1. Opportunities and Challenges
Legal Approaches & Access to Information
The OIG Report –
Opportunities and Challenges
Russell J. Gaspar 1

2. The More Things Change . . .
The issued addressed by OIG are not new – they’ve been the subject of discussion since at least the External Review process in the mid-1990s
The OIG report finally provides a strong agency impetus for improvement
Will the new initiatives be supported by the industry?

3. APHIS Certification of DQPs
APHIS rejected this in 1979
Opportunities:
Outreach to equine vets
More consistent enforcement based on uniform training
Eliminate enforcement disparity when VMOs are not present
Eliminate DQP conflicts of interest
Accountability -- direct discipline of ineffective DQPs
Challenges:
Rulemaking process – whether and when?
Opposition from HIOs?
Staffing, training and money to train and monitor DQPs

4. Decertification of HIOs
Opportunities:
Clear focus on the effectiveness of HIO programs to impose and enforce penalties
Improve APHIS’s regulatory ability to decertify an HIO program that fails to enforce the HPA
Challenges:
Rulemaking process
Opposition from HIOs?
Staffing, training and money to monitor HIO operations

5. Uniform Penalties Opportunities:
Continue one of the good aspects of the Operating Plan concept
Obtain consistent and somewhat stronger penalties/deterrence across the HIO programs
Implement via HIO rule books in 2011
Challenges:
Opposition from HIOs?
Will fewer tickets be written?
The $64 Question—What happens to APHIS civil enforcement?

6. Increased Funding Can APHIS get the money?
Authorization limitation in HPA
Current political climate
Appropriations after FY 2011
If APHIS gets the money, will it be enough?