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PEACE CORPSOffice of Inspector GeneralMissionTo conduct audits, evaluations, and investigations that uphold theeffectiveness, efficiency, and integrity of the agency in achieving thegoals set forth in the Peace Corps Act that Peace Corps Volunteershelp the people of the countries in which they serve in meetingtheir needs for trained manpower, and help to promote a betterunderstanding of the American people on the part of the peoplesserved, and a better understanding of other peoples on the part of theAmerican people.Semiannual Report to CongressOctober 1, 2011–March 31, 2011
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PEACE CORPS OFFICE OF INSPECTOR GENERALTable of ContentsHighlights from this Report .1Message from the Inspector General . 1Management and Administration .4Agency Context and OIG Staffing . 4Awards . 5OIG Organizational Chart . 6Advice and Assistance Provided to the Agency and Others .8Fraud Alert . 8Policies and Procedures . 8Best Practices . 8Status of PC/Morocco: Assessment of Medical Care and Death Inquiry . 8Audits .10Headquarters Audits. 11Peace Corps Fiscal Year 2010 Financial Statement Audit . 11Annual Review of Peace Corps Fiscal Year 2010 Information Security Program . 12Audits of Overseas Operations . 13PC/Belize: Audit . 13PC/Ethiopia: Audit . 14PC/Mexico: Audit . 15PC/Mozambique: Audit . 15PC/Togo: Audit . 16PC/Ukraine: Audit . 16Evaluations .20Volunteer Delivery System: Follow-up Program Evaluation . 21Country Program Evaluations . 22PC/Ethiopia: Country Program Evaluation . 22PC/Jamaica: Country Program Evaluation . 23Investigations .26Legacy Cases . 27Homicide Investigation and Judicial Activities at a Post in Central Africa . 27Criminal and Misconduct Related Investigations . 27Former Country Director Pleads Guilty in U.S. Federal District Court . 27
Former Cashier Debarred at a Post in the South Pacific . 27Misconduct Allegations . 27Conflict of Interest Involving a COTR . 28PROTECT Act Allegation at a Post in Southern Africa . 28PROTECT Act Allegation at a Post in the South Pacific . 28PROTECT Act Allegation at a Post in Southern Africa . 28Mishandling of Grant Funds and Other Misconduct at a Post in West Africa . 28Sexual Assault at a Post in West Africa. 29Sexual Harassment at a Post in Central America. 29Staff Fraternization with a Volunteer at a Post in Central America . 29Kickback Practices at a Post in East Africa . 30Embezzlement of Imprest Funds at a Post in Central America . 30Allegation of Mismanagement and Retaliation against a Volunteer at a Post in the SouthPacific . 30Misuse of a Military Postal Address at a Post in East Asia . 30Investigation of Federal Employees’ Compensation Act Recipients . 30Coordination with Other Law Enforcement and Federal Entities . 31Continued Support from Regional Security Officers World-wide . 31Oversight Inquiry and Support. 31Homeland Security Assistance with PROTECT Act Investigations . 31Investigative Assistance of FECA Cases . 32Tables .341: List of Reports: Audits and Program Evaluations . 342: Reports with Questioned Costs, Unsupported Costs, and Funds Put to Better Use . 353: Status of Reports Issued by OIG with Questioned and Unsupported Costs . 364: Status of Reports Issued by OIG with Funds to be Put to Better Use . 375: Recommendations on which Corrective Action has not been Completed. 386: Summary of Investigative Activity . 407: Summary of Hotline and Other Complaints . 418: References to Reporting Requirements of the Inspector General Act . 42Appendices .44A: Reporting of Peer Reviews . 44B: Contract Audit Reports . 44
PEACE CORPS OFFICE OF INSPECTOR GENERALHighlights from this ReportMessage from the Inspector GeneralI am pleased to present the Peace Corps Office of Inspector General’s(OIG) Semiannual Report to Congress for the period of October 1,2010–March 31, 2011. As the Peace Corps celebrates its 50thAnniversary this year, OIG remains committed to promoting andincreasing the effectiveness and efficiency of Peace Corps programsand operations. During this reporting period we issued a follow-upprogram evaluation report of ―the Volunteer Delivery System‖ theprocesses that enable the agency to recruit and place Volunteers in thefield as well as eight post audit and evaluation reports. Ourinvestigative staff closed 29 investigations and made referrals to theagency’s suspension and debarment official, which resulted in thedebarment of a former employee and a former personal services contractor.The Audit Unit has continued its critical work in connection with the agency’s FinancialStatement Audit by assisting the agency in improving its overall financial health in accordancewith the requirements of the Federal Managers Financial Integrity Act and the FederalInformation Security Management Act (FISMA). During this reporting period, the Audit Unitcompleted reports for post audits conducted in Belize, Ethiopia, Mexico, Mozambique, Togo,and Ukraine. The Audit Unit initiated work on post audits of Rwanda and Albania. Atheadquarters the Audit Unit initiated work on the formulation and execution of Peace Corps’budget process, the tracking and monitoring of small grant funds, and the operations of regionalrecruitment offices.The Evaluation Unit completed reports for program evaluations conducted in Ethiopia andJamaica in addition to the report on the Volunteer Delivery System at headquarters. TheEvaluation Unit initiated work on program evaluations of Cambodia, Fiji, the Kyrgyz Republic,Liberia, Romania, and Swaziland, and initiated an evaluation of the impact of the rule limitingstaff terms, ―The Five-year Rule,‖ both domestically and in the field. In addition, it launched areview of the agency’s implementation of protocols and procedures in response to Volunteerswho have been victims of sexual assault. This review was initiated as a result of media reportsthat highlighted returned Peace Corps Volunteers concerns about the agency’s responsiveness tosuch assaults.Our investigative efforts, in collaboration with the Assistant U.S. Attorney for the District ofColumbia, led to the conviction of a former Peace Corps country director. In December 2010,the former country director pled guilty in U.S. District Court to one count of engaging inunauthorized activities in a matter affecting the U.S. government. In February 2011, he wassentenced to two years probation and ordered to pay 33,000 in restitution to the Peace Corps.October 1, 2010 to March 31, 20111
This case also resulted in a historical first for Peace Corps. Peace Corps’ Suspension/DebarmentOfficial debarred the former country director discussed above and another individual whoembezzled funds from Peace Corps from participation in the federal government contractingprocess.The Investigation Unit has also achieved significant gains in its Federal Employees’Compensation Act (FECA) investigations, uncovering numerous examples of abuse in thesystem, resulting in overall savings to the agency of 300,000. In addition, the InvestigationUnit investigated allegations of misconduct by staff and Volunteers including five ProsecutorialRemedies and Other Tools to end the Exploitation of Children Today Act (PROTECT Act) casesduring this reporting period.In 2009 the Peace Corps’ Director issued a policy on how agency staff members handleconfidential allegations made by Peace Corps trainees and Volunteers. The policy became aPeace Corps Manual section in January 2011. Since longstanding OIG and Peace Corps policyalready provided Volunteers the ability to report allegations confidentially to OIG, my staffworked with the agency to develop a training module on complying with the policy on handlingsensitive allegations.Subsequently OIG participated in three training sessions for new overseas staff on the policy andhas worked with the agency to ensure the policy is included in the Volunteer Handbook. I havealso communicated directly to country directors the importance of reporting allegations to OIGand maintaining the confidentiality of those making allegations, and I have provided countrydirectors with OIG materials and posters to distribute and display at posts overseas. In addition,OIG has initiated an outreach committee to inform staff and Volunteers of the role of OIGamong other things, and we are looking for more ways to reach out to Volunteers throughout theVolunteer lifecycle.During this reporting period the agency made substantial progress to address OIGrecommendations, particularly in the areas of Volunteer safety and security, medical care, andcontract management. We commend the efforts of the chief compliance officer in supporting theclosure of 250 recommendations since the reporting period started on October 1, 2010.We appreciate the cooperation of the Director, management, staff, and Volunteers, and I amproud of OIG staff for their effort to promote efficiency and integrity in the Peace Corps.2Semiannual Report to Congress
Management and AdministrationAll the posters featured in this SARC were first unveiled at the OIG open house inFebruary. This poster shows the various entities with whom we work.
Management and AdministrationAgency ContextAs of March 31, 2011, there were 8,780 Peace Corps Volunteers and trainees serving in 77countries at 71 posts. This total includes 401 Volunteers and trainees funded by the President’sEmergency Plan for AIDS Relief (PEPFAR) to work on HIV/AIDS projects at 15 posts and 151Peace Corps Response Volunteers serving short-term assignments in 34 countries (32 posts).The Volunteers and their programs are supported by 952 American direct-hire staff: 207overseas; 133 in the regional recruiting offices; and the remaining 612 at headquarters.Approximately 2,045 locally hired personnel complete post staffing. The Peace Corps also hascorporate contracts domestically and overseas, principally for guard services and training, andhires expert consultants, largely for training and financial management.OIG StaffingJerry Black joined OIG as a senior evaluator in December 2010. Before coming back to thePeace Corps he worked in the Dominican Republic as a consultant to USAID, coordinatingmonitoring and evaluation activities for its agricultural development project (USAID/RED).From 2006--2008 Mr. Black acted as an evaluation specialist and expert consultant to the PeaceCorps, focused on improving the agency’s monitoring, reporting, and evaluation systems. Mr.Black has worked as an independent consultant for domestic and international developmentorganizations on a range of economic growth and poverty reduction initiatives. Mr. Black servedas a Peace Corps Volunteer from 1992—1994 in the Comoros Islands, where he worked as anEnglish teacher. He holds a bachelor’s degree in English Literature from Washington Universityand a Master of International Affairs from Columbia University.Senior Auditor Bradley Grubb was promoted to Assistant Inspector General for Audits. Mr.Grubb has worked for Peace Corps OIG for two years conducting overseas audits and severalheadquarters audits. He previously worked for the Department of Defense OIG.At the end of this reporting period, the position of senior auditor is vacant. OIG is expects to fillthe position in the coming months.4Semiannual Report to Congress
PEACE CORPS OFFICE OF INSPECTOR GENERALAwardsThe Council of Inspectors Generalon Integrity and Efficiency(CIGIE) presented OIG with twoawards of excellence on October19, 2010. Assistant InspectorGeneral for Investigations GeoffreyJohnson, Senior Evaluator SusanGasper, and Special Agent MarkSupple received a Special ActAward for the multidisciplinaryinquiry into the death of aVolunteer and accompanyingassessment of health care inPictured from l--r AIG/I Geoffrey Johnson, Senior Evaluator Susan Gasper, SpecialMorocco. Expert Jeffrey Lee,Agent Mark Supple, Senior Evaluator April Miller, and Expert Jeffrey LeeFormer Assistant Inspector Generalfor Audits Gerald Montoya, and Senior Evaluator April Miller received an award for OIG’sperformance audit of the agency’s process for soliciting, awarding, and administering contractsthat combined the talents of our audit and evaluations staff.October 1, 2010 to March 31, 20115
OIG Organizational ChartInspector GeneralKathy A. BullerDeputy IG and Legal CounselJoaquin FerraoExpertRobin WalkerExecutive AssistantLisa ChesnelAIG/InvestigationsGeoffrey JohnsonAIG/EvaluationsJim O'KeefeAIG/AuditsBradley GrubbSr. InvestigatorJoseph BodensteinerSr. AuditorSteven KaffenSr. EvaluatorJeremy BlackSr. InvestigatorJoyce ShoresSr. AuditorSnehal NanavatiSr. EvaluatorSusan GasperSr. InvestigatorMark SuppleSr. AuditorJoseph WagnerSr. EvaluatorReuben MarshallSr. AuditorvacantSr. EvaluatorApril ThompsonMillerExpertJeffrey LeeSr. EvaluatorHeather RobinsonCriminal ResearchSpecialistJeffrey ReichertProgram AnalystDanel Trisi6Semiannual Report to Congress
Advice and Assistance Provided to theAgency and OthersThis poster was developed to highlight the important changes in the Peace CorpsManual, section 271 and the role that OIG plays in protecting the confidentiality ofVolunteers/trainees.
Advice and Assistance Provided to theAgency and OthersFraud AlertIn March 2011, OIG issued a fraud alert to Peace Corps Volunteers, their families and theirfriends, cautioning them to be aware of telephone and Internet scams seeking money based uponan overseas traveler’s unforeseen financial emergency. Because Peace Corps Volunteersfrequently travel throughout the world, their families and friends in the U.S. may readily fallvictim to these types of scams.Policies and ProceduresOIG provided advice and assistance to the Peace Corps Senior Policy Committee by commentingon drafts of new or updated policies and procedures. The agency is engaged in a robust effort toupdate, and where appropriate, to develop policies and procedures. OIG’s proactive engagementis intended to help support efforts to improve the effectiveness and efficiency of Peace Corpsprograms and operations. Some of the proposed revisions are in response to earlier OIGrecommendations.Best PracticesOIG auditors and evaluators presented best practices and common deficiencies noted by OIG tooverseas personnel. The auditors and evaluators led sessions during overseas staff training forcountry directors, directors of programming and training, and directors of management andoperations. The presentations focus on how overseas personnel can improve the efficiency andeffectiveness of their roles, enhance overall compliance with policies and procedures, and avoidcommon mistakes.Status of PC/Morocco: Assessment of Medical Care and Death InquiryOIG continues to follow-up and report on the agency’s progress related to the Moroccoassessment and death inquiry. All recommendations are now closed.8Semiannual Report to Congress
AuditsPC/Mozambique Health Volunteer Megan Nelson displays clothing sewn by youngwomen in her community with her guidance.
AuditsOverviewThe Audit Unit conducts audits of agency operations that support the Peace Corps’ missionincluding field activities at overseas posts, regional recruitment offices, and headquartersfunctions. Audits are conducted in accordance with generally accepted government auditingstandards issued by the Comptroller General of the United States.The objective of OIG audits is to independently examine the financial and administrativeoperations of the Peace Corps; to promote economy and efficiency; and ensure compliance withfederal and Peace Corps regulations. Audits cover agency activities carried out at overseas postsand among interrelated offices. Auditors provide conclusions based on document and dataanalysis, interviews, and direct observation.The Audit Unit oversees audits of the agency’s financial statements and information systemsecurity and conducts audits of agency-wide programs managed by headquarters. OIG utilizescontracts with an independent public accountant (IPA) for legislatively mandated audit work.The Accountability of Tax Dollars Act of 2002 mandates an annual audit of Peace Corps’financial statements. OIG oversees and serves as the contracting officer’s technicalrepresentative for contracts with the IPA to perform the agency’s annual audit. To fulfill itsresponsibilities, the Audit Unit monitors the IPA’s work to ensure that it is of acceptable quality,in compliance with federal law and professional standards, and is completed within guidelinesestablished by the Office of Management and Budget (OMB).The Audit Unit contracts with an IPA in connection with OIG’s responsibility for meetingspecific requirements set by the Federal Information Security Management Act. Theserequirements include performing annual reviews of the Peace Corps’ information securityprogram and reporting related selected data to OMB.The Audit Unit is currently conducting audits of Peace Corps’ budget formulation and executionand of the regional recruitment offices. With the assistance of the Evaluation Unit, an audit isbeing conducted on small grants management.The Audit Unit uses a risk-based assessment to select overseas posts to review for operationalefficiency and effectiveness, financial stewardship, and compliance with agency policy andfederal regulations. At overseas operations auditors review various operations including imprestfund management and cashiering, acquisitions and contracts, personal property management,medical supply control, and personnel management. During this period, auditors completedaudits of Belize, Ethiopia, Mexico, Mozambique, Togo, and Ukraine. Post audits of Albania andRwanda are underway.10Semiannual Report to Congress
PEACE CORPS OFFICE OF INSPECTOR GENERALDuring our overseas post audits, OIG identifies reoccurring issues and trends. Our reportsfrequently contain recommendations to headquarters for strengthening controls to detect andprevent the systematic weaknesses noted. During this reporting period OIG continued to reporton posts’ difficulty in complying with the agency’s medical supplies policies and procedures.OIG recommended improved property management systems and procedures to safeguardpersonal property and prevent loss or theft. In addition, OIG repeatedly identified the lack ofinitial security certifications and recertification for personal services contractors’. Posts arerequired to request that embassy regional security officers conduct a background investigation ofpersonal service contractors prior to contracting and to obtain the security certifications verifyingthat the individual is eligible to work for Peace Corps. OIG communicated these concerns inprevious audits and continue to monitor the agency’s progress in correcting these deficiencies.Headquarters AuditsPeace Corps Fiscal Year 2010 Financial Statement AuditOIG contracted with Urbach Kahn & Werlin LLP (UKW), an independent certified publicaccounting firm, to audit the Peace Corps’ financial statements. UKW’s federal sector practicewas acquired by Clifton Gunderson LLP (CG) by merger on March 22, 2010. The contractrequired the audit be done in accordance with U.S. generally accepted government auditingstandards; OMB Bulletin 07-04, Audit Requirements for Federal Financial Statements; and theGovernment Accountability Office/President’s Council on Integrity and Efficiency FinancialAudit Manual. CG’s audit reports for fiscal year (FY) 2010 included: (1) an opinion on thefinancial statements, (2) a report on internal control, and (3) a report on compliance with lawsand regulations.In the audit of the Peace Corps, CG found that the fiscal year 2010 financial statements presentedfairly, in all material respects, the financial position of the agency as of September 30, 2010, andits net costs, changes in net position, and budgetary resources conformed with U.S. generallyaccepted accounting principles. In addition, the firm reported that there were no materialweaknesses related to internal control. However, CG’s report on internal control did identify twosignificant deficiencies:Business processes related to property, plant, and equipment accountability need to be improved.Improvements needed are related to recording, tracking, and physical verification of certainassets.Information system security controls need improvement. The auditor cited security management,contingency planning, access controls, and configuration management as areas needingimprovement.For the FY 2010 audit, a significant deficiency is defined as a deficiency, or a combination ofdeficiencies, in internal control that is less severe than a material weakness, yet important enoughto merit attention by those charged with governance. A material weakness is defined as adeficiency, or combination of deficiencies, in internal control, such that there is a reasonableOctober 1, 2010 to March 31, 201111
possibility that a material misstatement of the entity’s financial statements will not be preventedor detected and corrected on a timely basis. CG found no instances of reportable noncompliancewith the laws and regulations it tested or other matters that are required to be reported underGovernment Auditing Standards or OMB guidance.In connection with the contract, OIG reviewed CG's report and related documentation andinquired of its representatives. Our review, as differentiated from an audit in accordance withU.S. generally accepted government auditing standards, was not intended to enable us to express,and OIG did not express, opinions on Peace Corps’ financial statements, internal control, orconclusions on compliance with laws and regulations. CG was responsible for the auditor'sreports issued on November 9, 2010, and the conclusions expressed in the reports. However, ourreview disclosed no instances where CG did not comply, in all material respects, with U.S.generally accepted government auditing standards.As required by OMB Circular A-136, Financial Reporting Requirements, the auditor’s reportswere published within the Peace Corps FY 2010 Performance and Accountability Report. Inaddition, a separate letter describing internal control weaknesses, which do not meet thedefinition of a significant deficiency, was issued directly to Peace Corps’ management.Annual Review of Peace Corps Fiscal Year 2010 Information Security ProgramThe Federal Information Security Management Act (FISMA) mandates that federal agenciesestablish effective information security protections and a program to secure its informationsystems from unauthorized access, use, disclosure, modification, and other harmful impacts.These requirements must be met through adherence to specific guidelines established by theNational Institute of Standards and Technology. FISMA also requires OIGs to annually reviewtheir agency’s information security programs. OMB is responsible for reporting to Congress onthe overall progress of the federal government in meeting FISMA requirements. This isaccomplished through an online data collection tool that is used by agencies to report to OMBannually. Federal agencies and their respective OIGs are required to submit their responsesregarding FISMA compliance to OMB. The data collected in response to the OMB requirementsare designed to measure an agency’s progress.OIG contracted with CG to perform the annual review of the Peace Corps’ information securityprogram. CG assisted OIG in preparing OMB responses for FISMA and provided reportsassociated with reviewing a representative sample of Peace Corps’ information systems.Overall, the review concluded that the Peace Corps has made progress over the last few years inaddressing its information security weaknesses and becoming fully compliant with FISMA. Bythe end of FY 2010 the Peace Corps had issued Authorizations to Operate (ATO) for 88 percentof its information systems. The agency continues to maintain an up-to-date comprehensivesystem inventory in accordance with Federal Information Processing Standards. However, thePeace Corps still faces some important challenges in becoming fully FISMA compliant. Forexample, the agency reported to OMB in FY 2010 that one of eight agency information systemsneeded to be fully certified and accredited to meet FISMA requirements, and OIG determinedthat for three of eight systems, contingency plans had not been tested in accordance with federalpolicy.12Semiannual Report to Congress
PEACE CORPS OFFICE OF INSPECTOR GENERALAlthough some progress was made during FY 2010, several security issues from previousFISMA annual reviews were brought to management’s attention because they had not been fullyremediated. The more significant issues include:Certification and accreditation of 100 percent of Peace Corps’ information systemsImplementation of adequate controls over the Plan of Action and Milestone processCompletion of risk assessments and system security plansImplementation of adequate controls over the vulnerability assessment processCompletion and implementation of adequate contingency planning controls over the agency’sinformation system environmentCompletion of updates to in
Mar 31, 2011 · PAGE INTENTIONALLY LEFT BLANK . PEACE CORPS OFFICE OF INSPECTOR GENERAL . the position of senior auditor is vacant. OIG is expects to fill the position in the coming months. PEACE CORPS OFFICE OF INSPECTOR GENERAL October 1, . OIG Organizational Chart . Inspector General Kathy A. Buller
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