June 2003




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.


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.


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.


Date: June 23, 2003

To: The Commissioner

From: Inspector General

Subject: Best Practices in Federal Paper Records Management (A-04-03-13030)


The objective of our review was to identify best practices that may enable the Social Security Administration (SSA) to enhance its paper records management.


Recent technological advances, budget cuts, and other events have significantly impacted Federal records management. In today's business environment, a Federal agency's success or failure can depend on how well it manages its records.

The Federal Records Act of 1950, as amended, established the framework for records management programs in Federal agencies. Federal law "requires [t]he head of each Federal agency…[to] make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of the agency and designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities." The National Archives and Records Administration (NARA) is responsible for assisting Federal agencies in maintaining adequate and proper documentation of Government policies and transactions.

SSA's Records Officer, who heads the Records Management Team (RMT), is responsible for planning, directing, administering and evaluating the Agency's records management program. To assist the Records Officer, SSA has designated Records Management Coordinators at central and regional offices. These coordinators act as liaisons for records management activities between their offices and the Records Management Team.


This review is aimed at enhancing SSA's paper records management and focuses on best practices used by those Federal agencies that are in the forefront of records management. We visited the following three agencies to obtain knowledge and observe their paper records management practices:

the Central Intelligence Agency (CIA),

the Federal Deposit Insurance Corporation (FDIC), and

the National Labor Relations Board (NLRB).

We selected these agencies because records management experts from NARA and a member of the Federal Information and Records Managers Council recognized them as having best practices in paper records management.

We performed our work at SSA Headquarters in Baltimore, Maryland, the Southeastern Program Service Center and field office in Birmingham, Alabama, and selected Federal agencies in Washington, D.C. We conducted our review from September through November 2002 in accordance with generally accepted government auditing standards. See Appendix A for a more complete description of our scope and methodology.


Although the Government, as a whole, is generally successful in searching for and retrieving its paper records, this process can require substantial effort and resources. Despite its move toward electronic records storage, SSA continues to be responsible for millions of paper files. SSA is working to improve its management of paper records. The best practices we identified in the Government sector have the potential for use in

SSA's records management operations. For example, SSA may be able to improve its paper records management through the following.

Active Records Management that ensures maximum oversight authority, sufficient resources, and adequate technical expertise.

Quality Control and Monitoring of records management via on-site reviews.

Centralized Storage and Automated Tracking System to measure the timeliness of folder movement.

Training program on detailed records management.

NARA's Targeted Assistance Program for assistance in planning and implementing new records initiatives.


In December 2001, SRA International, Inc., (SRA) reported on recordkeeping perceptions and practices at selected Federal agencies. Overall, SRA reported that the character and quality of records management varied significantly across-and within-agencies. SRA noted that, despite the explosive growth in electronic records, paper remains the primary format for preserving records Governmentwide. Although the Government is generally successful in searching for and retrieving paper records, the process requires substantial resources. SRA determined that the best recordkeeping practices tended to exist for case files since they have a well-defined, business-related purpose. Similarly, agencies with good, conscientious records management programs recognize that poor records management can lead to adverse legal judgments, unwanted legislation, and/or public embarrassment.


SSA's case folder volume poses significant challenges for the Agency. SSA houses over 35 million folders, many of which are used by operating components nationwide. Although SSA is moving toward electronic records storage, it will continue to be responsible for millions of paper files. Appendix B provides an overview of SSA's record storage and retrieval processes. Like other Federal agencies, SSA has many competing business priorities that affect the resources available to ensure effective records management. Nevertheless, ineffective records management practices can harm Agency operations as well as beneficiaries who rely on SSA.

PricewaterhouseCoopers LLP, in its audits of SSA's financial statements for Fiscal Years 1998 through 2000, underscored the importance of case files to SSA's operations and recommended the Agency continue with such initiatives as electronic imaging. Until such imaging is in place, PricewaterhouseCoopers recommended SSA enhance its process for tracking and securing case files. Similarly, we have stressed the importance of good case folder management and recommended that SSA increase its oversight of records management contractors.


The Federal agencies we reviewed recognize that lost or untimely retrieved records undermine an agency's integrity and impair its ability to achieve its mission. As a result, these agencies follow practices that result in efficient and effective paper records management. We particularly noted that the Federal agencies we contacted have benefited by adopting the five best practices identified in Table 1.

Table 1: Best Practices

We acknowledge that SSA management endorses and has implemented some aspects of these practices and are encouraged that SSA continues to refine and improve its records management. Records managers we contacted emphasized that management's commitment to sound records operations is essential for the successful implementation of these practices.

Records managers from the agencies we contacted emphasized that their components must provide oversight throughout the records' life cycle, which includes the creation, maintenance, and disposition of paper records. These agencies also recommended that records management closely coordinate with operations personnel in planning new initiatives, developing records retention schedules, and managing records stored in off-site locations.

Federal law requires that Federal agencies establish and maintain an active, continuing program for managing its records. Moreover, a records program must provide for effective controls over the creation, maintenance, and use of records in conducting business. Although Federal law and agency policies require sound records management, the successful implementation of such practices is still elusive for many agencies.

In its December 10, 2001 Report on Current Recordkeeping Practices Within the Federal Government, SRA maintained that the quality of records management is heavily influenced by the degree to which an agency's records officer and staff are involved in their agency's principal business programs. However, the perception of records management personnel is that integration between records management and the business processes of many agencies is distinctly lacking.

Although records management typically receives a low priority, problems in this area can have serious implications for an agency. For example, in the Oklahoma City bombing investigation, it became evident that the Federal Bureau of Investigation (FBI) had problems in its records management system. After acknowledging the problem, the FBI responded by becoming proactive in its records management oversight. The management initiatives the FBI implemented include the following.

Creating a Records Management Division to ensure executive direction and full-time oversight of all records policy and functions.

Consolidating all records operations to ensure consistency, thoroughness and accountability.

Retraining every employee on proper document production, maintenance and handling procedures.

Modernizing its information technology system by moving toward a near paperless electronic case file.

The quality control plan outlined by an agency's records management team should be continually monitored. The agencies we contacted practiced effective quality control and monitoring. To illustrate, one agency described how it routinely visited its off-site storage locations to audit its contractor's procedures. Also, this agency monitored the quantity of records created, the response time for providing records and the number of records destroyed or sent to the National Archives.

Federal regulations state that agency records management programs should provide for periodic internal evaluations. These evaluations, among other things, should assess the effectiveness of the agency's records management program. NARA personnel stressed quality control should not be regarded as a "one time fix." Instead, systems and processes must be constantly observed and refined to maintain and improve an agency's records management program. One of the Federal agencies we reviewed, as part of its quality control program, revalidated its record inventory every 2 years at the central storage facility and satellite locations.

When an agency fails to implement an effective quality control and monitoring program, there can be negative consequences. Again, we refer to the FBI's Oklahoma City bombing investigation. The agency belatedly discovered over 3,100 pages of records it failed to provide to defense lawyers during the Oklahoma City bombing trial. An Inspector General's investigation attributed the missing documents in part to inadequate quality control systems. As a result, the FBI implemented new quality control policies and procedures.

The agencies we contacted managed their records using centralized storage facilities to minimize case folder movement and the risk of lost records. While some situations necessitate case folder movement, such as legal proceedings, the agencies strive to keep official records at one or two locations. In its December 2001 report, SRA stated one factor that indicated good records management was whether an agency managed its records in a centrally coordinated manner. Agencies in SRA's study that centrally coordinated the management of their records appeared to be able to locate their records better than agencies that managed their records in a decentralized manner. The records managers we talked with emphasized that (1) minimizing file movement is critical in maintaining effective records operations and (2) centralized storage is essential to minimizing file movement.

Agencies we contacted also used automated record tracking systems in conjunction with centralized storage facilities. These systems allow agencies to determine (1) the location of a record at any time, (2) whether the case is active or archived, and (3) how long it takes to retrieve and deliver a folder to the user. To facilitate data entry into their automated tracking systems, the agencies implemented bar-coding systems. The Agencies bar-coded their records and installed bar-code reading devices at their storage facilities and at user locations throughout the agency. The bar-coded records are scanned at the centralized storage facility as well as the agency components to record every receipt and transfer of records.

A benefit of logging the receipt of a folder at an agency component is that, when a record is sent to a wrong location, it can be quickly identified and forwarded to its intended destination. One of the agencies we contacted tracked how long folders were "checked out" of the central storage facility and followed up on outstanding folders. Another agency endorsed the concept of producing an "aging" report to measure response times in the folder retrieval process. The Records Manager at this agency stated monitoring and responding to an aging report is "not unlike a librarian checking on overdue books."

To minimize case folder movement, one of the agencies we contacted used an electronic database that enabled the user to search abstracts of certain records for relevant information. The record abstract is described as a list of key words and information, such as names, biographical information, and critical decision data. The agency used optical character recognition technology to generate the abstract from the paper record. The abstract enables the user to obtain key information without physically retrieving the folder.

The Federal agencies we contacted stressed the importance of adequately trained staff in achieving and maintaining an efficient and effective paper records handling process. For example, one of the actions the FBI took to improve its records management program was to retrain employees on proper document production, maintenance and retrieval/handling procedures. One of the agencies we contacted had a detailed records management training plan that included:

orientation to records management concepts and agency procedures,

rotation of job duties to give employees the opportunity to experience all facets of the records operations,

suggested courses of study for records industry certifications,

developmental plans tailored to the employees' needs,

provisions for membership in professional records management organizations, and

mechanisms for measuring the skills and knowledge related to records operations.

Training employees reduces the risk of errors and helps ensure consistency in the application of agency policies and procedures.

One Federal agency we contacted strongly endorsed using NARA's expert guidance and assistance in designing and refining Federal records management systems. In particular, this agency encouraged participation in NARA's Targeted Assistance program. This program forms a partnership between NARA and Federal agencies to address paper and electronic records management issues. As part of this service, NARA coordinates with an agency's records management staff to provide effective training of operations personnel.

In its December 2001 report, SRA stated the level of communication and interaction between agencies and NARA influenced the quality of agency records management, particularly in the area of records retention scheduling. NARA implemented the Targeted Assistance program to better meet agencies' needs and assist those agencies in transitioning from a paper-based to an electronic record management system. Federal agencies nationwide participate in the Targeted Assistance program, and NARA has over 200 ongoing projects with these agencies.

We believe the best practices identified in this report may enhance SSA's paper records management. The success realized by the agencies we contacted warrants SSA's consideration of these best practices. Additionally, we recognize it may not always be practical or cost-beneficial to implement the best practices of other organizations. Therefore, as part of its evaluation process, SSA should determine whether it will benefit from adopting any or all of these practices. We have matched these best practices to our understanding of SSA's operations and have identified several potential applications that we believe management should consider. Therefore, we recommend that SSA consider the following.

1. Re-evaluate the organizational placement of its Records Officer and team to ensure maximum oversight authority, sufficient resources, and adequate technical expertise, such as representation of systems personnel.

2. Incorporate reviews of record management controls into its Onsite Security Control and Audit Review Program.

3. Enhance its automated tracking systems by producing reports to track the timeliness of folder movement, how long a folder has been with a user, and any other folder movement anomalies.

4. Create electronic record abstracts that would contain a synopsis of critical document information that could be used in lieu of obtaining the paper case folder, allowing users to quickly obtain needed information and minimizing case folder movement.

5. Increase coordination with NARA in the planning and implementation of new paper or electronic record initiatives.


SSA generally agreed with Recommendations 2, 3, and 5. With regards to Recommendation 1, SSA stated that the RMT has an active role in all Agency system initiatives and works closely with staff on paper and electronic records issues. Therefore, SSA believes the organizational placement of the RMT is correct. In response to Recommendation 4, SSA stated that electronic record abstracts would have limited value and may have significant costs. The full text of SSA's comments is included in Appendix C.


We appreciate SSA's consideration of the RMT's organizational placement. We encourage SSA to periodically monitor the team to ensure it has the proper oversight authority, sufficient resources, and adequate technical expertise.

We continue to believe that electronic record abstracts would be beneficial for both SSA's paper and electronic records processes. One Federal agency we visited applied the best practice of electronic abstracts to both paper and electronic records, which improved its records retrieval process. An electronic abstract is beneficial because it condenses a lengthy document into key points and enables the user to access information in a timely manner without having to retrieve or search an entire case folder or electronic record. We urge SSA to explore the benefits of electronic abstracts as it transitions to the electronic folder. We also encourage SSA to consider the benefits of abstracts as it creates new paper records.

James G. Huse, Jr.


APPENDIX A - Scope and Methodology

APPENDIX B - The Social Security Administration's Records Storage and Retrieval

APPENDIX C - Agency Comments

APPENDIX D - OIG Contacts and Staff Acknowledgments

Appendix A

Scope and Methodology

To meet our objective, we performed the following steps.

Obtained an understanding of the Social Security Administration's (SSA) paper records processes and basic business functions. We interviewed records management and operational components at SSA's Central Office and personnel at the Southeastern Program Service Center and Birmingham, Alabama, field office.

Interviewed leading experts in the field of records management to identify Federal agencies that were successful in the area of records management.

Visited three Federal agencies to obtain knowledge of, and observe, their record management practices. See Table 1 for the agencies and brief descriptions of their missions.

Determined whether the best practices we identified were potentially beneficial to SSA, by either enhancing procedures already in place or implementing new procedures.

Table 1: Description of Agencies Contacted

Agency Mission
Central Intelligence Agency (CIA) The CIA's mission is to support the President, the National Security Council, and all who make and execute U.S. national security policy. The CIA accomplishes this by providing accurate, evidence-based, comprehensive, and timely foreign intelligence related to national security and conducting counterintelligence activities, special activities, and other functions related to foreign intelligence and national security as directed by the President.

Federal Deposit Insurance Corporation
(FDIC) The FDIC's mission is to maintain the stability of, and public confidence in, the Nation's financial system. The FDIC was created in 1933 to insure deposits and promote safe and sound banking practices.

National Labor Relations Board (NLRB) The NLRB is an independent Federal agency created in 1935 to enforce the National Labor Relations Act. The agency investigates and attempts to remedy unfair labor practices by employers and unions.

Appendix B

The Social Security Administration's Records Storage and Retrieval Processes

In administering its Old-Age and Survivors Insurance (OASI), Disability Insurance (DI), and Supplemental Security Income (SSI) programs, the Social Security Administration (SSA) uses paper and on-line electronic systems to document its customer applications. SSA retains applicant information in paper folders and master electronic files. The Agency's policies, procedures and standards for records retention and disposition are in its Administrative Instructions Manual System.

In general, SSA components need case folders to handle a variety of actions that affect eligibility and/or payment amounts. Case folders typically contain detailed information about individual's earnings and financial resources. In processing DI claims, SSA personnel rely on medical and earnings information contained in potentially large paper folders. Folders for DI claims may move between SSA offices depending on the stage of the claims process-initial claim, appeal, and continuing disability review.

SSA components request case folders through automated systems. As an option to requesting the entire case folder, they can request SSA personnel at the storage location to extract and send the needed information. If this is not practical, the case folder is mailed. SSA stores over 35 million case folders at 3 facilities. Although these are SSA facilities, private contractors provide for the day-to-day operations. The facilities and a brief description of their storage responsibilities are below.

The National Records Center in the Kansas City region stores OASI and DI awards for individuals age 55 and older and maintains about 25 million folders.

The Office of Central Operation's Megasite in Woodlawn, Maryland, stores OASI and DI awards for individuals below age 55 and maintains between 5 and 10 million folders.

The Folder Servicing Operation in Wilkes-Barre, Pennsylvania, stores SSI awards, and maintains between 4 to 5 million folders.

SSA also stores folders in Federal Records Centers (FRC) operated by the National Archives and Records Administration. The FRCs store folders that have the lowest activity (for example, disability denials where no appeal is anticipated) and SSI material received after the initial award.

As of the time of this audit, SSA scanned OASI documents and made these available to employees in electronic format. SSA is developing an electronic business process for disability claims, with the implementation goal of Calendar Year 2004.

Appendix C

Agency Comments


MEMORANDUM 32239-24-956

Date: May 13, 2003

To: James G. Huse, Jr.
Inspector General

From: Larry W. Dye /s/
Chief of Staff

Subject: Office of the Inspector General (OIG) Draft Management Advisory Report, "Best Practices in Federal Paper Records Management" (A-04-03-13030)-INFORMATION

We appreciate the OIG's efforts in conducting this review. Our comments on the report content and recommendations are attached.

Please let us know if we can be of further assistance. Staff questions can be referred to
Trudy Williams on extension 50380.

SSA Response


Thank you for the opportunity to review and comment on the subject draft report. Within SSA, our records management policies and procedures are consistent with the National Archives and Records Administration (NARA). These policies and procedures are defined in the Administrative Instructions Manual System (AIMS) Guidelines, Records Management Handbooks, in the Records Retention Schedules and by our Records Management Coordinators (RMC) who are located in all major components nationwide. The policies, retention schedules and a list of all RMCs are available to all SSA employees via SSA's Digital Library. In addition, as part of our ongoing efforts to ensure proper records management, the RMCs and members of SSA's Records Management Team (RMT) randomly select and visit at least five sites each year. The site visit reports identify deficiencies and stipulate the corrective measures to be taken. In addition, the RMT is working with other SSA components to expand its audits/reviews of records management practices throughout the Agency.

In addition to the ongoing records management program elements described above, an SSA intercomponent steering committee was formed to oversee all projects related to SSA's transition to an electronic-folder. The groups' charter calls for the development of a vision and timeframe for the transition from paper folders to electronic folders and to ensure that the myriad of initiatives are integrated. The key initiatives fall in seven broad categories including Claims Folder Content, Electronic Signature, Authentication, Retention Schedules, Electronic Forms, Internet Applications and Privacy & Access. The Operational Records Management Initiatives/Procedures Committee briefed the Commissioner in February 2003 and will continue to report to her as the initiatives develop.
Finally, we have the E-Records Management Initiative whose purpose is to fulfill one of the primary directives in the President's Management Agenda focusing on "e-Government." SSA's Chief Information Officer chairs the workgroup that reports on all e-Government activities within SSA.

Our responses to the specific recommendations are provided below.

Recommendation 1
SSA should re-evaluate the organizational placement of its Records Officer and team to ensure maximum oversight authority, sufficient resources, and adequate technical expertise, such as representation of systems personnel.

SSA Comment
We disagree. We recognize that records management issues have increased in complexity in recent years as more and more of the Agency's records move from paper to electronic format. The Agency's RMT has an active role in all major Agency systems initiatives, including projects such as the Commissioner's Assignment and Correspondence Tracking System and AeDIB. The RMT ensures that all records-related guidance and directives provided by NARA are followed and works closely with staff within the Agency to address all paper and electronic records issues. We believe the organizational location of the RMT is correct.

Recommendation 2
SSA should incorporate reviews of record management controls into its Onsite Security Control and Audit Review (OSCAR) program.

SSA Comment
We partially agree. In addition to the field surveys conducted by the RMC and the RMT described above, we plan to expand reviews of records management in the field offices and are considering using the OSCAR to elicit information on records management practices from 10 to 20 percent of SSA's field offices.

Recommendation 3
SSA should enhance its automated tracking systems by producing reports to track the timeliness of folder movement, how long a folder has been with a user and any other folder movement anomalies.
SSA Comment

We partially agree. The Processing Center (PC) users already have the ability to obtain this information and produce reports by using the offline parametric searches of the Processing Center Action Control System (PCACS). For instance, PCs can track folder records by a specific component (e.g., Module 1), function (e.g., Claims Authorizer) and station within each site. Based on this tracking, specifics such as the age and/or Social Security Number range or terminal digit can be obtained. In addition, record element conditions such as record type descriptors, folder listing codes or Federal Record Center codes can be identified. Date elements such as current site date or hold date can also be extracted from this parametric capability. The PCs also have various sort options from site age to terminal digit. Output options, such as counts only, full or standard queries as well as scheduling and report frequency, are also available for the sites to customize their reports. Processing Center number seven, located in the Office of Disability Operations, uses the offline parametric report to account for all folder control records reading in location Auxiliary Rolling Heights, Files-In, Files-In (AUXRH FIN FIN) with a special event indicator of AGE 59. We will encourage the PCACS users to make use of these reports to track folder movement and anomalies.

Recommendation 4
SSA should create electronic record abstracts that would contain a synopsis of critical document information that could be used in lieu of obtaining the paper case folder, allowing users to quickly obtain needed information and minimizing case folder movement.

SSA Comment
We disagree. The PCs process approximately 80 percent of their actions in a paperless environment. SSA is currently developing an electronic disability process that will use an electronic folder in lieu of paper folders and will eventually eliminate the need to handle, store and ship paper folders.

It appears the single additive benefit of this recommendation to electronic transfer of scanned materials could be realized only if such abstracts were available to a user up front to determine if the needed information is in fact in the file before requesting the scanning of the materials. However, it is not clear from the report if OIG is recommending that SSA create electronic abstracts for new files from a point in time forward, create abstracts for all existing files or create abstracts for files only when retrieval is requested. Depending on the intent, this recommendation could have significant associated costs.

Recommendation 5
SSA should increase coordination with NARA in the planning and implementation of new paper or electronic record initiatives.

SSA Comment
We agree and have been working very closely with NARA over the past several months. NARA representatives have made a number of site visits and have assisted us in drafting new records schedules, including the new "Claims Processing System Schedule" which addresses electronic initiatives, including AeDIB.

Appendix D

OIG Contacts and Staff Acknowledgments
OIG Contacts
Mark Bailey, Director, (816) 936-5591
Frank Nagy, Deputy Director, Atlanta OA (404) 562-5552

Staff Acknowledgments
In addition to those named above:
Charles Lober, Senior Auditor
David McGhee, Auditor
Kimberly Beauchamp, Writer/Editor

For additional copies of this report, please visit our web site at or contact the Office of the Inspector General's Public Affairs Specialist at (410) 966-1375. Refer to Common Identification Number A-04-03-13030.

Overview of the Office of the Inspector General

Office of Audit

The Office of Audit (OA) conducts comprehensive financial and performance audits of the Social Security Administration's (SSA) programs and makes recommendations to ensure that program objectives are achieved effectively and efficiently. Financial audits, required by the Chief Financial Officers' Act of 1990, assess whether SSA's financial statements fairly present the Agency's financial position, results of operations and cash flow. Performance audits review the economy, efficiency and effectiveness of SSA's programs. OA also conducts short-term management and program evaluations focused on issues of concern to SSA, Congress and the general public. Evaluations often focus on identifying and recommending ways to prevent and minimize program fraud and inefficiency, rather than detecting problems after they occur.

Office of Executive Operations

The Office of Executive Operations (OEO) supports the Office of the Inspector General (OIG) by providing information resource management; systems security; and the coordination of budget, procurement, telecommunications, facilities and equipment, and human resources. In addition, this office is the focal point for the OIG's strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act. OEO is also responsible for performing internal reviews to ensure that OIG offices nationwide hold themselves to the same rigorous standards that we expect from SSA, as well as conducting investigations of OIG employees, when necessary. Finally, OEO administers OIG's public affairs, media, and interagency activities, coordinates responses to Congressional requests for information, and also communicates OIG's planned and current activities and their results to the Commissioner and Congress.

Office of Investigations

The Office of Investigations (OI) conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement of SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, physicians, interpreters, representative payees, third parties, and by SSA employees in the performance of their duties. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.

Counsel to the Inspector General

The Counsel to the Inspector General provides legal advice and counsel to the Inspector General on various matters, including: 1) statutes, regulations, legislation, and policy directives governing the administration of SSA's programs; 2) investigative procedures and techniques; and 3) legal implications and conclusions to be drawn from audit and investigative material produced by the OIG. The Counsel's office also administers the civil monetary penalty program.