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We found that although the CFPB's Policy for Conference/Meeting Planning and Attendance identified roles and responsibilities for conference coordination and approval, it did not adequately reflect the CFPB's current process for conference activities in certain respects. For example, the policy does not define the individuals, by title, level, or position, who are authorized to coordinate conferences; it contains limited guidance for the Treasury DO and the Office of Procurement acquisition approaches; and it provides no guidance for the BPD ARC approach. In addition, we found that the policy does not include guidance provided in the Non-Academic External Training and Education Policy pertaining to the expedited approval process for training requests. The inconsistencies between policies and process are likely attributable to the dynamic nature of change at a new agency like the CFPB, and the inconsistency between the two policies related to the submission of the training requests is likely attributable to the need for enhanced coordination when implementing multiple policies in close succession. If policies and procedures do not reflect current practices, the agency may procure conferences without appropriate approval.
The Policy for Conference/Meeting Planning and Attendance does not provide clear guidance on the authority to coordinate and approve conferences. We reviewed the policy and the supporting procedures to assess the effectiveness of the internal control structure described in the materials and to evaluate whether the materials accurately reflected current conference practices. The policy identifies the roles and responsibilities of the CFPB's departmental offices and office heads as follows:
Office Heads are responsible for coordinating and approving their Office's request for a CFPB-sponsored conference or meeting consistent with this policy. CFPB office heads are also responsible for maintaining supporting documentation regarding conferences and training.
However, the policy and supporting procedures do not clearly delineate or define which employees, by title, level, or position, are considered to be office heads.
Our review of conferences planned by Treasury DO identified that individuals in a variety of positions and staff levels at the CFPB coordinated and approved conferences. For example, in our review of 10 conferences planned by Treasury DO, we identified that conferences were coordinated and/or approved by individuals in the following positions at the CFPB: Administration Operations Assistant, Director of Regional Examinations, Examiner, Supervisory Examiner, Human Resources Specialist, Training Coordinator, Senior Procurement Analyst, Supervisory Program and Management Analyst, and Budget Analyst. Because the term office heads had not been defined, we could not determine whether these conference coordinators and approvers met the standards outlined in the policy and procedures.
The Policy for Conference/Meeting Planning and Attendance does not specify the criteria for using the Treasury DO approach instead of the Office of Procurement approach. We determined that in practice, the CFPB uses the Treasury DO acquisition approach to procure agency-sponsored conferences under $25,000 and uses the Office of Procurement acquisition approach to procure agency-sponsored conferences above $25,000. The Policy for Conference/Meeting Planning and Attendance, however, does not specify the $25,000 threshold as a criterion for determining the approach to be used. Rather, the policy indicates that the Office of Procurement should be contacted if Treasury DO cannot accommodate the request to coordinate a conference. We believe that the policy should specify this monetary threshold as the determining factor for these acquisition approaches.
The Policy for Conference/Meeting Planning and Attendance does not mention the BPD ARC acquisition approach. BPD ARC has an agreement with the CFPB that authorizes it to perform procurement services on the CFPB's behalf. In practice, upon receiving a request for agency- sponsored or nonsponsored conference support, the CFPB's Office of Procurement determines whether internal resources are available to complete the procurement process; if not, the conference will be procured through BPD ARC. The Office of Procurement has the discretion to make this determination based on the availability of resources. During our evaluation, we identified nine conference contracts procured through BPD ARC. In our opinion, the conference policies should describe each of the acquisition approaches used by the agency and the determining factors for using each.
The Non-Academic External Training and Education Policy and the Policy for Conference/ Meeting Planning and Attendance require employees to complete SF-182 forms for training requests but provide inconsistent guidance as to when the SF-182 forms should be approved and submitted to the Office of Human Capital (OHC). Both policies require that forms be approved and submitted to the OHC prior to the staff member registering for the applicable conference or training. The Policy for Conference/Meeting Planning and Attendance requires that all SF-182 forms be approved and submitted to the OHC 10 days prior to the conference registration date. The Non-Academic External Training and Education Policy, however, also describes a process for expediting the approval of SF-182 forms submitted less than 10 days before the conference registration date. We believe that these policies should provide consistent guidance with respect to SF-182 form approval requirements.
The Policy for Conference/Meeting Planning and Attendance does not clearly define which employees have approval authority for conferences and does not adequately describe and provide 2013-AE-C-011 6 parameters for the four acquisition approaches. In addition, the policy does not include guidance on expedited SF-182 form approval, which is included in the Non-Academic External Training and Education Policy. Policies should be updated to ensure that the CFPB provides consistent guidance on conference activities, including (1) defining the appropriate title, level, or position of individuals responsible for conference coordination and approval; (2) identifying when to use each of the four acquisition approaches for conference coordination; and (3) consistently reflecting SF-182 form submission requirements.
We recommend that the CFO
Regarding recommendation 1, the Chief Operating Officer stated the following:
Management concurs with this recommendation and notes that, as discussed in the OIG's report, the existing conferences policy does identify the roles and responsibilities for conference coordination and approval. The Bureau is currently in the process of enhancing the conferences policy to provide additional detail regarding employees authorized to coordinate and approve conferences, meetings, and other events. The updated policy will also identify all conference acquisition approaches utilized by the Bureau and provide additional detail regarding the criteria for each approach. The Bureau will continue to revisit and update this policy periodically to reflect evolving Bureau practices in order to ensure that conference costs and activities are appropriately and efficiently utilized.
Regarding recommendation 2, the Chief Operating Officer stated the following:
Management concurs with this recommendation. Since the Bureau's launch on July 21, 2011, it has made considerable progress in developing the policies and procedures necessary to carry out its mission. As the Bureau's internal practices have evolved in scope and complexity, it periodically revisits these policies and procedures in an effort to ensure that they reflect the most up-to-date and best practices and are consistent with other Bureau policies and procedures. In addition to updating the existing conferences policy, the Bureau is simultaneously reviewing other policies and procedures related to conferences to ensure a consistent and coordinated framework. These periodic reviews will be a part of continuing efforts to update and improve the Bureau's processes.
In our opinion, the actions described by the Chief Operating Officer are responsive to our recommendations, and we plan to follow up on the CFO's actions to ensure that each recommendation is fully addressed.