Lack of Compliance with Agency Regulations?

The requests sought the standards for OS&LE and LETC personnel to maintain qualifications and certification. VA Directive 0730 August 11, 2000 was released in response to this request (12 01 19 VA Response12  VA Release (1)). This is verified by the first paragraph in the memorandum in this release 12 VA Release (6) that states OS&LE personnel must adhere to VA Directive and Handbook 0730.  This means all personnel within the VA Police nationwide organization to include OS&LE and LETC personnel fall the same regulatory qualification and certification requirements.

The initial and continuing education for the OS&LE and LETC personnel should have been easy to release as both are spelled out in the Directive 0730 and the associated VA Handbook 0730, but there was no comprehensive release. This raised my suspicion that these two organizations may not be complying with the elements or the spirit and intent of Directive and Handbook 0730. This suspicion was at least partially confirmed by the memorandum found in the release a document within 12 VA Release (6). Per the Directive and Handbook 0730 VA Police personnel have to have initial and annual medical and psychological evaluations and if the OS&LE and LETC personnel were in compliance, the memorandum from Frederick R. Jackson would be unnecessary.

“2. Beginning with FY 12 annual psychological assessments will be accomplished once a year by each OS&LE Special Agent. …” … “Completion of the annual physical examination and psychological assessment is required for each armed Special Agent assigned to OS&LE North and South. …”

Had the armed personnel within OS&LE and LETC been inspected or assessed by an oversight body this element of non-compliance would have been identified and corrected and not require a corrective memorandum. This also raises the question as to what this noncompliance would mean to the US Marshals Service (USMS). The USMS directive (12 VA Release (5)) requires the applicant for deputation to have completed a basic law enforcement training program and have successfully qualified with their weapon. By the Directive 0730, the only basic law enforcement course recognized by the VA Police is course in Little Rock Arkansas. But one of the released applications (12 VA Release (7)) identifies the USAFOSI Academy as the completed course.  The first thought is that a waiver or some other way to substitute a recognized law enforcement academy for the LETC basic officer course would explain this, but no waiver instruction document was released.

Because there are no oversight documents there is no way to know if OS&LE and LETC are in compliance with any aspect of the VA Police regulations. The irony is that OS&LE website states that these personnel inspect VA Police throughout the nation to ensure compliance with the regulations they are at least partially not in compliance and LETC is conducting training on these same regulations while apparently not adhering to them.  If they are currently in compliance, the question to be asked would be how long were they not in compliance and what activities were they responsible for and completed before regulatory requirements were met?