combined-10th-11th-report.pdf

Negotiated Settlement Agreement, Combined Tenth and Eleventh Semi-Annual Report December 2008 COMPLIANCE OVERVIEW The Compliance Unit continues to provide compliance oversight and review policies related to the Agreement. The Compliance Unit is responsible for overseeing the Department's internal Compliance Assessors and providing direction to the assigned personnel to further the Department’s efforts toward compliance with the Agreement. In the revised compliance assessment plan, the Department will conduct monthly assessments for 45 of the 51 Tasks required by the Agreement. The assessments are an ongoing process to refine the report criteria and ensure follow-up when necessary. As identified in the Agreement, the Compliance Unit serves as the liaison between OPD, the IMT, and the Plaintiffs’ Attorneys, and assists with the Department’s compliance with the Agreement. The Unit maintains project implementation tracking on tasks assigned to the three bureaus (Services, Investigation, and Field Operations) and the Internal Affairs Division. Additionally, OIG coordinates cross-organization implementation issues and works to resolve interpretation differences within the Agreement. While serving as liaison between the OPD, the IMT, and Plaintiffs’ Attorneys, the Compliance Unit continues to conduct Monthly Meetings, on behalf of the IMT, to focus on everything from policy, training, and implementation progress to agreement language changes and clarifications. The Compliance Unit continues to be the custodian of all NSA documentation created by the Department and also puts together agendas and tracks meeting minutes, which are distributed to all participants as a record of meetings and discussions held among stakeholders. The meetings have produced changes and clarifications in the Agreement language, modifications to implementation timelines for several Tasks, and a modified review process for publication drafts. COMPLIANCE PROGRESS SUMMARY For implementation, delegation and tracking purposes, Agreement reform provisions were separated into 52 separate Tasks. Only 51 are assessed for actual practice compliance (the 52nd task concerns contractual housekeeping provisions). Only the IMT can deem the Department in compliance, and only after conducting an audit of a task. In order to achieve full compliance, three stages of compliance must be satisfied: policy, training, and actual practice (implementation). Implementation activities and the compliance status of each task are outlined in the Task Implementation Section of this report. Implementation progress is summarized in Table 2. Table 2. Task Compliance Status Tasks in Policy Compliance 51of 51 Tasks in Training Compliance 44 of 44 Tasks in Full Actual Practice Compliance 18 of 51 Tasks in Partial Actual Practice Compliance 21 of 51 The status of each task is reported here as of November 15, 2008. A number of tasks are still not in full actual practice compliance, but have been recognized as being in partial compliance by the IMT. Table 3 lists the 51 tasks with their due dates and summarizes the current state of compliance. 18