Diana Shaw, formerly Acting Inspector General at State and now with Wiley’s White Collar and Government Investigations, was interviewed on Wiley’s Government Contracts podcast. Here are a few takeaways:
- Shaw reminded listeners that one of the big disconnects in working with auditors is to remember that they must work from criteria set in policy. This is a professional standard to protect the audited entity from an auditor substituting their judgment or opinion in reviewing the work.
- She recognizes that auditees may be frustrated when the standards don’t neatly apply to their circumstances. In this case, auditees should make sure auditors are informed about unique circumstances.
- Significant disconnects result in IG recommendations that the policy needs to be updated to address the different circumstances.
- When a contractor/recipient and agency recognize unique circumstances at the onset of an award and agree on a plan to address the policy requirement, the agreement should be documented at that point, not much later in response to an audit recommendation.
- Shaw also noted that one of the responsibilities of the Inspectors General is to protect whistleblowers. USAID’s OIG is required to investigate allegations of retaliation against whistleblowers. The resulting report is submitted to Congress and the USAID Administrator.
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- Recently, OIGs have been going after companies and organizations that have language in awards, employment agreements, non-disclosure agreements, and confidentiality agreements that require the individual to report concerns internally before contacting others.
- Such language should be readily found and revised to assure staff always have an avenue to report to their funding agency, its Inspector General, the SEC (if applicable), and a member of Congress.
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Listen to the podcast here.
