City of Chicago Office of Inspector General
Table of Contents
Table of Contents|910|I | Mission|910|| Purpose of the Annual Plan|910|A | Subject to Change .-;|910|B| Departmental Action|910|C| Process|910|| Selection of Topics for Inclusion in the Annual Plan|910|A | Topic Source ¦ 5
B| Prioritization Criteria|910|C | Risk Assessment|910|D | OIG Role and Value Added :|910|E | Follow-Up on Past APR Reports|910|F| Available Staff Resources|910|| 2023 New Projects|910|A | City Development and Regulatory|910|B| Community Services 11
C | Finance and Administration 12
D| Infrastructure 14
E| Public Safety 16
| Reports Published in 2022 19
A | City Development and Regulatory 19
B| Community Services 19
C | Finance and Administration 19
D| Infrastructure 19
E| Public Safety 19
| Follow-Up Reports to Conduct in 2023 20
VII | Projects in Progress 21
A | City Development and Regulatory 21
B| Community Services 21
C| Finance and Administration 21
D| Infrastructure 22
1.1 Public Safety 23
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Acronyms
APR OIG Audit and Program Review Section
ARO Affordability Requirements Ordinance
BACP Department of Business Affairs and Consumer Protection
BORC Department of Streets and Sanitation's Bureau of Rodent Control
CDO Chief Data Officer
CDOT Chicago Department of Transportation
CDPH Chicago Department of Public Health
CFD Chicago Fire Department
COFA City Council Office of Financial Analysis
CPD Chicago Police Department .
CPL Chicago Public Library
DCASE Department of Cultural Affairs and Special Events
DEI Diversity, Equity, and Inclusion
DFSS Department of Family and Support Services
DHR Department of Human Resources
DOB Department of Buildings
DOH Department of Housing
DPD Department of Planning and Development
DPS Department of Procurement Services
DSS Department of Streets and Sanitation
EAP Employee Assistance Program
EEO Equal Employment Opportunity
FHWA Federal Highway Administration
GAS Government Auditing Standards
GBV Gender-based violence
IAD Chicago Fire Department's Internal Affairs Division
ISO Information Security Office
IT Information Technology
ISTP Information Security and Technology Policies
LSE Life Safety Evaluation
MCC Municipal Code of Chicago
OBM Office of Budget and Management
OEMC Office of Emergency Management and Communications
OIG Office of Inspector General
PBC Public Building Commission
RDA Redevelopment Agreement
SLA Service Level Agreement
SRO Single Room Occupancy
TIF Tax Increment Financing
ZBA Zoning Board of Appeals
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City of Chicago Office oflnspector General
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.
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 Compliance Section, which performs legally mandated reviews ofthe City's hiring and employment practices to ensure compliance with the City's various hiring Plans.
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II | Purpose of the Annual Plan
The purpose of the 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.
A | 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 of the 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.
C| 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 year, and reviews, updates, and publishes the final Plan in December.
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III | Selection of Topics for Inclusion in the Annual Plan
A | Topic Source
OIG gathers potential audit topics from a variety of sources, including: intakes received from the public; suggestions from City officials, employees, and stakeholders; 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.
We will be releasing an online survey to solicit feedback and to inform the final plan to be published in December 2022. We encourage the public to submit suggestions anytime through the OIG website: iqchicaqo.org/contact-us/help-improve-city-government/ .
B | Prioritization Criteria
OIG considers several factors in selecting projects for the Annual Plan, including preliminary risk assessments of the 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.
C I Risk Assessment
A risk factor, is an observable and/or measurable indicator of conditions or events that 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 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
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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.
D | 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).
In addition, OIG strives to ensure that the selection of projects provides coverage across the full spectrum of governmental functions and services.
E | 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 ofthe 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 of the 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.
F | 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
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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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IV | 2023 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 25 potential project topics listed below into 5 broad categories corresponding with the functions and departments presented in the City's Annual Appropriation Ordinance, Summary E. 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 2022 Plan to be published in December. Each topic listed includes,
Background Background on and relevance of the topic, and
Rationale:
Potential Potential questions the project will seek to answer. APR refines the objectives after Objectives: obtaining more.information about the topic from the department.
There are seven projects on the 2022 Plan that have not been launched and will not be carried over to the 2023 Plan because they were considered lower priority than other projects. There projects are:
Department of Housing Troubled Buildings Initiative
Department of Planning and Development Large Lots Program
Administrative Fines for Vehicle Stickers Inquiry
Enforcement of Truck Idling Limits
Capital Project Implementation
DSS Tree Trimming, Planting, and Removal
DSS Street Sweeping Efficiency
AI City Development and Regulatory
1. Department of Business Affairs and Consumer Protection (BACP) Labor Rights Enforcement
Background The City of Chicago has several laws in place to protect workers, including
and ordinances defining local minimum wage, domestic worker rights, paid sick
Rationale: leave, wage theft, and COVID-19 vaccine and anti-retaliation protections. In 2019 City Council created BACP's Office of Labor Standards (OLS) to enforce these protections for all Chicago workers. OLS is responsible for conducting outreach to local employers, processing and investigating complaints, mediating disputes, directing settlement proceedings, and issuing violations. This audit will determine whether BACP has been effective in enforcing these ordinances.
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Potential • Does BACP's Office of Labor Standards enforce provisions of the City's labor
Objectives: rights ordinances to ensure employer compliance? Such ordinances address
wage theft, domestic worker rights, paid sick leave, and anti-retaliation
related to COVID-19 and vaccines.
Do BACP's rules related to these ordinances meet best practices?
2. Department of Cultural Affairs and Special Events (DCASE) Chicago
Film Office
Background Film production is a major Chicago industry. The city ranks in the top six
and nationally for overall film production and the film industry has contributed an
Rationale: estimated $2 billion in local revenue since 1980. Film productions directly impact Chicago residents by generating permit revenue and employment opportunities but may also create potential interruptions in the form of street closures, noise, pollution, and use of City infrastructure and resources. City Council members and local advocates-have voiced concern about inequitable distribution of these impacts, particularly in South and West neighborhoods which are home to major film studios and popular filming sites.
The Chicago Film Office serves as a liaison between City departments and film productions for permits, logistical support, and other city services. This audit would determine how the Film Office responds to resident complaints, whether the City meets its community benefit commitments to neighborhoods where film production takes place, and whether it ensures that productions reimburse the City appropriately for services.
Potential • Does DCASE ensure that production companies pay fees due to
Objectives: participating City agencies (CPD, CFD, and DSS), and do those fees recoup
the full cost of City services?
Does the Film Office coordinate with City departments to respond to public complaints about film productions?
How does the Film Office hold productions accountable for complaints and any associated code violations?
Does the Film Office meet its community benefit commitments for neighborhoods impacted by filming?
3. Department of Planning and Development (DPD) Jobs Covenants
Background When it uses City resources for economic development investments such as Tax
and Increment Financing (TIF), DPD signs a Redevelopment Agreement (RDA) with
Rationale: the developer. These RDAs often include covenants requiring the developer to provide quantifiable and measurable public benefits in exchange for their taxpayer-funded support, such as a minimum number of jobs created. A 2012 Illinois Public Interest Research Group report on job creation through TIF projects found that some agreements contained scarcely enforceable standards for public benefits, while others reported job creation and retention numbers that were not substantiated. This audit will determine whether DPD includes such covenants in all RDAs and whether it enforces these covenants.
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Potential Objectives:
Does DPD include public benefit covenants in all Tax Increment Financing
(TIF) redevelopment agreements with private entities?
Does DPD enforce its public benefit covenants with private entities?
Zoning Board of Appeals (ZBA) Decisions
Background Property owners must receive approval from the ZBA to develop a property in a
and way that does not comply with the Chicago Zoning Ordinance. The Ordinance
Rationale: limits such variations to situations in which strict compliance would create
specific difficulties or hardships. Through an initial review of meeting minutes, it appears the ZBA approves most variation requests. However, publicly-available documentation does not appear to demonstrate the specific hardships defined by the ordinance.
Furthermore, the variation application process is legally complex and requires numerous fees, creating the risk that it will be restricted to those with the resources to navigate the process. This audit will determine whether ZBA's variance decision process adheres to the limits allowed by the Zoning Ordinance and the acceptable reasons specified in the MCC
Potential • Does ZBA make decisions regarding ordinance variations only within its Objectives: authority?
• Does ZBA make variation decisions consistent with approval criteria, evidence, hardships, and/or other review factors?
Inclusionary Housing Task Force Report Implementation
Background In September 2020, the Department of Housing (DOH) published the
and Inclusionary Housing Task Force Staff Report to inform updates of the City's
Rationale: primary inclusionary housing tool, the Affordable Requirement Ordinance (ARO).
The ARO requires new and rehabbed residential developments to include a percentage of affordable units, aiming to ensure that "private development creates affordable housing in communities where the market and public policy have failed to do so." The report included nine recommendations to strengthen inclusionary housing policies in Chicago. To provide transparency to the residents of Chicago, this audit will assess what changes DOH has made to inclusionary housing policies to address the Report's recommendations.
Potential • Has DOH implemented corrective actions to address the recommendations
Objective: from the Inclusionary Housing Task Force Staff Report?
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B| Community Services
i. Chicago Department of Public Health (CDPH) Enforcement of Prohibition on Illegal Dumping
Background Illegal dumping creates physical and environmental hazards in the
and neighborhoods where it occurs. CDPH relies on complaints to identify cases of
Rationale: illegal dumping. However, this complaint-driven process might not be effective or equitable since underserved areas may have a greater number of empty lots or abandoned buildings that invite illegal dumping but lack resources to address the issue. CDPH, DSS, CPD, and DOL each have a role in the process of inspecting, cleaning, and prosecuting instances of illegal dumping. In 2019, CBS 2 News reported on dumping that had repeatedly occurred in the same lot for ten years despite persistent complaints to the City. This audit would determine whether CDPH responds effectively and equitably to complaints and coordinates with other City departments to address illegal dumping cases.
Potential • Does CDPH respond to illegal ("fly") dumping complaints in a timely manner? Objectives: • Is there a disparity in the outcomes of complaint-driven process in different areas of the city?
• To what extent do CDPH, DSS, CPD, and DOL work together to address the issue of illegal dumping?
2. Mental Health Equity
Background The World Health Organization reported a 25% increase in the prevalence of
and anxiety and depression worldwide, and local media reported an increase in the
Rationale: number of emergency calls related to mental health. The City reports that "40% of Chicagoans feel that mental health is one of the greatest challenges facing Chicago today." The Framework for Mental Health Equity is a broad initiative that seeks to provide residents with comprehensive care and fill gaps in the current mental healthcare system. Specifically, it aims to increase access to mental health services across the City with a focus on communities that experience high levels of poverty and violence. Additionally, the Framework aims to increase violence prevention programming. This audit will assess the extent to which the Framework has succeeded in meeting its goals.
Potential • Has CDPH implemented the goals outlined in Mayor Lightfoot's Framework
Objectives: for Mental Health Equity?
• Does CDPH measure the progress of its mental health equity initiatives to inform future goals?
3. Chicago Public Library (CPL) Staff Development Plan
Background The Chicago Public Library has served the city for nearly 150 years, often as the
and public's first interaction with City services. In recent years, CPL has seen
Rationale: increases in the community's need for library-based social services, access to CPL's social workers, and digital resources. Additionally, aldermen have asked about the library's response to some of the city's most vulnerable populations, including at-risk children and people experiencing homelessness. As part of its
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2020-2024 Strategic Plan, CPL set a number of goals to train staff to meet these expanding needs, with particular focus on accessibility, diversity and inclusion, and trauma-informed collective care. This audit would assess CPL's progress towards achieving these staff development-related goals.
Potential • Has CPL implemented the staff development portions of its 2020 strategic Objective: plan?
Department of Family & Support Services' (DFSS) Gender-Based Violence (GBV) and Human Trafficking Reduction
Background Survivors of GBV and human trafficking can face multiple barriers when
and interacting with government agencies and seeking services. The Citywide
Rationale: Strategic Plan aims to reduce these barriers and provide trauma-informed
Potential Objectives:
services to survivors through a whole of government approach. This audit will determine the extent to which these goals have been achieved and the role that the GBV Inter-agency Working Group played in the process.
• Has DFSS achieved the goals it committed to in the Citywide Strategic Plan to Address Gender-based Violence and Human Trafficking?
• Has the Mayor's Office ensured that the GBV Inter-agency Working Group implemented the Citywide Strategic Plan to Address Gender-based Violence and Human Trafficking?
Food Equity Council and Agenda
Background In recent years, the City has acknowledged the longstanding and growing need
and to address food insecurity across the city, particularly in historically
Rationale: disenfranchised communities on the South and West sides. In winter 2020, the Mayor's Office, the Greater Chicago Food Depository, and the Departments of Public Health (CDPH) and Family and Support Services (DFSS) collaborated to create the Food Equity Agenda, with the goal to "transform the food system by removing barriers to urban farming, supporting BIPOC food entrepreneurs, and better connecting residents with nutrition programs and healthy, affordable food." According to the City, the agenda is also a "key implementation step" of the mayor's anti-poverty strategy and citywide Healthy Chicago 2025 plan. This audit would determine whether the City achieved the goals of the Food Equity Agenda and related Food Equity Council.
Potential • Has the City achieved the goals it committed to in the Food Equity Agenda?
Objectives: • Has the Food Equity Council increased transparency, set policy, and published annual reports on their progress?
C| Finance and Administration 1. Prompt Payment
Background The City is generally required by contract to pay an invoice within 60 days,
and Preliminary data analysis suggests that some departments may be slow to
Rationale: submit payment approvals to the Department of Finance The City commissioned
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a disparity study for its Minority- and Women-owned Business Enterprise (MBEAA/BE) program in construction contracts, which found that slow payment is a particular barrier to these firms' ability to do business with the City. This audit will determine whether the City pays invoices within the required timeframe.
• Does the City pay invoices within the contractually required time period?
Contract Monitoring and Closeout Procedures
Background In 2015, the Procurement Reform Task Force identified a lack of compliance
and monitoring and robust closeout processes as serious risks for the City and its
Rationale: sister agencies. In 2020, DPD created procedures for monitoring and closeout, including a closeout checklist and site visit guidance. However, elected officials continue to raise concerns about timeliness of the closeout process and inconsistency of compliance monitoring among departments. This audit will determine whether the Department of Procurement Services' (DPS) contract compliance and closeout procedures are aligned with best practices and implemented consistently across departments.
Potential • Are DPS' contract compliance monitoring and closeout procedures aligned
Objectives: with best practices?
• Do City departments effectively and consistently use the contract compliance monitoring and closeout procedures DPS created?
City Council Office of Financial Analysis (COFA) Compliance with Municipal Code Reporting Requirements
Background COFA is required by the Municipal Code of Chicago (MCC) to provide City
and Council with independent annual and quarterly reports, including fiscal impact
Rationale: statements, budget options reports, and reviews of annual budget forecasts, as well as any ad hoc reports requested by aldermen. Recently, there have been complaints regarding the timeliness of the reports and media outlets have reported that sections of COFA documents may have been plagiarized. This audit will seek to determine if COFA fulfills its role by publishing accurate, timely reports to serve City Council.
Potential Objective:
Does COFA provide all reporting required by the MCC, including fiscal. impact statements, budget options reports, and a review of annual budget forecasts?
4. Earmarked Funds
Background Earmarked funds are monies set aside by City Council for special purposes such
and as homelessness prevention, the emergency telephone system, and public art.
Rationale: These funds are typically raised through City fees and surcharges, and in many
cases, MCC requires them to be kept separately from the City's general expense
fund ("the corporate fund").
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Potential Objectives:
During the course of a current audit, OIG discovered that an earmarked fund required by MCC does not exist within the City accounting system and that the earmarked money had been deposited into the corporate fund. Although OIG inquired, the Office of Budget and Management (OBM) did not confirm whether the fund had ever existed, raising procedural questions about how earmarked funds are created and whether they are used as intended by City Council. This audit will determine whether earmarked taxpayer dollars are collected and spent as intended.
What is the process to ensure that special funds required by the MCC are established?
Have the funds and separate accounts required to exist by the MCC been established and are they actively used?
What procedures ensure that the creation and use of special funds is transparent to the public?
5. Employee Assistance Program (EAP) Performance
Background Employee assistance programs are intended to support employees whose job
and performance is suffering due to issues such as mental health needs, substance
Potential Objectives:
Rationale: abuse, stress, or grief. The City of Chicago's EAP is a free resource for roughly 13,500 non-police and fire employees and their eligible family members that provides confidential assessments, counseling, and referral services. The City's EAP aims to "eliminate costly consequences of personal problems that may affect productivity and efficiency" and provide employees with "the opportunity to lead healthier, happier, and productive lives to the benefit of all." However, the City does not publish metrics on the program's effectiveness and the EAP was staffed by a sole clinician as of September 2022, raising questions about the program's utilization and accessibility. This audit would assess the design, performance, and legal compliance of the program.
Is the City's EAP designed and managed in alignment with best practices?
Does the City set goals for and monitor the effectiveness of its EAP?
Are EAP records kept in compliance with national, state, and local confidentiality laws?
D| Infrastructure
1. Information Security Office (ISO) Information Technology (IT) Project Review
Background The City's Information Security and Technology Policies (ISTP) require the ISO to
and review all IT projects to ensure that they meet minimum security controls before
Rationale: moving into production. The ISO is also responsible for periodically reviewing active information systems to ensure that they remain in compliance with the policies. Adherence to the ISTP is important to protect the confidentiality, integrity and availability ofthe City's information technology data and assets. This
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audit will determine whether the ISO reviews projects and ensures compliance as required.
Potential • Does ISO conduct readiness assessments on IT projects to ensure that the
Objectives: projects conform with the City's Information Security and Technology
policies?
Does ISO conduct periodic compliance assessments on active IT projects?
1, Chicago Department of Transportation (CDOT) Street Resurfacing and Maintenance
Background In a 2015 audit, OIG found that CDOT's pavement management program did not
and meet federal guidelines and lacked sufficient street condition data, relying
Rationale: 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 to determine whether improvements have been made to increase the efficiency and effectiveness ofthe program.
Potential • Does CDOT manage streets in a cost-effective way that extends pavement Objective: life?
Water Billing Accuracy
Background Several news stories have identified instances of the City overbilling residents for
and water usage, with some of the errors amounting to tens of thousands of dollars.
Potential Objectives:
Rationale: Residents reported difficulty in getting the issues resolved, often being charged penalties on the disputed amounts. This audit will determine whether the City responds appropriately to overbilling cases and also examine the City's management of water service disconnection for vacant properties.
• Does the City credit or refund metered accounts the correct amount following an overcharge?
Does the City effectively manage disconnecting water service for vacant properties?
DSS's Administration of Car Impound Lots
Background The City of Chicago tows and impounds vehicles that have created parking
and hazards, been abandoned, belong to drivers who owe debt to the City, or that
Rationale: have allegedly been used in a crime. The towing and impound process has been subject to complaints and negative press. Drivers have alleged that the pounds have misplaced cars, and the Department of Finance acknowledged that a WBEZ review found incorrectly calculated fines and fees due to computer and human errors as well as inaccurate inventories. This audit will examine how DSS and its contractor, United Road Towing, manage and administer the car impound lots under their control.
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Potential • Does DSS ensure that its impound lots correctly calculate impound, storage,
Objectives: and administrative fees and fines levied on drivers?
Does DSS ensure that its impound lots maintain accurate inventories of impounded vehicles?
Does DSS ensure that vehicles identified for disposal are eligible and that disposal reports are complete and accurate?
Does DSS ensure that the impound and recovery process is clear and navigable to residents?
5. DSS Rat Abatement
Background Rat infestations are a perennial health and quality-of-life concern in Chicago,
and which is considered one of America's 'rattiest' cities. OIG has received multiple
Rationale: complaints about the efficiency and effectiveness of the City's rat abatement
program. This project would determine whether BORC conducts abatement in a timely, effective, and equitable manner and in accordance with best practices.
Potential • Does DSS' Bureau of Rodent Control (BORC) meet its target rodent
Objectives: complaint response time of five days or fewer?
Does BORC deliver complaint-based and preventive abatement services in an effective and equitable manner?
Do BORCs complaint-based and preventive activities follow best practices in Integrated Pest Management?
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: 2023 Public Safety Draft Outlook for Public Comment.
1. Chicago Police Department (CPD) and Chicago Fire Department (CFD) Position Civilianization
Background and
Rationale:
Potential Objective:
Civilianization is the process where administrative positions held by sworn or uniformed officers are converted into positions that are held by non-sworn or non-uniformed individuals. Civilianization presents opportunities for cost savings and increased operational efficiencies. Past OIG reports identified missed opportunities to civilianize positions in the police and fire departments. This advisory will determine what progress each department has made and what barriers to civilianization may still exist.
• Have CPD and CFD maximized opportunities for civilianizing positions?
2. CFD Overtime Management
Background Despite budgeting $166 million for overtime between 2017 and 2021, CFD spent
and over $330 million on overtime across those five years. While some use of
Rationale: overtime is expected, excessive or inequitably distributed overtime may indicate
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suboptimal personnel management. This audit will evaluate CFD's overtime practices.
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?
3. Office of Emergency Management and Communications (OEMC) 311 Call Center Effectiveness
Background The 311 call center is an essential service for people to report service needs,
and check the status of previous service requests, obtain information regarding City
Rationale: programs or events, and file non-emergency police reports. In the City service delivery process, the 311 call center plays a key information triage role between residents and the relevant City departments. This audit will determine whether 311 is an effective means of collecting these requests and whether it provides enough information to other City departments to allow them to respond to the requests they receive.
Potential • Does 311 meet best practices for call center performance? Objectives: • Does 311 ensure that City departments get an appropriate amount of information to carry out service requests?
4. Life Safety Ordinance Enforcement
Background Following several deadly fires, a 2004 ordinance required hundreds of high-rise
and buildings built before 1975 to retrofit with automatic sprinkler systems or pass a
Rationale: Life Safety Evaluation (LSE). LSEs are scored tests conducted by architects or engineers to certify the adequacy of fire safety measures. Due to the expense of sprinkler retrofits, most pre-1975 high-rises opted for LSEs instead.
During a current audit, OIG determined that the City does not maintain a required public list of pre-1975 high-rise buildings that have passed LSEs, making it difficult to judge how many have mitigated their fire safety risks. This project will determine whether DOB and CFD maintain a public list of compliant buildings as required by MCC and ensure that covered high-rise buildings fulfill life safety requirements.
Potential • Do the Department of Buildings (DOB) and CFD ensure that relevant high-
Objectives: rise buildings have submitted and passed Life Safety Evaluations, and does
DOB maintain a public list of compliant buildings as required by MCC? • Do DOB and CFD ensure that buildings that maintain the features identified in life safety compliance plans after renovations or construction, and do they ensure compliance with life safety data reporting requirements?
Auclil and Program Re\ ieu Section Draft 2023 Annual Plan
City of Chicago Office of Inspector General
5. CFD Equipment Inventory
Background CFD uses specialized firefighting and emergency medical equipment that may
and require secure custody or be expensive to replace. OIG previously issued a
Rationale: property-control advisory (#19-006) about a large number of CFD badges reported stolen or missing prior to members' retirement, and audits in Sacramento, St. Louis, and Long Beach have found that fire departments did not meet best practices for the use, maintenance, and disposal of inventory. Although CFD General Order 93-006 requires a complete physical inventory of CFD's property every year, the nearly 30-year old Order gives responsibility for the inventory to two separate divisions that now appear to be combined into a liaison position within a different bureau.
This audit will determine whether CFD maintains an accurate count and control of its equipment and other property.
Potential • Does CFD have controls to ensure that it maintains a consistent and
Objectives: accurate inventory of equipment and property as required by CFD General
Order 93-006 and MCC § 2-36-230?
Audit and Program Ke\ ieu Section Draft 2023 Annual Plan
na City of Chicago Office of Inspector General
V I Reports Published in 2022
APR published the following 6 reports in 2022 (as of October 12, 2022). All are available at iqchicaqo.org .
A | City Development and Regulatory
Audit of the City's Compliance with the TIF Sunshine Ordinance and TIF Surplus Executive Order (#19-1047), published January 27, 2022
Audit of the Department of Buildings' Permit Inspections Process (#20-0831), published August 25, 2022
B| Community Services
1. Audit of the Department of Family and Support Services' Strategic Contracting (#20-1629), published August 9, 2022
C| Finance and Administration
1. Advisory Concerning the City of Chicago's Data Quality (#21-1035), published February 1, 2022
D| Infrastructure
1. Chicago Department of Transportation Traffic Signal Planning Audit Follow-Up (#21-2195), published March 9, 2022
E| Public Safety
1. Follow-Up to Audit of Policies and Practices Related to Discrimination and Sexual Harassment Within the Chicago Fire Department (#22-0209), published April 26, 2022
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City of Chicago Office of Inspector General
VI I Follow-Up Reports to Conduct in 2023
The following published reports will be evaluated for follow-up in 2023. 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 the City's Compliance with the Tax Increment Financing Sunshine Ordinance and Surplus Executive Order (published January 27, 2022)
Audit of City Council Committee and Employee Administration (published October 13, 2021)
Second OIG Audit of the Chicago Fire Department's Fire and Emergency Medical Response Times (published October 12, 2021)
Audit of the Public Building Commission's Administration of Building Commissioning (published September 23, 2021)
Audit of the Department of Buildings' Permit Inspections Process (published August 25, 2022)
Audit of the Department of Family and Support Services' Strategic Contracting (published August 9, 2022)
Chicago Department of Transportation Commercial Driveway Billing Audit (published July 1, 2019; first follow-up published April 21, 2020; second follow-up published August 5, 2021)
Audit of the Chicago Police Department and Department of Family and Support Services' Administration of the Juvenile Intervention and Support Center (published February 25, 2020; first follow-up published November 18, 2021)
Audit and Program Review Section Draft 12023 Annual Plan
City of Chicago Office of Inspector General
VII I Projects in Progress
The following 13 projects are underway as of October 12, 2022.
A | City Development and Regulatory
Audit of DOB and Department of Law's Prosecution and Resolution of Off-Premise Sign Permit Violations (#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.
Audit of the Department of Planning and Development's (DPD) Neighborhood Opportunity Fund Administration (#21-0395)
This audit evaluates DPD's administration of the Neighborhood Opportunity Fund to ensure consistent application of program rules, outcome monitoring, and performance measurement.
B| Community Services
1. Audit of the Chicago Department of Public Health (CDPH)
Construction and Demolition Debris Recycling (#20-1562)
This audit evaluates CDPH's enforcement of the ordinances requiring contractors to recycle certain amounts of debris from demolition and construction projects.
2. Audit of the Chicago Department of Family & Support Services (DFSS)
Homeless Encampment Outreach (#22-0078)
This audit evaluates whether DFSS coordinates and plans encampment cleanings and Accelerated Moving Events (AMEs) with partner agencies to help protect the rights of encampment residents. Further, the audit determines whether DFSS notifies encampment residents of encampment cleanings in accordance with City policy and that those who participate in AMEs receive housing, remain in housing for 12 months, and retain housing after the end of the program period.
C| Finance and Administration
1. Audit Regarding the Status of Workers' Compensation Improvements Recommended by Grant Thornton LLP (#22-0208)
This audit will determine whether the Department of Finance (DOF) has implemented corrective actions based on the recommendations made by Grant Thornton, LLP in its 2019 report on the workers' compensation program.
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City of Chicago Office of Inspector General
Advisory Concerning the City's Reliance on Complaints to Provide City Services (#02022-000043808)
This advisory summarizes OIG's past encounters with the City's reliance on complaints and suggests improvements to promote a balance between complaint-based and proactive service provision.
Follow-Up of the City's Capital Improvement Program Development and Evaluation Audit (#c2022-00004382i)
This follow-up will determine the status ofthe City's corrective actions regarding the 2020 audit of the City's Capital Improvement Program development and evaluation.
Follow-Up of the Department of Human Resources (DHR) Employee Performance Evaluation Audit (#02022-000044057)
This follow-up will determine the status of corrective actions proposed by DHR in response to the 2020 Employee Performance Evaluation audit.
Follow-Up of the Municipal Depository Designation Process Audit (#02022-000043978)
This follow-up will determine the status ofthe City's corrective actions regarding the 2021 audit of the Municipal Depository designation process.
Advisory Concerning the City's Interdepartmental Coordination (#02022-000044054)
This advisory summarizes OIG's past observations regarding interdepartmental coordination.
D| Infrastructure
Audit of Department of Water Management's (DWM) Sewer Cave-In Response (#22-0035)
This audit determines whether DWM addresses confirmed sewer cave-ins in a timely and equitable manner.
Follow-Up ofthe Department of Streets and Sanitation (DSS) Commercial and High-Density Residential Recycling Enforcement Audit (#02022-000043938)
This follow-up will determine the status of corrective actions regarding the 2020 audit of DSS's commercial and high-density residential recycling enforcement.
Audit and Program Review Section Draft 2023 Annual Plan
E| Public Safety
l. Audit ofthe Chicago Fire Department's (CFD) Fire Prevention Bureau's Inspection Processes (#02022-000043822)
This audit determines whether CFD's Fire Prevention Bureau completes required annual inspections of buildings, and required annual tests of sprinklers, standpipes and fire pumps. This audit also determines whether the Bureau notifies building owners of noncompliance, collects re-inspection fees, conducts follow-up inspections of known issues, and maintains complete and accurate records.
Audit and Program Review Section Draft 2023 Annual Plan
The City of Chicago Office of Inspector General 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's authority to produce reports of its findings and recommendations is established in the City of Chicago Municipal Code §§ 2-56-030(d), -035(c), -110, -230, and -240. For further information about this report, please contact the City of Chicago Office of Inspector General, 740 N. Sedgwick Ave., Suite 200, Chicago, IL 60654, or visit our website at iqchicaqo.org .
Suggest Ways to Improve City Government:
igchicago.org/contact-us/help-improve-citv-qovernment
Report Fraud, Waste, and Abuse in City Programs:
Call OIG's complaint hotline at (866) 448-4754 / TTY: (773) 478-2066 iqchicaqo.org/contact-us/report-fraud-waste-abuse/
Cover photo courtesy of Chicago Architecture Center Alternate formats available upon request.