Q. What are the OIG’s investigative priorities?
A. The OIG focuses its investigative resources and efforts in three primary areas: (1) procurement and contract fraud, (2) workers’ compensation fraud, and (3) employee integrity matters. Issues not aligned with these investigative priorities are also addressed by the OIG but are done so on a case-by-case basis.
Q. Must the OIG investigate every allegation it receives?
A. No, the OIG does not have to investigate every allegation it receives. Oftentimes, the OIG will refer allegations it receives but opts not to investigate to another responsible entity, such as another OIG or law enforcement organization or GPO management, as appropriate.
Q. Are all investigators employees of GPO? Are they contractors to GPO? How do they identify themselves to a supervisor or employee who is to be interviewed?
A. OIG investigations are conducted by Special Agents employed by GPO OIG; all of whom are government employees. Prior to each initial interview, the agent will identify himself/herself verbally and, when possible and appropriate, display his/her OIG-issued badge and credentials that identify him/her as an OIG Special Agent.
Q. How are supervisors (and employees) notified when they are to be contacted by an investigator for an interview?
A. During an investigation, the OIG Special Agent conducting the investigation will contact the individual to be interviewed directly (usually via telephone) and schedule the interview for a mutually agreed upon date, time, and location. In order to provide a layer of confidentiality for the employee to be interviewed and to contribute to the integrity of the investigation, the interview request and/or interview will not be coordinated with the employee’s supervisor/manager unless specifically requested by the employee or when the OIG is unable to contact the employee in a reasonable amount of time.
Q. What advice, guidance or information should a supervisor give an employee who is to be interviewed by an investigator?
A. First and foremost, any individual interviewed by an OIG Special Agent should remember to be truthful and completely forthcoming in answering all questions. In addition, all GPO employees are required by law and GPO directive to cooperate fully in any OIG investigation. It should be noted, however, that the duty to cooperate does not mean the employee being interviewed loses his/her right against self-incrimination (i.e. 5th Amendment rights) in the event the employee is the Subject of the investigation. The agent conducting the interview will advise the employee if he/she is the Subject of the investigation, as well as provide the employee the proper rights advisement.
Please note that a supervisor may always contact the OIG or GPO Office of General Counsel with situational specific questions, if desired.
Q. May an employee have a union representative present during an interview?
A. Yes, any employee covered by a collective bargaining unit agreement has the right to have a union representative present during an interview if (1) the employee reasonably believes that the interview may result in disciplinary action against the employee and (2) the employee requests representation.
Q. Is there an established OIG investigative timeline?
A. The OIG does not have a firm or legally mandated investigative timeline. However, the OIG generally allots 45 days to review each allegation received and determine whether a full investigation should be initiated. If a full investigation is not initiated, then the OIG may refer the matter to GPO management or another agency for review and/or action, if appropriate, prior to closing the matter to file for possible future reference. In the event a full investigation is initiated, then the investigative timeline is generally six (6) months or longer from the date the full investigation is initiated. The timeline is determined by a number of factors, such the number and complexity of the allegation(s), geographical location of the alleged wrong-doing and participants, prosecutor timeline, OIG resource availability, etc.
Q. How does the OIG report its investigative findings?
A. The OIG reports its investigative findings to the appropriate action authorities through one of three forms – a Report of Investigation (ROI), Letterhead Memorandum (LHM), or Letterhead Letter (LHL) – depending upon the recipient of the report and type/complexity of investigation. The ROI and LHM are primarily used to report investigative findings to GPO management. A LHL is primarily used to report OIG investigative findings to an agency outside of GPO, such as a U.S. Attorney’s Office or another law enforcement organization. ROIs are also occasionally used to report investigative findings to an organization outside of GPO.
Q. Does the OIG impose discipline in any capacity?
A. No, the OIG is only a “finder of facts.” It does not impose any type of corrective action regarding the matters it investigates. The OIG provides its investigative findings to the appropriate action authority (i.e. a federal/state/local prosecutor, GPO management, etc.) for review and determination by that respective entity as to whether action to obtain a criminal, civil, and/or administrative remedy is appropriate.