The AOC Inspector General’s Statement of Management Opportunities and Performance Challenges (continued)

The Opportunities and Challenges

We believe these four challenges present significant opportunities for AOC organizational improvement. These challenges should be viewed as parts of a whole, rather than as separate, unrelated parts. From our perspective, the key of all the challenges is related to changing the agency-wide culture that views internal controls as an extra burden, rather than as a necessary part of how each employee approaches day–to-day work. AOC still does not have a robust program; however, senior management at this point has committed to establishing internal controls as a cornerstone, rather than as an extra chore.

We are pleased to report that Policy Enforcement, which was listed as a challenge last year, has been eliminated. AOC has made remarkable progress in establishing a central policy library and managing annual updates. Accountability for policy enforcement has been placed with the policy owner, with oversight by senior management and the OIG. Currently, policies are routinely revised or eliminated on a scheduled basis.

Similarly, Procurement Policy has been eliminated as one part of a broader procurement challenge, as AOC issued their first-ever Contracting Manual on March 31, 2014. However, AOC has not yet implemented two proactive initiatives to reduce fraud risks in contracting, and those initiatives remain as challenges from last year’s Statement.

We are looking more closely at the fraud risk-avoidance initiatives recommended in last year’s Statement, and so we are suspending them in this Statement. A revised version of these recommendations may return in next year’s Statement or, if warranted, earlier in a report with detailed legal analysis that includes a discussion of the lack of binding Federal Acquisition Regulations applying to the AOC.

Two challenges listed below continue, at least in part, from last year and this Statement includes updates to those challenges:

• Enhancing Internal Controls

• Improving Human Capital Management

We are adding a new challenge this year which we further describe in this report:

• Property Accountability and Surplus Property Disposal

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