Public Accountability Report

Pursuant to the State Officials and Employees Ethics Act (Ethics Act), the Office of Executive Inspector General for the Agencies of the Illinois Governor (OEIG) is an independent state agency that investigates allegations of fraud, waste, abuse, mismanagement, misconduct, nonfeasance, misfeasance, malfeasance, and violations of the Ethics Act and related laws or rules by entities under its jurisdiction. The OEIG’s primary functions are investigations, revolving-door determinations, ethics and harassment prevention training, and hiring and employment monitoring.

Investigations

Initial Review and Processing of Complaints

In fiscal year 2024, the OEIG received 3,035 complaints. Within 30 days of receipt, each complaint must be evaluated to determine whether there will be an investigation, a referral of the matter to another agency, or a declination of the matter. Within this time frame, the OEIG must also assess and record the nature of the complaint for reporting purposes; make all necessary redactions to the complaint and attachments before referring pursuant to statutory requirements; and assess the complaint for any harassment or discrimination allegations to ensure notices for these complainants are sent within five business days.

Opened Investigations

If a complaint is opened for investigation, it is assigned to a team of investigators and attorneys. This team conducts investigative activity, such as collecting and reviewing records and conducting interviews. The OEIG then determines whether there is reasonable cause to believe misconduct has occurred.

Upon conclusion of an investigation and a finding of misconduct, the OEIG provides a copy of its Final Summary Report to the affected state agency and the appropriate ultimate jurisdictional authority, such as the Governor or the board of trustees of a public university. When the OEIG makes a finding of misconduct, it may recommend employee discipline or termination, or other remedial action.

Investigations are split between the General Investigations Division and the Regional Transit Board Division (RTB). In fiscal year 2024, the OEIG received 3,035 complaints (2,822 General and 213 RTB), initiated 214 investigations (163 General and 51 RTB), completed 288 investigations (245 General and 43 RTB), and issued 186 Final Summary Reports that found there was reasonable cause to believe there was wrongdoing. At the close of fiscal year 2024, 246 investigations (200 General and 46 RTB) remained open.

Revolving-Door Determinations

Beginning in 2010, the Ethics Act requires the OEIG to determine whether certain state employees, appointees, and officials who, by the nature of their duties, are restricted from accepting non-state employment opportunities or compensation within one year of leaving state employment. Generally, these revolving-door determinations under the Ethics Act are intended to prevent former public servants who may have personally or substantially participated in contracting, licensing, or regulatory decisions from accepting employment from entities that were directly implicated in those decisions. Therefore, this process serves to ensure employees are making decisions that are in the best fiscal and public interest of the state.

In fiscal year 2024, the OEIG investigated and issued 273 revolving-door determinations. By statute, these determinations must be completed within ten calendar days.

Ethics and Harassment and Discrimination Prevention Training

All state employees, board members, and elected officials under the jurisdiction of the OEIG are required to complete an ethics training program overseen by the Executive Ethics Commission (EEC) and the OEIG on an annual basis. In calendar year 2023, state employees, board members, and elected officials participated in over 172,000 ethics training sessions overseen by the EEC and the OEIG. The OEIG produced ethics training for more than 60,000 employees and officials in agencies directly under the Governor, and approved training plans and materials used by the four Chicago-area regional transit boards and the nine state public universities.

All state employees, board members, and elected officials under the jurisdiction of the OEIG are also required to complete a harassment and discrimination prevention training program annually, and new employees take training within 30 days of starting new employment. In overseeing harassment and discrimination prevention training, the OEIG has worked with the EEC to review and approve training program materials. In calendar year 2023, the OEIG approved 32 harassment and discrimination prevention training programs. This number represents trainings approved in calendar year 2023, including trainings that were administered in calendar year 2023 and in calendar year 2024, as well as duplicate trainings used by multiple entities. For example, one university developed a training that multiple universities administered.

In calendar year 2023, entities under the OEIG’s jurisdiction reported that over 172,000 harassment and discrimination prevention training programs were completed. To further compliance with the training requirements, during calendar year 2023, the OEIG utilized its resources to guide, educate, and collaborate with agencies regarding the training. For example, to assist entities with preparing Ethics Act-compliant harassment and discrimination prevention trainings, the OEIG provided guidance by drafting and circulating materials containing information addressing statutorily mandated minimum requirements.

Hiring and Employment Monitoring (HEM)

The Ethics Act directs the OEIG to “review hiring and employment files of each State agency within [its] jurisdiction to ensure compliance with Rutan v. Republican Party of Illinois . . . and with all applicable employment laws.” (5 ILCS 430/20-20(9)) The OEIG's HEM division conducts compliance-based reviews of state hiring and employment procedures and decisions to ensure that they are lawful, merit-based, and/or justifiable.

As part of HEM’s compliance work, HEM monitors hiring sequences — which include in-person or virtual real-time monitoring of interviews — and conducts desk audits, which are paper-based reviews of agency hiring sequences after the interviews have been completed. HEM’s reviews routinely involve all personnel actions taken during a hiring sequence including the initial hiring planning, posting of the position, screening applicants, interviewing candidates, and selection (or cancellation). In fiscal year 2024, HEM reviewed 60 hiring sequences and performed 54 desk audits. In connection with those activities, HEM monitored 81 interviews in person or virtually, and reviewed 3,520 applications for state employment.

HEM issues Advisories that include a summarization of a specific hiring review conducted by HEM. These Advisories are transmitted to the agency human resources personnel and the Central Management Services Chief Compliance Officer, with copies to the Governor’s office and the head of the relevant agency. Each Advisory contains a summary detailing the subject and scope of HEM’s review; a description of HEM’s conclusions regarding the agency’s compliance with applicable rules and procedures; and recommendations on how to proceed, if necessary. HEM issued 81 Advisories in fiscal year 2024, 12 of which included requests for written agency responses that the OEIG received.

In January 2019, due in significant part to HEM’s work, the federal court entered orders in the Shakman litigation delineating nearly 1,000 exempt positions, which led to the creation of the Exempt List, a comprehensive list of exempt positions for which hiring and employment decisions may be made on the basis of political or other non-merit factors; and an Exempt Employment Plan, which is incorporated in the CEP, for filling positions on the Exempt List. The Exempt Employment Plan provisions set forth procedures for adding or deleting positions from the Exempt List, providing that only the Governor or the EIG may initiate such a change. HEM reviews all Exempt List addition and deletion requests from the Governor’s office and recommends approval of or objection to the proposed change to the EIG, who must respond to the Governor’s request within ten business days unless an extension is sought. Prior to making a final recommendation, HEM conducts a comprehensive review of all available information related to the position and regularly communicates or meets with agency staff regarding questions about the position’s history, duties, reporting structure, and necessity. In fiscal year 2024, HEM made 53 determinations on Exempt List change requests, ultimately recommending approval of 48 additions and five deletions.

The Exempt Employment Plan also provides that candidates selected for exempt positions must meet the minimum qualifications and perform the duties of the exempt position being filled as set forth in the underlying position description: HEM’s work on ensuring and reporting on compliance with its provisions continues. In fiscal year 2024, HEM received and reviewed certification paperwork for 228 candidates. HEM staff further reviewed 166 position description clarifications for positions on the Exempt List to ensure that the modifications did not impact the position’s exempt status.

Regional Transit Boards

The OEIG investigates allegations of waste, fraud, abuse, and other misconduct by officials and employees at the Regional Transit Boards (the Regional Transportation Authority, the Chicago Transit Authority, Metra, and Pace). The OEIG’s investigative work holds individuals accountable for their conduct and deters improper conduct by others. These enforcement and deterrent roles result in significant cost savings by stopping and preventing wasteful and improper conduct. The General Assembly recognized the OEIG’s value and cost-effectiveness by placing all four of the Regional Transit Boards under its jurisdiction in 2011.

Fiscal Year 2025 Activities