Inspector General’s 2021 Statement to Chicago City Council


Madame Chair and Members of the City Council:

Thank you for the opportunity to appear before the City Council Committee on Budget and Government Operations and to submit the following opening statement.

Since our last annual Budget Committee hearing, OIG has continued to execute its mission work to promote economy, effectiveness, efficiency, and integrity in government operations through audits, evaluations, and investigations of City actors and programs. OIG’s national standing is reflected in its inclusion and membership in federal, intergovernmental working groups and task forces, and as subject matter experts called on to present at national government and public oversight conferences, as well as government policy forums hosted by leading academic institutions. The rigor of OIG’s formal processes, standards and multi-disciplinary products across its various mission realms is additionally reflected in the conferral of national awards at the individual project level and, at the organizational level, in OIG’s being the first agency in the City to be found in Full Compliance with all requirements of the consent decree entered in Illinois v. Chicago.

In order to sustain that rigor and standing, OIG must subject itself to formal scrutiny. We do that in part by operating to the outer boundaries of transparency permitted by law, so that those who our work serves, and is designed to serve, this body notable among them, can assess and offer suggestions for how we may improve. The office also invites close, formal, evaluative scrutiny through a triennial Peer Review of processes and operations conducted by an outside team of professionals from the national oversight community. We have just begun a Peer Review process, which will produce formal findings to be reported out publicly in 2022. In the meantime, and throughout 2021, our work has proceeded with minimal interruption despite the exogenous civil and societal challenges affecting us all. Our regular work has grown to an order of magnitude and complexity that cannot be captured in a brief opening statement. Therefore, in the interests of the effective and efficient use of time, attached to this introductory statement, and for the public record, is an addendum providing a narrative compendium of OIG activity and operations over the past year, at present, and in the near future, as well as a summary of the proposed uses of presumed one-time appropriations from federal relief funding.

In closing, I note three trends, one positive and two of concern, that have emerged over the course of 2021. First, public stakeholder knowledge about, interest and engagement in, and use of OIG-generated work is markedly growing, and that work is being put to increasingly sophisticated and dynamic use by civil society. (By way of example, OIG’s Information Portal has been visited approximately 20,000 times in the last 12 months, with more than 45,000 pages of information viewed by the public.) Second, in contrast to that increased public engagement, this Council appears to be engaging with OIG’s work and the Information Portal less. There have been fewer briefings to this body on OIG work this year as compared to prior years. And hearings on OIG reports remain rare and episodic, even where hearings are required by the Municipal Code. To assist you—in most governments, the IG’s principal user is the legislature—we will be building platform capacity to host virtual briefings for the Council at the time of the release of reports. Third, also of concern, OIG findings and recommendations to City departments are being met with agreement as much as ever, but the follow-through on commitments to implement those recommendations has, frankly, fallen off a cliff. This may in part be the product of stresses of the lingering pandemic on government operations but appears more so to be the product of there being no consequence at all to failing to execute on promises made in response to OIG recommendations. We know from inquiries from community stakeholders that this trend is not going unnoticed. In the near term, OIG’s Information Portal will be expanded to include a recommendation tracker for its work, so that you will more easily be able to perform the important role of legislative oversight. In the meantime, OIG remains committed to finding new ways to enable all City stakeholders to make optimal use of our work. We welcome dialogue and engagement with you in the service of helping the City serve all of its constituents in more effective, efficient, and equitable ways, and with the greater integrity and transparency necessary to fostering legitimacy and the trust in government which is required to meet the sobering challenges of the times. I look forward to answering your questions.

Addendum to the 2022 Budget Hearing Statement of the Inspector General
Investigations (OIG-Investigations)
The Municipal Code of Chicago (MCC) limits disclosure of certain aspects of OIG’s disciplinary and criminal investigations. Litigation––whether criminal, civil, or administrative––further dampens OIG’s ability to discuss matters in the public domain and the prudence of doing so. In 2021, OIG’s Investigations Section has continued to process an increased number of complaints from the levels seen several years ago. At the same time, it has moved matters such that the number of cases on OIG’s investigations docket that are open longer than 12 months remains consistently low, with a disproportionate number of those that are open longer than one year involving criminal investigations directed by law enforcement partners. Outreach efforts from our community engagement programming continue to broaden public awareness of the work and functions of the office, which in turn results in more complaints and suggestions for topics for OIG consideration. OIG investigations continue to result in substantial recoveries for the City; two concluded matters this year stemming from OIG investigations resulted in six-figure settlements of claims by the City against contractors and vendors.

Increasingly, investigations, and especially those involving analysis of large datasets or the forensic review of digital evidence by OIG’s Center for Information Technology and Analysis (CITA), are resulting in published reports with findings and program recommendations separate and apart from disciplinary or prosecutorial outcomes. For example, this year, OIG-Investigations reported out the findings of a joint OIG-Investigations—Illinois Secretary of State OIG (ILSOS) investigative and data analytical project involving broadscale inventory control and tracking of thousands of municipal license plates issued to the City by ILSOS. Acting on OIG’s findings and recommendations, the City is working to significantly improve its inventory control and tracking systems and has entered into a collaborative intergovernmental reporting process with ILSOS that will serve as a model for ILSOS’ relationship with localities across the State. Topics of other OIG-Investigative inquiries soon to be reported out in a manner that identifies areas for procedural or operational improvement include reports on the Hilco Smokestack Demolition in April 2020, the May 2021 failures of the Roseland Pumping Station, the conferral of a license to The Giant Penny Whistle in the 25th Ward, and the City’s handling of the aftermath of the search warrant execution at the home of Anjanette Young, among others.

OIG-Investigations has, historically, oftentimes deferred findings and recommendations on violations of the City’s Ethics Ordinance in favor of far more consequential outcomes available from administrative and debarment remedies and criminal investigation, charging and prosecution. This year, OIG-Investigations and the Board of Ethics (BOE) collaboratively devised new consultative and coordinate protocols to address conduct which is simultaneously susceptible to these multiple paralleling tracks to better assure that, going forward, all possible City equities are served and remedies pursued. More generally, the relationship between OIG and BOE—at the level of both the Board and the Office of the Executive Director—has evolved into a broader, more dynamic consultative form that better serves the objective of greater integrity in City operations.

Finally, and in some ways most significantly, in 2021 the OIG-Investigations and Legal Sections have brought to full implementation and operation the collaborative O’Hare 21 Integrity Monitoring Program. OIG is the lead for this innovative multi-agency (OIG, and the Departments of Aviation and Procurement Services) and public-private oversight and contract administration initiative. As hoped and as previously discussed before this body, this working group approach now offers a scalable model for application to all major City construction projects in the future.

Audit and Program Review (OIG-APR)
OIG-APR continues to generate nationally recognized government performance audits, as well as advisories and notifications arising from federal Government Accountability Office standard projects. Over the past 12 months, APR issued reports on the following topics:
• Department of Human Resources (DHR) Employee Performance Evaluation Audit
• Department of Assets, Information and Services (AIS) Police Vehicle Repair and Maintenance Follow-Up
• AIS Information Technology Investments Follow-Up
• Department of Streets and Sanitation (DSS) Commercial and High-Density Residential Recycling Enforcement
• Smart Lighting Funding Transparency (Chicago Infrastructure Trust) Notification
• Development of Capital Improvement Program Audit
• Chicago Department of Public Health (CDPH) Air Pollution Enforcement Follow-Up
• Department of Water Management (DWM) Overtime Management Follow-Up
• Chicago Fire Department (CFD) Discrimination and Harassment
• CDPH Contact Tracing Data Privacy and Security Audit
• Trust Fund Housing Quality Inspections Follow-Up
• DHR Employee Performance Evaluation Follow-Up
• Department of Law (DOL) Sanitation Citation Notification Delay Follow-Up
• DSS Weed Cutting Follow-Up
• Chicago Department of Transportation (CDOT) Driveway Billing 2nd Follow-Up
• Department of Finance (DOF) Municipal Depositories Audit
• Public Building Commission (PBC) Energy Conservation Commissioning

Active performance audits projects in the pipeline include (with projected publication dates as known):
• Tax Increment Financing (TIF) Surplus and Sunshine Audit (October 2021)
• City Council Committee Spending Audit (October 2021)
• CFD Response Times Audit (October 2021)
• Department of Buildings (DOB) Permit Inspections Audit
• DOB/DOL Off-Premise Signs Audit
• Department of Family and Support Services (DFSS) Strategic Contracting Audit
• Neighborhood Opportunity Fund Audit
• Juvenile Intervention Support Center Follow-Up
• CDPH Demolition Debris Recycling Audit
• City Data Quality Advisory
• CDPH Contact Tracing Follow-Up

Consonant with our longstanding practices and national best practice, OIG-APR publishes a draft Annual Plan before formally finalizing it shortly after approval of the City’s budget. It is currently posted to our website,, for review and public comment. Topics included in the 2022 Draft Audit Plan are:
• Department of Business Affairs and Consumer Protection (DBACP) Minimum Wage and Fair Workweek Enforcement
• Department of Cultural Affairs and Special Events (DCASE) Chicago Film Office
• Department of Housing (DOH) Troubled Buildings Initiative
• Department of Planning and Development (DPD) Jobs Covenants
• DPD Large Lots Program and City-Owned Land Inventory
• Standards and Process Compliance of Zoning Board of Appeals (ZBA) Determinations
• Enforcement of Prohibition on Illegal Dumping
• Mayor’s Office for People with Disabilities (MOPD) HomeMod Program
• Complaint-Driven Service Provision Advisory
• Administrative Fines for Vehicle Stickers Inquiry
• Contractor/Vendor Prompt Payment
• Workers’ Compensation Program
• Contract Monitoring and Closeout Procedures
• Capital Project Implementation
• Council Office of Financial Analysis (COFA) Compliance with MCC Reporting Requirements
• Information Security Office (ISO) Information Technology Project Review
• Enforcement of Vehicle Idling Limits
• CDOT Street Resurfacing and Maintenance
• DSS Tree Trimming, Planting, and Removal
• Cleaning of and Service Provided to Encampments of People Experiencing Homelessness
• DSS Street Sweeping Efficiency
• DWM Sewer Cave-In Repair Time
• Water Billing Accuracy
• Chicago Police Department (CPD) and CFD Position Civilianization
• CFD Fire Prevention Inspections
• CFD Overtime Management
• Office of Emergency Management and Communications (OEMC) 311 Call Center Effectiveness

Public Safety (OIG-PS)
The published work of OIG-PS has drawn national use and acclaim, raising the Section to the stature of national leader and model for civilian police oversight bodies. Notably, the rigor of its processes, standards, and work product operating in integrated fashion with OIG’s Legal, CITA and Investigations Sections has resulted in OIG’s being the first agency in the City to be found in Full Compliance with all requirements of the consent decree entered in Illinois v. Chicago. Over the last 12 months, OIG-PS issued reports on the following topics:
• Evaluation of the Use of the Affidavit Override in Disciplinary Investigations of CPD Members
• Evaluation of CPD’s Post-Firearm Discharge Policy
• Report on Chicago’s Response to George Floyd Protests and Unrest
• “Gang Database” Follow-Up
• Urgent Recommendations on CPD’s Search Warrant Policies
• Evaluation of CPD’s Random Review of Body-Worn Camera Recordings Follow-Up
• Second Interim Report: Search Warrants Executed by CPD
• Interactive Flowcharts on the Disciplinary Process for CPD Members
• Review of the Disciplinary Grievance Procedure for CPD Members
• CPD Budget Explainer
• Evaluation of the Demographic Impacts of CPD’s Hiring Process
• CPD’s Use of ShotSpotter Technology
• Review of CPD’s Management and Production of Records Follow-Up

OIG-PS Projects for ultimate public reporting that are in process include evaluative work on the following program topics:
• Consistency and Fairness in the Disciplinary Process for CPD Members
• Data Quality re: CPD Settlements/Judgements
• Wrong Address Search Warrant Executions
• Enforcement of CPD’s Rule 14 (Prohibiting False Reports)
• Racial/Ethnic Disparities in CPD’s Use of Force
• Officer Wellness
• Implementation of Discipline for CPD Members
• Review of CPD’s Equal Employment Opportunity Policy/Practices
• Data Quality Limitations – 911 Response Times
• Homicide Investigative Process/Clearance Rates
• Enforcement of CPD’s Rules 21 and 22 (Duty to Report)
• CPD Promotions

Like OIG-APR, consonant with best practices, and as required by the consent decree, OIG-PS conducts its work in part based on a published Annual Plan. The draft Annual Plan for 2022, which undergoes review and comment by the Independent Monitor for the consent decree and the Office of the Illinois Attorney General (the plaintiff in Illinois v. Chicago), as well as further public input—including input by Council members—includes the following potential descriptive and evaluative projects under consideration for 2022:
• CompStat and Data-Driven Policing
• Annual Performance Evaluations for Police Officers
• CPD’s Latent Print Unit
• CPD’s Community Concerns Program and the City Service Request System
• History and Functions of the Police Board
• CPD’s Organizational Structure
• Operations of CPD’s Education and Training Division
• CPD’s Collection and Use of Sentiment Data
• “Scoop and Run” Transport of Victims of Traumatic Injuries
• Workers’ Compensation for CPD Members
• City and CPD Relationship with Private Police Departments
• Mediation Process for Misconduct Complaints
• Department Response to Allegations of Gender-Based Violence by CPD Members
• Department Response to Survivors of Gender-Based Violence
• Deficiencies in Weapons Qualifications
• Department Compliance with Chicago’s Welcoming City Ordinance
• School-Related Arrests
• Inventory, Use, and Impact of Military-Grade Equipment
• Treatment of Intoxicated or Incapacitated Persons
• Use of Facial Recognition Technology
• Arrest Diversion
• CPD’s Civil Rights Unit
• CPD Language Access Policy Compliance

Additionally, over the last 12 months, OIG-PS has conducted the MCC-mandated review of more than 1,000 closed police disciplinary investigations and issued recommendations to reopen ones it found to be materially deficient.

Center for Information Technology and Analysis (CITA)
In the last 12 months, CITA staff have, in addition to supporting data and data analytical needs for projects across the OIG mission realms, performed the following:
• Operated and upgraded OIG’s transparent, reliable, and user-friendly visualization and filtering of government public information in its public-facing Information Portal. From 10/1/2020 to 9/30/2021, the Portal had over 19,581 visitors who viewed over 45,500 pages of information.
• On-target to implement a new case management system in 2021.
• Administered the installation of a major IT infrastructure expansion to provide additional computer and storage capacity as well as an enhanced Uninterrupted Power Source capacity necessary to support continued expansion of publicly accessible information, as well as to ensure continuity of operations in case of building power loss. Currently, OIG moves approximately 1 billion rows of data daily from various City database applications.
• Supported and staffed City COVID-19 relief programs, including:
o Development of the CDPH Vaccination provider dashboard to monitor vaccine distribution and usage in real time and monitor data for trends and patterns.
o Along with other OIG Sections, detailing of personnel to staff the City’s COVID-19 Point of Dispensing Sites as Site Coordinators at various of the City Colleges and the United Center from January through April 2021, as well as personnel as call takers staffing the City’s COVID-19 Hotline.

CITA continues its expansive and iterative work on OIG’s public Information Portal providing visualization of integrated datasets pertaining to City operations of high public interest. Decisions regarding which aspects of the Portal to develop or enhance are informed by a number of inputs—the evaluative and investigative work of OIG’s mission components; public feedback and suggestions; community surveys; engagement and education meetings; and presentations to community organizations, experts, advocates, and leaders across the City that are developed and facilitated by OIG’s Community Outreach and Engagement Director. The biggest addition in the last year, prompted both by stakeholder feedback and OIG’s mission work, are dashboards and interactive maps for 911 calls for CPD service that include, among other breakdowns and filters, 911 calls designated as behavioral health-related. New CITA-created OIG Information Portal Dashboards to be added this month (October 2021) to the more than 30 existing public dashboards include:
• CFD Fire & Emergency Events (911) dashboard and interactive maps (refreshed daily) showing where reported and logged events occurred by location of service, including all emergency events based on designation by OEMC dispatchers/call-takers
• TIF Transparency dashboard mapping all TIF Districts with corresponding District information and interactive filters for view financial data (fund balance year over year from 2017 to 2021 for each District)
• Levels of Force Disparities dashboard, a new addition to the existing family of dashboards on CPD use of force that allows users to query and view the relationship between the subject responses and the level of force used by CPD sworn members’ responses as reflected on Tactical Response Reports, including by gender and race/ethnicity
• CPD Sworn Members dashboards enhanced to enable more user-friendly visualization, filter and query for title, race, gender, specific month.

2022 Budget and Initiatives
OIG’s total budget is largely determined by an MCC-determined percentage calculator written into OIG’s enabling ordinance. Because the calculator and therefore the resulting OIG appropriation cannot be determined until the end of the budget process for the City in its entirety, OIG usually submits a flat budget (relative to the preceding year), with additional OBM-specified requirements. After doing so, OIG is then informed just prior to the final formulation of the proposed City budget what the ordinance calculator will yield. OIG is then asked to quickly specify how it proposes to spend any additional funds. Both this year and last, our proposed budget as submitted has assumed most of the late-added (above year-over-year flat budget) projected moneys are from one-time sources such that they should not be over-applied to operations that will require sustained funding in out-years. In overview, the additional funding (above flat) is proposed for an application of 80 percent to one-time non-personnel expenditures: