Statutory Inspectors General in the Federal Government: A Primer

January 3, 2019 – November 13, 2023 R45450

Statutory Inspectors General in the Federal
November 13, 2023
Government: A Primer
Ben Wilhelm
This report provides an overview of statutory inspectors general (IGs) in the federal government,
Analyst in Government
including their structure, functions, and related issues for Congress.
Organization and
Management
Statutory IGs—established by law rather than administrative directive—are intended to be

independent, nonpartisan officials who aim to prevent and detect waste, fraud, and abuse in the
federal government. To execute their missions, IGs lead offices of inspector general (OIGs) that

conduct various reviews of agency programs and operations—including audits, investigations,
inspections, and evaluations—and provide findings and recommendations to improve them. IGs possess several authorities to
carry out their respective missions, such as the ability to independently hire staff, access relevant agency records and
information, and report findings and recommendations directly to Congress.
A total of 74 statutory IGs currently operate across the
federal government. Statutory IGs can be grouped into four
types: (1) establishment, (2) designated federal entity
(DFE), (3) other permanent, and (4) special. Establishment
(33 of 74) and DFE (31) IGs are governed by the Inspector
General Act of 1978, as amended, whereas other permanent
(7) and special (3) IGs are governed by separate statutes.
Statutory authorities and requirements can differ among the

four IG types, resulting in varied levels of independence, transparency, and accountability.
Statutory IGs are central actors on government oversight, and Congress plays a key role in establishing the structures and
authorities to enable that oversight. The structure and placement of IGs in government agencies allows OIG personnel to
develop the expertise necessary to conduct in-depth assessments of agency programs. Further, IGs’ dual reporting structure—
to agency heads and to Congress—positions them to advise agencies on how to improve their programs and policies and to
advise Congress on how to monitor and facilitate such improvement. Congress, therefore, may have an interest in ensuring
that statutory IGs possess the resources and authorities necessary to fulfill their oversight roles.
As the federal government continues to evolve, so too does the role of IGs in government oversight. Agency programs and
operations have increased in terms of breadth, complexity, and interconnectedness. Consequently, IGs may face increasing
demand to complete statutorily mandated reviews of programs and operations that require (1) a broader focus on program
performance and effectiveness in addition to waste, fraud, and abuse; (2) analysis of specialty or technical programs, possibly
in emerging policy areas; and (3) use of more complex analytical methods and tools. Congress may consider several options
regarding IG structures, functions, and coordination as the role of IGs in government oversight evolves.

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his report provides an overview of statutory inspectors general (IGs) in the federal
government, including their structure, functions, and related issues for Congress.
T
Report Roadmap
•
Establishment of Statutory IGs. History and evolution of the Inspector General Act of 1978.
•
Structure of the IG Community. Different types of IGs and their distribution across the government.
•
Types of IG Reviews. Differences among an IG audit, inspection or evaluation, and investigation.
•
IG Statutory Authorities and Requirements. Comparison of selected authorities and requirements across
different IG types.
•
Coordination and Oversight of Statutory IGs. Overview of the structure and functions of the Council of
Inspectors General on Integrity and Efficiency and other coordinating bodies.
•
Issues for Congress. High-level overview of broad issues facing statutory IGs.
Establishment of Statutory IGs
Statutory inspectors general (IGs) are intended to be independent, nonpartisan officials who
prevent and detect waste, fraud, abuse, and mismanagement within federal departments and
agencies. To execute their missions, IGs lead offices of inspector general (OIGs) that conduct
audits, investigations, and other evaluations of agency programs and operations and produce
recommendations to improve them. Statutory IGs exist in more than 70 federal entities, including
departments, agencies, boards, commissions, and government-sponsored enterprises.
Brief History of Statutory IGs Until 1978
The origins of the modern-day IGs can be traced to the late 1950s, with the statutory
establishment of an “IG and Comptroller” for the Department of State in 1959. Soon after, in
1962, the Kennedy Administration created an IG for the Department of Agriculture.1 Prior to the
establishment of IGs in the federal government, agencies often employed internal audit and
investigative units to combat waste, fraud, and abuse.2
In 1976, Congress established the first statutory IG that resembles the modern-day model for the
Department of Health, Education, and Welfare (HEW; now the Department of Health and Human
Services).3 Congressional investigations had uncovered widespread inefficiencies and
mismanagement of the department’s programs and operations, as well as weaknesses within the
department’s audit and investigative units.4 The House Committee on Government Operations
investigative report recommended, among other things, that the Secretary of HEW place all audit
and investigation units “under the direction of a single official who reports directly to the

1 Congress established the Department of State “Inspector General and Comptroller” in 1959 (P.L. 86-108), and the
Secretary of Agriculture administratively created an IG in 1962. These two IGs have been described as early prototypes
for modern-day IGs. For more information on the history of IGs, see Paul Light, Monitoring Government, Inspectors
General and the Search for Accountability (Washington, DC: Brookings Institution, 1993), pp. 23-43.
2 See, for example, U.S. Congress, House Committee on Government Operations, Subcommittee on Intergovernmental
Relations and Human Resources, Establishment of Offices of Inspectors General, hearings on H.R. 2819 and H.R.
4184, 95th Cong., 1st sess., May 17, 24; June 1, 7, 13, 21, 29; and July 25, 27 (Washington, DC: GPO, 1977), pp. 478-
728.
3 P.L. 94-505, §401(h).
4 See, for example, U.S. Congress, House Committee on Government Operations, Department of Health, Education,
and Welfare (Prevention and Detection of Fraud and Program Abuse), Tenth Report, 94th Congress, 2nd sess., January
26, 1976, H.Rept. 94-786 (Washington, DC: GPO, 1976).
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Statutory Inspectors General in the Federal Government: A Primer

Secretary and has no program operating responsibilities.”5 This official would be responsible for
identifying “serious problems” and “lack of progress in correcting such problems.”6 Congress
ultimately established the HEW IG under this model7 as well as an IG for the Department of
Energy under a similar model in 1977.8
Inspector General Act of 1978
The establishment of the HEW and Department of Energy IGs laid the groundwork for Congress
to create additional statutory IGs through the Inspector General Act of 1978 (hereinafter IG Act).9
According to the Senate Committee on Governmental Affairs report that accompanied the
legislation, the committee believed that extending the IG concept to more agencies would
improve government programs and operations. The committee further identified IG independence
from agency management as a key characteristic in fostering such improvements.10
Central Tenets of the IG Act
The IG Act initially created 12 IGs for federal “establishments” and provided a blueprint for IG
authorities and responsibilities.11 The act laid out three primary purposes for IGs:
1. conduct audits and investigations of programs and operations of their affiliated
federal entities;12
2. recommend policies that promote the efficiency, economy, and effectiveness of
agency programs and operations, as well as preventing and detecting waste,
fraud, and abuse; and
3. keep the affiliated entity head and Congress “fully and currently informed” of
fraud and “other serious problems, abuses, and deficiencies” in such programs
and operations, as well as progress in implementing related corrective actions.13
Evolution of the IG Act
Congress has substantially amended the IG Act three times since its enactment, as described
below.14 The amendments generally aimed to expand the number of statutory IGs and enhance
their independence, transparency, and accountability.

5 Ibid., p. 11.
6 Ibid.
7 U.S. Congress, House Committee on Government Operations, report to accompany H.R. 15390, 94th Congress, 2nd
sess., H.Rept. 94-1573 (Washington, DC: GPO, 1976).
8 P.L. 95-91, §208.
9 P.L. 95-452; The IG Act, as amended, is listed in 5 U.S.C. §§ 401 et seq. (IG Act), which is accessible at
https://uscode.house.gov/view.xhtml?path=/prelim@title5/part1/chapter4&edition=prelim.
10 U.S. Congress, Senate Committee on Governmental Affairs, report to accompany H.R. 8588, 95th Congress, 2nd sess.,
August 8, 1978, S.Rept. 95-1071 (Washington, DC: GPO, 1978), pp. 6-8.
11 Federal “establishments” consist of Cabinet-level departments and larger agencies in the executive branch.
Establishment IGs are appointed by the President by and with the advice and consent of the Senate.
12 Affiliated federal entity refers to an entity within the scope of an IG’s jurisdiction. For example, the Department of
Homeland Security and its components are considered an “affiliated federal entity” of the department’s IG.
13 5 U.S.C. §402.
14 In addition, the Homeland Security Act of 2002 vested certain OIGs with law enforcement authorities, including the
power to (1) carry a firearm; (2) make arrests without a warrant; and (3) seek and execute warrants for arrest, search of
premises, or seizure of evidence. See P.L. 107-296, §812; listed in 5 U.S.C. §406(f).
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• The Inspector General Act Amendments of 1988 (P.L. 100-504) expanded the
total number of statutory IGs, particularly by authorizing additional
establishment IGs and creating a new category of IGs for “designated federal
entities” (DFEs).15 The act also established a uniform salary rate and separate
appropriations accounts for each establishment IG. Further, the act added several
new semiannual reporting requirements for IGs, such as a requirement for IGs to
provide a list of each audit report issued during the reporting period. Finally, the
law required external peer reviews of OIGs, during which a federal “audit entity”
reviews each OIG’s internal controls and compliance with audit standards.
• The Inspector General Reform Act of 2008 (P.L. 110-409) established a new
Council of Inspectors General on Integrity and Efficiency (CIGIE) to coordinate
and oversee the IG community, including an Integrity Committee to investigate
alleged IG wrongdoing. The law increased the uniform salary rate for
establishment IGs and established a salary formula for DFE IGs. The act also
provided additional authorities and protections to enhance the independence of
IGs, such as budget protections, access to independent legal counsel, and
advanced congressional notification for the removal or transfer of IGs. Finally,
the act further amended IG semiannual reporting obligations and required OIG
websites to include all completed audits and reports.
• The Inspector General Empowerment Act of 2016 (P.L. 114-317) aimed to
enhance IG access to and use of agency records. The act exempted IGs from the
Computer Matching and Privacy Protection Act (CMPPA),16 which is intended to
allow IGs to conduct computerized data comparisons across different agency
automated record systems without the restrictions created by the CMPPA.17 The
act also directed CIGIE to resolve jurisdictional disputes between IGs and altered
the membership structure and investigatory procedures of the CIGIE Integrity
Committee. Regarding transparency and accountability, the act required IGs to
submit any documents containing recommendations for corrective action to
agency heads and congressional committees of jurisdiction, as well as any
Member of Congress or other individuals upon request.
• The Securing Inspector General Independence Act of 2022 and the Integrity
Committee Transparency Act of 2022 (Title LII of P.L. 117-263, the FY2023
National Defense Authorization Act) sought to increase the independence of the
IG community by placing new limits on the removal of IGs, the management of
vacancies, and the selection of acting IGs. The act increased the information that
the President and heads of DFEs must provide to Congress prior to removal of an
IG. The amendments also limited the circumstances in which an IG may be
placed on non-duty status. When a vacancy in an IG position does occur, the act
limited those who may serve as an acting IG to certain officials within the IG
community and also required the President to report to Congress if there are
extended periods in which an IG position is vacant and without a nominee. The
act also increased the IG community’s transparency to Congress by altering the
requirements for semi-annual reports and enhancing reporting by CIGIE’s
Integrity Committee.

15 DFEs consist primarily of smaller entities, such as commissions, boards, and government-sponsored enterprises (e.g.,
National Science Foundation and Legal Services Corporation). DFE IGs are appointed by the affiliated entity heads.
16 The CMPPA is codified at 5 U.S.C. §552a.
17 See 5 U.S.C. §406(j).
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Structure of the IG Community
Types of IGs
Statutory IGs may be grouped into four types: (1) establishment, (2) designated federal entity
(DFE), (3) other permanent, and (4) special.18 Federal laws explicitly define only the first two
types of IGs but not the latter two types, though stakeholders sometimes divide IGs into these
four types. Consequently, this report groups IGs into the four types based on criteria that are
commonly used to distinguish between IGs, including authorizing statute, appointment method,
affiliated federal entity and the branch of government in which it is located, oversight jurisdiction,
and oversight duration. Table 1 describes each IG type according to these criteria.
Table 1. Distinguishing Characteristics of Statutory IG Types
Other
Feature
Establishment IG
DFE IG
Permanent IG
Special IG
Authorizing
IG Act
Individual statutes outside of the IG Act
statute
Appointment
President, by and
Agency head
President, by and
President, by and
method
with the advice and
with the advice and
with the advice and
consent of the
consent of Senate
consent of Senate
Senate
or
or
agency head
President alone
Affiliated federal Cabinet
Smaller entities (e.g.,
Certain legislative
Some affiliated with
entity
departments,
boards, commissions,
branch agencies
specified federal
Cabinet-level
and government-
Certain intelligence
entities; others not
agencies, and larger
sponsored enterprises)
agencies outside of
expressly affiliated
agencies in the
Certain intelligence
DOD
with a particular
executive branch
agencies within DOD
entity
Oversight
Authority to oversee the programs and
Authority to
jurisdiction
operations of an affiliated entity or entities
oversee federal
programs,
operations, or funds
as specified in
authorizing statute
Oversight
Permanent (no sunset date)
Temporary (allowed
duration
to sunset)
Source: CRS analysis of the Inspector General Act of 1978, as amended, and authorizing statutes for other IGs.
Notes: IGs can be grouped into types other than those listed based on a different set of criteria.

18 The types do not include IGs for certain U.S. Armed Forces—the Army, Air Force, and Navy. (The Department of
Homeland Security IG oversees the U.S. Coast Guard.) While these service branch IGs are required by statute, they are
distinct from IGs under the IG Act and related provisions and are not generally considered among the “statutory
inspectors general,” including in this report. Further, the categories do not include nonstatutory IGs. For example, the
House of Representatives IG is authorized pursuant to House Rule II, clause 8. See CRS In Focus IF11024, Office of
the House of Representatives Inspector General, by Jacob R. Straus.
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Statutory Inspectors General in the Federal Government: A Primer

Composition of Statutory IGs
As of February 2023, 74 statutory IGs operate in the federal government.19 The IG Act governs
64 IGs, including 33 establishment and 31 DFE IGs. The remaining 10 IGs are governed by
individual statutes outside the IG Act, including seven other permanent and three special IGs
(Figure 1). Five out of seven other permanent IGs operate for legislative branch agencies—the
Architect of the Capitol (AOC), Government Publishing Office (GPO), Government
Accountability Office (GAO), Library of Congress (LOC), and U.S. Capitol Police (USCP). The
remaining two operate for executive branch intelligence agencies—the Central Intelligence
Agency (CIA) and Intelligence Community (IC). The three special IGs are the IGs for
Afghanistan Reconstruction (SIGAR), the Troubled Asset Relief Program (SIGTARP), and
Pandemic Recovery (SIGPR).20 Appendix A lists current statutory IGs by type.
Figure 1. Statutory IGs by Type and Authorizing Statute
As of November 2023

Source: CRS analysis of the Inspector General Act of 1978, as amended, and authorizing statutes for other IGs.
Notes: The figure does not include IGs for certain U.S. Armed Forces—the Air Force, Army, and Navy. (The
Department of Homeland Security IG, which is included in the figure, oversees the U.S. Coast Guard.) While
these IGs exist in statute, their structure and authorities differ significantly from other statutory IGs and are
beyond the scope of this report. Further, the figure does not include nonstatutory IGs, such as the IG for the
House of Representatives.
Distribution of IGs Across Federal Entities
The majority of IGs oversee the activities of a single affiliated federal entity and its components.
For example, the IG for the Department of Homeland Security (DHS) is responsible for
evaluating programs and operations of the entire department and its components, such as the
Federal Emergency Management Agency. In some cases, however, multiple IGs operate for a
single entity. In other cases, one IG operates for multiple entities.
Multiple IGs Operating for a Single Federal Entity
Two Cabinet-level departments are affiliated with more than one IG: the Department of Defense
(DOD) and the Department of the Treasury. Both departments have a department-wide IG and
one or more separate IGs for certain components or programs (Table 2).

19 This number does not reflect statutory IGs that have been abolished.
20 SIGTARP (P.L. 110-343, §121) is listed in 12 U.S.C. §5231, SIGAR (P.L. 110-181, §1229) is listed in 5 U.S.C.
§415 note, and SIGPR (P.L. 116-136, §4018) is listed in 15 U.S.C. §9053.
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Table 2. Multiple Statutory IGs Affiliated with a Single Federal Entity
Department of Defense (DOD) IGs
Department of the Treasury (DOT) IGs
DOD (department-wide)
DOT (department-wide)
Defense Intelligence Agency
Treasury Inspector General for Tax Administration
National Geospatial Intelligence Agency
(Internal Revenue Service)
National Security Agency
Special Inspector General for Pandemic Recovery
(certain CARES Act programs)
National Reconnaissance Office
Source: CRS analysis of the Inspector General Act of 1978 and other statutes governing the listed IGs.
Notes: The table does not include IGs for U.S. Armed Forces within the DOD—the Air Force, Army, and
Navy. While these military IGs exist in statute, their structure and authorities differ significantly from other
statutory IGs and are beyond the scope of this report. In addition, the table does not include the Special
Inspector General for Afghanistan Reconstruction (SIGAR) or the Special Inspector General for the Troubled
Asset Relief Program (SIGTARP). Although SIGAR and SIGTARP might evaluate, respectively, DOD and DOT
programs, they are not housed in or affiliated with the departments. While the Special Inspector General for
Pandemic Recovery (SIGPR) is similar in authority and function to SIGAR and SIGTARP, it is organized within
DOT under 15 U.S.C. §9053(a).
Single IG Operating for Multiple Federal Entities
Congress has authorized some IGs to oversee the programs, operations, and activities of more
than one entity either on a permanent or temporary basis. The expansion of an IG’s jurisdiction to
include multiple entities has generally stemmed from agency reorganizations or congressional
concern regarding oversight of a particular agency or program.21
Table 3 provides examples of IGs who have permanent expanded jurisdiction. In the past,
Congress has also temporarily expanded IG jurisdiction to include operations of unaffiliated
agencies. For example, Congress directed the GAO IG to serve concurrently as the IG for the
Commission on Civil Rights for FY2012 and FY2013.22 The Consolidated Appropriations Act,
2014, authorized the DOT IG to oversee the Metropolitan Washington Airports Authority
(MWAA), a nonfederal entity.23

21 A recent example of legislation that established such an arrangement is the Postal Service Reform Act of 2022 (P.L.
117-108; H.R. 3076), which abolished the OIG for the Postal Regulatory Commission and reorganized its functions
into the existing OIG for the United States Postal Service. See CRS Insight IN11685, Changes to Postal Regulatory
Commission Administration in the Postal Service Reform Act of 2022, by Ben Wilhelm.
22 P.L. 112-55, Division B, Title IV, 125 Stat. 628; P.L. 113-6, Division B, Title IV, 128 Stat. 266; GAO, OIG,
Semiannual Report, April 1, 2014-September 30, 2014, October 2014, p. 5, https://www.gao.gov/assets/670/
667257.pdf.
23 P.L. 113-76, Division L, Title I; 128 Stat. 600. It is unclear whether the IG has overseen MWAA beyond FY2015.
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Table 3. Examples of a Single Statutory IG Affiliated with Multiple Federal Entities
Office of
Inspector
Affiliated federal
Authorizing statute
General
entities
Description
and U.S. Code citation
Intelligence
IC elements (defined
The IC IG is explicitly authorized to
P.L. 111-259, §405
Community
in 50 U.S.C. §3003)
oversee the programs and activities under
Codified in 50 U.S.C.
(IC)
the purview of the Director of National
§3033
Intelligence (DNI), who serves as the head
of the IC. The IC IG replaced the now-
defunct IG for the Office of the DNI,
whose jurisdiction was limited to this
office and who had substantially less
authority and independence (P.L. 108-458,
§1078).
Board of
(1) FRB
The FRB IG is explicitly authorized to
P.L. 111-203, §§1011 and
Governors of
(2) Consumer
oversee the CFPB, which resulted from
1081
the Federal
Financial Protection
CFPB’s establishment as a new
Listed in 5 U.S.C.
Reserve
Bureau (CFPB)
“independent bureau” within the Federal
§415(a)(2).
System (FRB)
Reserve System in 2010 under the Dodd-
Frank Wall Street Reform and Consumer
Protection Act.
Department of (1) DOT
The DOT IG is expressly authorized to
P.L. 106-424, §12
Transportation (2) National
oversee the “financial management,
Codified in 49 U.S.C.
(DOT)
Transportation Safety
property management, and business
§1137
Board (NTSB)
operations” of the NTSB. Congress
expanded the IG’s jurisdiction to cover
the NTSB in 2000 due to perceived lack
of oversight of the board.
Department of (1) DOS
The DOS IG’s jurisdiction was expanded
P.L. 105-277, Division G,
State (DOS)
(2) Broadcasting
to include BBG upon the agency’s
Title XIII, Chapter 3,
Board of Governors
removal from the DOS and establishment
§1322
(BBG)
as an independent agency in 1998 under
Listed in 22 U.S.C.
the Foreign Affairs and Restructuring Act. §6209a
U.S. Aid for
(1) USAID
The USAID IG has explicit authority to
P.L. 87-195, §239(e)
International
(2) Overseas Private
“conduct reviews, investigations, and
Listed in 22 U.S.C.
Development
Investment
inspections of all phases of the
§2199(e)
(USAID)
Corporation
Corporation’s activities and activities.”
U.S. Postal
(1) USPS
Under the Postal Service Reform Act of
P.L. 117-108, §209(a)
Service (USPS)
(2) Postal Regulatory
2022, the USPS IG “shall function as the
39 U.S.C. §202(e)
Commission
Inspector General for the Postal
Regulatory Commission.”
Source: CRS analysis of statutes authorizing or expanding the oversight jurisdiction of each listed IG.
Types of IG Reviews
IGs conduct reviews of government programs and operations. The genesis and frequency of such
reviews can vary. An IG generally conducts a review in response to a statutory mandate, at the
request of Congress or other stakeholders (e.g., the President), or upon self-initiation. Reviews
can occur once or periodically. IG reviews can be grouped into three broad categories: (1)
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performance audits,24 (2) inspections or evaluations, and (3) investigations.25 Table 4 and the
sections below discuss certain differences between the review types in terms of three
characteristics: quality standards, scope of analysis, and type of analysis.
Table 4. Key Differences Among Common Types of IG Reviews
Characteristic
Performance Audita
Inspection or Evaluation
Investigation
Quality
Generally Accepted
Quality Standards for Inspection
Quality Standards for
standards
Government Auditing
and Evaluation (also known as
Investigationsc,e
Standards (GAGAS, also
the Blue Book)c,d
known as the Yellow Book)b,c
Type of analysis
Programmatic (compliance, efficiency and effectiveness,
Nonprogrammatic (individual
internal control, prospective analysis)f
misconduct)
Scope of
Entire agency program or
Specific aspect of a program
Actions of a government
analysis
operation
or operation or a specific
employee, contractor, or
agency facility
grantee
Source: CRS analysis of laws, regulations, and administrative directives governing statutory IGs.
Notes: The table does not reflect all differences among audits, inspections or evaluations, and investigations. In
addition, differences in the “scope of analysis” between a performance audit and inspection or evaluation vary
and depend on the issue being evaluated. In some cases, the scope of analysis might be similar.
a. In addition to performance audits, IGs must conduct, or hire an independent external auditor to conduct,
audits of agency financial statements (commonly referred to as a financial audit). See 31 U.S.C. §3521(e).
Financial audits are beyond the scope of this report.
b. The U.S. Government Accountability Office (GAO) issues a publication containing the GAGAS, which is
accessible at https://www.gao.gov/yellowbook/overview.
c. The Council of Inspectors General on Integrity and Efficiency (CIGIE) issues Quality Standards for Federal
Offices of Inspectors General, known as the Silver Book, which apply to all IG reviews. The standards are
accessible at https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf.
d. These CIGIE-issued standards are accessible at https://www.ignet.gov/sites/default/files/files/
QualityStandardsforInspectionandEvaluation-2020.pdf.
e. These CIGIE-issued standards are accessible at https://www.ignet.gov/sites/default/files/files/
invprg1211appi.pdf. Criminal investigations conducted by OIGs with statutory law enforcement authority
are also governed by guidelines established by the Attorney General. See U.S. Department of Justice,
Guidelines for OIGs With Statutory Law Enforcement Authority, December 2003, https://www.ignet.gov/sites/
default/files/files/agleguidelines.pdf.
f.
GAO’s Yellow Book identifies and defines four categories of performance audit objectives: (1) program
effectiveness and results, (2) internal control, (3) compliance, and (4) prospective analysis. See GAO,
Government Auditing Standards, 2018 Revision, GAO-18-568G, pp. 10-14, https://www.gao.gov/assets/700/
693136.pdf.
Quality Standards
IG reviews are governed by different quality standards. IG audits are subject to the generally
accepted government auditing standards (GAGAS) developed by GAO.26 Inspections or
evaluations and investigations, by contrast, are governed by separate standards developed by the

24 OIG audits can be divided into two subcategories: performance and financial. Financial audits are beyond the scope
of this report.
25 OIG investigations can be divided into two subcategories: criminal and administrative. IGs also perform other types
of reviews outside of these three categories. For example, the U.S. Postal Service IG periodically issues white papers
on certain topics, which are accessible at https://www.uspsoig.gov/document-type/white-papers.
26 See GAO, “The Yellow Book,” at https://www.gao.gov/yellowbook/overview.
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CIGIE.27 While several standards are identical or similar across the three review types, the
requirements to meet those standards differ by type. For example, one GAO report noted that IG
audits are “subject to more depth in the requirements for levels of evidence and documentation
supporting findings” than IG inspections.28
IG Audits vs. Inspections or Evaluations:
Examples of Differences in the Quality Control Standard
Both IG audits and inspections or evaluations must adhere to a “quality control” standard, but the requirements
to meet the standard differ between the two types of reviews.
IG audit: GAO’s Yellow Book requires an audit organization to, among other things (1) monitor the quality of
audits and summarize the results of the monitoring process annually; and (2) identify a supervisor to manage an
audit and fulfil specific responsibilities, such as tracking the progress of the audit and reviewing work performed
by the audit team to ensure compliance with GAGAS.29
IG inspection or evaluation: CIGIE’s Blue Book does not require annual reports on quality monitoring.30
Further, the supervisory requirements for an inspection call only for “adequate supervision” that ensures that all
inspection team members understand the purpose and goals of the inspection.
Type of Analysis
IG audits and inspections or evaluations include programmatic analysis, which may involve
analyses related to the compliance, internal control, or efficiency and effectiveness of agency
programs and operations.31 They also often include recommendations to improve such programs
and operations. IG investigations, by contrast, typically include nonprogrammatic analysis and
instead focus primarily on alleged misuse or mismanagement of an agency’s programs,
operations, or resources by an individual government employee, contractor, or grantee. Unlike
audits and inspections or evaluations, IG investigations can directly result in disciplinary actions
that are criminal (e.g., indictments and prosecutions) or administrative (e.g., monetary payments,
suspension/debarment, or termination of employment).
Scope of Analysis
Performance audits may be broader in scope compared to inspections or evaluations and
investigations. A performance audit may assess the agency-wide implementation of a program
across multiple agency components and facilities. An inspection or evaluation, by contrast, may
sometimes focus on a specific aspect of a program or the operations of a particular agency facility
or geographic region containing agency facilities. Investigations typically focus on the actions of
a specific agency employee, grantee, or contractor for alleged misconduct or wrongdoing.

27 CIGIE’s Quality Standards for Inspection and Evaluation are outlined in the Blue Book and are accessible at
https://www.ignet.gov/sites/default/files/files/QualityStandardsforInspectionandEvaluation-2020.pdf. CIGIE’s Quality
Standards for Investigations are accessible at https://www.ignet.gov/sites/default/files/files/invprg1211appi.pdf.
28 GAO, Inspectors General, Activities of the Department of State Office of the Inspector General, GAO-07-138, March
2007, p. 19, at https://www.gao.gov/assets/260/258069.pdf.
29 GAO, Government Auditing Standards 2018 Revision, July 2018, GAO-18-568G, pp. 89-91, at https://www.gao.gov/
assets/files.gao.gov/assets/gao-18-568g.pdf.
30 CIGIE, Quality Standards for Inspection and Evaluation, January 2012, p. 8.
31 GAO’s Yellow Book identifies and defines four categories of performance audit objectives: (1) program effectiveness
and results, (2) internal control, (3) compliance, and (4) prospective analysis. The Yellow Book further states that these
objectives can be pursued simultaneously within a single audit. See GAO, Government Auditing Standards, 2018
Revision, GAO-18-568G, pp. 10-14, at https://www.gao.gov/assets/files.gao.gov/assets/gao-18-568g.pdf.
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Example of Differences in Units of Analysis Among an IG Performance Audit,
Inspection or Evaluation, and Investigation
The Department of Veterans Affairs (VA) IG conducted several reviews of veteran wait times and access to care
that varied in scope and analysis, such as
•
an audit of veteran wait times and timely access to care at multiple VA medical facilities across one Veterans
Integrated Service Network (VISN);32
•
an inspection of veteran access to care and quality of care—including wait times—at one VA medical facility
within a specific VISN;33 and
•
an investigation of employees at one VA medical facility within a specific VISN for allegedly manipulating wait
times to meet scheduling appointment goals.34
IG Statutory Authorities and Requirements
IGs possess many authorities and responsibilities to carry out their respective missions, many of
which aim to establish and protect IG independence from undue influence. For example, the IG
Act grants covered IGs broad authority to
• conduct audits and investigations, which cannot be prohibited or prevented by the
affiliated entity head (except, in some cases, for national security reasons);
• access directly the records and information related to the affiliated entity’s
programs and operations;
• request assistance from other federal, state, and local government agencies;
• subpoena information and documents;
• administer oaths when conducting interviews;
• independently hire staff and manage their own resources; and
• receive and respond to complaints of waste, fraud, and abuse from agency
employees, whose identity is to be protected.35
The subsections below and Appendix B compare selected statutory authorities and requirements
by IG type: establishment, DFE, other permanent, and special. However, the manner in which
each IG interprets and implements these authorities and responsibilities can vary widely, thus
potentially resulting in substantially different structures, operations, and activities across IGs.
The discussion in this section focuses on IG authorities and requirements that are expressly
mandated in the applicable authorizing statute.36 Although special IGs and other permanent IGs in
the legislative branch are not created under the IG Act, their authorizing statutes incorporate—and
therefore make applicable—certain provisions of the IG Act. These “incorporation by reference”

32 VA OIG, Veterans Health Administration, Audit of Veteran Wait Time Data, Choice Access, and Consult
Management in VISN 6, March 2, 2017, at https://www.va.gov/oig/pubs/vaoig-16-02618-424.pdf.
33 VA OIG, Healthcare Inspection, Scheduling, Staffing, and Quality of Care Concerns at the Alaska VA Healthcare
System, Anchorage, Alaska, July 7, 2015, at https://www.va.gov/oig/pubs/VAOIG-14-04077-405.pdf.
34 VA OIG, Administrative Summary of Investigation by the VA Office of the Inspector General in Response to
Allegations Regarding Patient Wait Times, VA Medical Center in Salisbury, North Carolina, October 4, 2016, at
https://www.va.gov/oig/pubs/admin-reports/wait-times-14-02890-255.pdf.
35 5 U.S.C. §§403(a), 406(a), 406(e), and 407. Authorities and requirements may differ for IGs not explicitly covered
by the IG Act. For more information on selected IG authorities and requirements, see Appendix B.
36 Where possible, the subsections provide examples of instances in which IGs have elected to comply with a
nonmandatory provision.
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provisions are subject to some interpretation. Even when the authorizing statute for a special IG
or other permanent IG in the legislative branch clearly and unequivocally incorporates a specific
provision of the IG Act, interpretation may vary regarding whether subsequent amendments to
that incorporated provision apply to the IGs if they occurred after the enactment of the IG’s
authorizing statute.37
Oversight Jurisdiction
As mentioned previously, establishment, DFE, and other permanent IGs generally do not have
cross-agency jurisdiction and therefore evaluate only the programs, operations, and activities of
their respective affiliated agencies. For example, the DHS IG must annually evaluate the
department’s information security programs and practices, but it does not evaluate such programs
and practices for another department.38 Oversight jurisdiction, however, can extend to nonfederal
third parties, such as contractors and grantees. For example, the IG for the National Archives and
Records Administration audited the agency’s management of grant fund use by certain grantees.39
Some special IGs, by comparison, possess express cross-agency jurisdiction. They are authorized
to evaluate a specific program, operation, or activity irrespective of the agencies implementing
them. For instance, SIGAR oversees all federal funding for programs and operations related to
Afghanistan reconstruction, which involves multiple agencies. SIGAR, therefore, may examine
government-wide efforts to train, advise, and assist the Afghan National Defense and Security
Forces.40 The DOD IG, by contrast, may examine only reconstruction activities under DOD’s
purview, such as the military’s efforts to train, advise, and assist the Afghan Air Force.41

37 Although an argument can be made that the incorporation by reference includes subsequent amendments to the
referenced statute, it would also appear that traditional canons of statutory interpretation may suggest that the proper
construction of the authorizing statutes is that they incorporate only the text of the referenced provisions as they existed
at the time the applicable authorizing statute was adopted. See Hassett v. Welch, 303 U.S. 303, 314 (1938), wherein the
court stated, “Where one statute adopts the particular provisions of another by a specific and descriptive reference to
the statute or provisions adopted, the effect is the same as though the statute or provisions adopted had been
incorporated bodily into the adopting statute…. Such adoption takes the statute as it exists at the time of adoption and
does not include subsequent additions or modifications of the statute so taken unless it does so by express intent.” Legal
interpretation of the treatment of provisions incorporated by reference are beyond the scope of this report.
38 This assessment is required by the Federal Information Security Modernization Act. See 44 U.S.C. §3555.
39 National Archives and Records Administration OIG, Audit of NARA’s Oversight of Selected Grantees’ Use of Grant
Funds, February 16, 2011, at https://www.archives.gov/files/oig/pdf/2011/audit-report-11-03.pdf.
40 See, for example, SIGAR, Reconstructing the Afghan National Defense and Security Forces: Lessons Learned from
the U.S. Experience in Afghanistan, September 2017, at https://www.sigar.mil/pdf/lessonslearned/SIGAR-17-62-
LL.pdf.
41 DOD OIG, Progress of U.S. and Coalition Efforts to Train, Advise, and Assist the Afghan Air Force, January 4,
2018, at https://media.defense.gov/2018/Jan/29/2001870851/-1/-1/1/DODIG-2018-058-REDACTED.PDF.
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SIGPR and Pandemic Oversight
In March 2020, Congress passed the Coronavirus Aid, Recovery, and Economic Security (CARES) Act,42 which
provided funding to a number of federal agencies and programs in response to the pressures created by the
COVID-19 pandemic. The CARES Act also established a variety of oversight mechanisms to monitor how these
funds were used. This included the creation of the Special Inspector General for Pandemic Recovery (SIGPR) to
provide oversight of Department of the Treasury (DOT) programs included in Title IV of the CARES Act.43
Unlike the other two special IGs (the SIGAR and SIGTARP), SIGPR’s jurisdiction is limited to certain activities of
the DOT under the CARES Act and does not extend to other agencies. In addition, there has been disagreement
within DOT regarding the extent of SIGPR’s jurisdiction. SIGPR has argued that its jurisdiction extends to all DOT
programs under the CARES Act, while other DOT officials have argued that its jurisdiction is limited to Title IV
programs. In April 2021, the Department of Justice’s Office of Legal Counsel issued an opinion concluding that the
SIGPR’s jurisdiction was limited to CARES Act Title IV programs.44 SIGPR has asked Congress to consider
expanding its jurisdiction.45
Appointment Method
Most statutory IGs (71 of 74) must be appointed “without regard to political affiliation” and “on
the basis of integrity and demonstrated ability in accounting, auditing, financial analysis, law,
management analysis, public administration, or investigations.”46 The appointment qualifications
for the three special IGs do not include this “without regard to political affiliation” language, but
they do include the other language regarding integrity and technical expertise.47 Statutory IGs are
appointed under one of three different methods:
1. by the President, by and with the advice and consent of the Senate;
2. by the President alone; or
3. by the head of the affiliated federal entity.
As shown in Table 5, a total of 38 out of 74 statutory IGs are appointed by the President, 37 of
which—establishment IGs (33), other permanent IGs in the executive branch (2), the SIGTARP,
and SIGPR—require Senate confirmation. SIGAR is the only statutory IG appointed by the
President alone without Senate confirmation. In addition, 36 out of 74 IGs are appointed by the
heads of their affiliated federal entities: designated federal entity (DFE) (31) and other permanent
IGs in the legislative branch (5). Unlike other IGs, the U.S. Capitol Police and Architect of the

42 P.L. 116-136.
43 CARES Act §4018(c)(1); 15 U.S.C. §9053(c)(1).
44 See “Authority of the Special Inspector General for Pandemic Recovery to Oversee Programs Established Under the
CARES Act,” Memorandum Opinion for the Acting General Counsel Department of the Treasury, and the Special
Inspector General for Pandemic Recovery, April 29, 2021, at https://www.justice.gov/olc/file/1390936/download.
45 See, for example, Special Inspector General for Pandemic Recovery, Quarterly Report to the United States
Congress: April to June 2021, July 30, 2021, p. 20, at https://www.sigpr.gov/sites/sigpr/files/2021-07/SIGPR-
Quarterly-Report-June-2021-Final.pdf.
46 5 U.S.C. §403(a) and §415(c) (establishment and DFE IGs); 2 U.S.C. §1808(c)(1)(a) (AOC IG); 2 U.S.C.
§1909(b)(1) (USCP IG); 2 U.S.C. §185(c)(1)(a) (LOC IG); 41 U.S.C. §3902(a) (GPO IG); 31 U.S.C. §705(b)(1) (GAO
IG). The CIA IG must also be selected “on the basis of compliance with security standards of [the CIA] and prior
experience in the field of foreign intelligence” (50 U.S.C. §3517(b)(1)).
47 It may be the case that the variation in qualification requirements for the special IGs might lead to the nomination of
individuals who were selected by the President in part due to their partisan backgrounds. If Congress is concerned
about potential partisanship from a nominee, the Senate could vet that concern during the confirmation process.
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Capitol IGs must be appointed by their affiliated entity heads in consultation with other
permanent IGs in the legislative branch.48
Table 5. Appointment Methods for Statutory IGs
President Nominates,
Agency or Entity
President
Authorizing Statutes
Senate Confirms
Head Appoints
Appoints
Total
Inspector General Act of
33a
31b
0
64
1978, as amended
Other statutes
4c
5d
1e
10
Total
37
36
1
74
Source: CRS analysis of authorizing statutes for the listed IGs. The table does not include statutory IGs that
have been abolished.
a. Includes all establishment IGs. See 5 U.S.C. §§403 and 401(1).
b. Includes all DFE IGs. See 5 U.S.C. Appendix (IG Act), §415(c).
c. Includes the IGs for the Central Intelligence Agency, the Intelligence Community, and the Special IG for the
Troubled Asset Relief Program, and the Special Inspector General for Pandemic Recovery. See, respectively,
50 U.S.C. §3517(b)(1), 50 U.S.C. §3033(c)(1), 12 U.S.C. §5231(b)(1), and 15 U.S.C. §9053(b)(1).
d. Includes the IGs for the Architect of the Capitol, Government Accountability Office, Government
Publishing Office, Library of Congress, and the U.S. Capitol Police. See, respectively, 2 U.S.C.
§1808(c)(1)(A), 31 U.S.C. §705(b)(1), 44 U.S.C. §3902(a), 2 U.S.C. §185(c)(1)(A), and 2 U.S.C. §1909(b)(1).
e. Includes the Special IG for Afghanistan Reconstruction. See 5 U.S.C. §415 note.
Removal Method
IGs can be removed or transferred to another position under one of two different methods: (1) by
the President, or (2) by the head of the affiliated federal entity. Establishment, special, and other
permanent IGs in the executive branch are removable or transferrable by the President.49 In
contrast, DFE IGs and other permanent IGs in the legislative branch are removable or
transferrable by the heads of their affiliated entities.50 Additional procedures are required to
remove or transfer certain IGs as follows:
• DFE IG headed by a board, committee, or commission. Removal or transfer
upon written concurrence of a two-thirds majority of the members of the board,
committee, or commission.51
• U.S. Postal Service (USPS) IG. Removal upon written concurrence of at least
seven out of nine postal governors and only “for cause” (e.g., malfeasance or
neglect of duty).52

48 2 U.S.C. §1808(c)(1)(A) (AOC IG); 2 U.S.C. §1909(b)(1) (USCP IG). For a summary of appointment methods for
the five legislative branch IGs, see CRS Insight IN11763, Appointment Methods for Legislative Branch Inspectors
General, by Ben Wilhelm.
49 5 U.S.C. §403(b) (establishment IGs); 5 U.S.C. §415 note (SIGAR); 12 U.S.C. §5231(b)(4) (SIGTARP); 50 U.S.C.
§3033(c)(4) (IC IG); 50 U.S.C. §3517(b)(6) (CIA IG).
50 5 U.S.C. §415(e) (DFE IGs); 2 U.S.C. §1808(c)(2) (AOC IG); 2 U.S.C. §1909(b)(3) (USCP IG); 31 U.S.C.
§705(b)(2) (GAO IG); 44 U.S.C. §3902(b) (GPO IG); 2 U.S.C. §185(c)(2) (LOC IG).
51 5 U.S.C. §415(e)(1).
52 39 U.S.C. §202(e).
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• USCP IG. Removal upon a “unanimous vote” of all voting members on the
Capitol Police Board.53
In most cases, Congress must receive advanced notice of an IG’s removal or transfer. The
removal authority must communicate to both houses of Congress, in writing, the “substantive
rationale” for the IG’s removal or transfer 30 days in advance for establishment, DFE, and special
IGs—representing 68 out of 74 IGs.54 Additionally, this notice must include information on any
“open or completed inquiry” into the IG being removed.55
Advanced notice requirements for removal vary across other permanent IGs. Authorizing statutes
for other permanent IGs in the executive branch require the same 30-day advanced written notice
(including substantive rationale) but only to the congressional intelligence committees.
Authorizing statutes for the other permanent IGs in the legislative branch do not explicitly require
advanced notice and instead require written communication to Congress explaining the reason for
removal.56 Advanced notice to Congress is not explicitly required for transfers of other permanent
IGs.
Term Limits
All but two statutory IGs may serve indefinitely. The USPS and USCP IGs are subject to term
limits. The USPS IG is appointed to a seven-year term and can be reappointed for an unlimited
number of terms.57 The USCP IG is appointed to serve a five-year term for up to three terms (15
years total).58
Transparency of Budget Formulation and Proposals
Establishment, DFE, and other permanent IGs in the executive branch are required to develop
annual budget estimates that are distinct from the budgets of their affiliated entities. Further, such
budget estimates must include some transparency into the requested amounts before agency heads
and the President can modify them.59 The budget formulation and submission process for the
aforementioned IG types includes the following key steps:
• IG budget estimate to affiliated agency head. The IG submits an annual budget
estimate for its office to the affiliated entity head. The estimate must include (1)
the aggregate amount for the IG’s total operations, (2) a subtotal amount for
training needs, and (3) resources necessary to support CIGIE.60

53 2 U.S.C. §1909(b)(3).
54 The 68 IGs include establishment, DFE, and special IGs.
55 See 5 U.S.C. §403(b)(1)(B).
56 2 U.S.C. §1808(c)(2) (AOC IG); 31 U.S.C. §705(b)(2) (GAO IG); 44 U.S.C. §3902(b) (GPO IG); 2 U.S.C.
§185(c)(2) (LOC IG); 2 U.S.C. §1909(b)(3) (USCP IG).
57 39 U.S.C. §202(e)(2)(a).
58 2 U.S.C. §1909(b)(2).
59 5 U.S.C. §§406(g) and 415(g)(1) (establishment and DFE IGs); 50 U.S.C. §3033(n) (IC IG); and 50 U.S.C.
§3517(f)(2) (CIA IG).
60 Congress has appropriated funds directly to CIGIE’s Inspector General Council Fund for specific purposes. For
instance, Congress has provided funding in recent years to support the Oversight.gov website. See, for example,
Division D, Section 633 of the Consolidated Appropriations Act of 2019 (P.L. 116-6) appropriating $2 million to the
Inspector General Council Fund.
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• Agency budget request to President. The affiliated entity head compiles and
submits an aggregated budget request for the IG to the President. The budget
request includes any comments from the IG regarding the entity head’s proposal.
• President’s annual budget to Congress. The President submits an annual
budget to Congress. The budget submission must include (1) the IG’s original
budget that was transmitted to the entity head, (2) the President’s requested
amount for the IG, (3) the amount requested by the President for training of IGs,
and (4) any comments from the IG if the President’s amount would “substantially
inhibit” the IG from performing his or her duties.61
This process provides IGs at least some budgetary independence from their affiliated entities,
particularly by enabling Congress to perceive differences between the budgetary perspectives of
IGs and affiliated agencies or the President. Governing statutory provisions outline the following
submission process, although it is unclear whether every IG interprets the statute similarly.
Notably, one congressional committee investigation questioned whether the President was
consistently following the IG Act’s requirements for transparency of IG budget formulation.62
Treatment of budget estimates for other permanent IGs in the legislative branch varies. The
authorizing statues for the USCP, LOC, and GAO IGs do not explicitly require the IGs to develop
budget estimates that are distinct from the affiliated entity’s budget request.63 The extent to which
these budget estimate requirements apply to the special IGs and the GPO and AOC IGs is
unclear.64 Some of these IGs have historically developed separate budget estimates.65
Appropriations
Federal laws explicitly provide establishment IGs and other permanent IGs in the executive
branch a separate appropriations account for their respective offices.66 This requirement provides
an additional level of budgetary independence from the affiliated entity by preventing attempts to
limit, reallocate, or otherwise reduce IG funding once it has been specified in law, except as
provided through established transfer and reprogramming procedures and related interactions
between agencies and the appropriations committees.67

61 5 U.S.C. §§406(g) and 415(g)(1) (establishment and DFE IGs); 50 U.S.C. §3033(n) (IC IG); and 50 U.S.C.
§3517(f)(2) (CIA IG).
62 U.S. Congress, Senate Committee on Homeland Security and Governmental Affairs, Undermining Independent
Oversight, minority staff report, no date [released August 15, 2018], p. 2, at https://www.hsgac.senate.gov/imo/media/
doc/REPORT-Undermining%20Independent%20Oversight-
The%20President's%20Fiscal%20Year%202019%20Budget%20Does%20Not%20Adequately%20Support%20Federal
%20Inspectors%20General.pdf.
63 Authorizing statutes for the USCP, LOC, and GAO IGs do not incorporate the provision in Section 6 that contains
these budgetary requirements, nor do they include language establishing similar requirements. See 2 U.S.C.
§1909(d)(1) (USCP IG); 2 U.S.C. §185(d)(1) (LOC IG); and 31 U.S.C. §705 (GAO IG).
64 Authorizing statutes for special IGs and the AOC and GPO IGs incorporate portions of Section 6 of the IG Act.
However, it is unclear whether this incorporation extends the requirements to those IGs. See 2 U.S.C. §1808(d)(1)
(AOC IG) and 44 U.S.C. §3903(a) (GPO IG); 12 U.S.C. §5231(d)(1) (SIGTARP); and 5 U.S.C. §415 note (SIGAR).
65 See, for example, the SIGTARP FY2022 budget justification at https://home.treasury.gov/system/files/266/09.-
SIGTARP-FY-2022-CJ.pdf and the LOC FY2021 budget justification at https://www.loc.gov/static/portals/about/
reports-and-budgets/documents/budgets/fy2022.pdf#page=109.
66 31 U.S.C. §1105(a)(25); 50 U.S.C. §3517(f)(1) (CIA IG); 50 U.S.C. §3033(m) (IC IG).
67 For more information on reprogramming and transfers, see CRS Report R43098, Transfer and Reprogramming of
Appropriations: An Overview of Authorities, Limitations, and Procedures, by Michelle D. Christensen; and CRS
Report R47019, The Executive Budget Process: An Overview, by Dominick A. Fiorentino and Taylor N. Riccard.
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Appropriations for DFE IGs and other permanent IGs in the legislative branch, in contrast, are
part of the affiliated entity’s appropriations account. Absent statutory separation of a budget
account, the appropriations may be more susceptible to some reallocation of funds, although other
protections may apply.68 Authorizing statutes for special IGs do not explicitly require separate
appropriations accounts, although in practice the President may propose, and Congress may fund,
special IGs through separately listed accounts.69
Reporting Requirements
Statutory IGs have various reporting obligations to Congress, the Attorney General, agency
heads, and the public. Some reporting requirements are periodic, while others are triggered by a
specific event. The subsections below highlight some of the required reports for statutory IGs.70
Semiannual Report
The IG Act requires establishment and DFE IGs to issue semiannual reports that summarize the
activities of their offices. For example, the reports must include a summary of each audit and
inspection or evaluation report issued before the start of the reporting period that includes
“outstanding unimplemented recommendations” and the aggregate potential cost savings of those
recommendations.71 The IG Act further requires DFE and establishment IGs to make semiannual
reports available to the affiliated entity head, Congress, and the public, as follows:
• The IG submits report to the affiliated entity head by April 30 and October 31
each year.
• The affiliated entity head submits the report to the appropriate congressional
committees within 30 days of receiving it. The report must remain unaltered, but
it may include additional comments from the agency head.
• The affiliated entity head makes the report available to the public within 60 days
of receiving it.72
Other permanent IGs must also issue semiannual reports, though required content can vary by
IG.73 For example, the semiannual report for the IC IG must include comparatively less
information on OIG activities than establishment and DFE IGs. Further, the IC IG has an
additional reporting requirement to certify whether the IG has had “full and direct access to all

68 For example, appropriations committees may choose to allocate funding to an IG in ways that would require advance
notification of any attempt by an affiliated entity head to reprogram funds away from the IG to another purpose.
69 For example, the President’s FY2022 budget submission included a separate account for SIGTARP. See U.S. Office
of Management and Budget, Budget of the United States Government, Fiscal Year 2022, Appendix, pp. 1025-26, at
https://www.whitehouse.gov/wp-content/uploads/2021/05/tre_fy22.pdf.
70 Federal laws sometimes assign one-time or periodic reporting requirements on a specific policy area or subject.
These requirements are beyond the scope of this report.
71 5 U.S.C. §405(a)(10).
72 Ibid., at §405(b).
73 Authorizing statutes for other permanent IGs in the legislative branch (except the GAO IG) incorporate portions of
Section 5 of the IG Act, which require IGs to issue semiannual reports. However, it is unclear whether this
incorporation extends all elements of the semiannual report required by the IG Act to these IGs. See 2 U.S.C.
§1808(d)(1) (AOC IG); 2 U.S.C. §1909(c)(2) (USCP IG); 2 U.S.C. §185(d)(1) (LOC IG); and 44 U.S.C. §3903(a)
(GPO IG). Authorizing statutes for the GAO IG and other permanent IGs in the executive branch do not incorporate
Section 5 but establish separate semiannual reporting requirements. See 31 U.S.C. §705(e) (GAO IG); 50 U.S.C.
§3033(k)(1) (IC IG); 50 U.S.C. §3517(d)(1) (CIA IG).
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information” relevant to IG functions.74 Special IGs are required to issue quarterly reports rather
than semiannual reports, which must include a “detailed statement” of obligations, expenditures,
and revenues associated with the programs, funds, and activities that they oversee.75
Seven-Day Letter
Establishment, DFE, and most other permanent IGs (five out of seven) are required to
immediately report to their affiliated entity heads any “particularly serious or flagrant problems,
abuses or deficiencies relating to the administration of programs and operations” at their affiliated
entities. The affiliated entity head must transmit the report unaltered to Congress within seven
calendar days.76 This type of report is commonly referred to as the “seven-day letter.” Authorizing
statutes for the USCP and GAO IGs do not explicitly require issuance of seven-day letters, but
they may do so in practice.77 The extent to which such requirements apply to special IGs is
unclear.78
Top Management and Performance Challenges
The Reports Consolidation Act of 2000 requires IGs for executive branch agencies to annually
identify the “most serious management and performance challenges” facing their affiliated
agencies and to track the agency’s progress in addressing those challenges.79 These are commonly
referred to as top management and performance challenges (TMPCs). A covered IG must submit
the statement to the affiliated entity head 30 days in advance of the entity head’s submission of
the Annual Financial Report (AFR) or Performance and Accountability Report (PAR). The
agency head must include the statement unaltered (but with any comments) in the entity’s AFR or
PAR. IGs for government corporations in the executive branch, as well as special IGs and other
permanent IGs in the legislative branch, are not explicitly required to identify TMPCs.80
However, some of these IGs have elected to do so.81 CIGIE has periodically released reports on
common TMPCs facing multiple agencies.82

74 50 U.S.C. §3033(k)(1)(b)(v). A similar requirement applies to the CIA IG. See 50 U.S.C. §3517(d)(1)(D).
75 12 U.S.C. §5231(i)(1) (SIGTARP); 5 U.S.C. §415 note (SIGAR); and 15 U.S.C. §9053(f)(1) (SIGPR).
76 5 U.S.C. §§405(d) and 415(g)(1) (establishment and DFE IGs); 50 U.S.C. §3033(k)(2) (IG IC); and 50 U.S.C.
§3517(d)(2) (CIA IG). Authorizing statutes for the AOC, LOC, and GPO IGs clearly incorporate portions of Section 5
of the IG Act pertaining to the seven-day letter. See 2 U.S.C. §1808(d)(1) (AOC IG); 2 U.S.C. 185(d)(1) (LOC IG);
and 44 U.S.C. §3903(a) (GPO IG).
77 Authorizing statutes for the USCP and GAO IGs do not incorporate portions of Section 5 of the IG Act requiring the
seven-day letter, nor do they establish similar requirements. See 2 U.S.C. §1909 (USCP IG); 31 U.S.C. §705 (GAO
IG).
78 Authorizing statutes for SIGAR, SIGTARP, and SIGPR do not explicitly incorporate Section 5 of the IG Act, nor do
they establish similar requirements. However, their authorizing statutes state that the IGs “shall also have the
responsibilities and duties of inspectors general under the Inspector General Act of 1978,” which may include the
seven-day letter. See 12 U.S.C. §5231(c)(3) (SIGTARP) and 5 U.S.C. §415 (SIGAR).
79 31 U.S.C. §3516(d). In this context, executive branch agency is defined as a “department, agency, or instrumentality
in the executive branch of the United States Government,” but it excludes government corporations defined in 31
U.S.C. §9101. See 31 U.S.C. §102 and 31 U.S.C. §3501.
80 Ibid. 31 U.S.C. §9101 lists “Government corporations” that are exempt from issuing TMPCs.
81 For example, SIGTARP has identified TMPCs since at least Q4 of FY2017. The reports are accessible at
https://www.sigtarp.gov/Pages/Reports-Testimony-Home.aspx.
82 CIGIE, Top Management and Performance Challenges Facing Multiple Federal Agencies, February 2021, at
https://www.ignet.gov/sites/default/files/untracked/TMPC_report_02022021.pdf.
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Transparency of IG Reports and Recommendations
Federal laws require varied levels of transparency for IG reports and related recommendations for
corrective action. The IG Act requires the following for establishment and DFE IGs:
• Public availability of semiannual reports. Semiannual reports must be made
available to the public “upon request and at a reasonable cost.”83
• Audits and inspection or evaluation reports on OIG websites. Audit,
inspection, and evaluation reports must be posted on the OIG’s website within
three days of submitting final versions of the report to the affiliated entity head.84
• Documents containing recommendations on OIG websites. Any “document
making a recommendation for corrective action” must be posted on the OIG’s
website within three days of submitting the final recommendation to the affiliated
entity head.85
Application of these transparency requirements varies among other permanent IGs as follows:
• Semiannual reports. Four out of five other permanent IGs in the legislative
branch are statutorily required to make semiannual reports available to the public
in the same manner specified in the IG Act.86 The GAO IG and other permanent
IGs in the executive branch, by contrast, are not explicitly required to make the
reports publicly available.87
• Audits and inspections or evaluation reports on OIG websites. Authorizing
statutes for all seven other permanent IGs do not explicitly require the IGs to post
individual audit, inspection, or evaluation reports on their respective OIG
websites.88
• Documents containing recommendations on OIG websites. The GAO IG and
other permanent IGs in the executive branch are not explicitly required to post
documents containing recommendations on their respective OIG websites.89 It is
unclear whether the AOC, GPO, LOC, and USCP IGs must post such
documents.90 Some IGs have elected to post certain reports on their websites. For
example, the GAO OIG website includes reports on audits and inspections or

83 5 U.S.C. §405(c).
84 5 U.S.C. §420(b).
85 5 U.S.C. §404(e)(1)(C).
86 Authorizing statutes for the AOC, GPO, LOC, and UCSP IGs clearly incorporate portions of Section 5 pertaining to
public availability of semiannual reports. See 2 U.S.C. §1808(d)(1) (AOC IG); 44 U.S.C. §3903(a) (GPO IG); 2 U.S.C.
§185(d)(1) (LOC IG); and 2 U.S.C. §1909(c) (USCP IG).
87 Authorizing statutes for the GAO, CIA, and IC IGs do not incorporate Section 5 of the IG Act, nor do they establish
similar requirements. See 31 U.S.C. §705 (GAO IG); 50 U.S.C. §3033 (IC IG); and 50 U.S.C. §3517 (CIA IG).
88 The authorizing statutes for the AOC, CIA, IC, GAO, GPO, LOC, and USCP IGs do not incorporate Section 8M of
the IG Act, nor do they establish similar requirements. See 2 U.S.C. §1808 (AOC IG); 50 U.S.C. §3517 (CIA IG); 50
U.S.C. §3033 (IC IG); 44 U.S.C. §3903 (GPO IG); 2 U.S.C. §185 (LOC IG); and 2 U.S.C. §1909 (USCP IG).
89 Authorizing statutes for the GAO, CIA, and IC IGs do not incorporate Section 4 of the IG Act, nor do they establish
similar requirements. See 31 U.S.C. §705 (GAO IG); 50 U.S.C. §3033 (IC IG); and 50 U.S.C. §3517 (CIA IG).
90 The authorizing statutes for the AOC, GPO, LOC, and USCP IGs incorporate portions of Section 4 of the IG Act.
However, whether such incorporation extends requirements for documents with recommendations to be posted on OIG
websites to these IGs is unclear. See 2 U.S.C. §1808(d)(1) (AOC IG); 44 U.S.C. §3903(a) (GPO IG); 2 U.S.C.
§185(d)(1) (LOC IG); and 2 U.S.C. §1909(c) (USCP IG).
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evaluations as well as semiannual and peer review reports.91 By contrast, the
USCP OIG website lists only peer review reports.92
Special IG reports are also subject to certain transparency requirements. The Special Inspector
General for the Troubled Asset Relief Program’s authorizing statute requires the IG to make its
quarterly reports available to the public, but the statute does not explicitly require those reports to
be posted on a public website.93 SIGAR must make its quarterly reports available to the public
and post them on a public website in English and other languages that the IG determines “are
widely used and understood in Afghanistan.”94 SIGPR, by contrast, is only explicitly required,
under its authorizing statute, to issue its quarterly reports to Congress.95 The extent to which
special IGs must post individual audits, inspections, or evaluation reports and documents
containing recommendations on their websites or other public websites is unclear.96
Oversight.gov
The majority of IGs have elected to participate in Oversight.gov—an electronic repository
launched in October 2017 that contains most IG reports issued since 2014 and some earlier
reports.97 While Oversight.gov was originally created on the initiative of the oversight
community, in 2020 Congress passed legislation requiring CIGIE to “establish and maintain” the
website and requiring most IGs to participate.98 Unlike many individual OIG websites,
Oversight.gov features a searchable database that can filter reports across OIGs based on several
criteria, such as a specific IG, review type, or keyword. Since January 2023 all IGs have been
listed as participants on the website. IGs determine which reports to post on the website, and
most, but not all, participating IGs post at least some reports. Many reports, including some not
published on Oversight.gov, are also available on individual OIG websites.
Coordination and Oversight of Statutory IGs
Council of the Inspectors General on Integrity and Efficiency
CIGIE is the primary oversight and coordinative body for the IG community. The council
consolidated and replaced two IG coordinating bodies previously established by executive order:

91 GAO OIG, “Overview,” at https://www.gao.gov/ig/.
92 USCP OIG, “Office of the Inspector General,” at https://www.uscp.gov/the-department/office-inspector-general.
93 12 U.S.C. §5231(i)(5).
94 5 U.S.C. §415 note.
95 15 U.S.C. §9053(f).
96 The authorizing statutes for SIGAR, SIGTARP, and SIGPR do not incorporate Sections 4(b)(2), 5, or 8M of the IG
Act, nor do they establish similar requirements. However, their authorizing statutes state that the IGs “shall also have
the responsibilities and duties of inspectors general under the Inspector General Act of 1978,” which might include the
aforementioned transparency requirements. See 5 U.S.C. §415 note (SIGAR); 12 U.S.C. §5231(c)(3) (SIGTARP); and
15 U.S.C. §9053(c)(3) (SIGPR).
97 CIGIE, “CIGIE Launches Oversight.gov: IGs Found More Than $25 Billion in Potential Cost Savings in FY2017,
New Website Shows,” October 2, 2017, https://www.ignet.gov/sites/default/files/files/
CIGIE%20Announces%20Official%20Launch%20of%20Oversight_gov_10_02_17_Final.pdf. For more information
on the website, see https://oversight.gov/about. Many OIG websites have more complete libraries of older reports than
Oversight.gov does.
98 P.L. 116-260 §501 (Consolidated Appropriations Act, 2021), codified at 5 U.S.C. §424(e). Congress has also
provided appropriations specifically to support Oversight.gov, including $850,000 in the FY2023 Consolidated
Appropriations Act (P.L. 117-328).
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the President’s Council on Integrity and Efficiency and the Executive Council on Integrity and
Efficiency.99 CIGIE members include all statutory IGs along with other relevant officers, such as
representatives of the Federal Bureau of Investigation (FBI) and the Office of Special Counsel.
The council chairperson is an IG elected from members of the council, and the Office of
Management and Budget Deputy Director for Management serves as the executive chairperson.100
Pursuant to the IG Act, CIGIE’s mission is to “address the integrity, economy, and effectiveness
of issues that transcend individual Government agencies” and “increase the professionalism and
effectiveness of [OIG] personnel.”101 The IG Act vests CIGIE with several responsibilities to
accomplish this mission,102 which can be grouped into the following categories:
• IG workforce training and development. CIGIE is required to support
professional development for IGs.103 It also maintains at least three training
academies for auditors, investigators, inspectors/evaluators, and other personnel
in IG offices.104 CIGIE also develops and maintains other resources and guides to
aid OIG personnel in conducting their work.105
• Coordination of IG external peer reviews. CIGIE develops and manages the
policies and procedures that govern how IGs conduct external peer review—a
process that involves one OIG assessing whether another OIG’s audits,
inspections, and investigations comply with the applicable quality standards.106
• Investigations of alleged IG wrongdoing. The CIGIE Integrity Committee—the
sole statutorily established committee within the council—receives, reviews, and
refers for investigation allegations of misconduct by the IG or other OIG officials
according to processes and procedures detailed in the IG Act.107
• Identification of IG candidates. The IG Act requires CIGIE to submit
recommendations of candidates for vacant IG positions to the appropriate the
appointing authority.108 In response to this provision, the council established a
Candidate Recommendations Panel, which identifies and vets candidates for IG
positions.109
• Cross-jurisdictional reports. CIGIE periodically publishes reports on issues that
transcend individual agency and IG jurisdictions. For example, as mentioned
previously, CIGIE periodically issues reports on cross-cutting top management

99 See Executive Order 12805, “Integrity and Efficiency in Federal Programs,” 57 Federal Register 20627, May 11,
1992; and Executive Order 12301, “Integrity and Efficiency in Federal Programs,” 46 Federal Register 19211, March
26, 1981.
100 5 U.S.C. §§424(b)(1) and 424(b)(2).
101 Ibid., at §424(a).
102 Ibid., at §424(c).
103 5 U.S.C. §424(c)(1)(E).
104 Ibid. See also CIGIE, “CIGIE Training Institute,” https://www.ignet.gov/content/cigie-training-institute.
105 See, for example, CIGIE, “Manuals and Guides,” https://ignet.gov/content/manuals-guides.
106 See, for example, CIGIE, “IG Peer Reviews,” https://www.ignet.gov/content/ig-peer-reviews.
107 5 U.S.C. §424(d). The committee is composed of six members—four IGs on CIGIE, the FBI representative on the
council, and the Director of the Office of Government Ethics. The committee chairperson is elected to a two-year term
by the members of the committee.
108 5 U.S.C. §424(c)(1)(F).
109 For more information on the panel, see, for example, GAO, Inspectors General, Information on Vacancies and IG
Community Views on Their Impact, GAO-18-270, March 2018, p. 7, https://www.gao.gov/assets/700/690561.pdf.
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and performance challenges facing multiple agencies, such as IT security and
management.110
Historically, CIGIE has not received a direct appropriation from Congress. Rather, the council is
financed by the IG member offices, which contribute a pro rata amount of their annual funding to
CIGIE together with payments received in connection with attendance at CIGIE training. The
contributions are placed into a no-year revolving fund.111
Other Coordinating Bodies
Other interagency mechanisms have been created by law or administrative directive to support
coordination among IGs for specific issues. Current examples are described below.112
• Lead Inspector General (LIG) for Overseas Contingency Operations (OCO).
The LIG is a formal coordination role assigned to the IG for DOD, the
Department of State, or the U.S. Agency for International Development.113 The
LIG provides comprehensive oversight of programs and operations in support of
OCO, including the management and coordination of all related audits,
inspections or evaluations, and investigations conducted by the three IGs. The
chair of CIGIE must designate an LIG for each covered OCO.
• Council of Inspectors General on Financial Oversight (CIGFO). CIGFO is
composed of IGs for nine financial regulatory agencies and is chaired by the
Treasury IG. The mission of CIGFO is to facilitate information sharing among
the nine IGs and develop ways to improve financial oversight.114 In some cases,
CIGFO has engaged in activities that build upon existing work of individual IGs.
For example, CIGFO identified cross-cutting top management challenges facing
all nine financial regulatory agencies.115
• Pandemic Response Accountability Committee (PRAC). The PRAC is
composed of nine IGs specified by law and additional IGs appointed by the
PRAC’s chairperson.116 PRAC is tasked with conducting and supporting
oversight of the federal government’s response to the COVID-19 pandemic and
the funds spent in support of that activity. PRAC has a coordinating function
among IGs and regarding issues that cross agency jurisdictional boundaries.117

110 CIGIE, “Top Management and Performance Challenges Facing Multiple Federal Agencies,” at
https://www.ignet.gov/content/top-challenges.
111 5 U.S.C. §424(c)(3)(A)(ii); CIGIE, “Charter,” https://www.ignet.gov/content/charter; CIGIE, FY2018 Agency
Financial Report, November 14, 2018, pp. 32-33, at https://ignet.gov/sites/default/files/files/
CIGIE_2018_Agency_Financial_Report.pdf; and email communication with CIGIE on December 13, 2018.
112 A past example of a statutory coordinating body is the Recovery Accountability and Transparency Board, which
consisted of federal IGs and was tasked with overseeing funds covered under the American Recovery and
Reinvestment Act of 2009. For more information, see CRS Report R40572, General Oversight Provisions in the
American Recovery and Reinvestment Act of 2009 (ARRA): Requirements and Related Issues, by Clinton T. Brass.
113 P.L. 112-239, §848; listed in 5 U.S.C. §419.
114 P.L. 111-203, §989E; listed in 5 U.S.C. §424 note.
115 CIGFO, Top Management and Performance Challenges Facing Financial Regulatory Organizations, September
2018, at https://oig.treasury.gov/sites/oig/files/Audit_Reports_and_Testimonies/
CIGFO%20TMPC%20Final%20Report%202019.pub.pdf.
116 P.L. 116-136 §15010; listen in 5 U.S.C. §424 note.
117 Ibid.
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Issues for Congress
Statutory IGs play a key role in government oversight, and Congress plays a key role in
establishing the structures and authorities to enable that oversight. The structure and placement of
IGs in government agencies allows OIG personnel to develop the expertise necessary to conduct
in-depth assessments of agency programs. Further, IGs’ dual reporting structure—to their agency
heads and Congress—positions them to advise agencies on how to improve their programs and
policies and to advise Congress on how to monitor and facilitate such improvement. Congress,
therefore, may have an interest in ensuring that statutory IGs possess the resources and authorities
necessary to fulfill their oversight roles.
As the federal government continues to evolve, so too does the role of IGs in government
oversight. Agency programs and operations have increased in breadth, complexity, and
interconnectedness. Consequently, IGs may face increasing demand to complete statutorily
mandated reviews of programs and operations that require (1) a broader focus on program
performance and effectiveness in addition to waste, fraud, and abuse; (2) analysis of specialty or
technical programs, possibly in emerging policy areas;118 and (3) use of more complex analytical
methods and tools.
Congress may consider several options regarding IG structures, functions, and coordination as the
role of IGs in government oversight evolves.119 In serving Congress with nonpartisan and
objective analysis and research, CRS does not make recommendations or take positions on
particular options.
Independence
Federal laws and administrative standards require IGs to be independent of the entities and/or
activities they evaluate. There is no standard definition, however, for what constitutes IG
independence. Rather, IGs derive independence from a combination of statutory authorities and
requirements, such as the requirement that IGs be appointed on the basis of integrity and
demonstrated ability in certain skill sets, and independence and transparency of IG budgets.120 It
could be argued that challenges remain to ensuring that IGs possess the requisite independence to
carry out their missions. Congress may consider several broad questions if it weighs further
options related to IG independence, such as the following:
• What constitutes IG independence? IGs, agencies, and Congress may perceive
independence differently, and by extension, may interpret and exercise statutory
authorities that affect independence in varied (and possibly divergent) ways. A
GAO report that assessed an IG’s level of independence stated the following:

118 For an example of such a proposal, see Amy C. Gaudion, “Recognizing the Role of Inspectors General in the U.S.
Cybersecurity Restructuring Task,” Belmont Law Review, vol. 9, no. 1 (2021), pp. 180-230 (suggesting that OIGs
might be well-positioned to support federal cybersecurity strategies).
119 Congress and other stakeholders have held events to commemorate the 20th, 25th, and 40th anniversaries of the IG
Act that have included discussions of many of the issues described in this section. See, for example, U.S. Congress,
Senate Committee on Governmental Affairs, The Inspector General Act: 20 Years Later, 105th Cong., 2nd sess.,
September 9, 1998, S.Hrg. 105-737 (Washington, DC: GPO, 1998); U.S. Congress, House Committee on Government
Reform, Subcommittee on Government Efficiency and Financial Management, 25th Anniversary of the Inspector
General Act—Where Do We Go From Here? 108th Cong., 1st sess., October 8, 2003, Serial No. 108-110 (Washington,
DC: GPO, 2004); and CIGIE, “Building on 40 Years of Excellence in Independent Oversight,” 2018, at
https://www.ignet.gov/2018-commemoration.
120 See, for example, 5 U.S.C. §§406(a)(7), 403(b), and 403(g).
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To a large extent, independence is a state of mind of the auditor. The extent to which
an auditor’s independence has been affected by surrounding influences cannot be
easily assessed by a third party. Any effort to assess auditor independence requires
considerable subjective judgment, and reasonable people have room for
disagreement.121
• What factors affect IG independence? Several internal and external factors
may also affect an IG’s independence. Examples of internal factors include self-
interest, familiarity with agency personnel in units undergoing a review, and
other “threats to independence” outlined in CIGIE’s quality standards.122
Examples of external factors include IG statutory authorities—such as
appointment and removal methods and access to agency records—structure and
leadership of the affiliated entity, and political influence.
• What is the appropriate balance between IG independence and agency
management? The IG Act established a dual reporting structure that requires IGs
to report to both Congress and their affiliated entity heads.123 This structure
creates potential tension between IGs and their affiliated entity heads. An IG,
therefore, must maintain independence from the agency head to assess the
agency’s programs and operations objectively while also fostering a working
relationship with agencies to ensure the effectiveness of those assessments.124
Appointment and Removal Methods
As noted earlier in this report, IGs can generally be appointed under one of three methods: (1) by
the President, with the advice and consent of the Senate (PAS); (2) by the President alone (PA); or
(3) by the affiliated entity head. Observers have asserted that appointment and removal methods
affect an IG’s independence and effectiveness—both directly and indirectly—though opinions
vary regarding the level and type of impact. Following the removal of IGs during both the Obama
and Trump Administrations, the issue of removal has received particular attention in Congress.125
Congress addressed some of its principal concerns regarding removal and IG independence with
provisions included in the FY2023 National Defense Authorization Act (P.L. 117-263), which

121 GAO, Inspectors General: Allegations About the Independence of the Former VA Inspector General, GAO/AMFD-
89-46, March 1989, p. 3, at http://www.gao.gov/assets/220/211076.pdf.
122 CIGIE, Quality Standards for Federal Offices of Inspectors General, August 2012, pp. 10 and 12-13,
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf.
123 5 U.S.C. §403(a); 5 U.S.C. §404(a)(5).
124 Congress acknowledged the potential for such tension but stated that the “potential advantages far outweigh the
potential risks.” U.S. Congress, Senate Committee on Governmental Affairs, report to accompany H.R. 8588, 95th
Congress, 2nd sess., August 8, 1978, S.Rept. 95-1071 (Washington, DC: GPO, 1978), p. 9. See also Partnership for
Public Service, Walking the Line, Inspectors General Balancing Independence and Impact, September 2016,
https://ourpublicservice.org/wp-content/uploads/2016/09/0bd2a00052bc1e7c216c5ee89fc4b457-1491000841.pdf. The
Partnership for Public Service describes itself as a “nonprofit, nonpartisan organization that strives for a more effective
government for the American people.” For more information on the Partnership for Public Service, see
https://ourpublicservice.org/about/.
125 See CRS In Focus IF11546, Removal of Inspectors General: Rules, Practice, and Considerations for Congress, by
Ben Wilhelm; and CRS Legal Sidebar LSB10476, Presidential Removal of IGs Under the Inspector General Act, by
Todd Garvey. For additional discussion of potential options for Congress to alter IG removal methods, see CRS Report
R46762, Congress’s Authority to Limit the Removal of Inspectors General, by Todd Garvey; and CRS In Focus
IF11698, Legislative Proposals Related to the Removal of Inspectors General in the 116th Congress, by Ben Wilhelm.
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require more substantive reporting to Congress prior to removals and limit the circumstances
under which IGs can be removed or placed on non-duty status.126
Direct Impact
Some observers have argued that the PAS appointment method strengthens IG independence. For
example, GAO general counsel Gary Kepplinger suggested that PAS-appointed IGs experience
greater organizational independence compared to agency-appointed IGs, noting that “the further
removed the appointment source is from the entity to be audited, the greater the level of
independence.”127 Others have asserted that PAS appointments—including converting an IG from
agency appointment to a PAS appointment—might politicize the IG position and reduce IG
effectiveness.128
Similar debates exist regarding IG removal methods. Some observers have expressed concern
over potential politicization of the IG removal process, which may undermine IG
independence.129 Some have suggested that limiting the removal of IGs “for cause” could
mitigate arbitrary removal (such as for political reasons) and enhance IG independence.130 Others
have asserted that this limitation might prevent the President or agency heads from removing IGs
for legitimate reasons (such as poor performance), thus diminishing IG accountability.131
Indirect Impact
IG appointment and removal methods may also indirectly affect independence by contributing to
IG vacancies. Concerns exist that the IG vetting and confirmation processes (particularly PAS
appointments) take too long, leading to prolonged IG vacancies and use of acting IGs.132 It could
also be argued that removal methods (such as “for cause” removal and term limits) might increase
the number and length of IG vacancies.

126 Title LII, Subtitle A.
127 GAO, Inspectors General: Independent Oversight of Financial Regulatory Agencies, GAO-09-524T, March 25,
2009, pp. 3-4, at http://www.gao.gov/new.items/d09524t.pdf.
128 See, for example, U.S. Congress, House Committee on Oversight and Government Reform, Subcommittee on
Government Management, Organization, and Procurement, The Roles and Responsibilities of Inspectors General
Within Financial Regulatory Agencies, 111th Cong., 1st sess., March 25, 2009, Serial No. 111-49 (Washington, DC:
GPO, 2010), pp. 34, 46, 49, 53, and 70; and U.S. Congress, House Committee on Government Reform, The
Politicization of Inspectors General, minority staff report, October 21, 2004, https://web.archive.org/web/
20050724160427/http://reform.democrats.house.gov/story.asp?id=726.
129 See, for example, U.S. Congress, House Committee on Oversight and Government Reform, “Update and
Supplement to the Initial Report: The Firing of the Inspector General for the Corporation for National and Community
Service,” majority staff press release, March 2, 2010, at https://oversight.house.gov/report/update-and-supplement-to-
the-initial-report-the-firing-of-the-inspector-general-for-the-corporation-for-national-and-community-service/.
130 See, for example, GAO, Highlights of the Comptroller General’s Panel on Federal Oversight and The Inspectors
General, GAO-06-931SP, September 2006, pp. 2 and 5, at https://www.gao.gov/assets/210/202958.pdf.
131 See, for example, U.S. Congress, House Committee on Oversight and Government Reform, Subcommittee on
Government Management, Organization, and Procurement, Inspectors General: Independence and Integrity, 110th
Cong., 1st sess., June 20, 2007, Serial No. 110-48 (Washington, DC: GPO, 2008), pp. 13, 34, and 105; and U.S.
Congress, Senate Committee on Homeland Security and Governmental Affairs, Strengthening the Unique Role of the
Nation’s Inspectors General, 110th Cong., 1st sess., July 11, 2007, S.Hrg. 110-587 (Washington, DC: GPO, 2008), pp.
134-139.
132 See, for example, U.S. Congress, Senate Committee on Homeland Security and Governmental Affairs, Watchdogs
Needed: Top Government Investigator Positions Left Unfilled for Years, 114th Cong., 1st sess., June 3, 2015, S.Hrg.
114-486 (Washington, DC: GPO, 2015), pp. 2, 5, 8-10, 14, 16, 18-19, 23, 25, and 32.
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Some observers have argued that acting IGs are inherently, or may be perceived as, less
independent or effective compared to permanent IGs for various reasons. Examples include not
having gone through formal vetting processes, reduced ability to set long-term strategies and
priorities, and perverse incentives not to report problems in agency operations or resist political
pressure from agency heads—particularly for those seeking the permanent position.133 For
example, in a letter to the majority and minority leaders of the Senate for the 115th Congress,
CIGIE stated that
no matter how able or experienced an Acting Inspector General may be, a permanent IG
has the ability to exercise more authority in setting policies and procedures and, by virtue
of the authority provided for in the IG Act, inevitably will be seen as having greater
independence.134
Other observers have asserted that acting IGs are not inherently less independent, nor do they
appear or are perceived as less independent, than permanent IGs. For example, in a GAO report,
some permanent IGs and OIG employees responding to a survey provided several reasons for
why acting IGs are not less independent than permanent IGs. Examples include that acting IGs
have the same statutory authorities as permanent IGs, are held to the same standards as permanent
IGs, and are typically career OIG employees who prioritize independence.135
Audit Follow-Up and Oversight of IG Recommendations
While IGs are authorized to develop recommendations to improve government programs and
operations, they are not authorized to enforce them.136 Rather, agencies possess the authority to
ensure the implementation of IG recommendations and resolve any disagreements on
recommendations between the IG and the agency.137 Certain agencies must “take action to address
deficiencies” identified in IG reports or to certify that no action is necessary or appropriate.138
Congress and other observers have expressed concern about the total number of unimplemented
IG recommendations and potential barriers to resolving them, such as the quality and consistency
of agency and IG audit follow-up procedures, tracking unimplemented recommendations, and
determining the resolution of recommendations.139 Some observers have discussed options to
improve audit follow-up and oversight of IG recommendations, such as
• standardized and enhanced audit follow-up procedures, including defined roles
and responsibilities for IGs and their affiliated agencies;

133 Ibid., pp. 9, 16, and 45-47; GAO, Inspectors General, Information on Vacancies and IG Community Views on Their
Impact, GAO-18-270, March 2018, pp. 27-41, at https://www.gao.gov/assets/700/690561.pdf.
134 CIGIE, letter to Senator Mitch McConnell and the Honorable Harry Reid, November 7, 2016, p. 2,
https://www.ignet.gov/sites/default/files/files/CIGIE_Senate_Letter_IG_Vacancies_07Nov16%20(1).pdf.
135 GAO, Inspectors General, Information on Vacancies and IG Community Views on Their Impact, GAO-18-270,
March 2018, pp. 28-41, at https://www.gao.gov/assets/700/690561.pdf.
136 The IG Act prohibits IGs from undertaking “program operating responsibilities,” which includes enforcement of
recommendations. See 5 U.S.C. §§415(b) and 422(a)(2).
137 OMB, Audit Followup, Circular A-50, September 29, 1982, at https://www.whitehouse.gov/wp-content/uploads/
2017/11/Circular-050.pdf.
138 See, for example, Department of the Treasury responsibilities outlined in 12 U.S.C. §5231(f).
139 U.S. Congress, Senate Committee on Homeland Security and Governmental Affairs, Subcommittee on Regulatory
Affairs and Federal Management, Implementing Solutions: The Importance of Following Through on GAO and OIG
Recommendations, 114th Cong., 1st sess., December 10, 2015, S.Hrg. 114-265 (Washington, DC: GPO, 2016).
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• systematic tracking of and reporting on the total number and status of IG
recommendations;140
• prioritization of IG recommendations; and
• a centralized, public database of all open recommendations.141
Workforce Composition and Skills
OIGs need personnel with an appropriate mix of skills to effectively pursue their statutory
missions to prevent and detect government waste, fraud, and abuse. Traditionally, OIG
workforces have been primarily composed of auditors and investigators, though OIG workforce
professions and skills have diversified.142 These positions generally require education and
experience in audit and investigative procedures, such as assessing agency programs according to
government auditing standards and compiling and analyzing evidence. However, the qualification
requirements for these positions may not require experience in certain specialty areas that OIGs
might evaluate, such as information technology (IT).143
Some have argued that OIGs should further diversify their workforces, including by building
expertise in specialty areas beyond auditing and investigations such as IT, cybersecurity, and data
analysis. Some observers have further argued that broadening the mix of OIG personnel skills
could improve the quality and utility of audits and inspections or evaluations.144 For example, it
could be argued that building IT expertise within an OIG might enhance audit findings and
recommendations related to securing and modernizing legacy IT systems—a key management
and performance challenge facing multiple agencies.145

140 See, for example, Project on Government Oversight (POGO), The Watchdogs After Forty Years: Recommendation
for our Nation’s Federal Inspectors General, July 9, 2018, p. 21. POGO describes itself as a “nonpartisan, independent
watchdog that investigates and exposes waste, corruption, and abuse of power, and when the government fails to serve
the public or silences those who report wrongdoing.” POGO’s mission further notes that the organization champions
“reforms to achieve a more efficient, ethical, and accountable federal government that safeguards constitutional
principles.” For more information on POGO, see https://www.pogo.org/; Bipartisan Policy Center, Oversight Matters:
What’s Next for Inspectors General, July 2018, pp. 9, 10, 15 and 16. The Bipartisan Policy Center describes itself as a
“non-profit organization that combines the best ideas from both parties to promote health, security, and opportunity for
all Americans. BPC drives principled and politically viable policy solutions through the power of rigorous analysis,
painstaking negotiation, and aggressive advocacy.” For more information on the Bipartisan Policy Center, see
https://bipartisanpolicy.org.
141 Oversight.gov allows some tracking of open recommendations (https://www.oversight.gov/recommendations).
Legislation has been introduced in recent Congresses that would direct CIGIE to establish a searchable database of all
open IG recommendations. See the Inspector General Recommendation Transparency Act of 2018 (S. 2178; 115th
Congress), and Inspector General Recommendation Transparency Act of 2016 (S. 3109; 114th Congress).
142 GAO, Inspectors General, Reporting on Independence, Effectiveness, and Expertise, GAO-11-770, September
2011, pp. 16-18.
143 See, for example, the OPM qualification standards requirements for the 0511 (Auditor), 1810 (Investigator), and
1811 (Criminal Investigator) positions, accessible at https://www.opm.gov/policy-data-oversight/classification-
qualifications/general-schedule-qualification-standards/#url=List-by-Occupational-Series.
144 See, for example, the Partnership for Public Service, The Forward Looking Inspector General, November 14, 2017,
p. 9, at https://www.grantthornton.com/-/media/content-page-files/public-sector/pdfs/articles/2017/the-forward-
looking-IG.ashx; Bipartisan Policy Center, Oversight Matters, p. 26.
145 CIGIE, Top Management and Performance Challenges Facing Multiple Federal Agencies, April 18, 2018, pp. 3-5.
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IG Effectiveness
Some observers have asserted that IG reviews disproportionately focus on program compliance
and outputs rather than program outcomes.146 The Partnership for Public Service characterized
this dichotomy as “the difference between counting the number of people who show up at a job
training program, versus examining the number of attendees who get and keep a job after
participating in the program.”147 Observers have further argued that greater emphasis on program
outcomes could better improve agency programs and operations and, by extension, increase IG
effectiveness. Some IGs already assess program outcomes in addition to outputs and compliance.
For example, a Department of Labor IG audit concluded that the Job Corps program could not
demonstrate that it helped place participants in meaningful jobs related to their training due
primarily to noncompliance with certain program policies and ineffective transition services.148
In addition, some observers have argued that certain statutory requirements do not promote IG
effectiveness. For example, the Project on Government Oversight argued that statutorily required
metrics in IG semiannual reports focus on program outputs—such as the dollar value of
disallowed costs—but not necessarily on program outcomes149 and that the IG peer review
process focuses on compliance with applicable quality standards and does not evaluate the quality
or effectiveness of an IG’s work.150 Including an evaluation of IG performance and effectiveness
as part of the peer review process might impact how IGs approach, conduct, and report on audits
and investigations.
CIGIE Structure and Functions
Some observers have argued that CIGIE’s structures and operations could be altered to strengthen
coordination and oversight of the IG community.151 Examples include the following:
• Strengthening oversight of the IG community. Examples include enhancing
the peer review process, expanding the duties of the CIGIE Integrity Committee,
and elevating the role of the CIGIE Candidate Recommendations Panel in vetting
IG candidates.
• Reforming reporting requirements. Examples include maintaining an index of
IG reporting requirements, developing standardized templates for semiannual
reports, statutorily altering required content in semiannual reports, and statutorily
requiring maintenance of and participation in Oversight.gov.
• Enhancing data analytics capabilities. Responsibilities could include
systematic tracking and analysis of data across IGs (such as IG vacancies and
budgets), strengthening analyses to identify cross-agency top management and

146 See, for example, Bipartisan Policy Center, Oversight Matters, p. 17.
147 Partnership for Public Service, The Forward-Looking Inspector General, November 4, 2017, p. 2.
148 U.S. Department of Labor, OIG, Job Corps Could Not Demonstrate Beneficial Job Training Outcomes, March 30,
2018, https://www.oig.dol.gov/public/reports/oa/2018/04-18-001-03-370.pdf.
149 POGO, Inspectors General: Accountability is a Balancing Act, March 20, 2009, pp. 13-17, 47, and 97-98, archived
at http://www.pogoarchives.org/m/go/ig/accountability/ig-accountability-20090320.pdf; and POGO, Rating the
Watchdogs: Are Our Inspectors General Effective? August 10, 2018, https://www.pogo.org/analysis/2018/08/rating-
watchdogs-are-our-inspectors-general-effective/.
150 POGO, Inspectors General: Accountability is a Balancing Act, March 20, 2009, pp. 43-45, archived at
http://www.pogoarchives.org/m/go/ig/accountability/ig-accountability-20090320.pdf.
151 Congress has recently considered legislation that would increase CIGIE’s reporting requirements and make other
adjustments to the duties and organization of CIGIE. See IG Independence and Empowerment Act (H.R. 2662; 117th
Congress).
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performance challenges, and continuing development of an open
recommendations database.
• Enhancing coordination and resource sharing. CIGIE could, for example,
research and identify opportunities for IGs to utilize shared services.
• Reforming the CIGIE funding model. CIGIE and other stakeholders have
recommended authorizing a direct appropriation for the council to help facilitate
accomplishment of statutory duties as well as existing and proposed
administrative duties (such as further developing Oversight.gov).152

152 See, for example, Kathy A. Buller, Chair of the CIGIE Legislation Committee, letter to Lesley A. Field, Acting
Executive Chairperson, CIGIE, January 28, 2021, https://ignet.gov/sites/default/files/untracked/
CIGIE_Legislative_Priorities_117th_Congress.pdf.
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Appendix A. Statutory Inspectors General by Type
The four tables below list statutory inspectors general (IGs) by type—establishment, DFE, other
permanent, and special. The tables include the IG’s affiliated entity, year of establishment, and
original authorizing statute. The tables do not include IGs that have been abolished or
administratively established.
Table A-1. Establishment IGs
As of November 2023
Year
Original
Office of Inspector General
initially
authorizing
(current name of agency listed)
established
statute
Department of Health and Human Servicesa
1976
P.L. 94-505
Department of Energya
1977
P.L. 95-91
Department of Agriculture
1978
P.L. 95-452
Department of Commerce
Department of Housing and Urban Development
Department of Labor
Department of the Interior
Department of Transportation
Department of Veterans Affairs
Environmental Protection Agency and the Chemical Safety Hazard and
Investigation Boardb
General Services Administration
National Aeronautics and Space Administration
Small Business Administration
Department of Education
1979
P.L. 96-88
Department of State and the Broadcasting Board of Governorsc
1980
P.L. 96-465
Agency for International Development
1981
P.L. 97-113
Department of Defense
1982
P.L. 97-252
Railroad Retirement Board
1983
P.L. 98-76
Department of Justice
1988
P.L. 100-504
Department of the Treasury
Nuclear Regulatory Commission
Office of Personnel Management
Corporation for National and Community Service (AmeriCorps)
1993
P.L. 103-82
Federal Deposit Insurance Corporation (FDIC)d
1993
P.L. 103-204
Social Security Administration
1994
P.L. 103-296
Treasury IG for Tax Administration
1998
P.L. 105-206
Tennessee Valley Authority (TVA)e
2000
P.L. 106-422
Department of Homeland Security
2002
P.L. 107-296
Export-Import Bank of the United States
2002
P.L. 107-189
Federal Housing Finance Agency (FHFA)f
2008
P.L. 110-289
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Year
Original
Office of Inspector General
initially
authorizing
(current name of agency listed)
established
statute
National Reconnaissance Office (NRO)g
2014
P.L. 113-126
National Security Agency (NSA)g
2014
P.L. 113-126
Federal Communications Commission (FCC)h
2018
P.L. 115-141
Source: CRS analysis of the United States Code and original authorizing statutes for the listed IGs.
Notes: “Federal establishments” are defined in 5 U.S.C. §401(1). IGs for establishments are appointed and
removable by the President. The table does not include previous establishment IGs that were abolished.
a. The IG Amendments Act of 1988 (P.L. 110-504) abolished the IGs for the Departments of Energy and
Health, Welfare, and Education and created IGs for the Department of Energy and Department of Health
and Human Services as “establishments” under the IG Act of 1978.
b. The EPA IG also oversees the Chemical Safety and Hazard Investigation Board, which was established under
the Clean Air Amendments Act of 1990 (P.L. 101-549).
c. The Foreign Affairs and Restructuring Act (P.L. 105-207, §1322) expanded the Department of State IG’s
jurisdiction to include the Broadcasting Board of Governors in 1998.
d. The FDIC was originally defined as a designated federal entity (DFE) under the IG Amendments Act of
1988. The Resolution Trust Corporation Completion Act (P.L. 103-204) redesignated the FDIC as an
establishment.
e. The TVA was originally defined as a DFE under the IG Amendments Act of 1988. The Bil to Amend the
Inspectors General Act of 1978 (5 U.S.C. App) to Provide That Certain Designated Federal Entities Shall Be
Establishments Under Such Act, and For Other Purposes (P.L. 106-422) redesignated the TVA as an
establishment.
f.
The IG Amendments Act of 1988 originally defined the Federal Home Loan Bank Board as a DFE. The
Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (P.L. 101-73) abolished the board,
replaced it with the Federal Housing Finance Board (FHFB), and designated the FHFB as a DFE. The Housing
and Economic Recovery Act of 2008 (P.L. 110-289) abolished the FHFB, replaced it with the FHFA, and
designated the FHFA as an establishment.
g. The NRO and NSA were originally defined as DFEs under the Intel igence Authorization Act for Fiscal Year
2010 (P.L. 111-259). The Intelligence Authorization Act for Fiscal Year 2014 (P.L. 113-126) redesignated the
NRO and NSA as establishments.
h. The FCC was originally defined as a DFE under the IG Amendments Act of 1988. The Consolidated
Appropriations Act, 2018 (P.L. 115-141) redesignated the FCC as an establishment.
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Table A-2. Designated Federal Entity (DFE) IGs
As of November 2023
Year
Original
Office of Inspector General
initially
authorizing
(current name of agency listed)
established
statute
Amtrak
1988
P.L. 100-504
Appalachian Regional Commission
Board of Governors of the Federal Reserve and the Bureau of
Consumer Financial Protectiona
Commodity Futures Trading Commission
Consumer Product Safety Commission
Corporation for Public Broadcasting
Equal Employment Opportunity Commission
Farm Credit Administration
Federal Election Commission
Federal Labor Relations Authority
Federal Maritime Commission
Federal Trade Commission
Legal Services Corporation
National Archives and Records Administration
National Credit Union Administration
National Endowment for the Arts
National Endowment for the Humanities
National Labor Relations Board
National Science Foundation
Peace Corps
Pension Benefit Guaranty Corporation
Smithsonian Institution
U.S. International Trade Commission
U.S. Postal Serviceb
U.S. Securities and Exchange Commission
Denali Commission
1999
P.L. 106-31
Election Assistance Commission
2002
P.L. 107-252
Defense Intelligence Agency
2010
P.L. 111-259
National Geospatial-Intelligence Agency
2010
P.L. 111-259
Committee for Purchase From People Who Are Blind or Severely
2015
P.L. 114-113
Disabled (AbilityOne)
U.S. International Development Finance Corporation
2018
P.L. 115-254
Source: CRS analysis of the United States Code and original authorizing statutes for the listed IGs.
Notes: “Designated federal entities” (DFEs) are defined in 5 U.S.C. §415(a)(2). The table does not include
previous DFE IGs that were abolished.
a. The Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203, §1011 and §1081)
expanded the jurisdiction of the IG for the Federal Reserve Board to cover the Consumer Financial
Protection Bureau.
b. The Postal Service Reform Act of 2022 (P.L. 117-108; §209(a)) expanded the jurisdiction of the IG for the
U.S. Postal Service to cover the Postal Regulatory Commission.
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Table A-3. Other Permanent IGs
As of November 2023
Year
Original
Office of Inspector General
initially
authorizing
U.S. Code
(current name of agency listed)
established
statute
citation
Government Publishing Officea
1988
P.L. 100-504
44 U.S.C. §3901-3903
Central Intelligence Agency
1989
P.L. 101-193
50 U.S.C. §3517
Library of Congress
2005
P.L. 109-55
2 U.S.C. §185
U.S. Capitol Police
2005
P.L. 109-55
2 U.S.C. §1909
Architect of the Capitol
2007
P.L. 110-161
2 U.S.C. §1808
Government Accountability Office
2008
P.L. 110-323
31 U.S.C. §705
Intelligence Community
2010
P.L. 111-259
50 U.S.C. §3033
Source: CRS analysis of the United States Code and original authorizing statutes for the listed IGs.
Notes: Includes agency IGs that operate under individual statutes outside of the IG Act of 1978, as amended.
The table does not reflect other permanent IGs that were abolished.
a. Formerly the Government Printing Office.
Table A-4. Special IGs
As of November 2023
Year
Original
Office of Inspector General
initially
authorizing
U.S. Code
(current name of agency listed)
established
statute
citation
Special Inspector General for Afghanistan
Reconstruction (SIGAR)
2008
P.L. 110-181
5 U.S.C. §415 note
Special Inspector General for the Troubled
Asset Relief Program (SIGTARP)
2008
P.L. 110-343
12 U.S.C. §5231
Special Inspector General for Pandemic
Recovery (SIGPR)
2020
P.L. 116-136
15 U.S.C. §9053
Source: CRS analysis of the United States Code and original authorizing statutes for the listed IGs.
Notes: Includes IGs that operate under individual statutes outside of the IG Act of 1978, as amended, and have
statutory sunset dates. The table does not include previous special IGs that expired or were abolished.
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Appendix B. Selected IG Statutory Authorities and
Requirements
Table B-1 compares selected statutory authorities and requirements across the four different types
of statutory IGs in the federal government. Unless otherwise noted in bold, the listed authorities
and requirements apply to all IGs grouped under each type. The table focuses on IG authorities
and requirements that are expressly mandated in the applicable authorizing statute. Although
special IGs and other permanent IGs in the legislative branch are not created under the IG Act,
their authorizing statutes incorporate—and therefore make applicable—certain provisions of the
IG Act. These “incorporation by reference” provisions are subject to some interpretation. Even
when the authorizing statute for a special IG or other permanent IG in the legislative branch
clearly and unequivocally incorporates a specific provision of the IG Act, interpretation may vary
regarding whether subsequent amendments to that incorporated provision apply to the IGs if they
occurred after the enactment of the IG’s authorizing statute.153
The list below defines and explains recurring terms included in the table:
• Identical requirement. The requirement is identical to the corresponding
requirement in the IG Act. The authorizing statutes for the listed IGs explicitly
state the identical requirement or clearly incorporate the sections of the IG Act
that contain the requirement. Applies to the listed IGs.
• Similar requirement. The requirement is similar, but not identical, to a
corresponding requirement in the IG Act. The authorizing statutes for the listed
IGs explicitly state the similar requirement or clearly incorporate portions of the
sections of the IG Act that contain the requirement. Applies to the listed IGs.
• No similar requirement specified in authorizing statutes. The authorizing
statutes for the listed IGs do not explicitly state the requirement, nor do they
incorporate sections of the IG Act containing the requirement. Does not apply to
listed IGs.
• Unclear requirement. The authorizing statutes for the listed IGs incorporate the
IG Act section that includes the requirement, but the requirement was added as an
amendment to the IG Act after enactment of the authorizing statutes for the listed
IGs. May or may not apply to the listed IGs.

153 Although an argument can be made that the incorporation by reference includes subsequent amendments to the
referenced statute, it would also appear that traditional canons of statutory interpretation may suggest that the proper
construction of the authorizing statutes is that they incorporate only the text of the referenced provisions as they existed
at the time the applicable authorizing statute was adopted. See Hassett v. Welch, 303 U.S. 303, 314 (1938), wherein the
court stated, “Where one statute adopts the particular provisions of another by a specific and descriptive reference to
the statute or provisions adopted, the effect is the same as though the statute or provisions adopted had been
incorporated bodily into the adopting statute…. Such adoption takes the statute as it exists at the time of adoption and
does not include subsequent additions or modifications of the statute so taken unless it does so by express intent.” Legal
interpretation of the treatment of provisions incorporated by reference are beyond the scope of this report.
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Table B-1. Comparison of Selected Statutory Authorities and Requirements for IGs
Unless otherwise noted in bold, the listed authorities and requirements apply to all IGs grouped under each type
Other Permanent IG
Authority or
Establishment
DFE
Requirement
IG
IG
Executive Brancha
Legislative Branchb
Special IG
Appointment, Removal, Term Limits, and Oversight Jurisdiction
Oversight
Single-agency jurisdiction. Oversight of programs, operations, and activities under the jurisdiction of a single
Cross-agency jurisdiction. Oversight of
jurisdiction
affiliated federal entity or entities (see Table 3 for examples of exceptions)
a program, operation, or activity
irrespective of agency jurisdiction
SIGPR: Jurisdiction over
Department of the Treasury’s
CARES Act Title IV programs
Appointment
Appointed by President
Appointed by the affiliated
Appointed by
Appointed by the
Appointed by the President with the
method
with the advice and
entity head
President with the
affiliated entity head
advice and consent of the Senate
consent of the Senate
USPS IG: Appointed by a advice and consent of
USCP and AOC IGs:
SIGAR: Appointed by the President
majority vote of the Postal
the Senate
Appointed by the
alone
Board governors and the
affiliated entity head in
Postal Regulatory
consultation with other
commissioners.d
legislative branch IGsc
Removal or
Removal or transfer by
Removal or transfer for
Removal only by
Removal only by
Removal or transfer by President
transfer method
President for any
any reason by the entity
President for any
affiliated entity head for
for any reason
reason
head, or upon written
reason
any reason
concurrence of two-thirds
USCP IG: Removal
majority of the governing
only upon unanimous
board, committee, or
vote of all voting
commission
members of the Capitol
USPS IG: Removal for
Police Board for any
cause only upon written
reasonf
concurrence of seven out
of nine Postal Board
governors and three
Postal Regulatory
commissionerse
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Other Permanent IG
Authority or
Establishment
DFE
Requirement
IG
IG
Executive Brancha
Legislative Branchb
Special IG
Congressional
President to notify
Affiliated entity head to
President to notify
Affiliated entity head to
President to notify Congress, in
notification of
Congress, in writing,
notify Congress, in writing, congressional
promptly notify
writing, the substantive rationale for
removal or
the substantive rationale the substantive rationale
intelligence
Congress, in writing,
removal or transfer no later than 30
transfer
for removal or transfer
for removal or transfer no
committees, in
the reasons for a
days before the action
no later than 30 days
later than 30 days before
writing, the
removal only upon such
before the action
the action
substantive rational
removalg
for removal no later
USCP IG: Capitol
than 30 days before
Police Board to notify
the action
certain congressional
committees, in writing,
the reasons for removal
only upon such
removalh
Term limit
None
None
None
USPS IG: Seven-year term limit for unlimited
USCP IG: Five-year term limit for up to three
number of termsi
termsj
Salary, Appropriations, and Budget Formulation
Salary
Executive Schedule (EX) Not less than the average
EX III maximum, plus
Specific dol ar amount
EX III maximum, plus 3%
III maximum, plus 3%
total compensation of the
3%
below the salary of the
affiliated entity’s senior
affiliated entity head
level executives
GPO and LOC IGs:
No specific amount or
pay scale specified in
authorizing statutesk
Budget
Standalone annual budget estimate separate from affiliated agency’s budget
No similar requirement
Unclear requirementm
formulation
estimate
specified in authorizing
statutes (although
subject to congressional
direction)l
AOC and GPO IGs:
Unclear requirement
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Other Permanent IG
Authority or
Establishment
DFE
Requirement
IG
IG
Executive Brancha
Legislative Branchb
Special IG
Appropriations
Separate appropriations
No separate account
Separate
No separate account
No similar requirement specified in
account in President’s
appropriations
authorizing statutesn
budget
account in President’s
budget
Reporting Requirements
Semiannual or
Required to issue a semiannual report that
Similar requirement (IGs must issue a semiannual
Required to issue quarterly reports
quarterly reports
summarizes IG activities specified in the IG Act
report, but required elements of the report can
that include a detailed statement of
vary)
all obligations, expenditures, and
revenues associated with covered
programs and activities
Seven-day letter
Required to report “particularly serious or flagrant
Similar requirement
Identical requirement
Unclear requirement
problems, abuses, or deficiencies” in agency programs
GAO and USCP IGs:
or operations to affiliated entity head, who must
No similar requirement
transmit the report unaltered to appropriate
specified in authorizing
congressional committees and subcommittees within
statutes
seven days
Top management
Required to report the “most serious management and performance challenges
No similar requirement specified in authorizing statutes
challenges
facing the agency” and the agency’s progress in addressing those challenges
IGs for government corporations: Statutorily exempto
Transparency of IG Reports and Recommendations
Transparency of
Semiannual reports. Required availability to the public
Semiannual reports.
Semiannual reports.
Quarterly reports.
reports and
“upon request and at a reasonable cost”
No similar
Identical requirement
SIGTARP: Available to the public
recommendations
requirement specified GAO: No similar
upon request
in authorizing statutes requirement specified in SIGAR: Available on a public
authorizing statute
website
SIGPR: Available to Congress
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Other Permanent IG
Authority or
Establishment
DFE
Requirement
IG
IG
Executive Brancha
Legislative Branchb
Special IG
Audits and inspections or evaluations on website. Reports
Audits and inspections
Audits and inspections or
Audits and inspections or evaluations
(or portion of the reports) must be posted on the
or evaluations on
evaluations on website.
on website. Unclear requirement
OIG’s website within three days of submitting final
website. No similar
No similar requirement
versions of the reports to the affiliated entity head
requirement specified specified in authorizing
in authorizing statutes statute
Documents with recommendations on website. Any
Documents with
Documents with
Documents with recommendations on
“documents making a recommendation for corrective
recommendations on
recommendations on
website. Unclear requirement
action” must be posted on the OIG’s website within
website. No similar
website. Unclear
three days of submitting the final recommendation to
requirement specified requirement
the affiliated entity head
in authorizing statutes GAO IG: No similar
requirement specified in
authorizing statute
Source: CRS analysis of the IG Act and authorizing statutes for IGs established outside of the IG Act.
Notes: The table focuses on IG authorities and requirements that are expressly mandated in the applicable authorizing statute. Although special IGs and other permanent
IGs in the legislative branch are not created under the IG Act, their authorizing statutes incorporate—and therefore make applicable—certain provisions of the IG Act. It
should be noted that these “incorporation by reference” provisions are subject to some interpretation. Even when the authorizing statute for a special IG or other
permanent IG in the legislative branch clearly and unequivocally incorporates a specific provision of the IG Act, interpretation may vary regarding whether subsequent
amendments to that incorporated provision apply to the IGs if they occurred after the enactment of the IG’s authorizing statute.
a. Includes IGs for the Central Intelligence Agency and Intelligence Community.
b. Includes the IGs for the Architect of the Capitol (AOC), Government Accountability Office, Government Publishing Office (GPO), Library of Congress (LOC), and
U.S. Capitol Police (USCP).
c. 2 U.S.C. §1909(b)(1) (UCSP IG); 2 U.S.C. §1808(c)(1)(A) (AOC IG).
d. 39 U.S.C. §202(e)(2).
e. 39 U.S.C. §202(e)(3).
f.
2 U.S.C. §1909(b)(3).
g. Pursuant to 2 U.S.C. §1909(b)(3), the Capital Police Board must communicate the reasons for removing the USCP IG prior to the end of his/her term to the House
Committee on Administration, Senate Committee on Rules and Administration, and House and Senate Committees on Appropriations.
h. The committees include the House Committee on Administration, Senate Committee on Rules and Administration, and the House and Senate Committees on
Appropriation. See 2 U.S.C. §1909(b)(3).
i.
39 U.S.C. §202(e)(2).
j.
2 U.S.C. §1909(b)(2).
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k. The authorizing statute for the GPO IG states: “Any authority to make payments under this title [enacting this chapter and provisions set out as notes under
Sections 101 and 3901 of this title] shall be effective only to such extent as provided in appropriations Acts.” See P.L. 100-504, Title II, §205, 102 Stat. 2531; 39
U.S.C. §3901 note.
l.
In practice, the LOC IG has compiled and submitted standalone annual budget estimates. In recent years, the House and Senate Committees on Appropriation have
called for legislative branch agency budget requests to include separate sections for IG budget estimates. U.S. Congress, Conference Committee, conference report
to accompany H.R. 5895, 115th Cong., 2nd sess., H.Rept. 115-929 (Washington, DC: GPO, 2018), p. 201; and U.S. Congress, Senate Committee on Appropriations,
report to accompany S. 1648, 115th Cong., 1st sess., S.Rept. 115-137 (Washington, DC: GPO, 2017), p. 5.
m. In practice, SIGAR and SIGTARP have compiled and submitted standalone annual budget estimates for their respective offices.
n. In practice, the President’s annual budget submission has historically provided separate accounts for both SIGAR and SIGTARP OIGs.
o. These include government corporations defined in 31 U.S.C. §9101. According to a CIGIE report, intelligence community IGs do not issue public top management
and performance challenges reports. See CIGIE, Top Management and Performance Challenges Facing Multiple Federal Agencies, April 2018, p. 1, at
https://www.oversight.gov/sites/default/files/oig-reports/CIGIE_Top_Challenges_Report_April_2018.pdf.

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Statutory Inspectors General in the Federal Government: A Primer

Author Information

Ben Wilhelm

Analyst in Government Organization and
Management

Acknowledgments
The original author of this report is former CRS analyst Kathryn Francis. Graphics and tables in
this report were designed by Amber Wilhelm, Visual Information Specialist.

Disclaimer
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Congressional Research Service
R45450 · VERSION 11 · UPDATED
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