in the host-country.
• The PAO/IO provides mission with daily reports on media reports of U.S. foreign policy activities world-wide mission activities in country.
• The PAO/IO provides media guidance and support for VIP visitors of all mission elements.
• The PAO/IO uses the Bureau of Public Affairs’ Foreign Press Centers and Office of Broadcast Services to support host-country media activities in the U.S.
The mission’s Information Resource Center (IRC) carries out international information programs supportive of MPP goals and objectives.
• The IRC has an annual written strategic plan, including a mission statement, goals and objectives, and plan of action addressing MPP priorities.
• The Regional Library Officer (RELO) makes regular visits to provide written assessments of IRC activities.
• The IRC has an effective countrywide outreach program to DRS contacts and institutions relevant to MMP priorities.
• The IRC distributes an effective mixture of translated versus English-language, and electronic versus hardcopy documents.
• The IRC supports mission officers’ research for speeches, papers, etc. and provides MPP relevant presentation materials.
• The IRC resources and activities complement and do not duplicate Foreign Commercial Service and Foreign Agricultural Service resources and/or activities.
• The IRC maintains the Embassy website and ensures it is relevant and up-to-date with information provided by mission elements.
• The IRC provides effective, regular support for PAS’ American Corners projects.
Where applicable, the English language teaching program provides selected key audiences with quality English language instruction within a professional program that also reflects American cultural thoughts and concepts, as well as democratic and educational values.
• The program has a professionally qualified and experienced director of courses.
• There is a trained teaching staff with advanced proficiency in English (if not native speakers), with knowledge of methodologies, techniques, and technologies in teaching English as a foreign language.
• The program has well-organized curricula that include course achievement goals and assessment criteria.\
• The core texts are high quality, American-published materials that include a strong American cultural component in order to acquaint the students with the United States.
Suggested inspection techniques:
✓ Review the MPP to determine public diplomacy objectives and outcomes, associated resources, and operational plan.
✓ Discuss with the chief of mission and/or DCM how public diplomacy activities are supporting MPP objectives.
✓ Discuss with the chief of mission and/or DCM how the PAS is involved in the drafting of the MPP to ensure public diplomacy goals, objectives, and activities are included throughout the document according to a mission strategy.
✓ Discuss with chief of mission and/or DCM the PAO’s role in coordinating media activities involving all mission elements, including VIP visits.
✓ Discuss host country media attitudes and trends with the PAO. Review data on placement of public affairs material with the local media, including the press, radio, and television.
✓ Review PAS’ Media Reaction reports, its daily report to the mission on U.S. foreign policy-related news, and its spot reporting to Washington on the local media and related issues.
✓ Review PAS’ topical reporting on issues outside the media environment.
✓ Review a list of PAS use/placements of Department-generated OP-Eds, Washington File material, AETN and other material during the last 12 months, including the audience categories targeted, to assess whether these programs are supporting MPP objectives.
✓ Review the IRC annual plan and budget, annual statistical reports, and regional information resource officer trip reports. Discuss IRC operations with the IRC director and PAO to determine whether and how IRC operations are linked to MPP objectives.
✓ Review the IRC’s strategic plan, outreach, and programming efforts.
✓ Review records on academic and professional exchanges, and discuss with public diplomacy staff how these exchanges have contributed to MPP objectives.
✓ Determine whether follow-up activities are being conducted.
✓ Discuss with the chief of mission/DCM how the mission is involved in the selection of candidates for exchange programs, and participate in follow-up activities.
✓ If applicable, discuss with the PAO relations with the Fulbright Commission and its contributions to public diplomacy goals.
✓ Review PAS’ cultural programs in the last 24 months and their relevance to MPP goals and objectives.
✓ Review PAS’ speaker programs in the last 24 months and their relevance to MPP goals and objectives.
✓ Review distribution records system listings, and discuss with the PAO whether listings are kept current and are restricted to those that contribute to meeting MPP objectives.
✓ Examine the grant documents for authorized signatures, costs, and purposes. Where required by the grant, determine whether reports have been submitted on how programs were carried out and funds spent, and that files are orderly and useful.
✓ Where applicable, review records on recycled funds to determine whether authority to recycle was received from Washington, whether funds have been used only for the purposes authorized, and whether funds have been deposited expeditiously with the embassy Class B cashier.
✓ Determine whether the inspected entity has established controls for the accountability of funds from the point of collection to the point of deposit.
GUIDELINES FOR INSPECTING SAFETY AND OCCUPATIONAL HEALTH FUNCTIONS
OBJECTIVE: To evaluate the efficiency and effectiveness of safety procedures.
REFERENCES: 6 FAM
CRITERIA
The inspected entity has had a recent Safety, Health and Environmental Management inspection, and has responded to the SHEM report.
The inspected entity has had a recent FBO fire inspection, and is conducting fire drills. Emergency exits are not blocked or locked.
Employees of the inspected organization have received safety and health training.
The inspected entity is performing the required mishap investigation and reporting.
The inspected entity is maintaining appropriate records and documentation regarding safety and health issues.
The usage and disposal of hazardous materials and pesticides is in accordance with Department of State guidance.
Environmental issues, such as air and water quality, are being managed appropriately.
The inspected entity is adhering to Department of State guidance regarding use of seat belts, no smoking, etc.
For posts with snack bars or cafeterias, the post is conducting regular health inspections of food storage and handling processes.
All electrical transformers containing polychlorinated biphenols (PCBs) have been replaced. (6 FAM 778.3)
Elevator inspection requirements are being met.
• Landlords of STL properties have provided certificates of inspection and testing of all traction, winding-drum, and hydraulic type elevators located in STL office properties. (6 FAM 766.2a)
• The inspected entity is regularly checking certificates of inspection and testing of elevators located in STL residential properties. (6 FAM 766.2b)
• The inspected organization is inspecting and testing all traction, winding-drum, and hydraulic type elevators in GO/LTL facilities according to established A/FBO standards. (6 FAM 766.1)
The inspected entity is complying with Department of State policy on integrated pest management.
Swimming pools are fenced and cannot be accessed by unaccompanied children.
Suggested inspection techniques:
✓ Review the most recent SHEM inspection report, and the status of compliance with report recommendations.
✓ Review the most recent FBO Fire inspection report, and the status of compliance with report recommendations.
✓ Review records and cables dealing with fires, mishaps, and accidents for the last few years.
✓ Discuss with the GSO staff the attention being given to hazardous materials and pesticides. If the inspected entity is using a pesticide contractor, review how the contractor’s adherence to required standards is being monitored.
✓ If there is a snack bar or cafeteria, determine whether frequent health inspections of food storage and food handling processes are being performed.
✓ If there are elevators in any official or residential buildings, review the elevator inspection records.
✓ During the course of the inspection, look around. Determine whether there are obvious health hazards. Look for blocked or locked fire exits, etc.
✓ Determine whether swimming pools have adequate safeguards against entry by unaccompanied children.
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[1] Since representatives of agencies other than the Department of State are present at most overseas missions, this provision conveys a degree of “cross-agency” authority upon the IG. However, OIG inspectors do not have authorization to review the internal operations of other agencies. Inspectors are authorized to examine other agencies’ overall contribution to mission goals, the coordination of their activities, and control by the chief of mission.
[2] The special visa program permits foreign national employees to apply for permanent residence in the United States.
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