The Perfect Storm of Self-Oversight
The Federal Whistleblower Protection Office (FWPO) has achieved what government efficiency experts are calling "bureaucratic perpetual motion" after discovering that Case File #WB-2019-4471—a complex three-year investigation into alleged procedural violations—was actually an anonymous complaint the office filed against itself.
The revelation emerged during a routine internal audit when Senior Investigator Margaret Kowalski realized she had been investigating her own supervisor's handling of a complaint she herself had submitted using Form WB-227-C, which her department designed specifically for investigating the department that designed Form WB-227-C.
Photo: Margaret Kowalski, via pediatrics.wustl.edu
"This represents the pinnacle of governmental self-sufficiency," explains Dr. Richard Pembley of the American Institute for Administrative Sciences. "They've created a closed-loop system where oversight oversees itself overseeing its oversight. It's beautiful in its completeness."
The Investigation Investigates Itself
FWPO Director Janet Morrison stressed that the situation, while "visually confusing," demonstrates the office's commitment to thorough investigation regardless of target. The original complaint, filed by someone identified only as "Concerned Employee #4," alleged that the office was not properly investigating complaints about its investigation procedures.
Photo: Janet Morrison, via janetmorrisonbooks.com
"We take all whistleblower complaints seriously," Morrison explained during a press conference held in the same conference room where investigators had been meeting to discuss the investigation they were unknowingly conducting into themselves. "The fact that we've been investigating ourselves only proves our dedication to accountability, even when we don't know we're being accountable to ourselves."
The investigation file reveals remarkable thoroughness. Over three years, investigators conducted 47 interviews with office staff about office staff, reviewed 2,340 pages of internal documents about reviewing internal documents, and held monthly progress meetings to discuss why progress meetings weren't producing progress.
Procedural Complications
The discovery has created what legal experts describe as "a jurisdictional ouroboros." The FWPO must now determine whether it can legally investigate its investigation of itself, or whether the investigation of the investigation requires a separate investigation by a different office.
"We're in uncharted territory," admits Associate Deputy Director for Self-Investigation Harold Chen. "Our procedures manual has seventeen chapters on investigating other agencies, but nothing about investigating ourselves investigating ourselves. We're essentially making up the rules for investigating the rules we made up."
The office has established a Special Working Group on Self-Investigative Protocols, chaired by the same Margaret Kowalski who originally filed the complaint that started the investigation she was assigned to investigate. The working group's first recommendation was to form a subcommittee to investigate whether the working group has the authority to investigate its own investigation authority.
The Paper Trail of Confusion
Internal documents obtained through a Freedom of Information Act request (filed by the FWPO against itself) reveal the investigation's byzantine complexity. Investigators spent eight months trying to interview "Concerned Employee #4," unaware that Concerned Employee #4 was Margaret Kowalski, who was leading the effort to locate herself.
"We kept missing each other," Kowalski explained. "I'd schedule interviews with myself, then get called away to work on the investigation into why I wasn't available for interviews. It was like chasing my own tail, except the tail was also chasing me."
The investigation generated 847 pages of reports documenting the office's failure to investigate itself properly, written by the same staff members whose investigative failures were being investigated by themselves.
Expert Reactions
Government accountability advocates praised the FWPO's inadvertent achievement. "This is transparency taken to its logical conclusion," explains Sarah Martinez of Citizens for Governmental Oversight. "They've eliminated the traditional barrier between investigator and investigated. It's democracy in its purest form—everyone watching everyone else, especially when everyone else is themselves."
The Office of Inspector General announced plans to investigate the FWPO's investigation of itself, pending approval from the Inspector General Oversight Committee, which reports to the FWPO.
Moving Forward Backwards
Director Morrison announced that the office will continue investigating itself while simultaneously investigating why it was investigating itself, creating what she termed "a robust framework for comprehensive self-accountability."
"We've proven that oversight works," Morrison declared. "We caught ourselves red-handed doing exactly what we were supposed to be doing, just not the way we were supposed to be doing it. That's the kind of rigorous self-examination that makes government work."
The FWPO has requested a budget increase to hire additional investigators to investigate the investigators who are investigating themselves, ensuring that future self-investigations will be properly overseen by the same people conducting them.
Case File #WB-2019-4471 remains officially open, with investigators continuing to investigate themselves for failing to realize they were investigating themselves. The office expects to reach a conclusion sometime after they finish investigating why they haven't reached a conclusion yet.