Audit of the Regional Counsel Role in the Enforcement Process
Report Information
Recommendations
Develop a new position description and conduct a position evaluation
for the dual role Regional Counsel/Enforcement Supervisor position
and have headquarters Office of Human Resources verify the
evaluation outcome.
Ensure that a dual role holder meets the requirements for the new
position.
Develop a management control to ensure that when an agency
attorney is also assigned a line function, written legal advice provided
by this individual is easily distinguished from non-legal advice.
Develop for agency attorneys who are also assigned a line function
guidance to convey the need to clarify in conversations involving
sensitive information that the information disclosed is of a sensitive
nature.