Audit of the CPSC’s Position Designation and Suitability Program

Submitting OIG:

Consumer Product Safety Commission OIG

Date Issued:

Thursday, April 29, 2021

Agency Reviewed / Investigated:

Consumer Product Safety Commission

Submitting OIG-Specific Report Number:

21-A-07

Location(s):

Agency-Wide

Type of Report:

Audit

Questioned Costs:

$49,631

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
Audit-CPSCs-Position-Designation-Suitability-Program-04292021-Final.pdf	779.21 KB

Recommendation Number	Recommendation Status	Significant Recommendation
1	Open	Yes
Update and implement EXRM directives, policies, and procedures regarding position designation to reflect current EXRM operations and address current OPM policies and guidelines.
2	Open	Yes
Develop and maintain an accessible database with all information required to effectively manage the position designation and suitability program. At a minimum, this system should contain the name of the employee or contractor, position number and title, position designation, tier of background investigation completed, entry-on-duty date, date the background investigation was requested, date the background investigation was completed, whether it was an initial investigation or reinvestigation, whether reciprocity was applied, and reinvestigation due date.
4	Open	No
Use the information developed in Recommendation Two to track an employee’s investigation versus the designation of their position and ensure they are properly aligned.
5	Open	No
Use an automated tool to track when employee and contractor reinvestigations are due.
6	Open	No
Update the investigations of employees whose completed investigation has exceeded the five-year reinvestigation requirement.
7	Open	No
Allocate the appropriate resources going forward to ensure that all reinvestigations are initiated on or before the due date.
8	Open	Yes
Establish a process to include Office of Human Resources Management during the drafting of the statement of work to determine the appropriate investigative tier for contractors prior to when the request for quotes is released to potential vendors.
9	Open	Yes
Develop a formal documented process (directive or standard operating procedure) for onboarding contractors.
10	Open	No
Develop a system to communicate any changes in the onboarding process to contracting officer’s representatives and other personnel involved in the onboarding of employees and contractors.
11	Open	No
Develop and document a systematic and repeatable risk assessment process to evaluate the risk of applying reciprocity for incoming contractors.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

Open

Yes

Update and implement EXRM directives, policies, and procedures regarding position designation to reflect current EXRM operations and address current OPM policies and guidelines.

Open

Yes

Develop and maintain an accessible database with all information required to effectively manage the position designation and suitability program. At a minimum, this system should contain the name of the employee or contractor, position number and title, position designation, tier of background investigation completed, entry-on-duty date, date the background investigation was requested, date the background investigation was completed, whether it was an initial investigation or reinvestigation, whether reciprocity was applied, and reinvestigation due date.

Open

Use the information developed in Recommendation Two to track an employee’s investigation versus the designation of their position and ensure they are properly aligned.