Controls Over Accountable Property at the Baltimore Field Division of the Federal Bureau of Investigation
Report Number 04-37
Office of the Inspector General
According to the Administrative Officer, any BFD employee can request that a certain item of property be purchased, but only certain employees can actually procure an item and obligate funds. Specifically, the BFD has 20 purchase credit cardholders, with card limits ranging from $10,000 to $100,000, and three contracting officers. The BFD's four supply technicians are among the 20 purchase credit cardholders, as are two of the contracting officers. The Administrative Officer is both a purchase cardholder and a contracting officer. According to FBI policy, only the supply technicians or the contracting officers may purchase equipment; the other cardholders can only purchase supplies. The Financial Manager confirmed that this policy is in use at the BFD.
Credit cards may be used for overt transactions up to $2,500, but purchase orders should be used to procure items with costs from $2,501 to $25,000. In addition, the BFD uses telephonic numbers for undercover purchases. A telephonic number is an identifying number assigned to expenses that are to be paid from case funds, rather than general office funds. According to the Financial Manager, a telephonic number is generally required for maintenance or service charges of $500 or more, and for equipment purchases of $1,000 or more. However, there is no maximum dollar amount for a telephonic number. In addition, a confidential credit card may be used for undercover purchases. The procurement procedures for these purchases are the same, except that the purchases are made under a fictitious name.
The starting point for many property purchases at the BFD is the FD-369 form. (Refer to Appendix V for a sample FD-369 form.) According to the BFD's Lead Supply Technician, in order to procure an item, the employee seeking the purchase completes an FD-369 form. The FD-369 form is reviewed initially by a supply technician and then forwarded to either the Financial Manager or the Administrative Officer for approval. If the FD-369 form is signed and approved by either of these officials, the purchase is made.
In addition, according to the Administrative Officer, the BFD only uses third-party drafts for recurring commercial payments or when a vendor does not accept credit cards. The BFD requires that a separate form, besides the FD-369, be prepared to request a third-party draft.
Receipt of Property
All property that is received at the BFD is delivered to a trailer located in the parking lot to be x-rayed and screened for dangerous components. Once the package is deemed safe, it is placed near the supply room or, if the item is too large, a supply technician is called to retrieve it. The Lead Supply Technician stated that once property, equipment, or supplies arrive at the BFD, the supply technician who reviewed the FD-369 form physically receives and inspects an item, adds it to the Property Management Application, if necessary, and delivers the item to the employee who ordered it.
The practice described by the Lead Supply Technician complies with the FBI's procedures for receiving property. Section 5-1 of the Accountable Property Manual states, in part, that, "[i]t is the responsibility of each [s]upply [t]echnician or property custodian to receive all shipments of supplies, furniture, and equipment consigned to his/her cost center(s). When the property has been received, the [s]upply [t]echnician or property custodian must thoroughly inspect the shipment to ensure that the items received are correct, that shipping damage has not occurred and to determine if a complete or partial shipment was received." However, the Lead Supply Technician also acknowledged that when an employee orders an item with a purchase credit card, the cardholder may appear as the addressee on the package. In these cases, the employees in the x-ray trailer will usually contact the purchaser, instead of a supply technician, to retrieve the package.
The Lead Supply Technician also stated that property can be received by the BFD through forfeitures, gifts, or as abandoned property; however, he stated that very little property has been added to the Property Management Application through gifts.21 The Lead Supply Technician explained that for forfeitures and abandoned property, FBI Headquarters sends him an electronic communication to notify him that the property is arriving. An employee in the BFD's forfeiture section will actually receive the property; however, the Lead Supply Technician stated that someone from the forfeiture section will bring the property to him to have a barcode affixed and the item added to the Property Management Application. The Lead Supply Technician does not believe he even receives an electronic communication when the item's value is under $1,000.
Placement into Inventory
If the acquisition cost of the property received meets or exceeds the $1,000 threshold amount, a supply technician will place an FBI barcode on the item and manually enter the barcode number and the item's identifying information into the Property Management Application. If the acquisition cost does not exceed $1,000, a barcode will not be placed on the item, and it will not be entered into the Property Management Application. In either event, the supply technician will then deliver the item to the employee who ordered it. Confidential property is also included in the Property Management Application, but no barcodes are affixed to this property. These items are specifically identified as confidential in the Property Management Application and can only be queried in the Property Management Application through their serial numbers.
Presently, three of the four supply technicians assigned to the BFD are located at the Baltimore office while the other supply technician is located at the Calverton, Maryland resident agency. Except for the Calverton resident agency, any property designated for a resident agency is affixed with barcodes and entered into the Property Management Application at the Baltimore office. According to the Lead Supply Technician, all of the supply technicians have edit and query mode in the Property Management Application; however, only FBI Headquarters can delete a record from the Property Management Application. The property custodians have query mode in the Property Management Application only.
Tracking of Under $1,000 Property
According to the Unit Chief in the Property Procurement and Management Section at FBI Headquarters, there are no standardized procedures for tracking under $1,000 property and the manner in which this property is tracked is left up to the Accountable Property Officer in the field divisions. At the BFD, the Accountable Property Officer is the Special Agent in Charge. Based on our interviews with the nine property custodians, only four property custodians track the under $1,000 property in their control at all. The property areas with under $1,000 tracking are: 1) photography equipment; 2) computer equipment, 3) technical equipment; and 4) ET. These four property custodians maintain Microsoft Access databases of all of the property in their control, not just the property with an acquisition cost of less than $1,000.
According to the property custodian for photography equipment, his Microsoft Access database was established approximately two years ago, specifically in response to Stull's thefts. Only the property custodian, his supervisor, the relief photographer, and the Administrative Officer have write access to the database, and changes can only be made at the property custodian's computer.
In contrast, the property custodian for technical equipment established his tracking system in Microsoft Excel about six years ago. He has since converted his database to Access and named it the Baltimore Technical Management System. The property custodian explained that the reason an item is included in the Baltimore Technical Management System has more to do with its operational purpose than its dollar value. For example, a customized or special-order camera with an acquisition cost of $100 would be included in the Baltimore Technical Management System. On the other hand, a power supply with an acquisition cost of $200 would not be included in the Baltimore Technical Management System because it is available commercially. Six technical agents, including the property custodian, have access to the Baltimore Technical Management System.
According to the Lead Supply Technician, the nine property custodians are responsible for the equipment and property that they charge out to employees. The Accountable Property Manual does not describe procedures for distributing or assigning out property and only includes instructions for using the property charge-in and charge-out features in the Property Management Application to assign an item of property to a specific person. However, FBI policy requires that laptop computers and firearms be charged out to specific individuals in the Property Management Application and that property pass (FD-281) forms be maintained for these items. (Refer to Appendix IV for a sample FD-281 form.)
In addition, during our audit, and particularly during our inventory review, we found that the property custodians have their own policies for when to prepare an FD-281 form. For example, the property custodian for firearms stated that he issues FD-281 forms for all weapons, but the property custodian for ET only prepares FD-281 forms for hand-held radios. In addition, the property custodian for computer equipment stated that he prepares FD-281 forms for both desktop and laptop computers while the property custodian for photography equipment stated that he prepares FD-281 forms for everything. The property custodian for photography equipment added that he even prepares FD-281 forms, which assign property to him, for the items that are in his photography equipment storage area.
According to the Lead Supply Technician, to assign property included in the Property Management Application to an employee, the property custodian would prepare an FD-281 form, sign the form, have the employee who is checking out the equipment sign the form, and then send the form to a supply technician. The supply technician will enter the information into the Property Management Application, and make a copy of the FD-281 for his records. The original will be returned to the property custodian.
Section 128-1.5202 of the Justice Property Management Regulations describe the Department of Justice policy regarding the physical inventory of personal property. This section states, in part, that:
Section 14-4 of the Accountable Property Manual provides an inventory schedule that is in compliance with the Justice Property Management Regulations and provides similar limitations on who can perform an inventory. According to Unit Chief in the Property Procurement and Management Section at FBI Headquarters, FBI inventories are performed on a biennial cycle. The first year, 100 percent of capitalized and non-capitalized property is inventoried, and the second year, only capitalized and sensitive property is inventoried.22 Also according to the Unit Chief, property with an acquisition cost of less than $1,000 is not included in the biennial inventory. Moreover, according to the Lead Supply Technician, these items are also never inventoried separately at the BFD.
The BFD's most recent 100-percent biennial inventories occurred in 1998, 2001, and 2003. In addition, the Lead Supply Technician stated that in January 2003, the BFD conducted an inventory of only photography equipment as a result of Stull's arrest. This inventory consisted of a 100-percent review of the photography equipment listed in the Property Management Application. However, because the BFD did not have a universe of the under $1,000 photography equipment to compare to, the Lead Supply Technician acknowledged that they essentially only created a list of the remaining under $1,000 photography equipment.
During the inventory, the four supply technicians assist other employees because, as described in the Justice Property Management Regulations, the supply technicians are not allowed to conduct the inventory themselves.23 The inventory begins with the assigned employees traveling around the Baltimore office and the resident agencies, using portable scanners to scan the Property Management Application barcodes affixed to items. Afterwards, a Property Management Application report, which lists the items not scanned, is run. The assigned employees then go back to search for the items previously missed. This process continues until the deadline date set for the inventory by FBI Headquarters. After this date, the Lead Supply Technician must send a Report of Lost/Stolen Property (FD-500) to FBI Headquarters for each of the items not located. (Refer to Appendix VI for a sample FD-500 form.)
The Lead Supply Technician also described the BFD's procedures for disposal of property. He stated that when an item has been identified as surplus, a property custodian will bring the property to him and he will send an electronic communication to notify FBI Headquarters. He then waits for FBI Headquarters to tell him how to dispose of the property. During that time, the item is stored in an area of the supply room, which only he and the other supply technicians frequent, but to which others do have access. The Lead Supply Technician added that there is no approval process at the BFD for the disposal of an item. The property custodian simply brings the item to the Lead Supply Technician or notifies him of its location if the item is too large to move.
If an item is disposed of, this status is documented in the Property Management Application. Once an item is marked as disposed of in the Property Management Application, it will no longer appear on the list of items to be inventoried. In addition, according to the Unit Chief in the Property Procurement and Management Section at FBI Headquarters, her FBI Headquarters unit is responsible for authorizing the BFD to dispose of property included in the Property Management Application, but property that falls below the $1,000 threshold is solely under the control of the Accountable Property Officer. Furthermore, the Accountable Property Manual includes a requirement that once FBI Headquarters approves the disposition of an item of property, the field office has 30 days to dispose of it.