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April 12, 2023

FAA’s Office of Investigations and Professional Responsibility Needs To Enhance Internal Controls for Conducting Administrative Investigations

Requested by the Federal Aviation Administrator
Project ID: 
AV2023024
View PDF Document
What We Looked At
The Federal Aviation Administration’s (FAA) Office of Investigations and Professional Responsibility (AXI) conducts administrative investigations and special inquiries on FAA employees and contractors suspected of violating Agency orders, regulations, and policy. The Federal Aviation Administrator asked our office to conduct a review of AXI following a December 2020 Senate Committee report that detailed significant lapses in aviation safety oversight and leadership at FAA. Our audit objective was to assess AXI’s policies, procedures, and practices for conducting administrative investigations and evaluate its compliance with applicable standards or best practices.
 
What We Found
AXI’s guidance overlaps with and contradicts FAA’s guidance, potentially leaving investigators unclear about their responsibilities. An FAA directive also currently prohibits investigators from concluding whether employees actually engaged in misconduct, which senior AXI officials believe would make their reports more effective. Per the request of the Administrator, we obtained training records to determine if investigators received the necessary indoctrination training. However, AXI’s electronic training system records are not current, making it difficult to track whether agents are fully trained on proper investigative techniques and protocols. In addition, the office lacks internal controls to ensure the appropriate official always reviews and signs investigation reports. As a result, sensitive investigation reports could be issued without management’s awareness. Field investigators also lack clear guidance on referring criminal cases to OIG, and AXI does not have internal controls to ensure that it accounts for investigative requests that it rejects or that do not fall under its authority. Without an accurate record, some cases may get overlooked. Finally, AXI’s policies, procedures, and practices do not comply with Federal or AXI standards for program reviews, which hinders its ability to ensure investigators meet program requirements, help FAA take effective corrective action against employees who engage in misconduct, and prevent errors from reoccurring.
 
Our Recommendations
FAA concurred with all 11 of our recommendations to strengthen AXI’s policies, procedures, and practices for conducting administrative investigations.

Recommendations

Open

Closed

No. 1 to FAA

Require AXI to develop a process to collect and share best practices for investigators in compliance with AXI guidance.

No. 2 to FAA

Revise Security and Hazardous Materials Safety Order 1600.20 guidance to avoid overlap or contradiction with similar procedures contained in FAA Order 1600.38.

No. 3 to FAA

Revise AXI’s guidance to clarify that investigators should pursue administrative investigations when OIG declines cases for criminal referral.

No. 4 to FAA

Develop and publish roles and responsibilities for AXI deputy director position.

No. 5 to FAA

Develop and implement procedures for investigators to electronically record interviews in accordance with FAA’s Human Resources Policy Manual requirements.

No. 6 to FAA

Develop and implement a management control to credit and account for Agency and non-Agency investigator training courses in AXI’s electronic training system.

No. 7 to FAA

Develop and implement an internal control to ensure that only the management official with requisite signature authority signs for investigative reports.

No. 8 to FAA

Develop and implement procedures consistent with DOT Order 8000.8A to ensure investigators consistently send criminal cases to the Internal Investigations Division Manager and coordinate with OIG’s Office of Investigations on the referral process.

No. 9 to FAA

Develop and implement a management control to require the Internal Investigations Division Manager to track cases that have been rejected by the Internal Investigations Division (AXI-100).

No. 10 to FAA

Develop procedures to ensure the Investigations Standards and Policy Division (AXI-200) maintains auditable documentation, in accordance with established Agency retention periods, to support findings identified in its annual reports of AXI-100 investigation procedures.

No. 11 to FAA

Develop and implement a management control to ensure AXI-200 complies with its Program Reviewer Guide requirements to (a) prepare annual reports, (b) conduct the required number of annual reviews of AXI investigative operations, (c) use consistent investigative and reporting criteria, and (d) identify investigation case numbers when reporting its evaluation of AXI-100’s investigative operations.