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Overall, we did not identify any material discrepancies in our sample testing of conference expenses. However, our sample testing did show that the OHC has not consistently obtained conference and training certificates and affidavits from employees who attend conferences or training. The Non-Academic External Training and Education Policy requires employees to submit training certificates or affidavits to validate employee attendance at conferences and training; however, the policy does not require the OHC to conduct reviews of conference and training documentation. Inadequate recordkeeping and lack of reviews increase the risk that noncompliance with the policy will remain undetected, and instances of noncompliance may increase the risk that the CFPB could expend funds for conferences and training that employees do not attend or complete.
Employees are not consistently submitting evidence of conference attendance or training completion. The Non-Academic External Training and Education Policy requires evidence of attendance or completion in the form of a certificate of completion or a signed affidavit. With regard to employees who do not complete training or attend a conference, the policy states that
An employee must reimburse CFPB for the total cost of a learning opportunity paid for, but not successfully completed, if s/he fails to provide adequate documentation of completion to the Office of Human Capital (OHC) within 30 calendar days of the program end.
We used SF-182 training approval forms to identify 17 employees who attended external training after the May 11, 2012, policy implementation date. We reviewed the corresponding training certificates and affidavits to determine whether these employees submitted the required documentation within the 30-calendar-day deadline. Seven of the conference attendees did not provide training certificates or affidavits to the OHC within the 30-day time frame as prescribed by the policy. Further, we found that one of the affidavits was electronically signed on March 22, 2013, but was backdated in writing to July 19, 2012. Without proof of completion, the CFPB could be paying for conferences and training that employees do not attend or complete.
We recommend that the OHC
Regarding recommendation 3, the Chief Operating Officer stated the following:
Management concurs with this recommendation. Since the conclusion of the OIG's test work, the Bureau has reviewed the referenced policy, procedures, and related documentation. The Bureau has already taken actions to clarify and enhance the policy language, and has created an External Training Standard Operating Procedure (SOP) outlining the roles and responsibilities of each Bureau employee in the process. Further, since the end of the test period, September, 2012, OHC has automated the SF-182 External Education Request form, incorporating it into the Learning Management System (LMS) which enhances the workflows, records approval steps, and provides the needed documentation to support the Policy. OHC has benchmarked other agencies in accordance with like policies and procedures, and finds them in alignment with our enhanced approach. OHC has also created revisions to the External Training Policy to clarify language and separate tasking steps into the SOP for cleaner language and processing. Lastly, as part of the SOP, OHC has clarified process and language to ensure the proper receipt of training certifications and affidavits, and has created on audit process to outline a monthly review against these procedures and documentation.
Regarding recommendation 4, the Chief Operating Officer stated the following:
Management concurs with this recommendation. By automating the SF-182 External Training Request Form, and incorporated it into the Learning Management System (LMS), OHC bolstered the documentation of requesting employees, supervisors, and OHC as part of the approval and record keeping for conference requests. The last step in the automated SF-182 workflow, includes a verification process completed by both the employee and the supervisor, validating that the employee did, in fact, attend the conference. This approach is utilized by other federal agencies that the Bureau has benchmarked following the OIG Audit findings. Further, OHC has outlined this process in a new standard operating procedure (SOP) for external training, which outlines process steps to ensure the proper receipt of training certifications and affidavits. Also as part of the external training SOP, OHC has created an audit process for monthly review against these procedures and documentation of employee conference attendance. OHC anticipates full implementation of the updated audit process by October, 2013.
In our opinion, the actions described by the Chief Operating Officer are responsive to our recommendations, and we plan to follow up on the OHC's actions to ensure that each recommendation is fully addressed.