derek kerr, a whistleblower. an audit of the program is a good idea but it should not be a peer review audit. that would just buy into the biases and weaknesses that all whistleblower programs have. it would be important to get to an whistleblower advocacy organization, such as the government accountability project in washington d.c. one of the consultants could advise to the standards that a whistleblower program should have to meet the needs of the whistleblowers in the public. it needs to be an independent audit and not by the same folks. we heard a lot about the rising quantity of complaints, but i want to talk about the quality or value of those complaints. since the inception, the whistleblower program has been plagued by minor complaints. the 2010-2011 civil grand jury found that 36% were true whistleblower complaints alleging fraud, waste, and abuse. then the whistleblower program developed a risk assessment policy that was designed to triage the complaints and sort them out into low, medium, or high risk