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CITY OF CHICAGO
OFFICE OF:INSPECTOR GENERAL :
AUDIT AND PROGRAM REVIEW SECTION-? ¦ 2021 ANNUAL PLAN '
APPROVED BY THE INSPECTOR GENERAL DECEMBER 23, 2020
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OIG APR 2021 ANNUAL PLAN
TABLE OF CONTENTS
MISSION|910|PURPOSE OFTHE ANNUAL PLAN|910|A SUBJECT TO CHANGE 6
B DEPARTMENTAL ACTION|910|C PROCESS .- 6
SELECTION OF TOPICS FOR INCLUSION IN THE ANNUAL PLAN|910|A TOPIC SOURCES|910|B PRIORITIZATION CRITERIA|910|1. Risk Assessment |910|2 OIG Role and Value Added |910|3. Follow-Up on Past APR Reports 9
4 Available Staff Resources 9
2021 NEW PROJECTS 10
CITY DEVELOPMENT AND REGULATORY 11
1. COVID-19 Emergency Assistance Funds 11|109|Neighborhood Opportunity Fund Administration 11
COMMUNITY SERVICES 11
1. Department of Family & Support Services' (DFSS) Meals on Wheels Program
Administration 11
FINANCE AND ADMINISTRATION 12
Workers'Compensation Program 12
Pro-Equity Contracting Goal Achievement 12
City Data Quality 12
Capital Project Implementation 12
Complaint-Driven Service Provision 13
Cloud Computing Tax Enforcement 13
Environmental Programs 13
Fee and Fine Writedowns and Unenforced Municipal Code Penalties 13
D INFRASTRUCTURE 14
Department of Streets and Sanitation (DSS) Street Sweeping Efficiency 14
DSS Homeless Encampment Cleaning 14
DSS Tree Trimming, Planting, and Removal 14
Chicago Department of Transportation (CDOT) Street Resurfacing and
Maintenance 15
Bike Lane Maintenance and Enforcement 15
Department of water management (DWM) Sewer Cave-In Repair Time 15
Department of Assets, Information and Services' (AIS) Maintenance of
Energy-Saving Systems in City Buildings 16
E PUBLIC SAFETY 16
Chicago Fire Department (CFD) Fire Prevention Inspections 16
CFD Albrccht Decree Compliance 16
3. CFD Management of Overtime ' 17
4 Chicago Police Department (CPD) and CFD Position Civihanization 17
REPORTS PUBLISHED IN 2020 18
A CITY DEVELOPMENT AND REGULATORY ..... 18
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OIG APR 2021 ANNUAL PLAN DECEMBER 23, 2020
B COMMUNITY SERVICES 18
C. FINANCE AND ADMINISTRATION 18
1 Follow-Up on OIG's Audit of the City's Process for Evaluating ond Setting User
Fees (#19-1246) 18
OIG Advisory Concerning the City of Chicago Data Portal (#19-1029) 19
Audit of the Operations of the Chicago Board of Election Commissioners
(CBOEC) Follow-Up Inquiry (#19-0899) 20
Department of Human Resources (DHR) Employee Performance Evaluation
Audit (#19-0929) 22
Audit of the City's Capital Improvement Program Development and
Evaluation (#19-0681) 22
D INFRASTRUCTURE 23
Department of Water Management Overtime Monitoring Audit (#17-0664) 23
Chicago Department of Transportation Commercial Driveway (CDOT) Billing
Follow-Up Inquiry (#20-0194) 24
CDOT Traffic Signal Planning Audit (#19-0766) 25
Department of Streets and Sanitation's (DSS) Weed Cutting Program Audit
(#19-0525) 25
Department of Assets, Information and Services' (AIS) Maintenance of Police
Vehicles foilow-Up Inquiry (#20-0868) 26
Department of assets, information and services' Management of Information
Technology Investments Follow-Up Inquiry (#20-0923) 27
DSS Commercial and High-Density Residential Recycling Enforcement Audit
(#19-0942) 28
E. PUBLIC SAFETY 29
Chicago Police Department (CPD) Overtime Controls Audit Follow-Up Inquiry
(#19-0590) 29
Audit ofthe Chicago Police Department and the Department of Family and
Support Services' (DFSS) Administration of the Juvenile Intervention and
Support Center (JISC) (#18-0087) 31
OIG Notification Concerning the Effect of Chicago Fire Department (CFD)
"Manning" Requirements on Investigations into Allegations of Workplace
Harassment (#19-0547) 32
FOLLOW-UP REPORTS TO CONDUCT IN 2021 34
PROJECTS IN PROGRESS 35
A CITY DEVELOPMENT AND REGULATORY 35
Audit of Compliance with the Tax Increment Financing (TIF) Sunshine
Ordinance and the TIF Surplus Executive Order (#19-1047) 35
Department of Buildings (DOB) Permit Issuance and Inspections Audit (#20-
0831) ... 35
3 DOB and Department of Law Prosecution and Resolution of Off-Premise Sign
Permit Violations Audit (#20-1285) . 35
B COMMUNITY SERVICES . ... 35
Chicago Department of Public Health (CDPH) Air Pollution Enforcement
Audit Foliow-^p Inquiry (#20-1167) .. . .35
CDPH COVID-19 Contact Tracing Data Privacy ond Sccur.ty Audit (#20-1263) 35
OIG APR 2021 ANNUAL PLAN
CDPH Construction and Demolition Debris Recycling Audit (#20-1562) 36
Department of Family and Support Services (DFSS) Strategic Framework
(#20-1629) 36
FINANCE AND ADMINISTRATION 36
City Council Committee Expenditures Audit (#20-0285) 36
Municipal Depository Reporting and Pledge Compliance Audit (#20-1024) 36
Chicago Infrastructure Trust Smart Lighting Project Funding Notification
(#19-1364) 36
INFRASTRUCTURE 36
Public Building Commission (PBC) Energy Conservation Commissioning
Audit (#20-0830) 36
Department of Water Management (DWM) Overtime Audit Follow-Up
Inquiry (#20-1268) 37
PUBLIC SAFETY '. 37
Chicago Fire Department (CFD) Discrimination and Sexual Harassment Audit
(#19-0547) 37
CFD Response Times Audit (#20-0567) 37
Chicago Police Department (CPD) Dashboard Cameras Audit (#20-0590) 37
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OIG APR 2021 ANNUAL PLAN
ACRONYMS
2FM Department of Fleet and Facility Management
AIS Department of Assets, Information and Services
APR OIG Audit and Program Review Section
CBOEC Chicago Board of Election Commissioners
CDOT Chicago Department of Transportation
CDPH Chicago Department of Public Health
CFD Chicago Fire Department
CIP Chicago Capital Improvement Program
CPD Chicago Police Department
DFSS Department of Family and Support Services
DHR Department of Human Resources
DOB Department of Buildings
DOF Department of Finance
DolT Department of Innovation and Technology
DPD Department of Planning and Development
DSS Department of Streets and Sanitation
DWM Department of Water Management
EEO Equal Employment Opportunity
FHWA Federal Highway Administration
GAS Government Auditing Standards
GFOA Government Finance Officers Association
DISC Juvenile Intervention and Support Center
MCC Municipal Code of Chicago
OBM Office of Budget and Management
OIG Office of Inspector General
PBC Public Building Commission
TIF Tax Increment Financing
OIG APR 2021 ANNUAL PLAN
I. MISSION
The City of Chicago Office of Inspector General (OIG) is an independent, nonpartisan oversight agency whose mission is to promote economy, efficiency, effectiveness, and integrity in the administration of programs and operation of City government.
The OIG Audit and Program Review (APR) section supports the OIG mission by conducting independent, objective analysis and evaluation of municipal programs and operations, issuing public reports, and making recommendations to strengthen and improve the delivery of public services.
APR conducts performance audits of Chicago municipal programs and operations in accordance with generally accepted Government Auditing Standards (GAS or "Yellow Book," 2018 revision) established by the United States Government Accountability Office. As defined in GAS 1.21,
Performance audits provide objective analysis, findings, and conclusions to assist management and those charged with governance and oversight, with, among other things, improving program performance and operations, reducing costs, facilitating decision making by parties responsible for overseeing or initiating corrective action, and contributing to public accountability.
In addition to performance audits, APR may also generate non-audit work such as advisories, notifications, and descriptions of programs.1
APR's role is separate from, but complements, the work performed by the OIG Investigations and Public Safety sections. Investigations primarily examines allegations of individual misconduct or wrongdoing, and Public Safety focuses on the Police Department, Civilian Office of Police Accountability, and the Police Board, endeavoring to promote public safety, protect civil liberties and civil rights, and ensure the accountability ofthe police force. APR undertakes projects designed to help the City maximize the effectiveness and efficiency of programs and processes. APR is also distinct from the OIG Diversity, Equity, Inclusion, and Compliance Section, which performs legally mandated reviews ofthe City's hiring and employment practices to ensure compliance with the City's various hiring Plans.
1 OIG advisories and department notifications describe management problems observed by OIG through direct review or in the course of othei act vities
OIG APR 2021 ANNUAL PLAN
PURPOSE OF THE ANNUAL PLAN
The purpose ofthe APR Annual Plan is to identify potential projects for the upcoming fiscal year. Projects are selected based on OIG's prioritization criteria, which we describe below.
SUBJECT TO CHANGE
The Annual Plan is a guiding document that is subject to change; it does not prohibit APR from setting new priorities or initiating different projects over the course ofthe year. Circumstances that arise during the year may prompt OIG to undertake new, higher priority projects or reduce the priority of a planned project. Some topics on the Annual Plan may be deferred to following years. In addition, a project on the Annual Plan that originally begins as an audit may instead be completed as an OIG advisory, department notification, or other non-audit report, or terminated if OIG determines that further work will not bring substantial benefit to the City or is not cost effective for OIG.
B. DEPARTMENTAL ACTION
OIG encourages City departments to proactively assess any program included on the Plan and to alert OIG to any corrective action taken in advance of and/or during an APR performance audit. Such action will not necessarily deter APR from auditing the program, but the audit will assess and report on any proactive and promptly reactive measures the department has taken.
PROCESS
The Annual Plan is drafted in consultation with the Inspector General, senior OIG staff, and APR staff, with final approval by the Inspector General. OIG publishes a draft of the Annual Plan for public comment each September, and reviews, updates, and publishes the final Plan in December.
OIG APR 2021 ANNUAL PLAN
III. SELECTION OFTOPICS FOR INCLUSION IN THE ANNUAL PLAN
TOPIC SOURCES
OIG gathers potential audit topics from a variety of sources, including: complaints received from the public via the OIG tip line, suggestions from governmental leadership; past OIG reports; OIG investigations; OIG staff knowledge; other governments' performance audits, audited financial statements, internal audits, and risk assessments; new City initiatives; program performance targets and results; public hearings and proceedings; and public source information, including media, professional, and academic reports and publications.
This spring we distributed an online survey soliciting audit topics from the public. We received 874 responses, which informed our selections for the Draft 2021 Plan. We also distributed an online survey soliciting feedback on the draft plan OIG published for public comment on September 30, 2020. We received 492 responses, which further informed our selections for this final version ofthe plan. We encourage the public to submit suggestions anytime through the OIG website: iqchicaqo.org/contact-us/help- 1 mprove-city-qovernment/.
PRIORITIZATION CRITERIA
OIG considers numerous factors in selecting projects for the Annual Plan, including preliminary risk assessments ofthe programs or services involved in potential new project topics; the unique value a potential project might bring to City stakeholders; and the availability of APR resources, taking into account resources required to conduct follow-ups on past reports.
1. RISK ASSESSMENT
A risk factor is an observable and/or measurable indicator of conditions or eventsthat could adversely affect an organization, absent effective internal controls. APR's assessment of topics is based on risk factors reflecting the nature and potential vulnerabilities of departments, programs, and vendors. APR considers a variety of risk factors, such as,
Resources used to deliver service
o Size (in dollars budgeted) of department/program o Number of staff working in department/program
Public interest/impact
o Critical to City's mission or core service provision
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OIG APR 2021 ANNUAL PLAN
o Affects public health or safety o Affects vulnerable populations
o Affects equitable provision and distribution of City services and support
• Number of residents, employees, and/or businesses affected/served
o Quality/quantity of service provision o Customer satisfaction
Compliance with laws, regulations, or policies
Volume, type, and dollar amount of financial transactions
Quality of internal control systems, including,
o Existence of robust operational policies and procedures o Existence and use of performance metrics
Underfunded mandate or mismatch between program objectives and available resources
APR assesses risk based on discussions with departments and leadership, information requested from departments, information obtained from prior OIG work, publicly available information, and additional research. In some cases, OIG selects a project because there is a preliminary indication of specific program vulnerabilities. In other cases, OIG selects a project where there is little or no indication of program vulnerabilities, but the public and governmental leadership would benefit from independent evaluation and assurance that the program is working well.
2. OIG ROLE AND VALUE ADDED
OIG seeks to add unique value arising from its role as the City's independent oversight agency by prioritizing APR projects that,
analyze performance of governmental operations and programs where analysis requires data and information not available to external entities;
analyze governmental operations and programs where no recent independent analysis exists;
develop knowledge of the operation of municipal programs and services; and/or
analyze narrow, obscure, or complex aspects of municipal operations that receive little attention (in addition to broad scope topics).
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OIG APR 202"! ANNUAL PLAN
In addition, OIG strives to ensure that the selection of projects provides coverage across the full spectrum of governmental functions and services.
FOLLOW-UP ON PAST APR REPORTS
APR evaluates each completed audit six months after publication to determine whether, when, and how to conduct follow-up. Factors considered in determining what, if any, follow-up action to take include the nature of the original findings and recommendations, changes in management or staff structure, and external circumstances affecting the department. For example, APR may decide to postpone follow-up for an additional six months, conduct another full audit with complete re-testing, or simply request and evaluate documentation of corrective actions from management.
Follow-up reports are an essential part ofthe oversight process because they enable OIG to evaluate the actions taken by a department or agency to address problems identified in the original audit report. For that reason, they take the highest priority when planning the activities of APR personnel.
AVAILABLE STAFF RESOURCES
The number, experience, and specific expertise of staff available to APR affect the selection of project topics and their scope. APR will not undertake projects unless OIG has the required competencies available among its personnel or can procure them from external sources. APR will request assistance from other OIG staff when their specialized expertise (e.g., legal or data analysis) may benefit a project, and will adhere to all GAS requirements for the use of such internal specialists.
To maximize their utility, performance audits must be timely. Unexpected delays caused by an auditee, such as slow responses to APR requests, or problems with the quality of program data, are noted as findings or limitations in published audit reports. Proper planning requires the Deputy Inspector General and Chief Performance Analysts to assign adequate staff—or, if necessary, reduce audit scope— to ensure timely completion of all projects.
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OIG APR 2021 ANNUAL PLAN
IV. 2021 NEW PROJECTS
As projects are completed and staff become available, APR reviews the topics on the Annual Plan and conducts additional research prior to launch. ("Launch" is the official opening of an audit with a department.) The final decision to launch a project requires approval by the Inspector General on a just-in-time basis, because circumstances affecting the decision of whether or when to launch a specific project are expected to change throughout the year.
APR groups the 22 potential project topics listed below into 5 broad categories corresponding with the functions and departments presented in the City's Annual Appropriation Ordinance, Summary E2 We do not rank the topics. The numbers below are provided solely for ease of identification. We are soliciting public comment on these topics and will use that feedback to determine which topics to include on the final 2021 Plan to be published in December. Each topic listed includes,
Potential Potential questions the project will seek to answer. APR refines the Objectives: objectives after obtaining more information about the topic from the department.
Rationale: Relevance of and background on the topic.
There are five projects on the 2020 Plan that have not been launched and will not be carried over to the 2021 Plan for the following reasons:
Department of Business Affairs and Consumer Protection Enforcement of the Shared Housing Ordinance, because of recent changes to the ordinance. We will revisit this topic in 2022.
City Budget Development Process, because of the unique impact of COVID-19 and the related recession on the 2021 budget. We will revisit this topic in a future year.
Lead Water Service Line Mitigation, because the City announced its plan to begin replacing the estimated 400,000 lead service lines in Chicago
Water Billing Exemptions, because it was considered lower priority than other infrastructure-related projects.
Chicago Emergency Telephone System Board Administration of Emergency Telephone System Fund, because it was considered lower priority than other public safety-related projects.
2 For tho City's Annual Appropriation Ordinances, see httns/AvvvvV cuvofchicano oro/citv/en/deots/obm/ sunpsupo, inf: i/aei ;i.i-;i -hi idnot-recc-irimericialions- --documents html OIG also has oversight duties relating to operation and projects of the Public Building Commission (PBC) Planned audits of PBC activity aie included in tlie inf'astiucture category
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OIG APR 2021 ANNUAL PLAN
A. CITY DEVELOPMENT AND REGULATORY
1.
Potential Objectives:
Rationale:
COVID-19 EMERGENCY ASSISTANCE FUNDS
Did the City ensure that assistance was provided to target populations and only to eligible applicants?
Did the City ensure that the application process was accessible, user friendly, and timely?
The City has created various cash assistance programs to provide money to individuals and businesses suffering lost revenue as a result of COVID-19. This audit will determine whether the programs have been effective in disbursing funds to the intended recipients.
2. NEIGHBORHOOD OPPORTUNITY FUND ADMINISTRATION
Potential • Does the Department of Planning and Development (DPD) award Objectives: Neighborhood Opportunity Fund grants in a fair and equitable
manner, as required by Chapter 16-14 ofthe Municipal Code of
Chicago (MCC)?
• Does DPD verify that grants are spent for the purposes originally proposed by the grantees?
Rationale: The Neighborhood Opportunity Fund collects fees from downtown development projects in return for relief from certain zoning requirements and awards grants to eligible businesses on the South and West Sides of Chicago. As of August 19, 2020, the Fund had committed $49 million to 157 projects.3 This audit will examine DPD's administration of the Fund, including the selection of grantees and monitoring of their adherence to the grant requirements.
B. COMMUNITY SERVICES
1. DEPARTMENT OF FAMILY & SUPPORT SERVICES' (DFSS) MEALS ON WHEELS PROGRAM ADMINISTRATION
Potential • Does DFSS' administration ofthe Meals on Wheels program align Objectives' with best practices?
Rationale. OIG received a complaint about the effectiveness and efficiency of the City's Meals on Wheels program, a weekly meal delivery service for older adults. This audit will evaluate whether the program follows best practices.
J Ciiy of Chicago. "City Will Start Accepting Neighborhood Oppoi tunity Kind Grant Applications on Sept 14,' August 19, 2020, accessed August 24, 2020 lilt is: v^vav Chicago opy/cii v/eiVcieots/clcci/r-rovdrs
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OIG APR 2021 ANNUAL PLAN
C. FINANCE AND ADMINISTRATION
WORKERS'COMPENSATION PROGRAM Potential • Has the City implemented recommend
Objectives: Thornton in its 2019 audit of the workers' compensation program?
Rationale: The City hired Grant Thornton to review the workers' compensation program in early 2019 and make recommendations to ensure the program's legal compliance, prevent fraud, and improve efficiency. This report will determine whether the City has implemented the recommendations.
PRO-EQUITY CONTRACTING GOAL ACHIEVEMENT
Potential • Do the City's efforts to increase the participation on City contracts Objectives: by businesses owned by women, minorities, persons with
disabilities, and other traditionally disadvantaged groups, align
with best practice strategies in other cities?
Rationale: The City has a variety of Minority Business Enterprise, Women Business Enterprise, Disadvantaged Business Enterprise, and Business Enterprises Owned by People with Disabilities outreach programs and contracting incentives. This audit will assess whether these efforts increase the capacity of these businesses to compete for municipal contracts.
CITY DATA QUALITY "
Potential • How can the City ensure that it collects and effectively organizes Objectives: complete and accurate data related to municipal operations?
Rationale: Multiple OIG audits have encountered incomplete, inaccurate, or otherwise unusable data in City files and databases, which hinders the City's ability to deliver services and measure-performance. This advisory will compile examples and suggest ways the Mayor's Office may drive better data quality in the City.
4. CAPITAL PROJECT IMPLEMENTATION
Potential • Does the City implement capital projects in accordance with best Objective: practices?
Rationale: The City's 2019-2023 Capital Improvement Program includes $8.5 billion to be spent on capital projects over five years, and the 2021-2025 plan totals $11.7 billion This audit will conduct case studies of selected past capital projects to determine whether the City follows best practices for project execution.
OIG APR 2021 ANNUAL PLAN
COMPLAINT-DRIVEN SERVICE PROVISION
Potential • How can the City effectively balance complaint-driven service
Objective: provision with proactive service provision7
Rationale: Multiple OIG audits have uncovered City services that are driven
primarily or entirely by 311 service requests. While 311 is an important source of information, exclusive reliance on complaints to drive service provision is neither efficient nor equitable. This advisory will suggest ways to design proactive programs to complement complaint-based service.
6. CLOUD COMPUTING TAX ENFORCEMENT
Potential • Does the Department of Finance (DOF) ensure all required
Objective: entities pay the Personal Property Lease Transaction Tax for the
non-possessory lease of a computer to input, modify, or retrieve
data supplied by the customer? • Does DOF make all related private letter rulings available to the
public?
Rationale: Chicago began taxing cloud computing services under its Personal
Property Lease Transaction Tax in 2016 at a rate of 5.25%, increasing to 7.25% in 2020. In response to a Freedom of Information Act request, the City released private letter rulings suggesting some confusion regarding entities and services that are exempt from the tax. This audit will evaluate DOF's administration and enforcement ofthe tax.
ENVIRONMENTAL PROGRAMS
Potential • How can the City strengthen its environmental services and Objective: programs?
Rationale: Multiple OIG audits have identified problems with programs and
services formerly provided by the Department of Environment, which was disbanded in 2011. This advisory will compile examples and suggest ways the City could better support these services.
FEE AND FINE WRITEDOWNS AND UNENFORCED MUNICIPAL CODE PENALTIES
Potential • How prevalent is under-enforcement or non-enforcement of City
Ci;.:i c i ives fees and fines7
Rationale' Past OIG work has found instances where fines and fees were
imposed at the wrong amounts, significantly written down by the Department of Law or Department of Administrative Hearings, or not
OIG APR 2021 ANNUAL PLAN
imposed at all. This advisory will provide the Mayor's Office and City Council with examples of such enforcement gaps.
D. INFRASTRUCTURE
DEPARTMENT OF STREETS AND SANITATION (DSS) STREET SWEEPING EFFICIENCY
Potential • Do DSS' street sweeping routes maximize the effectiveness and Objectives: efficiency of street sweeping citywide?
Rationale: Historically, DSS has organized street sweeping routes on a ward basis, generally assigning one sweeper to each ward, and using laborers to hang temporary "No Parking" signs. Given the significant size differences among wards, this approach results in some streets being swept more often than others. This audit will evaluate DSS' performance of this function.
DSS HOMELESS ENCAMPMENT CLEANING
Potential • Does the City provide adequate notice of encampment cleanings Objectives: and evictions to individuals experiencing homelessness?
Does the City protect the personal property of individuals experiencing homelessness during encampment cleanings and evictions?
Does the City's provision of services to homeless encampments meet best practices?
Rationale: The City periodically performs cleanings, temporary evictions, and service outreach to encampments (or "tent cities") where people experiencing homelessness live. This audit will evaluate whether the City provides adequate notice to encampment residents, protects their personal property, and follows best practices for such cleanings.
¦ 3. DSS TREE TRIMMING, PLANTING, AND REMOVAL
Potential • Does the DSS Bureau of Forestry achieve its goal of responding to Objectives: tree trimming requests within 45-days7
Do the City's urban forest management practices meet best practices?
Is tree removal and replacement conducted equitably across the City'?
Rationale' OIG has received complaints about the length of time it takes the City to respond to tree-trimming requests, and a 2019 OIG advisory noted that the City's reliance on requests alone, rather than grid-based
OIG APR 2021 ANNUAL PLAN
4.
potentiai Objectives:
Rationale:
5.
Potential Objectives:
Rationale:
scheduled trimming, is neither equitable not efficient. This audit will evaluate DSS' urban forestry practices against best practices.
CHICAGO DEPARTMENT OF TRANSPORTATION (CDOT) STREET RESURFACING AND MAINTENANCE
Does CDOT manage streets in a cost-effective way that extends pavement life?
In a 2015 audit, OIG found that CDOT's pavement management program did not meet federal guidelines and lacked sufficient street condition data, relying instead on constituent complaints and visual inspections. The audit also found that the City could save $4.6 million annually by reallocating money from resurfacing to preventive maintenance. Poor street conditions continue to concern roadway users. This audit will re-examine the City's pavement management program.
BIKE LANE MAINTENANCE AND ENFORCEMENT
Does the City adequately enforce the prohibition on vehicles stopping or standing in bicycle lanes, including for the City's own vehicles?
• - Does the City keep bike lanes free of other obstructions such as
snow, water, and potholes7
OIG has received complaints about the number of vehicles that block bicycle lanes, including City vehicles, endangering cyclists. This audit will evaluate the City's enforcement of the prohibition on blocking bike lanes, as well as the City's efforts to keep lanes free of other obstructions.
6. DEPARTMENT OF WATER MANAGEMENT (DWM) SEWER CAVE-IN REPAIR TIME
Potential • Does DWM conduct sewer cave-in inspections and repairs in a Objectives: timely manner?
Rationale: OIG has received complaints about the amount of time it takes DWM to repair sewer cave-ins (holes in pavement caused by collapsed underground sewer infrastructure). This audit will evaluate the Department's sewer-cave in repair time.
OIG APR 2021 ANNUAL PLAN
7.
Potential Objectives:
Rationale:
DEPARTMENT OF ASSETS, INFORMATION AND SERVICES' (AIS) MAINTENANCE OF ENERGY-SAVING SYSTEMS IN CITY BUILDINGS
• Does AIS maintain energy-saving mechanical systems in accordance with commissioning documents, operation and maintenance manuals, and related building documentation to ensure public buildings are meeting their energy usage goals?
OIG is currently conducting an audit examining whether the Public Building Commission provides the City with complete and accurate instructions on how to operate energy-saving systems (e.g., solar, geothermal) in facilities it builds or remodels for the City. This audit will'examine whether AIS, in turn, properly maintainsthe buildings to achieve energy savings.
E. PUBLIC SAFETY
Note: OIG's Public Safety Section conducts inspections, evaluations, and reviews of City police and police accountability programs, operations, and policies. See the Public Safety Section's annual plan at office/public-safetv-section/current-proiects/.
1.
Potential Objectives:
Rationale:
CHICAGO FIRE DEPARTMENT (CFD) FIRE PREVENTION INSPECTIONS
Does CFD's Fire Prevention Bureau conduct the annual inspections required by the MCC7
Does CFD notify noncomphant building owners and conduct timely follow-up inspection of known violations?
The inspection of buildings for adherence to the fire code and timely correction of violations is a critical component of public safety. CFD does not currently publish fire inspection activity on the City's Data Portal. This audit will evaluate the Department's performance of this role.
2. CFD ALBRECHT DECREE COMPLIANCE
Potential • Do CFD's promotional practices effectively address the concerns Objectives: identified by the Albrecht Decree?
RaiionalE' In response to a federal lawsuit alleging discriminatory hiring and promotion practices at CFD, the City entered into the Albrecht Decree in 1982 There continues to be public concern over CFD's hinng'and promotion practices. This audit will evaluate the extent to
OIG APR 2021 ANNUAL PLAN
which the City's current practices remedy the conditions that gave rise to the Decree.
CFD MANAGEMENT OF OVERTIME
Potential • Does CFD allocate staff in a manner that minimizes overtime? Objectives: • Does CFD maintain and enforce policies that ensure appropriate and equitable assignment of overtime to staff?
Rationale: In recent years, spending on CFD overtime has increased
significantly. While some use of overtime is expected, excessive or inequitably distributed overtime may indicate suboptimal personnel management. This audit will evaluate CFD's overtime practices.
CHICAGO POLICE DEPARTMENT (CPD) AND CFD POSITION CIVILIANIZATION
Potential • Have CPD and CFD maximized opportunities for civilianizing Objectives: positions?
Rationale: Past OIG reports identified positions in the police and fire
departments that were filled by sworn or uniformed members but could be performed by civilians. This advisory will determine what progress each department has made and what barriers to civilianization may still exist.
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OIG APR 2021 ANNUAL PLAN
V. REPORTS PUBLISHED IN 2020
APR published the following 15 reports in 2020 (as of December 23, 2020). All are available at iqchicaqo.org/1
CITY DEVELOPMENT AND REGULATORY
None
COMMUNITY SERVICES
None
FINANCE AND ADMINISTRATION
1. FOLLOW-UP ON OIG'S AUDIT OF THE CITY'S PROCESS FOR EVALUATING AND SETTING USER FEES (#19-1246)
Publication
Date: March 10, 2020
Summary: OIG completed a follow-up to our June 2018 audit ofthe City's
process for evaluating and setting user fees. The purpose ofthe audit was to determine whether the City complied with its Financial and Budgetary Policies and followed national best practices embodied in the recommendations ofthe Government Finance Officers Association (GFOA). OIG found that the City did not adhere to its own policies or GFOA recommendations. We also found that the City did not perform accurate full-cost analyses. This created the risk that the City may not identify operational efficiencies because department leadership and City Council have no basis for knowing the actual cost of providing services to the public. OIG recommended that the Office of Budget and Management (OBM) develop a fee policy in line with GFOA recommendations, begin regular review of all City fees, enhance public transparency, perform full-cost analyses, and consider developing an alternative Cost Allocation Plan, among other actions.
In its response to the audit, OBM described corrective actions it would take related to several of OIG's recommendations. However, it disagreed with the recommendations to enhance public transparency, support fee proposals with full-cost analyses, and
¦'• OIG audit reports and advisories are published in full on the web siif OIG notifications and minor inquiries are summarized in QIC's quarterly reports
PACE lb
OIG APR 2021 ANNUAL PLAN
consider developing an alternative Cost Allocation Plan to support future full-cost analyses.
In November 2019, OIG inquired about the status of corrective actions taken by OBM. Based on the Office's follow-up response, OIG concludes that it has fully implemented four corrective actions, partially implemented two, and not implemented two. Specifically, OBM developed a fee policy and practices that align with GFOA recommendations; developed a master list of fees and a periodic review schedule; ensured that fee analyses accurately account for direct and indirect costs by developing its cost information template; developed a Citywide indirect cost rate for use in fee analyses; and added language to its fee policy requiring annual updates to this rate and allowing the use of more detailed indirect cost rates when necessa ry.
OBM declined to ask departments to perform full-cost analyses, but did require them to provide complete direct and indirect cost information through a uniform template each time a fee is up for review. OBM also declined to undertake long-term forecasting, but addressed some ofthe related risks by establishing a periodic fee review schedule. Finally, OBM did not begin a pilot program for department-performed, full-cost analyses and did not provide additional public information or opportunities for public feedback regarding fees.
2. OIG ADVISORY CONCERNING THE CITY OF CHICAGO DATA PORTAL (#19-1029)
Publication
Date: March 23,2020
Summary: An OIG advisory determined that the City does not comply with the requirements of Executive Order No 2012-2, which governs the administration ofthe Chicago Data Portal Over the course of several OIG projects, we had observed multiple issues with the Portal's completeness, accuracy, and usability, which prevent users from accessing relevant City information and reaching accurate conclusions about City initiatives and resources.
OIG encouraged the City to meet its existing obligations and strengthen its open data processes As the City reengages with its open data strategy via the newly created Department of Assets, Information and Services and the movement of senior technology officers to the Mayor's Office, it should take steos to comply with the
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current executive order, including publication ofthe required annual Open Data Compliance Report. The City should also improve the Portal's functionality, consistency, and accuracy by standardizing its open data planning, documentation, and staffing practices, and by conducting a review of existing City data websites to identify opportunities for consolidation.
The City agreed with, and committed to address, all of OIG's suggestions. The City stated that it plans to "build on previous efforts to establish a first-class data program not only in open data but also in governance, privacy and protection, access and sharing," acknowledging that it will "achieve full transparency and accountability only when [its] data is accurate, comprehensive, usable, and clearly communicated." The City also noted that the results of its own evaluation of the City's Open Data Program were in line with OIG's observations and suggestions.
3. AUDIT OF THE OPERATIONS OFTHE CHICAGO BOARD OF
ELECTION COMMISSIONERS (CBOEC) FOLLOW-UP INQUIRY (#19-0899)
Publication
Date: March 30, 2020
Summary: OIG completed a follow-up to its January 2019 audit ofthe financial and human resource operations of CBOEC. Per the Illinois Election Code, CBOEC is responsible for conducting all elections within the City of Chicago. The Code further requires the City and Cook County . to fund the Board. The purpose of our 2019 audit was to determine whether CBOEC employed sufficient financial controls to prevent waste, fraud, and abuse; whether its human resources program was designed to support its mission; and whether it maintained a contingency plan to ensure continuity of operations in the event of attack or disaster.
OIG's audit found significant gaps in C BO EC's financial administration related to vendor payments, cost allocations, budgeting, employee reimbursements, payroll, contract procurement, and cash management. CBOEC did not fulfill its obligations under the Patient Protection and Affordable Care Act, budget accurately for its personnel needs, have transparent hiring or promotional practices, or have succession plans for leadership and other critical positions. Lastly, CBOEC did not have a contingency plan to maintain continuity of operations in the event of attack or disaster OIG made recommendations aimed at improving CBOEC's
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fiscal administration, bringing its hiring, compensation, and employee succession programs into alignment with best practices, and establishing plans to ensure the safety and reliability of elections in the event of catastrophe. CBOEC provided a set of preliminary responses to the audit's recommendations in January 2019 and committed to providing a final response by May 31, 2019. However, OIG never received a final response from the Board.
In September 2019, OIG inquired about corrective actions taken by CBOEC. The Board provided a response to OIG's inquiry in October but did not respond to our subsequent requests for clarification until February 2020.
Based on CBOEC's responses, OIG concluded that the Board fully implemented 5 of the 19 audit recommendations, substantially -implemented 5, partially implemented 5, and did not implement 4.
Regarding its financial practices, CBOEC has acquired access to the City's electronic financial system; returned unused grant funds to the State of Illinois; discontinued the practice of allowing its commissioners to accrue vacation time; and has begun reporting its executive director's vacation time to the County. Additionally, CBOEC has begun reconciling its transaction logs and regularly depositing revenue; started using proper appropriation codes in its budget requests; received a refund from the County for an hourly payroll miscalculation; created an initial inventory of its contracts; and improved its purchasing rules. CBOEC also stated that it has segregated its internal payroll duties and reduced its reliance on sole source procurements. Additionally, regarding its human resources program, the Board stated it has analyzed its obligations under the Affordable Care Act and chosen to end its practice of employing hourly workers. CBOEC also updated its employee handbook, developed an employee performance management program with criteria for salary increases, and committed to finalizing job descriptions for "key/critical positions." Finally, CBOEC created a detailed contingency plan and inventory of its IT hardware and software.
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DEPARTMENT OF HUMAN RESOURCES (DHR) EMPLOYEE PERFORMANCE EVALUATION AUDIT (#19-0929)
Publication
Date: October 14, 2020
Summary: OIG evaluated DHR's management of the City employee
performance evaluation process to determine whether DHR ensures that City departments evaluate their employees' performance.
We found that DHR does not ensure that departments evaluate all employees. DHR has not clearly defined the roles and responsibilities related to periodic evaluations in Personnel Rule XIV, nor does it require or monitor departmental compliance with the rule. As a result, more than 10,000 City employees currently work in 7 City departments that report they do not conduct any performance evaluations, and another 6,000 City employees work in 13 other departments that report they do not annually conduct performance evaluations of all of their employees.
OIG recommended that DHR develop a Citywide performance evaluation system with standardized procedures to ensure that required periodic employee evaluations occur, while still allowing for customization across City departments. In addition, DHR should revise Personnel Rule XIV to clearly define performance evaluation expectations and responsibilities, and report on departmental compliance to the Mayor's Office. DHR agreed with our recommendations and committed to implementation of corrective actions.
AUDIT OFTHE CITY'S CAPITAL IMPROVEMENT PROGRAM DEVELOPMENT AND EVALUATION (#19-0681)
Publication
Date- December 22, 2020
Summary: OIG conducted an audit ofthe development and evaluation ofthe City's Capital Improvement Program (CIP), a five-year plan for infrastructure spending.
OIG concluded that the City's CIP development and evaluation process largely follows leading practices foi development but does not consistently evaluate goal achievement using performance measures or incorporate lessons learned from completed projects into future capital decision-making We recommended that the
OIG APR 2021 ANNUAL PLAN
Office of Budget and Management (OBM) define Citywide standards and increase transparency.
In response to our audit finding and recommendations, OBM stated that it agreed and incorporated some ofthe recommendations into the 2021-2025 CIP, released in November 2020. OBM intends to increase transparency by publicly sharing selection criteria and identifying additional opportunities for public engagement and input. OBM will also increase departmental coordination by facilitating "discussions with and between the responsible departments" and establishing "a process and protocol for this review."
D. INFRASTRUCTURE
1. DEPARTMENT OF WATER MANAGEMENT OVERTIME MONITORING AUDIT (#17-0664)
Publication
Date: March 25,2020
Summary: OIG conducted an audit of DWM's overtime monitoring. The purpose ofthe audit was to determine if DWM effectively monitored overtime to prevent waste and abuse. OIG concluded that DWM had developed policies and tools to manage overtime but did not utilize these resources consistently. We could not assess whether DWM appropriately distributed overtime because its records did not clearly identify the order in which the Department offered extra hours to employees. Instead, OIG found that "call-out" processes across DWM were neither standardized nor transparent, creating a climate where employees might perceive the overtime system as unfair—potentially undermining morale and triggering grievances. DWM managers at all levels had limited awareness ofthe full range ofthe Department's overtime processes, had not exercised robust oversight, and had not consistently maintained overtime records. OIG also identified inconsistencies in DWM's crew transfer process.
OIG recommended that DWM update and distribute its overtime policies, use monitoring tools to inform operational decisions, and continue efforts to develop internal reporting tools that provide a real-time view of overtime usage. We also recommended that DWM improve the consistency, transparency, and fairness of the overtime process by 1) identifying, documenting, and standardizing overtime call-out processes, 2) retaining overtime records, and 3) updating its existing transfer documentation. DWM agreed with the audit
OIG APR 2021 ANNUAL PLAN
findings and committed to make better use of overtime monitoring tools. The Department also agreed to revise some call-out procedures and to update its transfer request form and retention policy, and directed all bureaus to provide transparency by posting their call-out lists for employees to see.
2. CHICAGO DEPARTMENT OF TRANSPORTATION COMMERCIAL DRIVEWAY (CDOT) BILLING FOLLOW-UP INQUIRY (#20-0194)
Publication
Date: April 21, 2020
Summary: OIG completed a follow-up to its July 2019 audit of CDOT's billing
process for commercial driveway permit annual fees. The purpose of the 2019 audit was to determine whether CDOT accurately and completely billed commercial property owners for driveways that use the public way. Our audit found that the Department either did not bill, or inaccurately billed, an estimated 6,713 permitholders, had no confidence that all relevant driveways were recorded in its driveway permit system, and did not actively pursue payment for driveway permit fees that were past due.
OIG recommended several steps that CDOT should take to correct data problems hampering its billing operations and to prevent such problems in the future. Furthermore, we recommended that CDOT collaborate with other departments to include driveway permit fees in the City's standardized debt collection process.
In February 2020, OIG inquired about the status of corrective actions taken by CDOT. Based on CDOT's follow-up response, OIG concludes that CDOT partially implemented corrective actions. Specifically, CDOT created procedures to correct inaccurate driveway records and prevent future inaccuracies, developed and initiated a process to migrate data to the new Infor Public Sector (IPS) system, and documented standardized driveway permitting and billing procedures to share with relevant employees.
To fully implement the corrective actions recommended in the audit, the Department should identify inaccurate driveway permit records or undocumented driveways, credit and reimburse overbilled accounts, develop monitoring tools for permits at risk for inaccurate billing or non-billing, and migrate to IPS as planned.
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CDOT TRAFFIC SIGNAL PLANNING AUDIT (#19-0766)
Publication
Date: June 17, 2020
Summary: OIG conducted an audit to evaluate whether CDOT's traffic signal planning meets industry best practices as defined by the Federal Highway Administration (FHWA). FFIWA recommends that agencies adopt written traffic signal management plans with defined goals, objectives, and performance measures. OIG concluded that CDOT does not have a traffic signal management plan and has not established program objectives or performance measures connecting traffic signal planning, operations, and maintenance activities to broader Department and City goals related to traffic safety, equity, and mobility.
In addition, OIG found that rather than proactively maintaining and retiming traffic signals, CDOT conducts most of its work in response to 311 complaints, aldermanic requests, and major construction projects. This approach to maintenance limits CDOT's ability to address problems early or to ensure that signals are timed optimally for changing traffic conditions.
In response to our audit findings and recommendations, CDOT agreed to develop a traffic signal management plan, create performance measures to track progress toward its goals, and analyze staffing levels in relation to FHWA guidance.
DEPARTMENT OF STREETS AND SANITATION'S (DSS) WEED CUTTING PROGRAM AUDIT (#19-0525)
Publication
Date: July 23, 2020
Summary: OIG conducted an audit of DSS' weed-cutting program. DSS is responsible for cutting weeds that have grown higher than ten inches on the public way, as well as City-owned and private vacant land. DSS ward superintendents manage this process by visually surveying their wards, responding to complaints, and providing direction to weed-cutting contractors.
Based on the audit results, OIG concluded that DSS does not meet its goals for timely weed cutting. As a starting point, because there is no reliable list of City-owned properties that require mowing, DSS
i
cannot effectively manage City-owned vacant property. Moreover, the Department cannot accurately assess its performance in
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OIG APR 2021 ANNUAL PLAN
responding to weed-cutting complaints, because its data system is insufficient to ensure that important information is consistently and accurately captured.
In response to our audit findings and recommendations, DSS has begun providing the contractor with weekly lists of City-owned lots to mow and continues to issue tickets to private properties in violation ofthe ordinance. DSS plans to work with the Departments of Law and Planning and Development to help improve the City lot list by, for example, having ward superintendents provide other departments with information about vacant properties to aid in the ownership verification process. DSS stated it is in the process of shortening its complaint response goal from 42 days to 21 days and will communicate the change to staff. Finally, before the 2021 weed cutting season, the Department plans to improve its data collection systems and processes
Publication Date:
Summary: ¦
5. DEPARTMENT OF ASSETS, INFORMATION AND SERVICES' (AIS) MAINTENANCE OF POLICE VEHICLES FOLLOW-UP INQUIRY (#20-0868)
November 10, 2020
In September 2020, OIG completed a follow-up to its September 2019 Audit ofthe Department of Fleet and Facility Management's (2FM) maintenance of police vehicles. Based on the auditee's responses, • OIG concludes that 2FM—which has since been incorporated into AIS—has fully implemented three of six audit recommendations, substantially implemented one, partially implemented one, and not implemented one.
The purpose of the 2019 audit was to determine whether 2FM met the industry standard of at least 95% fleet availability. "Availability" is a fleet management performance measure that compares the number of hours a vehicle is expected to be available for use (e.g , eight hours a day) to the actual number of hours it is available. Our audit found that 2FM could not determine whether it met the industry standard of at least 95% fleet availability because it lacked accurate data, and that 2FM did not perform most preventive maintenance in a timely manner
OIG recommended several corrective steps for 2FM to address the data errors that hindered accurate determination of fleet availability We also recommended that the Department analyze its operations
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OIG APR 2021 ANNUAL PLAN
to determine if additional resources were needed. Finally, we recommended that 2FM improve communication with the Chicago Police Department (CPD) to facilitate reaching its preventive maintenance goals.
Based on the Department's follow-up response, OIG concludes that AIS has taken the following corrective actions:
reconfigured its fleet management software, M5, to reflect the entire time a vehicle is unavailable;
provided staff with trainings and monthly reports to address the issue of erroneously open work orders;
identified additional resources needed for timely preventive maintenance;
• improved its communication with CPD; and
prioritized preventive maintenance activities and initiated collaboration with CPD and OBM, although its efforts in these areas have been hampered by recent civil unrest.
OIG urges AIS to implement the remaining recommendations by determining vehicle-specific availability requirements and informing CPD of all vehicles that are overdue for preventive maintenance.
6. DEPARTMENT OF ASSETS, INFORMATION AND SERVICES'
MANAGEMENT OF INFORMATION TECHNOLOGY INVESTMENTS FOLLOW-UP INQUIRY (#20-0923)
Publication
Date- November 12, 2020
Summary: In August 2020, OIG inquired about the status of corrective actions taken in response to its December 2019 Audit ofthe Department of Innovation and Technology's (DolT) Management of Information Technology Investments. Based on the auditee's responses, OIG concludes that DolT—which has since been incorporated into AIS as the Bureau of Information Technology—has fully implemented five of eleven audit recommendations, substantially implemented four, and partially implemented two.
The purpose ofthe December 2019 audit was to determine whether DolT managed information technology (IT) investments in accordance with the U.S Government Accountability Office's Information Technology Investment Management framework. Our audit found that DolT did not consistently adhere to best practices for project selection, thereby increasing the risks of projects delivering fewer benefits, costing more, and/or taking longer than expected to
OIG APR 2021 ANNUAL PLAN
complete. In addition, DolT's data collection practices hampered effective monitoring and evaluation of project and portfolio performance, consequently limiting the Department's ability to identify opportunities for improvement.
Based on the results ofthe audit, OIG recommended that DolT follow internal policies and industry best practices with respect to project selection, monitoring, and evaluation. These recommendations included completing internal documents to guide these activities, requiring all project managers to follow these policies consistently, and empowering governing committees to meet mandates for project oversight. In its response to the'audit, DolT described corrective actions it would take.
Based on the Department's follow-up response, OIG concludes that AIS has substantially implemented corrective actions. Specifically, AIS has,
updated its Project Management Office (PMO) Handbook in key areas and required its project managers to follow it;
developed procedures for collecting more robust data for project selection;
• implemented new project management tools;
implemented monthly Information Technology Governance Board (ITGB) meetings;
ensured that project managers and the PMO Director provide the data needed for ITGB to execute its oversight role; and
endeavored to fully staff its Information Security Office.
To fully satisfy the audit's recommendations, AIS should add full project life cycle costs (such as maintenance and ongoing support) to its project cost estimates, and work with the Office of Budget and Management and the Mayor's Office to ensure that all City departments submit their IT project requests to ITGB for review and approval.
7. DSS COMMERCIAL AND HIGH-DENSITY RESIDENTIAL RECYCLING ENFORCEMENT AUDIT (#19-0942)
Publication
Date December 2, 2020
Summary: OIG evaluated DSS' enforcement of recycling requirements for commercial and high-density residential buildings underthe Chicago Recycling Ordinance (MCC Chapter 11-5)
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OIG APR 2021 ANNUAL PLAN
OIG found that DSS does not proactively enforce the Chicago Recycling Ordinance requiring commercial and high-density residential building owners to provide recycling services; rather, the Department relies on a complaint-based process in which Ward Superintendents inspect for compliance. However, the Department's Mobile E-Ticket (MET) system does not allow users to cite ordinance violations, so Ward Superintendents are unable to enforce fines. OIG also found that DSS does not ensure private haulers submit complete, accurate, and timely reports detailing the buildings they served, and the amount and type of materials hauled. Ofthe 15 required hauler reports OIG requested, DSS,
possessed nine, three of which were submitted after the February 28, 2019 deadline;
obtained four upon OIG's October 2019 request; and
did not possess or obtain two.
OIG determined five ofthe thirteen reports were incomplete and that DSS did not review their adequacy or cite private haulers for incomplete submissions.
The Department stated that it agrees with OIG's findings and recommendations and that it will implement corrective actions. DSS has begun working with DOL and AIS to revise citation processes and add the ordinance to the MET system. The City has engaged a consultant to conduct a comprehensive waste study, and DSS will await the results before developing a proactive enforcement strategy. The waste study will also inform any changes to the design, collection, and usage of private hauler reports.
E. PUBLIC SAFETY
1. CHICAGO POLICE DEPARTMENT (CPD) OVERTIME CONTROLS AUDIT FOLLOW-UP INQUIRY (#19-0590)
Publication
Date: February 3, 2020
Summary: OIG completed a follow-up to its audit of CPD overtime controls.
Based on the Department's responses, OIG concluded that CPD has initiated a systemwide overhaul of its overtime system, but that reform is still a substantial work in progress. CPD has fully or substantially implemented 4 corrective actions, while 7 have been partially implemented, and 2 remain unimplemented
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OIG's 2017 audit found that CPD's operational controls did not adequately prevent unnecessary overtime, deter abuse of minimum time provisions, or ensure that overtime was paid in compliance with policies and procedures. We also found that CPD management controls did not adequately prevent officer fatigue, control costs, or detect and prevent fraud, waste, and abuse. OIG made several recommendations to improve CPD's timekeeping and overtime controls, including,
work with the Office of Budget and Management to implement an automated timekeeping system that includes controls to ensure that timekeeping records are accurate, verifiable, and complete;
ensure that all CPD members, timekeepers, and supervisors are trained on and familiar with timekeeping policies, as well as following these policies with the proper tools;
establish clear expectations for management responsibilities, including accountability for unjustified overtime; and
ensure that all timekeeping directives are consistent and up to date, as well as routinely reviewed to confirm they conform with- obligations under current bargaining agreements and CPD processes.
CPD described corrective actions it would take regarding most audit recommendations but disagreed with OIG's recommendation that the Department limit the number of hours officers may work, including second jobs.
In June 2019, OIG inquired about corrective actions taken by CPD. Based on the Department's follow-up response, its overtime overhaul includes requiring all members to swipe in and swipe out during their regular tour of duty shift using an automated time and attendance system, as well as moving from a paper-based system to an electronic system However, additional reform—-with a focus on swiping compliance, providing appropriate training and tools to help supervisors identify and address patterns of waste or abuse, and implementing a policy limiting total hours and secondary employment—is still needed.
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OIG APR 2021 ANNUAL PLAN
2. AUDIT OF THE CHICAGO POLICE DEPARTMENT AND THE
DEPARTMENTOF FAMILY AND SUPPORT SERVICES' (DFSS) ADMINISTRATION OF THE JUVENILE INTERVENTION AND SUPPORT CENTER (DISC) (#18-0087)
Publication
Date: February 25, 2020
Summary: OIG conducted an audit ofthe JISC, a partnership between CPD and DFSS, implemented to divert youth arrested for low-level offenses away from the juvenile justice system and into social service case management. The purpose ofthe audit was to determine whether JISC is designed according to best practices for law enforcement-based youth diversion and whether its administration of diversion programming is consistent with its goals, including reducing youth recidivism.
OIG found that the JISC program partners cannot reliably assess the case management program's effect on youth recidivism due to poor record-keeping and insufficient interagency communication. JISC lacks a charter or governing board and does not have reliable data on its performance. As a result, the City cannot determine whether it has created positive or negative outcomes for the over 3,000 youth processed in each ofthe past 14 years, nor measure the return on its $5 million annual investment in the program. OIG also found that because JISC is not designed according to best practices for youth diversion programs, it subjects youth to a negative-experience that does not encourage their success and may actually retraumatize youth or increase their likelihood of reoffending. Lastly, OIG found that while the existence of JISC is probably not leading officers to arrest more juveniles than they otherwise would, there are demographic inequities with regard to which arrestees have been diverted from further involvement in the justice system.
OIG recommended that CPD and DFSS improve their recordkeeping procedures and collaboration, including creating accountability mechanisms for JISC's case management contractor and establishing partnerships with external agencies. We recommended that the departments should engage with community organizations, subject-matter experts, and criminal justice system stakeholders to bring JISC's design into accordance with best practices for diversion programs and to provide a more trauma-informed experience for youth. OIG also recommended that CPD select and train its JISC staff in accordance with best practices
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OIG APR 2021 ANNUAL PLAN
and implement review mechanisms to prevent inconsistent or inequitable outcomes for youth. CPD and DFSS agreed with nearly all our recommendations and began some corrective actions during the audit.
3. OIG NOTIFICATION CONCERNING THE EFFECT OF CHICAGO FIRE DEPARTMENT (CFD) "MANNING" REQUIREMENTS ON INVESTIGATIONS INTO ALLEGATIONS OF WORKPLACE HARASSMENT (#19-0547)
Publication
Date: 1 Summarized in Ql OIG Quarterly Report, April 15, 2020
Summary: In the course of fieldwork associated with OIG's pending audit of
discrimination and sexual harassment at CFD, we identified an aspect of CFD operations that may have discouraged Department members from reporting incidents of misconduct to the City's Equal Employment Opportunity (EEO) officer.
The pertinent practice relates to the "manning" requirements in the collective bargaining agreement (CBA) between CFD and the Chicago Firefighters Union. The CBA requires a minimum number of members on each Department apparatus (e.g., fire truck). The CBA allows 35 variances at any one time from these minimums. Notably, because an ambulance cannot operate effectively without two members, the variance process does not cover that category of apparatus.
OIG learned that when a CFD apparatus lacks the minimum number of members prescribed by the CBA, and the Department does not use a variance, the apparatus is taken out of service. Generally, this is what happens when an.on-duty CFD member has occasion to meet with EEO personnel; because CFD regularly uses all 35 variances to cover for members absent for their entire shifts, the sole exception from the "manning" requirements is unavailable in this situation. The usual practice is for all members assigned to the apparatus to travel to the Quinn Fire Academy or CFD Headquarters, then the one member continues on to the EEO meeting The other members remain at the Academy or Headquarters until their coworker gets back, at which point the apparatus returns to service.
OIG identified two principal problems arising from this practice First, from an operational perspective, it reduces the number of apparatuses and members available to respond to emergencies Second, the conspicuousness of a member's interaction with ELO
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OIG APR 2021 ANNUAL PLAN
personnel, as well as the inconvenience it creates for their team, discourages members from lodging EEO complaints or participating in investigations.
OIG urged the Department to take expeditious steps to develop and implement new procedures that eliminate—or at least mitigate— these problems. Rather than taking apparatuses out of service, we suggested that CFD consider using the rehire process to cover for members who have appointments with EEO personnel, or paying members to attend such appointments while off duty. To the extent reforming the process requires, or would be made easier by, changes to the CBA, OIG recommended that the Department prioritize this issue in contract negotiations.
In response to OIG's notification, CFD stated it had worked with the Department of Human Resources (DHR) to outline a plan to address our concerns and ensure that all EEO interviews are treated with the appropriate amount of discretion and confidentiality. In summary, CFD stated that the process for scheduling EEO interviews would be changed to allow an interviewee to either attend at the beginning of their shift—thereby allowing for increased privacy—or on a non-duty day—in which case they would receive overtime pay for the time spent in the interview. The Department stated that it would be working with DHR to turn this plan into a formal policy.
OIG APP 2021 ANNUAL PI^N
VI. FOLLOW-UP REPORTS TO CONDUCT IN 2021
The following published reports will be evaluated for follow-up in 2021. APR first considers a report for follow-up six months after publication: Follow-up may be postponed until 12 or more months after report publication depending on the nature and scope of corrective actions required. Summaries ofthe original reports are in the previous and following sections of this Plan.
Audit of CPD and DFSS' Administration of the Juvenile Intervention Support Center (published February 25, 2020)
CDOTTraffic Signal Planning Audit (published Junel7, 2020)
DSS Weed Cutting Program Audit (published July 23, 2020)
DHR Employee Performance Evaluation Audit (published October 14, 2020)
DSS Commercial and High-Density Residential Recycling Enforcement Audit (published December 2, 2020)
Audit ofthe City's Capital Improvement Program Development and Evaluation (published December 15, 2020)
CFD Discrimination and Harassment Audit (publication date TBD)
Audit of Compliance with the TIF Sunshine Ordinance and the TIF Surplus Executive Order (publication date TBD)
City Council Committee Expenditures Audit (publication date TBD)
OIG APR 2021 ANNUAL PLAN
VII. PROJECTS IN PROGRESS
The following 15 projects are underway as of December 23, 2020,
CITY DEVELOPMENT AND REGULATORY
AUDIT OF COMPLIANCE WITH THE TAX INCREMENT FINANCING (TIF) SUNSHINE ORDINANCE AND THE TIF SURPLUS EXECUTIVE ORDER (#19-1047)
This audit evaluatesthe Department of Planning and Development's compliance with the TIF Sunshine Ordinance (MCC § 2-45-155) and Executive Order 2013-3 (Declaration of TIF surplus funds in TIF eligible areas).
DEPARTMENT OF BUILDINGS (DOB) PERMIT ISSUANCE AND INSPECTIONS AUDIT (#20-0831)
This audit evaluates whether DOB performs the required permit-related building inspections, included those necessary for Certificates of Occupancy.
DOB AND DEPARTMENT OF LAW PROSECUTION AND RESOLUTION OF OFF-PREMISE SIGN PERMIT VIOLATIONS AUDIT (#20-1285)
This audit evaluates the departments' efforts to remediate off-premise sign permit violations by imposing penalties, ensuring valid permits are obtained, or removing unpermitted off-premise signs.
COMMUNITY SERVICES
CHICAGO DEPARTMENT OF PUBLIC HEALTH (CDPH) AIR POLLUTION ENFORCEMENT AUDIT FOLLOW-UP INQUIRY (#20-1167)
This inquiry follows up on corrective actions taken in response to OIG's 2019 audit of CDPH's inspection and monitoring of facilities that pollute the air.
CDPH COVID-19 CONTACT TRACING DATA PRIVACY AND SECURITY AUDIT (#20-1263)
This audit evaluates the City's policies and procedures related to safeguarding the privacy and security of personal information gathered through COVID-19 contact tracing.
OIG APR 2021 ANNUAL PLAN
CDPH CONSTRUCTION AND DEMOLITION DEBRIS RECYCLING AUDIT (#20-1562)
This audit evaluates CDPH's enforcement ofthe ordinances requiring contractors to recycle certain amounts of debris from demolition and construction projects.
DEPARTMENT OF FAMILY AND SUPPORT SERVICES (DFSS) STRATEGIC FRAMEWORK (#20-1629)
This audit evaluates DFSS' implementation of its strategic framework, including its process for selecting delegate agencies and reviewing their performance.
FINANCE AND ADMINISTRATION
1. CITY COUNCIL COMMITTEE EXPENDITURES AUDIT (#20-0285)
This audit evaluates whether City Council committees comply with municipal code requirements regarding committee budgets, expenditures, and personnel usage.
MUNICIPAL DEPOSITORY REPORTING AND PLEDGE COMPLIANCE AUDIT (#20-1024)
This audit evaluates whether the Department of Finance enforces the municipal code provisions requiring banks that hold City money to report lending and deposit information, and sign pledges promising to abstain from discriminatory and predatory lending practices.
CHICAGO INFRASTRUCTURE TRUST SMART LIGHTING PROJECT FUNDING NOTIFICATION (#19-1364)
This notification to City Council highlights potential areas of improvement related to communication and transparency during the legislative process, using the Smart Lighting Project as an example.
INFRASTRUCTURE
1. PUBLIC BUILDING COMMISSION (PBC) ENERGY CONSERVATION' COMMISSIONING AUDIT (#20-0830)
This audit evaluates whether PBC provides clients with all required commissioning and equipment documentation within the time frames specified in the Chicago Energy Conservation Code (MCC Title 14N).
Old APR 202: ANNUAL PLAN
2. DEPARTMENT OF WATER MANAGEMENT (DWM) OVERTIME AUDIT FOLLOW-UP INQUIRY (#20-1268)
This inquiry follows up on corrective actions taken in response to OIG's 2020 audit of DWM's overtime monitoring practices.
E. PUBLIC SAFETY
CHICAGO FIRE DEPARTMENT (CFD) DISCRIMINATION AND SEXUAL HARASSMENT AUDIT (#19-0547)
This audit evaluates CFD's efforts to prevent and address discrimination and sexual harassment in CFD.
CFD RESPONSE TIMES AUDIT (#20-0567)
This audit evaluates whether CFD's response time goals for fire and medical emergency response, respectively, meet state and national standards, and whether there are significant differences in response times across neighborhoods.
CHICAGO POLICE DEPARTMENT (CPD) DASHBOARD CAMERAS AUDIT (#20-0590)
This audit evaluates whether CPD manages and maintains dashboard cameras and footage in an effective manner.
MISSION
The City of Chicago Office of Inspector General (OIG) is an independent, nonpartisan oversight agency whose mission is to promote economy, efficiency, effectiveness, and integrity in the administration of programs and operations of City government. OIG achieves this mission through,
• administrative and criminal investigations by its Investigations Section;
performance audits of City programs and operations by its Audit and Program Review Section;
inspections, evaluations and reviews of City police and police accountability programs, operations, and policies by its Public Safety Section; and
compliance audit and monitoring of City hiring and human resources activities and issues of equity, inclusion and diversity by its Diversity, Equity, Inclusion, and Compliance Section.
From these activities, OIG issues reports of findings and disciplinary and other recommendations,
to assure that City officials, employees, and vendors are held accountable for violations of laws and policies;
to improve the efficiency and cost-effectiveness government operations; and
to prevent, detect, identify, expose, and eliminate waste, inefficiency, misconduct, fraud, corruption, and abuse of public authority and resources.
AUTHORITY
OIG's authority to produce reports of its findings and recommendations is established in the City of Chicago Municipal Code §§ 2-5G-030(d), -035(c), -110, -230, and 240.