ML20307A372

Dnfsb FY2021 Annual Plan Dated November 2, 2020

ML20307A372
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Issue date:	11/02/2020
From:	Feitel R NRC/OIG
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Office of the Inspector General U.S. Defense Nuclear Facilities Safety Board Annual Plan Fiscal Year 2021

FOREWORD The Consolidated Appropriations Act, 2014, provided that notwithstanding any other provision of law, the Inspector General (IG) of the Nuclear Regulatory Commission (the NRC) is authorized in 2014 and subsequent years to exercise the same authorities with respect to the Defense Nuclear Facilities Safety Board (the DNFSB), as determined by the NRC Inspector General (IG), as the IG exercises under the Inspector General Act of 1978 (5 U.S.C. App.) with respect to the NRC. I am pleased to present the Office of the Inspector General's (the OIG) FY 2021 Annual Plan for the Defense Nuclear Facilities Safety Board (the DNFSB). The Annual Plan provides the audit and investigative strategies and associated summaries of the specific work planned for the coming year. It sets forth the OIG's formal strategy for identifying priority issues and managing its workload and resources for Fiscal Year (FY) 2021.

Congress created the DNFSB in September 1988 as an independent Executive Branch agency to identify the nature and consequences of potential threats to public health and safety at the Department of Energys (DOE) defense nuclear facilities, elevate those issues to the highest levels of authority, and inform the public. The DNFSB strives to protect public health and safety by ensuring implementation of safety standards at DOE defense nuclear facilities, conducting in-depth reviews of new DOE defense facilities during design and construction to ensure the early integration of safety into design; and providing oversight to prevent an accidental detonation of a nuclear weapon during the evaluation, maintenance, or dismantling process.

The OIG sought input both from Congress and the DNFSB in the development of this Annual Plan.

We have programmed all available resources to address the matters identified in this plan.

This approach maximizes the use of our resources. However, to respond to a changing environment, it is sometimes necessary to modify this plan as circumstances, priorities, and resources warrant.

Robert J. Feitel Inspector General Robert J. Feitel Digitally signed by Robert J. Feitel Date: 2020.11.02 11:22:52 -05'00'

TABLE OF CONTENTS MISSION AND AUTHORITY................................................................................................. 1 PLANNING STRATEGY........................................................................................................ 2 AUDIT AND INVESTIGATION UNIVERSE........................................................................... 2 AUDIT STRATEGY............................................................................................................... 3 INVESTIGATION STRATEGY.............................................................................................. 4 PERFORMANCE MEASURES............................................................................................. 6 OPERATIONAL PROCESSES............................................................................................. 6 AUDITS...................................................................................................................... 6 INVESTIGATIONS..................................................................................................... 8 HOTLINE.................................................................................................................... 9 APPENDICES A. AUDITS PLANNED FOR FY 2021 Audit of the DNFSBs Fiscal Year 2020 Financial Statements................................... A-1 Independent Evaluation of the DNFSBs Implementation of the Federal Information Security Modernization Act of 2014 for Fiscal Year 2020.......................................... A-2 Survey of the Defense Nuclear Facilities Safety Boards Culture and Climate.......... A-3 Audit of the DNFSBs Compliance with Executive Order 13950, Combating Race and Sex Stereotyping...................................................................... A-4 Audit of DNFSBs Fiscal Year 2021 Compliance with Improper Payment Laws........................................................................................................... A-5 Audit of DNFSBs Fiscal Year 2021 Financial Statements........................................ A-6 Audit of the DNFSBs Internal Control Program......................................................... A-7 Audit of the DNFSBs Compliance with Standards Established by the Digital Accountability and Transparency Act of 2014............................................................ A-8 Independent Evaluation of the DNFSBs Implementation of the Federal Information Security Modernization Act of 2014 for Fiscal Year 2021....................... A-9 Audit of the DNFSBs Process for Planning and Implementing Oversight Activities.................................................................................................. A-10 B. INVESTIGATIONS - PRIORITIES, OBJECTIVES, AND INITIATIVES FOR FY 2021 C. ISSUE AREAS AND DESIGNATED ISSUE AREA MONITORS D. ABBREVIATIONS AND ACRONYMS

1 MISSION AND AUTHORITY The Nuclear Regulatory Commissions (the NRC) Office of the Inspector General (the OIG) was established on April 15, 1989, pursuant to Inspector General Act Amendments contained in Public Law 100-504. In addition, the Consolidated Appropriations Act, 2014, provided that notwithstanding any other provision of law, the NRC Inspector General (IG) is authorized in 2014 and subsequent years to exercise the same authorities with respect to the Defense Nuclear Facilities Safety Board (the DNFSB), as determined by the NRC IG, as the IG exercises under the Inspector General Act of 1978 (5 U.S. C. App.) with respect to the NRC.

The OIGs mission is to provide independent, objective audit and investigative oversight of Nuclear Regulatory Commission and Defense Nuclear Facilities Safety Board operations to protect people and the environment.

In furtherance of the execution of this mission and of particular importance to the OIGs annual plan development, the IG summarized what he considers to be the most serious management and performance challenges facing the DNFSB and assessed the DNFSBs progress in addressing those challenges. In its latest annual assessment (October 2020), the IG identified the following as the most serious management and performance challenges facing the DNFSB:0F1

1. Management of a healthy and sustainable organizational culture and climate

2. Management of security over internal infrastructure (personnel, physical, and cyber security)

3. Management of administrative functions

4. Management of technical programs

5. Management of the DNFSBs COVID-19 pandemic response Through its Issue Area Monitor (IAM) program, the OIG staff monitor the DNFSBs performance on these management and performance challenges. These challenges help inform decisions concerning which audits and evaluations to conduct each fiscal year.

1The challenges are not ranked in any order of importance.

2 PLANNING STRATEGY The FY 2021 Annual Plan is based, in part, on knowledge gained through the OIG audit and investigative activities. These activities pertain to the DNFSB and its operations, work conducted under the IAM program, and management and performance challenges facing the DNFSB as of October 2020 as identified by the OIG.

AUDIT AND INVESTIGATION UNIVERSE The DNFSB, an independent executive branch agency established by Congress in September 1988 is charged with providing technical safety oversight of the Department of Energys (DOE) defense nuclear facilities and activities in order to provide adequate protection of the health and safety of the public and workers. Its mission is to provide independent analysis, advice, and recommendations to the Secretary of Energy to inform the Secretary, as operator and regulator of DOEs defense nuclear facilities, in providing adequate protection of public health and safety at these facilities.

When fully staffed, the DNFSBs board is composed of five Presidentially appointed, Senate confirmed members who are required by law to be respected experts in the field of nuclear safety with a demonstrated competence and knowledge relevant to its independent investigative and oversight functions. Most of the DNFSBs approximate 100 full-time equivalents work at the agencys Washington, DC, headquarters. The DNFSBs FY 2020 budget was $31 million. The Board requested

$28,836,000 and 114 full-time equivalents (FTEs) to carry out its mission in Fiscal Year (FY) 2021.

The DNFSBs enabling statute assigns specific functions to the agency for accomplishing its safety oversight mission, including to:

• Review and evaluate the content and implementation of standards relating to the design, construction, operation, and decommissioning of DOE defense nuclear facilities at each facility and recommend to the Secretary of Energy specific measures needed to ensure that public health and safety are adequately protected.

• Investigate any event or practice at a DOE defense nuclear facility the DNFSB determines has adversely affected, or may adversely affect, public health and safety.

• Review the design of new DOE defense nuclear facilities before construction begins and recommend modifications of the design deemed necessary to ensure public health and safety.

• Make recommendations to the Secretary of Energy pertaining to operation,

3 standards, and research needs pertaining to DOE defense nuclear facilities that the DNFSB deems necessary to ensure public health and safety. In making its recommendations, the DNFSB shall consider, and specifically assess, risk and the technical and economic feasibility of implementing the recommended measures.

The OIGs audit and investigation oversight responsibilities are derived from the DNFSBs array of programs, functions, and support activities established to accomplish its mission.

AUDIT STRATEGY Effective audit planning requires current knowledge about the DNFSBs mission, and the programs and activities used to carry out that mission. Accordingly, the OIG continually monitors specific issue areas to strengthen its internal coordination and overall planning process. Under the offices IAM program, staff designated as IAMs are assigned responsibility for keeping abreast of major DNFSB programs and activities. The broad IAM areas address information management, nuclear safety, and corporate management. Appendix C contains a list of the IAMs and the issue areas for which they are responsible.

The audit planning process yields audit assignments that identify opportunities for increased efficiency, economy, and effectiveness in DNFSB programs and operations; detect and prevent fraud, waste, and mismanagement; improve program and security activities at headquarters and site locations; and, respond to emerging circumstances and priorities. The priority for conducting audits is based on (1) mandatory legislative requirements; (2) critical agency risk areas; (3) emphasis by the President, Congress, Board Chairman, or other Board Members; (4) a programs susceptibility to fraud, manipulation, or other irregularities; (5) dollar magnitude or resources involved in the proposed audit area; (6) newness, changed conditions, or sensitivity of an organization, program, function, or activities; (7) prior audit experience, including the adequacy of internal controls; and, (8) availability of audit resources.

INVESTIGATION STRATEGY The OIGs investigation strategies and initiatives add value to DNFSB programs and operations by identifying and investigating allegations of fraud, waste, and abuse leading to criminal, civil, and administrative penalties, and recoveries. By focusing on results, the OIG has designed specific performance targets focusing on effectiveness. Because the DNFSBs mission is to protect public health and safety, the main investigative concentration involves alleged DNFSB misconduct or inappropriate actions that could adversely impact health and safety-related matters.

These investigations typically include allegations of:

4

• Misconduct by high-ranking DNFSB officials and other DNFSB officials, such as managers and inspectors, whose positions directly impact public health and safety.

• Failure by the DNFSBs management to ensure that health and safety matters are appropriately addressed.

• Conflict of interest and ethics violations.

• Indications of management or supervisory retaliation or reprisal.

The OIG will also implement initiatives designed to monitor specific high-risk areas within the DNFSBs corporate management that are most vulnerable to fraud, waste, and abuse. A significant focus will be on emerging information technology and national security issues that could negatively impact the security and integrity of DNFSB data and operations. The OIG is committed to improving the security of the constantly changing electronic business environment by investigating unauthorized intrusions and computer-related fraud, and by conducting computer forensic examinations. Other proactive initiatives will focus on determining instances of procurement fraud, theft of property, insider threats, and government travel charge card and government purchase card misuse and abuse.

As part of these proactive initiatives, the OIG will meet with the DNFSBs internal and external stakeholders to identify systemic issues or vulnerabilities. This approach will allow the identification of potential vulnerabilities and an opportunity to improve agency performance, as warranted.

OIG personnel will routinely interact with public interest groups, individual citizens, industry workers, and DNFSB staff to identify possible lapses in the DNFSBs oversight that could impact public health and safety. The OIG will also conduct proactive initiatives and reviews into areas of current or future regulatory safety or security interest to identify emerging issues or address ongoing concerns regarding the quality of the DNFSBs oversight.

Appendix B provides investigation priorities, objectives, and initiatives for FY 2021.

Specific investigations are not included in the plan because investigations are primarily responsive to reported violations of law and misconduct by DNFSB employees and contractors, as well as allegations of irregularities or abuse in the DNFSBs programs and operations.

5 PERFORMANCE MEASURES

1. Percentage of OIG audit products and activities that cause the agency to take corrective action to improve agency safety, security, or corporate management programs; ratify adherence to agency policies, procedures, or requirements; or identify real dollar savings or reduced regulatory burden (i.e., high impact).

2. Percentage of audit recommendations agreed to by agency.

3. Percentage of final agency actions taken within 2 years on audit recommendations.

4. Percentage of OIG investigative products and activities that identify opportunities for improvements to agency safety, security, or corporate management programs; ratify adherence to policies/procedures; or confirm or disprove allegations of wrongdoing (e.g., high impact).

5. Percentage of agency actions taken in response to investigative reports.

6. Percentage of cases completed within 18 months.

6 OPERATIONAL PROCESSES The following sections detail the approach used to carry out the audit and investigative responsibilities previously discussed.

AUDITS The OIGs audit process comprises the steps taken to conduct audits and involves specific actions, ranging from annual audit planning to audit follow up activities. The underlying goal of the audit process is to maintain an open channel of communication between the auditors and DNFSB officials to ensure that audit findings are accurate and fairly presented in the audit report.

The OIG performs the following types of audits:

Performance - Performance audits focus on the DNFSBs administrative and program operations and evaluate the effectiveness and efficiency with which managerial responsibilities are carried out, including whether the programs achieve intended results.

Financial - These audits, which include the financial statement audit required by the Accountability of Tax Dollars Act of 2002 and OMB Bulletin 15-02 (Audit Requirements for Federal Financial Statements), attest to the reasonableness of the DNFSBs financial statements and evaluate financial programs.

Contract - Contract audits evaluate the costs of goods and services procured by the DNFSB from commercial enterprises.

The key elements in the audit process are as follows:

Audit Planning - Each year, suggestions are solicited from Congress, DNFSB management, external parties, and OIG staff. An annual audit plan (i.e., this document) is developed and distributed to interested parties. It contains a listing of planned audits to be initiated during the fiscal year depending on availability of resources and the general objectives of the audits. The annual audit plan is a living document that may be revised as circumstances warrant, with a subsequent redistribution of staff resources.

Audit Notification - Formal notification is provided to the office responsible for a specific program, activity, or function, informing them of the OIGs intent to begin an audit of that program, activity, or function.

7 Entrance Conference - A meeting is held to advise DNFSB officials of the objective(s), and scope of the audit, and the general audit methodology to be followed.

Survey - Exploratory work is conducted before the more detailed audit work commences to gather data for refining audit objectives, as appropriate; documenting internal control systems; becoming familiar with the activities, programs, and processes to be audited; and identifying areas of concern to management. At the conclusion of the survey phase, the audit team will recommend to the Assistant Inspector General for Audits (AIGA) a Go or No Go decision regarding the verification phase. If the audit team recommends a No Go, and it is approved by the AIGA, the audit is dropped.

Audit Fieldwork - A comprehensive review is performed of selected areas of a program, activity, or function using an audit program developed specifically to address the audit objectives.

End of Fieldwork Briefing with Agency - At the conclusion of audit fieldwork, the audit team discusses the tentative report findings and recommendations with the auditee.

Discussion Draft Report - A discussion draft copy of the report is provided to DNFSB management to allow them the opportunity to prepare for the exit conference.

Exit Conference - A meeting is held with the appropriate DNFSB officials to discuss the discussion draft report. This meeting provides DNFSB management with the opportunity to confirm information, ask questions, and provide any necessary clarifying data.

Final Draft Report - If requested by DNFSB management during the exit conference, a final draft copy of the report that includes comments or revisions from the exit conference is provided to the DNFSB to obtain formal written comments.

Final Audit Report - The final report includes, as necessary, any revisions to the facts, conclusions, and recommendations of the draft report discussed in the exit conference or generated in written comments supplied by DNFSB managers. Written comments are included as an appendix to the report.

Some audits are sensitive and/or classified. In these cases, final audit reports are not made available to the public.

8 Response to Report Recommendations - Offices responsible for the specific program or process audited provide a written response on each recommendation (usually within 30 days) contained in the final report.

DNFSB management responses include a decision for each recommendation indicating agreement or disagreement with the recommended action. For agreement, DNFSB management provides corrective actions taken or planned and actual or target dates for completion. For disagreement, DNFSB management provides their reasons for disagreement and any alternative proposals for corrective action.

Impasse Resolution - If the response by the action office to a recommendation is unsatisfactory, the OIG may determine that intervention at a higher level is required.

Audit Follow up and Closure - This process ensures that recommendations made to management are implemented.

INVESTIGATIONS The OIGs investigative process normally begins with the receipt of an allegation of fraud, mismanagement, or misconduct. Because a decision to initiate an investigation must be made within a few days of each referral, the OIG does not schedule specific investigations in its annual investigative plan.

Investigations are opened in accordance with OIG priorities in consideration of prosecutorial guidelines established by the local U.S. Attorneys for the Department of Justice (DOJ). OIG investigations are governed by the Council of the Inspectors General on Integrity and Efficiency Quality Standards for Investigations, the OIG Special Agent Handbook, and various guidance provided periodically by the DOJ.

Only four individuals in the OIG can authorize the opening of an investigative case: the Inspector General (IG), the Deputy IG, the Assistant IG for Investigations, and the Deputy Assistant IG for Investigations. Every allegation received by the OIG is given a unique identification number and entered into a database. Some allegations result in investigations, while others are retained as the basis for audits, referred to DNFSB management, or, if appropriate, referred to another law enforcement agency.

9 When an investigation is opened, it is assigned to a special agent who prepares a plan of investigation. This planning process includes a review of the criminal and civil statutes, program regulations, and agency policies that may be involved. The special agent then conducts the investigation and uses a variety of investigative techniques to ensure completion.

In cases where the special agent determines that a crime may have been committed, he or she will discuss the investigation with a federal and/or local prosecutor to determine if prosecution will be pursued. In cases where a prosecuting attorney decides to proceed with a criminal or civil prosecution, the special agent assists the attorney in any preparation for court proceedings that may be required.

For investigations that do not result in prosecution and are handled administratively by the agency, the special agent prepares an investigative report summarizing the facts disclosed during the investigation. The investigative report is distributed to agency officials who have a need to know the results of the investigation. For investigative reports provided to agency officials, the OIG requires a response within 120 days regarding any potential action taken as a result of the investigative findings.

The OIG summarizes the criminal and administrative action taken as a result of its investigations and includes this data in its Semiannual Report to Congress.

9 HOTLINE The OIG Hotline Program provides DNFSB employees, contract employees, and the public with a confidential means of reporting to the OIG instances of fraud, waste, and abuse relating to Board programs and operations.

Please

Contact:

E-mail:

Online Form Telephone: 1-800-233-3497 TDD 1-800-201-7165, or 7-1-1 Address: U.S. Nuclear Regulatory Commission Office of the Inspector General Hotline Program Mail Stop O5-E13 11555 Rockville Pike Rockville, MD 20852

APPENDIX A A.

AUDITS PLANNED FOR FY 2021

Appendix A A-1 Audit of the DNFSBs Fiscal Year 2020 Financial Statements DESCRIPTION AND JUSTIFICATION:

Under the Chief Financial Officers Act, the Government Management and Reform Act, and OMB Bulletin 19-03, Audit Requirements for Federal Financial Statements, the OIG is required to audit the DNFSBs financial statements. The report on the audit of the agencys financial statements is due on November 16, 2020. 1F2 OBJECTIVES:

The audit objectives are to:

• Express opinions on the agencys financial statements and internal controls over financial reporting;

• Review compliance with applicable laws, regulations, contracts, and grant agreements; and

• Review controls in the DNFSBs computer systems that are significant to the financial statements.

SCHEDULE:

Initiated in the 3rd quarter of FY 2020.

STRATEGIC GOAL 3:

Increase the economy, efficiency, and effectiveness with which the DNFSB manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within the DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 3:

Management of administrative functions.

2 The due date for this audit is now December 2020, by mutual agreement between the OIG and the DNFSB.

Appendix A A-2 Independent Evaluation of the DNFSBs Implementation of the Federal Information Security Modernization Act of 2014 for Fiscal Year 2020 DESCRIPTION AND JUSTIFICATION:

The Federal Information Security Modernization Act (FISMA) was enacted in 2014.

The FISMA outlines the information security management requirements for agencies, including the requirement for an annual independent assessment by agencies Inspectors General. In addition, the FISMA includes provisions such as the development of minimum standards for agency systems, aimed at further strengthening the security of federal government information and information systems. The annual assessments provide agencies with the information needed to determine the effectiveness of overall security programs and to develop strategies and best practices for improving information security.

The FISMA provides the framework for securing the federal governments information technology including both unclassified and national security systems. All agencies must implement the requirements of the FISMA and report annually to the Office of Management and Budget and Congress on the effectiveness of their security programs.

OBJECTIVE:

The evaluation objective is to conduct an independent assessment of the DNFSBs implementation of the FISMA for Fiscal Year 2020.

SCHEDULE:

Initiated in the 4th quarter of FY 2020.

STRATEGIC GOAL 3:

Increase the economy, efficiency, and effectiveness with which the DNFSB manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within the DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 2:

Management of security over internal infrastructure (personnel, physical, and cyber security).

Appendix A A-3 Survey of the Defense Nuclear Facilities Safety Boards Culture and Climate DESCRIPTION AND JUSTIFICATION:

In 2015, the OIG contracted with an international firm to conduct an independent survey that evaluated the organizational culture and climate of the DNFSBs workforce. This survey identified agency strengths and opportunities for improvements. Comparisons were made to national and government norms.

A clear understanding of the DNFSBs current culture and climate will facilitate identification of agency strengths and opportunities for improvement as it continues to experience significant challenges. These challenges include attrition, knowledge management, a major reorganization, the DNFSB leadership publicly expressing a desire to downsize, and controversy regarding the DNFSBs collaboration with the DOE. The survey will assess the degree to which these challenges have affected the level of employee engagement and morale.

OBJECTIVES:

The survey objectives will be to:

Measure the Boards culture and climate to identify areas of strength and opportunities for improvement;

• Compare the results of this survey against the survey results that the OIG previously reported; and

• Provide, where practical, benchmarks for the qualitative and quantitative findings against other organizations.

SCHEDULE:

Initiated in the 4th quarter of FY 2020.

STRATEGIC GOAL:

Addresses all strategic challenges facing the DNFSB.

Strategy: Incorporates all OIG goals, strategies, and actions.

MANAGEMENT CHALLENGE:

Addresses all management challenges.

Appendix A A-4 Audit of the DNFSBs Compliance with Executive Order 13950, Combating Race and Sex Stereotyping DESCRIPTION AND JUSTIFICATION:

Executive Order (E.O.) 13950, Combating Race and Sex Stereotyping, dated September 22, 2020, requires federal agencies, federal grantees, federal contractors, and the Uniformed Services to address trainings that include divisive concepts, race or sex stereotyping, and race or sex scapegoating.

Section 6(c)(ii) of the E.O. states that each agency head shall request the agency inspector general to thoroughly review and assess by the end of the calendar year, and not less than annually thereafter, agency compliance with the requirements of this order in the form of a report submitted to the Office of Management and Budget (OMB).

OBJECTIVE:

To review and assess agency compliance with the requirements of E.O. 13950, "Combating Race and Sex Stereotyping."

SCHEDULE:

Initiate in the 1st quarter of FY 2021.

STRATEGIC GOAL:

Increase the economy, efficiency, and effectiveness with which NRC manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 3:

Management of administrative functions.

Appendix A A-5 Audit of DNFSBs Fiscal Year 2021 Compliance with Improper Payment Laws DESCRIPTION AND JUSTIFICATION:

An improper payment is (a) any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements, and (b) includes any payment to an ineligible recipient, any payment for an ineligible good or service, any duplicate payment, any payment for a good or service not received (except for such payments where authorized by law), and any payment that does not account for credit for applicable discounts.

The Improper Payments Elimination and Recovery Act of 2010 (IPERA) (Public Law 111-204) amended the Improper Payments Information Act of 2002 and required agencies to identify and review all programs and activities they administer that may be susceptible to significant improper payments based on guidance provided by the Office of Management and Budget. For programs or activities with estimated improper payments, each agency was required to prepare a report on actions it has taken or plans to take to recover improper payments and prevent future improper payments. In addition, section 3 of IPERA required Inspectors General to review each agencys improper payment reporting and issue an annual report. On March 2, 2020, the Payment Integrity Information Act of 2019 (PIIA) (Public Law 116-117) repealed IPERA (and other laws) but set forth similar improper payment reporting requirements, including an annual compliance report by Inspectors General.

OBJECTIVES:

The audit objectives will be to assess the NRCs compliance with IPERA, as amended by PIIA, and report any material weaknesses in internal control.

SCHEDULE:

Initiate in the 2nd quarter of FY 2021.

STRATEGIC GOAL 3:

Increase the economy, efficiency, and effectiveness with which the DNFSB manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within the DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 3:

Management of administrative functions.

Appendix A A-6 Audit of DNFSBs Fiscal Year 2021 Financial Statements DESCRIPTION AND JUSTIFICATION:

Under the Chief Financial Officers Act, the Government Management and Reform Act, and OMB Bulletin 19-03, Audit Requirements for Federal Financial Statements, the OIG is required to audit the DNFSBs financial statements. The report on the audit of the agencys financial statements is due on November 15, 2021.

OBJECTIVES:

The audit objectives are to:

• Express opinions on the DNFSBs financial statements and internal controls.

• Review compliance with applicable laws and regulations.

• Review the controls in the DNFSBs computer systems that are significant to the financial statements.

• Assess the agencys compliance with OMB Circular A-123, (Revised),

Managements Responsibility for Enterprise Risk Management and Internal Control.

SCHEDULE:

Initiate in the 2nd quarter of FY 2021.

STRATEGIC GOAL 3:

Increase the economy, efficiency, and effectiveness with which the DNFSB manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within the DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 3:

Management of administrative functions.

Appendix A A-7 Audit of the DNFSBs Internal Control Program DESCRIPTION AND JUSTIFICATION:

The DNFSBs Directive 22-1 states that the DNFSBs Internal Control Program is to establish and maintain cost-effective internal controls, in part, to ensure programs achieve their intended results and that resources are used consistent with the Boards mission. The DNFSBs Internal Control Program Operating Procedures require formal assessment of significant work processes, periodically. The Board may assess additional specific work processes as determined by the Executive Committee on Internal Control (ECIC) based on the following factors considered cumulatively: (1) Risk Assessment, (2) Frequency, (3) Results of Previous Internal Control Program Assessments, (4) Results of External Audits, and (5) Cost versus Benefit OBJECTIVE:

To determine whether the DNFSB consistently adheres to federal and agency guidance and processes when reviewing Formal Internal Control Assessments.

SCHEDULE:

Initiate in 3rd quarter of FY 2021.

STRATEGIC GOAL:

Addresses all strategic goals.

Strategy: Addresses all strategies.

MANAGEMENT CHALLENGE:

Addresses all management challenges.

Appendix A A-8 Audit of the DNFSBs Compliance with Standards Established by the Digital Accountability and Transparency Act of 2014 DESCRIPTION AND JUSTIFICATION:

The Digital Accountability and Transparency Act of 2014 (DATA Act) was enacted May 9, 2014 and requires federal agencies to report financial and payment data in accordance with data standards established by the Department of Treasury and the Office of Management and Budget. The data reported will be displayed on a website available to taxpayers and policy makers. In addition, the DATA Act requires Inspectors General (IGs) to review the data submitted by the agency under the act and report to Congress on the completeness, timeliness, quality, and accuracy of this information. In accordance with the act, the IG issued an audit report in November 2019, and plans to issue the next reports in 2021, and 2023. This audit pertains to the review of FY 2021 data. The report is due in November 2021.

OBJECTIVES:

The audit objectives are to review the 1st quarter data submitted by the DNFSB under the DATA Act and: (1) determine the completeness, timeliness, accuracy, and quality of the data sampled and (2) assess the implementation of the governing standards by the agency.

SCHEDULE:

Initiate in the 3rd quarter of FY 2021.

STRATEGIC GOAL 3:

Increase the economy, efficiency, and effectiveness with which the DNFSB manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within the DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 3:

Management of administrative functions.

Appendix A A-9 Independent Evaluation of the DNFSBs Implementation of the Federal Information Security Modernization Act of 2014 for Fiscal Year 2021 DESCRIPTION AND JUSTIFICATION:

The Federal Information Security Modernization Act (FISMA) was enacted in 2014.

The FISMA outlines the information security management requirements for agencies, including the requirement for an annual independent assessment by agencies Inspectors General. In addition, the FISMA includes provisions such as the development of minimum standards for agency systems, aimed at further strengthening the security of federal government information and information systems. The annual assessments provide agencies with the information needed to determine the effectiveness of overall security programs and to develop strategies and best practices for improving information security.

The FISMA provides the framework for securing the federal governments information technology including both unclassified and national security systems. All agencies must implement the requirements of the FISMA and report annually to the Office of Management and Budget and Congress on the effectiveness of their security programs.

OBJECTIVE:

The evaluation objective is to conduct an independent assessment of the DNFSBs implementation of the FISMA for Fiscal Year 2021.

SCHEDULE:

Initiate in the 3rd quarter of FY 2021.

STRATEGIC GOAL 3:

Increase the economy, efficiency, and effectiveness with which the DNFSB manages and exercises stewardship over its resources.

Strategy 3-1: Identify areas of corporate management risk within the DNFSB and conduct audits and/or investigations that lead to DNFSB program improvements.

MANAGEMENT CHALLENGE 2:

Management of security over internal infrastructure (personnel, physical, and cyber security).

Appendix A A-10 Audit of the DNFSBs Process for Planning and Implementing Oversight Activities DESCRIPTION AND JUSTIFICATION:

The DNFSB routinely develops an annual plan to conduct oversight of Department of Energy (DOE) defense nuclear facilities. The DNFSBs independent oversight of DOE defense nuclear facilities is carried out by technical experts located at DNFSB headquarters as well as by Resident Inspectors who are located at the various facilities throughout the country. Together, this cadre of highly experienced and knowledgeable staff conduct inspections to determine if the facilities are operated safely and in accordance with established regulations.

OBJECTIVE:

The objectives of this audit are to determine whether:

• The DNFSBs planning and implementation of oversight activities are efficiently and effectively conducted;

• Staffing and prioritization of oversight activities are reasonably determined; and

• DNFSBs coordination with DOE on oversight activities is adequate and appropriate to meet its oversight responsibilities.

SCHEDULE:

Initiate in 4th quarter of FY 2021 STRATEGIC GOAL 1:

Strengthen the DNFSBs efforts to oversee the safe operation of DOE defense nuclear facilities.

Strategy 1-1: Identify risk areas associated with the DNFSBs oversight of DOE defense nuclear facilities and conduct audits and/or investigations that lead to improved performance and communications.

MANAGEMENT CHALLENGE 4:

Management of technical programs.

APPENDIX B INVESTIGATIONS - PRIORITIES, OBJECTIVES, AND INITIATIVES FOR FY 2021

B-1 INTRODUCTION The Assistant Inspector General for Investigations (AIGI) has responsibility for developing and implementing an investigative program that furthers the OIGs objectives. The AIGIs primary responsibilities include investigating possible violations of criminal statutes relating to the DNFSBs programs and activities, investigating allegations of misconduct by DNFSB employees, interfacing with the DOJ on OIG-related criminal matters, and coordinating investigations and OIG initiatives with other federal, state, and local investigative agencies and other AIGIs.

Investigations cover a broad range of allegations concerning criminal wrongdoing or administrative misconduct affecting various DNFSB programs and operations.

Investigations may be initiated as a result of allegations or referrals from private citizens; DNFSB employees; Congress; other federal, state, and local law enforcement agencies; OIG audits; the OIG Hotline; and, proactive efforts directed at areas bearing a high potential for fraud, waste, and abuse.

This investigative plan was developed to focus OIG investigative priorities and use available resources most effectively. It provides strategies and planned investigative work for FY 2021. The most serious management and performance challenges facing the DNFSB, as identified by the IG, were also considered in the development of this plan.

PRIORITIES The OIG estimates it will initiate approximately five investigations in FY 2021.

Reactive investigations into allegations of criminal and other wrongdoing will claim priority on the OIGs use of available resources. Because the DNFSBs mission is to protect public health and safety, Investigations main concentration of effort and resources will involve investigations of alleged DNFSB employee misconduct that could adversely impact public health and safety related matters.

OBJECTIVES To facilitate the most effective and efficient use of limited resources, Investigations has established specific objectives aimed at preventing and detecting fraud, waste, and abuse as well as optimizing the DNFSBs effectiveness and efficiency.

Investigations will focus its investigative efforts in areas which include possible violations of criminal statutes relating to the DNFSBs programs and operations and allegations of misconduct by DNFSB employees.

Investigations Appendix B B-2 INITIATIVES

• Investigate allegations of misconduct by DNFSB employees and contractors in accordance with federal statutes, regulations, and management directives.

• Investigate alleged violations of government-wide ethics regulations posed by conflicts of interest.

• Conduct fraud awareness briefings and information presentations to provide practical and implementable knowledge-basis for DNFSB employees and external stakeholders that support anti-fraud activities.

• Conduct activities to protect the DNFSBs Information Technology (IT) infrastructure against both internal and external computer intrusions by working in close coordination with DNFSB IT staff.

• Attempt to detect possible wrongdoing perpetrated against the DNFSBs procurement and contracting program. This will include periodic meetings with DNFSB management officials, contract specialists, project managers, project officers, and other identified employees.

• Proactive review of government travel charge card and the government purchase card programs to prevent, detect, and investigate alleged misuse and abuse.

• Proactively focus attention on emerging issue areas that present potential future challenges for the DNFSB that may require OIG involvement.

Investigations Appendix B B-3 The OIG Hotline

• Promptly process complaints received via the OIG Hotline. Initiate investigations when warranted and properly dispose of allegations that do not warrant OIG investigation.

Freedom of Information Act (FOIA) & Privacy Act

• Promptly process all requests for OIG information received under the FOIA.

Coordinate as appropriate with the General Counsel to the IG and the NRC and the DNFSB FOIA and Privacy Section.

Liaison Program

• Maintain close working relationships with the Intelligence Community (IC) and other law enforcement agencies, public interest groups, and the Congress.

This will be accomplished through periodic meetings with pertinent congressional staff, public interest groups, and appropriate IC and law enforcement organizations.

ALLOCATION OF RESOURCES Investigations undertakes both proactive initiatives and reactive investigations. The majority of available investigative resources will be used for reactive investigations.

The balance will be allocated to proactive investigative efforts such as reviews of DNFSB contract files, examinations of DNFSB information technology systems to identify weaknesses or misuse by agency employees, reviews of delinquent government travel and purchase card accounts, and other initiatives.

APPENDIX C C. ISSUE AREAS AND DESIGNATED ISSUE AREA MONITORS

Issue Area Monitors Appendix C C-1 ISSUE AREAS AND DESIGNATED ISSUE AREA MONITORS DNFSB Corporate Support Functions Vicki Foster Tincy Thomas de Colón Megan Tate Angel Wang Jimmy Wong Financial Terri Cooper Felicia Silver Jenny Cheung Muhammad Arefin Curtis Brown William Chung Information Technology Terri Cooper Felicia Silver Jenny Cheung Muhammad Arefin Curtis Brown William Chung DNFSB - Nuclear Materials (Safety and Security)

Regina Revinzon Tim Wilson Roxana Hartsock Janelle Wiggs Stephanie Dingbaum Connor McCune DNFSB - Nuclear Safety Regina Revinzon Tim Wilson Roxana Hartsock Janelle Wiggs Stephanie Dingbaum Connor McCune

APPENDIX D D. ABBREVIATIONS AND ACRONYMS

0BABBREVIATIONS AND ACRONYMS AIGA Assistant Inspector General for Audit AIGI Assistant Inspector General for Investigation CIGIE Council of the Inspectors General on Integrity and Efficiency DATA Digital Accountability and Transparency Act DOE U.S. Department of Energy DOJ U.S. Department of Justice DNFSB Defense Nuclear Facilities Safety Board FISMA Federal Information Security Modernization Act FOIA Freedom of Information Act FY Fiscal Year HCF Human Capital Framework HCAAF Human Capital Assessment and Accountability Framework IAM Issue Area Monitor IC Intelligence Community IG Inspector General IT Information Technology NRC U.S. Nuclear Regulatory Commission OIG Office of the Inspector General OMB Office of Management and Budget OPM Office of Personnel Management