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Holding the Government Accountable

Watchdogs Need to Bark About Their Recommendations

Two reports issued by federal watchdogs last month offer a study in contrast.

In one report, the Special Inspector General for Afghanistan Reconstruction (SIGAR) announced that the Department of Defense (DoD) has implemented more than 75 percent of the watchdog’s recommendations. In another report, the Special Inspector General for the Troubled Asset Relief Program (SIGTARP) said that fewer than 25 percent of its recommendations have been fully implemented.


Although many of the recommendations issued by these Special IGs have met different fates, their reports serve as a helpful reminder: it is important for watchdogs throughout the federal government to track the status of their recommendations and the money recovered for U.S. taxpayers, and to raise a ruckus when their words fall on deaf ears at the agencies they oversee.

IG recommendations are not always practical or wise, and a 100 percent implementation rate would suggest an IG was only going after low-hanging fruit. At their best, however, watchdogs can address systemic problems and help agencies save money, root out corruption, and protect the public’s health, safety, and security. Congress and the public deserve to know how often agencies actually implement IG recommendations and save taxpayer dollars, in order to hold both agencies and IGs accountable. When agencies decide not to implement an IG recommendation, they should provide a detailed explanation to Congress and the public justifying their decision.

The SIGAR looked at the status of all 209 recommendations it made to DoD in audit and inspection reports from January 2008 through June 2014. It found that 196 recommendations (94 percent) were closed as of the end of last year; 161 recommendations (77 percent) were closed and implemented; 35 recommendations (17 percent) were closed and not implemented; and 13 recommendations (6 percent) remained open.


Of the 161 closed and implemented recommendations, 84 “had intended outcomes of either ensuring accountability and oversight of contract funds, or ensuring that facilities are safely constructed, completed, and used as intended,” the SIGAR wrote. Seven audits resulted in an “estimated $1.1 billion in cost savings or funds put to better use.” For instance, a September 2013 audit of DoD construction plans found that the Department lacked a comprehensive plan for addressing future reductions in the Afghan National Security Forces. In response to SIGAR’s recommendations, DoD stopped construction on all or part of 101 projects, resulting in estimated cost savings of up to $800 million.

While highlighting its implemented recommendations, the SIGAR also pointed to cases where it had to close a recommendation because DoD decided not to enact it. In an April 2013 audit, for instance, the SIGAR identified weaknesses in DoD’s system to prevent U.S. contracting dollars from ending up in the hands of individuals and entities who support the Taliban and other insurgent groups. The SIGAR recommended that contractors be required to certify they do not have subcontracts with individuals or entities identified as insurgency supporters, but DoD disagreed, stating it did not have the authority on its own to impose this requirement. In its latest report, the SIGAR said it “maintains that requiring prime contractors to certify that they do not have subcontracts with the enemy is an important safeguard against U.S. funds being diverted to individuals and entities threatening the U.S. and coalition forces in Afghanistan.”

Other recommendations, such as strengthening DoD oversight of fuel purchases for the Afghan National Police, remain open while the SIGAR waits for documentation of full implementation. “[W]e are encouraged by DOD’s commitment to addressing our recommendations and will continue to review any support provided and close recommendations, as appropriate,” the SIGAR concluded.

The SIGTARP—established in 2008 to oversee the government’s bailout of Wall Street—has done a similarly admirable job of tracking its recommendations. In its latest quarterly report, the watchdog revealed that most of its recommendations have not been fully implemented by officials at the Treasury Department and other financial regulatory agencies. “As of December 31, 2014, SIGTARP has made 151 recommendations to Treasury and Federal banking regulators, 115 of which remain unimplemented,” the SIGTARP wrote. Of the 115 recommendations that were not fully implemented, 79 were not implemented at all, 22 were only partially implemented, 8 are still in process, and 6 are “TBD/NA,” according to SIGTARP’s data.

In one case, the SIGTARP had urged Treasury to ensure that mortgage servicers have the staffing and resources they need to handle applications from struggling homeowners seeking relief under a Treasury assistance program. “Treasury responded that it agrees with this recommendation, however, it is unclear whether Treasury is going to take any additional action beyond what it already does to implement this recommendation,” the SIGTARP wrote. “Agreeing with the principle of the recommendation, without changing course is not sufficient for SIGTARP to consider Treasury’s response as an agreement to implement the recommendation because it would result in no change for this alarming problem.”

“The more time Treasury spends not seeing a problem, and not taking action to fix the problem, the more homeowners suffer,” the SIGTARP concluded.

Special IGs aren’t the only watchdogs keeping tabs on their recommendations. The Department of Homeland Security’s Office of Inspector General (DHS OIG) recently reported that 94 of its recommendations have been open and unresolved for at least six months. The good news is that this number is down from 675 open and unresolved recommendations several years ago. The bad news is that 18 of the recommendations have been languishing for more than 1,000 days, including some that involve systemic problems such as DHS’s contract oversight.

For instance, several open recommendations date back to October 2010, when the OIG examined public assistance contracts managed by the Federal Emergency Management Agency (FEMA) in the aftermath of hurricanes and other natural disasters. The OIG raised concerns that FEMA might not be in compliance with a law that “requires the government to select engineering and architecture firms based on their competency, qualifications, and experience.” However, as of October 2014, several of the OIG’s recommendations from this audit—such as developing policies for “monitoring and evaluating contractor performance and for certifying and reconciling contractor invoices and supporting documentation”—remained unimplemented.

All IGs operating under the Inspector General Act are required to provide Congress with semiannual reports including the number of recommendations that have been open for six months or longer, among other stats. However, by issuing a separate report on unimplemented recommendations, the DHS OIG and other watchdogs can draw specific attention to the problem and help ensure that important details do not get buried in the semiannual updates.

In addition, all IGs should follow the SIGAR’s lead and report on recommendations that were actually implemented (not just closed), and on dollars that were actually recovered (not just potential savings). “Far more useful [than the semiannual reporting requirements] in determining overall OIG effectiveness would be information on recommendations that were implemented, and whether the results were as anticipated, actual monetary recoveries, and the implications of significant unimplemented recommendations,” the Project On Government Oversight wrote in a 2009 report on IG accountability.

POGO has supported bipartisan legislation—the Government Contractor Accountability Act of 2013 (S. 664), sponsored by Senators Jeanne Shaheen (D-NH) and John Boozman (R-AR)—that would improve reporting on agency responses to IG audits. POGO has also called for the public release of any such reports.

Image from Flickr user Kofi Opoku-Ansah and the Special Inspector General for Afghanistan Reconstruction.