[Audit Report on the Unemployment Insurance Program, Department of Labor, Government of the Virgin Islands]
[From the U.S. Government Printing Office, www.gpo.gov]
Report No. 99-i-148
Title: Audit Report on the Unemployment Insurance Program, Department
of Labor, Government of the Virgin Islands
Date: DECEMBER 18, 1998
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U.S. Department of the Interior
Office of Inspector General
AUDIT REPORT
UNEMPLOYMENT INSURANCE PROGRAM,
DEPARTMENT OF LABOR, GOVERNMENT OF THE
VIRGIN ISLANDS
REPORT NO. 99-I-148
DECEMBER 1998
MEMORANDUM
TO: The Secretary
FROM: Eljay B. Bowron
Inspector General
SUBJECT SUMMARY: Final Audit Report -
"Unemployment Insurance Program,
Department of Labor, Government of the
Virgin Islands" (No. 99-i-148)
Attached for your information is a copy of the subject final
audit report. The objective of the audit was to determine
whether the Virgin Island's Department of Labor (1)
adequately enforced the collection of unemployment taxes
from employers and deposited such collections in the
appropriate accounts and (2) ensured that only qualified
applicants received unemployment benefits.
The Department's Division of Unemployment Insurance did not
(1) issue unemployment insurance bills to employers in a
consistent and timely manner; (2) ensure the accuracy of
employers' unemployment accounts; (3) actively follow up
with employers concerning delinquent unemployment taxes; (4)
consistently assess interest and penalties against
delinquent employers; (5) ensure that only qualified
applicants received unemployment insurance benefits; (6)
maintain an adequate level of internal controls over
computer operations; (7) adequately safeguard computer and
hard copy files for all individuals who applied for
unemployment benefits; (8) ensure that monthly bank
reconciliations were performed; and (9) ensure that blank,
canceled, and voided checks were controlled and secured. As
a result, delinquent unemployment taxes totaled about
$18.5 million, 156 claimants received excess benefit
payments of more than $152,800, supporting records were not
available for 183 additional claimants who received benefit
payments of about $400,400, and 197 canceled checks for
benefit payments could not be located.
Based on the response from the Governor of the Virgin
Islands to the draft report's 12 recommendations to improve
the unemployment tax collection, unemployment benefit
payment, and administrative oversight functions within the
Division of Unemployment Insurance, we considered three
recommendations resolved and implemented and nine
recommendations resolved but not implemented.
If you have any questions concerning this matter, please
contact me at (202) 208-5745 or Mr. Robert J. Williams,
Assistant Inspector General for Audits, at (202) 208-4252.
Attachment
V-IN-VIS-004-97
Honorable Roy L. Schneider
Governor of the Virgin Islands
No. 21 Kongens Gade
Charlotte Amalie, Virgin Islands 00802
Subject: Audit Report on the Unemployment Insurance
Program, Department of Labor,
Government of the Virgin Islands (No. 99-i-148)
Dear Governor Schneider:
This report presents the results of our review of the
Unemployment Insurance Program administered by the
Department of Labor, Government of the Virgin Islands.
The objective of the audit was to determine whether the
Department (1) adequately enforced the collection of
unemployment taxes from employers and deposited such
collections in the appropriate accounts and (2) ensured
that only qualified applicants received unemployment
benefits.
Based on our review, we concluded that the Department's
Division of Unemployment Insurance did not (1)
effectively collect unemployment taxes from employers,
(2) ensure that only qualified applicants received
unemployment benefits, and (3) have an adequate level
of administrative controls over its bank accounts.
Specifically, we found that:
- The Division did not (1) issue unemployment
insurance bills to employers in a consistent and timely
manner, (2) ensure the accuracy of employers'
unemployment accounts, (3) actively follow up with
employers concerning delinquent unemployment taxes, (4)
consistently assess interest and penalties against
delinquent employers, and (5) maintain an adequate
level of internal controls over computer operations.
As a result, 43 employers overpaid their unemployment
taxes and had to be issued refunds totaling about
$496,600, 21 employers underreported their
unemployment taxes by about $60,000, about 2,100
employers owed $17.4 million in delinquent unemployment
taxes and 80 government and nonprofit employers owed
$1.1 million for unemployment benefits paid to their
former employees, interest and penalties totaling about
$16,400 were not assessed during fiscal years 1996 and
1997, and there was little assurance that the status of
employers' unemployment tax accounts on the Division's
computer system was reliable.
- The Division did not (1) ensure that only qualified
applicants received unemployment insurance benefits and
(2) adequately safeguard computer and hard copy files
for all individuals who applied for unemployment
benefits. As a result, 156 claimants received excess
benefit payments of more than $152,800, supporting
records were not available for 183 additional claimants
who received benefit payments of about $400,400, and
there was little assurance that information on
claimants and benefits payments on the Division's
computer system was reliable.
- The Division did not ensure that (1) monthly bank
reconciliations were performed and (2) blank, canceled,
and voided checks were properly controlled and secured.
As a result, discrepancies existed between bank and
book balances for the Division's Unemployment Benefit
Account, and 197 canceled checks for benefit payments
could not be located.
We made 12 recommendations to the Governor of the
Virgin Islands to improve the unemployment tax
collection, unemployment benefit payment, and
administrative oversight functions within the Division
of Unemployment Insurance.
The October 8, 1998, response (Appendix 2) from the
Commissioner of Labor indicated concurrence with all 12
recommendations and provided information on corrective
actions that had been or were being taken. Based on
the response, we consider three recommendations
resolved and implemented and nine recommendations
resolved but not implemented. Accordingly, the
unimplemented recommendations will be forwarded to the
Assistant Secretary for Policy, Management and Budget
for tracking of implementation.
Since the report's recommendations are considered
resolved, no further response to this office is
required (see Appendix 3).
The Inspector General Act, Public Law 95-452, Section
5(a)(3), as amended requires semiannual reporting to
the U.S. Congress on all audit reports issued, the
monetary impact of audit findings (Appendix 1), actions
taken to implement audit recommendations, and
identification of each significant recommendation on
which corrective action has not been taken.
We appreciate the assistance of the staff of the
Department of Labor in the conduct of our audit.
Sincerely,
Eljay B. Bowron
Inspector General
CONTENTS
Page
INTRODUCTION.................... 1
BACKGROUND ................................ 1
OBJECTIVE AND SCOPE................................ 2
PRIOR AUDIT COVERAGE............................... 3
FINDINGS AND RECOMMENDATIONS....................... 4
A. UNEMPLOYMENT TAX COLLECTIONS................... 4
B. UNEMPLOYMENT BENEFIT PAYMENTS.................. 12
C. ADMINISTRATIVE CONTROLS........................ 17
APPENDICES
1. CLASSIFICATION OF MONETARY AMOUNTS............. 20
2. DEPARTMENT OF LABOR RESPONSE................... 21
3. STATUS OF AUDIT REPORT RECOMMENDATIONS......... 28
INTRODUCTION
BACKGROUND
The Unemployment Insurance Program in the Virgin
Islands is a coordinated Federal-local program that
operates under the provisions of Title 20, Chapter V,
of the Code of Federal Regulations and Title 24,
Chapter 12, of the Virgin Islands Code. The Code of
Federal Regulations defines the Federal requirements
under which state unemployment insurance programs must
operate to be eligible for certification under the
Federal Unemployment Tax Act. Such certification
allows tax credits to be given to employers against
unemployment taxes imposed by the Internal Revenue Code
of 1954 and grants to be given to the states for
administrative expenses of their unemployment insurance
programs. The Virgin Islands Code defines the specific
policies and procedures under which the Unemployment
Insurance Program operates in the Virgin Islands.
According to the Governor's Executive Budget for fiscal
year 1998, the Virgin Islands Department of Labor has
the overall responsibility for "promoting and
protecting the welfare of workers, and developing
programs and services designed to alleviate labor
problems which would interfere with business harmony
and stability." The Department's Division of
Unemployment Insurance provides temporary income to
workers who are unemployed or underemployed through no
fault of their own. In accordance with Title 24,
Section 301, of the Virgin Islands Code, benefit
payments to claimants are funded through "the
systematic accumulation of funds [paid by employers]
during periods of employment from which benefits may be
paid [to individuals] during periods of unemployment."
The Division of Unemployment Insurance has a total
staff of 38 employees and maintains an office on
St. Thomas and two offices on St. Croix. The office on
St. Thomas is the main office, and it processes all
unemployment tax payments received from employers and
all unemployment benefit payments made to claimants.
This office also maintains all files related to
employers in the Virgin Islands. All three offices
accept applications for unemployment benefits and
maintain files related to applicants in their
respective geographic areas of responsibility.
Interstate and combined wage claims (benefits paid to
claimants who worked in the United States and the
Virgin Islands during the benefit year) are processed
by the office on St. Thomas.
The Division's records indicate that, during fiscal
year 1997, there were about 3,400 Federal, local
government, and private employers in the Virgin
Islands. Private employers are required by the Virgin
Islands Code and the Department of Labor's regulations
to submit to the Division quarterly reports of all
employees and their wages and to pay unemployment tax
contributions based on tax rates assigned by the
Division. Federal and local government agencies and
nonprofit organizations may elect to reimburse the
unemployment insurance program for benefits paid to
their former employees in lieu of making quarterly
unemployment tax payments, and all such entities in the
Virgin Islands have chosen that reimbursement method.
Unemployment tax collections from private employers
totaled $8.8 million during fiscal year 1996 and
$7.7 million during fiscal year 1997.
Under Federal law, the unemployment tax collections are
deposited with the Treasury of the United States on
account for the Virgin Islands. The Division makes
drawdowns against this account to pay weekly
unemployment benefits to claimants. The drawdowns from
the Federal Unemployment Insurance Fund totaled
$9.9 million during fiscal year 1996 and $7.4 million
during fiscal year 1997.
To qualify for unemployment benefits, an applicant must
meet certain eligibility requirements that are defined
in the Virgin Islands Code and the Unemployment Benefit
Manual. In general, a claimant must have qualifying
wages, be unemployed or underemployed, be physically
able to work, be available to work, and be actively
seeking work. A claimant can receive benefits of as
much as $231 per week (depending on the total amount of
qualifying wages) for an initial period of 26 weeks.
Benefit amounts may be reduced or denied entirely if
the claimant receives other forms of income. If an
applicant is disqualified from receiving benefits and
disagrees with this determination, the individual may
appeal and ask for a hearing by an impartial examiner.
About 11,000 claimants[1] received benefits totaling
$11.5 million during fiscal year 1996, and about 7,300
claimants received benefits totaling $6.7 million
during fiscal year 1997. Unemployment tax refunds to
employers and other payments from the Unemployment
Insurance accounts totaled about $283,000 in fiscal
year 1996 and $828,000 in fiscal year 1997.
OBJECTIVE AND SCOPE
The objective of the audit was to determine whether the
Department of Labor (1) adequately enforced the
collection of unemployment taxes from employers and
deposited such collections into the appropriate
accounts and (2) ensured that only qualified applicants
received unemployment benefits. The scope of the audit
included a review of unemployment tax billing and
collection practices and unemployment benefit payment
practices that were in effect during fiscal years 1996
and 1997 and other periods as appropriate. The audit
was performed at the offices of the Department of Labor
on St. Thomas and St. Croix and the Department of
Finance on St. Thomas.
Our review was made in accordance with the "Government
Auditing Standards," issued by the Comptroller General
of the United States. Accordingly, we included such
tests of records and other auditing procedures that
were considered necessary under the circumstances.
We limited the evaluation of internal controls over
operations of the Division of Unemployment Insurance to
the extent that we considered necessary to accomplish
the audit objective. The internal control weaknesses
identified were related to the collection of insurance
taxes from employers, the processing of unemployment
benefit claims and payments, and the administrative
controls over bank accounts. These weaknesses are
discussed in the Findings and Recommendations section
of this report. The recommendations, if implemented,
should improve the internal controls in these areas.
PRIOR AUDIT COVERAGE
Neither the General Accounting Office nor the Office of
Inspector General has conducted any prior audits of the
Unemployment Insurance Program of the Virgin Islands
Department of Labor.
**FOOTNOTES**
[1]:The 11,000 claimants during fiscal year 1996 included
individuals who were unemployed or underemployed in the
aftermath of Hurricane Marilyn in September 1995.
FINDINGS AND RECOMMENDATIONS
A. UNEMPLOYMENT TAX COLLECTIONS
The Division of Unemployment Insurance did not
effectively enforce the collection of unemployment tax
contributions from employers. Specifically, the
Division did not (1) issue unemployment insurance bills
to employers in a consistent and timely manner, (2)
ensure the accuracy of employers' unemployment
accounts, (3) actively follow up with employers who had
delinquent unemployment taxes, and (4) consistently
assess interest and penalties against delinquent
employers. Title 24, Section 309, of the Virgin
Islands Code outlines the legal requirements related to
the collection of delinquent and contested unemployment
taxes. Section 310.8 of the Department of Finance's
Government Accounting Manual requires that agencies
keep an up-to-date record of issued bills and
periodically follow up on those bills which are past
due. The Department of Labor's Unemployment Tax Manual
contains the procedures for the collection of
unemployment taxes. However, the deficiencies existed
because Division officials did not effectively
supervise the collection process or organize available
staff resources to ensure compliance with existing
policies and procedures. In addition, the Division was
dependent on an outdated computer system that did not
have basic internal controls to ensure the integrity of
data and the accuracy of the bills issued. As a
result, 43 employers overpaid their unemployment taxes
and had to be issued refunds totaling about $496,600;
21 employers underreported their unemployment taxes by
about $60,000 because the incorrect tax rates were
used; about 2,100 employers (who were subject to
quarterly payment of unemployment taxes) owed $17.4
million in delinquent unemployment taxes and
80 employers (who had elected to pay unemployment taxes
on a reimbursable basis) owed $1.1 million for
unemployment benefits paid to their former employees;
and interest and penalties totaling about $16,400 were
not assessed during fiscal years 1996 and 1997.
Issuance of Bills
The Division issued quarterly unemployment insurance
report forms, which are used by the employers to report
the names, Social Security numbers, and salaries of its
employees and to determine the amount of unemployment
taxes to be paid, to employers in a timely manner.
Additionally, the Division issued up to two special
notices to employers each year: one notice to inform
them that a "delinquent tax rate" of 9.5 percent would
be applied in the following year if any delinquent
unemployment taxes were not paid by December 31 and the
second notice to inform them, by January 31, of their
unemployment tax rate for the current year.[2]
However, Part E-8c of the Unemployment Insurance Manual
also requires that the Division issue statements of
account (bills) to employers at other times during the
year as needed to inform them of transactions related
to their unemployment insurance accounts; missing
quarterly reports; and outstanding unemployment taxes,
including interest and penalties. Our review disclosed
that such bills were not issued to employers after
1994. Additionally, bills for the first quarter, which
ended March 31, 1997, were not issued until May 1997,
and bills for the second quarter, which ended June 30,
1997, were not issued until August 1997. Further,
these bills were not subjected to the Division's normal
process of printing an "edit run" to allow its staff to
identify obvious errors prior to printing and issuing
the bills. We also found that bills for the third
quarter, which ended September 30, 1997, were not
issued. The Division's Computer Manager told us that
he was instructed by his supervisor not to issue the
third quarter bills because the "edit run" would not be
corrected and the issuance of inaccurate bills would
result in "too many" inquiries from employers.
However, the Computer Manager's supervisor said that a
computer problem resulted in the incorrect calculation
of interest due on outstanding balances and that the
bills were therefore not issued.
Verification of Employer Payments
Part E-7b of the Unemployment Tax Manual requires the
Division to contact employers by telephone to verify
and/or correct the amount of unemployment tax payments
received, and Part E-7g of the Manual requires the
Division to send memoranda to employers who have
underpaid or overpaid unemployment taxes, interest, or
penalties. However, we found that the Division did not
always perform these functions. As a result, some
employers continued to make overpayments over a period
of several quarters and eventually had to be refunded
payments by the Division. For example, we found that
at least 43 employers were issued refunds totaling
about $496,600 during the period of June 1995 to August
1997.
Additionally, we reviewed a sample of 60 employer
accounts (35 on St. Thomas and 25 on St. Croix) and
found that 21 employers who had delinquent unemployment
taxes totaling $961,000 had underreported their tax
liabilities by about $60,000 because they had used the
incorrect unemployment tax rates. However, we found no
evidence in the Division's files for these employers to
indicate that they had been contacted regarding the
underreported taxes or the delinquent balances.
Therefore, we contacted the employers through site
visits and telephone inquiries to determine the reasons
for the delinquencies and/or the underreporting of
taxes. In 12 cases, the employers stated that they had
not been contacted by the Division concerning the
unpaid or underreported taxes. For example:
- One business did not submit quarterly unemployment
reports or make unemployment tax payments for calendar
years 1993 through 1995 and had made only one payment
for 1996. Although the business had an outstanding
balance of more than $130,000, the business owner had
not been contacted by the Division, and no legal action
had been taken to enforce collection of the delinquent
amount.
- Another business did not make any unemployment tax
payments in 4 years. Although the business had an
outstanding balance of more than $140,000, this
business owner also had not been contacted by the
Division, and no legal action had been taken to collect
the delinquent amount.
Collection of Delinquent Taxes
The collection enforcement procedures established by
the Virgin Islands Code and the Unemployment Tax Manual
were not used by the Division to ensure the collection
of delinquent unemployment taxes. Title 24, Section
309(b)(1), of the Virgin Islands Code states that if an
employer defaults on unemployment tax payments and/or
interest and penalties accrued on an outstanding
balance, civil action should be taken against the
employer. The Tax Manual also defines collection
options that are available to the Division, including
establishing an 8-month installment payment plan,
issuing demand letters, and seeking an injunction
against the continued operation of the delinquent
business. However, none of these collection options
were used by the Division. As a result, as of July
1997, 2,099 employers who were subject to quarterly
payment of unemployment taxes owed delinquent taxes of
$17.4 million, and 80 employers who had elected to pay
unemployment taxes on a reimbursable basis owed an
additional $1.1 million as reimbursement for
unemployment benefits paid to their former employees.
To test the level of collection enforcement activity by
the Division, we reviewed the files for a sample of 60
employers (35 on St. Thomas and 25 on St. Croix). We
found that 24 employees (8 on St. Thomas and 16 on
St. Croix) had delinquent taxes of about $988,500.
However, the records maintained by the Division's
revenue officers contained documentation of collection
action for only 2 of the 24 delinquent employers (both
on St. Thomas). For example:
- One business did not file unemployment reports or
pay taxes for 11 consecutive quarters in 1995 through
1997. Despite attempts by Division officials,
including an audit of the business in June 1996 which
disclosed that the business owner had underreported
wages paid to employees in 1992, 1993, and 1994, the
business owner did not agree to an installment payment
plan or otherwise pay the unemployment taxes of $47,400
that were owed. However, the Division did not pursue
more aggressive collection actions, such as seeking an
injunction against further business activity or
referring the case for legal action.
- Another business had not made any quarterly
unemployment tax payments since September 1993 and owed
$590,000. Although the business agreed to an
installment payment plan in 1995, it did not make
regular payments against the delinquent amount. The
business owner told us that the Government owed the
business for two contracts and that it therefore did
not have funds to pay the delinquent taxes. However,
the Division did not pursue other available collection
options, such as offsetting the delinquent taxes
against the amounts that the Government may have owed
the business.
The Division's Acting Chief of Tax told us that the
three revenue officers on St. Croix did not perform
collection activities because they had to routinely
respond to inquiries from employers concerning errors
in their accounts. The Chief stated, however, that
during 1995 and 1997, the one revenue officer on
St. Thomas contacted delinquent employers by telephone.
Division officials also stated that the lack of more
aggressive collection efforts was due to the lack of
vehicles for site visits by revenue officers. At the
July 23, 1998, meeting to discuss the preliminary draft
of this report, the Commissioner of Labor noted that an
undetermined portion of the delinquent unemployment
insurance taxes of $17.4 million may be owed by
employers who are no longer in business and therefore
should be written off as uncollectible.
We also found that the Division was not effective in
pursuing the collection of amounts owed by government
and nonprofit employers who had elected to reimburse
the Unemployment Insurance Program for unemployment
benefits paid to their former employees in lieu of
making quarterly unemployment tax payments.
Specifically, as of September 30, 1997, 48 government
employers owed $936,500 and 32 nonprofit employers owed
$231,200, for a total of about $1.1 million. Although
Title 24, Section 308(e), of the Virgin Islands Code
requires that nonprofit employers who elect to use the
reimbursement method obtain surety bonds in the event
that funds are not available to pay extended
unemployment benefits to former employees, the Division
did not ensure that such surety bonds had been
obtained. We found that 5 of 10 employers contacted
were not aware that they had outstanding balances.
Assessment of Penalties and Interest
Our review also disclosed that during fiscal years 1996
and 1997, Division employees backdated the receipts for
281 unemployment tax payments in order to prevent the
Division's computer from automatically assessing
penalties and interest on late payments, which resulted
in the loss of penalties and interest totaling $16,400.
Although Division policy states that only the Director
and the Chief of Tax are authorized to waive penalties
and interest, Division officials told us that other
Division employees were familiar with the procedures
necessary to bypass the computerized assessment of
penalties and interest. However, several employees
told us that they were instructed by past and present
supervisors to backdate the contribution payment
receipts. We could not verify either explanation
because there was no documentation as to who bypassed
the process to automatically assess penalties and
interest. When we told the Division's Director of the
backdating, she developed a form to be used by the
Division to approve and document the waiver of
penalties and interest.
Use of Staff Resources. We believe that the principal
cause of the collection enforcement deficiencies
disclosed by our review was that the Division did not
effectively supervise and use its available staff
resources. Specifically, although most of the
employer-related activity and record keeping took place
on St. Thomas, the Division's Tax Contribution Section
had six staff positions on St. Thomas (a collector, a
fiscal assistant, two data entry operators, and two
revenue officers) and six staff positions on St. Croix
(the Acting Chief of Tax, an auditor, three revenue
officers, and a computer programmer). Therefore, in
addition to the revenue officers on both islands
devoting a significant amount of time in responding to
inquiries from employers instead of conducting
collection enforcement activities, as discussed
previously, we found that some of the staff members on
St. Croix were not used appropriately as follows:
- The computer programmer on St. Croix was assigned as
a collector, which we believe was not an effective use
of the employee's computer programming expertise.
Additionally, the presence of a computer programmer at
the St. Thomas office would have allowed the Division
to segregate some of the computer-related
responsibilities. Instead, the Division's Computer
Manager on St. Thomas had no support staff and had
unrestricted access to all computer operations.
- The auditor on St. Croix had completed only two
audits of employers during the past 4 years, although
many employers on St. Thomas who had large-dollar
delinquencies had never been audited. Therefore, we
believe that the auditor's expertise could have been
more effectively used on St. Thomas.
Additionally, because the Acting Chief of Tax was
located on St. Croix rather than on St. Thomas, where
most of the employer-related activity and record
keeping was centered, he could not provide adequate
supervisory oversight over the activities of the Tax
Contribution Section's staff on St. Thomas. The audit
guide "Assessing Internal Controls in Performance
Audits," issued by the U.S. General Accounting Office,
states that a key element of an effective system of
internal controls is that "qualified and continuous
supervision is to be provided to ensure that internal
control objectives are achieved." Therefore, we
believe that the allocation of the Division's staff,
particularly with regard to the Tax Contribution
Section, should be reviewed and revised to allow for
more effective supervision and use of available staff
resources.
Reliability of Computerized Data
The "Fraud Examiners Manual"[3] includes a description
of the general security controls that should exist
within a computerized system. According to the
"Manual," these controls include the following: (1)
restricting programmers' access to input data and
computer operations, (2) restricting computer
operators' access to computer programs, (3) ensuring
that only authorized people have access to the computer
programs and data files by using password access
restrictions, and (4) establishing emergency
procedures for the backup and restoration of computer
programs and critical data files. However, none of
these control features were in place within the
Division's computer operations unit. The Computer
Manager worked alone and performed all administrative,
programming, and operating tasks related to the
computer system. Moreover, the Computer Manager told
us that he had access to all employees' passwords and
to the Chief of Security's main password, which gave
him unlimited access to all of the system's
capabilities and data. Although user passwords should
be changed at least once a year, the Computer Manager
used an option within the system to match passwords to
specific screens/functions, which did not allow
employees to set their own passwords. The Computer
Manager also told us that after Hurricane Marilyn in
September 1995, he entered information to establish new
and update existing claimant accounts because of the
increased number of unemployment claims received after
the hurricane. We believe that all of these factors
resulted in a major breakdown of internal controls over
the Division's computer operations which placed the
integrity of all unemployment insurance tax collection
and benefit payment data, including confidential
employer and employee data, at risk. During our audit,
we noted discrepancies between information in the
Division's computer and in the related hard copy files
as follows:
- The computer file for an employer showed that, as of
November 18, 1997, the employer owed interest of $984.
However, because the business's "start" date was
October 4, 1997, it was unlikely that interest of $984
on unpaid unemployment taxes would have accumulated in
the 6 weeks that the business was in operation.
Therefore, we believe that either the interest due
amount or the recorded business start date was
incorrect.
- Similarly, the computer file for another employer
showed that, as of November 18, 1997, the employer owed
interest of $27,783. However, the business's "start"
date was June 2, 1997, and the employer was current in
the payment of unemployment taxes for the second and
third quarters of calendar year 1997. Therefore, we
believe that either the interest due amount or the
recorded business start date was incorrect.
- On June 8, 1995, one of the 43 employers discussed
previously in this finding had made overpayments of
unemployment taxes and received a refund payment of
$27,709 based on data contained in the Division's
computer system. However, our review of the hard copy
files for this employer indicated that the employer
owed delinquent taxes of $74,212 for the same time
period and was therefore not entitled to the refund.
- Another employer's computer record showed a credit
balance of $9,285, which indicated an overpayment.
However, our review of the hard copy files disclosed
that the employer owed delinquent taxes of $77,235. We
found that the discrepancy occurred because of a data
input error related to the settlement of an
administrative appeal.
Because of the errors cited, we believe that
unemployment insurance data on the Division's computer
is not reliable.
As of February 1998, when our audit fieldwork was
completed, Virgin Islands Department of Labor officials
were in the process of finalizing a grant agreement
with the U.S. Department of Labor that would provide
$2.9 million for the acquisition and installation of a
new computer system for the Unemployment Insurance
Program, which would allow the Division to improve its
operations and also overcome "Year 2000 problems"[4] in
its computer system. However, we believe that the
staffing and operating procedures of the Division's
computer operations unit should also be analyzed and
revised to provide a reasonable level of internal
control and assurance that the unemployment insurance
data are accurate and reliable.
In a July 21, 1998, memorandum to the Information
Technology staff, the newly hired Assistant Director
established interim procedures to (1) restrict computer
programmers' access to data input and computer
operations functions, (2) restrict computer operators'
access to computer programs, (3) ensure that system
users had active passwords to restrict unauthorized
access to the system, (4) establish emergency
procedures for off-site backup of important computer
files, and (5) maintain an audit history of all
computer accesses. At the July 23, 1998, meeting to
discuss a preliminary draft of this report, the
Commissioner stated that the Department had received a
portion of the U.S. Department of Labor grant to
upgrade its computer operations and had begun
negotiations to acquire a new unemployment insurance
software system from a state whose unemployment
insurance program was similar to that of the Virgin
Islands.
Recommendations
We recommend that the Governor of the Virgin Islands
direct the Commissioner of Labor to:
1. Enforce existing procedures contained in the
Unemployment Tax Manual which require the Division of
Unemployment Insurance to issue periodic (such as
quarterly) statements of account to employers that are
delinquent in the payment of unemployment insurance
taxes.
2. Enforce existing procedures contained in the
Unemployment Tax Manual which require the Division of
Unemployment Insurance to contact employers that are
delinquent in the filing of quarterly unemployment
insurance tax reports or that have overpaid or
underpaid unemployment taxes.
3. Enforce existing procedures contained in the
Unemployment Tax Manual which require the Division of
Unemployment Insurance to follow up with delinquent
employers to ensure that they make arrangements to pay
outstanding balances. For those employers who do not
respond to initial collection efforts, other
enforcement collection options should be used. After
all available collection options have been made,
accounts for employers that are no longer in operation
should be written off as uncollectible.
4. Establish formal procedures to ensure that waivers
of penalties and interest on delinquent unemployment
taxes are made only with the written approval of
authorized Division of Unemployment Insurance
officials.
5. Perform an analysis of the work load and staffing to
identify the staffing needs of the Tax Contribution
Section of the Division of Unemployment Insurance and
restructure the Section to achieve better supervision
and use of staff resources.
6. Ensure that Division of Unemployment Insurance
officials adequately plan for the acquisition and
installation of the new computer system so that the
system will meet the Division's long-term data
processing needs, provide an adequate level of internal
controls and segregation of duties, and provide
accurate and reliable data.
**FOOTNOTES**
[2]:The unemployment tax rates vary depending on the
extent to whicheach employer's former employees received
unemployment insurance benefits in the prior calendar year.
[3]:The "Fraud Examiners Manual" (second edition),
Chapter 1.1600 ("Computer Fraud"), published by the Association
of Certified Fraud Examiners, 1993.
[4]:The term "Year 2000 problems" is used to describe
the potential failure of information technology systems,
applications, and hardware that would make them unreliable
because of their inability to correctly interpret dates
after December 31, 1999. (That is, many computer
systems that use two digits to keep track of the date will,
on January 1, 2000, recognize "double zero" not as 2000
but as 1900.) Commissioner of Labor Response and Office
of Inspector General Reply
The October 8, 1998, response (Appendix 2) to the draft
report from the Commissioner of Labor concurred with
the six recommendations and indicated that corrective
actions either had been or would be taken. Based on
the response, we consider Recommendations 1, 4, and 6
resolved and implemented and Recommendations 2, 3, and
5 resolved but not implemented (see Appendix 3).
B. UNEMPLOYMENT BENEFIT PAYMENTS
The Division of Unemployment Insurance did not (1)
ensure that only qualified applicants received
unemployment insurance benefits and (2) adequately
safeguard computer and hard copy files for all
individuals who applied for unemployment benefits.
Title 24, Sections 304 and 305(d)(2), of the Virgin
Islands Code contains the basic eligibility
requirements for unemployment benefit applicants, and
Section 312 of the Code makes the Commissioner of Labor
responsible for providing regulations for the
destruction of agency records. The Unemployment
Benefit Manual contains specific procedures for
processing claims. However, there were insufficient
management controls to ensure that these requirements
were complied with by the staff of the Division's
Benefit Claim Section. As a result, 156 claimants
received excess benefit payments of more than $152,800,
and supporting records were not available for 183
additional claimants who received benefit payments of
about $400,400.
Processing of Benefit Applications
According to the Unemployment Benefit Manual, each
applicant for unemployment benefits is required to
complete an initial claim form and provide the reason
for separation from the last employer. If the reason
given on the initial claim form is "lack of work," the
claim is automatically accepted without being forwarded
to one of the Division's adjudicators.[5] If the
applicant does not provide a letter of separation from
the last employer, a copy of the initial claim form
must be sent to the last employer for verification of
the reason for separation. Additionally, the last
employer is to be notified when benefits are paid to a
former employee.
However, based on our review of a sample of
31 applicant files, we found that 3 applicants had
received unemployment benefits, although they had
listed "lack of work" as the reason for separation from
the last employer and their files did not contain
documentation verifying that the reason for separation
had been obtained from their last employer. One
applicant had voluntarily quit his job but received
unemployment benefits of $345, which had not been
recovered by the Division at the time of our review.
When the employer was notified that unemployment
benefits had been paid to the former employee, the
employer contacted the Division to explain that the
employee had voluntarily quit his job.
The Unemployment Benefit Manual also requires that
applicants submit a copy of their Social Security card
with their initial claim forms. The Division's Chief
of Benefits told us that verification of Social
Security numbers was given "special attention."
However, we found that the numbers were not always
verified in that our review of the Division's benefit
payment list disclosed that the Social Security numbers
provided by four applicants were not valid. In one
instance, the applicant's file contained a copy of the
individual's Social Security card, but the number on
the benefits list and on benefit checks issued to the
individual was different.
The Unemployment Benefit Manual further requires that
benefits be reduced or denied if an individual receives
any earnings, earning substitutes, or replacements such
as back pay and pensions. Each new applicant should
be interviewed by Benefit Claim Section personnel to
verify information on the initial claim form and to
obtain additional information as necessary about any
additional income reported by the applicant. However,
based on our review of 25 files for applicants who had
been overpaid, we found that in six instances, the
individuals received additional income that would have
made them ineligible for unemployment benefits.
However, this additional income was not identified at
the time of processing of the initial claim. For
example:
- An applicant received unemployment benefits of about
$4,500 for a 5-month period during which he also
received workman's compensation benefits. The Division
had not recovered improper payments of about $3,600 at
the time of our review.
- Another applicant received unemployment benefits of
about $2,080 for a 2-month period during which he also
received severance and vacation pay. The Division had
not recovered improper payments of about $1,900 at the
time of our review.
The Unemployment Benefit Manual further requires an
applicant who is certified as eligible for benefits to
perform weekly job searches and submit job search
reports as a condition of continuing to receive weekly
benefit payments. The job search reports are to be
mailed to the Division by unemployed individuals and
hand carried to the Division by underemployed
individuals. The form used for the job search reports
contains the notices "Your job search[es] are subject
to verification" and "It is necessary that you answer
the questions on this form and return it." However,
the Chief of Benefits told us that the job search
reports were not reviewed and/or verified because there
was "no one on staff" to perform such reviews.
Additionally, there was no followup to ensure that all
benefit claimants submitted the job search reports as
required. We found that, as a result, applicants
continued to receive unemployment benefits after
obtaining full-time employment. For example:
- A claimant received unemployment benefits of about
$2,450 for a 4-month period during which he was
employed on a full-time basis. The entire overpayment
amount was outstanding.
- Another claimant received unemployment benefits of
$3,440 for a 3-month period during which she was
employed on a full-time basis. The individual became
unemployed again, and deductions were being made from
her current unemployment benefits to liquidate the
$3,000 balance that was outstanding.
Supervisory Oversight
Based on our review, we believe that the deficiencies
cited in the benefit payment process occurred because
of an insufficient level of supervisory oversight of
the Benefit Claim Section staff. Specifically,
although the Section had five employees on St. Thomas
and nine employees on St. Croix, the Chief of Benefits,
who was responsible for supervising the Benefit Claim
Section staff on both islands, was located on St.
Thomas. Further, the Benefit Claim Section's two claim
adjudicators on St. Thomas told us that their
recommendations to approve applicants' claims for
unemployment benefits were not reviewed by a supervisor
before being approved and processed for payment. The
Chief of Benefits told us that she did not review the
decisions of one of the claim adjudicators. Of
25 overpayment cases reviewed, we found that in 8
cases, totaling $14,100, the overpayments resulted from
the subsequent reversal of the decisions made by the
claim adjudicators. In these cases, we believe that
supervisory reviews prior to approving the claims could
have prevented the overpayments.
We also believe that the lack of adequate supervisory
oversight contributed to the Benefit Claim Section's
inability to consistently meet the 14-day processing
time frame established in the Unemployment Insurance
Appraisal Manual. In the 1997 Unemployment Insurance
Program and Budget Plan, the former Commissioner of
Labor stated that only 41.9 percent of 1996
unemployment benefit cases were resolved within 14
days. Our review disclosed that only 17 (34.7 percent)
of 49 cases processed by the intrastate adjudicator
during 1997 were resolved within the established time
frame. In the 1997 budget plan, the former
Commissioner of Labor recommended that the vacant
position of Local Office Manager on St. Thomas be
filled to give the Chief of Benefits the opportunity to
effectively monitor all office functions on both
islands. However, the Chief of Benefits was located on
St. Thomas, and there was no budgeted position for a
Local Office Manager on St. Croix to supervise the
staff on that island.
We also found that the lack of segregation of duties in
the Benefit Claim Section compromised the integrity of
the entire benefit payment process. Specifically, the
Chief of Benefits was personally involved in key phases
of the benefit payment process, including performing
data entry of claimant information and printing,
signature stamping, and mailing benefit payment checks.
The U.S. General Accounting Office's guide "Assessing
Internal Controls in Performance Audits" states that
"key duties and responsibilities in authorizing,
processing, recording, and reviewing transactions
should be separated among individuals."
Collection of Benefit Overpayments
Title 24, Section 305(j)(1), of the Virgin Islands Code
requires that claimants repay any overpayments of
unemployment benefits within 2 years of the date of
final determination of their case. The Code also
provides that no repayment will be required if the
overpayment was not the fault of the claimant.
However, our review of the Division's benefit payment
process disclosed that 156 unemployment benefit
claimants (including the specific examples discussed
earlier in this finding) received benefit overpayments
totaling $152,800 based on claims that originated
during the period of 1984 to 1997. The overpayments
were for individual amounts that ranged from $61 to
$5,590, and 65 of the 156 overpayments remained
outstanding longer than the 2-year limit stated in the
Virgin Islands Code. Based on our review of the case
files for a sample of 25 overpayments, we found that 15
overpayments ($21,840) resulted from improper claims by
the applicants, 8 overpayments ($14,190) resulted from
errors by the Division, and 2 overpayments ($460) were
for reasons that were undeterminable because of
incomplete files. We also found that the Division's
Benefit Claim Section had not made a reasonable level
of effort to contact the claimants and to arrange for
repayment of the overpayments which did not result from
errors by the Division. Specifically, 20 of the 25
claimants had never been contacted, and repayment
agreements were negotiated with only 2 of the 15
claimants whose claims were improper. In one of those
cases, the claimant made only four payments, totaling
$200, during the period of June 1995 to December 1997
and owed about $2,730 at the time of our review. In
the other case, the claimant was unemployed, and
deductions were being made from her benefit payments to
liquidate the $3,000 outstanding balance of her
overpayment. In November 1997, two other cases were
referred to the Attorney General for legal action,
although the Division had not used all available
administrative enforcement actions. Further, the
Division had not written off the eight overpayments,
totaling $14,190, that resulted from errors made by the
Division.
Reliability of Computer and Hard Copy Files
We found that significant internal control weaknesses
in the Division's computer operations compromised the
integrity and reliability of data related to the
unemployment benefit payment process (also see Finding
A). The Computer Manager had complete and unrestricted
access to all computer operations and passwords, which
included the ability to enter and revise claimants'
data files and the responsibility to print unemployment
benefit checks. In addition, the Division did not have
any contingency plans for backing up critical files.
On July 8, 1997 (the start date of this audit), the
records for 1,031 benefit claimants were deleted from
the computer master file. The Computer Manager
initially told us that erroneous dates entered into
some of the claimant records by a summer student had
caused the system to fail during the printing of
benefit checks, thus resulting in the records that were
processed being deleted. However, the Computer Manager
later told us that the problem occurred because one of
the computer's 10 disks had become warped because of
the excessive heat in the computer room. In a
memorandum to the Director of the Division of
Unemployment Insurance, the Computer Manager identified
all of the deleted records by Social Security number
and requested that the related hard copy files be used
to reenter the deleted claimant information into the
system to rebuild the master file. However, the hard
copy files for 192 St. Thomas claimants could not be
located. Benefit payment records indicate that the
192 claimants had been paid a total of $418,700 in
unemployment benefits during the period of July 1995 to
June 1997. As of February 1998, the files for 183 of
the 192 claimants had not been located. Therefore,
there was no support for the benefit payments of about
$400,400 that had been made to these 183 individuals.
As discussed in Finding A, Virgin Islands Department of
Labor officials were in the process of finalizing a
grant agreement with the U.S. Department of Labor that
would provide $2.9 million for the acquisition and
installation of a new computer system for the
Unemployment Insurance Program. In addition to our
recommendation (No. A.6) that the staffing and
operating procedures of the Division's computer
operations unit should be analyzed and revised to
provide a reasonable level of internal controls and
assurance that unemployment insurance data are accurate
and reliable, we believe that the Department should
establish formal records retention and disposal
procedures for computer and hard copy records related
to the Unemployment Insurance Program, including the
backup of critical computer files.
Recommendations
We recommend that the Governor of the Virgin Islands
direct the Commissioner of Labor to:
1. Enforce existing procedures contained in the
Unemployment Benefit Manual which require the Division
of Unemployment Insurance to verify claimants' Social
Security numbers and statements regarding termination
of employment, sources of income, and results of job
searches.
2. Perform a work load and staffing analysis to
identify the staffing needs of the Benefit Claim
Section of the Division of Unemployment Insurance and
restructure the Section to achieve better use of staff
resources, a greater level of supervisory oversight of
daily operations, and an adequate level of segregation
of duties.
3. Enforce existing procedures contained in the
Unemployment Benefit Manual which require the Division
of Unemployment Insurance to take collection
enforcement action to recover overpayments and other
improper payments to claimants except for those that
were caused by errors made by Division staff, which
should be written off in accordance with program
requirements.
4. Develop and implement formal records retention and
disposal procedures for the Division of Unemployment
Insurance which will ensure that permanent computer and
hard copy records are maintained for all active
unemployment insurance taxpayers and benefit claimants.
The records retention and disposal plan should also be
in compliance with any records retention requirements
of the Federal Unemployment Tax Act and provide for
secure backup copies of critical computer files.
Commissioner of Labor Response and Office of
Inspector General Reply
The October 8, 1998, response (Appendix 2) to the draft
report from the Commissioner of Labor concurred with
the four recommendations and indicated that corrective
actions would be taken. Based on the response, we
consider Recommendations 1,2, 3, and 4 resolved but not
implemented (see Appendix 3).
**FOOTNOTES**
[5]:According to Department officials, the function of
the adjudicators is to gather additional information
and make an unbiased decision as to a claimant's
eligibility when the reason for separation from the
last employer is an issue in the case.
C. ADMINISTRATIVE CONTROLS
The Division of Unemployment Insurance did not maintain
an adequate level of administrative control over the
Unemployment Insurance Program's bank accounts.
Specifically, the Division did not ensure that (1)
monthly bank reconciliations were performed and (2)
blank, canceled, and voided checks were properly
controlled and secured. Good business practices
dictate that bank accounts be periodically reconciled
and that blank, canceled, and voided checks be properly
controlled and secured. The deficiencies occurred
because the Division did not have formal policies and
procedures for reconciling bank accounts and
controlling blank, canceled, and voided checks. As a
result, discrepancies existed in the cash balances
recorded in the bank statements and the Division's
internal records for the Unemployment Benefit Account,
and 197 canceled checks for benefit payments could not
be located.
Reconciliation of Bank Accounts
The Division had not reconciled the Clearing Account
and Unemployment Benefit Accounts (both checking
accounts) in more than 20 years. Although Division
personnel verified the posting of drawdowns from the
U.S. Treasury, they did not verify the posting of
deposits of unemployment tax collections, canceled
benefit checks, or other bank transactions. Instead,
Division staff maintained an internal register for the
Unemployment Benefit Account that listed all drawdowns
as "debits" and all issued benefit checks as "credits."
However, the balances shown on the internal register
did not match the bank statements because the register
did not take into consideration outstanding checks,
bank service charges, and other "in transit"
transactions. The Division employee who maintained the
internal register said that the procedures she used
were based on supervisory instructions provided to her
about 20 years ago. The Division did not have any
formal procedures for performing formal reconciliations
between the balances shown on the internal register and
on the bank statements.
In March 1997, the Director of the Division instituted
a computerized reconciliation program for the
Division's bank accounts. However, this program was
only a check reconciliation process because it did not
include a reconciliation of deposit information or of
the final monthly account balances. Further, the
computerized check reconciliation program was stopped
in April 1997 because of a situation in which 89
unemployment benefit checks had duplicate check numbers
(see the section "Control of Checks"). Although this
problem was subsequently corrected, the check
reconciliation program was not reactivated.
We also found that there was inadequate supervisory
oversight of the bank account reconciliation process.
For example, the Director told us that she was not
aware that formal reconciliations were not performed
between the Division's internal register and the bank
statements. Further, there was a lack of proper
segregation of duties related to the maintenance of the
Division's bank accounts. Specifically, the same
employee who requested drawdowns from the U.S. Treasury
also prepared the internal bank account registers,
prepared monthly reports to the U.S. Department of
Labor on the status of the accounts, stored canceled
checks, and had the authority to issue "hand drawn"
unemployment benefit checks. We believe that the
absence of monthly bank reconciliations, the lack of
internal procedures for the processing of drawdowns
from the U.S. Treasury, and the lack of segregation of
duties constituted a serious breakdown in basic
internal controls that put Unemployment Insurance
Program funds at the risk of loss or misuse. As noted
in Finding B, the U.S. General Accounting Office's
guide "Assessing Internal Controls in Performance
Audits" states that "key duties and responsibilities in
authorizing, processing, recording, and reviewing
transactions should be separated among individuals."
Control of Checks
The Division did not have formal policies and
procedures related to the handling of unemployment
benefit checks. As a result, control over blank,
canceled, and voided checks was inadequate. For
example, although the Division used prenumbered blank
checks, computer-generated numbers were also printed on
the checks during the check printing process. During
April 1997, the computer-generated numbers on 89 checks
were different from the preprinted numbers. This
duplication caused the Division's automated check
reconciliation program to malfunction (see the section
"Reconciliation of Bank Accounts"). Further, although
the bank used the preprinted numbers in its bank
statements, the Division used the computer-generated
check numbers in all of its internal record keeping.
We also found that a record was not maintained of the
sequence of preprinted numbers on the batches of blank
checks provided to the Division's Computer Manager for
the printing of benefit checks. Therefore, there was
no control over the use of the blank checks.
Additionally, the Division did not maintain a register
or otherwise control the issuance of "hand drawn"
checks.
Control over canceled and voided checks was also
inadequate. Specifically, we found that canceled
checks were stored in unlocked cabinets which were
easily accessible to all of the Division's employees
and that voided checks were kept in various locations,
including employees' desks. We performed a numerical
trace of all checks issued from the Unemployment
Benefit Account during fiscal year 1996 and were unable
to locate 159 checks among either the canceled or
voided checks. This number included 31 checks that
were not listed in the internal check register. We
also were unable to locate 38 checks, totaling about
$7,800, that were issued to benefit claimants in 1997
under the special Disaster Unemployment Assistance
program which was instituted after Hurricane Bertha in
July 1997. Also, during our review of the case files
for benefit claimants, we found six checks, totaling
about $1,570, that had not been either voided by the
Division or mailed to the claimants.
Recommendations
We recommend that the Governor of the Virgin Islands
direct the Commissioner of Labor to:
1. Develop and implement formal policies and procedures
to ensure that the Division of Unemployment Insurance
reconciles its bank accounts on a monthly basis;
provides an adequate level of supervisory oversight of
the bank reconciliation process; and maintains an
adequate level of segregation of duties for functions
related to the physical handling, record-keeping, and
supervisory oversight of the Division's resources.
2. Develop and implement formal policies and procedures
to ensure that the Division of Unemployment Insurance
maintains an adequate level of control over blank,
canceled, and voided checks. The procedures should
ensure that a record is maintained of the numerical
sequence of blank checks issued to the computer
operations unit, the preprinted check numbers are used
for all internal record-keeping functions, a record is
maintained of all voided checks and all "hand drawn"
checks, and all voided and canceled checks are stored
in a secure area which is accessible only to authorized
Division personnel. The procedures should also
establish controls to ensure that "hand drawn" checks
are properly authorized and supported.
Commissioner of Labor Response and Office of
Inspector General Reply
The October 8, 1998, response (Appendix 2) to the draft
report from the Commissioner of Labor concurred with
the two recommendations and indicated that corrective
actions would be taken. Based on the response, we
consider Recommendations 1 and 2 resolved but not
implemented (see Appendix 3).
APPENDIX 1
CLASSIFICATION OF MONETARY AMOUNTS
Unrealized Unsupported
Finding
Revenues* Costs*
A. Unemployment Tax Collections
Verification of Employer Payments$60,000
Collection of Delinquent Taxes18,500,000
Assessment of Penalties and Interest16,400
B. Benefit Payments
Collection of Benefit Overpayments152,800
Reliability of Computer and
Hard Copy Files $400,400
C. Administrative Controls
Control of Checks 7,800
Totals $18,729,200 $408,200
*Amounts represent local collections processed through
the Unemployment Trust Fund in the Treasury of the
United States in accordance with Sections 903 and 904
of the Social Security Act and the Federal Unemployment
Tax Act.
APPENDIX 2
Page 1 of 7
COMMISSIONER OF LABOR RESPONSE
APPENDIX 3
STATUS OF AUDIT REPORT RECOMMENDATIONS
--------------------------------------------------------
Finding/Recommendation
Action
Reference Status Required
A.1, A.4, and A.6 Implemented. No further action is
required.
A.2, A.3, and A.5 Resolved;
not The recommendations will be
implemented.referred to the Assistant
Secretary for Policy,
Management and Budget for
tracking of implementation.
However, when corrective
actions have been
B.1, B.2, B.3, completed, appropriate
and B.4 Resolved; supporting documentation
not should be provided to our
implemented.office.
The recommendations will be
referred to the Assistant
Secretary for Policy,
Management and Budget for
C.1 and C.2 tracking of implementation.
Resolved; However, when corrective
not actions have been
implemented.completed, appropriate
supporting documentation
should be provided to our
office.
The recommendations will be
referred to the Assistant
Secretary for Policy,
Management and Budget for
tracking of implementation.
However, when corrective
actions have been
completed, appropriate
supporting documentation
should be provided to our
office.
----------------------------------------------------------
ILLEGAL OR WASTEFUL ACTIVITIES SHOULD BE REPORTED
TO THE OFFICE OF INSPECTOR GENERAL BY:
Sending written documents to:
Within the Continental United States
U.S. Department of the Interior
Office of Inspector General
1849 C Street,N.W.
Mail Stop 5341
Washington, D.C. 20240
Calling:
Our 24 hour
Telephone HOTLINE
1-800-424-5081 or
(202) 208-5300
TDD for hearing impaired
(202) 208-2420 or
1-800-354-0996
Outside the Continental United States
Caribbean Region
U.S. Department of the Interior
Office of Inspector General
Eastern Division- Investigations
1550 Wilson Boulevard
Suite 410
Arlington, Virginia 22209
Calling:
(703) 235-9221
North Pacific Region
U.S. Department of the Interior
Office of Inspector General
North Pacific Region
238 Archbishop F.C. F'lores Street
Suite 807, PDN Building
Agana, Guam 96910
Calling:
(700) 550-7428 or
COMM 9-011-671-472-7279