Skip to content
Social Security Online
Office of the Inspector General
OIG Seal image
Blank Spacer Image

Audit Report - A-13-96-02001


Office of Audit

Review of Intergovernmental Personnel Act Assignments of Senior Staff - A-13-96-02001 - 9/30/97

This final report presents the results of our review of Intergovernmental Personnel Act (IPA) assignments of senior staff by the Social Security Administration (SSA). The IPA authorizes the temporary assignment of personnel between the Federal Government and nonfederal organizations. The objective of our review was to determine whether assignments of SSA personnel to external organizations were handled in accordance with the criteria that assignments be of benefit to SSA. Our determinations were based on: interviews of SSA personnel; reviews of personnel, travel, and financial records; and reviews of applicable sections of the IPA and SSA`s policies and procedures.

Our review was prompted by reports issued in 1995 by the Environmental Protection Agency (EPA), Office of Inspector General (OIG), regarding EPA`s administration of IPA assignments. The reports concluded that, although in general the assignments met the intent of the criteria established for the program, internal controls over individual assignments needed improvement. Specifically, EPA/OIG concluded that, in some instances, the IPA program was used more for the benefit and convenience of the employees than for either the EPA or host organization. Therefore, the intent, cost, and value of these assignments were deemed questionable. Since there had been no recent reviews or oversight of similar assignments at SSA, we initiated this review.

We found that SSA infrequently used the IPA program for senior staff (four assignments in 2 years). In three of the four IPAs, SSA did not benefit from the expenses paid in the development of these staff because they retired almost immediately after the completion of the assignment. The cost (salaries and benefits) to SSA for these three assignments was estimated to be about $568,000. SSA policy requires IPA assignees to agree to return to the Agency and serve for a period of time at least equal to the length of the assignment. This requirement is intended to ensure that SSA receives the benefit of an employee with enhanced skills for its costs. Failure to comply with this service requirement renders the assignee liable for all nonsalary costs associated with the assignment, unless waived for good cause. We found no documentation to indicate that SSA explored this liability.

The service requirement is not effective unless liability for breach is developed or penalties are established for cases where the employee did not incur nonsalary expenses as part of the assignment. Other controls to ensure assignments are of benefit to SSA, such as requiring evaluations so that SSA can monitor the effectiveness of the IPA program in meeting its needs, were not used.

We recommend that SSA closely monitor and control IPA assignments through the Office of the Deputy Commissioner for Human Resources (DCHR) and empower DCHR with authority and responsibility to ensure that the criteria are followed. We also recommend that SSA encourage compliance with the service requirement by: 1) developing liability for nonsalary expenses where an IPA assignee fails to complete his or her service commitment; 2) considering policy changes to include additional disincentives other than liability for nonsalary expenses for failure to comply; and 3) conducting evaluations of each assignment to ensure the needs of SSA are met.

We also found two other assignments to external organizations which began as "details" that could be considered de facto IPAs in that they involved the temporary assignment of personnel from SSA to an external organization. However, these assignments were not categorized as IPAs nor did they comply with basic IPA criteria, such as providing the terms of the assignment in an executed agreement. They also did not comply with "detail" criteria such as requiring reimbursement (unless certain criteria are met) and ending the temporary assignment on or before the authorized "not to exceed" date. These two assignments were of questionable benefit to SSA and cost SSA an estimated $975,000. We recommend that SSA establish controls over such assignments so they can be properly categorized as an IPA or "detail" and monitored for compliance. SSA generally agreed with our recommendations (See Appendix B).

BACKGROUND

In 1995, EPA/OIG reviewed EPA`s administration of IPA assignments and issued reports on its findings. EPA policy is to use the IPA program to the maximum extent possible to promote employee learning and growth. At the time of the EPA/OIG review in 1994-1995, there were 134 active assignments. One report concluded that in general, EPA`s IPA program met the intent of the IPA as the assignments were of mutual concern and benefit to the organizations involved. However, management controls over individual assignments needed improvement. Some assignments had multiple problems, leading EPA/OIG to conclude that, in some instances, the IPA program was used more for the benefit and convenience of the employees than either the EPA or the organizations to which the employees were assigned, or was used to "farm out" unwanted employees. The intent and cost of some assignments, as well as the benefit to EPA, were deemed questionable.

Public Law 91-648 (IPA of 1970), which SSA has augmented with Agency policies and procedures, provides the authority for IPA assignments. The IPA authorizes the temporary assignment of personnel between the Federal Government and eligible nonfederal organizations, such as State and local governments, institutions of higher learning, and other nonprofit organizations. The main purpose is to provide mutual benefit to the organizations involved by providing program and developmental experience for the assigned employee to enhance the employee`s performance in his or her regular job and to provide assistance to the host organization that cannot be obtained from other sources.

Policies and procedures for implementing IPA assignments are contained in SSA`s AIMS. Pertinent provisions include the following:

  • Assignments must be related to SSA`s programmatic mission and made for the mutual concern and benefit of the organizations involved.
  • Assignments may be made on a detail or appointment basis and should be kept to the minimum time frame necessary to complete the assigned tasks.
  • A written IPA agreement must be executed to document the obligations and responsibilities of the parties to the assignment.
  • Cost-sharing arrangements of an assignment are negotiable. SSA may pay all, some, or none of the costs. Cost-sharing should reflect the mutual and proportionate benefit to the respective organizations.
  • As a condition of accepting a mobility assignment, an employee must agree to return to SSA and serve for a period of time equal to the length of the assignment. Failure to do so will render the employee liable for all costs of the assignment (except salary), although this liability may be waived for good cause.
  • Initial IPA assignments may not exceed 2 years (and may be subsequently extended).
  • IPA assignments have to be approved by the Commissioner of Social Security (although this authority has recently been delegated to the Deputy Commissioners, Inspector General, and General Counsel).
  • Organizations must have their eligibility to participate certified by the Office of Personnel Management (OPM) before they are eligible to enter into an IPA agreement.
  • IPA assignments are management-initiated. However, DCHR`s Office of Training (OT) has been designated to provide administrative leadership, technical direction, and coordination of the IPA program. All IPA requests must be screened and reviewed by OT.
  • After completion of an IPA, participants and their supervisors must complete evaluations of the assignments to determine the overall effectiveness of the program.

Back to top

SCOPE

The objective of our review was to determine whether assignments of SSA personnel to external organizations were handled in accordance with the criteria that assignments be of benefit to SSA.

To achieve our objective, we:

  • reviewed applicable sections of IPA and related laws, SSA policies and procedures, and internal controls;
  • interviewed personnel responsible for administering SSA’s IPA program; and
  • reviewed SSA personnel files, as well as related payroll and other financial records of employees, who were identified as having been senior staff who were the subject of an IPA assignment or otherwise detailed to an external organization during Fiscal Years (FY) 1994 or 1995.

We reviewed those internal controls which existed during our review for handling IPAs in accordance with established criteria. Field work was performed at SSA Headquarters in Baltimore, Maryland, between April 1996 and January 1997. Our audit was performed in accordance with generally accepted government auditing standards.

RESULTS OF REVIEW

IPAs

SSA infrequently used IPA assignments for senior staff (four reported cases in 2 years). IPA policies and procedures required that IPA assignments be of benefit to SSA. In three of the four cases, the personnel assigned to work outside the Agency retired shortly after their assignments ended. These three assignments cost SSA about $568,000 and did not benefit the Agency in that the expertise developed by these personnel was never available to SSA.

To foster the objective of providing benefit to the Agency, assignees must agree to serve at SSA after their assignments are completed for a minimum period equal to the length of their assignments (or be liable for all nonsalary costs of the assignments) and evaluations must be prepared so that SSA can monitor the effectiveness of the IPA program in meeting its needs. In the three assignments that did not benefit the Agency, there was no documentation that liability for nonsalary costs was explored or that an evaluation was conducted.

These three cases are described below.

CASE 1

An employee from the Southeastern Program Service Center was assigned to an agency of the State of Alabama. The IPA agreement was for 18 months from June 1, 1993, to November 30, 1994, with an estimated cost of about $124,000. The negotiated SSA share was 26 percent, or about $32,000. The employee retired with a separation incentive effective January 3, 1995.

CASE 2

An employee from the Seattle regional office was assigned to a nonprofit agency in the State of Washington. The IPA agreement was for 12 months from September 24, 1990, to September 20, 1991. Two 12-month extensions were approved, as well as a 12-month period of leave without pay (LWOP). The last extension ended September 17, 1994.

The employee worked continuously at the nonprofit organization for 48 months and retired effective December 31, 1994. Total estimated SSA share of the expenses for the 3 years of IPA was about $110,000, not including any benefits paid during the year of LWOP.

CASE 3

An employee from SSA Headquarters was assigned to the National Academy of Social Insurance (NASI). The IPA agreement was for 24 months from April 3, 1994, to April 2, 1996, with an estimated cost of about $208,000. The negotiated SSA share was the entire (100 percent) estimated cost. The IPA concluded on May 31, 1996, and the employee retired effective June 3, 1996.

Because of a congressional request, the General Accounting Office (GAO) examined this assignment. They found that the employee had been assigned to NASI since January 1992, and worked there continuously through April 1996. GAO estimated the cost to SSA to be about $426,000. GAO also found that SSA violated OPM regulations when it allowed the employee to work outside the Agency from January 1992 to April 1994 without any written agreement. GAO concluded that the employee`s continuous service constituted, in effect, an IPA assignment, even though it was not in writing. Also, SSA violated the statutory time limit for the assignment (48 consecutive months) as the employee worked 52 consecutive months at NASI. In response to these findings, SSA chose not to comment on the conclusions reached by GAO, but simply stated that it would ensure that future IPA assignments met all legal criteria.

Back to top

Other Matters: "Details"

During FYs 1994 and 1995, SSA used "details" to assign two senior staff to outside organizations. According to statutory criteria, a "detail" is defined as a temporary assignment of an employee to a different position for a specific period with the employee returning to his or her duties at the end of a detail. We have included these cases because, as with IPAs, they involved the temporary transfer of personnel to external organizations. GAO reached a similar conclusion in Case 3. Even if not considered IPAs, these cases indicate problems which should be noted regarding "details" of senior staff to outside organizations.

The two senior staff who were detailed worked at external organizations without authorization well beyond the "not to exceed" date of their assignments. Their personnel files had not been updated. These two details resulted in about $975,000 in questionable payroll expenses for SSA. Subsequent to our inquiry, SSA placed retroactive documentation in the detailees` personnel files in an attempt to explain their status and whereabouts during the unauthorized time periods. Generally, details are to be reimbursable unless specific criteria are met. There is no documentation to indicate that SSA considered or tried to obtain reimbursement in these cases.

An absence of controls regarding categorization of such assignments as an IPA or "detail" and the lack of monitoring for compliance with the applicable criteria allowed this situation to occur.

These two cases are described below.

CASE 1

This detail assigned an employee from Headquarters to work at the Federal Quality Institute (FQI). The detail, effective July 1, 1991, was not to exceed October 28, 1991. The detail was extended numerous times, until it was terminated December 19, 1994. The personnel file contained no documentation of any extensions past July 1993. The estimated payroll costs to SSA for this detail were about $290,000. After the detail was terminated, the employee was assigned to work as an Agency representative to the National Performance Review (NPR).

CASE 2

This detail also assigned an employee from Headquarters to work at FQI, except that this assignment involved a Senior Executive Service level employee. The detail started on June 6, 1988, and lasted until September 30, 1995. The only documentation in the personnel file was the original detail (not to exceed 1 year); there was no documentation for any extensions. The estimated payroll costs to SSA for this detail were about $685,000. After the detail was terminated, the employee was assigned to work as an Agency representative to the NPR.

Back to top

CONCLUSIONS AND RECOMMENDATIONS

Regarding IPAs, we concluded that SSA receives no benefit from funds invested in developing employee expertise and experience when the employee fails to honor his or her service obligation to the Agency and retires soon after the end of the IPA assignment. IPA criteria require each employee to agree to serve at SSA after the assignment for a length of time at least equal to the length of the IPA assignment. The service requirement is not effective in ensuring that SSA receives the value of an employee with enhanced knowledge and experience for its expenses. This occurs because there is no indication that liability (for nonsalary expenses) for breach of the service requirement contained in the executed IPA agreement is developed and because there is no penalty for breach in cases where the employee did not incur nonsalary expenses as part of the assignment.

SSA needs to develop liability for breach of the service requirement and consider policy revisions to include additional disincentives for failure to comply.

SSA policy requires evaluations of each assignment to determine how well the program meets SSA`s needs. This policy should act as a control in evaluating similar future assignments and could also act as a control for ongoing assignments if done periodically. Evaluations were not utilized. Their use could help ensure that SSA receives value for the funds invested in IPA assignments.

Regarding "details" of senior staff outside the Agency, we concluded that some cases did not follow criteria applicable to either an IPA or "detail." The two cases described are examples of personnel being paid by the Agency with no controls over their placements or costs. These situations could be considered de facto IPAs or simply "details" which significantly exceeded their authorized terms at considerable expense to SSA. These situations need to be controlled so they can be properly categorized as an IPA or "detail" and then monitored to ensure compliance with applicable criteria.

There needs to be increased scrutiny of assignments when SSA is paying any of the costs when its employees are working outside the Agency. Had SSA not engaged in the assignments identified in this report, about $1.5 million of funds could have been put to better use. IPA assignments resulting in assignees leaving the Agency without completing their service obligations and a lack of evaluation of such assignments, as well as nonreimbursable details significantly exceeding their authorized ending dates, leave the Agency open to the criticism that it is wasting funds.

We recommend that SSA:

1. Control IPA assignments through DCHR and empower it with authority and responsibility to ensure that criteria are followed. Previously, DCHR has acted primarily as a facilitator for management rather than a control mechanism.

2. Implement the requirement that liability for nonsalary expenses be developed when an IPA assignee fails to complete his or her service commitment. SSA should also consider revisions to the standard IPA agreement to provide additional disincentives (besides liability for nonsalary expenses) for failure to complete an agreed-upon service obligation.

3. Conduct evaluations of each completed IPA assignment to determine whether the assignment was beneficial to SSA.

4. Establish controls for details to external organizations so that personnel actions regarding length of the assignments and costs are monitored, and require documentation to justify any costs that are not reimbursable. Details to external organizations should be scrutinized to determine whether they should be categorized as an IPA, "detail," or otherwise, and regardless should be monitored by a component independent of management which initiated the assignment to better ensure compliance with applicable criteria.

SSA COMMENTS

SSA generally agreed with our recommendations. It agreed to take specific steps to implement all the recommendations listed above except the part which recommended that SSA consider including additional disincentives in the standard IPA agreement for failure to complete an agreed-upon service obligation. In SSA`s opinion, it lacks the legal authority to add disincentives to the standard IPA agreement absent specific legislative and/or regulatory authority. The full text of SSA`s comments is contained in Appendix B to this report.

OIG RESPONSE

We believe SSA should consider seeking the necessary legal authority to include additional disincentives for failure to comply with the agreed upon service obligation in the standard IPA agreement. The current provisions do not provide any meaningful disincentives for breach in cases where the employee did not incur nonsalary expenses as part of the assignment.

- David C. Williams

Back to top

APPENDICES

APPENDIX A

Breakout of $1.5 million in funds which could have been put to better use.

IPAs Estimated SSA Costs

Case 1 $32,000

Case 2 $110,000

Case 3 $426,000

Details

Case 1 $290,000

Case 2 $685,000

$1,543,000 (total)

APPENDIX C

MAJOR CONTRIBUTORS TO THIS REPORT

Office of the Inspector General

Gary A. Kramer, Director, Program Audits
Carl K. Markowitz, Audit Manager
Gerald L. Hockstein, Program Analyst
Franklin H. Williams, Senior Auditor

  Link to FirstGov.gov: U.S. Government portal Privacy Policy | Website Policies & Other Important Information | Site Map
Need Larger Text?
  Last reviewed or modified