SOCIAL SECURITY ADMINISTRATION

PERFORMANCE INDICATOR AUDIT:
800-Number Access

September 2006                  A-02-06-16108

AUDIT REPORT

Mission

We improve SSA programs and operations and protect them against fraud, waste, and abuse by conducting independent and objective audits, evaluations, and investigations. We provide timely, useful, and reliable information and advice to Administration officials, the Congress, and the public.

Authority

The Inspector General Act created independent audit and investigative units, called the Office of Inspector General (OIG). The mission of the OIG, as spelled out in the Act, is to:

Conduct and supervise independent and objective audits and investigations relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and operations.
Review and make recommendations regarding existing and proposed legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of problems in agency programs and operations.

To ensure objectivity, the IG Act empowers the IG with:

Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.

Vision

By conducting independent and objective audits, investigations, and evaluations, we are agents of positive change striving for continuous improvement in the Social Security Administration's programs, operations, and management and in our own office.


SOCIAL SECURITY

MEMORANDUM

Date:       September 25, 2006                                                                                                                Refer To:

To:         The Commissioner

From:      Inspector General
               
Subject:  Performance Indicator Audit:  800-Number Access (A-02-06-16108)

We contracted with PricewaterhouseCoopers, LLP (PwC) to evaluate 15 of the Social Security Administration’s performance indicators established to comply with the Government Performance and Results Act.  Attached is the final report presenting the results of one of the performance indicators PwC reviewed.  For the performance indicator included in this audit, PwC’s objectives were to:

• Assess the effectiveness of internal controls and test critical controls over data generation, calculation, and reporting processes for the specific performance indicator.
• Assess the overall reliability of the performance indicator’s computer processed data.  Data are reliable when they are complete, accurate, consistent and are not subject to inappropriate alteration.
• Test the accuracy of results presented and disclosed in the Fiscal Year 2005 Performance and Accountability Report.
• Assess if the performance indicator provides a meaningful measurement of the program it measures and the achievement of its stated objective.

This report contains the results of the audit for the following indicators:

• Optimize the speed in answering 800-number calls.
• Optimize the 800-number agent busy rate.

Please provide within 60 days a corrective action plan that addresses each recommendation.  If you wish to discuss the final report, please call me or have your staff contact Steven L. Schaeffer, Assistant Inspector General for Audit, at
(410) 965-9700.
Patrick P. O’Carroll, Jr.

Attachment

MEMORANDUM

Date: September 18, 2006

To: Inspector General

From: PricewaterhouseCoopers, LLP

Subject: Performance Indicator Audit:  800-Number Access (A-02-06-16108)

OBJECTIVE

The Government Performance and Results Act (GPRA) of 1993 requires the Social Security Administration (SSA) to develop performance indicators that assess the relevant service levels and outcomes of each program activity.  GPRA also calls for a description of the means employed to verify and validate the measured values used to report on program performance. 

Our audit was conducted in accordance with generally accepted government auditing standards for performance audits.  For the performance indicators included in this audit, our objectives were to:

1. Assess the effectiveness of internal controls and test critical controls over the data generation, calculation, and reporting processes for the specific performance indicator.

1. Assess the overall reliability of the performance indicator’s computer processed data.  Data are reliable when they are complete, accurate, consistent and are not subject to inappropriate alteration.

1. Test the accuracy of results presented and disclosed in the Fiscal Year

(FY) 2005 Performance and Accountability Report (PAR).

1. Assess if the performance indicator provides a meaningful measurement of the program it measures and the achievement of its stated objective.

BACKGROUND

We audited the following performance indicators as stated in the SSA FY 2005 PAR:

* The result reported in the FY 2005 PAR for the Agent Busy Rate (ABR) was 10 percent.  However, the ABR actual result for FY 2005 was 9.5 percent.  SSA management rounded the result of this indicator to the nearest whole number using the standard rounding convention of rounding down numbers less than or equal to .4 and rounding up numbers greater than or equal to .5.

SSA began using telephone service centers as a mechanism to interface with the public in the mid-seventies and established the National 800 Number Network in
October 1988.  The Call Center Network Solutions (CCNS) architecture that is used today for the National 800-Number Network was installed in 2001 to provide the general public with greater access to SSA programs, such as the Disability Insurance program, authorized by Title II of the Social Security Act, and the Supplemental Security Income program, authorized by Title XVI of the Social Security Act.  The National 800-Number Network was also implemented to provide the public with the ability to request changes to their individual records (i.e. address, earnings, etc).  Although the general public has a variety of other service options when obtaining information or conducting business with SSA (i.e. internet, field offices, etc.), the majority of the customers conduct their business with SSA via the telephone.  In FY 2005, SSA estimated that 57 million customers would access the National 800-Number Network to conduct their business with the Agency. 

When SSA customers dial the National 800-Number Network (800-SSA-1213) and request agent assistance, they are connected to an SSA agent in 1 of the 44 geographical SSA locations.  These locations consist of 36 Teleservice Centers
(TSC), 6 Program Service Centers (PSC), and 2 components of the SSA Office of Central Operations (OCO).   There are approximately 4,000 agents at the 36 TSCs and the 2 components of the OCO.  These agents have the primary responsibility of answering the 800-number incoming calls.  During times when the call volume exceeds the agents’ capabilities, SSA management has the ability to deploy additional personnel trained to act as agents to supplement the full time TSC personnel.  These personnel (known as "SPIKES") have primary responsibilities outside of the TSC function.  These responsibilities cover a variety of other administrative duties (i.e. claims processing, collections or mailings).  By using the assistance of "SPIKES", SSA management has the ability to efficiently operate the National 800-Number Network by reducing the length of time callers remain in queue, and reducing the number of agent busy messages given to callers.  There are approximately 2,000 "SPIKES" in the 6 PSCs (co-located at the TSC sites).

The 800-Number Access performance indicators are linked to SSA’s strategic objective to “…improve service with technology.”   The strategic objective is linked to the SSA’s strategic goal “…to deliver high quality, citizen-centered service…” which encompasses the Agency’s traditional and electronic services to applicants for benefits, current beneficiaries, and future beneficiaries.

RESULTS OF REVIEW

Overall, we found the nature of the performance indicators to be meaningful GPRA measurements.  However, SSA management could not provide PricewaterhouseCoopers, LLP (PwC) access to the systems used to generate the results of the performance indicators, as the systems are owned and operated by a contractor (Verizon).  In addition, SSA management was unable to provide adequate documentation that supported their conclusion that the Verizon systems used to generate the performance indicator results were sufficiently controlled to ensure the completeness, accuracy, and validity of the data.  As a result, PwC was unable to recalculate, and could not conclude on the accuracy of the results reported in the PAR for the performance indicators included in this report.

Specific to the Average Speed of Answer (ASA) performance indicator, we found the description of the data definition in the PAR to be inaccurate.

Indicator Backgrounds

Optimize the Speed in Answering 800-Number Calls

When an SSA customer calls the SSA National 800-Number Network, he/she is presented with a series of service selection announcements.  The callers have the option of conducting their business through automated prompts or via agent assistance.  If the customer chooses agent assistance, the vendor supplied Intelligent Contact Manager (ICM) application determines the most efficient routing destination for the call.  The ICM considers agent availability, estimated wait time in queue and the number of calls currently in queue before routing calls to an available agent.   If there are agents available to handle the incoming call, the call is immediately transferred and answered by an agent without waiting in queue.  These calls report a zero ASA and are included in the calculation for the ASA.   The ASA indicates how timely the agents and SPIKES are answering the incoming calls to the National 800-Number Network.  

When there are no agents available to handle the incoming call, the call is placed in queue and the wait time calculation begins.  Once an agent becomes available to handle the call, the system automatically routes the call to the available agent.  Once the agent answers the call, the wait time calculation ends.

The Automatic Call Distributor (ACD) systems record the call data.  The call data is downloaded from the ACDs to a Cisco Webview Application every 30 minutes.  The Cisco Webview Application is a vendor-supplied application that maintains and produces reports on the call data recorded by the ACDs on a real-time basis.
Every 60 minutes, the Office of Telephone Services (OTS) Voice Network Team (VNT) downloads the system generated reports of the call data from the Cisco Webview Application into spreadsheets for the recording and tracking of the hourly and year to date (YTD) ASA calculation.  The ACDs automatically calculate the YTD ASA calculation.  By tracking the ASA, SSA is able to manage the National 800-Number Network through internal forecasting projections.

Performance Indicator Calculation

“Answer Wait Times of All Calls” is defined as the cumulative wait times from calls being placed in queue waiting for agent assistance.  “All Calls Answered by Agents”is defined as the cumulative number of calls that were answered by agents.  For additional details on the calculation of this performance indicator, please refer to the flowcharts in Appendix C.

Optimize the 800-Number Agent Busy Rate

If the call queues are filled to capacity and there are no available agents to handle the incoming call, the caller receives a busy message.  A busy message is a voice announcement that informs the caller that the system is filled to capacity and asks the caller to call back at a later time.  The performance indicator measures the ABR based upon the number of calls that receive busy messages. 

The vendor supplied ICM application monitors the system capacity to ensure that all calls are getting through to the National 800-Number Network.  When the system is operating at full capacity and there is no available agent or queue space, the ICM routes the call to the network Menu Routing System (MRS) platform which tells the Voice Response Unit (VRU) to play a busy message that instructs the caller to call back at a later time.  The ICM records the call data for the calls receiving the busy messages.  The call data is downloaded from the ICM to the Cisco Webview Application
every 30 minutes.  Every 60 minutes, the OTS VNT downloads the call data from a Cisco Webview Application into spreadsheets for the recording and tracking of the ABR.  The OTS VNT performs the calculation for the ABR based upon the call data downloaded from the Cisco Webview application.  The OTS VNT compiles the cumulative daily ABR to calculate the YTD ABR which is ultimately reported in the PAR. 

Performance Indicator Calculation

“Number of Busy Messages” is defined as the number of blocked calls in the network that generate a busy message to the caller.  “Number of Calls Offered to Agents” is defined as the number of callers that requested an agent.  For additional details on the calculation of this performance indicator, please refer to the flowcharts in Appendix C.

Findings

Internal Controls and Data Reliability

reliability of the data produced from the Verizon systems.  Finally, Verizon did not provide SSA with adequate control attestation documentation (such as a Statement of Auditing Standards #70 report) to provide SSA management, or the auditor, assurance that the controls related to the performance indicator data were adequately designed and operating effectively.  As a result, PwC was not able to conclude on the reliability of the data that was used to calculate these performance indicator results.  SSA management concurred with this finding, and is currently working with Verizon to request that a Statement of Auditing Standards #70 report be provided.

SSA management informed PwC that they had performed extensive testing on the Verizon ACDs and ICMs during the installation of the CCNS architecture for the National 800-Number Network in 2001.  Management performed this testing to ensure the Verizon systems were accurately recording all of the pertinent call information; including total call times, ABRs, and caller wait times.  However, SSA management stated that the results of this testing were not retained beyond 3 years following installation of the CCNS architecture.  

Data Retention

The Cisco Webview Application system generated reports were maintained by OTS
for 180 days.  However, at the time of our request, the call data and reports had been deleted from the OTS systems.  PwC was informed that the call data that was deleted from the OTS systems were also stored on the SSA mainframe.  However, SSA management stated that the call data maintained on the SSA mainframe was not saved in a format that could be used by the auditor in recalculating the performance indicators, and that management was unable to provide the data to PwC.  As a result, PwC was unable to recalculate the performance indicator results, and could not verify the accuracy of results presented in the PAR.  It should be noted that SSA management is currently working on a project to save the data to the SSA mainframe in a format that will be usable by management and auditors. 

Accuracy of PAR Presentation and Disclosure

agent answered the call.  If the caller did not receive an announcement of their estimated wait time in queue, the ACD recorded the call as going straight to the agent without waiting in queue. 

SSA management stated that the ACDs were set to provide the caller with an estimated wait time for those incoming calls that were estimated to be answered by agents in greater than 1 minute.  The ACDs automatically estimated the queue wait times based upon agent availability and queue capacity.  Our research revealed that this calculation was commonly used in call center measurements.  Although PwC recognized that this calculation methodology was valid and in-line with call center industry standards, the definition as currently stated in the PAR did not accurately define how SSA calculated the ASA, and could cause the reader to reach the inappropriate conclusion.  SSA management concurred with this finding, and is currently updating the data definition for this indicator.

In addition, we noted that the linkage in the PAR between the ASA performance indicator and the indicator "Percent of individuals who do business with SSA rating the overall service as ‘excellent’, ‘very good’, or ‘good’" could be improved.  This performance indicator is a compilation of three separate service delivery options to the public:  800 number service, field office telephone service, and office visits.  SSA had made numerous technological enhancements to the National 800-Number Network in efforts to improve the service to the public.  As such, there have been “very favorable ratings they received for their courtesy, helpfulness, job knowledge and the clarity of their explanations.”   This link would complement the ASA performance indicator by informing the reader that the Agency is committed to continuous improvements, and that 85 percent of the public was satisfied with their interactions with SSA via the various service delivery options.  By excluding a reference to this complementary indicator, the reader may not develop a complete understanding of the relatively high level of public satisfaction through interactions with SSA.

RECOMMENDATIONS

For the performance indicators included in this report, we recommend SSA:

1. Work with Verizon to request access to systems for verification and/or adequate control attestation documentation (such as a Statement of Auditing Standards #70 report) be provided to SSA management.
   
   
2. Perform ongoing control tests related to the generation, storage, and calculation of performance indicator data.  These tests should be designed to ensure the data used to calculate the results of the performance indicators are complete, accurate, valid, and that access to the data is appropriately restricted.

3. Retain all documentation related to the testing procedures and results of those tests of the control environment related to the performance indicator data.

4. Archive the Cisco Webview Application source data used in calculating the performance indicator results and populating the internal management reports.  Additionally, call data maintained on the SSA mainframe should be kept in a usable format to provide support for the indicator results reported in the PAR.

Specific to the performance indicator, “Optimize the Speed in Answering 800-Number Calls,” we recommend SSA:

5. Revise the performance indicator data definition in the PAR so it more accurately reflects what is being measured specific to when call wait time calculations begin and end.

6. Include a narrative linkage in the description of this indicator to the “Percent of people who do business with SSA rating the overall service as ‘excellent’, ‘very good’, or ‘good’” performance indicator in the PAR.

Agency Comments

The Agency agreed with all of the recommendations.  The Agency’s comments are included in Appendix D.

Appendices

APPENDIX A – Acronyms

APPENDIX B – Scope and Methodology

APPENDIX C – Process Flowcharts

APPENDIX D – Agency Comments

Appendix A
Acronyms

Appendix B - Scope and Methodology

We updated our understanding of the Social Security Administration’s (SSA) Government Performance and Results Act (GPRA) processes.  This was completed through research and inquiry of SSA management.  We also requested SSA to provide various documents regarding the specific programs being measured as well as the specific measurement used to assess the effectiveness and efficiency of the related program. 

Through inquiry, observation, and other substantive testing, including testing of source documentation, we performed the following:

• Reviewed prior SSA, Government Accountability Office, Office of the Inspector General and other reports related to SSA’s GPRA performance and related information systems.
• Reviewed applicable laws, regulations and SSA policy.
• Met with the appropriate SSA personnel to confirm our understanding of the performance indicator. 
• Flowcharted the process.  (See Appendix C).
• Tested key controls related to manual or basic computerized processes (e.g., spreadsheets, databases, etc.).
• Conducted and evaluated tests of the manual controls within and surrounding each of the critical applications to determine whether the tested controls were adequate to provide and maintain reliable data to be used when measuring the specific indicator.
• Identified attributes, rules, and assumptions for each defined data element or source document.
• Recalculated the metrics of key performance indicators to ensure mathematical accuracy.
• For those indicators with results that SSA determined using computerized data, we assessed the completeness and accuracy of that data to determine the data's reliability as it pertains to the objectives of the audit.

As part of this audit, we documented our understanding, as conveyed to us by Agency personnel, of the alignment of the Agency’s mission, goals, objectives, processes, and related performance indicators.  We analyzed how these processes interacted with related processes within SSA and the existing measurement systems.  Our understanding of the Agency’s mission, goals, objectives, and processes were used to determine if the performance indicators appear to be valid and appropriate given our understanding of SSA’s mission, goals, objectives and processes.

We followed all performance audit standards in accordance with generally accepted government auditing standards.  In addition to these steps, we specifically performed the following to test the indicators included in this report:

Optimize The Speed in Answering 800-Number Calls

• Performed a walkthrough of the download process from the Cisco Webview Application to the electronic spreadsheets for the recording and tracking of the Average Speed of Answer (ASA).
• Inspected access permissions to the reports maintained in the Office of Telephone Services (OTS) Voice Network Team (VNT) folder on the shared drive.
• Conducted test calls to the SSA National 800-Number Network to assess the accuracy and completeness of the call data being recorded by the Automatic Call Distributor (ACD) systems.
• Inquired about the testing performed on the vendor supplied ACD systems.
• Inspected the Verizon FTS2001 Contract to understand the system specifications for the service being provided.

Optimize The 800-Number Agent Busy Rate

• Performed a walkthrough of the download process from the Cisco Webview Application to the electronic spreadsheets for the recording, tracking and calculation of the Agent Busy Rate (ABR).
• Inspected access permissions to the reports maintained in the OTS VNT folder on the shared drive.
• Inquired about the testing performed on the vendor supplied Intelligent Contact Manager (ICM) application.

Appendix C - Process Flowchart for 800-Number Access

-- IMAGE OMITTED IN THIS TEXT-ONLY VERSION --

Legend -

• Start of the 800-Number Access flow process:  This is represented by the white boxes.  The process is the same for the Optimize the Speed of Answering 800-Number Calls and Optimize the 800-Number Agent Busy Rate performance indicators.
• Optimize the Speed of Answering 800-Number Calls:  This process is represented by the gray shaded boxes.  Refer to the flowchart details on pages C-2 and C-3.
• Optimize the 800-Number Agent Busy Rate:  This process is represented by the peach shaded boxes.  Refer to the flowchart details on pages C-4 and C-5.

Flowchart of Optimize the Speed of Answering 800-Number Calls - Process Flowchart (Data Path)

-- IMAGE OMITTED IN THIS TEXT-ONLY VERSION --

Flowchart of Optimize the Speed in Answering 800-Number Calls – Narrative

• Caller dials into the Social Security Administration (SSA) 800-Number Network.
• Caller hears greeting and service selection announcements.
• Caller selects the automated services.

• Yes – Transaction processed by automated service selected.
• No – Caller’s call is offered to an agent.

• Agent available.

• Yes – The caller is routed to an agent.
• Agent answers the call. 

• No – Queue available.

• No – Caller receives busy message.
• Yes – Caller is placed in queue.  Start calculation of wait times
• Caller waits for an agent.
• No – Caller disconnects.
• Yes – Caller routed to agent
• Agent answers the call.  End calculation of wait times

• The ASA call data is recorded in the ACD systems.
• The ASA call data is transferred to the Cisco Webview Application every 30 minutes.
• Office of Telephone Services (OTS) VNT extracts the daily data for ASA every 60 minutes.
• OTS VNT compiles the YTD ASA data.
• Information sent to OCSO to be reported in the PAR.
• Data reported in the PAR.

Flowchart of Optimize the 800-Number Agent Busy Rate - Process Flowchart (Data Path)

-- IMAGE OMITTED IN THIS TEXT-ONLY VERSION --

Flowchart of Optimize the 800-Number Agent Busy Rate – Narrative

• Caller dials into the SSA 800-Number Network.
• Caller hears greeting and service selection announcements.
• Caller selects the automated services.
• Yes – Transaction processed by automated service selected.
• No – Caller’s call is offered to an agent.
• Agent available.
• Yes – The caller is routed to an agent.
• Agent answers the call. 
• No – Queue available.
• No – Caller receives busy message.
• The ABR call data is recorded in the ICM application.
• The ABR call data is transferred to the Cisco Webview Application every 30 minutes.
• OTS VNT extracts the daily data for ABR every 60 minutes.
• OTS VNT calculates the daily ABR.
• OTS VNT compiles the YTD ABR data.
• Information sent to OCSO to be reported in the PAR.

Data reported in the PAR.

Appendix D - Agency Comments

SOCIAL SECURITY

We appreciate OIG’s efforts in conducting this review.  Our comments on the draft report’s recommendations are attached.

Please let me know if you have any questions.  Staff inquiries may be directed to
Ms. Candace Skurnik, Director, Audit Management and Liaison Staff, at extension 54636.

Attachment:
SSA Response

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL’S (OIG) DRAFT REPORT, “PERFORMANCE INDICATOR AUDIT: 800 NUMBER ACCESS”
(A-02-06-16108)

Thank you for the opportunity to review and provide comments on this draft report. 

Recommendation 1

Work with Verizon to request access to systems for verification and/or adequate control attestation documentation (such as a Statement of Auditing Standards #70 report) be provided to SSA management.

Comment

We agree.  We will address this issue in the technical specifications of the next procurement, which will be in fiscal year (FY) 2007.

Recommendation 2

Perform ongoing control tests related to the generation, storage, and calculation of performance indicator data.  These tests should be designed to ensure that data used to calculate the results of the performance indicators are complete, accurate, valid, and that access to the data is appropriately restricted.

Comment

We agree.  We will address this issue in the technical specifications of the next procurement, which will be in FY 2007.

Recommendation 3

Retain all documentation related to the testing procedures and results of those tests of the control environment related to the performance indicator data.

Comment

We agree.  We will address this issue in the technical specifications of the next procurement, which will be in FY 2007.

Recommendation 4

Archive the Cisco Webview Application source data used in calculating the performance indicator results and populating the internal management reports.  Additionally, call data maintained on the SSA mainframe should be kept in a usable format to provide support for the indicator results reported in the Performance and Accountability Report (PAR).

Comment

We agree.  Currently the Cisco Webview Application source data is already archived on the SSA mainframe.  Regarding the need to have the call data maintained in a usable format, we will improve the tracking mechanism used to capture performance data so that third-parties can easily retrieve and analyze data.

Recommendation 5

Specific to the performance indicator, “Optimize the Speed in Answering 800-Number Calls,” revise the performance indicator data definition in the PAR so it more accurately reflects what is being measured specific to when call wait time calculations begin and end.

Comment

We agree.  We have revised the definition of “answer wait time” which will be included in the Agency’s FY 2007-2008 Annual Performance Plan and reported in the FY 2007 PAR:

The answer wait time of all calls divided by the number of all calls answered by
agents - Wait time begins from the time the call is placed in queue and ends when
an agent answers.  Calls that go straight to an agent without waiting in the queue
have a zero wait time but are included in the average speed of answer (ASA)
calculation.  ASA does not include callers who hang up after being in queue. 

Recommendation 6

Specific to the performance indicator, “Optimize the Speed in Answering 800-Number Calls,” include a narrative linkage in the description of this indicator to the “Percent of people who do business with SSA rating the overall service as “excellent,” “very good,” or “good”” performance indicator in the PAR.

Comment

We agree.  We will include this linkage in the FY 2006 PAR.

Overview of the Office of the Inspector General
The Office of the Inspector General (OIG) is comprised of our Office of Investigations (OI), Office of Audit (OA), Office of the Chief Counsel to the Inspector General (OCCIG), and Office of Resource Management (ORM).  To ensure compliance with policies and procedures, internal controls, and professional standards, we also have a comprehensive Professional Responsibility and Quality Assurance program.

Office of Audit
OA conducts and/or supervises financial and performance audits of the Social Security Administration’s (SSA) programs and operations and makes recommendations to ensure program objectives are achieved effectively and efficiently.  Financial audits assess whether SSA’s financial statements fairly present SSA’s financial position, results of operations, and cash flow.  Performance audits review the economy, efficiency, and effectiveness of SSA’s programs and operations.  OA also conducts short-term management and program evaluations and projects on issues of concern to SSA, Congress, and the general public.

Office of Investigations
OI conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement in SSA programs and operations.  This includes wrongdoing by applicants, beneficiaries, contractors, third parties, or SSA employees performing their official duties.  This office serves as OIG liaison to the Department of Justice on all matters relating to the investigations of SSA programs and personnel.  OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.

Office of the Chief Counsel to the Inspector General
OCCIG provides independent legal advice and counsel to the IG on various matters, including statutes, regulations, legislation, and policy directives.  OCCIG also advises the IG on investigative procedures and techniques, as well as on legal implications and conclusions to be drawn from audit and investigative material.  Finally, OCCIG administers the Civil Monetary Penalty program.

Office of Resource Management
ORM supports OIG by providing information resource management and systems security.  ORM also coordinates OIG’s budget, procurement, telecommunications, facilities, and human resources.  In addition, ORM is the focal point for OIG’s strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act of 1993.

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