The Office of Inspector General (OIG) conducted an audit of the Chicago Department of Transportation’s (CDOT) process for loading zone signs and the Department of Finance’s (DOF) process for residential disabled parking signs.

The objectives of the audit were to determine if,

• CDOT accurately recorded, calculated, and collected fees related to loading zone sign installations and renewals;
• DOF accurately recorded and collected fees related to disabled parking signs; and
• significant delays occurred during the application for and installation of loading zone and disabled parking signs.

Loading Zone Signs

We concluded that CDOT did not collect $3.9 million, or 59.9%, of the $6.4 million of annual loading zone fees invoiced in 2013, including amounts due from previous years. We also determined, however, that CDOT inaccurately calculated the installation fees for each of 95 loading zones we reviewed. CDOT charged per sign instead of per zone, causing business owners in the sample to overpay by a total of $10,550. Based on discussion with CDOT and this sample we find it reasonable to assume that all business owners with loading zone sign installations were inaccurately charged.

OIG also found that the City does not have a standardized process to maintain loading zone applications and that 88.4% of installations recorded within CDOT’s system lack complete data. Therefore, OIG was unable to review the entire population of installations to determine the average length of time from initial application to completion of the installation request. However, for the 95 loading zone installations reviewed, OIG determined that installation took an average of 337 days.

Finally, OIG identified a lack of segregation between the billing and collecting functions for loading zone application fees. At the time of the audit, CDOT had assigned a single administrative employee the responsibility of billing, receiving payment, transmitting payments and deposit tickets to DOF, and updating payment status in the program database.

Prior to the arrival of the current CDOT management team, the department had internally identified similar weaknesses in its collection processes and data reliability in a 2013 proposal entitled Loading Zone Restructuring. The proposal was presented to the Mayor’s staff in July of 2013 but has not been implemented. More information on this proposal is available in the background section of this report.

Residential Disabled Parking Signs

OIG determined that DOF collected all installation fees for disabled parking signs, but failed to collect 10% of annual renewal fees resulting in $3,250 of uncollected fees for the period we audited.

DOF did maintain complete data for residential disabled parking signs, and OIG therefore was able to determine that the City installed those signs in an average of 207 days from application to installation.

Recommendations

OIG recommends that CDOT seriously consider restructuring the loading zone process by actively pursuing changes such as those described in its 2013 Loading Zone Restructuring proposal, or that it engage with DOF and City Council to correct problems in the current billing and installation processes. CDOT should also determine all overpayments by business owners and develop the necessary corrective action to issue reimbursements. We recommend that DOF work with City Council to improve the residential disabled parking sign installation process. CDOT and DOF agreed with the OIG’s recommendations and responded with corrective actions the departments have taken or will take. The specific recommendations related to each finding, and CDOT’s and DOF’s responses, are described in the “Audit Findings and Recommendations” section of this report.

Management Response

CDOT and DOF responded to our audit findings and recommendations by describing corrective actions they have already taken and actions that they plan to take in order to address the issues identified in the audit. Both departments agreed with OIG that the sign  processes can and should be improved, and both departments committed to work with City Council to address those aspects of each process that involve aldermanic approval or potential changes to the Municipal Code.

The Office of Inspector General (OIG) conducted an audit of the City of Chicago’s water service focusing on account inventory, meter reading, and temporary water usage practices. The Department of Water Management (DWM) provides and manages water access while the Department of Finance (DOF) manages billing. The Municipal Code of Chicago (MCC) authorizes non-metered water service provision to single family homes and two-unit residences at a rate based on property characteristics rather than water usage. All other structures—old and new—are to receive metered water service. The City’s water system currently serves over 490,000 accounts in the city and suburbs.

The objectives of the audit were to determine whether the City,

• recorded meter read data in its water billing system in a timely manner;
• maintained a complete and accurate inventory of all locations receiving water service; and
• billed the legally required rate for temporary water usage from fire hydrants.

We found that DWM uploaded 100% of meter read data to the City’s water billing system in a timely manner, which is a critical step in the billing process. However, we also found that DWM allowed an estimated $3.9 million in free water use at private construction sites from June 2008 through December 2014. The revenue loss occurred because a permit fee for water used during construction activities was eliminated and the Department did not require property owners to install meters immediately after receiving a DWM water service connection.

In addition, we found that DWM was providing non-metered service to non-residential buildings and residential buildings with more than two units in violation of the MCC. DWM informed OIG that it identified 2,513 noncompliant, non-metered accounts in April 2011 and had worked to reduce that number to 837 by May of 2014. However, OIG’s examination of active accounts found that DWM had not identified all noncompliant non-metered accounts. Moreover, we found that DWM lacked a formal strategy for bringing noncompliant accounts into compliance in a timely manner.

We also found that the City provided $330,981 of water service to properties without collecting payment from property owners. DOF assigned an “inactive” status to accounts for 38 properties that were, in fact, receiving water service or had all necessary structures in place to receive water service. As a result, DOF failed to collect revenue for water used at 26 of those properties. DOF also lacked sufficient safeguards to prevent inappropriate classification of accounts as “permanently removed,” a classification limited to accounts for demolished buildings.

We reviewed a sample of water accounts and concluded that DWM maintained a complete inventory of properties with water service installed. However, we found gaps in the account verification process for new installations that could allow customers to receive water without being billed, although OIG saw no evidence that such an error has occurred.

Finally, we determined that DWM’s billing practices for temporary water usage from hydrants did not comply with the MCC. Specifically,

• DWM charged only one-third the rate prescribed by the MCC; and
• DWM granted fee waivers that are not authorized by the MCC.

In addition, DWM did not reliably track revenue generated from hydrant permits. As a result, we were unable to calculate the revenue lost due to DWM’s practices of granting fee waivers and charging a lower rate than required by the MCC.

OIG concluded that DWM effectively executed two processes that are crucial to the billing process—account creation and timely meter reading. However, DWM did not adequately charge for water use on private construction sites and hydrants, and gaps in DOF’s account status controls allowed some users to receive free water. OIG recommends that DWM ensure that all non-exempt customers are billed for water, bring all noncompliant, non-metered accounts into compliance with the MCC, and correct its billing practices related to hydrant permits. We recommend that DOF consider additional safeguards to prevent or detect inappropriate account classifications that could result in a failure to bill all accounts for water service.

In response to our audit findings and recommendations, DWM committed to begin requiring meter installations at the time new water service is requested and to take appropriate enforcement actions against noncompliant, non-metered accounts. DWM also stated that it will work with City Council to simplify the temporary water usage fee structure in order to ensure that it collects the appropriate fees for hydrant permits. DOF stated that it has created a weekly report that identifies accounts that may have been inappropriately deactivated for further review. DOF also stated that it has already reduced the number of users who can mark an account as permanently removed and will evaluate the feasibility of validating that the properties associated with permanently removed accounts were actually demolished.

The City of Chicago Office of Inspector General (OIG) has completed a follow-up to its October 2014 audit of the Department of Buildings’ (DOB) compliance with the annual elevator inspection requirements set forth in the Municipal Code of Chicago (MCC) § 13-20-100. OIG concludes that DOB’s corrective action related to two of the original audit findings is still pending, and DOB has fully implemented corrective action related to the remaining three audit findings.

The purpose of the 2014 audit was to determine the completion rates of annual elevator inspections for 2013, the timeliness of follow-up inspections, the completeness of inspection fee records, and the effectiveness of DOB audits of inspections performed by private inspectors under the Department’s Annual Inspection Certification (AIC) program. Our audit found that,

• DOB and AIC inspectors inspected only 33.9% of the buildings requiring annual elevator inspections in 2013;

• DOB did not routinely conduct follow-up inspections to ensure timely correction of elevator inspection violations;

• DOB failed to create fee records for 18.0% of completed elevator inspections performed by DOB staff, resulting in estimated unbilled inspection revenue of $50,200 over the course of a year;

• DOB had a backlog of 1,004 paper inspection records that had not been recorded in the DOB computer system as of January 2014, representing delayed billings of $186,155; and

• DOB did not use a statistically valid sampling methodology to select AIC inspections for audit.

Based upon the results of our audit, we recommended that DOB,

• consider expanding the AIC program or work with the Office of Budget and Management (OBM) to fund appropriate DOB staffing levels to ensure that all elevators are inspected annually;

• develop a method to track the timely correction of elevator violations and resolve the existing backlog of open elevator violations;

• take immediate action to ensure fee exception reports are regularly reviewed and necessary corrections are made so that the Department of Finance (DOF) may promptly initiate billing for each inspection;

• document procedures and persons responsible for reviewing the reports, and train staff appropriately;

• issue Certificates of Compliance only after payment of the inspection fee is received;

• work to clear the existing data entry backlog and develop procedures that ensure the timely entry of inspection record data;

• consider revising the audit sampling process so that the sample is statistically valid; and

• provide staff training in generally accepted sampling methods to ensure the quality of future audit work.

In its response to the audit, DOB described a number of corrective actions it planned to take. In May 2015, OIG inquired with DOB regarding the status of the corrective actions the Department had committed to and any other actions it may have taken in response to OIG’s audit. On the following pages we have summarized the five original audit findings and recommendations, as well as the Department’s response to our follow-up inquiry.

Based on DOB’s follow-up response, OIG concludes that the Department is still in the planning stage respecting corrective actions for two original audit findings and has fully implemented corrective actions that address the remaining three audit findings. It is also important to note that the scale of corrective action needed has increased since the time OIG issued the original audit. At the time of the audit, DOB records showed that 6,438 buildings required annual elevator inspections in 2013. However, in response to the audit the Department reviewed its data and found system errors had resulted in a serious understatement of its inventory of buildings requiring inspection. After correcting the errors the Department reported to OIG a building inventory of 9,875 for 2014 and 10,381 for 2015. DOB is to be credited for undertaking this review proactively and for its continuing actions to address the issue.

DOB is working diligently to implement corrective actions. However, it remains important for the Department to continue to strive towards its stated goal of 100% inspection completion rate for elevators citywide. To that end, we urge the Department to continue its expansion of the AIC program and its upgrade of its electronic inspection database. Expanding AIC will increase the total number of annual inspections completed while upgrading its electronic inspection database will allow the Department to conduct timely follow-up inspections.

The Office of Inspector General (OIG) conducted an audit of the Department of Family and Support Services (DFSS) homeless services. The audit focused on how DFSS selected and monitored 57 homeless service providers, known as “delegate agencies,” in 2013 and 2014. During those two years DFSS spent approximately $60.0 million on homeless services provided by delegate agencies.

The objectives of the audit were to determine if,

1. DFSS employed a process designed to ensure that it selected only qualified delegate agencies to provide homeless services;
2. DFSS’s audit process ensured delegate agency compliance with program requirements; and
3. DFSS held delegate agencies accountable for program performance.

OIG found that DFSS cannot assure delegate agencies that it scored all applications correctly. Although DFSS issued an appropriate Request for Proposal (RFP) and generally awarded funding to delegate agencies with the highest scores, OIG found that DFSS scored delegate agency applications inaccurately and inconsistently. DFSS reviewers erroneously awarded points for some programs, incorrectly calculated some applicants’ total scores, and assigned points in excess of the maximum available for an individual question. In addition to these inaccuracies, one application received facility assessment points despite not submitting a facility assessment, and one applicant was incorrectly penalized for having a finding of non-compliance in the previous year. Our review also found that DFSS did not follow its own guidelines for resolving substantial differences between reviewers’ scores. Without accurate and consistent application scoring, DFSS may not select the most qualified applicants.

OIG also found that, in at least once instance, DFSS allowed adverse findings from a program monitoring audit to go unrecorded. The Department uses these audits to monitor delegate agency performance. The audits are principally comprised of record reviews that check service performance reports and evaluate contract compliance. During an OIG observation, a DFSS auditor discovered missing documents, but did not record this issue because DFSS’s audit tool instructed her to report only on the completeness of documents in a chosen sample. The missing documents should have resulted in an adverse “finding” rating, but the Department gave the delegate agency a final rating of “no finding” because the missing documents were not a part of the chosen sample.

Finally, OIG found that while DFSS required delegate agencies to report on their performance, it did not hold them fully accountable for inaccurate reporting. DFSS required agencies to submit quarterly reports on their achievement of homeless service performance objectives and it reviewed the reports for accuracy. However, where DFSS found inaccurate reporting, the agencies were not required to take corrective action to prevent future misreporting. In addition, past misreporting was not recorded as an audit finding and thus was not factored into DFSS’ evaluation of the agency when deciding whether to award future contracts to the agency.

OIG concluded that DFSS may not select the most qualified agencies and fails to hold agencies fully accountable for all potential program inadequacies and inaccurate reporting. OIG recommended that DFSS improve training and quality control over its RFP application review process, design its audit tool to capture all known findings, and should also hold delegate agencies accountable for misreporting performance data.

In response to our audit findings and recommendations, DFSS stated that it has implemented an automated application scoring system to minimize human errors in the application scoring process and, going forward, “will strictly adhere” to its policy to resolve scoring discrepancies. To resolve the issue of unrecorded findings, DFSS has instructed its auditors to record observed issues irrespective of whether they appear in a sample. Finally, DFSS stated that beginning next year it will implement strategies to verify delegate agency performance.

The Plan includes information on audits that OIG is currently considering for 2016, follow-up audits that are likely to occur in 2016, ongoing projects, and audits completed year-to-date. OIG is soliciting comments from City Council, City Hall, and the public.

OIG will consider all comments in finalizing its 2016 Audit Plan. The 2016 Audit Plan will set forth intended subjects for audit but will not provide an order of priority. Work contemplated by the Plan will remain fluid with audits added and adjusted according to a variety of factors such as new events and information as well as resources available.

If you have comments or suggestions for the 2016 plan please email OIG at OIGNoticeandComment@chicagoinspectorgeneral.org

The City of Chicago Office of Inspector General (OIG) has completed a follow-up to its March 2015 audit of the Department of Business Affairs and Consumer Protection’s (BACP) administration of taxicab regulations in 2013. OIG concludes that BACP has implemented corrective actions related to three of the original four audit findings. Corrective action on the remaining finding remains premature because BACP has yet to take final action on medallion sales from the 2013 auction even though the bidding closed over 2 years ago. OIG is unable to verify full compliance with all applicable rules and regulations of the auction process until all sales are finalized.

The purpose of the March 2015 audit was to determine if BACP had an auction process that satisfied MCC § 9-112-480, inspected all taxicabs at least as often as required by MCC § 9-112-050, and accurately tracked whether taxicabs found to have safety violations were brought in for inspection in a timely manner. Our audit found that BACP,

• designed and implemented an auction process that should result in maximum revenue; however, OIG could not fully verify this because BACP had yet to finalize the 2013 medallion auction;

• inspected 99.5% of taxicabs in 2013 at least as often as required by the Municipal Code;

• did not employ inspection quality assurance best practices and did not conduct all brake tests in accordance with the standards of its Public Vehicle Safety Inspection Guide; and

• did not reliably track evidence of compliance with the two-day inspection reporting requirement following issuance of a Notification of Inspection.

Based upon the results of our audit, OIG recommended that BACP,

• take action to ensure that it can account for all required taxicab inspections either by completing the inspections or taking enforcement action against all noncompliant vehicles;

• implement procedures to provide reasonable assurance that it is completing inspections accurately;

• repair or replace the broken brake machine at the Public Vehicle Facility (PV Facility) in order to complete inspections according to its Public Vehicle Safety Inspection Guide or revise the Guide to specify brake test procedures in the absence of the machine; and

• develop a process to ensure that all Notifications of Inspection are submitted to the PV Facility and entered in a timely manner, and that the issue date of the Notification is recorded to ensure that taxicabs do not exceed the two-day inspection deadline.

In September 2015, OIG inquired with BACP regarding the status of the corrective actions the Department had committed to taking in response to OIG’s recommendations, as well as any other actions to address the concerns raised in the audit.

Based on BACP’s follow-up response, OIG concludes that BACP has implemented all the corrective actions that it had committed to in response to the original audit, including making revisions to its Public Vehicle Inspection Guide to specify the visual and manual brake test procedures used in place of the brake machine. It should be noted that, as of November 23, the 2013 medallion auction was yet to be finalized.

The Office of Inspector General (OIG) conducted an audit of the Chicago Department of Transportation’s (CDOT) pavement management program to determine if CDOT managed street maintenance in a cost-effective way that extended pavement life in accordance with the Federal Highway Administration’s (FHWA) pavement preservation program guidelines.[1] As part of this objective, OIG sought to determine if CDOT tracked street conditions and programmed preventive maintenance according to federal guidelines.

OIG found that CDOT’s pavement management program did not comport with FHWA’s pavement preservation program guidelines. Specifically, OIG found that CDOT’s pavement management program, which manages arterial and residential streets separately,[2] had deficits in the areas of street condition data, performance measurement, and preventive maintenance.

OIG found that CDOT lacked sufficient street condition data. CDOT completed a manual pavement condition index (PCI) survey of arterial streets in 2007 and an automated PCI survey in 2014.[3] However, CDOT lacked sufficient iterations of PCI data needed to determine pavement lifecycle trends, such as street deterioration rates, and to program maintenance activities accordingly. CDOT had no PCI data for residential streets. Instead, the Department shared less reliable constituent complaint and visual inspection data with City aldermen to inform their residential street resurfacing requests via the Aldermanic Menu Program (AMP).[4]

OIG also found that, between 2000 and 2014, CDOT performed no preventive maintenance, such as crack sealing and micro-surfacing, on arterial streets[5] and a negligible amount on residential streets. Instead, CDOT invested almost all of its resources in corrective maintenance and repair, such as pothole filling, resurfacing, and reconstruction, which CDOT management characterized as a “worst-first” approach. While some corrective maintenance and repair will always be required, the prevailing view among industry experts is that the “worst-first” approach is costly and ineffective and that regular and comprehensive preventive maintenance should be included as part of an agency’s pavement management program. OIG estimates that, by reallocating $2.9 million per year from resurfacing to preventive maintenance, the City could save $69.5 million over the 15-year lifecycle of a street, for an average annual savings of $4.6 million.

In light of this finding, OIG recommends that CDOT design and implement a pavement preservation program to achieve the most cost-effective means of extending the life of City streets. This recommendation includes specific action items, including developing in-house expertise about pavement preservation techniques, collecting reliable condition data on a routine basis, developing a proactive preventive maintenance strategy, and separating residential street resurfacing from AMP.

CDOT agreed with the majority of OIG’s recommendations. In response to our audit findings and recommendations, CDOT stated that, going forward, the Department will conduct street condition surveys every three years, including an automated PCI survey of arterial streets in 2017. CDOT stated that it will use the data to determine pavement lifecycle trends, to establish pavement performance goals, and to schedule reconstruction, resurfacing, and corrective and preventive maintenance activities accordingly. CDOT also agreed with the value of timely, preventive maintenance and described its plans to integrate such activities in its pavement management program. The Department did not agree with OIG’s recommendation that it holistically manage street maintenance by assigning both arterial and residential planning and decision-making to CDOT subject matter experts. The Department stated that it will not separate residential street resurfacing from AMP, thereby continuing to rely on aldermen to individually plan resurfacing in their wards along with the other needs and priorities addressed through AMP.

[1] FHWA formalizes and disseminates best practices for local and state transportation agencies (TAs) regarding the effective and efficient stewardship of roadways (see http://www.fhwa.dot.gov/). Although federal and state transportation grants do not currently require CDOT to utilize a pavement preservation program, CDOT agreed with OIG that FHWA pavement preservation guidelines are appropriate best practice guidance.

[2] CDOT stated that it uses the Illinois Department of Transportation’s functional classifications of roadways to delineate arterial from residential streets in its network (see http://www.cmap.illinois.gov/documents/10180/97401/FunctionalClassGuidebook.pdf/327d0751-44f7-4f9a-a0e3-e0655df633a3 and http://www.gettingaroundillinois.com/gai.htm?mt=fc). CDOT stated that generally arterial streets have centerline striped markings, exist at every half mile interval of road network, and have significantly higher traffic relative to residential streets.

[3] PCI is a measurement tool developed by the U.S. Army Corps of Engineers that assigns a numerical rating of pavement condition on a scale of 0 to 100, 0 being the worst possible condition and 100 being the best possible condition. ASTM International, “Standard Practice for Roads and Parking Lots Pavement Condition Index Surveys,” accessed October 8, 2015, http://www.cee.mtu.edu/~balkire/CE5403/ASTMD6433.pdf. A manual PCI survey is conducted by experienced engineers or maintenance supervisors who inspect roadways and assign a numerical value to various categories of pavement defect, taking into account the extent and severity of surface distress. An automated PCI survey utilizes technology, such as laser-equipped vehicles, to measure the roadway condition. U.S. DOT, FHWA, “Practical Guide for Quality Management of Pavement Condition Data Collection,” February 2013, 14-15, 18, accessed October 8, 2015,  http://www.fhwa.dot.gov/pavement/management/qm/data_qm_guide.pdf.

[4] Through AMP, each alderman receives $1.32 million per year to address residential street resurfacing among other ward-specific infrastructure needs. City of Chicago, Office of Budget and Management, “2014-2018 Capital Improvement Program,” 4, accessed October 8, 2015, http://www.cityofchicago.org/content/dam/city/depts/obm/supp_info/CIP_Archive/2014CapitalBook.pdf.

[5] At the conclusion of the audit, CDOT shared with OIG that it piloted a one-time crack seal program on 6.5 miles of arterial streets between October 2013 and April 2014. CDOT noted this pilot program in its management response (see Appendix E, page 3). Given the small scale of the program (i.e., one iteration of crack seal on about 1% of the City’s 577 arterial miles during the 15-year period reviewed), OIG determined that the new information did not change the spirit of the audit finding.

The Office of Inspector General (OIG) conducted an audit of the City of Chicago’s hiring process. The audit reviewed hires completed in 2013.[1]

The objective of the audit was to determine if the City filled vacant positions in a timely manner.

Hiring a City employee involves two overlapping processes:

• Budgetary Hiring Plan: The annual personnel budget for each City department includes a gross amount for all budgeted positions, reduced by an estimated personnel turnover amount calculated by the Office of Budget and Management (OBM).[2] The net of these two amounts is approved by the City Council in the annual appropriation ordinance, typically in November, for the fiscal year beginning January 1. Generally, during the last quarter of each year, OBM requires departments to submit a budgetary hiring plan—a proposed staggered schedule of hire dates for vacancies known or expected at January 1—that will ensure the department realizes its budgeted turnover amount. OBM then reviews and, as appropriate, revises and eventually approves each department’s budgetary hiring plan. OBM stated that some departments are not required to follow the budgetary hiring plan process. Those departments include the Office of the Mayor, City Treasurer, and City Clerk.

• Hiring Process: Hiring departments request OBM’s approval to begin the hiring process for each position they seek to fill. OBM evaluates the request for, among other things, its compliance with the OBM-approved department budgetary hiring plan. OBM stated that the approval process may vary for departments with high turnover and/or recruiting difficulty. After OBM’s approval, the departments work with the Department of Human Resources (DHR) to post each job opening, identify and interview candidates, and fill vacancies.

OIG found that it took the City an average of 176 days to fill vacant positions. Further analysis revealed the following three factors contributed to the six-month average time-to-hire:

1. The budgetary hiring plans required departments to delay hiring by an average of 100 days in order to ensure that they did not exceed their net personnel appropriations.
2. Although the average hiring process took 101 days (see below), departments submitted hiring requests on average only 33 days prior to the scheduled hire date. As a result, employees were hired on average 78 days after the scheduled hire date. Neither DHR nor OBM provided guidance to departments regarding when to submit hiring requests in order to hire on or about the first allowable date for filling the position specified under the OBM-approved budgetary hiring plan.
3. An average of 101 days elapsed between the hiring department’s request to hire and the new employee starting work. Nearly one-third of new hires started work more than 120 days after the department’s hiring request. DHR had no formal process to track actual hiring times and was unable to identify specific points and causes of delay.

OIG concluded that a significant portion of the six month time lapse to fill a vacancy, which was intended to keep annual personnel spending within City Council appropriations, in fact reduced personnel spending below City Council appropriation amounts to the potential operational detriment of City departments. In addition, the City has not set formal performance goals for the timeliness of the full hiring process and does not otherwise track the time-to-hire for the filling of departments’ vacancies. Finally, it does not have procedures in place to identify or measure delays and it has not established guidelines to assist departments in timing their hiring requests to meet the scheduled hiring dates set out in their respective OBM budgetary hiring plans.

To ensure transparency and provide clear communication to departments so that they may anticipate operational impact, OIG recommends that OBM formally and expressly communicate to hiring departments any denial of a hiring request and the reason for the denial, rather than allowing denied requests to remain in a status signifying they were still awaiting OBM approval. In addition, OIG recommends that OBM reconsider requiring departments to postpone filling vacancies until they have achieved their budgeted turnover amount. This practice forces departments to delay hiring into vacant positions and to operate with less than the turnover-adjusted net personnel budgets appropriated to them by the City Council. OBM should consider ways to adjust the process, allowing hiring to occur consistent with departments’ operational needs over the course of a fiscal year, and thereby reduce the adverse impact to the operational effectiveness of City departments that may result. OBM could also seek alternative ways to prevent departments from overspending on personnel, intervening only with those departments that are at risk of running over budget.

We also recommend that DHR work with OBM to define time-to-hire goals that include all relevant hiring process activities. DHR should develop procedures to measure hiring process steps in order to identify and remedy sources of delay. DHR should compare actual time-to-hire to the goal for each hire, analyze the results by department, and share its findings with the departments. If OBM continues to control departmental spending by enforcing scheduled hire dates, this guidance from DHR could assist departments in determining when to submit hiring requests in order to hire employees on the scheduled hire dates.

In response to our audit findings and recommendations, OBM disagreed and did not propose changes to the budgetary hiring plan process. OBM stated that its current methods for communicating with hiring departments are sufficient, and that it appropriately delays hiring into certain positions in order to control costs. Furthermore, OBM said that the dates used to calculate timeliness in the audit did not adequately capture the range of decisions made by OBM, DHR, and the hiring departments. OIG maintains that we used the appropriate dates, as confirmed by OBM during the course of the audit, and that it is important to measure the impact of the budgetary hiring plan on overall hiring timeliness. OIG had sought to identify specific points of hiring delays and speak with relevant hiring departments, but found it was not possible because the necessary information was not consistently documented. DHR partially agreed with OIG, stating that it would implement new methods for tracking milestones in the hiring process and identifying sources of delay. Such analysis would not, however, consider the amount of time the position was vacant with no action taken or from the time the hiring department submitted a hiring request until OBM approved it and forwarded it to DHR. DHR also committed to setting a time-to-hire goal for each hiring sequence in collaboration with the hiring department. The specific recommendations related to the finding, and management’s response, are described in the “Findings and Recommendations” section of this report.

[1] We excluded sworn police officers, Board of Elections staff, and other positions listed in the Scope section of this report from analysis because the hiring processes as described to OIG were not comparable.

[2] OBM uses each department’s hiring and vacancy history, as well as an assessment of the department’s operational needs, to estimate an expected employee turnover amount. The turnover amount represents the dollar value of the time between an employee leaving City employment and a new employee being hired—i.e., the time that the position is vacant and thus no salary or wages are paid. OBM reduces each department’s gross personnel budget by the turnover amount, resulting in a net personnel appropriation that is less than the total salaries and wages budgeted for all of a department’s positions.

The Office of Inspector General (OIG) conducted an audit of civilianization opportunities in the Chicago Fire Department (CFD) to identify whether there were positions held by uniformed members that could instead be filled by civilians.[1] OIG and CFD agreed that positions which did not require or benefit sufficiently from firefighter or paramedic training, experience, or credibility, or did not supervise positions engaged in firefighting or paramedic functions, would warrant possible civilianization.[2]

As of January 1, 2014 CFD had 4,639 employees. Ninety-five percent held positions budgeted in the Bureau of Operations, which consisted of five divisions: Fire Suppression and Rescue, Emergency Medical Services, Special Operations, Training, and Airport Operations. The remaining 234 employees held positions budgeted in CFD’s 5 other bureaus and offices: Office of the Fire Commissioner, Office of the First Deputy Fire Commissioner, Bureau of Logistics, Bureau of Fire Prevention, and Bureau of Administrative Services. We compared CFD’s organizational charts with personnel budget data and identified positions that did not appear to be primarily involved in, or had duties in addition to, emergency response and therefore could be eligible for civilianization. We learned that actual job duties were not always documented in position descriptions or titles, as in the case of two firefighters who served as mail carriers. Therefore, we also asked CFD to identify all employees who may have appeared on the budget documents and organizational charts to be assigned to emergency response duties but in fact were not.[3] We ultimately identified and discussed with CFD the positions and duties of 555 uniformed members, including 384 that, as of January 1, 2014, did not appear to be primarily involved in, or had duties in addition to, emergency response. The other 171 were either uniformed members on temporary assignments outside their normal duties, or uniformed members known to have been granted a reasonable accommodation under the Americans with Disabilities Act (ADA).

Based upon the results of our audit, we concluded that,

• CFD assigned 35 uniformed members to positions that did not require firefighter or paramedic training and experience, costing the City an estimated $4.5 million annually in overtime to backfill operational gaps created by these assignments. CFD could save an estimated $1.2 million annually by civilianizing 34 of these positions, returning the uniformed members to operations, and eliminating 1 position.[4]
• CFD provided at least 13 ADA reasonable accommodations either informally or without proper approval. Furthermore, CFD could not determine whether it had identified all uniformed members who had been granted accommodations.

OIG recommends that CFD civilianize 34 of the 35 positions mentioned above because the positions do not legally or operationally require or otherwise benefit sufficiently from firefighter or paramedic training, experience, or credibility, or do not supervise positions engaged in firefighting or paramedic functions. In addition, we recommend that CFD eliminate the commissary liaison position and develop other controls to settle disputes between uniformed members and the vendor.

There are likely to be more positions in CFD that could be civilianized, therefore we recommend that CFD undertake a comprehensive assessment of all uniformed member assignments to identify other opportunities for civilianization.[5] In addition, we recommend that CFD assess temporary assignments before assigning them to uniformed members to determine if the assignments could be performed by civilians. CFD should also develop a method to identify, track, and routinely review all temporary assignments to ensure uniformed members are returned to operations in a timely manner and temporary assignments have not passively defaulted or otherwise evolved into permanent positions.

To ensure transparency and accountability, including for budget and oversight purposes, we recommend that CFD document job descriptions for all positions and ensure the Department of Human Resources (DHR) and Office of Budget and Management (OBM) are informed of the actual responsibilities of uniformed members (not just their titles). This would entail communication about current assignments as well as defining a process to ensure DHR and OBM are informed of future assignments.

Finally, we recommend that CFD comply with the City’s Reasonable Accommodation Policy by ensuring all ADA reasonable accommodation requests are submitted to DHR’s Disability Officer for review and approval or denial.

In response to our audit findings and recommendations, CFD stated that it agreed with OIG’s recommendation for 32 of the 35 positions and described why it disagreed with eliminating one position and civilianizing two remaining positions. CFD also agreed with OIG’s recommendations to assess all positions, monitor and track temporary assignments, and ensure that job descriptions reflect actual responsibilities of uniformed positions. Finally, CFD agreed to comply with the City’s Reasonable Accommodation policy and asserted that it has already implemented compliance procedures responsive to the issues surfaced by OIG’s audit.

[1] The definition of “uniformed members” is established in the Municipal Code of Chicago § 2-36-020 titled “Membership of the uniformed service.” It states, “The following employees of the fire department, namely, the fire commissioner, the deputy commissioners, all chief officers and all subordinate officers and firefighters, fire engineers and paramedics, shall constitute the uniformed service and be known and designated as members of the fire department.” See Appendix A for a full list of job titles included in “uniformed members” and the oath of office to which CFD members swear.

[2] These criteria were based on a CFD position classification study completed in August 1993 by the Chicago Department of Personnel at the request of the Office of Budget and Management. We found them to be reasonable based on similar criteria used in civilianization analyses of the Los Angeles Fire Department, New York Fire Department, Oklahoma City Fire Department, and Wilmington, Delaware Fire Department.

[3] OIG did not independently verify the completeness and accuracy of all position information because it would have required interviewing each CFD employee regarding his or her assigned duties. We relied on CFD to self-report any uniformed members performing duties other than those indicated in the documentation.

[4] In this report we refer to “operations” and “operational positions” as those positions requiring the training, experience, credibility, or supervision of firefighters or paramedics.

[5] For example, New York, NY, Philadelphia, PA, and St. Paul, MN all employ civilians to inspect buildings for fire code compliance. Chicago’s Bureau of Fire Protection employs only uniformed members.