Controls Over Accountable Property at the Baltimore Field Division of the Federal Bureau of Investigation
Report Number 04-37
Office of the Inspector General
The FBI's Accountable Property Manual defines accountable property as "Property which, because of its value or nature, must be accounted for on an individual basis [in] the [Property Management Application]." Since February 2002, FBI policy has identified the property that must be accounted for in the Property Management Application as property with an acquisition cost of $1,000 or greater. However, in our judgment, the FBI needs to amend its definition of accountable property to mandate the tracking of certain property items that cost less than $1,000, for which tracking is currently discretionary. In its February 14, 2002, memorandum that increased the property threshold for accountable property from $500 to $1,000 (see Appendix VII), the Property Procurement and Management Section of the FBI stated:
Although there is no requirement to enter into [the Property Management Application] non-expendable property valued at less than $1000, at their discretion division heads may establish policy for tracking property valued at less than this threshold. If a division head desires to track property valued at less than the threshold, such as [videocassette recorders], cameras, televisions, etc., different colored barcode labels should be used for identification purposes. The use of a barcode label different in color from that used for the tracking of accountable property will enable division personnel to discriminate between items which must as a matter of policy be inventoried bi-annually [(sic)], and those subject to discretionary inventory.
During our audit, we found that the BFD adheres to the $1,000 threshold policy, and has chosen not to track under $1,000 property with the suggested different colored barcodes.10 Four of the nine BFD property custodians have developed separate databases outside of the Property Management Application to track under $1,000 property. However, these systems do not contain all of the elements required of a property accountability system and none of the property custodians conduct physical inventories of these items as required by the Justice Property Management Regulations.11
In our judgment, the FBI definition of accountable property excludes items that the Justice Property Management Regulations indicate should be accounted for as controlled personal property. Specifically, the Justice Property Management Regulations require bureaus to "establish personal property accountability systems . . . .,"12 and defines controlled personal property as:
[N]oncapitalized personal property that because of its nature must be subject to more stringent controls. Controlled personal property may or may not be recorded in a formal personal property accounting system. Controlled personal property includes, without limitation, property that: (1) [i]s leased by, in the custody of, or lent to or from [the Department of Justice]; (2) [d]ue to inherent attractiveness and/or portability, is subject to a high probability of theft or misuse; (3) [i]s warranted and requires knowledge of age and/or previous repair data when determining whether repair or replacement is appropriate; or (4) [c]ontains sensitive information or is sensitive in nature. Examples of sensitive property include weapons, hazardous products, surveillance and communication equipment, and property used for processing or storing classified information.13
We believe that photography equipment, such as cameras, technical equipment, such as televisions and videocassette recorders, and some computer peripheral equipment, to name a few, fall under the Justice Property Management Regulations definition of controlled personal property and are thus required to be included in a personal property accountability system regardless of cost and physically inventoried biennially.
We reviewed the FBI's reason for raising the Property Management Application threshold from $500 to $1,000. In the February 14, 2002, memorandum instituting the threshold change, the FBI stated that this change was consistent with current Department of Justice policy and by implementing it, the FBI would exempt nearly 154,000 items from future physical inventories. The Section Chief in the Property Procurement and Management Section at FBI Headquarters identified a 1994 policy memorandum as the document as instituting the $1,000 threshold at the Department of Justice. However, the 1994 memorandum stated that, even with the introduction of a $1,000 threshold, the Department of Justice "would continue to account for [items such as] televisions [and] videocassette recorders . . ." because of "the susceptibility of converting certain items to personal use." In our judgment, the FBI should amend its definition of accountable property to conform to Department of Justice requirements.
To test procurement and receipt of property, we: 1) tested a sample of procurement actions to determine if the purchased property was added to the Property Management Application, 2) tested a sample of credit card purchases to determine if the supporting documentation was adequate, and 3) reviewed the BFD's procedures for ordering and receiving property for adequate segregation of duties.
We tested a sample of property procured by the BFD in FY 2003 to determine whether these items were added to the Property Management Application. We selected a judgmental sample of 10 requisition forms, 10 purchase orders, and 10 orders using telephonic numbers from FY 2003 property purchases.14 These 30 procurement actions represented a total of 55 items of property. For those items with an acquisition cost of $1,000 or more, we requested a Property Management Application record to document the item's inclusion in the system. The Lead Supply Technician was able to provide a Property Management Application record for all of the items with acquisition costs of over $1,000. However, for those items with acquisition costs of under $1,000, there was not enough unique information included on the documents to identify the items in the separate databases maintained by the property custodians. Therefore, we could not verify that these items were included in any tracking system.
During our testing of credit card purchases, we found that the BFD Administrative Officer was approving payment of individual credit card bills without reviewing supporting documentation for the purchases. While FBI Headquarters only requires cardholders to maintain a log of their purchases, the BFD Financial Manager requires cardholders to complete and forward to her an FD-369 (requisition) form for each credit card purchase. Our testing revealed that not all cardholders complied with this requirement. According to the FBI Purchase Card Procedures, the Administrative Officer is responsible for approving individual bills and the Financial Manager is responsible for reconciling the individual bill to the consolidated bill. The Administrative Officer expressed concern that he is approving the bills for payment without knowing what items have been purchased or if such purchases were approved in advance. In our judgment, the Administrative Officer should receive, with each cardholder's bill, the FD-369 form and receipts that support the amounts on the bills.
Segregation of duties in the property management process is necessary to reduce the risk of error or fraud. We determined that a lack of segregation of duties - specifically between ordering and receipt of property - contributed to Stull's thefts remaining undetected. When a BFD employee orders an item using a credit card, the cardholder may appear as the addressee on the package. In these cases, the employees that screen deliveries of new property for security purposes may contact the cardholder to retrieve the package instead of a supply technician. Therefore, the supply technicians would not be aware that an item was received and should be entered in the Property Management Application unless the purchaser notified them.
In addition, even though Stull was not a cardholder, he could obtain equipment directly from the photography unit at FBI Headquarters using an electronic communication.15 The BFD has taken steps to correct this weakness by requiring BFD supervisory approval of photography equipment requests and ensuring deliveries are received by the supervisor instead of the property custodian.
To determine whether the BFD could locate and produce for our inspection property recorded in the Property Management Application, we selected items listed in the Property Management Application and physically verified them. We also conducted this testing on property lists maintained by the four property custodians who track under $1,000 property. Finally, to test the completeness of the Property Management Application and the databases maintained by the property custodians, we selected property items during office walk-throughs of the BFD and verified them to Property Management Application property records and the property custodians' databases.
We requested a universe of the property designated to the BFD in the Property Management Application. The data provided by FBI Headquarters contained 5,620 Property Management Application records as of January 30, 2004. In addition, we obtained universes from the four property custodians who maintain databases of the under $1,000 property in their control. These databases included a combined 6,071 property items. To test the BFD's ability to locate these items, we selected statistical samples from each of the universes below for review and asked the BFD to produce the items for our inspection. We concluded that the BFD located about 99 percent of the Property Management Application sample, but lower percentages of the other samples. The number of items in each universe and each sample and the results of our testing follow:
BFD Property Universes and Results of
Based on these results, we concluded that an item's exclusion from the Property Management Application decreased the BFD's chances of locating the item, even when the item was included in a property custodian's separate inventory database. The details from our testing of the various samples follow.
From the universe of 5,620 property items assigned to the BFD in the Property Management Application, we selected a statistical sample of 221 items. During our audit, the BFD's supply technicians and property custodians accounted for 219 of these items. They physically located and presented 210 of the items, provided certifications for 8, and documented that 1 additional item had been excessed. The remaining two items did not have barcodes or serial numbers, and we could not determine if the two items presented to us were the items selected for verification.
For the Property Management Application sample, we concluded that the BFD was able to account for 219 of the 221 items in the sample (99.1 percent). When projected to the population of 5,620 items, we are 95 percent confident that at least 17 of these property items (0.3 percent) would be unverifiable. (Appendix VIII contains the details of our sampling design.)
Under $1,000 Samples
We also received property listings from the four property custodians who maintain databases of the property in their control. The four property areas covered were: 1) photography equipment, 2) computer equipment, 3) technical equipment, and 4) ET. The four areas of under $1,000 property contained a combined total of 6,071 items of property. We then selected a statistical sample of property from these items for testing. To provide effective audit coverage of the 6,071 property items and to maintain a manageable sample size, we designed a stratified random sample that allowed for projection to the entire universe. However, the sample design did not allow for projection to individual types of property.
The stratified random sample included a total of 354 items. Based on the test results described below, the BFD could not locate 46 of these 354 items. In addition, we could not determine whether an additional 15 of the 354 items were located because the items physically presented to us by the BFD did not contain a verifiable barcode or serial number. Therefore, when projected to the population of 6,071 items, we are 95 percent confident that the BFD would not be able to locate at least 570 of these property items (9.4 percent) and that at least 133 of these property items (2.2 percent) would be unverifiable.
From the under $1,000 universe of 789 photography equipment items, we selected a statistical sample of 46 items for the BFD to locate. The supply technicians and the property custodian for photography equipment accounted for 44 of these items. They physically located and presented 41 of the items, and provided certifications for an additional 2 items. For the three remaining items, two camera lenses remain missing, but following fieldwork, the property custodian determined that an agent who was transferred to the Detroit Field Division took the third item - a camera - with him. Although this item was not located within the BFD and there was no official documentation of the transfer, we concluded that the BFD was able to successfully account for 44 of the 46 items in the sample (95.7 percent).
From the under $1,000 universe of 1,232 computer equipment items, we selected a statistical sample of 72 items for the BFD to locate. The supply technicians and property custodian for computer equipment accounted for 66 of these items (91.7 percent). They physically located and presented 50 items and provided documentation that 13 had been excessed, and 3 were transferred out. The other six items remain missing. Among the items missing were three computer monitors, one central processing unit, one printer, and one tape drive.
From the under $1,000 universe of 2,579 technical equipment items, we selected a statistical sample of 150 items for the BFD to locate. The supply technicians and the property custodian for technical equipment accounted for 108 of these items (72.0 percent). They physically located and presented 86 items, provided documentation that 3 were identified as surplus, 6 had been destroyed, 1 had been transferred out to another location, and 1 had been reported as lost or stolen. In addition, the property custodian provided certifications for 11 items.
The supply technicians and property custodian for technical equipment also presented 10 items to us that they stated were the items in the sample; however, these items had neither a barcode nor a serial number that we could verify. Among these 10 items were a pinhole lens, a color camera, and a set of binoculars. The other 32 items remain missing. Among the items missing were cassette recorders, video cameras, a television monitor, binoculars, and a videocassette recorder.
Finally, we tested a statistical sample of ET items for the BFD to locate. Because of the manner in which the property custodian for ET tracks the inventory in his database, we further subdivided the ET testing into three property areas: 1) radio equipment, 2) data communication equipment, and 3) physical security equipment.
From the under $1,000 universe of 471 ET radio equipment items, we selected a statistical sample of 27 items for the BFD to locate. The supply technicians and property custodian for ET accounted for 20 of these items (74.1 percent). They physically located 18 of the items and provided documentation that 2 items had been excessed. However, another three items, all of which were radio circuit lines, had neither a barcode nor a serial number that we could verify.18 The other four items, including a radio scanner and a radio charger, remain missing.
Data Communication Equipment
We selected a statistical sample of 30 items from the universe of 400 ET data communication equipment items for the BFD to locate. The supply technicians and property custodian for ET accounted for 28 of these items (93.3 percent). They physically located and presented 26 items in the sample and provided certifications for an additional 2 items. However, one item had neither a barcode nor a serial number that we could verify, and one item, a converter, remains missing.
Physical Security Equipment
We selected a statistical sample of 29 items from the universe of 600 ET physical security equipment items for the BFD to locate. The supply technicians and property custodian for ET accounted for 28 of these items (96.6 percent). They physically located and presented 25 items, provided certifications for 2, and documentation that 1 item had been transferred out of the BFD. However, one item, a color camera, had neither a barcode nor a serial number that we could verify.
Analysis of Under $1,000 Testing
For all four property areas under $1,000 that we tested, we found that the BFD has a decreased chance of locating property if it is excluded from the Property Management Application, even if it is included in a property custodian's separate inventory database. We also identified items that were not included in the Property Management Application even though the items met the FBI's definition of accountable property. Specifically, during our development of the under $1,000 universes, we found 141 items with listed acquisition costs exceeding $1,000 remaining in the ET list of radio equipment. We asked the Lead Supply Technician to review these items, and he determined that 21 of the 141 items had actual acquisition costs greater than $1,000 and therefore should be included in the Property Management Application. The items included, among others, one hand-held radio, four computer monitors, and eight remote consoles. The Lead Supply Technician concluded that other offices had ordered at least 15 of the 21 items for the BFD, and that the purchase order was never provided to him. Because we could not verify that purchases by other offices were the actual cause of these omissions from the Property Management Application, the Property Procurement and Management Section at FBI Headquarters should investigate whether this issue is unique to the BFD or whether items ordered on behalf of other divisions were also not included in the Property Management Application.
We identified three central processing units in the under $1,000 computer equipment database. As previously noted, all central processing units should be included in the Property Management Application regardless of cost. We determined that one central processing unit had been excessed, another was missing, and the third should have been added to the Property Management Application. The BFD could not provide an explanation as to why this oversight occurred.
We selected a judgmental sample of property currently in use at the BFD to determine whether the items were included in the Property Management Application. We selected a total of 55 items during walk-throughs of the Baltimore office and the resident agencies for eight of the nine property areas.19
The supply technicians provided copies of Property Management Application records for 48 of the 55 items selected. Of the remaining seven items, all were reported to have acquisition costs of under $1,000. According to the documentation provided, four of these items were once included in the Property Management Application but were deleted when the dollar threshold was increased to $1,000. The other three items, a camera tripod, laserjet printer, and computer monitor, were not required to be included in the Property Management Application based on their costs. Of the seven under $1,000 items, we were only able to locate five in the separate databases maintained by the property custodians.
After we completed our location testing and walk-throughs, we examined the frequency and results of the BFD's most recent physical inventories and tested the BFD's disposal of property for proper documentation and timeliness.
The Justice Property Management Regulations and the FBI's Accountable Property Manual require the BFD to perform a complete physical inventory of all capitalized property at least once every year and a complete physical inventory of all controlled personal property at least once every two years. We found that since FY 2001 the BFD has adhered to the FBI and Justice Property Management Regulations' requirements for inventories. It conducted the most recent biennial inventory in FY 2003. In addition, because of the thefts by Stull, the BFD conducted a special inventory of photography equipment in January 2003, and as a result developed a complete list of all accountable and non-accountable property in that area.
The FBI uses scanner technology to complete the overall inventory, and our review of the documentation of the 2003 inventory showed adequate segregation of duties with regard to the physical inventory process. The Property Management Application produces a report of the results of the physical inventory. According to the Administrative Officer, at the time of the 2003 biennial inventory, the Property Management Application contained approximately 5,000 property items that were assigned to the BFD. The Administrative Officer also stated that the BFD was unable to locate about one percent of these items during that inventory. We reviewed the documentation for the remaining 22 items (0.4 percent) that could not be located during or since the 2003 biennial inventory. We determined that the BFD conducted adequate searches for and reviews of the circumstances surrounding these missing items.
We also tested the BFD's compliance with the FBI requirement that an FD-500 form be submitted to FBI Headquarters when items are lost, missing, or stolen. (See Appendix VI for a sample FD-500 form.) The BFD provided copies of FD-500 forms that corresponded to the 22 property items that were not located during or since the 2003 biennial inventory.20 The BFD classified 2 items as stolen and 20 items as lost; none of the items were identified as confidential property or as containing sensitive or classified material. Based on these results, we concluded that the BFD complied with the FBI FD-500 documentation requirement.
FBI field divisions are responsible for informing FBI Headquarters that an item is ready for disposal and for complying with the timeline and method of disposal as instructed by FBI Headquarters. The Accountable Property Manual includes a requirement that once FBI Headquarters approves the disposal of an item of property, the field office has 30 days to dispose of it. As described below, our testing in this area revealed that the BFD did not fully comply with this 30-day requirement, but for valid reasons.
We received a list from FBI Headquarters of 474 items that had been disposed of or identified as excess by the BFD since January 1, 2003. In order to determine whether the BFD received the appropriate authorization to dispose of these items and whether the items were disposed of in the provided amount of time, we reviewed documentation for a judgmental sample of 47 items (10 percent). Our results are as follows:
Results of Disposal Testing at the BFD
We found that the BFD did not begin processing 1 item for disposal and did not actually dispose of another 7 of the 47 items. Rather, FBI Headquarters "admin deleted" these seven items from the Property Management Application when the property threshold increased from $500 to $1,000 because the items' acquisition costs were less than $1,000. The Property Management Application system classifies these items as "disposed" even though the items are still in use at BFD. We asked the Lead Supply Technician about the delays in 20 of the 34 items that were disposed of. He explained that for those items disposed of 4 days late, he had disposed of the items before the deadline, but that FBI Headquarters did not record the disposition until after the 30 days had passed. In addition, concerning the 54 and 74-day delays, the Lead Supply Technician stated that the electronic communications from FBI Headquarters that ordered the disposal of these items arrived while the 2003 inventory was being conducted. The Lead Supply Technician stated that not only did the supply technicians not have enough time to dispose of the items because of their involvement with the inventory, but also that the items themselves were included in the inventory because they were still active records in the Property Management Application. Therefore, these items could not be disposed of until the inventory was over. Based on the explanations provided, we concluded that the BFD's delay in disposing of several items of property during FY 2003 was reasonable.
We concluded that the FBI should expand its definition of accountable property to require that additional items be tracked in the Property Management Application that meet the definition of controlled personal property in the Justice Property Management Regulations. We believe that items such as cameras, televisions, and videocassette recorders fall under the Justice Property Management Regulations' definition of controlled personal property and are thus required to be included in a personal property accountability system and physically inventoried biennially.
We found that items excluded from the Property Management Application have a decreased chance of being located, even when tracked in a property custodian's separate inventory database. During our location testing, the BFD was able to locate about 99 percent of the items in the Property Management Application sample, but only about 83 percent of the items in the under $1,000 sample. When projecting to the Property Management Application population of 5,620 items, we are 95 percent confident that at least 17 of these property items (0.3 percent) would be unverifiable. Similarly, projecting to the population of 6,071 under $1,000 items tracked separately by property custodians, we are 95 percent confident that the BFD would not be able to locate at least 570 of these property items (9.4 percent) and that at least 133 of these property items (2.2 percent) would be unverifiable.
We also identified items that the BFD did not record in the Property Management Application even though the items met the FBI's definition of accountable property. Specifically, we identified 21 items that were being tracked by the ET property custodian that had acquisition costs of $1,000 or more, as well as 1 central processing unit listed in the computer equipment property custodian's database that had not been listed in the Property Management Application. In addition, we found a lack of segregation of duties between ordering and receipt of credit card purchases that may circumvent the entry of items into the Property Management Application and that individual credit card bills were approved for payment without adequate supporting documentation for the charges.
Finally, we determined that since FY 2001, the BFD has adhered to the FBI and Justice Property Management Regulations' requirements for biennial and annual inventories. We also determined that while the BFD's disposal of property may not have been timely, the BFD had acceptable reasons for the delays.
We recommend that the FBI:
We recommend that the BFD: