Tab
10019923 pt.1
RESPONSES TO ADMINISTRATOR'S 3/10/92 REQUEST
FOR ASSESSMENTS OF PROBLEMS RELATED TO
CONTRACT AND PROGRAM MANAGEMENT
Table of Contents
(updated 4/27/92)
A - Administrator's 3/10/92 Memorandum
- AA/OARM's 3/31/92 Follow-up Memorandum
B - Region I (dated 3/25/92)
— also, followup (dated 4/21/92)
C - Region II (dated 3/27/92)
D - Region III (dated 3/27/92)
E - Region IV (dated 3/26/92)
— also, followup (dated 4/16/92)
F - Region V (dated 3/25/92)
— also, two followups (FAXes dated 4/1/92 and
4/20/92, respectively)
G - Region VI (dated 3/30/92)
— also, followup (dated 4/2/92)
H * - Region VII (dated 3/31/92)
— also, followup (dated 4/14/92)
I - Region VIII (dated 3/26/92)
— also, followup (dated 4/1/92)
J - Region IX (dated 3/26/92)
— also, followup (dated 4/16/92)
K ' - Region X (dated 3/26/92)
L - OSWER (too voluminous; moved to separate binder)
M - OAR (dated 3/31/92)
N - OPPTS (dated 3/27/92)
— also, followups (dated 4/3/92 and 4/17/92)
O - OW (dated 3/27/92)
— also, followups (dated 4/6/92 and A/22/92)
- continued -
CXI
o>
2
CVI
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P - OPPE (dated 3/31/92)
— also, followup (dated 4/2/92)
Q - ORD (dated 3/27/92)
~ also, followup (dated 4/1/92)
R - OARM (dated 4/9/92)
— also, separate responses from OARM's Cincinnati
office (dated 4/3/92) and OARM's RTP office (dated
4/16/92)
S - OIA (dated 3/24/92)
— also, followup (dated 4/13/92)
T - OE (dated 4/3/92)
U - OGC (not yet received by SCCM staff)
V - AO (not yet received by SCCM staff)
W - IG (dated 3/24/92) (but not yet received by SCCM staff)
— also, followup (still being drafted by OIG)
X - OCEPA (dated 3/9/92)
— also, followup (dated 4/2/92)
Y - OCLA (not yet received by SCCM staff)
Z - OROSLR (dated 4/3/92)
NOTE: If you are aware of any inaccuracies in this list, please
contact Michael Northridge, staff, Administrator's Standing
Committee on Contract Management (260-9288).
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
MAR i 0
THE ADMINISTRATOR
MEMORANDUM
SUBJECT: Contract Management Review
TO: Assistant Administrators
Regional Administrators
General Counsel
Inspector General
Associate Administrators
In light of Tccent events concerning significant problems with the management of several
of the Agency's contracts, the Agency is undertaking a thorough review of the strengths and
weaknesses of the Agency's contract and project management efforts.
On April 2, 1992 I will be meeting with all Assistant Administrators, Regional
Administrators, Associate Administrators and other senior officials to discuss our present and
planned efforts to strengthen contract management. In this regard, by March 26,1992, we will
need an assessment of all present or potential problems falling within your purview related to
contract and project management. By March 26, we will also need from you a proposed plan
of action to address any present and potential problems you have identified.
My concerns about contract management are not limited to the specific contracts
identified in recent hearings, but extend to all of our contractual relationships.
The Inspector General's reports make a convincing case that the Agency's internal
management of contracts has been inadequate. I understand the Inspector General believes that
this inadequacy applies to contract and project management at large throughout the Agency. In
particular, the Inspector General believes we may not be receiving appropriate value from our
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contracts due to an Agency culture, built up over the last 20 years, which does not assign a high
priority to contract management In this regard, I expect you to carry out all of the actions
identified in Christian Holmes' attached memorandum which deals with jynmediate steps to
change mis situation. We will not tolerate even the appearance of inadequate management of
contracts.
You should submit your assessment directly to me. Armed with these facts, I will ask
Hank Habicht and Christian Holmes to oversee an effort involving all offices in the Agency to
ensure mat the quality of contract management at EPA is second to none. I view this matter
with the utmost seriousness. If we deal with it effectively it presents an opportunity to improve
permanently our effectiveness. My thanks for your *finipd*flff attention.
William K.
cc: Hank Habicht
Deputy Administrator
Christian R. Holmes
Acting AA/OARM
Attachment: C. Holmes 2/28/92 Memo Re:
Contracts Management
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UNITED STATES ENVIRONMENTAL PROTECTIG;, AGENCY
WASHINGTON. D.C. 204CO
MAR 2 f 1992
OFFICE OF
ADMINISTRATION
ANDRESOUCES
MANAGEMENT
MEMORANDUM
SUBJECT: Follow-up to the Administrator's March 10, 1992, Request
for a Review of EPA'^Zojxfraorts Management
FROM: Christian R. Ho]
Acting Assistant S&dndliistrator
TO: Assistant Administrators
General Counsel
Inspector General
Regional Administrators
Associate Administrators
The purpose of this memorandum is to follow up on the
Administrator's recent request that you provide by March 26, 1992,
an assessment of all present or potential problems falling within
your purview related to contract and program management. The
Administrator attached a copy of my February 28, 1992, memorandum
that outlined immediate and decisive actions taken to correct real
and potential abuses, and restore public credibility. Several
offices (e.g., Regions 6, 10, OCEPA) responded with specific steps
undertaken in support of improved contracts management. However,
the response to date to the Administrator's memorandum is less than
reassuring.
I have received from the Administrator's office six reports to
date (i.e., Regions 1, 2, 3, 10, and the Offices of Water, Research
and Development, and Solid Waste and Emergency Response) and I very
much appreciate these prompt and generally thorough replies. The
absence of a response from other offices and variations in the
level of information provided indicate the need to clarify the
scope of the Administrator's request. Briefly, the information
from all offices should include:
— vulnerabilities that were identified in any program,
management or other audit (e.g.. by OIG or GAO) during the
last five years;
Printed on Recycled Pai
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— vulnerabilities that were identified in any internal
control review pursuant to FMFIA requirements during the
last five years;
— corrective actions initiated or completed to address such
vulnerabilities;
— implementation schedules for any corrective actions not
yet completed;
— the number of contracts managed by each office, broken
down according to type of contract, dollar value and
purpose; and,
— the number of procurement personnel (e.g.. Contracting
Officers), program staff (e.g.. Project Officers, DOPOs,
Work Assignment Managers), and legal staff assigned to
contracts management.
I strongly encourage you to provide as much of this
information as possible before our meeting with the Administrator
this Thursday, April 2nd. The balance of this information should
be submitted no later than Thursday, April 16th. The information
should be sent via FAX to my office (FTS 260-0835).
Your prompt support in this effort would be greatly
appreciated.
cc: Hank Habicht
Senior Procurement Officers
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U.8. ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F.K. FEDERAL BUILDING, Boston, MA 02203
MEMORANDUM
DATE: March 25, 1992
SUBJ: Contract Management Review >*)
FROM: Julie D. Belaga, Regional Administrator/&*'***' &**•**"&*-
TO: William K. Reilly, Administrator
Please understand at the outset that we take our contract management
responsibilities very seriously. Contract support is vital to
carrying out our mission and so we will continue to do what is
prudent to protect these resources.
You can count one Region 1's resolve to carefully look at the
concerns that the IG report and other reviews have surfaced. We will
commit to bring together the many parts of our organization that use
and benefit from these contract services, and chart a course based
on the fact-finding and continuous improvement approach suggested in
Christian Holmes' memo. We agree that this cannot be handled with a
one time, quick fix.
As you requested, we have identified below present and potential
problems related to contracts management and how we intend to
address them.
Major Problem Areas and Proposed Actions
All employees need to know now what is at stake and what to do and
not to do.
ISSUE: All EPA staff who work around onsite contract staff need
to know and live by a common detailed set of ground rules.
They also must know and use the appropriate channels to
resolve any EPA-contractor issues or questions and be
knowledgeable about what the contract allows. Getting the
word out will take a significant effort and needs to be
done quickly.
ACTIONS: We have reviewed the IG reports and other agency materials
related to contracts problems and we are quickly getting
the problems and concerns communicated to our organization
using a practical, detailed, do's and don'ts list
approach.
We will alao be conducting an all employee contract
management awareness course within the next 60 days.
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The onsite contract efforts that are now in place within the region
need to be carefully reviewed.
ISSUE: There are a significant number of onsite contracts in
place now that will need to be looked at to insure that
they are in full compliance with guidelines and recent
contract practice interpretations
ACTION: Senior regional contract managers are now meeting with all
impacted workgroups where contractors are working to
surface and resolve problems. This review will
specifically look at how we can insure that use of onsite
contract services meet the "arms-length" approach
directive.
Clearly, a sustained, top-down approach is needed to develop a long-
term, workable contract management action plan.
ISSUE: solid contract management demands that all levels of EPA
management not only know the rules but also ensure that
they are enforced and that the resources are available to
really do the contract management job at hand.
ACTIONS: Contract management measures will be included in all SES,
and manager performance standard as well as for employees
actively involved in contract activities.
I have designated Patricia Meaney, our ARA, as the
region's Senior Procurement Official (Pat recently served
on the Headquarters Special ARC'S Contract taskforce) and
I have asked her to pull together a regional workgroup to
work with my senior managers in reviewing our current and
future major contract activities.
I ask your support for a FY'94 regional initiative
submitted to OARM to get each region the sorely needed
regional FTE to establish a dedicated contract
review/oversight position and to support day-to-day
contract administration work.
Added, trained regional contract managers are needed to address the
personal-services problem charges being leveled.
ISSUE : Anything that creates the appearance of a employer-
employee relationship is a problem
ACTIONS: We have been, and will continue to be very aggressive
about getting key regional personnel to contract
management rocertification.
We are also augmenting the regional contract project
officers with added trained alternates to address the
technical guidance and personal service issues.
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Other Specific Actions Taken to Address the Recent Contract issues
Flagged by the X<3 and in the Christian Holmes memo include:
<
That we must be able to clearly distinguish between EPA and
contractor staff
All onsite contractors have been instructed to wear badges
and contractor work space has signage clearly displaying
the company name. Major groups of onsite contractor staff
are clustered within the office areas in which they work.
We will review seating and separation issues with each
work group to see if further action is needed.
Contractors have been directed to identify themselves as
contractors in any situation where it might be assumed
that they were representing EPA, such as when they answer
the phone or are involved in meetings.
That prohibited contracting activity work Bust not be contracted for
and potentially vulnerable contract work needs careful review before
being initiated
Careful review is done nf the planned contract work vs
the Prohibited Contracting Activity List And the
Activities of Potential Vulnerability , both as a
statement of work (SOW) is created, And as changes are
proposed.
That regional EPA staff need to continue to retain the expertise to
be able to perform very sensitive, very critical functions in case
there were to be some sort of contract interruption
We have not, and will not, put ourselves in the position
of being totally dependent on contractors for knowing how
to get: our most critical jobs done. Specifically, we
believe EPA needs to continue to know how to do the most
vital contracted work. However, were we to lose contractor
services, there would obviously be a lot of important work
that would go undone as well as significant EPA staff
disruption owing to the services we now get from the many,
hard working onsite contractors.
That contractor training and travel needs close scrutiny
Both of these items are constantly monitored here and
approved on a case-by-case basis. Approval is banari on
the training need being in direct support of the contract
effort. Training is not approved where the contractors
should have been reasonably expected to have had the skill
when they were hired.
Travel is only approved when contractor participation in
the meeting or conference is in direct support of the
contract work, and is of an active nature.
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Other issues addressed
Contractors will not to be included in EPA awards.
We will not be involving contract staff in any onsite
entertainment or parties.
Contractor involvement in meetings with EPA will be
limited to exchanging contract-related project update
information.
I share your concerns about this situation and commit Region 1 to do
its part to ensure that we get our house in order. Our challenge
will be to devise sensible, well crafted solutions that solve the
problem for goody not just get us through another crisis.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION,
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
DATE: April 21, 1992
SUBJ: Review of Region I's Contracts Management
FROM: Julie Belaga
Regional Administrato
TO: Christian R. Holmes
Acting Assistant Administrator
This memorandum transmits Region I's response to your March 31,
1992 request for an assessment of all present or potential
problems falling within our purview related to contract and
program management. I have asked each Division and Office
Director to conduct an assessment within their organizations.
The attached report combines their responses.
If you need further information or clarification, please contact
Pat Meaney or Stephen Perkins, her Deputy and part-time member of
the staff of the Administrator's Standing Committee on Contract
Management, at 617-565-3355.
Attachment
. sJLo
PRINTED ON RECYCLED PAPER
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REVIEW OF REGION I's CONTRACTS MANAGEMENT
April 1992
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Vulnerabilities that were identified in anv program, management
or other audit (e.g. by OIG or GAP) during the last five years.
Corrective actions initiated or completed to address such
vulnerabilities. Implementation schedules for any corrective
actions not yet completed.
SDPERFUND RELATED CONTRACTS
1. A December, 1989 Contracts Operations Review and Assessment
Staff (CORAS) study of Region 1 (memo dated 4/3/90,
Attachment A) indicated one area of vulnerability. This
vulnerability was that there was only one ARCS PO. Since
the study, the Region has added two PO's, one DPO and one
cost estimator.
2. In June of 1990 a Quality Assurance Review of the Region I
ARCS Contracts was conducted by HQ PCMD. Although the
review found that in some instances the time for final work
plan approval exceeded the contractually established time
frames, the nature of the technical work was the cause and
the files were well documented to reflect that fact. No
formal finding or recommendation was issued on this subject.
3. The Eastern Audit Division of the OIG conducted an audit
entitled "Audit Survey on Region I's Efforts to Identify
Costs for Recovery from Potentially Responsible Parties
EPA", (E1SHCO-01-0261) from July 16, 1990 to
January 31, 1991. This audit addressed cost recovery
functions conducted by the Emergency Planning & Response
Branch (removal program), Waste Management Division
(remedial program) and the Superfund Finance Section (both
programs).
In the Findings and Recommendations section of the OIG
report, three removal program vulnerabilities were cited.
First was the need to maintain adequate documentation of
reconciliations. Second, that Interagency Agreement (IAG)
costs were not adequately addressed. And last, that site-
specific timesheets were not attached to travel vouchers.
The three removal program vulnerabilities identified in the
cost recovery OIG audit were addressed in a memo from Don
Berger to Art Pavluvcik, Audit Coordinator. The
vulnerabilities had all been corrected by the date of the
memo. It should be noted that none of the vulnerabilities
resulted in significant losses to PRPs or the government.
OIG recommendations regarding the IDI review were
immediately implemented by the OSC.
The OIG identified that private laboratories under the
Superfund Contract Laboratory Program were having serious
performance problems. This Region also has serious concerns
with this program and has raised these to EPA Headquarters.
The majority of the issues raised by OIG are Headquarters
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related. BSD has been working with Headquarters to improve
National oversight procedures and to implement a stringent
Regional oversight program through an enhanced tape audit
program, detailed laboratory performance status reports
prior to on-site audits, rigorous data validation, and
contractor oversight procedures, as well as requiring data
quality objectives for every project.
4. A February, 1991 DIG audit entitled "Review of Region I
oversight of PRP Superfund post-settlement activities",
(#E1SJDO-01-0145-1100133), noted that the Region's oversight
of its technical enforcement support (TES) contractors needs
improvement. The Region is addressing this vulnerability
under FMFIA in FY92 (see discussion below).
5. In response to a Headquarters request, Region I developed,
in the summer of 1991, an ARCS Vulnerability Assessment,
(see Attachment B) which identified four areas of
vulnerability. Two of the four areas are being addressed
nationally, as well as by the ARCS Regional Management Team:
audit and audit resolution and independent government cost
estimates (IGE's). The two other areas are not, however,
limited to items within the control of the Region: funding
(the way funds are released from Headquarters) and auditing
of subcontracts. In addition, this vulnerability assessment
outlined how Region I instituted control techniques to
ensure integrity of the program.
6. In August 1991, PCMD performed a special Contract Management
Review of the ARCS contracts in Region I (memo dated
11/27/91, Attachment C). The review included one potential
vulnerability directed at regional Contract Officer's
(CD's), regional determination of reasonableness of other
direct costs and travel costs incurred under Program
Management.
In response to the finding that RCOs must increase their
efforts to assure that ODCs and travel costs for Program
Management are reasonable and allocable, a memo was issued
on January 16, 1992 (see Attachment D) which detailed
actions to be taken to address this finding.
7. On August 12-15, 1991 the OIG conducted an unannounced site
review (Audit Report No. E1OHG1-0216) at the International
Depository, (IDI) Incorporated site in North Kingstown, RI.
Paul D. McKechnie, the Divisional Inspector General, sent a
memo dated December 16, 1991 to Paul Keough in which he
stated that there were no significant findings to report as
a result of the review. However, two recommendations
regarding documentation of the site entry/exit log were made
to the On Scene Coordinator and were immediately
implemented.
8. In February, 1992 OIG audit entitled "Final Report on
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Superfund Alternative Remedial Contract Strategy (ARCS)
Contracts in Regions 1, 3 and 5" (E1SGE2-03-0145-2100209)
concluded ARCS failed to meet Agency goals (RI/FS
completions in 18 months). Rather than accelerating the
remediation of Superfund Sites it has been delayed. The
entire report concludes that to a large measure the delays
occurred because of poor performance by the contractors and
lack of administration by the Agency. In the five Region I
sites included, 3 of the reasons reported for delays are RPM
and ORC availability and funding constraints, issues not
related to contractor performance. Headquarters is
currently preparing audit resolution comments.
PROCUREMENT - SMALL PURCHASES
An DIG review conducted in May, 1989 (Report E1BM9-01-0123-
07000000, 12/12/89) identified the following vulnerabilities for
which corrective actions have been taken.
1. Promote full and open competition: Some instances of sole
source acquisitions were noted that did not appear to have
adequate justification. Procurement staff have been made
more aware of the limitations and justification
requirements, and actively work with an initiator to insure
that all other viable options are exhausted first in an
effort to promote full and open competition.
2. Price reasonableness and competition: Competition to
achieve the best price for the government was the practice;
but, the files did not always contain the documentation to
support that for open market purchases over $1,000 (now
$2,500). The procurement staff now uses an EPA Form 1900-
13, Worksheet for Small Purchases, to document the files in
those instances. In addition, each purchase order file also
includes a Small Purchase File Check Sheet that is completed
when the file is created that serves as a check/reminder to
document the file with the appropriate documentation.
3. Training for staff: It was noted that staff on board at the
time did not appear to have all the training desirable, any
recent training experiences, or participate in the Agency
information exchange opportunities available (eg,
procurement conferences). The Performance Standards for all
staff now includes a critical job element pertaining to self
development with emphasis on job related training (subject
to limitations of training and travel budgets), each is
given the opportunity and encouraged to attend the annual
procurement conference, and we work with Headquarters
Procurement Office to bring related training opportunities
to the Region.
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4. Publication of contract actions: Open market procurement
actions in excess of $10,000 were not prominently posted as
required by the Federal Acquisition Regulations (FAR). We
have limited activity of this nature, but all such actions
are now posted on a bulletin board in the Procurement area.
5. Re j.ew the level of staffing: The auditor noted an opinion
that there appeared to be insufficient staffing to support
the volume of procurement activity. At the time only one
Contract Specialist and one Support Assistant serviced the
needs of the entire Region. We now have three Contract
Specialists and one Support Assistant on board.
An EPA Quality Assurance Review, conducted by PCMD during July,
1990, and documented in a memo from David O'Conner dated 8/20/90
identified the following vulnerabilities for which corrective
actions have been taken.
1. Inadequate sole source justifications and reasonableness of
price determinations: Justifications in some instances were
noted to be inadequate and the files not always documented
with a determination of price reasonableness. [See items 1
and 2 above.] The present staff and management is acutely
avare of the sole source issue and have implemented a
proective approach of involvement (i.e., generalists) with
initiators to resolve this issue. All staff on board now
have been cautioned and refreshed in this area. The issue
of price reasonableness has been solved by
institutionalizing the use of the EPA Form 1900-13 as noted
above.
2. No evidence of checking more than one GSA schedule: Staff
did riot always perform a price comparison for multiple award
Federal Supply Schedule purchases. We have now
institutionalized the use of the Small Purchase File Check
Sheet for every procurement activity. This checksheet has a
specific item addressing the need to include the evidence
that a price comparison was done.
3. Failure to include applicable Labor Standards: Not all
service contracts contained the appropriate Labor Standards
(eg, minimum wages, safe and sanitary conditions, etc.) as
required under the Service Contract Act. All service
contracts over $2,500 now have these provisions included.
4. Supplemental clauses for purchase orders not used: The
majority of files did not contain all the correct clauses.
As recommended by the auditor, we now have a pre-printed
check list of clauses that is used in the appropriate
purchase orders.
5. No established procedure for closing out small purchases:
Files lacked evidence of receipt of property and final
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payment in order to effect close-out. We now have a regular
process with Receiving and Finance to provide documentation
that supports the closeout and follow-up on overdue
deliveries to effect the closeout of delinquent purchases.
6. Inadequacy of maintenance of small purchase files: Some
files were issing documents or were poorly organized, etc.
Several steps have been instituted to remedy this situation.
We now use color coded files for a particular year, the
files are located where they can be observed, a sign-out
system is used for files pulled for any reason, a small
purchase file check list is used to be sure all appropriate
documentation is filed, and the files are reviewed
periodically by procurement staff to be sure that they are
being appropriately maintained.
7. Blanket purchase agreement deficiencies: BPA files did not
always contain adequate documentation. In some cases the
files did not reflect the full list of authorized callers
and some calls were apparently being improperly placed. We
now have a single individual responsible for the periodic
review and maintenance of the BPA files. Also, we maintain
a current listing of qualified call ordering officials and
include the appropriate individuals names in the BPA
agreements Potential problems are identified early by the
regular review of the files by the designated staff person
and monthly coordination with Finance.
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Vulnerabilities "that were identified in any internal control
review pursuant to FMFIA requirements during the last five years.
Corrective actions initiated or completed to address such
vulnerabilities. Implementation schedules for anv corrective
actions not vet completed.
1. In FY'91, the Region identified and corrected an ARCS
potential weakness, poorly documented procedures. The
regional PC's and CD's developed six written procedures for
the management of the ARCS contracts. (Conflict of Interest
and Limitation of Future Contracting; ARCS Subcontracting;
Monthly Report and Invoice Review; Award Fee; Use of ARCS
Contractors by BSD; Work Assignment Initiation and Work
Plan Approval).
2. The OIG issued a report of audit findings in February, 1991.
The audit was entitled "Review of Region I oversight of PRP
Superfund post-settlement activities", (#E1SJDO-01-0145-
1100133, reference item 3 above). As a result of this audit
the OIG noted, relative to contracts management, that the
Region's oversight of its Technical Enforcement Support
(TES) contractors needs improvement.
The Region has commtcted to addressing this deficiency in
the FMFIA Corrective /ction Tracking System, CATS #92-9. The
associated implementation schedule is as follows:
* Establish a workgroup to develop guidance on contractor
oversight....December 1, 1991
* Distribute final draft guidance for field testing....
February 1, 1992
* Evaluate results of field testing and modify guidance,
as appropriate April 1, 1992
* Distribute final guidance and establish a system to
monitor its implementation May 1, 1992
CURRENT STATUS - Schedule is delayed due to the change and
enlargement in scope to include ARCS contractors (movement
of PRP oversight woik from TES to ARCS). BSD and WMD are
working together to review ARCS and TES contractors Quality
Assurance Program Plans, ARCS Internal Audits and Contractor
QA reports.
3. Audits by the EPA Inspector General and the General
Accounting Office have identified the lack of Independent
Government Estimates (IGEs) for contractor work assignments
as a Superfund program weakness. This problem was further
identified in a GAO report issued in FY91. The auditors
concluded that a process needs to be developed to ensure
that IGEs are developed for all work assignments in a timely
manner.
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The Region has committed to addressing this deficiency in
the FMFIA Corrective Action Tracking System, CATS #92-10.
The associated implementation schedule is as follows:
* Establish a workgroup to prepare a plan for the
development of a system for the generation of
IGEs....November 15, 199*
* The workgroup gets input irrom various stakeholders to
assist in plan development December 15, 1991
* The workgroup meets with the Army COE and the Bureau of
Reclamation to determine what assistance they might
provide in the development of IGEs...January 15, 1992
* The workgroup reviews existing cost estimate systems
for application by the Region....March 15, 1992
* Develop a pilot IGE generation system..July 15, 1992
* Finalize/implement the IGE generation system...
September 15, 1992
CURRENT STATUS - As of 12/31/91 Region appointed an
independent government cost estimator (versus workgroup) who
has met with various groups (i.e. COE and BUREC). Per OSWER
Directive 9242.2-06 from Holmes and Guimond, as of 2/1/92
all work assignments over $25k nust have an IGE. Region I
is adhering to Headquarters directive utilizing existing
Region I staff, BUREC and COE. FY92 Regional work is being
prioritized to ensure work is not delayed, due to the
absence of an IGE. Development of regional pilot IGE
generation system and final procedures are delayed, pending
availability of IGE coordinator time.
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The number of contracts managed bv each office, broken down
according to type of contract, dollar value and purpose and the
number or procurement personnel, program staff, and legal staff
assigned to contracts management.
The following pages provide the above information for individual
contracts in Region I. Many of these are na4 'onal or zone
contracts. Where procurement personnel are lasted, the positions
are in the region unless it specifically says otherwise.
Listed below are summary statistics on regional personnel serving
in contracts management functions.
Contracting Officers
There are 10 Contracting Officers in Region I. Six are Regional
Contracting Officers (RCOs) in our Superfund Contracts Office.
The other four serve as procurement officials.
Project Officers
There are 5 people serving as Project Officers.
Deputy Project Officers (DPOs)/Delivery Ordev Project Officers
rPOPOs)
There is one person serving as a DPO and two serving as DOPOs.
Alternate Delivery Order Project Officers (ADOPOs)
There are 18 people serving as ADOPOs.
Work Assignment Managers (WAMs)
There are about 130 people currently serving as Work Assignment
Managers.
Legal Staff
There are three lawyers in the Office of Regional Counsel with
assigned contracts management responsibilities.
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Region I TE8 Contracts
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officers
2 (Alliance and COM FPC)
Cost Plus Award Fee (CPAF)
$30,692,471 Total ior Alliance
and COM
$26,156,451 CERCLA
$4,536,020 RCRA
To provide Technical
Enforcement Support for Region
I's CERCLA and RCRA Programs
1 in Headquarters
1 Zone Project Officer in
Headquarters.
3 Region I Project Officers
1 Region I Deputy Project
Officer
Work Assignment Managers
56 CERCLA
28 RCRA
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Region I RCRA Implementation Contract
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officers
Work Assignment Managers
Cost Plus Award Fee (CPAF)
$27,096,426 (Region I
1,521,508)
Regions I - V
To provide Technical Support
to RCRA Region I for the
Base and Corrective Action
Programs
1 in Headquarters
1 Project Officer in
Headquarters.
1 Region I Project Officer
5 RCRA
-------
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Cincinnati
Number of Contracts 1 (ERG)
Type of Contract 68-C1-0018
Total Maximum Dollar Value $30,000,000 (Region 1 buy in)
Purpose Graphic Design Services
Number of Procurement Personnel -
Contracting Officers Cincinnati
Project Officers Cincinnati - Justice Manning
Work Assignment Managers 1
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Headquarters OUST
Number of Contracts 4
Type of Contract Headquarters
Total Maximum Dollar Value $100,000 year / Region I
Purpose OUST Program Support
Number of Procurement Personnel -
Contracting Officer Headquarters
Project Officers Headquarter
Work Assignment Managers 4
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Region I Alternative Remedial Action Contracts (ARCS)
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officers
Deputy Project Officers
RMPs
Legal Staff
Cost Plus Award Fee (CPAF)
$555,992,514
Architectural and Engineering
Services to support the
Superfund Remedial Programs
(e.g., RI/FS, RD, RA)
6
3
3
42
Provided by HQ OGC
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Region I Emergency Response Service Contracts (ERGS)
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Administrative Contracting
Officers
Deputy Project Officers
On Scene Coordinators
Legal Staff
Fixed Rates for Services,
Indefinite Quantity/Indefinite
Delivery with Cost Plus Award
Fee Provisions
$13 Million
Provision of Emergency
Response Services to support
the Regional Superfund Removal
Program
1 (Lead CO for the Guardian
contract is in Region II,
Lead CO for the ETI
contract is in Region III)
14
Legal support is provided by
HQ OGC
-------
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Site Security Services
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officers
Legal Staff
Level of Effort, Cost
Re imbursement
$65,340
To provide Security Services
at the Davis GSR Superfund
site in support of the
Superfund Remedial Program
1
1
Provided by HQ OGC
-------
-------
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Metcalf « Eddy
1
Level of Effort, Cost Plus
Fixed Fee
$3,349,050
To provide technical support
to EPA Region I for NEPA,
wetlands, and marine-related
studies.
Number of Procurement Personnel
Contracting Officer 1 in RTF
Project Officers 1
Work Assignment Mgrs 17
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Number of Contracts
Type of Contract
Arthur D. Little
1
Level of Effort
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officers
Work Assignment Mgrs
$2,991,030
To provide technical support
to EPA Region I for NEPA,
wetlands, and marine-related
studies.
1 in RTP
1
4
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Number of Contracts
Type of Contract
WCH Industries, Inc.
1
Level of Effort
Total Maximum Dollar Value
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officers
Work Assignment Mgrs
$30,141
To provide technical support
to EPA Region I for NEPA,
wetlands, and marine-related
studies.
1 in RTP
1
1
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Tetra Tech Inc.
Region I's Water Quality Branch is overseeing several work
assignments for this contract (#68-C9-0013) managed out of EPA
Headquarters.
Number of Procurement Personnel
Work Assignment Mgrs 1
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Battelle Ocean Sciences
Region I's Water Quality Branch is overseeing several work
assignments for this contract (#68-C8-0105) managed out of EPA
Headquarters.
Number of Procurement Personnel
Work Assignment Mgrs 2
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Zone 1 Technical Assistance Team (TAT) Contracts
Region I Portion
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
2 Roy F. Weston (#68-WO-0036)
Resource Applicatir s, Inc.
(#68-WO-0023)
Level of Effort, Cost
Reimbursement
$42,987,933
To provide technical
assistance to Emergency
Planning, Response and Removal
programs.
Number of Procurement Personnel
Contracting Officer 1 in HQ
Project Officers 1 in HQ
Deputy Project Officer 1
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Zone l Emergency Response Cleanup Services (ERCS) Contract
Region I Portion
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
1 OHM Corp. (#68-01-7445)
Level of Effort, Cost
Reimbursement
To provide Emergency Response
Services to support the
regional Superfund Removal
programs
Number of Procurement Personnel
Contracting Officer 1 in HQ
Project Officers 1 in HQ
Deputy Project Officer 1
Ordering Officers 14
NOTE: Four of the Ordering Officers above also are Ordering
Officers on a Region IV ERCS contract with OHM (#68-81-4001).
There is no additional local Deputy Project Officer for the
Region IV contract.
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Contract Laboratory Program (CLP)
Region I Portion
Number of Contracts 11
Type of Contract Cost per Sample
Total Maximum Dollar Value
Purpose To provide analytical support
(sample analysis) to Region I.
Number of Procurement Personnel
Contracting Officer 1 in HQ
Project Officers 1 in HQ
Technical Project 1
Officer
Lab Contract Number
ABB Env, ME 68-D2-0025
Aquatec, VT 68-D2-0019
68-D2-0021
Ceimic, RI 68-D2-0021
Eerco, MA 68-DO-0161
IEA, CT 68-D1-0082
Resource Analyst, NH 68-D2-0026
Skinner & Sherman, MA 68-DO-0108
68-DO-0109
68-D9-0088
68-D2-0039
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Environmental Services Assistance Team (ESAT)
Region I Portion of Zone I Contract
Number of Contracts
Type of Contract
Total Maximum Dollar Value
Purpose
Cost plus Award Fee
To provide analytical, data
review, QA/QC technical
review, and administrative
support tasks for Superfund
and RCRA programs.
Number of Procurement Personnel
Contracting Officer 1 in HQ
Project Officers 1 in HQ
Regional Project 1
Officer
Contractor
Lockheed Engineering and
Sciences Co.
Contract Number
68-D1-0158
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Technical Operational Support Services (TOSS) Contract
Region I Portion
Number of Contracts
Type of Contract
Total Maximum Dollar Value
of Regional Delivery Orders
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officer
Delivery Order Project
Officers
Alternate DOPOs
Indefinite Quantity/Indefinite
Delivery
$2,502,000
Provision of Data Center, Info
Center, Telecommunications,
CIS Center operations support
and Air, Water, Waste and
Administrative information
systems operation and
maintenance
1
1
1
12
6
in HQ
in HQ
in Region
on Regional
Orders
on National
Orders
Delivery
Delivery
-------
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Labat Andersen inc.
Number of Contracts
Type of Contract
Total Maximum Dollar Value
of Regional Delivery Orders
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officer
Delivery Order Project
Officers
Indefinite Quantity/Indefinite
Delivery
$711,000
Provision of Library and
Record Center operations
1 in HQ
1 in HQ
1 in Region
Alternate DOPOs
5 on Regional Delivery
Orders
-------
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General Office Services for Region I
Number of Contracts 1 Work Inc. (Contract
#68000008)
Type c Contract Fixed Price
Total Maximum Dollar Value $195,148
Purpose Provision of general office
services, including mail,
courier and reception
Number of Procurement Personnel
Contracting Officer 1 in RTF
Project Officer 1
-------
-------
Occupational Medical Surveillance Program
Number of Contracts
Type of Contrac
Total Maximum Dollar Value
(Region 1 portion)
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officer
1 (Contract #D900256N1)
Fixed Price/Indefinite
Delivery
$133,970
Provision of medical
monitoring and surveillance
service for laboratory and
field workers (required by EPA
Order 1140)
1 in RTP
1
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Interaction Associates, inc.
Number of Contracts 1
Type of Contract Fixed Price
Total Maximum Dollar Value $24,990
Purpose Provision of strategic
planning consulting and
facilitation services
Number of Procurement Personnel
Contracting Officer l
Project Officer 1
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Tech Law
Number of Contracts
Type of Contract
Total Maximum Dollar Value
(Region I portion)
Purpose
Number of Procurement Personnel
Contracting Officer
Project Officer
approx $150,000
Provision of legal support
services in the development of
Superfund cases (document
review, file preparation,
records management, etc.)
1 in HQ
\ in Denver (NEIC)
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°-
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
U (I
WR } o 90 APR 3 1990
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Contract Operations Review and Assessment Staff (CORAS)
Assessment in Region 1
FROM: Clem Rastatter, Director
Office of Program Management
TO: Merrill Hohman, Director
Waste Management Division
As you are aware, an assessment of Superfund contract
management activities was conducted by the CORAS office on
December 18 and 19, 1989. The purpose of this review was to
assess the usefulness of various products which have been provided
by Headquarters to the Regions, as well as to identify and discuss
with your staff any contract administration problems or potential
vulnerabilities which may exist. The purpose of this memo is to
provide you with feedback regarding the observations and any
conclusions, as appropriate, which resulted from this visit.
We apologize for the length of time which has transpired
between the CORAS office review and the date of this memo.
However, the intent of the CORAS office has been to complete
visits to all ten Regions, in order to determine any overall
trends or issues nationwide, prior to providing feedback to
Regions individually. In this manner, the more complete picture
which has been obtained should result in a more meaningful
response.
In the area of Headquarters products furnished, we were
pleased to note your use of the CORAS Bulletin and your intention
to utilize the model performance standards for Project Officers,
Deputy Project Officers, and Work Assignment Managers in rewriting
performance standards in the future. Our knowledge of which items
have been most helpful to you should assist us in directing our
future efforts in the area of guidance to the Regions.
APR "i a '90'
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- 2 -
We noted a number of contract management areas which we would
consider to be "strengths." In the ARCS contract area, your
foresight in negotiating "diskette deliverables" from the
contractors is an innovative concept which appears to be working
very well. The ARCS invoice review procedure whereby the
Remedial Project Managers (RPM's) certify their portion of the
invoice to the ARCS Project Officer (PO), prior to invoice
signature by the ARCS PO, is a good one which should help to
.assure adequate review of contractor costs. Also, having the
RPM's evaluate contractor performance at this same time (on the
certification form) should provide an ongoing indication of
performance and should facilitate the performance evaluation board
process.
Your procedure of holding monthly meetings with each ARCS
contractor, to discuss performance and other issues in a timely
manner, is one which we strongly endorse. In the area of
training, the Regionally developed RPM training seminar is a good
product which conveys to RPM's the basic information which they
need. The input we received on training ideas in general,
including the concept of shorter training sessions possibly on
videotape, was valuable and will be kept in mind in future
training decisions.
Additional positive aspects noted were the use of E-mail as a
means of communication, which has been encouraged by the CORAS
office, and the good working relationship with the Regional
contracting officer personnel. Such a relationship between
program and contracting officer personnel should be an advantage
in addressing contract management issues which concern us all.
One of the Regional concerns which we discussed was the
computation of the so called PIRS score, which is a primary factor
in determining which ARCS contractor will get new work. Your
concern that the PIRS considers only technical level of effort
(LOE) and not program management is one which is shared by many
other Regions. As a result, a task force which includes CORAS
representation has been formed to look into this and other related
issues. The chairman of the task force, Dave Stutz of the
Procurement and Contract Management Division (PCMD), can be
reached at 382-2314. You may also provide input to the CORAS
representative, John Comstock, who can be reached at 245-4026.
Additional concerns such as conflict of interest issues,
contractor indemnification, and decreased workload for ARCS
contractors are concerns which have been expressed by nearly all
Regions, and we are working with other appropriate Headquarters
offices to address these concerns. We will keep you advised as to
current developments.
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- 3 -
Lastly, I believe your staff concurs that having only one
ARCS project officer may be insufficient for adequate oversight
and management of seven ARCS contracts. At the time of the
review, the PO was being assisted by a Deputy Project Officer
(DPO) and another employee who had recently been detailed to the
Contracts Management Section for 120 days. While this is
certainly helpful, we would support the assignment of additional
personnel to the ARCS project officer function, and are hopeful
that a way can be found to accomplish this.
Also, consideration might be given to providing training to
the RPM's in areas such as filling out work assignment forms and
establishing cost and hour estimates for contractor work to be
performed. (Tasks currently being performed by personnel within
the Contracts Management Section) This training would preclude
the complete loss of "institutional knowledge" in the event of
turnover in key personnel within the Contracts Management Section.
The CORAS office is available to further discuss this option with
you at your convenience.
We appreciate the time devoted by you and your staff during
the CORAS assessment. If you desire to further discuss any of the
above, feel free to contact Deborah Dietrich or Ken Adams of the
CORAS office at 475-9337.
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REGION X VULNERABILITY ASSESSMENT
Region I had previously identified ARCS Program Management
cost control as a potential vulnerable area under FMFIA.
The following control techniques are in place to ensure the
integrity of the program:
o RPM, Project and Contracting Officer review of work
plans, budgets, Monthly Progress Reports and invoices.
o Monthly meetings with each contractor to discuss
performance and progress.
o Written procedures which establish roles and
responsibilities of Project and Contracting Officers; level
and type of documentation.
o Performance evaluation process.
Our existing procedures provide close scrutiny of the ARCS
contractors. The Region has, however, identified four areas
of vulnerability. They are the following:
1. Audit and Audit Resolution
o The Region needs to be snore aggressive about requests
for audit.
o DCAA is 3-5 years behind on overhead rate audits,
o Inability to obtain audits of contractor invoices.
2. Funding
o The way funds are released leads to a proliferation of
work assignments and work assignment amendments.
-Different accounts require the issuance of
separate work assignments.
-Incremental funding impacts project planning
costs.
3. Subcontracts
o EPA has not audited cost reimbursable subcontracts.
o Mismanagement of subcontractors can lead to costly
changes.
4. Independent Government Estimates (IGEs)
o RPMs, Project Officers, Contracting Officers review
contractor prepared estimates but do not generate IGES.
o Unknown site conditions make it difficult for the
Government to prepare an estimate at project
initiation.
o Lack of Regional engineering estimators.
The Project and Contracting Officers meet on a regular basis
to discuss program improvements in order to reduce potential
vulnerabilities. The Region is cognizant of the far-
reaching impact of these vulnerabilities and has already
implemented, where appropriate, corrective action.
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
? WASHINGTON, D.C. 20460
OFFICE OF
DEC 0 ft' 91 ADM.N.STRATION
MANAGEMENT
•W' *> 7 '.O^' ULO u fl *' AND RESOURCES
MEMORANDUM
SUBJECT: Special Contract Management Review of the Alternative
Remedial Contracting Strategy (ARCS) Contracts in
Region 1
FROM: David J. O'Connor, Director
Procurement and Contracts Managemen€ Division (PM-214F)
TO: Patricia L. Meaney, Assistant Regional Administrator
for Planning and Management
Boston, Region 1
Merrill S. Hohman, Director
Waste Management Division
Boston, Region 1
In August 1991, my staff performed a special contract
management review of the ARCS contracts located in Region 1. The
purpose of the review was to determine the adequacy of cost
information supplied by contractors in their monthly progress
reports and invoices and to ascertain the level of cost review
and monitoring taking place in the Region. The review team also
attempted to identify the products and results of those
monitoring efforts. Attached is a copy of their report. A
summary of the findings and recommendations is presented below.
As you are aware, Region 1 has standardized procedures to
obtain information from ARCS contractors and to monitor
performance and costs, in both the program and contracting
offices. Contractors submit useful information, and the level of
detail in reports and invoices is generally excellent. The level
of documentation in files that demonstrates review of reports and
invoices is also excellent. There are many instances of
questioned, suspended, and/or disallowed costs. The program
office has initiated independent tracking systems that assist in
monitoring costs and performance. I congratulate your staff on
the quality of contract administration performed.
Printed on Recycled Paper
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-2-
The report contains only one major recommendation, which
concerns reasonableness of other direct costs and travel costs
incurred "nder Program Management. The report suggests several
methods . r obtaining additional information from contractors
related to those costs so that reasonableness can be monitored.
This report is issued to help enhance the administration of
contracts within your organization and to improve the overall
efficiency of the ARCS program. Please provide me within 90 days
of the date of this report a written response identifying any
proposed actions to be taken with a proposed schedule for
implementation. Should you have any questions, please call me on
FTS 260-5020.
Attachment
cc: Mark Walker
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
OFFICE OF
QCD ?7 199! ADMINISTRATION
wUi *• ' »un Deem irv»cc
AND RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT: Special Contract Management Review
ARCS Contract?, Region 1, Boston
Q*^^
.XJene V. Ra
FROM: .XJene V. Rasberry, Team
'-^Procurement Policy Staff
THRU: Belle N. Davis, Directo
Policy and Management
TO: David J. O'Connor, Director
Procurement and Contracts Management Division
I. SCOPE AND OBJECTIVES OF REVIEW
We have completed the special contract management review of
the Alternative Remedial Contracting Strategy (ARCS) contracts in
Region 1. We performed the review at your request to determine
the adequacy of cost information supplied by contractors in their
monthly reports and invoices and to ascertain the > level of cost
review and monitoring taking place in the Region. We also
attempted to identify the products and results of these
monitoring efforts.
The review team examined all pertinent documents for the
first six months of all Region 1 ARCS contracts and a random
sampling of the remaining documents. These included monthly
reports, invoices, review forms, and other general
correspondence .
During the week beginning August 12, 1991, Marilyn Torpey,
Suzanne Matsumoto, Tom Caffrey, and I reviewed the Region's
management of seven ARCS contracts. The reviews included file
reviews, interviews with the Regional Contracting Officers
(RCOs) , Regional Project Officers (RPOs) and staff, and Remedial
Project Managers (RPMs) . The team held an entrance conference
with Region 1 personnel on August 12. To accommodate Region 1
personnel schedules, the team conducted an exit conference on
August 15 and completed reviews on August 16.
Printed on Recycled Paper
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-2-
The team reviewed the following contracts:
Ebasco Services, Inc. (Ebasco) 68-W9-0034
NUS Corporation (NUS) 68-W8-0117
Roy F. Weston, Inc. (W' ton) 68-W9-0018
TRC Companies, Inc. (TRC) 68-W9-0033
Metcalf & Eddy (M&E) 68-W9-0036
COM Federal Programs Corporation (CDM) 68-W9-0045
Arthur D. Little, Inc. (ADL) 68-W8-1202
II. FINDINGS
A. MONTHLY INVOICES AND PROGRESS REPORTS
Invoices and progress reports cover identical one-month
periods (consistent with contractors' billing periods) and are
submitted at the same time to both the RPO and RCO. All ARCS
contractors follow basic formats for invoices and progress
reports.
1. Contract Requirements
All Region 1 ARCS contracts contain the standard Submission
of Invoice clause (EPAAR 1552.232-70), the Prompt Payment clause
(FAR 52.232-25), and Reports of Work attachment. However, in an
effort to obtain more useful and detailed information, RCOs
provided contractors with revised sample invoice and report
formats at individual post-award meetings. They previously
notified the contractors of that intent during negotiations and
indicated at that time that the revised formats would require no
more effort than the standard reporting requirements contained in
the solicitation and resulting contract.
The CDM, TRC, and Weston contracts were later modified to
incorporate these requirements. NUS, M&E, ADL, and Ebasco
contracts were not modified; however, these contractors are using
the revised formats.
2. Level of Detail in Invoices
Invoices in each Region 1 ARCS contract contain a contract
summary page that includes current month and cumulative hours and
costs expended. They also contain similar summary pages for
Program Management (PM), Remedial Planning, and each site-
specific work assignment. Invoices also break down labor hours
by professional and technical level for the prime contractor and
for each subcontractor for the current month and cumulatively for
the contract to date. All invoices include the categories shown
below:
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-3-
1. Labor
2. Overhead
3. Other Direct Costs (ODC)
4. Travel
5. Field Equipment (with EPA Fo* u 1730-1)*
6. Mobile Lab*
7. Team Subcontractors
8. Pool Subcontractors
9. Pollution Insurance
10. Lab Services
11. Computers*
12. G&A
13. Base Fee
14. Award Fee
* Not applicable to site-specific work assignments
All contractors provided at least the required basic
information. Some contractors, however, provided additional
data. Ebasco provided a breakdown for ODC but occasionally had
generic titles such as "other services" which could not be easily
identified. NUS broke down labor by individual employee and
provided detailed listings of ODC (brth for Program Management
and Remedial Planning), such as nunoer of packages sent by
express mail and quantity and cost for reproduction. NUS also
listed travel charges by employee name. He found that other
contractor files reviewed (Weston, TRC, M&E, CDM, and ADL) did
not include supplemental information for charges listed under ODC
and travel.
3. Level of Detail in Monthly Reports
Monthly Progress Reports for each Region 1 ARCS contract
contain three parts: an executive summary, a program management
summary, and a detailed site specific report for each work
assignment. Copies of the monthly progress reports are sent
simultaneously to the RCO, the RPO, and to the EPA Headquarters
Coordinator. The RPO distributes Sice Specific Progress Reports
to the responsible RPM. Contractors send a copy of the
corresponding monthly invoice with the RCO's and RPO's copies of
the reports to help to expedite review and approval of monthly
invoices.
The Executive Summary contains a brief description of
overall contract progress separated into technical, financial and
subcontracting sections. The technical section addresses Health
and Safety, Quality Assurance, Contract Administration, Field
Equipment, and other activities in Program Management as
well as key activities on work assignments. In the financial
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-4-
section, the contractor completes various detailed tables
depicting approved, actual, and variance amounts for LOE hours
and dollars, program management costs, and pool subcontract
costs. Additionally, the financial section includes a narrative
that highlights any areas of concern as reflec' «d on the
financial tables included in the report and explains any
variances in LOE and funding. An expenditures forecast for
Program Management for the next three months is included. The
subcontracts section includes a summary of subcontract awards,
planned versus actual costs in accordance with the approved
subcontracting plan, and pool subcontractor activity in terms of
dollars available versus dollars expended.
Each site-specific report appears in order of work
assignment issuance and includes a technical and financial
summary. The summary of technical activities includes highlights
of progress and problems; a summary schedule by task shoving
planned, revised, and actual start and completion dates; and a
summary for non-Contract Laboratory Program (CLP) laboratory
analyses. The financial summary is similar to the overall
progress summary with an expenditure forecast for six months.
Site-specific reports include a narrative summary of the
technical activities of the pool subcontractors. A summary that
addresses cost data, approved budget, cumulative actual costs,
estimated cost at completion, and variance for LOE and dollars is
also included.
Contractors are encouraged to use bullet format in progress
reports. They were instructed not to repeat information for work
assignments in the main report or repeat previous
accomplishments. These suggestions make the progress report less
voluminous and easier to read.
B. TYPE AND LEVEL OF REGIONAL REVIEW PERFORMED
All RCOs and RPOs monitor performance and costs in
accordance with procedures formalized in a Memorandum of
Understanding (MOU) dated July 9, 1991, which sets forth
responsibilities of the RPOs, Deputy RPOs, RCOs, and Contract
Specialists and establishes procedures for review of invoices and
monthly reports. Attached to the MOU are forms to be used by the
parties to document review. Another MOU establishes procedures
for initiation of work assignments and work plan approval.
1. Regional Contracting Officer
The RCO receives a copy of.the monthly report and invoice
for independent review and evaluation. He/she documents the
review on the Contracting Officer Review Monthly Progress Report
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-5-
t
and Invoice form. Documentation includes comments and actions
taken for both the monthly progress report and the invoice. The I
cognizant RCO also dates and initials the monthly reports to I
document review. If a problem exists on the invoice, the RCO j
coordinates with the RPO and notifies the contractor, i writing, '
to show cause and correct any mistakes and/or deficiency.
Generally, corrections occur before payment is made. Costs are . j
suspended until the contractor satisfactorily justifies charges. j
In some cases, the charges are disallowed. ;
t
2. Regional Project Officer '
The review team examined pertinent documentation maintained
in the program office and were impressed with the high quality
displayed. The RPOs receive complete copies of the invoices and
monthly reports. They perform a detailed review and complete the
Project Officer Review form, which allows comments for invoiced
PM and Remedial Planning costs, invoiced equipment, PM
activities, total PM hours expended, PN travel, subcontract ,
costs, and general comments. The RPO works closely with the RPM ,
to ensure reasonableness of technical work performed. The RPO is
also responsible for distributing a Remedial Contract Strategy
Monthly Progress Report to the cognizant RPM for overall
performance review and comment.
3. Remedial Project Manager
As indicated above, the RPM receives a site-specific
evaluation checklist which is used to review performance,
technical competence, resource utilization, etc. The RPM then
indicates on the checklist whether enough progress has been made
during the period to support payment. The document is then
returned to the RPO within three days for action and filing.
4. General
The review team unanimously agreed that the overall level of
review and documentation by Region 1 personnel is excellent.
However, it is not apparent whether ODC and travel costs for
Program Management are being monitored extensively. With the
exception of NUS, little supplemental Program Management
information is supplied by the contractors in the monthly reports
and invoices. Generally, ODC and travel charges for Program
Management are not excessive, averaging $1,000 per month per
contract. RPOs rely on RCOs to track Program Management ODC and
travel costs. The RCOs stated that they monitor those costs on a
month-to-month basis and would question costs only if something
out of the ordinary appears; i.e., the amount of ODC increases
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-6-
substantially from one month to the next. RCOs monitor travel
only to ensure that prior approval was obtained.
It is difficult to monitor ODC and travel for Program
Management. Although work plans for work assignments contain
breakdowns for ODC and travel, the only breakdown for those costs,
in Program Management is in the preaward Summary of Negotiations.
To improve monitoring in travel costs, the Region recently
established procedures that require contractors to obtain prior
approval for all travel. Justifications and estimated costs can
be reviewed prior to incurring costs.
File documentation for increasing Program Management ODC and
travel ceilings fully supports the need for additional funding.
However, the basis for determining the amount to be added was not
apparent.
C. PRODUCTS/RESULTS OF REGIONAL REVIEW
Region 1 personnel consistently complete review forms fully.
They take advantage of each "Comments" section and document
reviews and actions taken. The contract files also contained
sufficient examples of disallowed or deferred costs for the
review team to determine that Regional personnel are
conscientious about keeping costs down. RCOs requested each
contractor to monitor Program Management costs closely and keep
them to a minimum level.
The random review of file documents revealed that both RCOs
and RPOs question costs. The files contain evidence of actions
taken. For example, under the Ebasco contract, the RPM sent a
detailed memorandum to the RPO questioning the January 1990
invoice. Areas requiring closer review included use of labor and
charges for telephone, reproduction, shipping, word processing,
and miscellaneous expenses. After reviewing the April 1991
monthly report and invoices, the RCO questioned the RPO about
seemingly high consultant charges, charges for a business
luncheon, and an unexplained charge for "statistical charges."
As a result, the RCO questioned the contractor in writing. The
Contractor responded by removing erroneous charges for the
luncheon and provided supporting documentation for the other
questioned costs.
Under the CDM contract, the RCO annotated Invoice No. 15
that an equipment charge ($75.50) was incorrectly charged to a
specific site and would be credited and transferred to Program
Management. The RCO noted on another invoice that $479.13 was
removed because the contractor exceeded the expenditure limit on
a work assignment. Under the Metcalf & Eddy contract, the RCO
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-7-
noted that the monthly progress report adequately described the
progress that month and that field equipment charges were for
properly authorized equipment purchases. Under the Arthur D.
Little contract, the RPO questioned the contractor's allocation
of costs to site-specific work assignments and required the
contractor to reallocate them properly to PM. The RPO also
required the contractor to split prime dontractor and
subcontractor hours on the invoice, which was indicated as
critical to develop the award fee pool.
III. RECOMMENDATIONS
A. RCOs must increase their efforts to assure that ODC and
travel costs for Program Management are reasonable and allowable.
To provide a means to assure that those costs are reasonable and
allowable, RCOs should consider requiring contractors to provide
detailed breakdowns of all ODC and travel costs. However, to
achieve a balance between time-consuming "cost incurred1* audits
and incurring additional costs for contractors to provide more
extensive reports, RCOs should consider the following:
Require contractors to provide detailed data if charges
appear for items not agreed to in negotiations.
Establish what constitutes "unusual11 charges, and require
contractors to expand the narrative portion of reports to
discuss those charges.
Consider the feasibility of randomly selecting months in
which contractors must provide additional detailed data on
all charges or on specific categories such as ODC and
travel.
B. RCOs should include the basis for the amount of
increases in the rationale for raising ODC and travel ceilings.
C. RCOs should consider incorporating requirements for
submission of invoices and reports into those contracts that have
not been so modified so that there is no possibility of a
contractor's refusing to provide additional information in the
future.
IV. OTHER COMMENTS
The team commended the initiatives of both program and
contracting personnel in Region 1 to ensure that all ARCS
contracts are properly monitored. Especially noteworthy is the
manual of procedures developed and used by contracting personnel
and the MOUs for overall monitoring and work assignment
procedures. The program office also prepares various automated
reports to track trends among the ARCS contracts in the Region.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
______ JOHN F... _IOBNNBD¥ FEDERAL, BUILDING^ BOSTON, J«A 02203-2211
MEMORANDUM
DATE: January 16, 1992
SUBJECT: Special Contract Management Review of the ARCS
Contracts in Region I
PROM: Hilary E. Kelley, Chief^/^W/ £ ^iittLsJ. - •
Superfund Contracting Sectiony \J
TO: David Zeni *
Joshua
Kathleen
Reference is made to the Special Contract Management Review of
ARCS Contracts in Region I which was forwarded by memorandum
dated November 27, 1991.
The following action is to be taken in response to the
recommendations proposed by the review team:
Recommendation A; RCOs must increase their efforts to assure
that ODC and travel costs for Program Management are reasonable
and allowable.
Action Taken: RCOs are to take special care when reviewing
their contractors' invoices to assure that they and the
Project Officers have complete understanding as to the costs
being incurred against the various ODC cost centers which
differ from those agreed to in negotiations. Clarification
from contractors should be obtained if necessary.
RCOs are to review their contractors' monthly reports to
assure that the Program Management summaries adequately
document costs associated with travel and any significant
ODC. The need for contractors to provide more detail in
their monthly reports should be discussed with the Project
Officers.
RCOs are to randomly select four months in which contractors
must provide additional substantiating data on ODC and
travel charges. The months selected should be discussed and
agreed upon with the Project Officers. The contractors
should have no advanced knowledge for which months data will
be requested. A brief memorandum to the file documenting
which invoices have been agreed upon should appear in the
invoice file.
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Recommendation B; RCOs should include the basis for the amount
of increases_in the rationale for raising ODC and travel
ceilings. " " ~ ~ — ~ -
Action; RCOs are to document their rationale for raising
ODC and travel ceilings. A recommendation from the Project
Officers shall be obtained prior to raising these ceilings.
Documentation should appear as part of backup to the
modification involved.
Recommendation C; RCOs should consider incorporating
requirements for submission of invoices and reports into those
contracts that have not been modified so that there is no
possibility of a contractor's refusing to provide additional
information in the future.
Action; No action needs to be taken at this time except at
the discretion of the individual RCO. I consider the
requirements for submission of invoices and reports are
adequately covered by the contract document as it was
awarded. Their formats are administrative in nature and
often minor changes are necessary; modifying contracts for
every such change would be needlessly time consuming. The
contractors have no basis for refusing to provide
information to substantiate their incurred costs.
These recommendations were discussed with Maggie Leshen, Chief,
Contracts Management Section, Waste Management Division and she
concurred with the course of action.
If there are any questions, please see me.
cc: A. Fitzgerald
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
•v
' DAT!: MAP 2 7 1992
SUBJECT: Contract Management Review
Constant in« Sirtawon-Ertmtoff X
Regional Administrator Ls
TOi William K. Reilly
Administrator
In response to your request for a review of the strengths and
weaknesses of the Agency's contract and project management
efforts, I have undertaken a comprehensive review of all of
Region II*s contracting activities. I an pleased to report that
we have already initiated a series of activities designed to
reinforce our strengths and safeguard our resources from
potential misuse. I share your concern with respect to the
matters raised in recent hearings and agree that all contractual
relationships warrant attention. Given the brief tine frame in
which our response has been prepared, we would describe our
activities as part of a continuing regional improvement program.
This report builds on the region's previous experience and
reviews, and identifies the steps already in progress to
strengthen our management practices. We intend to develop this
effort more fully in the months to come and will be pleased to
provide you with more detailed reports in the future.
To begin with, we have responded positively to the directives
outlined in Christian Holmes' memo of February 28. I have
designated Herb Barrack, Assistant Regional Administrator for
Policy and Management, as the region's senior Regional
Procurement Officer. I heartily support the establishment of
this function at the regional level and look forward to working
out details of the responsibilities attached to this position
and the resource implications inherent in their execution. It
will also be essential to outline carefully the roles of
regional and headquarters procurement officers in order to
achieve maximum benefit from this enhanced oversight function.
To this end, we applaud the creation of OARM's Office of
Acquisition and Assistance Management and anticipate continued
close working relations with the Procurement and Contracts
Management Division (PCMD).
Although our formal evaluative process is still in an early
stage of development; at this point we have compiled preliminary
information from senior managers. In general, this expedited
initial review of regional contracting activities reaffirmed my
conviction that in Region II there is an awareness, a sense of
responsibility, and above all a linkage to senior management
with respect to the conduct of contractual activity. We have
noted a number of areas where strengthening and modification of
current regional practices are warranted and steps have been
initiated to address theee concerns. In order to bring about
REGION II FORM 1WO-1 (»/«3)
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the kind of improvements you are encouraging throughout the
Agency, Region II in actively engaged in the following
endeavors:
* To ensure adequate oversight of ARCS contracts, we have
established an interdisciplinary team of regional
specialists to conduct on-site reviews of Other Direct Cost
(ODC) documentation. This team brings expertise in audits,
contract management and finance to the task of ascertaining
compliance with EPA regulations, while verifying the
allowability, allocability and reasonableness of OOCs
invoiced under the Superfund remediation program. To date,
reviews of three of the region's six ARCS contractors have
been conducted, with the three remaining reviews planned for
later this fiscal year. These efforts are being coordinated
with PCMD in Headquarters, from which we recently received
detailed guidance on the implementation of this initiative.
Any findings resulting from our reviews will be addressed,
where appropriate, by regional contract officers in
coordination with PCMD.
» In response to the January 10, 1092, nemo from OSWP.R and
OAKM, Region XI established its own ARCS Management Team in
February 1992. This action proceeds from the recommendation
of the ARCS Task Force that such Regional Management Teams
b« established to evaluate and suggest further improvements
to the ARCS management process. The Region II team is
composed of representatives from the Emergency and Remedial
Response Division, the Environmental Services Division, and
the Office of Policy and Management. Members of the team
will also serve on the Regional Performance Evaluation Board
for ARCS, thereby utilizing their expertise and knowledge of
ARCS operations in the region.
* Herb Barrack, in his capacity as Senior Regional Procurement
Officer, has begun to issue a series of advisory nemos to
the Divisions. The first of these, dated March 12, was an
announcement of refresher training seminars in contract
management. All regional staff having any role in contract
management or oversight are required to participate in these
seminars, which are being held now through the beginning of
April. This training is in addition to the standard courses
already offered in Contract Administration, Project Officer
training and the RecertiMeation Refresher program. As an
attachment to the March 12 memo, your memo of April 17,
1990, on contracting and accountability was redistributed,
and managers were requested to review with their staffs the
appended lists of prohibited contracting practices and
activities of potential vulnerability.
»• A second advisory memo, dated March 23, reiterates ways to
avoid "personal service" relationships with EPA contractors.
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It clarifies such relationships for any employees who may
have been uncertain about the nature of these contacts.
Furthermore, it requires that all future procurement
requests originated in the region (regardless of where the
contract itself is managed) must be countersigned by the
Senior Regional Procurement Officer, and mandates the
wearing of distinctive contractor ID badges by all on-site
contractor staff. The March 23 nemo also includes a list of
contractor management practices that are prohibited
expressly because of their tendency to create personal
services relationships.
Our Emergency and Remedial Response Division is currently
reviewing the impact of CHjM Hill's involvement in Region
II'B Superfund program. Staff have already prepared a fact
sheet based on the results of a recent GAO audit of the
firm's overhead rate. In Region II, Hill was a prime
contractor under REM IV (which expired in November 1990),
under which the firm invoiced more than $10 million between
1985 and 1990. This work has not yet been audited, although
we understand that the OZG has just undertaken an audit of
CHjM Hill. The firm is currently a Region II subcontractor
under Malcolm Pirnie, where it is participating in five work
assignments.
We note that the OIG draft audit of Computer Sciences
Corporation (CSC) contract management made a number of
references to possible irregularities in contractor billing.
As detailed in Region II's FY-91 Assurance Letter, prepared
in compliance with the Federal Managers* Financial Integrity
Act (FMFIA), we have taken steps to strengthen internal
controls in this regard. During the past year, Superfund
and financial staff have devoted extensive efforts to
improving the level of invoice reviews conducted by regional
project officer* on Superfund contracts. This has included
training sessions and written guidance for project officers.
Additional steps have been taken to assure that on-site
contractors are easily distinguishable from EPA personnel.
All contractors have had GSA-iesued building passes with
photos for many years. Recently, when GSA ceased to issue
these passes, we decided to replace them with our own
identification badges. These badges are for all on-site
contractor personnel, who are required to wear them at all
times when in EPA Region II office space. All CSC employees
have nameplates prominently displayed in each office or work
station. These bear the CSC name and corporate logo and
clearly identify the contractors as CSC employees. He are
requiring all other on-site contractors to do the same.
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»• We have always had distinct areas for CSC employees in our
physical space, and hav« avoided to the fullest extent
possible the intermingling of EPA and contract employees.
Space has Always been a problem, however, and this has
limited our ability to create optimal work station
arrangements for all concerned. For this reason, we have
submitted specifications for the space we will occupy in the
new federal building, now under construction, to provide
separate and clearly identifiable areas for contract
employees.
» As part of our review of contract management practices, we
are developing a comprehensive regional inventory of all
contracts for which we have any oversight responsibilities,
together with a directory of divisional project and contract
officers and their respective training and certification
status.
The above list of key actions taken, or currently in progress,
is by no means exhaustive of the region's efforts to enhance its
contract management oversight. We are also continuing to
examine, in a more in-depth fashion, all aspects of regional
contracting practices. To that extent, I oannot conclusively
assure at this juncture that further review will not identify
other areas needing attention.
In the couree of our regional assessment, we identified several
critical contract management issues of national scope that must
be addressed at the Headquarters level. I have provided as an
attachment to this memo case examples that speak to these
issues. Several additional items are also described belowt
» One key recommendation we are making is that the Agency
provide resources and delegate authority to establish a ooet
and pricing capability in the regions. Regional capability
in this area is inadequate, and it is worth noting that most
agencies with large contracting responsibilities provide
this kind of analytical strength to their contracting
staffs. While such capability exists in PCMD, there are not
enough personnel available to provide such analysis to
Headquarters, let alone the entire Agency. The quality of
EPA's contract management would be measurably enhanced if
regions had readily available expertise to assure that
contract procurement and oversight is based on accurate and
timely cost analysis. These staff would perform reviews of
contractor-submitted work plans, independent government cost
estimates which are the basis for the negotiation of work
plans and budgets, and construction change orders. They
would also review delivery orders, check invoice-supporting
data on an ad hoc basis and assist in negotiations with
contractors.
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Currently, regional project officers servo as scle reviewers
on cost and pricing issues but generally lack the necessary
professional financial skills for this task. With the
proposed implementation of the Superfund Long Tern
Contracting Strategy (LTCS), which would delegate
significant new contract authorities to the regions, having
this evaluative capability in each regional office will
become even more critical.
*• There is no single, reliable and up-to-date source of
information on which Agency contracts are providing which
services, to whom, and where. It often can be difficult for
local staff even to identify the scope of work and the
contracting/project officers on a given contract.
» Contract regulations and guidance, program policy issuances
and other pertinent guidelines are not consolidate/I or
organized in a readily accessible manner. This i«
especially critical in the Superfund program, where there is
a wide variety of contract management guidance, including
OSWER Directives and Memoranda, CORAS Bulletins, and LTCS
Implementation Plans.
* Feedback from regional managers indicates that the Agency's
current project and contract officer training programs are
missing the mark in terms of their ability to impart a
thorough understanding of the legal and technical
requirements and responsibilities of these positions. When
so many trained individuals are found to be lacking in
skills needed for quality contract management, the fault is
certainly not in the trainees' capacity. We believe that
the content of the training courses may be entirely
appropriate, but would recommend a careful review of the
training designs being used and the classroom methodology
that is being applied by the instructors (who in most cases
are themselves contractors). Perhaps the training could be
augmented with a one-day session, presented by EPA
employees, on CO/PO responsibilities as they relate to
management and oversight of oontraots.
The past several fiscal years have brought about a significant
increase in the Agency's programmatic responsibilities, with the
advent of heightened public interest in environmental protection
and the resultant expansion and reauthorization of legislation.
At the same time, there has been no proportionate growth in the
resources (i.e., EPA work/ears) that are essential for assuring
effective internal controls and management oversight. These
resources include not only the workyears identified for
management of contracts, finance, grants and audits, but program
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vorkyears as well, which would enable EPA staff to devote the
time needed to assure effective control* are in place.
Thi* situation can only help to perpetuate the low priority that
management issues appear to occupy within the Agency's culture.
We are anxious to identify ways to enhance employee awareness of
the importance of quality contract management practices and the
need for strong internal controls, but our ability to do so when
faced with inadequate budgetary support is severely
compromised — training, heightened awareness and other non-
resource demanding actions can only go so far. It is
inconceivable that our goals could be accomplished without the
dedication of additional resources. I recognize the sensitivity
of resource issues, particularly in this difficult federal
budget climate. But in the absence of budgetary relief, our
discussions of reform are unlikely to result in permanent
change.
In the brief time available to respond to your March 10 memo, I
have summarized a series of past, present and future activities
that are designed to strengthen contract management practices
throughout Region II. At the same time, I have presented a
number of concerns that relate to national policies or areas
outside the control of an individual region. These issues will
no doubt be assessed in the context of the larger Agency-wide
review of the strengths and weaknesses of our ourrent contract
and project management efforts.
I look forward to discussing these important natters with you
and the Agency's senior officials at our April 2 meeting.
Attachment
cc: P. Henry Habicht n
Deputy Administrator
Christian R. Holmes
Acting Assistant Administrator, OARM
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Attachment
Bristoff to Reillyt Contract Management Review
CASE EXAMPLES
1. Audit Backlog and Associated coat Review issues
Issue
Recant audits have amply demonstrated the need for prompt and
comprehensive auditing of coat contracts. Reliance on outcide
cognizant audit agencies places EPA at a serious disadvantage in
securing timely audit* in view of the many competing requests for
such audits. That being the case, our Agency hae to secure
alternative mechanisms to insure that substantive reviews are
conducted within a reasonable timeframe.
The GAO audit of CHjM Hill, for instance, revealed numerous
questionable book-keeping practices. The GAO found that CH2M
Hill *e indirect oest rate included unallowable charges such as
liquor, spousal travel, parties, and aircraft rental. Most
disturbing was the fact that CH,M Hill was last formally audited
in 1986.
Indirect Costs are normally expressed as a percentage of direct
labor costs and reflect the reasonable and customary costs of
operating a business. This cost rate is established as part of
the original contract and is normally audited by outside agencies
(principally DCAA) to insure that this approved rate remains a
reasonable and appropriate overhead cost for the contract.
The lack of timely auditing of even our largest cost contractor
is unfortunately a characteristic problem rather than an
exception. Major audit backlogs have seriously weakened Agency
oversight on all our cost contracts. The Agency has attempted to
deal with this serious problem by establishing an in-house EPA
review function in the Procurement and Contracts Management
Division (PCMD). There are, however, only three financial
administrative contracting officers in PCMD. Given the size and
scope of the Agency's many large cost type contracts, additional
resources are clearly required.
A related area of weakness on our cost contracts involves
other direct eosts (ODC). These are specific expenditure items
billable under the contract. There are several weaknesses
associated with the current ODC situation, but the major problem
steins from the inadequate documentation submitted with invoices.
Contracting/project officers and work assignment managers can
only review the documentation submitted. While current invoices
all meet basic FAR requirements, a much greater level of detail
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would be required to provide a high degree of certitude that all
questionable cost* are caught prior to payment. The lack of
adequate documentation in submitted invoices is compounded by the
absence of uniform categories and presentation formate to
facilitate a quick assimilation of the financial data provided.
Even for the limited information provided, sufficient staff tine
is essential for the contracting/project officers to review and
research invoices. This is generally not available due to
staffing shortages and the tight review limits imposed by the
Prompt Payment Act. Although the greatest amount of
documentation is available at contractor hone offices, this
documentation is often inaccessible due to limited staff and
travel resources. Even where questionable cost items are found/
the reviewer now lacks the necessary quick-turnaround audit/cost
advisory support to follow up on leads and detect patterns of
fraud, waste and abuse.
Recommendations
o EPA must find a way (or an alternative) to insure that its
contracts are audited in a timely manner by cognizant audit
agencies. This audit oversight should also be supplemented
by PCMD cost analysis staff. The in-house cost reviews
performed by this staff will require more FTES, greater
travel resources and structured Agency guidance to
facilitate such reviews.
o A permanent regional cost analysis capability should be
established to perform reviews of the financial aspects of
work plans, check invoice supporting data, independent
government cost estimates, statements of work, construction
Change orders, definitiation of ERGS delivery orders, and
assist in negotiations. This function would be staffed by
experienced financial and technical analysts and would
operate in a similar manner to cost analysis units in many
agencies.
o The Agency should accelerate its efforts to secure detailed
invoice backup and a standard format for cost data
presentation. We understand that to date these efforts have
been hampered by problems such as different vendor cost
accounting systems, computer capabilities, and the expense
of EPA mandating changes over and above the FAR
requirements.
o The Prompt Payment Act requires COs and POe to quickly
process invoices under penalty of interest. Additional
resources will be needed to provide more comprehensive
reviews in the time allotted by these regulations.
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2. Environmental service* Assistance Team (ESAT) contracts
The ESAT Superfund laboratory support contract is a complex,
multifaceted contract which places many contract staff on EPA
premises. Its general statement of work covers analytical and
technical service* in EPA laboratories and mobile labs, data
review and QA/QC service*, and a general logistical and
administrative support category. This contract has become
integral to the operations of many BSD laboratories and Superfund
program division* as a principal conduit for samples for contract
Laboratory Program (CLP) laba.
Issue
This contract bears certain similarities to the esc mission
support contract that has provan so susceptible to criticism in a
recent IG's report. It has a high degree of vulnerability in the
area of personal services because of the on-site nature of much
of the services provided, its use of EPA laboratories and
equipment, and the similarity between the duties of its staff and
those of existing Agency personnel. PAR 37.104 (d) lists six
elements that should be used as a guide in determining whether or
not a contract is personal in nature. When the ESAT contractor
utilizes EPA laboratories alongside Agency chemists on the same
shift, at least five of the criteria for personal services appear
to be met and the sixth is highly dependent on the continuing
vigilance and oversight of EPA project management staff.
The six elements are: (1) performance on cite, (2) principal
tools and equipment furnished by the Government, (3) services are
applied directly to the integral effort of agencies or an
organizational subpart in furtherance of assigned function or
mission, (4) comparable services are performed by civil service
personnel, (5) need for services exist for more than i year, and
(6) the inherent nature of the service requires Government
supervision/direction.
Recommendations
In Region II various safeguards are in place. The EPA project
officer deals with the contractor team leader through written
directives. Each activity supported by ESAT has an EPA person
who oversees the ESAT performance of the activity and works
through the project officer to get tasks assigned or modified.
All ESAT contractors are provided office space not contiguous to
any office space Utilized by EPA personnel. When present at the
facility, all contractors wear clearly identifiable badges.
We recommend that these types of procedures be mandatory for the
ESAT contract. Wherever possible, contractor use of the BSD
laboratory should be further segregated through use of a
different shift for contractors.
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Even with these safeguards in place, we recognize that many
samples are enforcement related and close government supervision
is necessary in order insure adequacy of analytical results and
chain of custody. Unless stringent safeguards can be put in
place at locations using the ESAT contract to preclude personal
services, we question the continued utility of this contract to
the Agency,
J. fiaergeney Response Clean-up services Contract (BftCfl)
Issue
Due to the emergency nature of the removal progran, the Agency
has given On-Scena Coordinators the dual role of technical
representative and contracting officer on ERGS contracts.
Because this authority is vested in one person, the OSC initiates
the delivery order, directs the work at the site and receives and
accepts the services rendered by the contractor. This approach
trades off the usual checks and balances put in place to assure
sound contract Management in favor of the recogniaed need for
quick action at emergency removal sites.
Recomstentfat ion
The inherent vulnerability of this approach suggests that the
Agency reassess current practices and procedures to insure that
this unique delegation is properly monitored and controlled.
Issue
Currently/ the minimum standard requirement for an OSC to secure
a contract warrant authorizing him/her to bind the government up
to $250,000 in emergency response services consists of
participation in an eight hour training course entitled
"Superfund Emergency Ordering and Acquisition Procedures." in
contrast, a contracting officer's warrant allowing obligations up
to $25/000 normally requires a minimum of 104 hours of specific
training, A warrant of $500,000 requires a minimum of 300 hours
of specialized training.
Recommendation
Training for an OSC to acquire and maintain a contract warrant
Should be substantially expanded, consistent with the level of
authority and inherent responsibilities entrusted to these
employees.
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4. National Technical Operational support Services (Toss)
contract
issue
National TOSS Delivery Orders are not linked to regional
management oversight. National delivery orders for programs such
as RCRA, NPDBS and Superfund, written under the TOSS contract
with the Computer Sciences corporation (CSC) have been in place
for many yeare. The practice has always existed whereby the
DOPO, located in Headquarters, would write a general statement of
Work which could be applied to all regions, specific labor hours
were identified and portions then allocated to each region.
Headquarters would fund the delivery order and the interaction
between EPA and CSC as to what is to be done, timeframee,
priorities, etc., would take place between the Headquarters DOPO
and the CSC project manager in Washington. Regions have very
little input to this process on the front end. Typically, the
SOW is not made available to any EPA person in the region
although it is likely that the CSC site manager for the region
has a copy.
progress reports of work activities performed in the region are
reviewed by the Headquarters DOPO who also signs the payment
voucher. Regions are not heavily involved in this part of the
process either. Some programs have identified a program contact
point in the region for CSC matters or assumed that the regional
program system contact is also the contact for CSC activities.
However, this process is not uniform nor well defined.
In Region II, the IRM chief has little or no knowledge of esc
activities for nationally funded delivery orders although the IRM
Chief is typically viewed by OIRM ae the point of contact for CSC
activities in the regions. IRM chiefs report to the ARA* (SlRMOs
in the regions) who are responsible for IRM activities in the
regions, yet perhaps half of the total number of CSC employees in
the regions are funded out of national delivery orders for which
the ARAs have little knowledge or control over what they do.
Also, space, furniture, and telephone considerations are not now
coordinated with Headquarters DOPOe when ordering CSC hours for
the regions although we understand that this problem is about to
be addressed.
Recommendation (options)
o Assign a regional Alternate Delivery Order Project Officer
within the regional program area to each nationally funded
DO. SOWs should be written in part by the ADOPOs with
specific tasks and deliverable* for each region with
national priorities addressed by the Headquarters DOPO.
Management responsibilities for each regional portion of the
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National DO would be assigned to the ADOPO, including
signing the payment voucher. Management oversight
responsibilities (review and signoff of SOW*, MOD*,
vouchers, etc) should be given to the SIRMO or IRM Chief who
should be the DOPO for regionally funded TOSS OOs and has
experience in these natters. Turf issues will be avoided by
keeping the regional programs actively involved as ADOPOs.
It is our opinion that the regional DOPO should be the IRM
branch chief; this responsibility should not be delegated to
a subordinate staff member.
o Break up national delivery orders into separate regional
delivery orders funded by the national programs. DOPO
responsibilities would reside in the regional programs with
oversight responsibilities as specified in Option l.
o Statue quo, but require significantly improved communication
between National DOPO and regional program and IRM
community. Require dissemination of contract materials such
as SOW, MODs and vouchers to these groups. This option
should be viewed as the absolute minimum as we do not view
it as one that would solve the underlying problem.
Region II'a preferred option is to establish an alternate DOPO
within each region.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION «
841 Chestnut Buicfing
Phladejphia, Pennsylvania 19107
SUBJECT: contracts Management Review DATE:
FROM: A Edwin B. Erickson
Regional Administrator (3RAOO)
TO: William K. Reilly
Administrator (A-lOO)
This is in response to your memorandum of March 10th
concerning contracts management. In your memorandum we were
requested to provide an assessment of problems and a proposed
plan of action to address these problems. As you requested,
Region III fully intends to implement Christian Holmes'
memorandum concerning CSC management.
In specific regard to CSC, Region III is in the process of
conducting an internal vulnerability review of the contract.
This review is expected to be completed by mid-April and is being
conducted by staff independent of EPA-CSC daily operations.
After taking corrective action resulting from the CSC study, we
intend to review all contractual relationships regardless of
responsibility center (i.e. Region or Headquarters). Our draft
plan to address contracts is attached. We view this as an
ongoing process which will require redirection of Regional staff.
While we have not performed a detailed assessment of the
entire contracts management situation, below please find several
broad areas that we will focus on for potential problems:
- Competing job requirements of project officers. Project
officership is an adjunct duty for many of our staff.
- EPA emphasis has been on the delivery of programs for
attaining environmental goals. As a result we need to stress and
institutionalize the importance of adhering to procedural
requirements.
- Training specific to an individual contract or delivery order
is not available. Although contracts and project officer
training is required, the training is general in nature and does
not relate to unique aspects of a contract. Many of the Regional
delivery order project officers have not received training by
their national delivery order counterpart.
-------
- EPA's delivery mechanism for contracts is oriented toward
large Headquarters based contracts under which the delivery of
services and assignment of work is vested in the Regions.
Although there may be economies of scale, there is also potential
for contracts management problems because of remote management.
Although resources have been made available to the Regions
in Superfund, resources for S&B management support such as
contracts oversight have not kept pace with resources for program
implementation. For your information I have included several
graphics which show the trend for the past 10 years in the S&E
management support area. An attendant commitment, through
resources or redirection, within our various programs would also
be necessary.
As your lead Region for management, we feel that the resolve
for solving this problem must be matched by a resource base which
is adequate and comparable to the job at hand. If you would like
to discuss this further, please do not hesitate to let me know.
Attachments (2)
cc: H. Habicht w/attachments
C. Holmes w/attachments
-------
DRAFT
Region III Contracts Management Action Plan
3/20/92
lilltY/Acoountabilitv
• Appoint a Senior Manager as Senior Procurement Officer in
accordance with C. Holmes memo dated 2/28/92.
• All SES managers complete a special seminar on their role
and responsibilities in contract management in accordance with
C. Holmes memo dated 2/28/92.
• Applicable Mid-Managers and Section Chiefs complete basic
Contract Administration Training.
• Ensure Headquarters/Regional contract policy directives are
properly submitted to key EPA managers for implementation.
• Regional managers evaluate new directives/delegation of
functions which impact on staffs workload to determine if
functions can be adequately performed with current staff.
• Regional managers ensure that the staff required to perform
contract administration is properly trained, provided
timely guidance, and perform oversight of the functions to
assure contract compliance.
• Managers be advised that contract issues/weaknesses not in
compliance must be identified as risk assessment through the
Federal Managers Financial Integrity Act (FMFIA).
• Include in managers performance standards effective contract
administration requirements.
Establish a Reaienal contract Analvat Function
• Contract analyst would report directly to the SES Senior
Procurement Officer responsible for overseeing Regional
contract implementation, administration and decision
activities.
• Periodically review various contracting function to evaluate
performance, prepare written reports of vulnerable areas
and recommendations for improvement.
• Responsible for development of required Regional Training
Program which is tailored to the type of contract
administered.
-------
• Act as the Regional contracts FMFIA coordinator.
• Certify to the Senior Contract Officer names of managers,
CO's and PO's who have taken the required Regional
Contract Administration Training.
• Responsible for altering the Senior Procurement Officer of
early warning contract management issues and resolution
of those issues.
Regional Contract Training
Determine Headquarter and Regional contract administration
training requirements.
Design and implement a Regional development/training program
tailored to each employee who performs contract
administration duties. The training should provide skills
and knowledge that CD's, PO's, etc., must have to
effectively and efficiently administer their specific
contracts.
TQM concepts should be employed in developing Regional
training programs. Training development teams should be
established consisting of managers, supervisors, contract
administrators and technical personnel. Teams should design
training programs detailed to the specific contracts
employees administer.
Assign senior contracting/project officers to train program
personnel in the specific characterisice in each type of
contract administered.
Develop a Regional Contracts Manual which would indicate the
general overview of prohibited and sensitive contracting
activities.
Contract Management Reviews
Establish management review teams comprised of
administrative and technical staff knowledgeable in the area
selected for review.
Immediately review Regional activities under the Computer
Sciences Corp (CSC) contract.
Areas of review would include:
• Determine the number of Headquarter/Regional delivery
orders CSC has with the Region and dollar amounts.
-------
Require ID badges for all esc employees.
Workplace physically segregated between CSC and EPA
employees.
Has Headquarters PCMD provided proper guidance and
control techniques for both CSC and EPA employees.
Have Regional DPO's for CSC contracts been properly
trained in management support contracts.
Are CSC statements of work defined to the scope of work
to be performed by CSC employees.
Review CSC position description (PD) to insure they are
working in accordance with PD.
Are CSC work outputs and deliverables measured by EPA
DPO's.
Does the Region provide training/equipment/conference
space/travel beyond contract requirements.
Does CSC employees attend EPA social functions, utilize
We11ness Center, medical facilities or other EPA
contractor supplied services.
Are CSC employees Time and Attendance hours recorded
and periodically reviewed by EPA DPO.
Are EPA employees performing CSC functions, i.e.,
interviewing prospective CSC candidates or directing
work.
Are CSC employees performing inherently government
functions, i.e., providing policy, temporarily acting
in functions performed by EPA employees or privy to
conf ident ia1 information.
Do EPA DPO meet on regular basis to discuss policy and
problems.
Are Regional DPOs trained and do they properly review
CSC obligations/invoices to ensure compliance with the
contract.
On a periodic basis perform management review of
vulnerable contract areas and report appropriate
findings under the FMIA process.
-------
Regional contract Data Base
Establish a Regional data base of all Regional contracts.
Include in the data base identity of contract
administrators, (i.e., CO's, PO's, etc.) and their completed
acquisition training courses.
Data base can also be used to identify and select contracts
which may be vulnerable and require management review.
Require contract administrators to keep data base up to
date.
-------
REGIONAL "MANAGEMENT SUPPORT" WORKYEARS AS A PERCENT OF TOTAL
REGIONAL WORKYEARS -SALARY & EXPENSE APPROPRIATION
10.00% T
8.50%
PERCENT 0.00% f
7.50%
7.00%
6.50%
6.00%
.59%
Regional "Mfftnt Support" FTE decreased as a percent of total
Regional FTE by more than 2.0% between FY 84 and FY 93
The 2*$% decreaao from FY84
to FY93 has created a 132.2 FTE
"shortfall" In Ugt Support
FTE'S.
r.36%
FY84 FY85 FY86
Mgt Support includes FTEs from the foflwolng
program elements: Resources Mgt; Financial
Mgt; Personnel Mgt;. and Admin Mgt.
FY87 FY88 FY89
FISCAL YEAR
FY90
FY91
FY92
FY93
-------
YEARLY % INCREASES (DECREASES) OF TOTAL REGIONAL WORKYEARS AND
'MGMT SUPPORT" REGIONAL WORKYEARS-SALARY & EXPENSE APPROPRIATION
PERCENT
12.00%
10.00%
8.00%
6.00%
4.00%
2.00%
0.00%
-2.00% •
In only one of the past 9 yean ha* Mgt
Support FTE'a increased percentagewise
more than total fieglonal FTE'* (FY 90)
FY84 FY85 FY86 FY87
FY89 FY90 FY91 FY92 FY93
Mgt Support Includes FTEs from the
following program elements: Resources
Mgt; Financial Mgt; Personnel Mgt; and
Admin Mgt.
RSCAL YEAR
TOTAL
MGMT SUPPORT
-------
IS)
r-H
a!
6000
5000 +
4000
FTE 3000
2000
1000
USEPA REGIONAL WORKYEARS
'MANAGEMENT SUPPORT" WORKYEARS VS. TOTAL WORKYEARS
SALARY & EXPENSE APPROPRIATION
5922
Betvnon FY 84 and FY 93, toW Roglontl FTE
y 42%; Mgt. Support FTE by 9%
167.8
FY84
FY8S
FY86
Mgt Support includes FTEs from the
following program elements: Resources
Mgt; Financial Mgt; Personnel Mgt; and
Admin. Mgt.
FY67 FY88 FY89
FISCAL YEAR
FYflO
FY91
FY92
FY93
TOTAL
MGMT SUPPORT
-------
-------
-------
-------
04,-01/92 17:37 002
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REOION IV
. NJE.
ATLANTA. OCOOGIA »O»6B
MEMORANDUM
DAXBt March 26, 1992
SUBJECT: Region IV'e Vulnerability Assessment for Contracts
Managanant
FROM* Oraar C. Tidwall
Regional Administrator
TOI William K. Railly
Admini0trator
Attached, pleaae find our a*aeaeaient of all present or
potential problem* related to contract and project management
in Region IV;
Oor vulnerabilitiec are ranked for high, medium or low riak and
I am confident that the plena of action detailed in our
eubmieaion will serve aa a beginning for permanent improvements
in this very important area.
Attachment
oot Christian R. Holmes
Acting AA/OARM
Printed on Ikcyctot Piper
-------
-------
CW01/92 17:77 3E3
OVERVEIW OF VULNERABILITY ASSESSMENT
33 Vulnerable areas identified
25 High Risk
5 Medium Risk
3 Low Riak
High Risk Area* By Division...
Number Divieion Drivere
9 Waste Preponderance of Contracts
S BSD B6AT Contract
4 0PM CSC and LAI Contracts ***
3 ORC Minimal Contract Awareness
1 Air C6C Contract
1 Hater Minimal Contract Awareness
2 Regionwida Resources and Contract Mngmt.
Bigh Risk Areas by Category...
High Riek
Category VulnerableJ^reas
Contract Management Issues 10
Appearance of Personnel Services 4
Management Issues 4
Contract Awareness Issues 3
Conflict of Interest 2
Information Security/CBI 2
* CQNCiiOSlOMt Overall, it is a resource issue
*+* Vulnerabilities associated with CSC contract activities appeared
in every Division. i
-------
EMX01/92
17:37
004
VUK.MESIAftXLZS'ZEa BY CROUP
Are«a of Vulnerability
Division
Oagra* of
Vulnerability
i.e.
2.C.
2.K.
3. A.
3.B.
3.C.
3.J.
3.X.
3. 1..
3.H.
7.C.
2.0.
a.r.
3.O.
4tC.
ti.A.
7.D.
Contract Management Xaaue*
invoice Keviewa
inadequate ctatament* of work
inadequate contract Adniniatratlon
and Financial Managanent
Mature of Iocatioa of On-aite Contraetora
EPA - contractor Fraternisation
Poaaitoility of Appearance of Peraoanel •anrie*
SPA soployee znteraction vlth coc nployee*
P*raonal aerrice*
negion-wlde
OFN
OFM
Waat* Mgnt
Wavte Ngnt
waate Ngnt
waate Ngmt
waata Mgoit
waata ngnt
waata ngnt
E«D
ont
OTM
Waat* Mgnt
one
Air
MD
High
High
High
High
High
High
High
Hadiun
High
High
High
High
Medium
High
IiOW
High
High
-------
17:33
005
VUIKERABIIiZTZES B* GROUP
Araae at Vulnerability
Division
of
vulnerability
a.m.
3.t>.
3.B.
a.r.
7. ft.
1.*.
2.X.
4. 1.
7. A.
7.1.
3.B.
4.A.
4.D.
5. A.
conflict of interact
potential conflict* of lnt*re*t-BPA/contr*ctor
conflict of xnterevt and
Limitation of Putur* Oontraoting
( Contractor /oentrae tor )
contractor* ov*r««*in9 other Contractor*
(Contractor/contractor )
•utooontractor* to B7A Cuutraotoc*
(Contractor /Contractor )
potential conflict* of int*r**t
(Contractor /Contractor )
EVA M*j»«g««*nt z**u*«
K»gion*l it»«oaro«*
EPA'* M«avy ft»liano« on CSC * x«** of control
Barli*r notification of Availabl* centra trt ptind*
EPA' e Reliance on BBAT - boa* of control
Xnh*r«ntly oov*rn*tantal Function*
contract Xnfornantion and Awar«n«** x*ftua*
Bnployee contract Xnf omation Training
Contract Xnformantion Awarana**
Point of contact for Admlnlvtrativa z**ua*
contract Avaren«** xafomantio and
Training for staff
OPM
wa*t* Mgnt
wa*te M9Rt
ifavte Mgpit
BCD
Region-vide
OVM
«a*t* Mgut
BOO
BOO
wa*t*> Mgat
CMC
CMC
Mater
Medium
High
Medium
Low
High
High
nigh
bow
High
High
Medium
Bigh
High
High
-------
04x01/92 17:36
VULHSMkBXLTTtgS «f GROUP
of vnliMrcbility
Xotonnatloa Maturity/confidential
3.B.
4.B.
ACTOM* to CBZ/BofocoMMnt *«n«itiv«
Xnfomantion ••euz-ity
0OS
Division
of
Vulnerability
ZnforM*ntion
Wa»te
High
High
-------
04/01 -92
17:38
007
l.JL.
l.B.
2. A.
2.B.
a.c.
2.D.
2.E.
a.r.
3. A.
3.B.
3.O.
3.0.
3.E.
3.F.
3.O.
3.H.
3.Z.
3.J.
3.K.
3.1,,
3.M.
.M.
VUt,K8RABXZ,XTZKS BY DIVISION
Araa* of Vulnerability
Regional fteaouroea
invoice Review*
EPA'* Hectvy Reliance on cec - LOSS at control
rot*ntial conflict* ot int«r««t - WA/contractor
Znad*quat« fitatWMUita of work
^•raonal fl*rrio*»
inadaQuate Contract Administration
and rinaneial Mana^amant
Phyaioal location of on»0it* Contraotor*
Datura of I^B contraoti work Han negotiations
Cost of Rework
Moo-AligiMnant of Program/contracts Requirements
Coat KeiaburveiMnt Contract*
with oedicatad reraeniMl
FI«/»it« A**«*aMnt vulnerability
Conflict ot interest and
x.i»itation ot rutura contracting
(Contractor /contractor )
Contractors overaaain? other contractor*
( contractor /Contractor )
Subcontractor* to BfrA contraotora
( Contractor /Contractor >
•PA - Contractor »zratarnisation
Aoeaaa to CBt/snforeMwnt eenaitiva information
Xarliar Notification of Available contract Funds
0tat««ant of work Dwalopnent
Perfornanc* Evaluation loprorestent
Prograjn Managenent office
Property in Possession of contractors
snployaa contract XnConoation Training
Division
Region-vide
Region-wide
OPN
OPM
0PM
OPN
OPN
OPM
Haste Mgnt
Haste Mgmt
HMt* Mgat
Hast* Mgat
Waste Mgmt
Waste Ngnt
waste Hgtnt
waste Mgnt
Waste Mgnt
Waste Mgnt
waete Mgnt
waste Mgnt
waste Mgmt
Waste Mgnt
i
Degreei of
vulnerability
High
High
High
Median
High
High
High
Medium
High
nigh
High
High
Medium
LOW
High
High
Low
High
Median
High
High
Medium
-------
17:39
008
VUZJMERA8XX.XTXBS BIT DXVZ8ZOV
4.X.
4.B,
4.C.
4.P.
5. A;
6. A.
7. A.
7.B.
7.C.
7.D.
7.X.
Araaa of vulnerability
Contract Xnforaantion Avarabaa*
Informnntion ••eurity
Poviibllity of App««rano« of Parioniwl varrio*
roint of contact for AdMiniatcativa Zaaua*
Contract Awar«aa»» ZnfonM&tio and
Training for ataff
BVA Bmloya* tntaraotloo with C0C Bnployaac
«FA'» Miliancc on BOAT - £o»» of control
potential conflict* of intarait
( contractor /contractor )
Xn«4aquata atatanant ef work
r«r»onal *«ryio«*
Zoharantly Oovariunairtal Fuootlona
Ol via ion
one
one
one
one
ttatar
Air
K5D
BSD
B*D
MD
B»D
vulnar
High
High
ZiOV
Vl0h
Bl«b
High
Hlgb
Higb
High
Hlgb
Bigb
-------
04.-O1/S2
17:39
009
VULMKHABILITIBS BY RIBK
l.A.
!•».
2. A.
2.C.
2.0.
2.C.
3 .A.
3,«.
3.C.
3. P.
3.G«
3.H.
3. J.
3.X..
3.M.
4. A.
4.B.
4.D.
• *r v
».A.
ATM* of vulnerability
Hagional Reaouroea
invoice fceviewe
BPA'e Heavy Reliance on CSC - Loaa of Control
Zuadvquat* 5t»twn«nt« of work
Paraonal ••rvie»»
inadaquat* contract Adainiatration
and Financial Managanant
Hatura of IXJB contract i work Plan Hagotiationa
Coat of Rawork
Hon-Aliyoncnt of Program/contraota Kagoirwnanta
coat ftainburaanant contract*
with D*dieat«d »«r«onn*l
rza/8it» Aiaaaainant Vulnerability
conflict of interact and
Limitation of Future Contracting
( Contractor /Contractor )
EPA - contractor Fraternisation
Acoaaa to CBZ/Bnforoanant Mnaitive znfomatioa
•tateaent of WorX Oeyelopnwnt.
program Managamact office
Property in poaaeasion of contractor*
Contract znfoncantion Awarefl*aa
znfertnantion aecurity
Point of Contact for Adniniatrative Zaauei
contract Awarvneoa Znforiumtio and
Training for ataff
Divlaion
Region-wide
Megion-wide
0PM
0PM
0PM
0PM
Waate Mgmt
waite Mgnt
Meat* Mgnt
Waate Mgnt
waeto Mg»t
vaate Mgnt
Waete Mgat
Waste Mgat
weite Mgmt
CMC
ORC
one
water
Dagra* of
vulnerability
nigh
High
Blgb
ttigh
High
High
High
High
High
High
Sigh
Bigb
Bigh
High
High
High
High
High
High
-------
17:39
810
VULWERABZX.ITJBS BX RISK
Dagraa of
C.A.
7. A.
7,».
7.C.
7.D.
7.8.
2.B.
2.F.
3.B.
3.K.
3.H.
s.r.
3.X.
4.C.
Araaa of vulnerability
*»A BBpleyaa Intaraotion with c*C B^loyaa*
KPA'« H*li.ano» en MAT - fco»» of Control
rotantial confllotp of xntaraat
( Contractor /contractor )
Znadaquata (tatamant of Work
farfonal c»rric»»
inb*rani:ly oorar naiautal runotloaa
potantlal conCliot* of xntaravt-WA/co&traotor
rhyaloal Xiooatioa of on-0lta contractor*
Contractor* ovaraaalno; otbar Contraetora
( contractor /contractor )
rarfonMnea evaluation Zvprovaasnt
Xi^loyaa contract znforatatioa Training
•ubeontractor* to BB>A contraotora
( Contractor /Contraotor )
Barliar notification of Availabla contract ruada
poaaibility of Appaaranoa of raraonnal aanrioa
Di via ion
Air
•0D
VCD
MD
BCD
S«D
OFM
OTN
waata ngmt
Vaata Mgnt
Waata Hgnt
waata Mgwt
Waata Mg»tt
; OKC
Vulnar ability
Biffh
High
High
High
High
•i«h
Nadiwa
Madiiu
Madlon
Madion
MadittM
LOW
S«w
LOW
-------
04.-01/92 17:40 011
In light of recent events concerning problem* with EPA's management
of several of the Agency's contracts, the Agency's Administrator
made a commitment to undertake a thorough review of the strengths
and weaknesses of the Agency'0 contract and project management
efforts.
In the Administrator's March 10, 1992 memorandum, he requested that
the Region perform an assessment of all present or potential
problems related to contract and project management.
The following areas of vulnerability have been identified as having
an impact across all programs within the Agencyi
1A. REGIONAL RESOURCES: In recent years, the Agency'* workload
has increased in larger proportions than the workyear resource
distributions. Because of the availability of contract
dollars the Agency has relied increasingly moce on contract
support to accomplish the missions of the various programs.
within the Region, we have reviewed all contract functions to
identify areas where an EPA employee should be performing the
task to strengthen the internal control and provide an arms-
length working relationship with the contractors.
To remedy the immediate needs with the CSC contractors, four
(4) FTES need to be distributed to the Region immediately to
maintain the current work levels.
For the Region as a whole, to reduce our reliance on
contractor work, we will need a significant shift of contract
dollars to PTB resource within the Region*
ACTION PLANS
\
• Regional senior managers will work closely with the
Administrator and Headquarters counterparts to emphasize
the need for additional resources within the Regions to
support contract administration* During the Budget
Formulation process Headquarters should incorporate
additional resources for program and contract support
management.
• Regional managers will work with Headquarters to initiate
hearings with OMB to begin the process of converting
contract dollars to PTBs.
iB. XftVOXCB REVIEW* The Region is particularly vulnerable in the
area of invoice review* In some contractual agreements,
complete and accurate information concerning charges are not
received by the Project Officer for review. During our
assessment it was determined for many of the contractors
working under a Beadguartera delivery order, the programs have
-------
04X01.^92 17:40 3i:
no accasa to the invoices prior to payment. There 10 no
protection against fraud by the firm and accountability by the
Region is not maintained.
In the removal program, contractor cost* are computer tracked
on a daily basis and reinforced by Daily Log* (EPA Form 1900-
55) kept by On Scene Coordinators. These 1900-55 Reports
become the cornerstone for EPA approval of charges prior to
the contractor's submittal of monthly invoices. On the
remedial side, this is not the oase*
Remedial charges are stated by the firm in its monthly invoice
and progress reports to the agency, but may not represent real
work or exact charges for work performed only on an SPA site.
Complete and accurate information concerning remedial charges
axe not received by the program until a final audit by the
OI0, long after the payments have been made to the firms.
fiuch problems with remedial charges will take on even mor«
consequence if the agency moves to a •mission" approach where
the tasking of the contractor will be made and accountability
reduced until completion of the "mission."
T2ie recently implemented Invoice Procedures improve the
accountability issue but may not truly ensure that all charges
reflect work solely performed by th« firm on the EPA site.
The Region has recently developed and implemented invoice
Procedures which identify specific responsibilities for the
Work Assignment Managers/Remedial Project Managers, the
Project Officer and the Contracting Officer/Contracting
Specialist. This procedure will be able to ensure that
appropriate review of the monthly charges has been done and
will provide information in the official contracts file.
However, due to the nature of the remedial on-aite overview,
EPA will still be uncertain that the site charges are fully
accurate and that office charges reflect only work performed
for EPA.
ACTION PLAN:
The Region will charge its Contract Management Team to
review options whereby more scrutiny can be maintained
for invoice review*
The Contracting Officer/Contracting Specialist and
Project Officers can perform more detailed analysis of
costs based on the independent government estimates
prepared initially by the Cost Estimator.
The Division recommends that the OIG agree to perform
audits on a site specific basis rather than a contract
completion basis f this would reinforce to the contractor
the heed for accurate and timely accountability.
-------
17:41 Q13
Remedial contractors will be encouraged to use Site Daily
Logs which will be submitted to the Project Officer on a
monthly basis. The Project Officer vill work with the
Work Assignment Managers to determine reasonableness of
invoice costs.
-------
04X01X92 17:41 01<4
March 24, 1992
CSC • UU GOmBlCTB
VUUBBRABXLXTY AS8B88MBNT
Baaed upon the IG'a CSC Audit recommendations and subsequent
Beadquarter'e manoa, the following ara tha araaa of potential
vulnerability along with action* 1MB has taken or ia considering
in Region IVt
2A, BPA'S HEAVY RELXANCX ON CSC - Sinoa tha 1970s and at OMB's
direction, BPA haa inoreaaingly turned to oontractora to
provide a broad range of IRM service*• The Region ia
heavily dependent on two contractoras CSC for 50 workyears
and LAI for 28 workyaara (not all funded by the Region).
Overall we believe our uae of theae oontraotora ia
conaiatent with tha contract acopea and guidance received aa
to what government funotiona can ba contracted. There are
aeveral areaa where the Region eould ba aubjeot to
criticism
a) We have 17 LAI contact personnel aupporting tha
Region'a quickly growing and aoraly needed Recorda
Management Program but we do not have an BPA
•taffperaon other than a email portion of the 1MB
Section Chief/ Rebecca Kemp, tine devoted to managing
the Region'* Recorda Management Program. 1MB plans to
convert an exiating FTB/poaition to be the Region'a
^ Records Officer but ia waiting on the approval of a
diaability retirement requeat which will free the
poation for conversion.
b) He have a CSC ataffperson maintaining the BPA
Personal Property System (PPAS). The 16 considers this
an area of vulnerability because PPAS tracks BPA
equipment which ia uaed by CSC. BRMB would need to
evaluate vulnerability and options available to reduce
this perceived risk.
c) We have a CSC staff person as the System
Administrator for the Region'a 6Z6 computers. This ia
a key, full time job which preferably should ba an BPA
/ employee. An FTB would need to be allocated to do
this.
d) 1MB'a only secretary has shared phone answering with
the CSC administrative staff. 1MB will need a full
time employee or SBB/AARP person to replace CSC
support, particularly as CSC and 1MB staffs are
separated (see below).
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&VSl'-92 17:42 01=
2B. POTENTIAL CONFLICTS OF IHTBRBST - Region IV has maintained a
business-like yet friendly relationship with esc and IAI
over the years. There are a few instances of relative* of
BPA staff working for CSC. Also ion* staff baa moved from
CSC to EPA and via versa. An EPA and a CSC employee are
married. We are not aware of any compromising eituatione
that oould oau*e conflicts of interest. The following
actions are proposed*
a) Request the Regional Contracta Branch eetablieh
interim practical guidelines to follow.
b) Request EPA Headquarter* PCKD establish Agency
guidelines.
2C. INADEQUATE STATEMENTS OF WORK (SOW)- The degree of detail
that is necessary is a judgement call but there is clearly
room for improvement and updating in parts of the Region's
CSC SOW. Region XV is now revising the CSC SOW* and is
adding further detail. The IAI SOW should be sufficiently
detailed. The following actions are underwayt
a) Revise all SOWe for Regional CSC Delivery Orders.
b) Review and recommend improvemnta to the seven
Headquaters funded CSC Delivery Orders that support the
Region.
20. PERSONAL SERVICES - This again is a judgement call but the
Region is vulnerable because of the close BPA/C8C working
relationships and shared office space are indicators of
potential personal services. Actions being taken or
considered are:
a) The Region is further formalizing the manner in
which work is communicated to CSC. This will be
defined in the SOWs.
b) Working within the constraints of available space,
the Region will separate EPA and CSC/LAI staff* Where
this is not practical, contractor space will be clearly
defined and the EPA/contractor communications will
strictly adhere to the procedure* defined in the SOWs.
c) If the Region is forced to further separate CSC and
IAI staff, space would be needed for 30 staff nemenbere
(approximately 1/2 floor in the Tower Building) in
addition to the space already reserved on the Ground
Floor of the Tower Building for the new Records Center.
d) Over the past, year, CSC and LAI staff began wearing
special badges and using special office cubical name
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Q4/Q1/3Z 17:42 016
plate* to identify theoeelve* a* contract staff. We
will also add door signs on ground floor to indicate
CSC/LAI operated cervices (i.e., Library, RXVXC,
Computer Center and Record* Center).
e) All oontraotor etaff ehould be identified a* CSC or
LAI in the Region'* Telephone Directory.
2B. IHADBQUATB CONTRACT ADMHrX8TRAT2ON t FXHAMCXAL MMUkOBMBNT -
Working with availble reeooroe*, the Regional DOPOv
(Delivery Order Project Officer) and Ta«k Project.Officer*
do an effective job of over*eeing and adaiinietering the
Regional CBC and JAl delivery order* in the Region but the
IO i* recommending more contract adnini*tration. The Audit
will lead to increased formality and more procedure*,
training and paperwork. Therefore, the following action*
may be neoe**arys
a) The Region need* to »erion*ly consider dedicating
two new FTB* (a OM13/14 level aanager and an
Administrative position), full tine to administer the
CSC and LAI contracts.
b) Provide additional training in contracts
adminiatration for all DOP00 and Ta«k PO*.
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17:43 017
AREAS OF VULNERABILITY
5p Phvalcal location of on-«it,e
Tha fact that thaaa thrae contractor* wu«t ba located at th«
EPA facility oraataa a possible vulnerability. All SPA
anployaaa nay not know which paraonnal ara EPA and which ones
ara contractor . Thaaa functions ara vary clbaaly intartwinod
with EPA paraonnal. For axanpla^ tha BPA aMployaaa' nail i«
•ortad and dalivarad by a contractor; alao, any BPA raquirad
phyaioala ar« parfomad by a contractor aa wall aa BPA
coordinatad apaeial projaota ralatad to tha Baalth unit.
PROPOSED PLAN OF ACTION J
Ragion XV will poat «ign« in tha wallnaaa Center, tha Health
Unit, and tha Nail Room vtating that theia function* Ara run by
contractor paraonnal. Thia fact will ba clear to all BPA
paraonnal who uaa thaaa particular facilities.
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17:43
018
WASTE NANAOBMSHT DIVISION - REGION IVt
CONTRACT VULNERABILITY ASSESSMENT
March 1992
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04/81/-92 17:43 019
A. GENERAL
1. What contracts do you use to support your program?
I. To Support Emergency Response and Removal Program Activities!
Purpose of Contract Contractor Nan* Contract Type
a. Technical Assistance Roy F. Weston CPFF*
b. Technical Assistance RAX, Inc. (8a) CPFF*
c« First Response OHM, Inc. CPAF
d. Bmergenay Response Westinghouse Bazteah CFFF
e. Emergency Response ETZ CPFF
£. Emergency Response Four seasons CPFF
g. Bmergenay Response OHM, Inc. CPFF
h. Community Relations Dynamac CPAF
i. Site Specific Contracts As Selected CPFF
II. To Support Site Assessment Program Activities:
j. BRS Package Preparation Dynamac CPAF*
k. ARCS/FIT B ft V CPAF
1. Site Assessment Support Bionetics CPFF*
III* To Support Remedial Program Activities!
m. Technical Enf. Support CDM/FPC CPAF*
n. Technical Bnf* Support Dynamac , Inc. CPAF*
o. Remedial Response Bbasoo Services CPAF
p. Remedial Response B * V CPAF
q. Remedial Response Bechtel Environmental CPAF
r. Remedial Response Roy F. Weston, Inc. CPAF
s. Remedial Response CDN/FPC CPAF
t. Remedial Oversight Peer Consultants CPFF*
u. Bnv. Services Support NanTech CPFF*
v. Site Specific Contracts As Selected CPFF
IV. To Support Super fund Management Services Activities!
w. ARCS Tracking Dvpmt. Roy F. Weston FFP
x. Records Management Labat Anderson FPP
y. Computer Assistance CSC FFP
z. Remedial Oversight RAX CPFF
aa. Risk Assessment ManTech CPFF*
V. To Support RCRA Program Activities!
bb. RCRA Permitting Support A. T. Kearney CPAF*
oc. RCRA Compliance Support CDM/FPC CPAF*
dd. RCRA Compliance Support Dynamac CPAF*
vi. TO Support RCRA Management Services Activities:
ee. Computer -Support CSC FFP
ft. Records Management Labat Anderson FFP
* indicates that the Contracting Officer is located in RQ-PCMD
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04X01X92 17:48 002
11
XDBNTXFZBD MOUUB OF VULNERABILITY
* :
3a« Mature of the LOB Contract Itsalft itork P^an Negotiations
Moat of tha Superf und oontraota vara procured aa Laval of Effort
(LOB) contracts, which focua on the contractor 'a ability to
provida to EPA "it a baat ef forte." The "beet efforts "
requirement plaoaa BPA .in two vary vulnerable positions* a) BPA
nniat bear the riek and ooat of reworking marginal deliverablee;
and b) BPA 'a mi avion to complete aite cleanups ia not a
requirement of the LOB oontracta that BPA muet uaa to accomplish
this objective* The LOB oontraota only require the contraotora
"to try." in other words, frequently BPA's mission requirements
and ita business methods are not aligned/ making it very
difficult for the agency to accomplish ita mission*
There ia a perception by the Region baaed on experience that in
many instances the Region has not reoeivad the firm 'a beat
ef forte bacauae costs or hours or deliverable haa not met the
Work Assignment Manager 'a expectations. The Region is then left
a limited number of optional accept tha deliverable aa ia;
provide more dollars or hours for the firm to provide aa
acceptable product; curtail tha assignment and give it to
another firm for satisfactory completion; ADO provide a reduced
award fee through the Performance Evaluation Board. Hone of
theae optiona meet the Region 'a need for e complete and adequate
product delivered on time*
The Region haa taken ateps to reinforce ita objectives to the
contractors and has atreased to Program Managers/ Oite Managers
and Senior Officials of the oontraot firms that we cannot
tolerate unacceptable work products. The Region's action to
Terminate-For-Convenienoe haa had a side-effect of highlighting
that the Region does indeed have excess capacity in ARCS/ that
wa made our decision based on a number of factors including
performance evaluation scores (PZRS plus PH ratings) and that
the Region ia serious about aaeking effective oontraot
administration by the firms.
PROPOSED PLAN OF ACTION I
The Region must addreaa the ooat of rework and the lack of
alignment of our technical and the gonftr act's requirements.
Ret Cost of Rework -
Tha Ragion wants to limit the often protracted negotiations
prior to a final acceptance of a work plan. The establishment
of tha Cost Estimator within the Division now provides a tool
for more efficient analysis of an acceptable cost range for
proposed work assignments (RI/FS and RD especially).
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B4/01.'-S2 17:48 0K3
12
The WAN will work closely with the CO/C8, PO and cost Estimator
to identify detailed tasks and to price these out to a
"reasonable" cost range.
The Division will limit negotiation to a set amount of time and
funds; this could be managed through a "cap" on the negotiations
based on the desired work product. Extensions beyond the "cap"
will be allowed following approval by senior program managers;
this is to emphasise that the "cap" is not seen as a rigid
administrative tool*
The Region will also seek to incrementally fund the work Plan
Development assignment in order to avoid full commitment of
funds and the delays associated with deobligation if no approved
negotiations can be established*
Protracted negotiations involve no risk to the contractors since
the agency is to pay for "best efforts," and jeopardize XPA's
meeting deadlines and program commitments. The Region will work
to develop acceptable detailed costs and timeframes to allow for
meaningful negotiations between SPA and the contractors but to
curtail the length of these deliberations. Through such means,
the Region will increase accountability in negotiations.
Ret lion-Alignment of our programs and contract requirements -
The Region will continue to eeek opportunities to award
site-specific contracts on a fixed price level and is evaluating
the feasibility of awarding a fixed price remedial design
contract. By uaing fixed price contracts, BPA's mission to
"complete" work is also borne by the contractor; this puts BPA's
mission requirements and our business method in alignment. We
have previously placed and awarded site-specific removal
contracts; site specific contracts have proved to be very
effective tools. The Contracting Officer is now working with the
Remedial Branch officials to identify sites in order to place
and award site-specific remedial contracts.
Region IV should reexamine its Long-Term Contracting Strategy
Implementation Plans with an emphasis on contracts that will
provide us with more cost control and better services.
Specifically, the Plans should be revisited to determine the
feasibility of using fixed price contracts for having fixed
price components) which would place responsibility for
performance back to the contractor and provide EPA with the
contract vehicle it needs to manage contracted activities. In
particular, contracts with "dedicated" teams such as the
proposed FIT/TAT should be looked at carefully. Further
consideration should be given to firm fixed prices given the
repetitive nature of the work and existing historical data.
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04.-131/92 17:49 , 004
13
However/ if tha level-of-effort oontraot remains mm a
contractual vehicle for the agenoy/ then BPA must beoone mora
efficient in writing the SOW tacking the contractor; SOW* must
clearly specify agency needs.
3b* Coat Rir^Mi|?ur,sed Contract* with Dedicated Personnel
Coat reinbnreenent contract* are the leaat desirable types in
terns of Government versus Contractor risk since the contractor
has little or no incentive to be cost efficient* The FAR
(16.301-3) states that a cost reimbursement oontraot nay only be
need when appropriate Government aurveillanoe during performance
will provide reaaonable assurance that efficient methods and
effective cost controls are used.
Of the various types of cost reimbursement contracts/ those
requiring dedicated personnel are the most likely to be abused/
or give the appearance of being abusedr for personal services.
In some oases this is caused by the very surveillance required
by the FAR/ but applied in an overzealous and supervisory
fashion rather than as a monitoring effort.
PROPOSED PLAN OF ACTION!
The Region's oontract team (Contracting Officer, Project Officer
and program officials) will review requirements with a focus of
eliminating contracts with dedicated personnel whenever
possible* Zf dedicated contracts are deemed necessary» the
Region will add more checks and balances to ensure that
Government personnel axe not overstepping the bounds of personal
services and have periodic reviews with reports to management on
all dedicated oontracts.
3c. FIT/Site Aaaaaamant: Vulnerability
The transition of the site assessment work to the ARCS contracts
creates an area of vulnerability because of the nature of the
previous FIT oontract being fully-dedicated as conpared to the
current ARCS contracts being the exact opposite. In addition,
the same contractors who were responsible for tha aite
assessment work under the previous contract and have now become/
because of their experience/ the new subcontractors under ARCS.
The intent in this new situation is to continue to operate and
interact as if the new contract remains a fully dedicated
contract/ which it does net.
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04x31/32 17:50 335
14
More importantly, tbe peculiar aapaota of the ARCS contracts
could potentially oauae administrative conflicts for thoaa
individual* not attentive to the contract difference** Some
apeoif io araaa of concern are contractor* involved in writing
agency guidance; oontractora communicating need* directly to the
program inatead of the Project Officer; property purchaae* being
made without coordination of the appropriate people (PO and CS) ;
and the utilisation of faoilitie* and reaouroea in a manner not
allowed in the scop* of work for thia ARCS contract*
The Region haa met with tbe ARCS prime oontraotor reaponaible
for aite aaaeaament to atreaa the need for vigilance and
compliance with existing ARCS procedurea throughout thia effort*
The prime contractor muat atreaa to ite subcontractor that the
ARCS contract i* different from the previously dedicated
contract and that proper communication concerning taaking and
equipment use muat be referred through the Project Officer*
The contract team will reinforce thia administrative me**age.
PROPOSED PLAN OF ACTIONS
Tha Contracting Officer and the Project Officer will continue to
provide surveillance of all contract action* and continue to
eduoata BPA program personnel in the Site A**ea*ment Program of
the required and naceaaary procedures for effective contract
administration .
BPA will review the exieting contract type utilised for aite
assessment work and make the naoeaaary adjustments to procure
and award a contract that ia moat auited for the type of work
involved in the site assessment program*
3d* Conflict of Interest and l*4BUt"tfltions on Future Contgaotinc
In many oases , contractor* under contract to Region XV
frequently represent private responsible partiea and other
federal agencies in negotiationa with the agency* Such
representation does not take place on the aame sites. Since
most contract* are non-dedicated, thia aituation ia inevitable.
In aoma cases the contractors have been found to represent both
EPA and other responsible parties on different matt ere; this
leaves the perception of a COI. COI procedures are in place*
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&4/-01/92 17:50 336
15
PROPOSED PLAT! OF ACTION I
Given the limited number of contractors performing hazardous
waste cleanup, the Division recognizes that there is no way to
avoid the perception problem. The Region will reinforce to the
firm* that COI involves real AMD perceived conflict*. The
Region will await Final Guidance from BQ on COI.
EPA acknowledge* that contractor* are seeking new work in
hazardous wa*te management baaed on their experience, thu*
question* ol LOFC will ariee more frequently in the future.
Region IV will explore opportunities to u*e smaller
vite-specific contracts, preferably small and disadvantaged
businesses, to perform certain program task*, thu* reducing the
COI/LOFC impact since many small firms will not have been
extensively involved with private parties or other federal
agencies.
3e« Contractors Overseeing Other Coi^r, a.c.tor§
EPA ta*k* our hazardous waste contractor* to overview the work
of other contractors performing work for Responsible Parties who
are under EPA Orders. Since NAM* cannot always be on site, EPA
cannot be certain that proper oversight is truly being
perforated. On our removal *ite*« OBCs do conduct extensive
oversight. In addition these prime contractor* are very
familiar with each other and often enter into business
relationship* with each other.
TAT does have access to BRC8 CBI data (rates, provisional costs ,
G&A percentages, ejfeg. ) in order to document costs through ROMS.
The OSC presence on site does provide the agency with a higher
degree of confidence that adequate work is being performed by
the contractor. However, we do recognise that we are vulnerable
on EPA-Lead sites where other contractors are spending our funds
(BROS assignments) when these firms are also involved on other
work for Responsible Parties.
PROPOSED PLAN OF ACTION 1
EPA will review its oversight procedures, including federal
facilities, to ensure that valid techniques are being applied.
The Region will submit a request to BQ PCMD for them to develop
guidance regarding appropriate contractor roles in the conduct
of oversight responsibilities.
Spot cheeks of EPA and RP contractor performance will be
performed by WAM» working with CO/08 and PO.
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.-92 17:51 007
16
COI issues will be addressed promptly to maximize contractor
objectivity on EPA sites.
The Region will explore opportunities to use •mall and
dieadvantaged business in order to seek contractor* not a*
extensively involved with perceived conflict situations .
3£ • Subcontractors to BPA Contractors
A serious vulnerable area involves use of subcontractors within
the hasardous waste cleanup activities* Since the number of
firms involved with hazardous waste aanagenent are limited, nany
of then enter into subcontracts with each other* These
arrangements are legal and beyond BFA's control but are of
concern to the agency* The situation arises that a prim
contractor may become another firm's sub and vice versa* This
again may raise the issne of conflict perception regarding the
firm's objectivity to represent BPA. Another serious problem
nay exist in terms of the subcontract since BPA is not in a
privity arrangement with subcontractors.
PROPOSED PLAN OF ACTZOUt
The Region will analyse the extent of this situation and attempt
to •neourag* oenplianee by our firms with the negotiated goals
for small and disadvantaged business utilisation.
The Region will emphasise to its prime contractors the need to
maintain credibility of its tasking assignments through
avoidance of "extensive role reversals" in the prime - sub
business relationships.
3g« BPA — Contractor Fratmrti «
The presence of CSC and other contractors within the normal BPA
facilitias does encourage a degree of fraternisation and a
perception that contractor and agency employees are to be
treated equally • The on-soene relationship of TAT and BROS and
BPA employees working to resolve an emergency situation for an
extended period of time fosters fraternisation since most of the
sites are located in rsmote areas.
PROPOSED PLAN OF ACTION:
Agency controls concerning fraternisation and allowable rules of
conduct exist already; these will be raemphasized to all HAMa,
oosr co/css and POs involved with contractors. The agency
should develop and disseminate agency-wide "ARMS LENGTH" policy
for dealing with contractors.
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17:51 008
17
The Region will establish semi-annual, Standard of Conduct
Briefing* to inform BPA employees in general about changes in
laws governing Proouratnent Integrity and Conflict of Interest
issues. Ethics training ha* been conducted for OSCn.
The Region muot take action to eeparote contractor personnel
from BPA personnel, by locating then in a distinct location
within the building. On-*ite contractor personnel are to be
Identified by a badge which differ* from the BPA employees'
badge*
Unlimited access to the building of Superfund or RCRA
contractors shall be curtailed. These contractors shall not be
allowed unescorted in the OPM-Contracts area or the Contracts
Management Unit within the waste Management Division due to the
presence of sensitive contract Information.
BPA employees will take more vigilance in securing contract
documentation at their work stations.
3h. AQO«»» to CBi /8nf oiroittent Sensitive. Information
The presence of on-site contractors can jeopardise the agency's
guarding of Confidential Business Information or Enforcement
Sensitive Information since these contractors may have immediate
aooess to BPA employee work stations or computer programs.
On-site contractors are significantly involved in retrieving
cost recovery documentation and reconciling cost documentation*
On-site contractors are also involved in flagging enforcement
sensitive data for the removal program* Contractors also do
payroll for Superfund projects*
In HQ* contractor personnel are responsible for entering
enforcement data into the TBS tracking system (TESHATS).
PROPOSED PLAH OF ACTIONt
Separation of on-site contractors to a location removed from the
program or contracting personnel can more surely safeguard such
sensitive information.
CSC access to such information through their aooess to all
computer programs must be examined by IRM and new safeguards
developed to ensure that only legitimate BPA personnel have
access to the information. Access to official files will be
limited through presence of an authorized BPA employee.
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04/81XS2 17:52 009
18
Restricted building access to other SPA contractor* ha* been
implemented.
The Division recommends to 0PM to reconsider the currant
structure in Finance which ia to serve coat recovery purpose* t
The Division alao recommend* that a aecure separate location be
found to house CBZ and other sensitive documentation.
3i» Ear liar Notification of Avail able tfontracfc Funds
It ia eaaantial for program planning that information concerning
Fiscal Tear Allocation of Fund* ba made available to the Region*
early in the FT. We are ueually near or in the Second Quarter
before we know what fund* have been allocated for the program*.
In addition, what we are told by our BQ counterpart* regarding
Regional fund dietribution nay not reflect the fund* received by
the program* due to varioua "tap*" made by Regional Budget staff
(Oranm-Rudaan, nanagenent fees, drug free program/ employment
bill, flic.). The vulnerability in *uoh late notification la the
effect it ha* on coat of feotivenee* and ensuring that the top
priority project* are being funded.
PROPOSED PLAN OF ACTION I
The Region will eeek to have Headquarter* provide earlier
notification and subsequent prompt allotment*, acknowledging the
realitie* of Congreaaional approval* and OMB release of fund*.
3 j • Stp'frffinpnl^ of Work Development
The SOW ia key to ensuring that BPA will u*e a contractor to
provide a quality work product. The SOW nuat be detailed enough
to allow the contractor to know what BPA ia aeeking. iQEa
must be detailed enough to strengthen the Region's negotiating
proce**. Often the SOW i* unclear and cost* are such that allow
acre room for charges than initially sought by the WAM.
PROPOSED PLAN OF ACTION I
If the LOB contract vehicle remains in use. then BPA must become
more efficient in writing a Statement of Work that clearly
specifics our need*. In addition, the agency mu*t implement the
necessary step* to ensure that project* are monitored and
performance doe* net deviate from the scop* of work* The
Contracting Officer, the project Officer and the Cost Estimator
will work closely with the WAM prior to final development of the
Statement of Work to ensure that SOW language is clear and
adequate to ensure quality deliverable and that deadlines and
coat* are realistic and achievable.
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04/-01/92 17:52 010
r> . r^
19
WAMs are to be reminded that thay cannot direct the contractors
to perform work outside the Statement of Work, paraonal
aarvioea cannot be performed by any BPA oontraotor.
Tha Coat Batimator will work with RCRA ataf f to provide
appropriate training/guidance on coat estimationa •
3k* Perf or^^noe BvaluatiiPJl IffPir0
BPA muat make tha evaluation prooeaa work effectively, not juat
aa an incentive to the contractor through the award fee, but aa
a gauge of regional aatiaf action with oontraotor performance*
HAMs rnuat adequately detail the evaluation of the contractor 'a
performance, thua providing adequate background information to
aaaiat tha PBB evaluation rating*
PROPOSED PLAN OF ACTIONS
Regional management will reinforce upon WAMa and osca the need
for detailed evaluation of contractor aite-apeeifie
performance .
The respective POa will provide information from tha contract to
assist the WAMa and OSCs with evaluation criteria. Managers will
follow-up on deficient or late ratinga to enaure that the
Performance Evaluation Board receives adequate information on
which to base their recommendations to the TOO.
Regional senior managers will meet periodically with contractor
officials to discuss performance and program needs.
31* Program tjanajement Office
Multiple contracts were intentionally negotiated to serve
estimated program needa and to encourage competition. These
contracts contain required minimum hours and feea which muat be
met regardless of total use of the contractor by the Region. We
acknowledge that the availability of competitive firms is a
plus* Overcapacity ia a vulnerable issue due to these mandated
carrying charges associated with the contracts (Base Fees,
Program Management costs).
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17:53
20
In addition, SPA has com* under intense criticism by Congress
for allowing use of contract fund* to support program management
offices. Even though allowed by the contract* the perception
exists that funds are being used for contractor maintenance
rather than directly for site clean-up. Administrator Reilly
and OMB have indicated that they want PM to Site Specific Cost
percentage* in the ARCS contracts to be minimal; EPA indicated
PM costs could not be more than 20% of total costs, OMB is
seeking 15%. BPA has not yet fully identified what the
parameters will be to calculate this PM percentage. However/ BQ
is in the process of requiring the ARCS contractors to
zeclassify PM costs to include in their invoices
PM-Administrativa, PK-Technical Support and Site Specific Costs;
this reporting is to begin by June 1992. There is strong
concern that this will not necessarily improve the efficiency of
the ARCS program.
Region IV implemented a senior level ARCS Management Tean in
January 1991 to review capacity needs of our six ARCS firms.
Analysis indicated that our program needs did not warrant a
total of six firms. Basing our decision on capacity needs and
costs savings, in 1991 the Region took action to
terminate-for-oonvenience two ARCS firms (CB2MBill and Bbasco
Services). The problem in ARCS was not that too many contracts
were awarded but that the base LOB projections were too high
when coupled with our successful enforcement efforts.
PROPOSED PLAN OF ACTIONt
The Region has formalised its ARCS Management Team to continue
its evaluation of contract capacity needs. The Regional
Performance Evaluation Board has included a review of capacity
at each rating period.
The Region baa analyzed the capacity needs of other multiple
contracts for BRCS and found that the capacity issue
satisfactory. Contractors will be informed by senior management
and by CO and PO that capacity and cost controls are of
paramount concern to the Region.
Mew contracts will be negotiated without such mandated charges.
Region IV is seeking to eliminate PMO separate charges in future
contracts.
For present contracts/ BPA contract personnel shall periodically
participate in the Financial Monitoring Review team reviews to
ensure accurate PMO charges are being made.
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04'-ei/92 17:53 012
21
Monthly PMO charges will be analysed with the focus being on
limiting the ratio of PM to Sit* Specific charges to the OMB 15%
target*
Region IV will be working with its contractors to restructure
its ARCS invoice reporting to Allow for Site, PM-Administrative
and PM-Terchnical Support charge* t in accordance with BQ
directives .
3m* Property
EPA cannot always be certain that governmental property is being
used in the manner specified under the Contract, that the
property is properly being tagged as MSPA Property/" and that
the property is being solely used for EPA work* Resource
constraints prohibit frequent on-site audits. The Region
maintains a dedicated warehouse to support the site assessment
work; this facility haa extensive EPA Property including
vehicles. BPA cannot be completely certain that all government
property is being used solely for BPA purposes.
PROPOSED PLAN OF ACTION I
Region IV will work with HQ's Property Office and SF
Acquisitions Manager to ensure that contractors are properly
accounting for governmental property* Informal audits will be
periodically conducted by Region IV personnel*
Region IV will follow up on the recent Property Audit to ensure
compliance by the ARCS firms.
BPA will emphasize to the prime contractor responsible for the
maintenance and support of the dedicated warehouse that
government property, including use of vehicles which are clearly
marked with "EPA" license plates, are used for authorized BPA
work by contractor employees.
3n.
OSCs, HAMs, CSs and POs are required to take specific contracts
training in accordance with the Contracts Management Manual.
Often these courses are cursory in nature and do not adequately
prepare BPA personnel for administering diverse contract
responsibilities. There is a not a comprehensive/centralized
tracking system of WAM/PO training. With the addition of
Recertification requirements, this becomes more important.
-------
04'-ei/92 17:54 013
22
PROPOSED PLAN OF ACTION I
Contracting Officer will seek more appropriate training courses
for BPA staff involved in contract administration, providing
more in-depth .training to POe.
HQ should develop courses to cover critical vulnerable areas to
assist technical pereonnel*
New employee* will work with the C8 and POs and senior WKMs to
develop the necessary tools for contract administration.
Performance Agreements will incorporate contract administration
as part of PY standards for MAMs. Senior Managers will ensure
that HANS take the required courses within timeframee
established by the Divisional training profile.
PO and CS personnel will continue to neet periodically to review
contract issues; if necessary, Contract Advisories will be
developed by the Contracting Officer.
-------
34/01/02 17:54 - 014
\ •'"- .-">
\-
4 • Office of flftq^onal Counsel !
Identified Areas of Contract Vulnerability within ORCt
A» Contract: Inforraation ft|f
There is little information or control over staff contacts
with contractor personnel, which oould lead to a lack of
prioritization of tasks or to initiation of tasks outside
the acopa of the contract, information regarding the
service* that can be provided under the contract* ie
insufficiently distributed, which may lead to under
utilisation of the contractor* for services provided through
the contract. There is insufficient available information
on how to deal with contractors regarding new services that
nay be useful to ORC. Such a situation can lead to informal
discussions and possibly "new tasks" being generated
inadvertently. Generally there is an absence of information
on the quality of services rendered, which may lead to
problems being unaddreased through the proper channel*.
Plan of Action:
1. For all contractors, establish management
responsibility within ORC for monitoring requests for
contractor services and adopt a standard procedure
whereby the Project Officer provides a monthly report
of assigned tasks and status of each for review by ORC
management.
2. Obtain accurate information from the Project
Officer regarding the service* to be rendered by each
of the contractors providing support to ORC and ensure
full distribution within ORC.
3. Acquire information from the Project Officer
regarding the proper method of discussing new and/or
different tasks that may be appropriately provided by
the contractors.
4. Establish a system whereby the responsible ORC
person (see Item 1 above) receives information from the
case attorney relative to the quality and timeliness o£
each ta*k completed by the contractor.
B. Information Security
Information i* needed rleative to the measures in place to
ensure the security of BPA records /documents in the
possession of the contractors*
Plan of Action
1. Acquire information from the Project Officer and/or
security services contact regarding the document
-------
-------
34/01,'32 IV: 55 015
security meas».«.-es in place in the contractors' work
area.
C. Possibility of the Ama«iai-ana« of Personnel Services
one OKC employee is on the same telephone number A* several
Agency contractors, BO on occasion a contractor may an0w«r a
call which turns out to be for BPA.
Plan of Action
1. Arrange, through the proper offices, to have the
BPA employee placed on a separate telephone number.
D» Point of Qpntaot for Contractor Admini-atara^,i.Yft Tumnmm
Because of the nature of the position, the Administrative
Officer may become the point of oontaot for apaoe,
telephones, mail distribution, and other matters relating to
contractors' work related to ORC activities*
Plan of Action
1. Handle items relating to contractor space/
telephones, mail distribution and other matters through
the appropriate Project Officer.nation is needed
relative to the measures in plaoe to ensure the
security of BPA records/documents in the possession of
tha contractors.
-------
17:53 016
5. Water Management Division Contract Vulnerabilitiee
A* Contract Awarensa Inf orma -^-n^-nJ fog Staff
in general, Water Division appears to manage a limited
number of Contract*. Moat are nationally managed LOS
type contracts. However, certain vulnerabilities do
arise as a result of the survey*
1. All work assignment managers need to have received
appropriate training.
2< An updated contracts management aanual should be
made available in each section that manages contract*.
3« Section Chiefs who manage contracts should be
certified as Project Officers and perform oversight of
work assignments.
4. All managers should be familiar with contract
principles, i.e., contracting in EPA (BPA Order
1900.2).
Plan of Action
Initiate a Division wide contracting education and
training survey to inventory the extent of the
identified vulnerability, then seek appropriate
training.
-------
17:55 017
6. Air, Pesticides, Toxic Management Division
• vulnerabilities in Contract Management
A. Interaction With CSC
The vulnerabilities identified by the Air Division
are basically the vane a» OPN identified with the
management of the CSX) contract* consequently, their
concern* are included in the OPM vulnerability
assessment.
Plan of Action
A abort caee history of epeoifio problem* that were
identified with the management of the CSC contract
within the Air division will be drafted circulated,
and read by all manager* within the Division*
-------
&4/-01--S2 17:56 018
7. BBVIBOHOHZILL SERVICES ABSI8XANCB TKAM
(BSAT) CONTRACT VOLHBRABILITY ASBESSJOOiT
in recent weeks considerable negative attention has been focused on
contract management in BPA. Much of this attention has focused on
Inappropriate, personal service contract relationships between IPX
and contractors. Tha Acting Assistant Administrator for OARM, In a
February 28, 1992 name, afflrmad tha Agency's commitment to address
improving our management of SPA contracts. On March 23, 1992, the
Contract Management Division (CUD) provided ESAT Regional Project
Officers (RPOs) with new guidance on BSAT contract management and
indicated that CUD will conduct on-site audits at all regional
locations in the near future.
Based on Headquarters memoranda * instruction from CXD, and internal
Regional examination, the following areas of potential
vulnerability have been identified along with a proposed course of
corrective actioni
A. BPA'8 RBTiTAMCK OH E8aTs The BSAT contract was developed to
augment Regional Environmental Services Division (BSD)
resources used in support of the Superfund Program. Primary
funding for BSAT Is provided by the Superfund Program. Other
programs (eg. RCRA, water, etc.) have become contributors to
Region iv ESAT funding through programmatic "buy-ins".
Region IV Implemented the BSAT contract in November 1987 with
an initial staffing of nine contract employees. Since it's
inception, the authorised Region IV Team sise has Increased to
37 employees. The Region utilises the BSAT contract to augment
regional analytical, Duality assurance, and field services.
Typicallyr the contract is used to providet chemical and
biological laboratory support, field sampling and analytical
support, quality assurance review, Contract Laboratory Program
(CLP) data validation, risk assessment review, Field
Analytical Screening Project (FASP) operations! and Regional
Sample Control Center functions.
BSAT positions which are considered particularly vulnerable
are as follows! LAV Administrator- these responsibilities
should be performed by an BPA employee} Two field technician
positions- it is difficult to create necessary separation to
avoid personal service situations; RSCC function* requires
considerable interaction with BPA and field contract employees
in coordinating sample analysis scheduling.
Me are in the process of implementing a number of actions
items contained in the memorandum, "Proposed Action Plan to
Address Potential Contract Management Problems Related To The
BSAT Contract" (Action Memo) to determine needed corrective
actions.
-------
O4xei.'92 17:56 019
ACTION FLANt
• All task activities will be examined to ensure that they
are clearly within the scope of the contract Statement of
Work. Complete bv April 15 .
• All Work Team activities will be critically examined to
determine If there are personal services arrangamanta in
existence, or there exist tha appearance of personal
services situations. Those areas determined to be
questionable will be further examined to determine the
moat appropriate corrective action to alleviate the
problem • Complete bv April IB •
B. POTENTIAL COMrtiXCtti OF XBIBRSSTi We are not aware of any
situations which anggeat that the BOAT contract is
particularly vulnerable to conflicts of interest. There is a
requirement in the contract for the contractor to check for
conflict of interest on all work assignments.
ACTION FLAK I
• Mo actions planned.
C. INADEQUATE STATEMENT OF WORK (SOW) I Currently, B8AT is tasked
through tha use of generic Technical Instruction Documents
(TIDs) . While these TXD provide general task descriptions with
reference to specific Standard Operating Procedures and Agency
technical guidance documents, greater specificity nay be
necessary. This will be an area examined by CUD during their
upcoming audits. BSD is currently reviewing the adequacy of
our existing BSAT tasking process. (Refer to Action Memo)
ACTION FLAMs
» All Technical Instruction Documents (TIDs) will be
reexamined to ensure that the Task Descriptions
adequately describe the tasks to be performed and include
reference to required guidance and/or Standard Operating
Procedures, pomj^ete b
• We will assess the replacement of generic TIDs and
tasking each work unit on an Individual TID. This
examination will focus on the cost (in terms of time) of
using Individual TZDs , ways to minimize tasking delays in
using such an approach, and determine the payoff in terms
of providing greater management control. Complete by
Anril 30.
PERSONAL SERVICES* The Region is particularly vulnerable to
personal services situations with the ESAT contract because
the majority of the contract employees are located on-site.
Because of space limitations, It is difficult to provide
complete EPA and E8AT workspace separation and control
-------
17:57 020
employ** interaction. It in obvious that the first five
element* of personal service contract* are pr***nt to a
•ttbatantial degree with th* BSAT oontraot.
w* hav* located B6AT personnel in separate office workspaces
from BPA employees. The only exception is two offices which
are jointly occupied during a day-night shift change. This
joint occupancy occurs for a period of approximately one hour
each day. We have two laboratory situations where BPA and BSAT
employees are working in the aane laboratory* We are currently
evaluating how to address this problem area.
All BSAT employees are now wearing company issued
identification badges during duty hours. BPA employees wear
Agency issued identification badges during duty hours* BSAT
field and laboratory personnel wear field clothing and
laboratory coats of distinctly different from BPA's. The BSAT
clothing also bears a logo with their company's name.
Other initiatives are underway to further address the
avoidance of personal service situations (eg./ BSAT tasking,
employee instruction on avoiding personal services, workplace
separation, more rigid tasking requirements, increased
controls on technical direction, etc.). (Refer to Action
Memo.)
ACTXOB PLANt
Tour all BSAT employee work areas to ensure that there is
physical separation of BPA and oontraot employees, and
make recommendations for correcting any problem areas.
Complete by April IS.
Ensure that all BSAT office and laboratory work areas are
clearly identified. Complete by April 15 .
Ensure that all BSAT employees have and wear ManTech
Environmental Technology, inc. identification badges . The
BSAT Team Manager (BTM) has been directed to provide all
contract employees with badge* and instruct them to wear
these badge* during work hour*. Complatf* fry Mg»re>* *ft-
In* tract, the BTM that all BSAT laboratory, warehouse, and
field staff will wear laboratory coats or work clothing
which readily identifies them as contract employees.
Complete by March 30.
Conduct a mandatory seminar on "Avoiding Personal
Services" for all BSD employees involved with the BSAT
contract . complete, by i
Remove E8AT contract employee name* and number* from the
BPA telephone directory. Complete bv April 30.
-------
04-'01x^2 17:5? 021
• Issue a memorandum from the Division Director to all BSD
personnel specifying restriction* on contractor
participation in certain BPA activities (eg., staff
meetings , awards presentation* , training, socials , etc . ) .
ete by Aril IS.
• Issue a memorandum to the KTN and all BSD personnel
responsible for generating work assignments for B6AT
which specifies thnt all work assignments must be issued
only by the RPO« CPJBP1*^*B ^Y March 30 »
B. INHBRKMTLT GOVBJUMBHTAL FOHCTIOllSl An area that CMD will
examine is some KSAT functions to ensure that inherently
governmental functions are not being done by contract
employees. Areas such as QA/QC duties could possibly fall into
this category.
ACTION PLAN i
» Will be examined when CMD reviews BSAT
structure/operation .
We consider the BSAT contract , as it is currently structured, to be
extremely vulnerable. Once CMD completes its' regional assessments
within the next few weeks, it is very likely that the contract will
have some restructuring of both functions and operational
procedures, BSD is critically examining our management controls
over the BSAT contract to identify weaknesses and corrective
action*. (Refer to Action Memo.)
Currently, ESAT RPO responsibilities are being performed by Bobby
Carroll as a collateral duty. The RPO position requires more time
and attention than can be devoted by the RPO.
ACTION PLAHt
• Examine the need to realign the BSAT Regional Project
Officer (RPO) responsibilities and recommend suggested
changes to Regional management, cosipleiie by Mav is.
-------
-------
'i
? UNITED STATES ENVIRONMENtAL PROTECTION AGENCY
REGION IV
3«»S COUWTLANO STREET. N.E
ATLANTA. GEORGIA 3O3OS
MEMORANDUM
Date: April 16, 1992
Subject! Additional Contracts Information (Your request of
March 31, 1992)
Promt Donald J. Guiny ard ^
Assistant Regional /Kdwinistrator,
for Office of Policy and Management
To: Christian R. Holme B
Acting Assistant Administrator
for Administration
and Resources Management
Attached , please find the supplemental information that you requested
in your March 31, 1992 memo. Our approach is to send you addendums
to the vulnerability assessment that was previously provided to you.
The following documents are attached i
Attachment A Additional Region-wide Vulnerability
Attachment B Revised Vulnerability Matrix, showing
Action Plan Completion Dates
Attachment C Listing of Contracts by Division
Attachment D Contract Management Personnel by
Division
Attachment E Summary of Audit Findings
AB requested, we searched the FMFIA internal control reviews for the
past five years and found no identified contracting vulnerabilities.
There were three audit findings and they are included as Attachment E.
I hope that this information will help you in your efforts. If you
need further assistance, please do not hesitate to contact Jane
Sine? ley or Fran Ha r re 11 at FTS 257-2374. They will be happy to assist
you .
Attachments
Printed en Reoyotad Paper
-------
-------
Attachment A
-------
-------
Attachment A
Addendum to Region-wide Vulnerability Assessment
1C. POSITION DESCRIPTIONS AND PERFORMANCE STANDARDSx A change
to tha Contracts Management Manual (CMM) dated 8/15/91
requires that the position descriptions and performance
dtandardB of certain program staff and all EPA manager*
include criteria about their respective contracting duties.
These changes are in Chapter 7, paragraph 7.7 of the
Contracts Management Manual.
Supervisors must ensure that the position descriptions and
performance standards for Project Officers, Deputy Project
Officers, Work Assignment Managers, Remedial Project
Managers, Delivery Order Officers, Delivery Order Project
Officers, and On-Scene Coordinators include criteria on
their pre-award and post-award contracting duties.
All EPA managers, who have either direct or indirect
responsibility for the oversight of contractors, must have
language included in their performance standards emphasizing
strong contract management and controls. Such language must
recognize that EPA managers are responsible for ensuring the
proper utilization of contractors. The performance
standards should address items such ast ensuring employees
they supervise have adequate training in their contract
management duties; not utilizing contractors for the
performance of inherently governmental functions; and
ensuring that contractor employees are not treated as Agency
employees.
ACTION PLAN:
The Assistant Regional Administrator will issue a memorandum
to the Division Directors with the CMM criteria attached.
COMPLETION DATE!
September 30, 1992
-------
-------
Attachment B
-------
-------
Ufeto
Attachment B
Vulnerabilities By Division with Action Plan Completion Dates
P.I
Degree of Completion
of Vulnerability
I.A. JHaglciul nee
Division
».*.
2.C.
z.r.
3.0.
».*.
a.*.
3,1.
a.t.
a.N.
Petition M»0i:iptic>li*/»«£o*una« «td«.
of «iMtiEa
oanlUoc* at lnt*r**t
WAVMMtttt*
•*xvit.-»
Adainlktution
•nd
Caatnetori
of
Mtiur* of LOB Conttioti Work »Lui •••atiatlaiu
Celt uf Mwork
DRt of FvQ4*M»/
Cact tulabnncMat ContrMt*
Mlth 5«dic»fc»d V
»IT/*it. *>M«.nnt Vulnu-abi.lity
conflict of Inver»»v end
to
lnl.onut.ioa
**xli.»i NeUtiekVlon of Avtilmbl* Contrcat rnndii
of Work t>*v»lotw«nt
Progroi M»n»g»»»nt
j trmining
HUt* MQKt
W*ece Mgmt
•••«:• M^Bt
»••*• Myat
Wait*
Vn'fee Moat
W»et» Mgnt
W*rb«
High
•ifh
| Completed
•igl>
High
Ui«h
Awaiting Pinil Cuidanoe
High
High
Low
High
High
Biyh
*f-»t-»i
•f-i*-»a
-------
Valn*jr*biliti.» by Oivt»len wlvl. Aotlan »lmn delation
e* VuU«r*>ilifcy MvUion
p.l
of Cwtplction
Vulnerability tut*
4. A.
4. ft.
4.C
l.D
t .A.
«.*.
7.X.
7.D.
7.C.
7...
Contract Infarction Avannaa* | ORC
1
Intonation a paucity 1 okC
]
1
Pa«aibili«y 61 fcppaarana* of F«r*aun*L ••rvloB | OfcC
1
1
Point of Contact for Jufaiaiicntlv* X*»u*» j OHO
I
i
1
1
•FA a*pley«B Xoncrantion wivl. C«C fuplvymm* \ All
1
BtX'o ft*}&iMt0* Ott 89AT — Loaa o£ Control j S*tJ
1
1
!
In»d»^a«t» atntcacint cf warfc | (ID
I
1
1
Ituwzontly oov«rna»n»»l runetiona | IIP
1
High
•*,*
low
Bifk
Biyh
High
M*»l>
Ulfh
High
Bifh
l"-"-»a
O^plMM
0^,^^
.......
».«..»
coB(»».»t»a
COMPLY
C«cpl»t«d
*4.J*.y?
I4.je-»z
•9-15-18
-------
Attachment C
-------
-------
Attachment C
Pare
Contractor
Type S Amount
OFFICE OF POLICY i MANAGEMENT
Health Unit
Ada. Support Svcs.
ABP Support Svcs.
Library/Records Mgmt.
NBPA Studies
a.
b.
c.
d.
e.
i.
j-
k.
1.
B.
n.
o.
P«
q-
r.
s.
t.
a.
v.
Technical Assistance
Technical Assistance
First Response
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Site Specific Contract
Site Assessment Support
Technical Enf. Support
Technical Enf. Support
Remedial Response
Remedial Response
Remedial Response
Remedial Response
Remedial Response
Bnv. Services Support;
ARCS Tracking Dvpnvt.
Records Management
Computer Assistance
Remedial Oversight
RCRA Permitting Support
Comp. Health Svcs., Inc.
Tommy Nobis Ctr.
Computer Sciences Corp. (CSC)
Labat-Anders on. (LAI)
Gannett-Fleming
FFP
FPP
JD/IQ/CR
ID/IQ/CR
ID/IQ/CR
S.28M
$.12M
$1.1M
Sl.LM
$355K
WASTE MANAGEMBilT DIVISIOM
Roy F. Weston
RAX, Inc. (8a)
OHM, Inc.
Hestinghouse Haztech
ETI
Four Seasons
OHM, Inc.
OH Materials, Inc.
Bionetics
CDM/FPC
Dynaotac, Inc.
Ebasco Services
Black & Veatch
Bechtel Environmental
Roy F. Weston, Inc.
CDM/FPC
ICF Technology Inc.
Roy F. Weston
Labat - Anderson, Inc.
CSC, Inc.
RAI
A. T. Kearney
CPFF
CPFF
ID/IQ/CR
ID/IQ/CR
ID/IQ/CR
ID/IQ/CR
ID/IQ/CR
FFP
CPFF
CPAF
CPAP
CPAF
CPAF
CPAF
CPAF
CPAF
CPFF
CR
ID/IQ/CR
ID/IQ/CR
CPFF
CPAF
$ 42.8M
$ 3.3M
$ 26.5M
$ 24.2M
$ 22.3M
$ 23.9M
$ 26.5M
$ 1.5M
HAT'L
$ 29.5M
$ 29.5M
$111.5H
$110.5M
$112.8M
$ 46.6M
$114.3M
$ 18.7M
fl.lM
0.4N
1.1M
1,
8M
9.0M
3
3
2 & 5
2 & 5
3
4
1
3
3
3
3
3
3
6
4
4
3
3
3
3
3
3
1
2
2
3
1
-------
Purpose
CPA Audit Sycs.
CPA Audit Svcs.
Contractor
Type
OFFICE OF INSPECTOR GENERAL
fMABAGED BY OPM CONTRACTING OFFICERS)
HcBride & Lock
Brandon, Smith & Jones
ID/IQ/CR
ID/IQ/CR
$2.2M
$2.2H
3
3
On-Site Lab
ICF Technology, Inc.
EHVIRQMMEHT-AL SERVICES DIVISION
CPAP $18.7M
OFFICE OF REGIONAL COUHSBL
Contract Evidence
Audit Team Tecblaw
Docket Maintenance CSC
ID/IQ/CR
ID/IQ/CR
$32.5*4
$ 1.1M
Air Enforcement
Related Activities
(Training, Inspections,
Testing, etc.)
AIR. PESTICIDES t TOIIC MAHAGBHEKT DIVISION
Alliance Technlgy.
as above
Same aa above
Same as above
ADP Support Svcs.
Financial Info. Svc
Air Pollution Training
Institute
Pacific Environ. Svcs.
Midwest Research Institute
CSC
Information America
LOE
LOB
LOB
LOB
ID/IQ/CR
LOB
$311
TED
TBD
$1.1M
MAT'L
1
2
1
1
S
6
-------
Page 3
Purpose
Program Support
Technical Support
Tech. Support, Data Mgmt,
& Clean Hater Act Inpl.
Field Inspection-UIC
Data Bntry-NPDES
Data Entry-Wetland
Program Support-UST
Pernit/Enforcement
Program Support-PWSS
Hydrology Support
Contractor Mane
AMS
Battle Manorial lust.
Tetratech
Tetratech
Cadmus
CSC
CSC
ICF
Cadnus
Cadaus
Wade Miller
Type
WATER MANAGEMENT DIVISION
CPAP HAT'L
CPAF $48M
CPAF $15M
CPAF $ 6M
LOB KM"!
ID/IQ/CR $1.1M
ID/IQ/CR $1.1M
LOB HAT'L
LOB SAT'L
LOB KAT'L
LOB KAT'L
1
1
6
1
1
6
6
6
6
-------
Attachment C
MOTEft TO CONTRACT LISTING
1. Nationally managed contract. The Contracting Officer and Project
Officer are in Headquarters and either a Deputy Project Officer,
Regional Project Officer or a Delivery Order Project Officer is in
the region.
2. CSC and LAI are nationally, managed contracts but they serve almost
every Region XV Division, so they will appear several timee on this
listing.
3. Totally managed in Region IV.
4. Nationally managed zone contract.
5. Dollar amount shown is regional obligation - not total contract
amount.
6. Nationally managed contract. Total contract dollar amount is not
known.
-------
Attachment D
-------
-------
Attachment D
COHTOACTS MAKAGgMElIT PERSONHBL BY DIVISION
0PM
HASTE
MATER
ORC
AIR
BSD
Project
Officers
4
9
15
— _
___
Deputy
Project Officers
2
___
0
___
2
Work
Assign. Hnqrs.
100
26
11
On-Scene
Coordinator s
22
0
~»— . •
—
Contract
Specialist
14
___
0
„ UB
— -.—
___
28 4 137 22 14
Regional Total 205
-------
-------
Attadhment E
-------
-------
Attachment E
FINDING 5 OF OIG AUDIT REPORT B1SGB9-04-0016 DATED
12/26/98, ENTITLED "REGION IV'S REMOVAL CLEANUP ACTIVITIES"
-QUSSTIOHAB^p ypg OF ERGS CONTRACTORS/SUBCONTRACTORS ON REMEDIAL ACTIVITIES
OIG Recommendation*
5(a). Remind applicable Regional staff• of the restrictions on the
uee of ERCS contractors in cleanup actions under OSWBR Directive
9360.0-3B.
EPA's Corrective Actions for Finding 5(a):
5(a) Answered in 5(b)
OIG Recommendation;
5(b). establish controls to ensure staff compliance with OSWER
Directive 9360.0-03B and preclude actual/ apparent, or potential
conflict of interest situations involving ERCS contractors or their
subcontractors.
EPA'a Corrective Action for Finding 5(b)J
5(b). The Contract Management Unit, Information and Contracts
Management Section/ Waste Programs Branch, will develop Control* that
will ensure staff compliance with OSWER Directive 9360.0-03B as it
applies to actual, apparent or potential conflict of interest
solution* involving ERCS Contractors or their subcontractors. OSWER
Directive 9360.03B, as well as the Controls developed to ensure
compliance with this directive/ will be presented to all applicable
Haste Management Division Superfund Staff in a aeries of seminars
presented by the Contracts Management Unit,
Corrective Action Completed
-------
-------
6 & 7 OF DIG AUDIT REPORT E5EH7-04-0181-81927
DATED 9-26-88 ENTITLED "REGION IV'S
MANAGEMENT OF SIGNIFICANT SUPERFUND REMOVAL ACTIONS"
OIG Recommendation Mo. 6
The Regional Administrator shouldt
a. Establish and implement adequate internal controls to ensure that
Qn-Scene Coordinators do not go beyond the limits of their
authority by permitting contractors to begin work and incur
expenses prior to obtaining the Contracting Officer's approval.
b. Establish and implement standard documentation and filing
procedures to ensure project files contain complete documentation
of the history of site planning, authorizations/ and response
actions taken.
c. Establish and implement adequate controls to ensure that contract
delivery order scopes of work prepared by regional personnel are
clearly defined, avoid open-ended wording and require contractors
to meet performance objectives for proprietary technologies.
EPA'8 Corrective Actions for Recommendation No. 6(a)
1. The Region established regional contracting officers to support
the removal program, thus allowing the expeditious pursuit of
contracting mechanisms.
2. The Region will use direct competitive bidding (i.e.,
site-specific bidding), Pre-Qualified Offerers Procurement
Strategy (PQOPS), or other appropriate bidding procedures to
obtain specialized technologies.
EPA'S Corrective Actions for Recommendation No. 6(bl
1. The Region will comply with new Agency procedures regarding
standardized site files. (OSWER Directive 9360.2-01, July 19B8)
2. The Region will comply with new Agency guidance regarding
establishment of On-Scene Coordinator Administrative Support
-------
EPA'B Corrective Ret lone for Recommendation No. 6fci
1 . The Region will have Regional Contracting Officers support the
On-Scene Coordinator* mo that delivery orders and other documents
involving contractor direction or performance are sufficiently
clear and identify the objectives to be mat.
2 . The Region will have the Regional Contracting Officers attend the
monthly removal staff meetings.
Corrective Actions Completed
n No. 7
The Regional Administrator should:
a. Establish and implement adequate controls to ensure that on-scene
coordinators effectively monitor contractors to achieve treatment
standards required by contractual terms*
b. Take appropriate measures to ensure that the hazards remaining at
General Refining and Peak Oil after prior removal activities are
adequately addressed.
Corrective Actions for Recoamnendatign No < 7
1 . The Region will have the Regional Contracting Officers anwist
the On-Ccene Coordinators in developing contracts and in
assuring that contractual terms are met.
2. The Region will conduct additional cleanup at the General
Refining and Peak Oil sites. Additional cleanup at General
Refining is planned for nay-August 1989 and will involve
solidification/fixation of the 10 f 000 yards of stockpiled
waste. At Peak Oil/ further cleanup of the remaining tanks
(including liquids and sludges) and the ash pile will be
accomplished. It is not expected that the PRP's will
participate in these cleanup activities.
Corrective Action Completed
-------
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
77 WEST JACKSON BOULEVARD
CHICAGO. B- 60604-3590
ǤFIY TDTM AmMTON OP:
SUBJECT: Contract Management Reviev
FROM: Valdas V. Adamkus
Regional Administrator
TO: William X. Railly
Administrator
As requested in your March 10 memorandum, Z an reporting our
assessment and proposed action plan for all potential problems
relating to contract management. Region 5 has already
implemented many contract improvements and we plan to further
strengthen our contract practices.
Our short-term strategy is to reviev and improve our present
contract management practice*. Our long-term goal is to assess
Region 5 future work requirements and determine the best means
for performing that work—contract or in-house. If contracts are
required, we will asses* the number and types.
Region 5 initiated a contract management reviev in early March,
first focusing on the CSC contract. We plan to expand the reviev
to include Labat Anderson, Boos Allen and other on-site
contractors. We plan to complete our reviev by the first week in
May, given CSC cooperation. We have submitted an outline of our
reviev plan to OARM (Attachment l).
As a result of our awareness of good contracting practice* and
the results of the CSC audit, we have made many positive contract
management changes.
1. we have centralized administration for our CSC contract in
one DOPO, who monitors contractor performance and approves
contract payments.
2. We have located several key contract staff in separate,
distinct work areas. Five CSC contract employees (two operators
and and three program management staff) are in the computer room;
ten CSC data support staff, only, in our Technical Support Room;
and six CSC contract staffers involved in Superfund cost recovery
-------
•-J rr-.un r USHISOC. 6 w-UJUlViiNu TO 82600335 P.03
documentation are in separate vork areas in our comptroller's
office. Thirty-three BSAT contract employees who reviev
laboratory test results are in vork areas separate from the
laboratory. We are reviewing all other on-site contract
positions to determine if employees should be moved to separatre
areas or facilities.
3. All contractor staff desks and vork areas are distinctly
identified with the contractor name on the name plates.
4. Current contractor identification badges are slightly
different from EPA badges. However, significantly distinct
contractor badges are being ordered. They will be a different
color and will not have the EPA logo on them. Delivery should be
within 4-6 weeks.
5. Region 5 telephone listings separate contractor staff. A
separate contractor listing is included in the back of the
directory. The organisational listings also separate and
identify contractor personnel.
6. Ho contract employees are issued supplies from the DA supply
room. All requests must be made through the ADOPO or project
officer and must have the written approval of the ADOFO'e/project
officer's supervisor.
7. We conducted an A-7« review when the CSC contract was awarded
in order to determine if contract support was cost effective.
The decision to contract these services was supported.
S. We have performed a cursory reviev of the statements of work
for our regional CSC delivery orders* The statements of work do
not reflect any inherently governmental functions or prohibited
contracting activities. We will analyse the work actually
assigned and performed to verify the work in practice is not
inherently governmental and does not include prohibited
activities.
9. All CSC training requests are and have been reviewed and
approved/denied by the regional DOPO. The approvals and/or
denials are documented. Very minimal training has been approved
to date.
10. Contract training for ADOPOs monitoring the esc contract has
been scheduled for April.
11. We have provided management controls training, emphasising
contract management controls, for all senior staff, branch and
section chiefs in PY 1992.
-------
82602835 P.04
12. Guidance has been provided to all Region S TQM facilitators
concerning appropriate roles for contract staff in the TQN
process.
We will verify that these and other improvements, detailed in our
•Proposed Action Flan to Address Potential Problems in Region 5
Contract Management Program" (Attachment 2), strengthen our
contract management program*
Attachments
V. Adamkus
-------
-------
rjHHiN>_t £ HiwUJUHl 1N5 TO 82600835 P. 05
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604-3590
MAR
SUBJECT: Contract Management Reviews
t-5
FROM: Robert Springer /Assistant Regional Administrator
for Planning and Management
TO: John Chamber 1 in. Director, office of Administration,
Office of Administration and Resources Management
Attached is Region 5's draft plan for our contracts) management
review, we vill begin the review by analysing CSC activities and
Region S's management of those activities. We plan to expand the
review to include Labat Anderson, Inc. and Booz-Allen and other on-
site contractors as soon as appropriate, given the preliminary
results from our CSC review.
we are currently developing detailed review guides for each review
area identified in the draft plan. The review will begin this week
and our optimistic projected completion date is May t. We will
treat the review as an Internal Control Review with documented
review objectives, guides, workpapers and results; recommendations,
as appropriate, will be presented to the Deputy Regional
Administrator .
We will provide specific recommendations for each contract with the
goal of consistent contract management for all on-mite contracts to
the extent possible, given the nature of each contract. In the
interim, we are talcing steps to assure that contract staff are
separate and distinctly identified including clearly distinct name
tags, separate working space to the extent practical and
appropriate, and guidelines to all AOOPOs, supervisor*, managers
and executives on proper involvement and exclusion from EPA
activities and events.
Attachment
cc: Michael Bower, Director, Contracts Management Division
Office of Administration and Resources Management
Research Triangle Park
John A. Edwardson, Deputy Director
for Administration and Resources Management
Research Triangle Park
-------
-------
(-fun nmNCE & HC»-GUiN I iNlj TO 62630835 P. 06
DRAFT
CSC Contract Review Program
Review Strategy:
1. Determine review steps performed by Region S
2. Review work steps perforated by Region 5
3. Review (cursory) all areas where Region 5 action seems to be
adequate
4. Review (in-depth) all areas where Region S actions seems to be
inadequate
Review:
A. CSC Services - Personnel Specialist
a. Determine services required by SOW
b. Determine actual services
* 1. Determine csc positions in Region 9
* 2. Determine services provided by those positions
3. Review services against Personal Services contract
guidelines (Attachment A)
4. Review Labor categories to work performed to determine if
properly classified
s. Review services against EPA guidelines for inherently
Governmental functions (attachment &}
6. Review services for COX activities
ex: CSC manage themselves, process own invoices, use CSC
records to verify invoice charges
7. Quality of personnel against contract requirements
* Get CO Permission
(Ask Managers what is done, ask CSC staff what is done, verify)
B. Invoice/Payment Review Process - Accountant/Financial Analyst
l. verification and approval of invoice payment
Technical Review
Improper fund obligations and contract payments
(expired appropriations were obligated and improper
charges were paid, charges before D.O. signed)
Approving officials
second review performed
technical approval received
2. Labor Cost Review
Analyze labor hours against work performed
ex: review progress reports to hours charged
Analyse labor categories against work performed
ex: review progress reports to labor categories
Independent verification to TftA
Control for staff charging to more than l D.O.
3. other Costs
Equipment cost* Justified?
Equipment used for other projects (should not be
charged direct, in 0/H)
If leased, how much did we pay (more than purchase
price?)
-------
F'ROl-i FiNHNCE & ACCOUNT!NG TO 82600835 P.07
DRAFT
Check out fax use and mail room use
4. Overhead Costs - nothing charged direct under current
contract.
Project Management Costs - charged direct and indirect?
(all direct improper,automatically charged indirect;
unallowable Training (unnecessary for SOW, contractor
should provide, paying for developed staff)
Unallowable Travel - not directly related to D.O.
Idle tine - Indirect
«
C. Training for DOPOs/ADOPOs - Contract Specialist
Rave copies of contract?
Have copies of SOW*?
Have copies of O.O.s?
Received contract training?
Guidance by P.O./C.O.7
(Contracts training in April - these should have first chance)
0. EPA Contract Management/Oversight Practices - Internal Controls
Staff/Contracts Specialist
Review oversight by OOPO/AOOPO
Personnel qualifications reviewed when approved Contract
Project Plan
Waivers of TOSS contract educations/experience requirements
granted?
Were labor category upgrades justified?
statements of Work
Compared to Delivery order*
Reviewed
for inherently governmental or personal services
and COX activities
Who prepared - CSC assist?
Adequate description of work?
Schedule of performance?
Quality assurance checks?
Include personal services statements, such as "other
duties to be assigned by EPA"?
Did DOPO/ADOPO Ensure?
All Work performed after D.O. issued?
Pay for Labor categories not in O.O.?
Check rates against contract?
Quality Assurance Reviews Performed?
work load Analysis performed?
verbal Authorizations? Amendments shortly after?
written contractor notification for variances?
Do not allow funds to carry-over from year to year - Anti-
Deficiency Act
-------
94/01/1992 11:36 FRCn FINANCE 8. ACCOUNTING TO 82608833 P.03
rDRAFT
Who provided work product C guidance?
E. FMFIA - Internal Controls/ Contracts Specialist
identify weaknesses?
identify control objectives and techniques ?
those identified were implemented?
AICR - quality assurance reviews performed?
* contract administration in EPA performance standards
* contract management duties clearly assigned - position
descriptions
F. Lack of accountability for Government Property furnished to CSC
Property Specialist
lists of property •
accountability for equipment
G. Cost Benefit Analysis (A-76) performed in Region 5?
H. System Security - limited CSC access
I. Administrative - Property Specialist
Where are work areas?
separate & distinct from EPA?
Access to EPAt
distinct name tags?
Keys?
key cards?
Hours worked? (i.e. normal business, other)
Voice mail?
equipment - contract
training with EPA staff?
Physical security for facilities?
* Critical to success
-------
04.'01X1952 11:36 FROM FINflNCE 1 ACCOUNT INQ TO 326008359.09
PROPOSED ACTION PLAN TO ADDRESS POTENTIAL PROBLEMS IN REGION 5
CONTRACT MANAGEMENT PROGRAM
are currently conducting a review of contract management
practices in Region 5. We plan to uee this review to develop these
and other steps to improve our management in order to make our
Region s contracting program a model for EPA.
Training will be required for senior staff, branch chiefs and other
EPA staff with contract responsibilities, and all personnel. The
senior staff and branch chief training will prepare managers to
perform a self assessment of contract vulnerabilities.
1. Contracting officers will brief Region 5 Senior Staff on sound
contract management principles during the last week in April. The
briefing should provide a sound basis for assessing our contract
activities.
2. Contracting Officers will provide training to all Region 5
Branch Chiefs and staff with contracting responsibilities on good
contract management practices, including how to assign, monitor,
and evaluate contract work. Training will include:
o What constitutes appropriate work for contractors
o Writing statements of work for Delivery orders
o Monitoring and evaluating contractor performance
o Approving contract payments.
3. Contracting Officers will train all Region 5 personnel on
appropriate work for contractor personnel.
Based upon contracts management training, each Region s branch
chief will assess the branch1* vulnerability in contracting
practices. The assessments should be completed by the end of the
third quarter. Planning and Management Division will provide
self-assessment forms, and guidance, if requested. These self-
assessments will be reviewed by the appropriate Division Director
and the Region 5 Senior Procurement Manager. The contracts
management review team vill concurrently conduct its independent
review. The results of the self review and the team review will be
compared and assimilated for a complete analysis of our
vulnerability with recommended actions.
1. Planning and Management Division will continue to analyse all
Statements of work for all existing Delivery orders to determine if
they are adequate, we will assess ways to write statements of work
-------
so that they are specific in terns of deliverable* and provide
ways to measure and evaluate performance* We will amend all sows
that are not adequate.
2. Ac an interim aeasure, for one year, all Statements of Work for
all Delivery Orders written in Region 5 must receive review for
adequacy and approval fro* the Region 5 Senior Procurement Manager
through the Contracts and Grants Branch.
3. The review tea* will verify that the actual contract work
performed is within the scope of work in the delivery order and is
not personal services type work or a prohibited contract activity.
e of BPA ffStme and operations
No examples of activities have COM to our attention where contract
employees have sole knowledge of EPA systems or operations. We
vill analyse sensitive operations and systems and take any action
necessary to ensure EPA cognizance of all operations.
All payment requests will receive two reviews and approving
signatures. The first review is a technical review from the EPA
contract Manager who has cognisance of the work performed. The
technical approval will include a statement frov the technical
official that the costs incurred appear reasonable and accurate and
sufficient progress has been Bade by the contractor to support
payment for the period* or that certain costs should be withheld
because they cannot be verified. A checklist for this review vill
be completed and distributed to contract Managers.
A second, administrative review vill be performed by the DOPO or PO
to determine that correct contract rates are applied, labor
categories are correct, no direct charges are made for indirect
labor, and other administrative contract requirements
Roles tor assigning and monitoring contractor work vill be clearly
defined. Contract monitoring duties vill be included in all
appropriate performance standards and agreements.
All contract management staff will work closely with the
Contracting Officer and Region 5 Contracts staff to assure
contractors are performing adequately.
l. Region 5 is ordering new badges for contract personnel that are
more distinctive than current contractor badges. The color is
different from EPA badges and the EPA logo will be removed. We
will be advised this week of the delivery schedule, but toe badges
are anticipated in four to six weeks. All contract personnel vill
-------
be required to wear the identification badge, we will conduct spot
checks to assure badges are worn.
2. Region 5 has already separated a significant number of contract
personnel. As the need arises for Region 5 employees to wove,
contract employees will be physically separated from EPA employees.
Administrative Services will send Mas built" plans to each division
and each Division Director will determine whether the contract
employees need to be separated and the extent to which they should
be separated. The plans will be reviewed by the Senior Procurement
Manager to determine who should be moved and when.
Facilities
1. Region 5 contracts will be reviewed to determine if contractors
should receive equipment and supplies and, if so, what typo. We
will limit equipment and supplies according to the results of
review.
2. The Administrative Services Branch has requested Headquarters
guidance concerning contractor use of the EPA mail room. We will
control those services accordingly*
3. Access to SPA buildings and space will be determined by each
Project Officer. The Project Officer, with supervisory approval,
will advise Administrative Services how the access cards vill be
Keyed for each contract employee and the cards vill be keyed
accordingly. The key readers should be delivered next week.
4. use of the PAX machine will be limited to EPA business only.
No contract internal business will be conducted via the FAX
machine.
1. contractors vill continue to be excluded from Region S functions
and events, except in clearly defined roles on a "need* basis. The
contracts management review team vill analyze and recommend whether
contractor employees should be excluded from all EPA-related
activities, such as recreation' association functions.
2. Contractor participation in training courses vill continue to be
limited to training required to accomplish the assigned task and
vill be clearly defined, contractor participation in TQM projects
will continue to be limited to information giving only.
3. The contract management review team will analyse voice mail to
determine if it should be available to contract staff.
TOTOL P. 11
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09/06--194+ 26 = 66 FROM R SPRINGER
TO
32600835 P.01
UNITED tfJ!A!L'£8
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-------
-------
09/06X196K 22=72 FROM R SPRINGER TO 82600835 P.03
'}
z?
UNITED 9TATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
MAR 3 I 1992
MEMORANDUM
SUBJECT: Follow-up to the Adainiatrator'6 March 10, 1993, Request
for a Review of EPA^-'tqp^fa^ets Management
FROM: Christian R. Hoi
Acting Assistant
TO: Assistant Administrators
General Counsel
inspector General
Regional Administrators
Associate Administrators
The purpose of this memorandum is to follow up on the
Administrator's recent request that you provide by March 26, 1992,
an assessment of all present or potential problems falling within
your purview related to contract and program management. The
Administrator attached a copy of ay February 2t, 1992 r aemorandum
that outlined immediate and decisive actions taken to correct real
and potential abuses/ and restore public credibility. Several
offices (a.a., Regions 6, 10, OCEPA) responded with specific steps
undertaken in support of improved contracta management. However,
the response to date to the Administrator's memorandum ia leas than
I have received froa the Administrator's office aix reports to
(i.e., Regions 1, 2, 3, 10, and the Offices of Water, Research
and Oevelopaent, and Gelid Kasta and Emergency Response) and I very
much appreciate these prompt and generally thorough replies. The
absence of a response from other offices and variations in the
level of information provided indicate the need to clarify the
scope of the Administrator's request. Briefly, the information
from all offices should include:
- — vulnerabilities that were identified in any program,
management or other audit (e.g., by 010 or GAO) during the
laet five years;
-------
i-Kun k SPRINGER TO 82600835 P.04
- a -
— vulnerabilities that were identified in any internal
control review pursuant to FMTIA requirements during the
laet five years;
— corrective actions initiated or completed to address such
vulnerabilities;
— implementation echedulee for any corrective actions net
yet completed;
— the number of contracts managed by s»ch office, broken
down according to type of contract, dollar value and
purpose; and,
~ the number of procurement personnel fe.o.. Contracting
Officers), program etaff (&*£*.r Project Officers, DOPOs,
Work Assignment Manager*), and legal staff assigned to
contracts management.
I strongly encourage you to provide as much of this
information as possible before our nesting with the Administrator
this Thursday, April 2nd, The balance of this information should
be submitted no later than Thursday, April 16th. The information
should be seat via rax to my of floe (FTi llo-osaff).
Your prompt support in this effort would be greatly
appreciated.
cc: Hank Habicht
Senior Procurement Officers
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22 = 62 FROM R SPRINGER
TO
82600835 P.05
CATS VULNERABILITIES
Region 5 has reviewed and identified many potential contracts
management weaknesses and reported the weakness and corrective
action in the CATS report. Examples from 1992 include:
VULNERABILITY
SF Contractor Conflict
of Interest (1)
SF contract costs(3)
reasonable
CORRECTIVE ACTION
study and eliminate
prohibited activities
prepare independent gov.
estimates
SCHEDULED
COMPLETION
Completed
Completed
Delays in SF Cleanups(2) guidance written and
implemented on invoking
penalties when deliverable^
are late
SF Review of contract
deliverable* (2)
Documentation of time
extensions (2)
Possible personal
services in GLNPO
Contracts (3)
implement automated compliance tracking
system Completed
see guidance on penalties and
tracking system above Completed
April 1992
1. 90-day study
2. OIG audit
3. Internal review
-------
CONTRACTS DATA
Contractor Contract Type Dollar Valut
Labat Anderson ID/IQ 120,276
ASCI LOE 80,000
ASCI LOE 2,591,000
SAIC 667,000
Seaward Services 1,133,609
AMS 32,000
Booz, Allen 10,000
ICF 80,000
CSC LOE 2,004,624
CH2M Hill
B&V waste
WW Eng & sci
PRC Corp
E&E
Roy F. Weston
SEC Donohue
IT Env. Prog.
Response
Geosafe
CERT
Purpose
Support to
regional and GLNPO
libraries
Records Mgt
Records Mgt
Lab analytical support
research/produce
reports
develop information
strategy plan
operation and
maintenance of
research vessels
ARCS program database
data storage &
retrieval
develop video
technical computer
support services to
region
CPAF 227,222,913
CPAF 220,160,212
CPAF 58,347,645
CPAF 211,963,386
CPAF 60,855,304
CPAF 222,184,330
CPAF 227,331,084
CPAF
FFP 1,700,688
SF technical services
for remedial response
SF
Emergency
Site Removal
Litigation Support
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liv 1B/192+ 07 = 36 FROM R SPRINGER
TO
82600835 P.07
*r
TES
PRC Environmental
Metcalf & Eddy
CLP-see attached list
A.T. Kearney
ESAT-LOCfcheed CPAF
JVS FP
Perkin-Elmer FP
Hewlett Packard FP
Supreme Equipment Require
Alliance Tech LOE
Entropy
Engineering Sciences
Radian
Midwest Research
Cambridge systemstics
Science Applications
Pacific Env. Sci.
Alliance-Technologies
5,000,000
1,403,517
23,000,000
5,000,000
1,000,000
2,200,000
449,292
39,060
55,265
450,694
504,425
10r900
24,000
232,536
64,764
137,992
118,886
64,316
79,069
technical enforcement
support at RCRA
facilities,
administrative records
SF enforcement support
conduct inspections,
design corrective
actions
provide analytical
services on sampling
data
RCRA permit & prog
support
analytical
Laboratory
support- data,
scheduling, sampling
Administrative
Support Services
Lab equipment
maintenance
Lab equipment
maintenance
Lateral files
studies, training
inspections
data base
data base
emission work
FIP estimates
transportation
measures
study - RACT
regulation devel.
ozone inventory
This is a compilation of all projected contract activity in Region
5, where Region 5 awards the contract or administer* an existing
EPA contract.
-------
'0 S2600835 P.08
PROCUREMENT PERSONNEL
Supervisory Contract Specialist 1
Contracting Officers 3
Contracting Specialists 8
Project Officers 41
Work Assignment Managers 191
Legal Staff Assigned to Contracts Hgt 0
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nc SPRINGER
TO
82600835 P.09
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604-3590
t $ MM*
«PLY TO TK AnCNTCNCF
KEMORXMDPM
SUBJECT: Contract Management Review
FROM: Valdas v. Adamkufi
Regional Administrator
TO: William K. Reilly
Administrator
AS requested in your March 10 memorandum, I an reporting our
assessment and proposed action plan for all potential problems
relating to contract management. Region 5 has already
implemented many contract improvements and we plan to further
strengthen our contract practices.
Our short-term
Region 5 future
for performing that work—coi
required, we will assess the
is to review and
Our
a:
i' iLPAcfc tar
number and types.
to assess-
best means
If contracts are
;> S initiated a contract management review in ea^lv n>^h.
focusing on the CSC contract. We plan to expend the review
;lude Labat Anderson, Boo* Allen and ether en-site
fSstn S initi*
to include
contractors, we plan to complete our review by the first week in
May, given CSC cooperation. Ne have submitted an outline of our
review plan to OARM (Attachment 1).
As a result of our awareness of good contracting practices and
the results of the CSC audit, we have made many positive contr
management changes*
i .
on
Ne have
central jify
o monitors
. who
contract payments
. tor our CSC contract in
contractor performance ana approves
2. we have located several key contract^ staf| in s
distinct work areas. Five CSC contract employees (two operators
and and three program management staff) are in the computer room;
ten esc data support staff, only, i'n our Technical Support Room;
and six esc contract staffers involved in Superfund cost recovery
-------
09/-04'194+ 34 = 76 FROM R SPRINGER T0
82600835 P.10
documentation are in separate work areas in our Csspt roller's
office* Thirty-three ESAT contract employees who review
laboratory test results are in work areas separate from the
laboratory. He are reviewing all other on-slte contract
positions to determine^ it employees should be moved to separatre
areas or facilities. "" """ ~"~ "~ ~~ — — —
3. All contractor; staff desks and work areas are distinctly
identified with the contractor name on the name plates.
4. Current contractor identification badges are slightly
different from EPA badges. However, significantly distinct
contrgctpy i»*«roye
-------
atjiii.10 FPOn R SPRINGER
TO
82600835 P.11
13. Guidance has been provided to all Region 5 TQM facilitator*.
concerning appropriate roles for contract^ etaff in tne
process.
We will verify that these and other Improvements,, detailed in our
•Proposed Action Plan to Address Potential Problems in Region 5
Contract Management Program"
contract management program.
(Attachment 2), strengthen our
Attachments
das V. Adamktts
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09/26.'196+ 26 = 66 FROM R SPRINGER
TO
82600835 P.12
/*1"'J*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION S
77 WEST JACKSON BOULEVARD
CHICAGO. IL «06Q4-3590
MA
MEMORANDUM
SUBJECT:
FROM:
TO:
Contract Manage
Reviews
Robert Springer /Assistant Regional Administrator
for Planning and Management
John Chamberlin, Director, Office of Administration,
Office of Administration and Resources Management
Attached is Region 3's draft plan for our contracts management
review, we vill begin the review by analyzing CSC activities and
ReglonVs management of those activities. We plan to expand the
review to include Labat Anderson, Inc. and Booz-Allen and other on*
site contractors as soon as appropriate, given the preliminary
results fros our CSC review.
We are currently developing detailed review guides for each review
area identified in the draft plan. The review will begin this week
and our optimistic prelected n^mi^ia* *•».• im w ^ we vill
treat the review as an Internal Control Review with "documented
review objectives, guides, workpapers and results; recommendations,
as appropriate, will be presented to the Deputy Regional
Administrator.
We will provide specific recoa^endations for each contract with the
'of consistent contract managementfor all on-site contracts to
the extent possible, given the nature of each contract. In the
interim, we are taking steps to assure that contract staff are
separate and distinctly identified including clearly distinct name
tags, separate working space to the extent practical and
appropriate, and guidelines to all AOOPOs, supervisors, managers
and executives on proper involvement and exclusion from EPA
activities and events.
Attachment
Get Michael Bower, Director, contracts Management Division
Office of Administration and Resources Management
Research Triangle Park
John A. Edwardson, Deputy Director
for Administration and Resources Management
Research Triangle Park
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09/00/199+ 09=15 FROM R SPRINGER
TO
82600835 P.13
CSC Contract Review Program
Review Strategy:
l. Determine review steps performed by Region 5
2. Review work steps performed by Region 5
3. Review (cursory) all areas where Region 5 action seens to be
adequate
4. Review (in-depth) all areas where Region 5 actions seems to be
inadequate
Review:
A.
a.
b.
*
Services - Personnel Specialist
Determine services required by SOW
Determine actual services
1. Determine CSC positions in Region 5
* 2 . Determine services provided by those positions
3 . Review services against Personal Services contract
guidelines (Attachment A)
4. Review Labor categories to work performed to determine if
properly classified
5. Review services against EPA guidelines for inherently
Governmental functions (attachment B)
6. Review services for COX activities
ex: esc manage themselves, process own invoices, use esc
records to verify invoice charges
7. Quality of personnel against contract requirements
* Get CO Permission
(Ask managers what is done, ask CSC staff what is done, verify)
B. Invoice Pament »eviaw
- Accountant/Financial Analyst
1. Verification and approval of invoice payment
Technical Review
Improper fund obligations and contract payments
(expired appropriations were obligated and improper
charges were paid, charges before D.o. signed}
Approving official*
second review performed
technical approval received
2. Labor Cost Review
Analyze labor hours against work performed
ex: review progress reports to hours charged
Analyze labor categories against work performed
ex: review progress reports to labor categories
Independent verification to T6A
Control for staff charging to more than 1 D.O.
3. other Costs
Equipment costs justified?
Equipment used for other projects (should not be
charged direct, la O/H)
If leased, how much did we pay (more than purchase
price?)
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09.'31-'199+ 09=19 FROM R SPRINGER TO 82660835 P. 14
Check out fax us* and vail roon use
4. Overhead Costs - nothin? charged direct under current
contract.
Project Management Costs - charged direct and indirect?
(all direct improper,automatically charged indirect)
Unallowable Training (unnecessary for SOW, contractor
should provide, paying for developed staff)
Unallowable Travel - not directly related to D.O.
idle time - indirect
•
C. Training, for POPOs/APOPOs - Contract Specialist
Have copies of contract?
Have copies of sows?
Have copies of D.O.S?
Received contract training?
Guidance by P.O./C.O.?
(Contracts training in April ~ these should have first chance)
D. EPA Contract MagaaeTMnt-/oversight Practice^ - internal Controls
Staff/Contracts Specialist
Review oversight by DOPO/AOOPO
Personnel qualifications reviewed when approved Contract
Project Plan
waivers of TOSS contract educations/experience requirements
granted?
Were labor category upgrades justified?
statements of work
Compared to Delivery orders
Reviewed for inherently governmental or personal services
and COX activities
who prepared * CSC assist?
Adequate description of work?
Schedule of performance?
Quality assurance checks?
Include personal services statements, such as "other
duties to be assigned by EPA"?
Did DOPO/ADOPO Ensure?
All Work performed after D.O. issued?
Pay for Labor categories not in D.O.?
Check rates against contract?
Quality Assurance Reviews Performed?
Work load Analysis performed?
Verbal Authorizations? Amendment* shortly after?
written contractor notification for variances?
Do not allow funds to carry-caver from year to year - Anti-
Deficiency Act
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22 = 22 FROM R SPRINGER
10 82600835 P. 15
Who provides work product « guidance?
E. FMFIA, - Internal Controls/ Contracts Specialist
~~~ identify weaknesses?
identify control objectives and techniques ?
those identified were implemented?
AICR - quality assurance reviews performed?
* contract administration in EPA performance standards
* contract management duties clearly assigned - position
descriptions
F. Lack of accountability for Covernaent Property furnished to CSC
Pr operry specialist
lists of property -
accountability for equipment
G. Cost Benefit Analysis (A~76) performed in Region 5?
H. System Seeur^y,,,- limited CSC access
I. Administrative - Property Specialist
Where are work areas?
aeparifce fc ai«€inct from EPA?
Access ^.o EPA:
name tags?
keys?
key cards?
Hours worked? (i.e. normal business/ other)
equipment - contract
training1 vith SPA staff?
Physical security for facilities?
critical to success
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09x02,-!get 00 = 22 FROM R SPRINGER
10 82600835 P.16
PROPOSED ACTTQy PLAN TO ADDRESS POTENTIAL PROBLEMS 1[H BECTf|p
CONTRACT P*M*«****'*rr PPQgfc"
We are yur^gntiy eand*»efcing * r»vi»w Of contract management
practices in Region s^ We plan to use this review to develop these
and other steps to iaprove our management in order to make our
Region 5 contracting program a model for EPA.
Training vill be required for senior staff, bryneh ghle/g,»n4 other
-LUJj
EPA staff with <*7p*raet: rrflpfms « h * * 1 * * •* i and all personnel. The
"staff and branch chief training vill prepare Managers to
perform a self assessment of contract vulnerabilities.
1. contracting Officers will brief Region 5 Senior __gtaf.ft on sound
contract aanAa«a*nt principles during the last week in April. The
briefing should provide a sound basis for assessing our contract
activities.
2. Contracting Officers will provide training to all Region S
Branch Chiefs and staff wi^h contrj.r*^ y«gp^».
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13'01/I50+ 00:04 FROM R SPRINGER TO 82600835 P. 17
so that they are specific in teraa^ of deliverable* and provide
ways to measure and: evaluate performance. We win aggnd all sows
thai: are not adequate.
2. As an interim measure, for one year, all Statements of WorX for
all DeliVferv Ordettfc Written in Region 3 must receive revlWfor
adequacy and approval froa the Region S Senior Procurement Manager
through the Contracts1 and Grants Branch.
3. The review team will verify, that the actuaj. contract vork,
perforned_is within the scope of work in the delivery order and is
not personal service^ type work or a prohibited contract activity.
Knowledge of 8PA systems and Operations
No exaaplefft of activities have come to our attention where contract
employees have sole knowledge of gpA gv****^ or operations. We
ilyze senslClVl Operations and system*"
necessary to ensure EPA cocmitance of all operations.
WT11 analyze senslClVt Operations and systems" and take any action
necessary to ens
Payment .Approval
All payment requests, will receive two reviews and approving
signature*, me first review is a te6Enl.cai revfe^ fro*, the EPA
contract Manager who has cognisance or tha> work performed. The
technical approval will include a statement from the) technical
official that the costs incurred appear reasonable and accurate) and
sufficient progress .has been made by tne> contractor to support
payment for the period, or that certain costs should be withheld
becauoe they cannot be verified. A checklist for this review will
be completed and distributed to contract manager*.
A second, administrative review will be performed by the DOPO or PO
to determine that correct contract rates are applied, labor
categories are correct, no direct charges are made for indirect
labor, and other administrative contract require»ent* are sjat.
Role* for assigning'and monitoring contractor work will be clearly
defined. Contract monitoring duties, will be included in all
appropriate performance standards and agreements. -
All contract management staff will vork closely with the
contracting officer and Region 5 Contract* staff to assure
contractor* are performing adequately.
1. Region 5 ie ordering nev badges for contract personnel that are
more. distinctive than current contractor badges. TBa" color is
different from EPA badges and the EPA logo will be removed. We
will KM advised this week of the delivery schedule, but the badges
ar* anticipated in four to six weeks. All contract personnel will
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00:00 FROM R SPRINGER TO 62600835 P. 18
be required to wear the identification badge^ We will conduct spot
checxs to assure Ridges are worn. J
2. Region 5 has already separated a significant number of contract
personnel. As the need arises ~for Region 5 espioyees to iaove7~
contract employees will be physically separated from EP* employees.
Administrative Services will send "as built" plans to each division
and each Division Director will determine whether the contract
employees need to be separated and the extent to which they should
be separated. The plans will be reviewed by the Senior Procurement
Manager to determine who should be moved and when.
Facilities
X. Region 5 contyjac£f vill be reviewed^ to determine if contractors
should receive equipment and supplies;"'and, if so, what type. We
will lia.it equipment and supplies according to the results of
review.
2. The Administrative Services Branch has requested Headquarters
guidance concerning contractor use of the EPA nail room. We will
control those services accordingly.
3. Access to EPA buildinog and space vill be determined by each
Project Officer. The Project Officer/ with supervisory "approval,
will advise Administrative Services how the access cards vill be
keyed for each contract employee and the cards vill be keyed
accordingly. The key readers should be delivered next week.
4. Use of the wr »»eMi>» vill be Umi£e£ to EPA business only.
No contract internal business will be conducted via the Hot
machine.
1. Contractors vill continue to be excluded from Region S functions
»nd «»v*nf? except in clearly defined roles on a "need" basis. The
contracts management review team will analyze and recommend whether
contractor employees should be excluded from all EPA-related
activities , such as recreation association functions*
2. Contractor participation in training courses will continue to be
Usifeed to training required to accomplish the assigned task and
vill be clearly defined. Contractor participation in TQM projects
vill continue to be limited to information giving only.
3. The contract management review team will analyze voice mail to
determine if it should be available_to contract staff. '
TOTAL P.18
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•S.
"^ -^ 3 <^ ^5
UNITED STATES EKVIRONMENTAL PROTECTION ACENCY
Region 5
77 West Jackson Boulevard
Chicago. Illinois 60604>3590
FINANCIAL MANAGEMENT BRANCH
Finance and Accounting Section
Facsimile Request and Cover Sheet
Date of Tranaactlon 41 if \ 1_L-
Nuaber of Pages Including This Fage
flt csflMK o 0mv BKJBBHB 0 tm§ • n M • • sftnvvi • M » • Mtv ^ni
From: JOB OTtOIMfMU Atuuuiil
JS»*3-;i0«fc>
Fhone Ho. (FTS>OOi ?S86 FAX Vo. (FTS>886-7514
(312)886>731«
To:
Fhone So. FAX Ho. AC
MESSAGE:
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
HEK.Y TOTME ATTWWN OF.
R-19J
Follow-up to tfce Administrator's Request for a Review of
EFA's Contract* Management
FROM: ValOas V. AdaaJras
Regional Administrator
TO: Christian R. Koines
Acting Assistant Administrator
for Administration and Resource Management, PM-20S
We cent a copy of our Proposed Action Plan to Address Potential
Problems in the Region 5 Contract Management Program and our
Contract Management Reviev Plan to you on April 1, as you requested
in your March 31 Memorandum. We also submitted both plane to the
Administrator on March 25, 1992. In addition, we sent you (1) an
incomplete assessment of vulnerabilities and corrective actions
that were identified in any type audit related to contracts
management within the last 5 years, and (2) complete data relating
to contracts managed by Region 5 and procurement personnel in
Region 5. We are faxing the data to you again with this
submission. We are mailing the plans to you again in case they did
not reach you.
The purpose of this memo is to complete our reporting of
vulnerabilities and corrective actions identified concerning
contracts management. We have identified numerous vulnerabilities
within the last 5 years. Corrective actions have been completed
for most of these vulnerabilities. In cases where corrective
action is not complete, we have indicated our implementation
schedules. These vulnerabilities and corrective actions were
included in our corrective Action Tracking system reports and in
our Annual Reports on Management Controls. Copies of Region 5
reported vulnerabilities and corrective actions are attached.
Valdas V. AdamJcus
Attachments
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Attachment 1
1 of 2
CONTRACTS DATA
Cpntractor Contract Type Dollar Value
Labat Anderson ID/IQ 120,276
ASCI LOB 80,000
ASCI LOB 2,591,000
SAIC 667,000
Seaward Services 1,133,609
AMS 32,000
Booz, Allen 10,000
ICF 80,000
CSC LOE 2,004,624
CH2M Hill
B&V Waste
WW Eng & Sci
i
PRC Corp
£&£
Roy F. Woeton
SEC Donohue
IT Env. Prog.
Response
Geosafe
CERT
CPAF 227,222,913
CPAF 220,160,212
CPAF 58,347,645
CPAF 211,563,386
CPAF 60,855,304
CPAF 222,184,330
CPAF 227,331,084
CPAF
FFP 1,700,688
Purpose
Support to
regional and GLNFO
libraries
Records Mgt
Records Mgt
Lab analytical support
research/produce
reports
develop information
strategy plan
operation and
maintenance of
research vessels
ARCS program database
data storage &
retrieval
develop video
technical computer
support services
to region
SF technical services
for remedial response
SF Emergency
Site Removal
Litigation Support
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TES
PRO Environmental
Metcalf & Eddy
CLP-see attached list
A.T. Kearney
ESAT-Lockheed CPAF
JVS FP
Perkin-Elmer FP
Hewlett Packard FP
Supreme Equipment Require
Alliance Tech LOE
Entropy
Engineering Sciences
Radian
Midwest Research
Cambridge Systematic*
Science Applications
Pacific Env. Sci.
Alliance-Technologies
5,000,000
1,403,517
23,000,000
5,000,000
1,000,000
2,200,000
449,292
39,060
55,265
450,694
504,425
10,900
24,000
232,536
64,764
137,992
118,886
64,316
79,069
Attachment 1
2 of 2
technical enforcement
support at RCRA
facilities,
administrative records
3F enforcement support
conduct inspections,
design corrective
actions
provide analytical
services on sampling
data
RCRA permit & prog
support
analytical
Laboratory
support- data,
scheduling, sampling
Administrative
Support Serviced
Lab equ i pmen t
maintenance
Lab equipment
maintenance
Lateral files
studies, training
inspections
data base
data base
emission work
FJP estimates
transportation
measures
study - RACT
regulation devel.
ozone inventory
This is a compilation of all projected contract activity in Region
5, where Region 5 awards the contract or administers an existing
EPA contract.
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Attachment 2
ATTACHMENT E
AGENCY-LEVEL WEAKNESSES/CORRECTIVE ACTIONS
CATS Tracking Number i 91-6
Assessable Unlt/AU
507
Title of Agcncv-Level weakness and Description: Contracts management and
administration - The Superfund 90-Day Review mandated that EPA take a close
look at activities being performed by contractors, to assess potential
Conflict of interest. Simultaneously, the Region V OSP conducted an internal
review to determine if internal controls were in place to ensure that
contractor costs are necessary and reasonable. These were found to be
inadequate , and steps were taken to correct weaknesses.
Year Identified and Source of Discovery;
and the Superfund 90-Day Review
Critical Milestones in Corrective Action;
1990; OSF Internal Control Review
TIMBFRAMZS
Beginning Date Comletion
Actual
1. Assess the adequacy of internal 11/89
controls for contractor costs
2. Develop and implement new controls 12/89
3. Hire a cost-estimating engineer to 3/90
train RPKs and develop cost database
4. Initiate kick-off meetings for all 12/89
work assignments
5. Require the preparation of government 3/90
cost estimates (IGEs) for all new work
assignments
6. Conduct an in-house review of all 7/90
areas where contract work is pro-
hibited, and sensitive areas where
COI may have potential (per David
O'Connor's memo)
7. Take steps to correct weaknesses if 7/90
they exist
8. Verify the completeness and effect- 3/90
iveness of the corrective measures
Budget Implications. If Any!
* One FTE for costing engineer
Planned Actual Planned
11/89 12/89 12/89
12/89
3/90
12/89
3/90
7/90
7/90
3/90
9/90
7/90
9/90
7/90
9/90 9/90
Ongoing
7/90
9/90
9/90
7/90
9/90
9/90
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\
corrective Action Plan Status Updates;
* Activities from Jftfluarv l. 1991 to March 31. 1991
our cost-estimating engineer has been working with Work Assignment Managers
(WAMs) on a one-on-one basis to develop IGEs with then and as a training for
them, in addition, he is continuing to develop a cost database which can be
used in developing future iGEs. Additional training will be planned and
conducted as needed.
GAO conducted its exit interview for a waste, fraud and abuse audit of the
ARCS contracts which primarily reviewed increases in costs to several ongoing
RI/FS projects. Although their national draft audit report has not been
received, they expressed cone concerns in their exit briefing. One iten was
related to RPM review of monthly ARCS contractor progress reports.. They
indicated that their interviews of RPMs revealed that the RPMs would like to
see more detail in monthly reports to make them feel comfortable in reviewing
charges for reasonableness. Prior to the GAO exit interview, the ARCS POs and
cos had already identified a couple items of additional information that they
would like to see in monthly reports and were interested in surveying RPMs for
additional items RPMs would like in the reports and following up by requesting
the contractors to provide the information.
* Activities from April 1. 1991 to June 30. 1991
Our cost-estimating engineer has been working with Work Assignment Managers
(WAMs) on a one-on-one basis to develop IGEs with them and as a training for
them. In addition, he is continuing to develop a cost database which can be
used in developing future IGEs. Additional training will be planned and
conducted as needed.
GAO conducted its exit interview for a waste, fraud and abuse audit of the
ARCS contracts which primarily reviewed increases in costs to several ongoing
RI/F3 projects. Although their national draft audit report has not been
received, they expressed some concerns in their exit briefing. One item was
related to RPM review of monthly ARCS contractor progress reports. They
indicated that their interviews of RPMs revealed that the RPMs would like to
see more detail in monthly reports to make them feel comfortable in reviewing
charges for reasonableness. Prior to the GAO exit interview, the ARCS POs and
cos had already identified a couple items of additional information that they
would like to see in monthly reports and were interested in surveying RPMs for
additional items RPMs would like in the reports and following up by requesting
the contractors to provide the information.
* Activities from JuJ.y ?.. 1991 to September 30. 1991
& draft IG£ internal control policy memo has been drafted and will be
circulated for comment by the Office of Superfund, Office of Public Affairs,
and ARCS Contracting officers and will then be finalized during the first
quarter of FY92. Another activity which was accomplished this quarter vas that
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a memo was sent to the RPMa and other work assignment managers on the ARCS
contracts surveying them on what additional items of documentation they would
li1 in monthly contractor progress reports to assist them in their reviews.
Th responses are being summarized and follow up meetings will be held with
the ARCS Contracting Officers during the first quarter of FY92 to determine
what additional information should be provided by each contractor and what
needs to be done contractually to effect this. During the fourth quarter, an
ARCS task force from Headquarters has been reviewing management of the ARCS
contracts and we have provided substantial information on our internal
controls to address their questions, in addition, the EPA Inspector General
has started a follow-on audit of the ARCS contracts and we are cooperating
with them to provide the information they want to review and to schedule
interviews with the POs and any others they wish to interview. Also, staff
from the Procurement and Contracts Management Division reviewed the invoice
files of the Project Officer for the CHZMHili contract as part of a PCKD
regional review of some specific ARCS contractors.
* Activities—from October 1. 1991 to December 30. 1991
A formal IGE policy was drafted and revised during the first quarter of FY91
and was not sent out for comment because it was determined that it would be
better to make sure it was consistent with the policies under development at
EPA Headquarters. The policy will be sent for comment internally in the
second quarter. However, even without a formal policy, ZGEs are being
developed for every new work assignment. An additional item being worked on
is determining how each ARCS contractors invoices and monthly progress reports
need to be changed to allow the contracts management team to conduct a
thorough review of contractor charges. The ARCS POs and COs will meet during
the second quarter to finalise this review and determine what the contractors
should be requested to change. GAO and 1C reports were received this quarter
and we are reviewing the reports to determine necessary follow-up actions.
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ATTACHMENT E
AGENCY-LEVEL WEAKNESSES/CORRECTIVE ACTIONS
' CATS Tracking Number: 92-1
Assessable Unit/AU /; 507
Title of Agency-Level Weakness and Description; As a result of an audit which
they conducted, the OIS determined that the Region needs to act to ensure that
it is not the cause for delay in Superfund cleanups. They concluded that the
Region did not always review deliverable* in a timely fashion. Also that
batter documentation of tine extensions which are granted are necessary to
ensure that schedules remain enforceable. the Superfund Program and the
Office of Regional Counsel have already issued a joint Procedures for
Monitoring Compliance memorandum in partial response to the findings of the
OIG, but several additional actions will occur in the next several months.
These are listed below as Critical Milestones.
Year Identified and Source of_ Discovery; 1991 - IOIG Audit of Region V
Superfund Post-Settlement Activities. Report dated March 29, 1991.
Critical Milestones in Corrective Action; TIMEPRAMES
Beginning Date completion Date
Planned Actual Planned Actual
1. Develop and issue final guidance 7/91 7/91 10/91 8/91
and instructions for granting and
documenting extensions.
2. Develop and issue final instruc- 7/91 7/91 10/91 10/91
tions requiring use of the latest
model enforcement documents where
appropriate,
3. Implement an automated compliance
tracking system. (COMPTRAC). The
implementation schedule is as follows:
* Prepare draft implementation plan 10/91 10/91 10/91 10/91
* orient staff and supervisors 10/91 11/91 11/91 11/91
* Prepare final implementation plan 11/91 11/91 12/91 12/91
Plan" for FY'9i
* Conduct staff training on data 1/92 1/92 3/92
loading (as EPA HQ develops a national
compliance tracking policy for the
Superfund program, Region 5 will
modify and enhance COMPTRAC as necessary).
4. Convene a workgroup to draft a 7/91 7/91 10/91
guidance memorandum on the invocation
and documentation of stipulated
penalties.
5. Revise the Memorandum of Agreement 11/91 11/91 11/91 12/91
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between the WMD and the ESD (review -
of this document and the inclusion « '•
of necessary improvements will be
done on a quarterly basis as a joint
effort of both divisions).
6. verify completeness/effectiveness 6/92 7/92
of the above measures.
Budget Implications. If Any;
Corrective Action Plan Status Updates:
* December 31. 1991 Status Updates;. Generally, all milestones are
completed, some ahead of schedule. The automated compliance tracking system
is well on its way to being operational, but has been slowed by computer
program problems at the national level. On stipulated penalties, the Region
is participating with HQ on a guestionaire and data gathering exercise. From
this will be developed more guidance on the effective use of stipulated
penalties.
* March 31. 1952. Status JUtodat.e_L
* June 30r 1992. Status Update.;.
* September 30.1992. Status Uodate:
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rinr-tr«'_t ,i n'_i_uUIN i 1 Csm TU 82680835 P. 16
NATIONAL PROGRAM-LEVEL WEAKNESSES/CORRECTIVE ACTIONS
CATS Tracking mmb«r! 92-16
Assessable Unit/AU »; Great Lakes 503
Title of Agency-level Weakness and Description; Improvements
needed in Contract* Managment - inprovetnents are needed to ensure
proper contracts management in the Great Lakes National Program
Office, particulary with the CSC contract. The statement of work
is written in such a way where "personal services" may result.
Year Identified and Source of Discovery;
FY91 - Source) Management
Critical Milestones in Corrective Action: Number each Milestone i
the plan and give dates for each milestone. Explain any changes in
milestone dates reported in previous years.
1 . November^SCL. 1991 - Review CSC contract statement of work
and revise to strengthen work objectives.
2. December 15. 1991 - Meet with Region V Contracting
Officer to discuss personal services issue and develop
solutions to improve contracts management.
3. February IS. 1992 - Provide appropriate training to Work
Assignment Managers if necessary/ including refresher
sessions, to avoid problems in contracts management.
4. April 30, 1992 - Verify completion and effectiveness of
steps taken in milestones 1 through 3.
Budget Implications. If Any;
Corrective Action Flan Status Updates;
31, 1991. Status Update? A meeting of GLNPO
managers and staff was held in November to discuss
improvements needed in the management of contracts. It
was decided that GLNPO needed to revise the statement of
work to eliminate language that could be construed as
personal services.
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H^i-Jur>:"i 1 N'J TO 6.26&tJ635 F. 11
MCV06B9!
5RA
SUBJECT: 1991 Report on Management Controls
FROM: Valdas V. Adamfcus
Regional Administrator
TO: F. Henry Habicht XI
Deputy Administrator
I have taken the necessary measures to assure that ve have
evaluated our management controls in accordance with guidance
provided by the Office of Administration and Resources Management
and Office of Management and Budget. Based on our evaluation
process and the following information, it is our opinion that the
system of management controls in effect in Region S during the
fiscal year ending September 30, 1991, provide reasonable assurance
of compliance with the objectives of management control in
accordance with OMB Circulars A-123 - "Internal Controls" and
A-130 - "Management of Federal Information Resources," and the
Federal Managers' Financial integrity Act.
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PIG. GAP and OMB CONCERNS;
Auditors in the Office of Inspector General (016) and the General
Accounting Office (GAO) and the Office of Management and Budget
(OMB) have highlighted the following weaknesses in Region 5
programs and operations, which deserve our attention.
1. Superfund
An audit of the Region 5 Superfund post-settlement activities
highlighted the need for additional procedures in the Offices of
Regional Counsel and Haste Management Division to ensure timely,
effective and consistent enforcement response to Superfund
responsible parties' noncompliance with administrative and judicial
consent orders/ decrees. Procedures were strengthened and a joint
memorandum was prepared by ORC and WMD and issued to all
responsible personnel, outlining the improved procedures for
monitoring and enforcing CERCLA administrative and judicial
orders /decrees. In addition, ORC issued a memorandum identifying
model CERCLA enforcement and settlement orders/decrees* We are
treating this as an Agency-level weakness and additional actions to
address the weakness are identified In CATS (Attachment E,
Assessable Units 502, 507, and 505).
2. ARCS Contracts
GAO performed a national review of the "Status of EPA's Actions to
Reduce Superfund 'e Vulnerability to Fraud, Waste and Abuse." GAO
concentrated on Region 5 cost estimating, invoice reviews and award
fee process. While we have not yet received their report, the exit
conference focused on increases in ARCS contract costs for RI/FS
projects. GAO suggested improvements were needed in our
independent government estimating procedures and in our review of
monthly ARCS contractor progress reports as a basis for approving
progress payments.
The review concentrated on early projects involving ARCS
contractors. These projects had begun prior to our performing
independent government estimates. Waste Management Division has
prepared independent government estimates and used them in
negotiating costs beginning in P5f 1990 and throughout FY 1991 for
all new ARCS and Technical Enforcement Support contract work
assignments.
As a first step in addressing the progress payment problem, WMD is
surveying project managers to determine additional documentation
needed to approve contractor progress payments. Responses will be
summarized and changes in progress reporting will be implemented
with the contractors.
The Administrator's recent Superfund Task Force also reviewed the
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implementation of ARCS strategy and included Region 5 in its
review. Recent reviews of ARCS contractors in Region 5 did not
disclose any instances of contractors charging for inappropriate
and unnecessary administrative items. He will continue to closely
monitor ARCS costs.
3. National Pollutant Discharge Elimination System (NPDES)
A GAO audit of the NPDES in the Great Lakes area found that the
program is faced with many of the same compliance and enforcement
problems found in prior reviews. The audit report hae not been
issued. However, GAO identified weaknesses during its exit
conference in the areas of permit limits and permit enforcement.
Because permit limits were often expressed in terms of pollutant
concentrations rather than total quantity or mass, dischargers
could meet permit limits by diluting pollutants in wastewater. In
response to the permitting weakness, Region 5 drafted a letter/
reminding the States of existing guidance requiring limits to be
expressed in terms of mass as well as concentrations. The draft
has been approved in Headquarters and Region 5 plans to release it
in November.
The enforcement program weaknesses identified in the exit briefing
and highlighted in GAO's leter testimony to its Congressional
committee are being concurrently reviewed in Region S and
Headquarters. Any weaknesses requiring Region 5 corrective actions
will be addressed and corrective action plans prepared upon
completion of the GAO report and Agency reviews.
4. Audit follow-up
Reviews by the OIG are continuing to find that Regional and
Headquarters offices' audit follow-up is weak and that reporting is
incomplete or inaccurate, in Region 5, a strong audit follow-up
program continues to result in timely resolution of internal and
external audits. Of the 93 audits available for closure in FY
1991, only two over 180 days old remained open at September 30.
As of September 30, a total of 16 audits remained open over 180
days. Two were from grants under litigation and final
determinations will be made upon resolution. A proposed final
determination was submitted to the OIG on one audit and is under
review. The other 13 audits, issued several years ago and
subsequently referred to the Agency Audit Resolution Board, are
also still unresolved.
5. Accounts Receivable
The OIG finding states that "many accounts receivable are still not
being recorded on EPA's financial records." Since the issuance of
this audit report, Region 5's Office of Regional Counsel, Waste
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NOV 0 9 1990
MEMORANDUM
SUBJECT: 1990 Report on Internal controls
FROM; Valdas V. Adamkns
Regional Administrator
TO; F. Henry Habicbt II
Deputy Administrator
I am submitting this annual report as required by EPA
Resources Management Directive, Section 2560, Internal Control.
This report complies with OMB circular A-123, Internal Control
Systems, and the Federal Managers' Financial Integrity Act. It
also meets the internal control requirements of OMB Circular A-
130, Management of Federal Information Resources.
ASSURANCE STATEMENT
I have taken the necessary measures to assure that we have
evaluated our internal controls in accordance with guidance
provided by the Office of Administration and Resources
Management. Based on our evaluation process and my personal
knowledge, it is my opinion that the internal controls in effect
on September 30, 1990, taken as a whole, provide reasonable
assurance that Region 5 complies with the requirements of FMFIA.
ACCOMPLISHMENTS IN INTERNAL CONTROL PROGRAMS
Managers throughout Region 5 have taken seriously their
responsibility to improve internal controls. Significant
accomplishments in internal control programs are included in the
section covering OIG, GAO ,and OMB Concerns. Additional
accomplishments are included in the section titled "Other
Accomplishaents."
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-------
fiscal year, similarly, we will test sample supporting
documentation for reported internal control reviews and
alternative internal control reviews.
Although OIG Audit Report No. E1MMF9-11-0039-100049,
"Improvements Needed in Overtime Controls" did not review Region
5 overtime controls, we performed an alternative internal control
review during FY 1989. As a result of our review, we identified
two Agency-level weaknesses which were reported last year.
Region 5 has implemented corrective actions on both during FY
1990. A follow-up review is scheduled for January, 1991 to verify
the effectiveness of those actions.
Contracts Management »n
The Planning and Management Division has improved the work
plan review process under the Alternative Remedial Contracting
Strategy (ARCS) contracts by making mandatory use of a •'Work Plan
Budget Review/ Contract Office Checklist.11 The Work Plan
Evaluation Checklist is completed jointly by the Work Assignment
Manager and Project Officer and provides assurance to the
Contracting Officer that the technical aspects of the work
assignment have been adequately addressed and that the proposed
labor mix and resource utilization are appropriate for the work
required. The Work Plan Budget Review/Contract Office Checklist
provides a vehicle to ensure consistent Contracting Officer
review of Direct Labor rates, Indirect Rates, Other Direct costs
and Fees and assists the Contracting officer in determining the
reasonableness of proposed costs prior to vork plan approval.
The Office of Superfund (OSF) has taken several steps to
prevent contractor conflict of interest (COI) and to ensure that
contractor costs are necessary and reasonable, in April 1990 the
Director of the Procurement and Contracts Management Division
sent a memorandum to Region 5 outlining specific areas where
contracting was prohibited and identified areas where ve were to
be cautious. The OSF did a complete review and where areas of
concern were identified, took steps to correct or prevent
problems.
significant accomplishments have been made in controlling
Superf und contractor costs during FY 1990 . The OSF did an
extensive review of its internal controls for Superfund
contractor costs. An action plan was developed for ensuring that
contractor costs were necessary and reasonable, which included
the development of several new internal controls. The OSF hired
a cost-estimating engineer in July to train project managers in
preparing estimates and is now performing government cost
estimates for all new work assignments. Several government
estimates were prepared by Project Officers which successfully
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TO
reduced some proposed contractor costs. Additional controls are
detailed in Attachment E.
A Total Quality Management (TQM) initiative was conducted
with all seven superfund ARCS contractors, to train then on the
principles of TQM. Sources of problems in the Alternative
Remedial Contracting System process were identified, and small
work groups are being formed to identify and recommend solutions.
Finally, an invoice tracking system has been developed and
implemented to assist Superfund Project Officers in standardizing
reviews and assist Project Managers in invoice reviews.
Region 5 actively pursued improving the integrity,
availability, and confidentiality of automated information
systems. The following are some of these activities.
The Information Management Branch (1MB), Planning and
Management Division (PHD), is responsible for assuring successful
operation, maintenance, and security of over 1100 personal
computers in Region S. Procedures have been followed, which are
designed to assure that tampering, theft, and accidental
destruction of hardware and software are minimized. The PHD
reviews the adequacy of controls in each Region S office,. This
includes personnel controls, software and data controls (e.g.,
back-up diskettes), equipment and physical controls, physical
inventories and administrative controls.
In FY90 1KB developed the Region 5 Inventory Tracking System
(R5ITS), a multi-user system, to track EPA Regional computer
equipment, supplies and purchases. The system enables us to more
effectively and economically manage computer resources.
During the past five years the number and types of personal
computers in Region 5 has more than tripled. In FY90 the Region
reported its first thefts of portable computers (two) from staff
workstations during non-working hours. The risk of such
occurrences could increase as we add to the number of new
personal and lap top computers. Therefore, Region 5 has
determined that this area is an Agency-level weakness requiring
our close attention during FY 1991. New security guidance was
issued by the National Data Processing Division (NDPDJ in FY90,
which provides a general framework for EPA organisations to
follow. We will thoroughly review our existing documentation,
procedures, and audits, and take action/ as necessary.
The OSF conducted an internal review/vulnerability
assessment of its computer security, as well as a Total Quality
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ATTACHMENT E
AGENCY-LEVEL WEAKNESSES/CORRECTIVE ACTIONS
CATS Tracking Number;
assessable Unit/AU *: 507
Title of Agency-Level Weakness and Description; High turnover of RPHs and
oscs - The Remedial Project Managers and On-$cene Coordinators are the
critical first contact and on-going point persons for the Superfund effort.
TO an unusual degree, this program is dependent on them and their high
degree of professionalism. Professionalism and the high quality of their
work has not changed, but the continuing high level of pressure can have a
negative impact on the morale and precipitate turnover. During FY'88-89,
between 20 and 25% of the Region 5 RPMs left the Agency for other jobs.
Lack of continuity between RPMs is a concern, and can result in project
delays as new RPMs are brought up to speed.
Year Identified and Source of Discovery; 1989; Superfund 90-Day Review
Critical Milestones in Corrective Actions
TIMBFRAMES
Beginning Date Completion Date
Planned Actual Planned Actual
1. Participate fully in the RPM/OSC 10/B9
support program being put together
by Headquarters
2. Provide RPMs with contracts management 2/90
raining and guidance
3. aek higher grade levels for RPMs/OSCs 10/89
through "master" positions
4. utilize human resource initiatives 10/89
to retain qualified staff and provide
for a more timely transition of new RPMs
5. Verify the effectiveness of the 10/89
corrective actions
10/89 9/90 9/90
2/90 2/90 2/90
10/89 9/90 9/90
10/89 9/90 9/90
10/89 9/90
9/90
Budget Implications, if Anv:
Corrective Action Plan Status Updates;
* September 30. 1990. Status Update:
Prior to FY'&O, the Region's turnover rate for RPMs and OSCs was quite
high...20-25%. The OSF implemented the above actions in FY'90, including
the use of RPM/OSC awards during the year, to build morale and retain staff.
A PD for GS-13e was approved and many RPMs and OSCs have been promoted. As
of the end of the FY, there were 85 RPMs on board, with a loss of 8 during
the year (10%). The OSF had 22 OSCs oil board in September, with a loss of 2
during the year (9%). Managers believe that the higher retention rates
reflect the success of the corrective actions that have been implemented.
-------
*s of 9/30/90, all of the above actions have been completed. Internal
Controls for ensuring contractor costs were evaluated, and several new
controls put in place. Three OSF policies on preparing Action-nemos, Budget
negotiations, and roles of WAMs/POs in certifying that contractor costs are
necessary and reasonable were published by the Director, OSF, and training
for work Assignment Managers (WAMs) was provided by CMIU. A decision was
made by OSF managers to do Government Cost Estimates (IGEs). A cost-
estimating engineer was hired by CMIU in July, and he has developed a
database to use in preparing the IGEs. Several IGEs were prepared by the
Project officers in quarter four, which successfully reduced the
contractor's proposed workplans/budgets. Kick-off Meetings for new work
assignments, were instituted across all contracts, and have significantly
improved communications, while reducing rework on workplans. Action nemos
are routinely being reviewed for certification of cost reasonableness.
finally, a TQM initiative was conducted with all seven ARCS contractors, to
-rain them on the principles of TQM. Sources of waste in the ARCS process
vere identified, and small workgroups are being formed to identify and
recommend solutions.
in addition to the above corrective measures, the OSF has been cooperating
/1th GAO on three audits with CORAS and the PCMD. An invoice tracking
system has been developed and implemented to assist the Project Officers in
standardizing reviews, and assisting RPMs/WAMs in invoice review. CMIU
Created a WAM database to track compliance with the certification process
required by the contracts Management Manual. Finally, an MOU with the PMD
,as been drafted to designate Community Relations staff of the Office of
>ublic Affairs as WAMs on all community relations work assignments.
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ATTACHMENT E
AGENCY-LEVEL WEAKNESSES/ CORRECTIVE ACTIONS
CATS Tracking
Assessable Unit/AU *: 502
Title ef Aaeney-level Weakness and Description; More intense
review of oversight of contractors performing PRP searches. (Re
Audit BISHD9-05-0019-9100493) .
Year Identified: (PY 1990}
Critical Milestones in Corrective Action: Superfund employees in
the Haste Management Division (WMO) will maintain early and
continuous contact with Regional contractors performing PRP
searches. The Office of Regional counsel (ORC) will be available
to consult with WMD as it carries out this responsibility. The ORC
will request HEIC to audit contractors who perform poorly in
conducting PRP Searches, if appropriate.
Budget Implications. If Anv;
Corrective Action Plan Status Updates;
* September 30. 1990. Status Update; COMPLETE
* December 31. 1990. Status Update;
* March 31. 1991. Statue Update:.
* June 30. 199 1^ Status Update:
* September 30. 1991. Status Update:
-------
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-------
-------
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
H45 ROSS AVCNJl SUIT! tZW
TcX*?7S2022733
MAR 30
SUBJECT: Contract Management Review
FROM: B. J. 'Wynne
Regional Administrator
TO: waHam K. Reffljr
Administrator (A-100)
As directed in your request dated March K), 1992,1 have assessed the present and potential
problems related to Contract and Project Management The assessment and resulting plan
of action are attached The effort of Regional staff in compiling the plan, win assist in a
Regional initiative implemented several months ago, to improve an contract management
activities wjthin the Region.
The attached information also includes accomplishments in the area of contract
management, as wen as action items currently in progress. We recognize that some of the
proposed solutions require attention on a National level
I take this opportunity to ej^ueit my niuceie dedication towaid this initiative, and offer
assurance of a firm commitment to continue our focus toward strengthening aD contract
management activities within this Region.
Please advise if additional information or clarification is required.
Attachment
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AREA OF CONCERN
Physical location of contract
employees
Decentralization of National
Delivery Orders to accomplish
Permit Compliance System data
ATTACHMENT
PROPOSED SOLUTIONS
Segregate contract employees
Lack of FTC's to perform
inherently governmental
stxmi
Lack of guidance and training
fbrDOPO's
Inadequate guidance on require-
ments of National Delivery Order
e-g^ expectations of contractor
employee, delivery order require-
ments, Regional responsibilities
Inadequate training on specific*
of the TOSS contract; Unaware of
changing policies in contract
management; Lack of aH employee
training in the areas of Ethics
and/or Standards of Conduct
DOPO on National DO responsible
for oversight of services provided
contractor employee located in
Region.
Continue effort under National D.O., to
consistency of data.
Provide additional FIEs.
Develop contract specific courses rather than
the general eoanes currently given.
Receive m-depth guidance of requirements and
responsibilities from HQ DOPO, Assign alternate
DOPO within the Region,
Implement qnarterry/annual conferences for HQ
and Regions to discuss concerns, problems, etc.
related to TOSS.
Develop Regional bulletin to keep employees
apprised of revisions to contract management
Implement Ethics/Standards of Conduct training
mandatory for all EPA employees.
g Region is accountable for quaHty of
provided, as well as delays resulting from HQ
bottleneck, would prefer to have Regional or
or Alternate DOPO.
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Attachment
As stated in my cover memorandum, several Initiatives began several months ago, in an
effort to improve the region's overall contract management efforts. Listed below are
accomplishments, as weD as Initiatives current! *
EstabBthment of a Contract Management Impioiement Workgroup to provide better
support for all regional contract management Initiatives. We ait also developing an
Information system that wffl idenfuy employees i|*H>"fip*^p>* Workgroup.
The TOSS contract specifies a Vegtonal cortractsfl»iu^er" responsible for a variety
of administrative and technical functions* However, means of resourcing this
function was never communicated to Ac region; therefore, we wOJ request
clarification from OIRM/PCMD, as to howAey envisioned resourcing this function
at file time the contract was negotiated. The assistance that can be offered by Ae
additional FTE In the PuKUnement Section wffl be limited to duties that an
contractual; therefore, flu? technical expertise of uV "regional cunhatts manager",
is stffl required.
Request guidance and assistance from PCMD on interpreting OMB Circular A-7ev
so that appropriate determinations can be made regarding functions currenfly being
performed by cunUactors, that are considered hmerenfly governmental.
-------
Attachment
Request a clear delegation of authority tfom Chris Holmes for the
Procurement Officer, as waD as after staff personnel responsible for providing
assistance or guidance to regional contract managsn. The delegation should
outfine the parameters feat are allowed, «*, meeting with contractor, written
correspondence to contractor, etc. The level of responsibility of regional staff
should also be conveyed to the contractor.
Regional staff are Involved hi various Initiatives cnrrentiy being implemented
natfonalh/forcurKntandlbnn^SttperfnndConlncts. These Initiatives Inchxle the
recent National ARCS Implementation Plan. The Zone of regions 47,a0d 8, have
also developed a Zone ARCS Implementation Plan - These plans addras several
Issues raised as a result off the reviews conducted by the Dunn Task Force. In
addition, the Long Term Contracting Strategy task group Is currcnth/ developing an
Implementation plan that wffl determine the type, combination, and mnnber of
contracts that wffi replace the current Soperfund contracts.
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APR-22-1992 12'35 FROM EPS REGIOH 6 TO 82022600035 P.002 -014
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
1445 ROSS AVENUE, SUITE 1200
DALLAS, TX 75202-2733
April 2, 1992
MEMORANDUM
SUBJECT: Follow-up to the Administrator's March to, 1992, Request for a
Review of EPA's Contracts Management
FROM: ^ B. J. Wynne
Regional Administrator
f
* ^
TO: ^ ' Christian R. Holmes
Acting Assistant Administrator
Office of Administration and Resources Management (PM-208)
My staff has formulated answers to the six questions In your March 31, 1992 nemo,
which my office received by facsiitile transmission. Those answers can be found
as attachments A and B to this memorandum.
requested that we give you as much Information as possible by April 2, and
the remainder by April 16. I am pleased to tell you that our answers to
questions one through four are complete. The data for question five
(attachment B) is 90X complete and will be finalized by April 10, 1992. In
response to question 6, I have 3 Contracting Officers and 150 program staff
assigned to contracts management In the Regional office. With the exception of
Pant Phil lips, who has been assigned to John Barker's taskforce, I have no legal
staff assigned to this function.
If you require further information, or have questions regarding Information IP
the attachments, please do not hesitate to contact me at FTS 255-2100.
Attachments
Printed on Recycles PZKW
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flPR-02-1952 12:05 FROM EPft REGION 6 TO B2022600835 P.003/014
Attachment A
A. Vulnerabilities that were identified in any program, management or other audit
(e.g., by OIQ or QAO) during the last live years;
1. OIQ Final audit report No. P1SFF9-11 -0032-0100482, Obligations
and Disbursements of the Hazardous Substance Superfund For the
Fiscal Year Ended September 30,1989, issued September 24,1990,
reflected a material weakness in the internal controls for accounting
and controlling persona! property.
2. OIQ Draft Audit report No. E1NMF1-04-0169, EPA's Management of
Computer Science Corporation (CSC) Contract Activities Issued
February 4, 1992, reflected EPA's vulnerability to fraudulent,
wasteful, abusive, and illegal practices from CSC contract operations.
They had increased to unacceptable levels due to poor contract
management practice by agency management officials. However,
Region 6 concurred on only 50 percent of the original findings
presented in the position papers and draft audit.
B. Vulnerabilities that were identified in any internal control review pursuant to FMFIA
requirements during the last five years;
1. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness in
Assessing the Extent of Fraudulent Data in the Region 6 Public
Water Program.
2. Annual assurance letter for fiscal year ended PY90, Issued
November 1990, reflected an agency level material weakness of the
Comprehensive Environmental Response Compensation and Liability
Act (CERCLA) Records Center Rle Management.
3. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness in
Resource Conservation and Recovery Act (RCRA) Records Center
File Management.
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-2- Attachment A
4. Annual assurance letter tor fiscal year ended FY91, issued
November 1991, reflected a material weaknesses in Contractor
Invoice Payments for Alternative Remedial Contract Strategy (ARCS)
and Technical Enforcement Support (TES).
C. Corrective actions initiated or completed to address such vulnerabilities;
1. Reference A (1) above.
A system is now in place and is closely monitored to ensure that all
accountable property is entered into the Personal Property
Accounting System (PPAS). A 100 percent physical Inventory is
scheduled and target completion date is February 1992. A new
property accountable officer was designated and to be effective
August 12, 1990. Custodial areas have been established and
custodial officers have been appointed for each area.
2. Reference A (2) above.
Corrective Management action taken in response to draft audit report
on EPA's Management of CSC Contract activities are:
a. Management Accountability
- Designate a single SES-level Manager as Senior
Procurement Officer. Bill Hathaway, Assistant
Regional Administrator for Management, is responsible
for the effectiveness and integrity of aP procurement
activities in the Region. He will to be the single local
point for Procurement authority and accountability for
Region 6 beginning March 15,1992.
- SES-level seminar attendance required this fiscal
year. All SES-level managers In this Region were told
on March 2 that they win be required to attend training
this fiscal year on the subject of Senior level Contract
Management We understand that the training is to be
developed by the standing committee on Procurement.
We stand ready to participate at any level required with
the information of the committee and/or the
development and presentation of the seminar.
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-3- Attachment A
Clear Distinction between Contractor and EPA
- Clear identification of contractor employees. In
November, 1991, all oontmctor badges were modified
from the standard Region 6 badge to a contractor
badge that is dearly identifiable. Identification security
badges for all contractors have a green background to
distinguish them from EPA employees (white) and
visitors (purple). The green badges have •contractor'
prominently displayed on the face. Work stations
occupied by contract staff are identified by nameplate.
•• Physically segregate contract employees In the work
place whenever possible. Region 6 is in the middle of
a space expansion project. This afforded us the
opportunity to segregate the majority of contractor staff.
This will be completed by the end of FY92.
-- Training/entertaining contractors. Contract Managers
were put on notice on March 3 that contractors In this
Region are not to be included in events such as
awards ceremonies, staff meetings and conferences
except in a specific, defined role. Special Emphasis
Program Managers have been instructed not to
approach contractor personnel to invite their
attendance to organized functions. The clearly
identified badges currently in use enable us to identify
when contractor staff inappropriately attend such
functions. We hold the Contract Manager responsible
to resolve this with the contractor site manager.
- Assignments which violate the ban on personal
services. We are currently examining ail delivery
orders under the Technical Operation Support Services
(TOSS) contract for actual or potential instance which
violate the ban. We are developing options for action
to immediately resolve the actual occurrences and to
define the proper role of involved parties for the
potential instances. We are aware that this will likely
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t-rn r\c.ujuii o !U fa«:t)2ib0k38J^ P. 006/014
-4- Attachment A
result in the termination of some contract support. We
began tnte assessment in October, 1991, and have
already terminated acme activities in the Financial and
Management programs.
c. Contract Policy Review
- No action has been taken on the Regional level, but
we are ready to participate from a programmatic
standpoint in the national effort to identify mission
contracts whose statement of work can be downsized
and recompeted.
d. Organization Accountability
- On the Regional level, we will train and support
Contract Managers and their organizations.
Responsibility for compliance with the Agency's
definition of good contract management will rest with
Senior Level Managers and with the supervisors of
Contract Managers. Recognizing that the review and
evaluation of a Contract Manager's effectiveness on
specific contracts is not an authority delegated to the
Regional office, the Senior Procurement Official will
support routine programmatic evaluations and will
recommend that responsible Contracting Officers
rescind certification* of authority as appropriate.
3. Reference B (1) above.
Corrective action taken to resolve material weakness in assessing
the extent of Fraudulent Data in the Region 6 Public Water Program:
a. Developed (jointly with Region 6 States) protocol for
evaluating extent of data falsification.
b. implemented protocol and Investigate as appropriate,
c. Evaluated findings.
d. Took appropriate enforcement action and modify
routine oversight data audit procedures to minimize risk
in future program.
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flPR-Q2-1992 12:07 FROM EPA REGION 6 TO 82022603835 P.307/014
-6- Attachment A
The corrective action plan status updated is reflected in FY91,
Corrective Action Tracking System (CATS), No. 91 -1, required
action completed in FY91).
4. Reference b (2) above.
Corrective action taken to resolve material weakness of CERCLA
Records Center File Management:
a. A workgroup was formed and an implementation plan
was developed.
b. A proposal to reconfigure the Records Center to make
better use of misting space and to Include a file
viewing area was submitted to Headquarters for
approval. Actual reconfiguration began in FY91 and
was completed in December 1991. This is still
inadequate for existing and potential file growth.
Seventy percent of the Superfund sites are
enforcement; therefore, cost recovery documentation
and the file system are essential in order to recover
government funds. Management Division was
requested to consider the need for additional file room
space; however, efforts to obtain more apaos did net
include public viewing area. Some additional file
storage space was provided.
c. The microfilming of Superfund Administrative Records
was initiated. When microfilming is completed, the
hard copies are shipped to archives in Fort Worth,
Texas. This will allow space for file material currently
not stored In the Records Center to be moved In. in
FY91,81 linear feet of Administrative Records and the
Compendium were microfiche. These records have
been packed into boxes and indexed.
d. New file check-out procedures were developed which
now require that file user be on the 'authorized"
personnel list (EPA staff only) and be issued a bar
code for Identification purposes. Files must be
returned to the file room within 14 days of check-out,
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flPR-02-1952 12:06 FROM EPfi REGION 6 TO 82022606935 P.006/314
-e- Attachment A
e. Initiated a work assignment under the Label-Anderson,
Inc. (LAI) contract to obtain records management
expertise and consulting services to make
recommendations on how to change current file room
procedures. A Reoord/Informailon Manager was hired
from LA! in October"! 991.
f. The wail separating the RCRA and CERCLA file rooms
was torn down in August 1991. Thirteen additional file
cabinets were added in the new file space.
g. In December 1991, It was determined that new NPL
file structure was needed. Initiated restructuring of files
and document-level indexing of non-NPL flies. Purging
of duplicates is ongoing during restructuring/filing of
NPL files. MetceJf and Eddy contractors were hired to
reorganize and restructure Superfund records. NPL
files wili be restructured when the new file structure
finalized.
The corrective action Plan Status updates is reflected
in FY91 and FY92 CASTS, No. 91-2, Action is not
completed.
5. Reference B (3) above.
Corrective action taken to resolve material weakness for RCRA
Records Center File Management:
a. A workgroup was formed and an implementation plan
developed.
b. Reconfiguration of the file room to make better use of
existing space began in FY91 but will not be completed
until mid-FY92. This is still inadequate for existing and
potential file growth
c. New file check-out procedures were developed which
now require that a file user be on the 'authorized"
personnel list (EPA staff only) and be issued a bar
code for identification purposes. Files must be
returned to file room within 14 days of check-out.
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ftPR-02-1952 12=06 FROM EPfi REGION 6 TO 82322600335 P.009-'014
-7- Attachment A
o. Management Division was requested to consider the
need for additional file room space. Although more file
storage was obtained, this dd not include space for
public viewing areas.
The corrective action plan status updates is reflected
in FY91 and PY02 CATS, No, 91-3, action is not
completed.
6. Reference B (4) above.
Corrective action taken to resolve material weaknesses of Contract
Invoice Payment tor ARCS and TES Contracts:
a. A Vulnerability Assessment was conducted in August,
1991, in conjunction with the Management Division.
b. in third quarter, 1991, the ARCS Work Assignment
Managers (WAMs) were provided a bulletin on invoice
concerns and questioning invoices where costs are not
understood.
c. In fourth quarter, 1991, the WAMs workload under
ARCS and TES were reviewed and determined not to
exceed recommended experience and workload.
d. During fourth quarter, the Procurement and Contracts
Management Division (PCMD) conducted a Regional
review of our ARCS invoice review procedures and
files.
e. The Project Officer* (PO) in the zone are in the
process of developing a checklist for Program
Management invoice reviews,
f. In October 1991, an ARCS Newsletter discussing the
task force recommendations was distributed to WAMs
and their supervisors.
The corrective action plan status update is reflected in
FY91 and PY92 CATS, No. 92-1, action is not
completed.
-------
flPR-22-1392 12:08 FROM EP« REGION 6 TO 82022600835 P.010^014
-8- Attachment A
D. implementation schedules for any corrective actions not yet completed;
1. Reference A {1} above.
A100 percent physical inventory is scheduled and target completion
date is February 1992. At the present time, an audrt by Contract
Auditors for DIG is being performed in the same area and
completion of their field work Is scheduled for April 3,1992.
2. Reference A (2) above.
At the present time a final audit report has not been issued.
However, a task foroe at Region 6 Is working on resolving the
findings.
V
3. Reference B (2) above.
Planned actions to resolve material weakness of CERCLA Records
Center Pile Management:
a. Continue efforts toward eliminating unneeded records,
microfilming as much as budget allows, dear out of all files,
b. In 1982 when the Region acquires additional apace, small
storage area will be obtained where some records can be
stored. The sixth floor will have a locked room that RCRA
and Super-fund will share with twenty Times 2 cabinets.
Superfund will gain twelve of the twenty cabinets.
c. Continue search for innovative ways to reduce the bulk of
paperwork in the division in order to reduce paper files.
d. By February, 1992, train Superfund staff on new file structure.
Revise Confidential Business Information and enforcement
confidential file procedures. Train Superfund staff on revised
procedures.
e. Continue restructuring of non-NPL and NPL files and
document level indexing of files to completion.
f. Obtain equipment and software for putting files on optical disk
imagery. NO'S plan is to have this to all Regions by 1999.
The corrective action plan status updates is reflected in FY92
CATS, No. 91-2 and next FY92 quarterly CATS update is
April 1992.
-------
-9- Attachment A
A. Reference B (3) above.
Planned action to resolve material weakness of RCRA Records
Center File Management:
a. The wall separating the RCRA and CERCLA file room was
torn down in August 1991. However, the reconfiguration is
not scheduled to be completed until April, 1992, which will
allow for more file cabinets to fit in the Superfund file room.
No additional file cabinets are planned for the RCRA file
room.
b. Continue) efforts are directed toward eliminating unneeded
records (shipping to short- and long-term storage as well as
purging duplicated documents).
c. Will continue to search for innovative ways to reduce the bulk
of paperwork in this Division in order to reduce paper files.
d. Will continue to purge unneeded records (shipping used files
to off-she storage).
e. Will work with States on an agreement that they will maintain
files thai currently contain only the "Notification of Hazardous
Waste Activity" for 8700-12,
f. Wiil work to ensure a public viewing area is established in
1992.
The corrective action plan status updates is reflected in FY92
CATS, No. 91-3 and next FY92 quarterly CATS update is
April 1992.
5. Reference B (4) above.
Planned action to resolve material weakness of Contractor Invoice
Payment for ARCS and TES Contracts:
a. One recommendation from Region's Vulnerability Assessment
was to use an invoice review checklist to document the
Project Officer (PO) and Contracting Officer (CO) review of
the invoices. By January 1,1992, the Region will implement
the use of an invoice review checklist to document the PO
and COs review of invoice.
-------
fiPR-02-1992 12:09 FROM EPft REGION 6 TO 82022600835 P.012/014
•10- Attachment A
b. Continue to require monthly submittal of invoice and progress
report review check sheets. By February 29,1992, initiated
use of an invoice checklist by the Work Assignment Managers
(WSMs) to document their invoice reviews.
c. By March 1,1992, a request for incurred cost audits will be
submitted for the TES contracts.
d. By March 31,1992, and again by October 1,1992, monitor
WAM workload under ARCS and TES.
e. Revise the WAM invoice review training to include guidance
on payment of Hem In "gray" areas of allowable. By May 30,
1992, conduct revised review training for WAMs.
f. By June 30,1992, conduct spot check audits/reviews of the
contractors' documentation for specific monthly line item
charges for the ARCS and TES contracts.
The corrective action plan status update is reflected in FY92
CATS, No. 92-1 and next FY92 quarterly CATS update is
April 1992.
NOTE: This Data is based on audit reports since FY90 and Annual
Assurance Letters for FY87, FY88, FY89, FY90, and FY91.
-------
1 (J
P.013/014
ATTACHMENT B
CONTRACTS SUMMARY
APRIL 1, 1992
CONTRACTOR
Roy F. Weston
Fuor-Daniel, Inc.
COM
CH2M Hill
Jacobs Engineering
Morrison Knudssn
Sverdrup Corp
URS Consultant
PRC
Metcalf £ Eddy
PRC
Resource Applicat
An Analyt Test Serve
Beta
oulf
Keystone of TX
SW Lab of OK
SW Research of SA
ICF
Hewlett-Packard
Eniron t Ecology
CSC
Riedel
Lee Wilson & Assoc
Daniel T Serna
CADMUS
MRI
Tetra-Tecn
Aa Mgt Systems
SAIC
ICF
MRI
MRI
PURPOSE
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
TES 9
TES 10
RCRA Implement
TAT (8a)
CLP
CLP
CLP
CLP
CLP
CLP
ESAT
MAINTENANCE
TAT
TOSS
ERCS
Report Prep
Storeroon Ser
TYPE BE
CPAF/LOE
CPAF/LOE
CFAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
ID/IQ
FIXED PRICE
NPDES TECH SUPPLY ID/IQ
Streamline Proj
coast Wtr Proj
Coast Wtr Proj
Coast wtr Proj
Training
Training
CLEAN AIR ASST
ID/QI
ID/IQ
ID/IQ
FIXED PRICE
FIXED PRICE
LOB
i
i
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
N
N
N
N
N
N
N
N
N
R
Z
Z
Z
R
R
N
N
N
N
N
N
N
N
IONAL
ffl»
156,213
142,142
•
t
t
154,794,
151,873
150,241
155,373
67,305
157,811
33,100
33,100
8r267
3,991
i
i
i
i
,
t
i
i
t
2,038,
1,000,
3,970,
1,561
i
4,384,
4,627
i
6,000,
110
i
76,800,
357,000
110,137
1,092
147
600
37
50
90
42
37
10
9
i
i
i
t
t
i
i
t
i
t
i
t
437
204
394
624
713
447
250
577
000
000
709
758
780
000
560
760
000
000
COO
000
000
000
819
000
400
000
163
000
000
SCO
180
144
745
——•
N
2
2
2
2
2
2
2
2
5
e
5
5
6
6
6
6
6
6
5
1
4
5
2
1
1
7
8
8
8
8
8
8
8
-------
flPR-02-a9S2 12:10 FRO* EFft REGION 6 TO 82022500635 P.214/014
NOTES!
1. Dollar value shown is potential dollar value for the entire
contract,
2. Zone contract for Region 6-81 dollar value shown is total
potential dollar value.
3. Zone contract for Region* 5-7; dollar value shown is total
potential dollar value.
4. zone contract for Region* 5-10; dollar value shown ia total
potential dollar value.
5. National Contract; dollar value is potential dollar value for
the entire contract*
6. Contracts in contract lab progran; dollar values are for
Region 6 activity only.
7. Dollar value reflects FY92, one work assignment only. MAM in
HQ, potential dollar value of total contract unknown to
Region 6.
8. Dollar value is for Region 6 work assignment* under national
contract. Potential dollar value of total contract unknown.to
Region 6.
AttMNtnt t« CMrtlMCTS IIMMftY
TOTflL P.014
-------
-------
P.08S-'B14
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
1*«5 ROSS AVENUE, SUITE 1200
DALLAS, TX 75202-2733
April 2, 1992
MEMORANDUM
SUBJECT:
10, 1992, Request for a
FROM:
TO:
(
* ^
Follow-up to the Administrator's March
Review of EPA's Contracts Management
B. J. Wynne
Regional Administrator
Christian R. Holmes
Acting Assistant Administrator
Office of Administration and Resources Management (PM-208)
Hy staff has formulated answers to the six questions in your March 31, 1992 memo,
which my office received by facsimile transmission. Those answers can be found
as attachments A and B to this memorandum.
requested that we give you as much Information as possible by April 2, and
the remainder by April 16. I am pleased to tell you that our answers to
questions one through four are complete. The data far question five
(attachment 6) is 90% complete and will be finalized by April 10, 1992. In
resoonse to question 6, I have 3 Contracting Officers and 150 program staff
asstgrred to contracts management in the Regional office. With the exception of
Pam Phil i1ps, who has been assigned to John Barker's taskforce, I have no legal
staff assigned to this function.
If you require further information, or have questions regarding Information ir
the attachments, please do not hesitate to contact me at FTS 256-2100.
Attachments
Printeti or Recycled
-------
-------
I-KLT1 EPH FiuiUht b TO
Attachment A
A. Vulnerabilities that were identified In any program, management or other audit
(e.g., by OIQ or QAO) during the last live years;
1. OIG Final audit report No. P1SFF9-11-0032-0100492, Obligations
and Disbursement* of the Hazardous Substance Superfund For the
Fiscat Year Ended September 30,1999, issued September 24,1990,
reflected a material weakness in the internal controls for accounting
and controlling persona! property.
2. OIG Draft Audit report No. E1NMF1-04-0169, EPA's Management of
Computer Science Corporation (CSC) Contract Activities Issued
February 4, 1992, reflected ERA'S vulnerability to fraudulent,
wasteful, abusive, and illegal practices from CSC contract operations.
They had increased to unacceptable levels due to poor contract
management practice by agency management officials. However,
Region 6 concurred on only 60 percent of the original findings
presented in the position papers and draft audit.
B. Vulnerabilities that were identified in any internal control review pursuant to FMFIA
requirements during the last five years;
1. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness in
Assessing the Extent of Fraudulent Data in the Region 6 Public
Water Program.
2. Annual assurance tetter for fiscal year ended FY90, Issued
November 1990, reflected an agency level material weakness of the
Comprehensive Environmental Response Compensation and Liability
Act (CERCLA) Records Center Rle Management.
3. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness in
Resource Conservation and Recovery Act (RCRA) Records Center
Rle Management.
-------
Attachment A
4. Annual assurance letter for fiscal year ended FY91. iasued
November 1991, reflected a material weaknesses in Contractor
Invoice Payments for AHemative Remedial Contract Strategy (ARCS)
and Technical Enforcement Support (TES).
C. Corrective actions initiated or completed to address such vulnerabilities;
1. Reference A (1) above.
A system is now in place and is closely monitored to ensure that ail
accountable property ia entered into the Personal Property
Accounting System (PPAS). A 100 percent physical inventory is
scheduled and target completion date is February 1992. A new
property accountable officer was designated and to be effective
August 12, 1990. Custodial areas have been established and
custodial officers have been appointed for each area.
2. Reference A (2) above.
Corrective Management action taken in response to draft audit report
on EPA's Management of CSC Contract activities are:
a. Management Accountability
- Designate a single SES-level Manager as Senior
Procurement Officer. Bill Hathaway, Assistant
Regional Administrator for Management, is responsible
for the effectiveness and integrity of all procurement
activities in the Region. He will to be the single focal
point for Procurement authority and accountability for
Region 6 beginning March 15,1992.
- SES-level seminar attendance required this fiscal
year. All SES-level managers in this Region were told
on March 2 that they will be required to attend training
this fiscal year on the subject of Senior level Contract
Management We understand that tne training is to be
developed by the standing committee on Procurement.
We stand ready to participate at any level required with
the information of the committee and/or the
development and presentation of the seminar.
-------
fiPR-Oi-1932 12: OS FROM EPft REGION 6 TC 82Q2260QG35 P.005x014
-3- Attachment A
Clear Distinction between Contractor and EPA
- Clear identification of contractor employees, in
November, 1991, alt contractor badges were modified
from the standard Region 6 badge to a contractor
badge that is dearly identifiable. Identification security
badges for all contractors have a green background to
distinguish them from EPA employees (white) and
visitors (purple). The green badges have •contractor'
prominently displayed on the face. Work stations
occupied by contract staff are identified by nameplate.
•• Physically segregate contract employees in the work
place whenever possible. Region 6 is in the middle of
a space expansion project. Thfe afforded us the
opportunityto segregate the majority of contractor staff.
This will be completed by the end of FY92.
- Training/entertaining contractors. Contract Managers
were put on notice on March 3 that contractors In this
Region are not to be Included in events such as
awards ceremonies, staff meetings and conferences
except in a specific, defined roie. Special Emphasis
Program Managers have been instructed not to
approach contractor personnel to Invite their
attendance to organized functions. The dearly
identified badges currently in use enable us to identify
when contractor staff inappropriately attend such
functions. We hold the Contract Manager responsible
to resolve this with the contractor site manager.
- Assignments which violate the ban on personal
services. We are currently examining all delivery
orders underthe Technical Operation Support Services
(TOSS) contract for actual or potential instance which
violate the ban. We are developing options for action
to immediately resolve the actual occurrences and to
define the proper role of Involved parties tor the
potential instances. We are aware that this will likely
-------
fcPR-02-1992 12:07 FROM EPft REGION 6 TO 82022600835 P.006/014
-4- Attachment A
result in the termination of some contract support. We
began this assessment in October, 1991, and have
already terminated some activities in the Financial and
Management programs.
c. Contract Policy Review
~ No action has been taken on the Regional level, but
we are ready to participate from a programmatic
standpoint in the national effort to identify mission
contracts whose statement of work can be downsized
and recompeted.
d. Organization Accountability
- On the Regional level, we will train and support
Contract Managers and their organizations.
Responsibility for compliance with the Agency's
definition of good contract management will rest with
Senior Level Managers and with the supervisors of
Contract Managers. Recognizing that the review and
evaluation of a Contract Manager's effectiveness on
specific contract* is not an authority delegated to the
Regional office, the Senior Procurement Official will
support routine programmatic evaluations and will
recommend that responsible Contracting Officers
rescind certifications of authority as appropriate.
3. Reference B (1) above.
Corrective action taken to resolve material weakness in assessing
the extent of Fraudulent Data in the Region 6 Public Water Program:
a. Developed (jointly with Region 6 States) protocol for
evaluating extent of data falsification.
b. implemented protocol and Investigate as appropriate.
c. Evaluated findings.
d. Took appropriate enforcement action and modify
routine oversight data audit procedures to minimize risk
in future program.
-------
flPR-02-1952 12:87 rROM EPA REGICN 6 TO B20226B0B35 P.307-'014
-6- Attachment A
The corrective action plan statue updated is reflected in FY91,
Corrective Action Tracking System (CATS), No. 91 -1, required
action completed in FY91).
4. Reference b (2) above.
Corrective action taken to resolve material weakness of CERCLA
Records Center Rle Management:
a. A workgroup was formed and an implementation plan
was developed.
b. A proposal to reconfigure the Records Center to make
better use of existing space and to include a file
viewing area was submitted to Headquarters for
approval. Actual reconfiguration began in FY91 and
was completed in December 1891. This is still
inadequate for existing and potential file growth.
Seventy percent of the Superfund sites are
enforcement; therefore, cost recovery documentation
and the file system are essential in order to recover
government funds. Management Division was
requested to consider the need for additional file room
space; however, efforts to obtain more space did net
include public viewing area. Some additional file
storage space was provided.
c. The microfilming of Superfund Administrative Records
was initiated. When microfilming is completed, the
hard copies are shipped to archives in Fort Worth,
Texas. This will allow space for file material currently
not stored In the Records Center to be moved In. In
FY91,81 linear feet of Administrative Records and the
Compendium were microfiche. These records have
been packed Into boxes and indexed.
d. New file check-out procedures were developed which
now require that file user be on the "authorized"
personnel list (EPA staff only) and be issued a bar
code for identification purposes. Files must be
returned to the file room within 14 days of check-out.
-------
flPR-02-19S2 12=06 FPOfi EPfl REGION 6 TO 82022S06S35 P.006/314
-6- Attachment A
e. Initiated a work assignment under the Labat-Anderson,
Inc. (LAI) contract to obtain records management
expertise and consulting services to make
recommendations on how to change current file room
procedures. A Record/Information Manager was hired
from LAI in October 1991.
f. The wall separating the RCRA and CERCLA file rooms
was torn down in August 1991. Thirteen additional file
cabinets were added in the new file space.
g. In December 1991, it was determined that new NPL
file structure was needed. Initiated restructuring of files
and document-level indexing of non-NPL files. Purging
of duplicates is ongoing during restructuring/filing of
NPL files. Metcalf and Eddy contractors were hired to
reorganize and restructure Superfund records. NPL
files wili be restructured when the new file structure
finalized.
The corrective action Plan Status updates is reflected
in FY91 and FY92 CASTS, No. 91-2, Action is not
completed.
5. Reference B (3) above.
Corrective action taken to resolve material weakness for RCRA
Records Center File Management:
a. A workgroup was formed and an implementation plan
developed.
b. Reconfiguration of the file room to make better use of
existing space began in FY91 but will not be completed
until mid-FY92. This is still inadequate for existing and
potential file growth
c. New file check-out procedures were developed which
now require that a file user be on the "authorized"
personnel list (EPA staff only) and be issued a bar
code for identification purposes. Piles must be
returned to file room within u days of check-out.
-------
^ 12=06 FROM EPR REGION 6 TO 82322600335 P.
-7- Attachment A
d. Management Division was requested to consider the
need for additional file room space. Although more file
storage was obtained, this did not include space for
public viewing areas.
The corrective action plan status updates is reflected
in FY91 and PY82 CATS, No. 91-3, action is not
completed.
6. Reference B (A) above.
Corrective action taken to resolve material weaknesses of Contract
Invoice Payment for ARCS and TES Contracts:
a. A Vulnerability Assessment was conducted in August,
1991, in conjunction with the Management Division.
b. In third quarter, 1991, the ARCS Work Assignment
Managers (WAMs) were provided a bulletin on Invoice
concerns and questioning invoices where costs are not
understood.
c. In fourth quarter, 1991, the WAMs workload under
ARCS and TES were reviewed and determined not to
exceed recommended experience and workload.
d. During fourth quarter, the Procurement and Contracts
Management Division (PCMD) conducted a Regional
review of our ARCS invoice review procedures and
files.
e. The Project Officers (PO) in the zone are in the
process of developing a checklist for Program
Management invoice reviews.
f. In October 1991, an ARCS Newsletter discussing the
task force recommendations was distributed to WAMs
and their supervisors.
The corrective action plan status update is reflected in
FY91 and FY92 CATS, No. 92-1, action is not
completed.
°l
-------
flFP-i32-1392 12:06 FROM EPA REGION 6 TO 82822630835 P.010/014
-8- Attachment A
D. Implementation schedules for any corrective actions not yet completed;
1. Reference A (1} above.
date is February 1992. At the present time, an aucft by Contract
Auditors for DIG is being performed in the same area and
completion of their field work Is scheduled for April 3,1992.
2. Reference A (2) above.
At the present time a final audit report has not been issued.
However, a task force at Region 6 Is working on resolving the
findings.
3. Reference B (2) above.
Planned actions to resolve material weakness of CERCLA Records
Center File Management:
a. Continue efforts toward eliminating unneeded records,
microfilming as much as budget allows, dear out of ali files.
b. In 1992 when the Region acquires additional space, small
storage area will be obtained where some records can be
stored. The sixth floor will have a locked room that RCRA
and Superfund will sham with twenty Times 2 cabinets.
Superfund will gain twelve of the twenty cabinets.
c. Continue search for innovative ways to reduce the bulk of
paperwork in the division in order to reduce paper files.
d. By February, 1992, train Superfund staff on new file structure.
Revise Confidential Business information and enforcement
confidential file procedures. Train Superfund staff on revised
procedures.
e. Continue restructuring of non-NPL and NPL files and
document level indexing of files to completion.
f. Obtain equipment and software for putting files on optical disk
imagery. HCft plan is to have this to all Regions by 1999.
The corrective action plan status updates is reflected in FY92
CATS, No. 91-2 and next FY92 quarterly CATS update is
April 1992.
10
-------
FROI1 EPH REulON 6 TO 82022600Q35 P.011/014
-9- Attachment A
Reference B (3) above.
Planned action to resolve material weakness of RCRA Records
Center File Management:
a. The wall separating the RCRA and CERCLA file room was
torn down in August 1991. However, the reconfiguration is
not scheduled to be completed until April, 1992, which will
allow for more file cabinets to fit in the Superfund file room.
No additional file cabinets are planned for the RCRA file
room.
b. Continue! efforts are directed toward eliminating unneeded
records (shipping to short- and long-term storage as well as
purging duplicated documents).
c. Will continue to search for innovative ways to reduce the bulk
of paperwork in this Division in order to reduce paper files.
d. Will continue to purge unneeded records (shipping used files
to off-she storage).
e. Will work with States on an agreement that they will maintain
files that currently contain only the "Notification of Hazardous
Waste Activity" tor 8700-12.
f. Will work to ensure a public viewing area is established in
1992.
The corrective action plan status updates is reflected in FY92
CATS, No. 91-3 and next FY92 quarterly CATS update is
April 1992.
5. Reference B (4) above.
Planned action to resolve material weakness of Contractor Invoice
Payment for ARCS and TES Contracts:
a. One recommendation from Region's Vulnerability Assessment
was to use an invoice review checklist to document the
Project Officer (PO) and Contracting Officer (CO) review of
the invoices. By January 1,1992, the Region will implement
the use of an invoice review checklist to document the PO
and COs review of invoice.
-------
HfJK-02-1992 12J09 FROM EPft REGION 6 TO 82022600935 P.012x014
•10- Attachment A
b. Continue to require monthly submrttal of invoice and progress
report review check sheets. By February 29,1992, initiated
use of an invoice checklist by the Work Assignment Managers
(WSMs) to document their invoice reviews.
c. By March 1,1992. a request for incurred cost audits will be
submitted for the TES contracts.
d. By March 31,1992, and again by October 1,1992, monitor
WAM workload under ARCS and TES.
e. Revise the WAM invoice review training to include guidance
on payment of Hem in "gray" areas of allowable. By May 30,
1992, conduct revised review training for WAMs.
f. By June 30,1992, conduct spot check audits/reviews of the
contractors' documentation for specific monthly line item
charges for the ARCS and TES contracts.
The corrective action plan status update is reflected in FY92
CATS, No. 92-1 and next FY92 quarterly CATS update is
April 1992.
NOTE: This Data is based on audit reports since FY90 and Annual
Assurance Letters for FY87, FY88, FY89, FY90, and FY81.
-------
PPR-02-1992 12=10
FROM EPft REGION 6
TO 82022600335 P.013/014
ATTACHMENT B
CONTRACTS SUMMARY
APRIL 1, 19S2
CONTRACTOR
Roy F. Weston
Fucr- Daniel, Inc.
COM
CH2M Hill
Jacobs Engineering
Morrison Knudsen
sverdrup Corp
URS Consultant
PRC
Met calf t Eddy
PRC
Resource Applicat
An Analyt Test Serve
Betz
Gulf
Keystone of TX
SW Lab of OK
SW Research of SA
rep
Hewlett-Packard
En iron t Ecology
CSC
Riedel
Lee Wilson & Assoc
Daniel T Serna
CADMUS
MRI
Tetra~Tech
An Mgt Systems
SAIC
ICP
MRI
MRI
PURPOSE
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
TES 9
TES 10
RCRA Implement
TAT (8a)
CLP
CLP
CLP
CLP
CLP
CLP
ESAT
MAINTENANCE
TAT
TOSS
ERCS
Report Prep
Storeroom Ser
TYPE s;
i
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
ID/IQ
FIXED PRICE
NPDES TECH SUPPLY ID/IQ
Streamline Proj
Coast Wtr Proj
Coast Wtr Proj
Coast Wtr Proj
Training
Training
CLEAN AIR ASST
ID/QI
ID/IQ
ID/IQ
FIXED PRICE
FIXED PRICE
LOE
"NATIONAL T
•REGIONAL £
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
N
N
N
N
N
N
N
N
N
R
Z
Z
Z
R
R
N
N
N
N
N
N
N
N
156,213,437
142,142,204
154,794,394
151,673,624
150,241,713
155,373,447
67,305,250
157,811,577
33,100,000
33,100,000
8,267,709
3,991,758
2,038,780
1,000,000
3,970,560
1,561,760
4,384,000
4,627,000
6,000,000
110,000
76,800,000
357,000,000
110,137,819
1,092,000
147,400
600,000
37,163
50,000
90,OOO
42,500
37,180
10,144
9,745
2
2
2
2
2
2
2
2
5
5
5
5
6
6
6
6
6
6
5
1
4
5
2
1
1
7
e
8
8
8
8
8
6
-------
APR-02-19S2 12U0 FRO* EFP REGION 6 TO B2022600&35 P.0:4/014
NOTES! .
1. Dollar value shown is potential dollar value for the entire
contract,
2. 2one contract for Region 6-8; dollar value shown is total
potential dollar value.
3. Zone contract for Region* 5-7; dollar value shown is total
potential dollar value.
4. Zone contract for Regions 5-10; dollar value shown is total
potential dollar value.
5. National Contract; dollar value is potential dollar value for
the entire contract.
6. Contracts in contract lab program; dollar values are for
Region 6 activity only.
7. Dollar value reflects FY92, one work assignment only. WAM in
HQ, potential dollar value of total contract unknown to
Region 6.
6. Dollar value is for Region 6 work assignments under national
contract. Potential dollar value of total contract unknown to
Region 6.
AttMt*«lt t* CONTRACTS (USttAY
TOTAL P.014
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
1445 ROSS AVENUE, SUITE 1200
DALLAS, TX 75202-2733
10, 1992, Request for a
April 2, 1992
MEMORANDUM
SUBJECT: Follow-up to the Administrator's March
Review of EPA's Contracts Management
FROM: B. J. Wynne
\ Regional Administrator (
\&
TO: -s Christian R. Holmes
Acting Assistant Administrator
Office of Administration and Resources Management (PM-208)
My staff has formulated answers to the six questions in your March 31, 1992 memo,
which my office received by facsimile transmission. Those answers can be found
as attachments A and B to this memorandum.
You requested that we give you as much information as possible by April 2, and
the remainder by April 16. I am pleased to tell you that our answers to
questions one through four are complete. The data for question five
(attachment B) is 90% complete and will be finalized by April 10, 1992. In
response to question 6, I have 3 Contracting Officers and 150 program staff
assigned to contracts management in the Regional office. With the exception of
Pam Phillips, who has been assigned to John Barker's taskforce, I have no legal
staff assigned to this function.
If you require further information, or have questions regarding information in
the attachments, please do not hesitate to contact me at FTS 255-2100.
Attachments
Printed on Recycled Paper
-------
-------
Attachment A
A. Vulnerabilities that were identified in any program, management or other audit
(e.g., by OIG or GAO) during the last five years;
1. OIG Final audit report No. P1SFF9-11-0032-0100492, Obligations
and Disbursements of the Hazardous Substance Superfund For the
Fiscal Year Ended September 30,1989, issued September 24,1990,
reflected a material weakness in the internal controls for accounting
and controlling personal property.
2. OIG Draft Audit report No. E1NMF1 -04-0169, EPA's Management of
Computer Science Corporation (CSC) Contract Activities issued
February 4, 1992, reflected EPA's vulnerability to fraudulent,
wasteful, abusive, and illegal practices from CSC contract operations.
They had increased to unacceptable levels due to poor contract
management practice by agency management officials. However,
Region 6 concurred on only 50 percent of the original findings
presented in the position papers and draft audit.
B. Vulnerabilities that were identified in any internal control review pursuant to FMFIA
requirements during the last five years;
1. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness in
Assessing the Extent of Fraudulent Data in the Region 6 Public
Water Program.
2. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness of the
Comprehensive Environmental Response Compensation and Liability
Act (CERCLA) Records Center File Management.
3. Annual assurance letter for fiscal year ended FY90, issued
November 1990, reflected an agency level material weakness in
Resource Conservation and Recovery Act (RCRA) Records Center
File Management.
-------
-2- Attachment A
4. Annual assurance letter for fiscal year ended FY91, issued
November 1991, reflected a material weaknesses in Contractor
Invoice Payments for Alternative Remedial Contract Strategy (ARCS)
and Technical Enforcement Support (TES).
C. Corrective actions initiated or completed to address such vulnerabilities;
1. Reference A (1) above.
A system is now in place and is closely monitored to ensure that all
accountable property is entered into the Personal Property
Accounting System (PPAS). A 100 percent physical inventory is
scheduled and target completion date is February 1992. A new
property accountable officer was designated and to be effective
August 12, 1990. Custodial areas have been established and
custodial officers have been appointed for each area.
2. Reference A (2) above.
Corrective Management action taken in response to draft audit report
on EPA's Management of CSC Contract activities are:
a. Management Accountability
-- Designate a single SES-fevel Manager as Senior
Procurement Officer. Bill Hathaway, Assistant
Regional Administrator for Management, is responsible
for the effectiveness and integrity of all procurement
activities in the Region. He will to be the single focal
point for Procurement authority and accountability for
Region 6 beginning March 15, 1992.
- SES-level seminar attendance required this fiscal
year. All SES-level managers in this Region were told
on March 2 that they will be required to attend training
this fiscal year on the subject of Senior level Contract
Management. We understand that the training is to be
developed by the standing committee on Procurement.
We stand ready to participate at any level required with
the information of the committee and/or the
development and presentation of the seminar.
-------
-3- Attachment A
b. Clear Distinction between Contractor and EPA
-- Clear identification of contractor employees. In
November, 1991, all contractor badges were modified
from the standard Region 6 badge to a contractor
badge that is clearly identifiable. Identification security
badges for all contractors have a green background to
distinguish them from EPA employees (white) and
visitors (purple). The green badges have "contractor"
prominently displayed on the face. Work stations
occupied by contract staff are identified by nameplate.
-- Physically segregate contract employees in the work
place whenever possible. Region 6 is in the middle of
a space expansion project. This afforded us the
opportunity to segregate the majority of contractor staff.
This will be completed by the end of FY92.
-- Training/entertaining contractors. Contract Managers
were put on notice on March 3 that contractors in this
Region are not to be included in events such as
awards ceremonies, staff meetings and conferences
except in a specific, defined role. Special Emphasis
Program Managers have been instructed not to
approach contractor personnel to invite their
attendance to organized functions. The clearly
identified badges currently in use enable us to identify
when contractor staff inappropriately attend such
functions. We hold the Contract Manager responsible
to resolve this with the contractor site manager.
-- Assignments which violate the ban on personal
services. We are currently examining all delivery
orders under the Technical Operation Support Services
(TOSS) contract for actual or potential instance which
violate the ban. We are developing options for action
to immediately resolve the actual occurrences and to
define the proper role of involved parties for the
potential instances. We are aware that this will likely
-------
-4- Attachment A
result in the termination of some contract support. We
began this assessment in October, 1991, and have
already terminated some activities in the Financial and
Management programs.
c. Contract Policy Review
-- No action has been taken on the Regional level, but
we are ready to participate from a programmatic
standpoint in the national effort to identify mission
contracts whose statement of work can be downsized
and recompeted.
d. Organization Accountability
-- On the Regional level, we will train and support
Contract Managers and their organizations.
Responsibility for compliance with the Agency's
definition of good contract management will rest with
Senior Level Managers and with the supervisors of
Contract Managers. Recognizing that the review and
evaluation of a Contract Manager's effectiveness on
specific contracts is not an authority delegated to the
Regional office, the Senior Procurement Official will
support routine programmatic evaluations and will
recommend that responsible Contracting Officers
rescind certifications of authority as appropriate.
3. Reference B (1) above.
Corrective action taken to resolve material weakness in assessing
the extent of Fraudulent Data in the Region 6 Public Water Program:
a. Developed (jointly with Region 6 States) protocol for
evaluating extent of data falsification.
b. Implemented protocol and investigate as appropriate.
c. Evaluated findings.
d. Took appropriate enforcement action and modify
routine oversight data audit procedures to minimize risk
in future program.
-------
-5- Attachment A
The corrective action plan status updated is reflected in FY91,
Corrective Action Tracking System (CATS), No. 91-1, required
action completed in FY91).
4. Reference b (2) above.
Corrective action taken to resolve material weakness of CERCLA
Records Center File Management:
a. A workgroup was formed and an implementation plan
was developed.
b. A proposal to reconfigure the Records Center to make
better use of existing space and to include a file
viewing area was submitted to Headquarters for
approval. Actual reconfiguration began in FY91 and
was completed in December 1991. This is still
inadequate for existing and potential file growth.
Seventy percent of the Superfund sites are
enforcement; therefore, cost recovery documentation
and the file system are essential in order to recover
government funds. Management Division was
requested to consider the need for additional file room
space; however, efforts to obtain more space did not
include public viewing area. Some additional file
storage space was provided.
c. The microfilming of Superfund Administrative Records
was initiated. When microfilming is completed, the
hard copies are shipped to archives in Fort Worth,
Texas. This will allow space for file material currently
not stored in the Records Center to be moved in. In
FY91, 81 linear feet of Administrative Records and the
Compendium were microfiche. These records have
been packed into boxes and indexed.
d. New file check-out procedures were developed which
now require that file user be on the "authorized"
personnel list (EPA staff only) and be issued a bar
code for identification purposes. Files must be
returned to the file room within 14 days of check-out.
-------
-6- Attachment A
e. Initiated a work assignment under the Labat-Anderson,
Inc. (LAI) contract to obtain records management
expertise and consulting services to make
recommendations on how to change current file room
procedures. A Record/Information Manager was hired
from LAI in October 1991.
f. The wall separating the RCRA and CERCLA file rooms
was torn down in August 1991. Thirteen additional file
cabinets were added in the new file space.
g. In December 1991, it was determined that new NPL
file structure was needed. Initiated restructuring of files
and document-level indexing of non-NPL files. Purging
of duplicates is ongoing during restructuring/filing of
NPL files. Metcalf and Eddy contractors were hired to
reorganize and restructure Superfund records. NPL
files will be restructured when the new file structure
finalized.
The corrective action Plan Status updates is reflected
in FY91 and FY92 CASTS, No. 91-2, Action is not
completed .
5. Reference B (3) above.
Corrective action taken to resolve material weakness for RCRA
Records Center File Management:
a. A workgroup was formed and an implementation plan
developed.
b. Reconfiguration of the file room to make better use of
existing space began in FY91 but will not be completed
until mid-FY92. This is still inadequate for existing and
potential file growth.
c. New file check-out procedures were developed which
now require that a file user be on the "authorized"
personnel list (EPA staff only) and be issued a bar
code for identification purposes. Files must be
returned to file room within 14 days of check-out.
-------
-7- Attachment A
d. Management Division was requested to consider the
need for additional file room space. Although more file
storage was obtained, this did not include space for
public viewing areas.
The corrective action plan status updates is reflected
in FY91 and FY92 CATS, No. 91-3, action is not
completed.
6. Reference B (4) above.
Corrective action taken to resolve material weaknesses of Contract
Invoice Payment for ARCS and TES Contracts:
a. A Vulnerability Assessment was conducted in August,
1991, in conjunction with the Management Division.
b. In third quarter, 1991, the ARCS Work Assignment
Managers (WAMs) were provided a bulletin on invoice
concerns and questioning invoices where costs are not
understood.
c. In fourth quarter, 1991, the WAMs workload under
ARCS and TES were reviewed and determined not to
exceed recommended experience and workload.
d. During fourth quarter, the Procurement and Contracts
Management Division (PCMD) conducted a Regional
review of our ARCS invoice review procedures and
files.
e. The Project Officers (PO) in the zone are in the
process of developing a checklist for Program
Management invoice reviews.
f. In October 1991, an ARCS Newsletter discussing the
task force recommendations was distributed to WAMs
and their supervisors.
The corrective action plan status update is reflected in
FY91 and FY92 CATS, No. 92-1, action is not
completed.
-------
-8- Attachment A
D. Implementation schedules for any corrective actions not yet completed;
1. Reference A (1) above.
A 100 percent physical inventory is scheduled and target completion
date is February 1992. At the present time, an audit by Contract
Auditors for OIG is being performed in the same area and
completion of their field work is scheduled for April 3, 1992.
2. Reference A (2) above.
At the present time a final audit report has not been issued.
However, a task force at Region 6 is working on resolving the
findings.
3. Reference B (2) above.
Planned actions to resolve material weakness of CERCLA Records
Center File Management:
a. Continue efforts toward eliminating unneeded records,
microfilming as much as budget allows, clear out of all files.
b. In 1992 when the Region acquires additional space, small
storage area will be obtained where some records can be
stored. The sixth floor will have a locked room that RCRA
and Superfund will share with twenty Times 2 cabinets.
Superfund will gain twelve of the twenty cabinets.
c. Continue search for innovative ways to reduce the bulk of
paperwork in the division in order to reduce paper files.
d. By February, 1992, train Superfund staff on new file structure.
Revise Confidential Business Information and enforcement
confidential file procedures. Train Superfund staff on revised
procedures.
e. Continue restructuring of non-NPL and NPL files and
document level indexing of files to completion.
f. Obtain equipment and software for putting files on optical disk
imagery. HQ's plan is to have this to all Regions by 1999.
The corrective action plan status updates is reflected in FY92
CATS, No. 91-2 and next FY92 quarterly CATS update is
April 1992.
-------
-9- Attachment A
4. Reference B (3) above.
Planned action to resolve material weakness of RCRA Records
Center File Management:
a. The wall separating the RCRA and CERCLA file room was
torn down in August 1991. However, the reconfiguration is
not scheduled to be completed until April, 1992, which will
allow for more file cabinets to fit in the Superfund file room.
No additional file cabinets are planned for the RCRA file
room.
b. Continue! efforts are directed toward eliminating unneeded
records (shipping to short- and long-term storage as well as
purging duplicated documents).
c. Will continue to search for innovative ways to reduce the bulk
of paperwork in this Division in order to reduce paper files.
d. Will continue to purge unneeded records (shipping used files
to off-site storage).
e. Will work with States on an agreement that they will maintain
files that currently contain only the "Notification of Hazardous
Waste Activity" for 8700-12.
f. Will work to ensure a public viewing area is established in
1992.
The corrective action plan status updates is reflected in FY92
CATS, No. 91-3 and next FY92 quarterly CATS update is
April 1992.
5. Reference B (4) above.
Planned action to resolve material weakness of Contractor Invoice
Payment for ARCS and TES Contracts:
a. One recommendation from Region's Vulnerability Assessment
was to use an invoice review checklist to document the
Project Officer (PO) and Contracting Officer (CO) review of
the invoices. By January 1,1992, the Region will implement
the use of an invoice review checklist to document the PO
and COs review of invoice.
-------
-10- Attachment A
b. Continue to require monthly submittal of invoice and progress
report review check sheets. By February 29, 1992, initiated
use of an invoice checklist by the Work Assignment Managers
(WSMs) to document their invoice reviews.
c. By March 1, 1992, a request for incurred cost audits will be
submitted for the TES contracts.
d. By March 31, 1992, and again by October 1, 1992, monitor
WAM workload under ARCS and TES.
e. Revise the WAM invoice review training to include guidance
on payment of item in "gray" areas of allowable. By May 30,
1992, conduct revised review training for WAMs.
f. By June 30, 1992, conduct spot check audits/reviews of the
contractors' documentation for specific monthly line item
charges for the ARCS and TES contracts.
The corrective action plan status update is reflected in FY92
CATS, No. 92-1 and next FY92 quarterly CATS update is
April 1992.
NOTE: This Data is based on audit reports since FY90 and Annual
Assurance Letters for FY87, FY88, FY89, FY90, and FY91.
-------
ATTACHMENT B
CONTRACTS SUMMARY
APRIL 1, 1992
CONTRACTOR
Roy F. Weston
Fuor-Daniel, Inc.
COM
CH2M Hill
Jacobs Engineering
Morrison Knudsen
Sverdrup Corp
URS Consultant
PRC
Metcalf & Eddy
PRC
Resource Applicat
Am Analyt Test Serve
Betz
PURPOSE
TYPE
SERVICE
AREA
N=NATIONAL
Z=ZONE
R=REGIONAL
DOLLAR
VALUE
N
O
T
E
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
CPAF/LOE
Keystone of TX
SW Lab of OK
SW Research of SA
ICF
Hewlett-Packard
Eniron & Ecology
CSC
Riedel
Lee Wilson & Assoc
Daniel T Serna
CADMUS
MRI
Tetra-Tech
Am Mgt Systems
SAIC
ICF
MRI
MRI
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
ARCS
TES 9
TES 10
RCRA Implement CPAF/LOE
TAT (8a)
CLP
CLP
CLP
CLP
CLP
CLP
ESAT
MAINTENANCE
TAT
TOSS ID/IQ
ERGS
Report Prep
Storeroom Ser FIXED PRICE
NPDES TECH SUPPLY ID/IQ
Streamline Proj
Coast Wtr Proj
Coast Wtr Proj
Coast Wtr Proj
Training
Training
CLEAN AIR ASST
ID/QI
ID/IQ
ID/IQ
FIXED PRICE
FIXED PRICE
LOE
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
N
N
N
N
N
N
N
N
N
R
Z
Z
Z
R
R
N
N
N
N
N
N
N
N
156,213,437 2
142,142,204 2
154,794,394 2
151,873,624 2
150,241,713 2
155,373,447 2
67,305,250 2
157,811,577 2
33,100,000 5
33,100,000 5
8,267,709 5
3,991,758 5
2,038,780 6
1,000,000 6
3,970,560 6
1,561,760 6
4,384,000 6
4,627,000 6
6,000,000 5
110,000 1
76,800,000 4
357,000,000 5
110,137,819 2
1,092,000 1
147,400 1
600,000 7
37,163 8
50,000 8
90,000 8
42,500 8
37,180 8
10,144 8
9,745 8
-------
-------
NOTES:
1. Dollar value shown is potential dollar value for the entire
contract.
2. Zone contract for Region 6-8; dollar value shown is total
potential dollar value.
3. Zone contract for Regions 5-7; dollar value shown is total
potential dollar value.
4. Zone contract for Regions 5-10; dollar value shown is total
potential dollar value.
5. National Contract; dollar value is potential dollar value for
the entire contract.
6. Contracts in contract lab program; dollar values are for
Region 6 activity only.
7. Dollar value reflects FY92, one work assignment only. WAM in
HQ, potential dollar value of total contract unknown to
Region 6.
8. Dollar value is for Region 6 work assignments under national
contract. Potential dollar value of total contract unknown to
Region 6.
Att»ch»*nt to CONTRACTS SUMMARY
-------
-------
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VII
726 MINNESOTA AVENUE
KANSAS CITY, KANSAS 66101
OFFICE OF
THE REGIONAL ADMINISTRATOR
MAR311992
SUBJECTi Contract Mana
PROMi Morris Kay
Regional
TOt William K. Reilly
Administrator
in response to your memorandum of March 10, 1992, I have
taken several steps to review the strengths and weaknesses of our
regional contract and project management efforts. On March 17,
1992, I conducted a one-half day meeting with all of ay regional
managers to assist in identifying specific contracting and
internal control problems. Based on the outcome of that meeting
and an independent analysis we began several months ago, we
developed a list of 11 basic problems (real and potential).
Attachment 1 lists these problems with corrective action plans
and planned due datea. Attachments 2 and 3 list all regional and
national contracts utilised by this region. The Office of
Policy and Management is continuing to analyze all of the
contracts utilized by this region and will be developing plans
for corrective action.
Our assessment of these contracts generally indicates that
more problems exist on national contracts than regional
contracts. We conclude that regional contracts may be better
managed because those persons using the contract are close to the
Contracting and Project Officers. Therefore, the contract user
has easier access to the people responsible for the contract.
I also want to assure you that we are following the guidance
and have met all of the requirements provided by Christian Holmes
In his February 28, 1992, memorandum. In this regard, I
appointed Susan C. Gordon, my Assistant Regional Administrator,
as our regional Senior Procurement Official.
RECYCLES*
-------
-2-
Region VII has always taken contract management very
seriously, as demonstrated by our requiring standard contract
Invoices and independent government cost estimates on our ARCS
Contracts as early as 1988. Last year, we began surveillance
reviews of the ARCS contractors' invoices. In August 1991, we
performed an in depth review and assessment of the CSC contract
and its use. As a result of that review, we expedited our
planned contract management training and implemented other
activities to reduce our contract vulnerabilities. In September
1991, we conducted an all employee mandatory training on
"Contract Management Awareness". This training session was video
taped and is required viewing for all new employees. In March
1992/ we issued regional directions to all employees in the form
of "Contract Management Guidelines" (Attachment 4).
I assure you that we are totally committed to all efforts to
improve quality -contract management.
Attachments
cc: Christian Holmes
-------
Attachment 1
RBOION VTI'S COKTRXCT XSSBflSMBNT
1. Insufficient
resources allocated
to properly manage
contracts
Senior staff will
examine feasibility of
reallocating existing
regional resources
3rd Qtr
TY 1992
2. Lack of contract
management knowledge
0 Office of Policy and
Management and tha
Office of Regional
Counsel conducted all
employee nContract
Management Awareness
Training11
0 New regional employees
are required to view the
"Contract Management
Awareness Training"
video
0 Office of Policy and
Management issued
Contract Management
Guidelines to all
regional employees.
These guidelines will
also be -issued to new
employees
0 Office of Policy and
Management and the
Office of Regional
Counsel will provide
refresher contract
management training for
all employees
0 Senior Procurement
Official will require
annual certification by
all regional employees
having contract
management authority
that they have met all
the requirements for
managing contracts
Completed
9/91
On-going
Completed
3/92
Annually
4th Qtr
Annually
4th Qtr
-------
3. Lack of contract
specific training
• Superfund Contracting
Office will provide
training to all regional
contract users
0 Superfund Contracting
Office will provide
appropriate assistance
on national contract*
9 Office of Policy and
Management requested
that PCMD provide
contract specific
training on all national
contracts
Semi-
annual ly
2nd t 4th
Qtrs
On-going
Completed
1/92
4. Insufficient
written guidance on
national contracts
0 Senior Procurement
Official will request
that PCMD issue guidance
on lines of authority on
national contracts.
0 Senior Procurement
Official will request
that PCMD keep regional
contract users apprised
on a timely basis of any
negotiated terms and
conditions which are not
specific in the national
contract or the
statement of work
• Superfund Contracting
Office will serve as a
point of contact for all
contract issues and will
distribute contract
interpretations to all
regional users
3rd Qtr
FY 1992
3rd Qtr
FY 1992
On-going
-------
s. Lack of contract
file and Delivery
Order file
documentation
e Superfund Contracting
Office will identify all
required documentation
in regional contract
specific training
0 Regional Internal
Control Coordinator or
designee will reviev
contract file
documentation as part of
the internal control
proceee
Superfund Contracting
Office established zone
administrative
procedures for adequate
file documentation on
regional contracts
On-going
Annually
2nd Qtr
Completed
1991
6. Inadequate
Delivery Order
Statements of Work
Senior Procurement
Official will require
technical reviev of
statements of Work by
one level above the
requestor
Superfund contracting
Office will review all
Delivery Orders prior to
submission to ordering
offices in Headquarters
On-going
on-going
-------
7. some work
performed outside
Statement of Work
• Superfund Contracting
Office will obtain and
maintain copies of all
national contracts and
will review all new
requests to insure that
work is within scope of
contract
• Superfund Contracting
Office reviews all
regional contract
delivery orders prior
to issuance;
documentation of review
is now being required
0 Regional Internal
Control Coordinator or
designee will review
contract file
documentation as part of
the internal control
process
3rd Qtr
FY 1992 £
On-going
On-going
Annually
2nd Qtr
8. Lack of adequate
invoice review on
national Delivery
Orders
0 Senior Procurement
Official will recommend
to OARM that all
national delivery orders
bs reissued as regional
delivery orders
• Senior Procurement
Official will require
Delivery Order Project
Officers to follow
established regional
guidelines for invoice
reviews
3rd Qtr
FY 1992
4th Qtr
FY 1992
-------
9. Inadequate
independent
government cost
estimates
0 super-fund contracting
Office issued specific
guidelines to the zone
for preparing cost
estimates for ARCS
contracts
0 Superfund Contracting
Office will issue
regional guidelines for
preparing cost estimates
on all EPA contracts
Completed
3/92
3rd Qtr
FY 1992
10. Inadequate
property
accountability
• Senior Procurement
Official will recommend
to OARM that the
Contract Property
Administration
responsibility for
regional contracts be
delegated to the region
3rd Qtr
FY 1992
11. Perception of
personal services and
conflict of interest
0 Office of Policy and
Management and the
Office of Regional
Counsel provided all
employee mandatory
training on contract
management
0 Office of Policy and
Management and the
Office of Regional
Counsel will conduct
contract management
refresher training
0 Regional Internal
Control Coordinator or
deaignee will review
contract performance as
part of the internal
control process
Completed
9/91
Annually
4th Qtr
Annually
2nd Qtr
-------
CONTRACT* OVER $25,000 XANAOED >Y REGION VIZ
' ^~'f^iimM^^W&-^^l
si,' • ^j^SS^S^^^
CDM-FPC
68-W9-0021
Sverdrup Corp
68-W9-0032
CH2M Hill
68-W8-0112
Jacobs Engr
68-W8-0122
Riedel Env.
68-W1-0035
CWM
68-80-7005
Crown Const.
68-01-7459
Tappan Assoc.
68-W1-7001
68-01-7462*
NIT, Inc.
68-D2-0036
SRI
68-D1-015
i|^yp? ^^i^M^mM^^ •^^^•^(^h4llk^m
ARCS
ARCS
ARCS
ARCS
ERCS
- Remedial Activities
- Remedial Activities
- Remedial Activities
- Remedial Activities
- Removal Activities
Transportation £ Disposal
Dioxin Storage Buildings
Architect-Engineer Services
Dioxin Excavation
RECAP
RECAP
- Collection & Analysis
- Collection & Analysis
Page 1 of 1
-------
Attachment 3
CONTRACTS MANAGED BY BPA HEADQUARTERS
' : aiiwl? ' ibllf *•' *|j|||':!" ; ^
§;!^%^^HKiMiK
Health Systems
68-01-0004
ManTech
68-C8-0006
PRC Env
68-W9-0006
Metcalf « Eddy
68-W9-0007
CADMUS Group
68-C9-009
Flour Daniel
68-W9-0013
Roy F. Weston
68-W9-0015
MRI
6B-WO-0015
ICF
68-WO-0024
MR Env
6B-W9-0025
Nancy Low
68-WO-0030
E & E
68-WO-0037
AMS
68-W9-0038
AMS
68-W9-0039
PRC Env.
68-W9-0041
CSC
S8-WO-0043
^l^&fri !•!&•*> > ' 't^Mjjjt1 : *^Vv ;'|^i 'ityW&l *&&& : •'. -^ \ •
Develop pollution prevention material
Provide napping £ ecological data
TBS 9 - Enforcement support
TES 10 - Enforcement Support
Water «nf orcemant and permit*
ARCS - Remedial activities
ARCS - Remedial activities
Prevent and detect leake for UST*
Aasist in implementing UST programs
ARCS - Remedial activities
Market research and analysis
TAT - Removal activities
General Analysis and Support Services
ADP Support Services
RCRA permit & subtitle D support
TOSS - Computer & management support
-------
• ft3B*Sfi&S$:
Lockheed Engr
68-CO-0050
LAI
68-W9-0052
URS
68-W9-0053
SAIC
68-C8-0066
Cambridge
68-CO-0073
ICP
68-W9-0082
Temple, Barker
68-CO-0090
Univ of Neb
68-DO-0094
Pechan, Inc.
68*00-0120
Alliance Tech
6B-DO-0121
SAIC, Inc.
68-DO-0122
MRI
68-DO-0123
PES, Inc.
68-DO-0124
Radian, Inc.
68-DO-0125
ICF
68-D1-0135
Univ of Iowa
68-D1-0086
j [.;:;. :..:::'j::i:; ;;:;:>?;j;-yv •;.,..!;S: : yp*$ • • jMJS J^M^j-i^f-?' .•:*•> jif { '• /.f**';; i.},
Provide RCRA aerial photographic data
Records information management support
ARCS - Remedial activities
Water enforcement ft permit
Technical support for air pollution
Support to UST & LUST program*
Development of SRF programs
Pesticide applicator training
Regulatory plan assistance
Aarometric monitoring
Technical support for air pollution
Regulatory plan assistance
Technical support for air pollution
Technical support for air pollution
ESAT - Analytical services
CLP - Chemical analyses
-------
Attachment 4
March 1, 1992
REGION VII CONTRACT MANAGEMENT GUIDELINES
Working "Relationships
EPA employees are expected to be impartial and objective in their dealings with contractors.
Employees should avoid any situation which gives even the appearance of favoritism or conflict
Of interest. This is not to say that EPA employees cannot be cordial in their working
relationships with contractors, but the relationship should always be a business-like, arm's length
relationship. Contracting Officers, Project Officers, Work Assignment Managers, and other
EPA employees having direct control over contractors should not socialize with contractor
personnel,
Identification of Contractors
All contractors working in EPA space should wear clearly visible identification badges showing
that they are contractors. Contractors should display their company name on their desk name
plates. Contractor work space should have signage displaying the company name. Contractors
should always clearly identify themselves as contractors in any situation where it might be
assumed that they were representing EPA (such as when they answer the telephone or are
involved in meetings).
Contractor Workspace
Every effort should be made to house contractors in separate space from EPA employees, in
those cases where this is not possible, contractors should be physically grouped together in their
own work area and be clearly identified as contractors.
Awards/Recognition
EPA will not present awards or other formal recognition including letters of appreciation and
commendation to contractor staff. EPA employees may provide information on individual
contractor performance to contractor site managers.
Attendance at EPA Functions and Meetings
Contractors are not allowed to attend EPA meetings, retreats, social events, and training sessions
unless their presence is required to perform work authorized under the contract. Contractors
may attend "Brown Bag" presentations of general interest as long as they do not charge time to
the government for their attendance time. Again, contractors should not routinely attend EPA
staff meetings. Contractor personnel should only attend meetings for specific work authorized
under the contract. This does not prohibit regular meetings between EPA staff and contractors
to review work products.
-------
REGION VII CONTRACT MANAGEMENT GUIDELINES
Training
Contractors are expected to have the skills they require to perform their job. Therefore, EPA
will not provide training which is commercially available (This would include training such as
Total Quality and common word processing packages). EPA can provide training in those
instances where the training is somehow unique to EPA's environment or required for specific
performance under the contract and if there is no direct charge to the contract.
Supendsion/Worlc Assignment
EPA employees can not supervise contract employees. Contract employees are supervised by
contract supervisors. EPA employees may share information with contractors to perform the
required work. Only certain specially trained government employees, such as Delivery Order
Project Officers or Work Assignment Managers, may assign work to contractors. Work
assignment must fall within the scope of the contract as described in the statement of work.
Even in those cases where EPA personnel are authorized to assign work under a contract, they
can not supervise the contractor staff.
Personal Services
Personal Services contracts are noj allowed. A personal services relationship exists when a
contractor is treated essentially as another EPA employee. There are 6 elements described in
the Federal Acquisition Regulation which characterize a personal services relationship: (1)
Performance on site. (2) Principal tools and equipment furnished by the Government. (3)
Services are applied directly to the integral effort of agencies or an organizational subpart in
furtherance of assigned function or mission. (4) Comparable services, meeting comparable
needs, are performed in the same or similar agencies using civil service personnel. (5) The need
for the type of service provided can reasonably be expected to last beyond 1 year. (6) The
inherent nature of the service, or the manner in which it Is provided, reasonably requires
directly or indirectly, Government direction or supervision of contractor employees in order
to--(i) Adequately protect the Government's interest; (ii) Retain control of the function involved;
or (iii) Retain full personal responsibility for the function supported in a duly authorized Federal
officer or employee. All of these elements should be avoided, but the 6th element is critical.
Government supervision must be avoided. Contractors may not perform work which is
considered inherently Governmental.
-------
REGION VII CONTRACT MANAGEMENT GUIDELINES
Positioq Descriptions and Perfonpance Standards
EPA employees who are authorized to provide technical direction and accept deliverable* from
contractors must have specific language in their position descriptions and performance standards
describing these dudes.
Raauired TmJninp for EPA
Every EPA employee in Region vn is required to attend Region VU's'Contract Management
Awareness Training. New employees are given this training as part of the New Employee
Orientation process. Any employee who has not attended this training should arrange to attend
one of the regularly scheduled classes or view the training videotape which is available in the
PEAC training center.
Questions/Contract Management Reference Material
Questions on contract management should be directed to the Comptroller Branch in Region VH
or the Project Officer or Contracting Officer. Contracting information and guidance may also
be found in the following documents: Federal Acquisition Regulation (FAR), Environmental
Protection Agency Acquisition Regulation (EPAAR), EPA Contracts Management Manual, and
the Acquisition Handbook.
Audits
Requests by any office for Region vn contract management information in association with an
audit or inspection should be referred to the Region vn Comptroller Branch. All Regional audit
activity is coordinated through the Comptroller Branch.
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VII
726 MINNESOTA AVENUE
KANSAS CITY, KANSAS 66101
OFFICE OF
THE REGNAL ADMIVSTRA'
APR 14 1992
MEMORANDUM
SUBJECT: Follow-up to the AdmiALpta?ator's March 10, 1992,
Request for a Review/or/EPA's Contracts Management
FROM: Morris Kay/], • !/ i
Regional AtljjiiniJstrator
TO: Christian R. Holmes
Acting Assistant Administrator
In response to your memorandum of March 31, 1992, we have
made an assessment of all present or potential problems falling
within our purview related to contract and program management.
In our memorandum to the Administrator dated March 31, we
identified 11 basic problems with corrective action plans and
planned due dates. Attachment 1 is a copy of the listing.
Attachments 2, 3, and 4 address all of the items requested by
your memorandum.
We have implemented measures to strengthen our internal
controls and are developing standardized internal control
documentation to identify event cycles, control objectives and
control techniques common to contract management. This
documentation will become a part of each assessable unit's system
of internal controls and can be modified to accommodate any
unique provisions of a particular contract.
We have also established a prototype corrective action
tracking system for audit reports and internal and external
reviews. This tracking system is being modified to monitor
existing and potential contract management weaknesses applicable
to individual contracts. The modified system will also identify
actions necessary to correct these weaknesses and track the
implementation of the actions.
We are totally committed to efforts to improve quality
contract management activities.
RECYCLE .*•
-------
-------
Attachment 1
REGION VII'S CONTRACT ASSESSMENT
POTENTIAL PROBLEMS
CORRECTIVE ACTION
PLAN
ACTION
DATE
1. Insufficient
resources allocated
to properly manage
contracts
0 Senior staff will
examine feasibility of
reallocating existing
regional resources
3rd Qtr
FY 1992
2. Lack of contract
management knowledge
0 Office of Policy and
Management and the
Office of Regional
Counsel conducted all
employee "Contract
Management Awareness
Training"
0 New regional employees
are required to view the
"Contract Management
Awareness Training"
video
0 Office of Policy and
Management issued
Contract Management
Guidelines to all
regional employees.
These guidelines will
also be issued to new
employees
0 Office of Policy and
Management and the
Office of Regional
Counsel will provide
refresher contract
management training for
all employees
0 Senior Procurement
Official will require
annual certification by
all regional employees
having contract
management authority
that they have met all
the requirements for
managing contracts
Completed
9/91
On-going
Completed
3/92
Annually
4th Qtr
Annually
4th Qtr
-------
POTENTIAL PROBLEMS
CORRECTIVE ACTION
. * PLAN ..
ACTION DDE
DATE
3. Lack of contract
specific training
0 Superfund Contracting
Office will provide
training to all regional
contract users
0 Superfund Contracting
Office will provide
appropriate assistance
on national contracts
0 Office of Policy and
Management requested
that PCMD provide
contract specific
training on all national
contracts
Semi-
annual ly
2nd & 4th
Qtrs
On-going
Completed
1/92
4. Insufficient
written guidance on
national contracts
0 Senior Procurement
Official will request
that PCMD issue guidance
on lines of authority on
national contracts.
0 Senior Procurement
Official will request
that PCMD keep regional
contract users apprised
on a timely basis of any
negotiated terms and
conditions which are not
specific in the national
contract or the
statement of work
0 Superfund Contracting
Office will serve as a
point of contact for all
contract issues and will
distribute contract
interpretations to all
regional users
3rd Qtr
FY 1992
3rd Qtr
FY 1992
On-going
-------
POTENTIAL PROBLEMS
CORRECTIVE ACTION
PLAM
ACTION
DATE
5. Lack of contract
file and Delivery
Order file
documentat i on
0 Superfund Contracting
Office will identify all
required documentation
in regional contract
specific training
0 Regional Internal
Control Coordinator or
designee will review
contract file
documentation as part of
the internal control
process
0 Superfund Contracting
Office established zone
administrative
procedures for adequate
file documentation on
regional contracts
On-going
Annually
2nd Qtr
Completed
1991
6. Inadequate
Delivery Order
Statements of Work
0 Senior Procurement
Official will require
technical review of
Statements of Work by
one level above the
requestor
0 Superfund Contracting
Office will review all
Delivery Orders prior to
submission to ordering
offices in Headquarters
On-going
On-going
-------
POMSNTIAI, PROBLEMS
CORRECTIVE
ACTION
DATE
7. Some work
performed outside
Statement of Work
0 Superfund Contracting
Office will obtain and
maintain copies of all
national contracts and
will review all new
requests to insure that
work is within scope of
contract
0 Superfund Contracting
Office reviews all
regional contract
delivery orders prior
to issuance;
documentation of review
is now being required
0 Regional Internal
Control Coordinator or
designee will review
contract file
documentation as part of
the internal control
process
3rd Qtr
FY 1992 &
On-going
On-going
Annually
2nd Qtr
8. Lack of adequate
invoice review on
national Delivery
Orders
0 Senior Procurement
Official will recommend
to OARM that all
national delivery orders
be reissued as regional
delivery orders
0 Senior Procurement
Official will require
Delivery Order Project
Officers to follow
established regional
guidelines for invoice
reviews
3rd Qtr
FY 1992
4th Qtr
FY 1992
-------
POTENTIAL PROBLEMS
CORRECTIVE *Ct$Qir
ACTION DUE
DATE
9. Inadequate
independent
government cost
estimates
0 Superfund Contracting
Office issued specific
guidelines to the zone
for preparing cost
estimates for ARCS
contracts
0 Superfund Contracting
Office will issue
regional guidelines for
preparing cost estimates
on all EPA contracts
Completed
3/92
3rd Qtr
FY 1992
10. Inadequate
property
accountabi1ity
0 Senior Procurement
Official will recommend
to OARM that the
Contract Property
Administration
responsibility for
regional contracts be
delegated to the region
3rd Qtr
FY 1992
11. Perception of
personal services and
conflict of interest
0 Office of Policy and
Management and the
Office of Regional
Counsel provided all
employee mandatory
training on contract
management
0 Office of Policy and
Management and the
Office of Regional
Counsel will conduct
contract management
refresher training
0 Regional Internal
Control Coordinator or
designee will review
contract performance as
part of the internal
control process
Completed
9/91
Annually
4th Qtr
Annually
2nd Qtr
-------
-------
Attachment 2
PROGRAM MANAGEMENT/OTHER AUDIT VULNERABILITIES
VULNERABILITIES
CORRECTIVE ACTION
TAKEN
IMPLEMENTATION
DATE
1. No system for
accounting for incoming
referrals in regional
Section 404 Wetlands
program.
ENRV developed an
accounting system.
Completed
4th Qtr
FY 1991
2. Section 404 permit
data base contains
inaccurate and
incomplete data.
ENRV will develop
Data quality and
consistency
controls for their
database.
1st Qtr
FY 1993
3. No system to assure
the Section 404 permit
files contain a
complete administrative
record.
ENRV has
standardized the
indexing procedure.
Completed
4th Qtr
FY 1991
4. No procedures to
assure that PRP
baseline and follow-up
searches start timely.
WSTM will establish
control techniques
to monitor search
initiations.
Completed
1st Qtr
FY 1992
5. Attorney should
document PRP search
reviews.
WSTM developed a
PRP Search Work
Assignment Close
Out Request form
which documents the
review of the civil
investigator,
attorney and
Regional Project
Manager.
Completed
2nd Qtr
FY 1992
6. Establish controls
to assure that the PRP
search information in
the CERCLIS data base
is accurate and updated
timely.
WSTM assigned new
Environmental
Protection
Specialists to
provide timely and
accurate CERCLIS
data entry.
Completed
2nd Qtr
FY 1992
7. Inadequate testing
of internal controls.
WSTM will test
internal controls.
4th Qtr
FY 1992
-------
8. Inadequate internal
control objectives and
techniques for PRP
search program.
WSTM will develop
PRP search internal
control objectives
and techniques.
WSTM will test
internal control
objectives and
techniques.
4th Qtr
FY 1992
4th Qtr
FY 1993
9. Management Control
Plan did not include
PRP search initiatives.
WSTM will expand
Management Control
Plan to include
internal control
review and/or
alternate internal
control reviews of
the PRP search
program.
4th Qtr
FY 1992
10. Limited internal
control training for
Regional Managers.
Regional Internal
Control Coordinator
will provide
training to all
Region VII
managers.
4th Qtr
FY 1992
REGION VII HAS NOT PERFORMED AN INTERNAL CONTROL REVIEW IN THE LAST
FIVE YEARS. ALL REVIEWS HAVE BEEN ALTERNATE INTERNAL CONTROL
REVIEWS.
-------
Attachment 3
CONTRACTS OVER $25,000 MANAGED BY REGION VH
CONTRACTOR
NAME & NUMBER
CDM-FPC
68-W9-0021
Sverdrup Corp
68-W9-0032
CH2M Hill
68-W8-0112
Jacobs Engr
68-W8-0122
Riedel Env
68-W1-0035
Chem Waste
68-SO-7005
Crown Const
68-01-7459
Tappan Assoc
68-W2-7001
Riedel Env
68-01-7462
NFT
68-D2-0036
SRI
68-D1-0015
CONTRACT TYPE
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
Indefinite
Delivery /Quantity
w/ Fixed Unit
Prices
Indefinite
Delivery /Quantity
w/ Fixed Unit
Prices
Indefinite
De 1 i very / Quant i ty
w/ Fixed Unit
Prices
Indefinite
Delivery /Quantity
w/Fixed Unit
Prices
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
CONTRACT
VALUE
$154,794,394
$ 67,305,250
$151,873,624
$150,241,713
$114,012,530
$ 1,247,135
$ 5,645,417
$ 475,000
$ 38,895,662
$ 3,298,574
$ 28,195,923
CONTRACT
PURPOSE
ARCS -
Remedial
Activities
ARCS -
Remedial
Activities
ARCS -
Remedial
Activities
ARCS -
Remedial
Activities
ERGS -
Removal
Activities
Transporta-
tion and
Disposal
Construct ion
of Dioxin
Storage
Buildings
Architect-
Engineer
Design
Services
Dioxin
Excavation
in the State
of Missouri
Collection
and Analysis
Collection
and Analysis
-------
Attachment 4
NUMBER OF PROCUREMENT PERSONNEL IN REGION VH
PROCUREMENT
PERSONNEL
Contracting Officers
Contract Specialists
Project Officers
Reg i ona 1 / Deputy
Project Officers
Delivery Order
Project Officers
Work Assignment
Managers
On-Scene-
Coordinators
TOTAL
CONTRACTS MANAGED
BY REGION VII
3
3
4
1
28
15
54
CONTRACTS MANAGED
BY EPA
HEADQUARTERS/RTF/
CINCINNATI
6
8
37
51
NOTE: Some Work Assignment Managers have work assignments for
contracts managed by Region VII and by EPA Headquarters.
-------
"•K UNITED STATES ENVIRONMENTAL PROTECTION AGWCY
APR 141992
MEMORAMDPM
BUBJICT: Follow-up to the Administrator'* March 10, 1992,
Request for a Review of KPA'S Contracts Management
FROMi Morris Kay
Regional Administrator
TOt Christian R. Bolnes
Acting Assistant Administrator
in response to your memorandum of March 31, 1992, we have
made an assessment of all present or potential problems falling
within our purview related to contract and program management.
In our memorandum to the Administrator dated March 31, we
identified 11 basic problems with corrective action plans and
planned due dates. Attachment 1 is a copy of the listing.
Attachments 2, 3, and 4 address all of the items requested by
your memorandum.
We have implemented measures to strengthen our internal
controls and are developing standardized internal control
documentation to identify event cycles, control objectives and
control techniques common to contract management. This
documentation will become a part of each assessable unit's system
of internal controls and can be modified to accommodate any
unique provisions of a particular contract.
We have also established a prototype corrective action
tracking system for audit reports and internal and external
reviews. This tracking system is being modified to monitor
existing and potential contract management weaknesses applicable
to individual contracts. The modified system will also identify
actions necessary to correct these weaknesses and track the
implementation of the actions,
We are totally committed to efforts to improve quality
contract management activities.
CkRNAME k 1
3ATe
BI»A r». )»0c:
ei;
OFFICIAL FILE COPf
-------
-------
Attachment 1
KZOION VII'a COHTBACT AMESSXENT
1. Insufficient
resources allocated
to properly manage
contracts
Sanior staff vill
examine faaaibility of
raallocating axiating
regional reaourcaa
3rd Qtr
FY 1992
2. Lack of contract
management knowledge
8 Offica of Policy and
Xanaganant and the
Office of Regional
Counael conducted all
employee "Contract
Kanageaent Awareness
Training11 v,,-.
' New regional employees
are required to view the
"Contract Management
Awareness Training"
video
• Office of Policy and
Management iaaued
Contract Management
Guidelines to all
regional employees.
These guidelines will
also be issued to new
employees
• ocfioe of Policy and
Management and the
Office of Regional
Counsel will provide
refresher contract
management training for
all employees
• Senior Procurement
Official vill require
annual certification by
all regional employees
having contract
management authority
that they have met all
the requirements for
managing contracts
Completed
9/91
On-going
Completed
3/92
Annually
4th Qtr
Annually
4th Qtr
-------
3. Lack of contract
specific training
Superfund Contracting
Office will provide
training to all regional
contract uaers
• Superfund Contracting
Office will provide
appropriate assistance
on national contract*
• Office of Policy and .
Management requeeted
that PCMD provide
contract *pecific
training on all national
contract* fc"'
Semi-
annual ly
2nd & 4th
Qtr*
on-going
Completed
1/92
4. Insufficient
written guidance on
national contract*
• Senior Procurement
Official will regueet
that PCMD issue guidance
on line* of authority on
national contract*.
• Senior Procurement
official will request
that PCMD keep regional
contract u*er« apprised
on a timely basic of any
negotiated terms and
condition* which are not
specific in the national
contract cr the
statement of work
• Superfund Contracting
Office will serve a* a
point of contact for all
contract issue* and will
distribute contract
interpretation* to all
regional ucer*
3rd Qtr
FY 1992
3rd Qtr
FY 1992
On-going
-------
S. Lack of contract
file and Delivery
order file
documentation
Superfund Contracting
Office will identify all
required documentation
in regional contract
specific training
• Regional Internal
Control Coordinator or
designee will review
contract file
documentation ac part of.
the internal control
process
• superfund contracting
Office established zone"
administrative
procedures for adequate
file documentation on
regional contracts
On-going
Annually
2nd Qtr
Completed
1991
6. Inadequate
Delivery Order
Statements of Work
• Senior Procurement
Official will require
technical review of
Statements of Work by
one level above the
requestor
* Superfund Contracting
office will review all
Delivery orders prior to
submission to ordering
offices in Headquarters
On-going
On-going
-------
7. Some work
performed outside
Statement of Work
• Superfund Contracting
Office will obtain and
maintain copiee of all
national contract* and
will review all new
requests to insure that
work i» within scope of
contract
• Superfund Contracting
office review* all ,
regional contract
delivery ordera prior
to issuance;
documentation of review
is now being required
• Regional Internal
Control coordinator or
designee will review
contract file
documentation as part of
the internal control
process
3rd Qtr
FIT 1992 &
On-going
On-going
Annually
2nd Qtr
fi. Lack of adequate
invoice review on
national Delivery
Orders
• Senior Procurement
Official will recommend
to OARM that all
national delivery orders
be reissued as regional
delivery orders
• senior Procurement
official will require
Delivery order Project
Officers to follow
established regional
guidelines for invoice
reviews
3rd Qtr
ry 1992
4th Qtr
FY 1992
-------
9. Inadequate
independent
government cost
estimates
Superfund Contracting
Office issued specific
guideline* to the zone
for preparing cost
estimate* for ARCS
contract*
0 Superfund Contracting
Office will issue
regional guideline* for
preparing cost estimates
on all EPA contract*
Completed
3/92
3rd Qtr
FV 1992
10. Inadequate
property
accountability
• Senior Procurement
official will recommend
to OARM that the
Contract Property
Adninictration
responsibility for
regional contract* be
delegated to the region
3rd Qtr
FY 1992
11. Perception of
personal service* and
conflict of interest
• Office of Policy and
Management and the
Office of Regional
Counsel provided all
employee mandatory
training en contract
management
• Office of Policy and
Management and the
office of Regional
Counsel will conduct
contract management
refrevher training
* Regional Internal
Control Coordinator or
designee will review
contract performance as
part of the internal
control process
Completed
9/91
Annually
4th Qtr
Annually
2nd Qtr
-------
Attachment 2
PROGRAM MANAGEMENT/OTHER AUDIT VULNERABILITIES
;.:;.: •.•,!!*<**•
1, No system for
accounting for incoming
re terrain in regional
Section 404 Wetlands
program.
ENFV developed an
accounting system.
Completed
4th Qtr
FY 1991
2. Section 404 permit
data base contains
inaccurate and
incomplete data.
ENRV will develop
Data quality and
consistency
controls for their
database.
1st Qtr
FY 1993
3. Ho system to assure
the Section 404 permit
files contain a
complete administrative
record .
ENRV has
standardized the
indexing procedure.
Completed
4th Qtr
rc 1991
4. No procedures to
assure that PRP
baseline and follow-up
searches start timely.
WSTM will establish
control techniques
to monitor search
initiations .
Completed
1st Qtr
FY 1992
5. Attorney should
document PRP search
reviews.
WSTM developed a
PRP Search Work
Assignment Close
out Request form '
which documents the
review of the civil
investigator ,
attorney and
Regional Project
Manager.
Completed
2nd Qtr
FY 1992
6. Establish controls
to assure that the PRP
search information in
the CZRCLXS data base
is accurate and updated
WSTM assigned new
Environmental
Protection
Specialists to
provide timely and
accurate CERCLIS
data entry.
Completed
2nd Qtr
FY 1992
7. Inadequate testing
of internal controls.
NSTM will test
internal controls.
4th Qtr
FY 1992
-------
8. inadequate internal
control objective* and
techniques for PHP
search program.
WSTM will develop
PRP search internal
control objectives
and techniques.
WSTM will test
internal control
objectives and
techniques.
4th Qtr
FY 1992
4th Qtr
FY 1993
9. Management Control
Plan did not include
PRP search initiatives.
WSTM will expand
Management control
Plan to include
internal control
review and/or
alternate internal
control reviews of
the PRP search
program.
4th Qtr
FVT 1992
10. Limited internal
control training for
Regional Managers.
Regional Internal
Control coordinator
will provide
training to all
Region VIZ
managers.
4th Qtr
FY 1992
REGION VIZ HAS KOT PERTORKBD AN INTERNAL CONTROL REVIEW XH THE LAST
FIVX YEARS. ALL REVIEWS HAVE BEEN ALTERNATE INTERNAL CONTROL
REVIEWS.
-------
Attachment 3
CONTRACTS OVER $25,000 MANAGED BY REGION
$$»y;.sS»v;.." \* s^*f f-v£.f: ji*ji
:||jcearaBAqi;di!f
|KAX^*nnfflB*f
CDM-FPC
68-W9-0021
Sverdrup Corp
68-W9-0032
CR2K Hill
68-W8-0112
Jacobs Engr
68-W8-0122
Riedel Env
68-W1-0035
Chen Waste
68-SO-7005
Crown const
68-01-7459
Tappan Assoc
68-W2-7001
Riedel Znv
68-01-7462
NFT
68-D2-0036
SRI
66-D1-0015
ft*^Sf'W*i;HV^-;!2i:;i .?;(%?
^fco*mctt**pi.if
^fRkv^i^tiSfiJiPI^I^-'iSvS^i;
^j^llll^^^l^SS^^
Cost R«inbur»en*nt
Level of Effort
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
Cost Reimbursement
Level or Effort
indefinite
Del i very/ Quant i ty
w/ Fixed Unit
Prices
indefinite
Delivery/Quantity
w/ Fixed Dnit
Prices
Indefinite
Delivery/Quantity
vr/ Fixed Unit
Prices
Indefinite
Delivery/Quantity
v/ Fixed Unit
Prices
Cost Re inbur semen t
Level of Effort
Cose Reimbursement
Level of Effort
Cost Reimbursement
Level of Effort
:*':«• r' •".-•i^*i. %:-•)•»":• jJ/Aifii
^•comMmmi'
yw&tf:!*&-&iw%m
$154,794,394
$ 67,305,250
i
$151,873,624
• x.-..
$150,241,713
$114,012,530
$ 1,247,135
$ 5,645,417
$ 475,000
$ 38,895,662
$ 3,298,574
$ 28,195,923
t^'TfVKfOBt^^
ite*P^^^«y;wr
ARCS -
Remedial
Activities
ARCS -
Remedial
Activities
ARCS -
Remedial
Activities
ARCS -
Remedial
Activities
ERC5 -
Removal
Activities
Transporta-
tion and
Disposal
Construction
of Dioxin
Storage
Buildings
Architsct-
Engineer
Design
Services
Dioxin
Excavation
in the state
of Missouri
Collection
and Analysis
Collection
and Analysis
-------
Attachment 4
NUMBER OF PROCUREMENT PERSONNEL IN REGION VH
i!iS-«iaiE
.,, ..
CONTRXCTfl
.'--'."-
"i CONTRACTS i
Contracting Officars
Contract Spacialiets
Project Officers
Regional/Daputy
Project officera
Delivery Order
Project Officers
Work As»ignan*nt
Managers
28
37
On-Scene-
coordinatora
15
NOTE: SOB* work Assignment Managers have vorlc a»slgnin«nts for
contract* aaaagad by Region VII and by EPA Headquarters.
-------
-------
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
999 18th STREET - SUITE 500
DENVER. COLORADO 80202-2466
Mtt 26
Ref: 8PM-ARA
MEMORANDUM
TO: William K. Reilly
Administrator
FROM: Jack W. McGraw
Acting Regional Admii«.strator
• V
SUBJECT: Contracts Management Review
This responds to your March 12, 1992, memorandum, same
subject. I am attaching Region VIII 's Contracts Management
Review (Attachment 1) and the action plans we have developed
to improve contract management practices.
As a result of this review and other activities underway, I
have already taken the following actions to strengthen contracts
management in Region VIII:
1. Appointed a Senior Procurement Officer, the Acting
Assistant Regional Administrator for Policy and
Management, Paul Q. Riederer.
2 . Imposed a "freeze" on contract hiring so that no new
additional hiring will occur and no replacement hiring
will occur until each position has been reviewed on a
case -by- case basis to ensure adherence to procurement
and contract management guidelines.
3 . 9ftcTUn making a clear distinction between contractors
and EPA staff by providing separate, distinctive
identification badges for contractors and installing
signage in most instances, clearly identifying each
contract work station as such.
4 . Published new Contract Management Guidelines
(Attachment 2) for EPA Region VIII which consolidate
IG guidelines from several recent major audits.
Specifically, these guidelines address: working
relationships, identification of contractors,
contractor workspace, EPA- furnished property,
awards /recognitions, training, attendance at EPA
functions, proper supervision, etc.
5 . Conducted approximately 500 staff hours of information
sessions and awareness training including senior staff
-------
briefings, meetings with DOPOs, WAMs, etc., and on-site
contract staff, to announce clearly that Region VIII is
making changes quickly and we expect cooperation and
improvement.
6. Established a Contracts Management Review Taak Force
composed of the ARA and key procurement staff in the
Region. It is their job—under the direction of the
ARA--to complete all necessary reviews and action
plans, and to implement a "continuous improvement"
approach to improve contracts management in Region
VIII.
7. Developed detailed workplans (Attachments 3 and 4) to
ensure prompt follow-through actions to address issues
raised in the IG's audit of the CSC contract audit, the
ARCS contract audit and other vulnerable areas revealed
by our own analysis.
8. Received a- proposal from the ARA to reorganize the
Policy and Management Division, similar to OARM's
recent reorganization, to emphasize senior leadership
for contract management and to establish a direct line
of authority from me, through the ARA, to all Regional
staff conducting procurement and contracting
activities.
I can personally assure you that these actions have already
begun to constitute a "new culture" of contracts management in
Region VIII. I look forward to discussing these and other
important issues with you at our meeting on April 2-3. If you
need further information, please contact me or our Senior
Procurement Officer, Paul Riederer, at FTS 330-1603.
Attachments
cc: Christian Holmes
David O'Connor
Kerry Clough
-------
Attachment 1
CONTRACTS MANAGEMENT REVIEW
EPA REGION VIII
Senior Procurement Officer: Paul Q. Riederer,
Acting ARA
Senior Management Analyst: Robyn McKenry
Date: March 26, 1992
Throughout the month of February, interviews were conducted to
determine the current state of contracts management practices and
to identify potential management vulnerability of our contracts.
Our emphasis was on those contracts which employ non-Government
workers on site in our Regional office. A total of 51 interviews
were held with Delivery Order Project Officers (DOPOs), Project
Officers (POs), site managers, supervisors and contract staff by
a task force of six program analysts.
ON-SITE CONTRACTS
A matrix showing the contracts where EPA Region VIII has
"on-site" or "collocated" workers is attached (Attachment A).
EPA Region VIII has procured five (5) contracts that employ
90 non-Government workers and a grant for 59 AARPs/SEES for an
approximate annual dollar value of $6,120,000. The contractors
are: Computer Sciences Corporation (CSC), Bayaud Industries
(NISH), ICF Technology Inc. (ESAT), Labat-Anderson Inc.
(Superfund), and Labat-Anderson Inc. (RCRA). Although different
statutes and/or guidelines exist for NISH and AARPs/SEES
contracts, they were included in this review to ascertain our
vulnerability in the Region, for all non-Government workers on
site.
Observations (On-site Contracts)
Based on these 51 interviews, we concluded that in all
five contracts Region VIII may be vulnerable to: supervision
of contractors; commingling of contractors with EPA staff;
and contractors performing duties similar to EPA staff
(Attachment B). We recognized a continued need to educate the
Regional staff on contracts management, specifically with regard
to restrictions on supervision of contract workers; stricter
definitions of "technical advise" would be beneficial.
The tendency to supervise and interact inappropriately with
contractors seems to directly relate to the proximity of the
contractors to the EPA staff. Where contractors are commingled
there is a greater likelihood of EPA guidance being offered.
Conversely, the more detailed the written direction (SOW, TIDs .:
WADs) the greater the probability that work can progress
much EPA communication with the contractors.
-------
-------
Perhaps the most revealing information gathered during the
interviews was the outstanding manner in which the ESAT contract
for GIS is being administered. Without exception each
interviewer with ESAT interviews mentioned at the closeout
session the fact that they were impressed with the management of
the ESAT contract. The highlights of the superior way in which
the GIS portion of the ESAT contract is managed are:
1. All work is assigned and monitored through Technical
Instruction Documents (TIDs), Work Assignment Directives
(WADs) and a Statement of Work (SOW) . These documents must
travel through the Regional Project Officer (RPO) for
approval before being passed on to the ESAT Team Manager.
2. No supervision is provided by RPO or any other EPA
employee.
3. These workers are located in proximity but clearly separate
and distinct from EPA staff.
4. Without a doubt ESAT folks (on all levels) were the best
educated with regard to the rules and regulations governing
contract workers.
Recommendations (On-site Contracts)
Based on the 51 interviews and the feedback from the
interviewers the following recommendations for the management of
on-site contract workers emerged:
1. Wherever feasible, physically locate contractor workspaces
separate from the EPA employees;
2. Require badggg spd signs be displayed to differentiate
contract workers from EPA staff members; .
3. Develop communications strategy to ensure contractors:
a. identify themselves on the telephone as other than EPA
representatives,
b. are kept uniformly informed of EPA policies and
procedures regarding the working relationships
established between EPA and contract workers.
4. Develop contract management guidelines and train EPA and
contract staff on them within 30 days.
5. Provide training in contracts management and project
officer roles and responsibilities, with special emphasis
on DOPOs and WAMs.
6. Conduct further analysis of the lab ESAT contract and
AARPS/SEES grants.
-------
7. Appoint_additional "senior procurement officers" at two
Region VIII remote locations--the Region VIII Laboratory
and the Montana Operations Office--reporting to the ARA for
contracts management.
The data gathered during the interview process bears out the
course of action we have already begun within Region VIII. More
training is. required for all persons having interactions with
contract staff. Wherever feasible every effort should be made
to remove contract staff from situations in which they are
commingled with EPA staff. Collocation is preferred, providing
EPA with ease of access while separating and distinguishing
contractors from EPA staff members. *
OFF-SITE CONTRACTS
We also have taken steps to improve our management of
contracts involving off-site staff as well, such as contracts
involved in Superfund cleanup activities. We identified
vulnerabilities under the FIMFIA process and developed a
corrective action plan. We have reassigned a contracting officer
from Small Purchases to Superfund Contracting to oversee the
invoice review process. We have developed a review strategy
for invoices and on-site reviews of contractors (Attachment C).
This strategy clearly identifies roles and responsibilities of
contract specialists, project officers, and RMPs. We have
conducted training for employees involved in contract management
activities and plan additional training throughout the year. We
have also requested Headquarters to request an audit of indirect
costs charged by the two ARCs contracts which Region VIII
manages. '
The Region VIII Contracts Management Review Task Force will
continue to monitor both on-site and off-site contracts,
developing actions plans as needed.
Attachments
-------
ATTACHMENT A
LIST OF CONTRACTS
CONTRACTOR
&
CONTRACT #
Computer Sciences Corp.
(CSC)
68-WO-0043
RDOOnly
Bayaud Industries
(NISH)
68-DO-0074
1CF Technology Inc.
(ESAT)
68-01-7456
Labat-Anderson Inc.
(Superfund)
68-W9-0052
Labat-Anderson Inc. (RCRA)
68-W9-0052
DO-0210
ESTIMATED
DOLLAR
VALUE OF
CONTRACT
$850,000/yr
$470.000/yr
$l,000,000/yr
$900,000/yr
CONTRACTING
OFFICER
(PHONED
Louise Senzel
(FTS-260-8508)
Kathy Weant
(FTS-629-3567)
Larry Presnell
(FTS-629-3166)
Pat Murphy
(FTS-260-8508)
PROJECT
OFFICER/
DOPO (PHONE D
Brenda Daly/PO
(FTS-260-2381)
AJ Vigil/DOPO
(294-7547)
Ben Jordan/CO
(293-1635)
Lynn Beasley/PO
(FTS-260-8600)
Steve Callio/RPO
(294-1056)
Linda Garrison/ PO
(FTS-260-6939)
, '). !.!'
Carole Macy/DOPO
(294-7038)
Rolland Lech/DOPO
(293-1516)
SITE
MANAGER
[ON/OFF SITE?]
(PHONEl)
Nick Robinson
[ON SITE]
(293-1284)
Ralph Breden *
[ON SITE]
(293-1482)
Eileen Simmons
(236-7081)
Cindy Osbourae
(294-7181)
k,
#OF
WORKERS
i
22
21
29
18
Touli Jau current as of: March 1992
-------
ATTACHMENT B
ACTIONS BEING TAKEN TO ADDRESS AREAS OF POTENTIAL VULNERABILITY
CONTRACTOR
POTENTIAL VULNERABILITY
ACTIONS BEING TAKEN
Computer Sciences Corp.
(CSQ
68-WO-0043
contract workers
Misunderstandings related to EPA supervision
of contract workers
Performing same or similar duties as EPA
employees
Signs to identify cubicals in place & special
badges for contract workers
Training for EPA staff, including WAMs,
Pos and DOPOs (HQ)
No EPA backup of contractors
Relocation 9/92 (new lease required prior to
implementation)
Bayaud Industries
(N1SH)
68-DO-0074
Performing same or similar duties as EPA
employees
Commingled workers (receptionists)
Evaluation of 'special situation" because of
status under Federal legislation and
regulation
ICF Technology Inc.
(ESAT)
68-01-7456
Labat-Anderson Inc.
(Superfund)
68-W9-0052
GIS - NONE
Lab - Insufficient data to determine
GIS-THIS CONTRACT SHOULD BE
USED AS A MODEL FOR OTHER
CONTRACT MANAGEMENT
Lab-Gather more data
Handling CBI
Develop internal controls
Labat-Anderson Inc. (RCRA)
68-W9-0052
DO-0210
Handling CBI
Develop internal controls
Data current as of: MARCH 1992
-------
Attachment C
Alternative Remedial Contracting Strategy (ARCS)
Public Voucher Validation Review Procedures
The following is an outline of procedures and guidelines for Contracting Officers
(COs), Project Officers (POs), Work Assignment Managers (WAMs) and Remedial
Project Managers (RPMs) to follow when performing a public voucher validation review
of ARCS contracts with cost-reimbursement provisions. Public vouchers are received
on a monthly basis from ARCS prime contractors as a result of program management
and remedial activities. Program management constitutes those technical and
administrative functions which are required to support the delivery of the technical
hours. Remedial and site assessment activities are those associated with the site
management, remedial investigation, feasibility studies and all engineering services in
design and execution of a remedy. Public voucher costs will be input into the ARCS
Contract Tracking System (ACTS). Use of the ACTS is standard for all ARCS type
contracts awarded by EPA.
Purpose:
The public voucher validation review procedures enable the reviewer to determine if the
contractor's billings are allowable and allocable in accordance with the terms and
conditions set forth in the contract. This review will be in conjunction with the Public
Voucher Validation Procedures for Regional Contracting Officers memorandum issued
by David J. O'Connor on February 10, 1992 (Attachment D), and in accordance with
the requirements identified in the Superfund Contracts Management Issues
memorandum issued by Christian Holmes and Don R. Clay on January 31, 1992
(Attachment E).
Objective:
The objectives of the review are as follows:
a. To ensure that billings are made in accordance with contractual terms and
are adequately supported.
b. To ensure that public vouchers are reviewed monthly by the CO, PO, WAM
and/or RPM utilizing the Public Voucher Validation Review Checklist.
c. To consistently document the reviews.
Attachments A and B, the Public Voucher Validation Review Checklist, will ensure the
completion of these objectives.
-------
Timing:
a. During the initial "start-up"phase, approximately two (2) months, aM public
vouchers will be thoroughly reviewed, by the CO, in accordance with the Public
Voucher Review Validation Checklist. The initial two month period of thorough
reviews, will establish whether the contractor's cost documentation and records are
reliable. After the first two months, the CO will utilize random sampling to determine
the scope or depth of his/her review of subsequent public vouchers. Utilizing random
sampling techniques, the CO will focus on various cost elements which are not
identified on Attachment B as the CO's primary review responsibility. If situations
arise where there is reason to question the validity or accuracy of the contractor's
public vouchers, the public voucher for that month and the next month should be
thoroughly reviewed by the CO. When the reviewer is satisfied that the contractor's
cost documentation and records are reliable, random sampling can be re-established.
b. The PO's, WAM's and/or RPM's who have the primary review responsibility
in accordance with Attachment B, will continue to conduct a thorough review of those
cost elements.
c. The optimum time for the public voucher review will be prior to the payment
of the particular public voucher. During the initial "start-up" phase, the public
voucher review may occur after a payment has been made. Deductions will then have
to be take from the next public voucher.
Reporting:
a. All findings resulting from the public voucher validation review, and actions
taken or proposed by the reviewer, including a time frame for resolution, should be
recorded on the Public Voucher Validation Review Checklist, Attachment A.
b. For questioned cost elements that have been identified on the contractor's
public vouchtrfor Program Management, the PO will initially communicate directly
with the contractor to resolve the issues. Issues that cannot be satisfactorily resolved
by the PO with the contractor, the PO will work with the CO for resolution. The Public
Voucher Validation Review Checklist (Attachment A) will be utilized for unresolved
issues.
c. For questioned cost elements that have been identified on the contractor's
public voucher for Work Assignments, the WAM and/or RPM will initially
communicate directly with the contractor to resolve the issues. Issues that cannot be
satisfactorily resolved by the WAM and/or RPM with the contractor, the WAM and/or
RPM will work with the POfor resolution. Issues that cannot be satisfactorily resolved
by the PO with the contractor, the PO will work with the CO for resolution. The Public
-------
Voucher Validation Review Checklist (Attachment A) will be utilized for unresolved
issues. ~ \
d. The original copy of Attachment A, with or without issues, shall be forwarded
to the CO to be maintained in the official contract file.
Documentation:
a. Attachment A is the public voucher validation review checklist which should
be used to document the review by the CO, PO, WAM and/or RPM.
b. Attachment B defines the specific areas to be reviewed.
c. Attachment C is the cost suspension/disallowance form.
d. Attachment D is the memorandum on Public Voucher Validation Procedures
for Regional Contracting Officers issued by David J. O'Connor on February 10, 1992
e. Attachment E is the memorandum on Superfund Contracts Management
Issues issued by Christian Holmes and Don R. Clay on January 31, 1992.
Resources:
a. In order to conduct a thorough review of all incoming public vouchers a
minimum work-force of one (1) contracting officer, two (2) contracting specialists, one
(1) contracting AARP and two (2) CSC contract employees will be required by the
contracts of/Ice.
b. In order to conduct a thorough review of all incoming public vouchers in the
program area a minimum work-force of one (1) project officer, one (1) deputy project
officer and one (1) work assignment manager and/or remedial project manager per
work assignment will be required.
c. A decrease in any of the resources will diminish the extent of public voucher
review.
-------
Public Voucher Validation Renew Checklist
for Program ManMement
CSC
PO
I. Direct Libor
2. Travel
3. Relocllion of Contract Employee!
4. Mtleriili ind Equipment
5. Other Direct Com
6 Overhead, fringe. Hindling end O&A •>
7. Torn Subcontract .—__>
8. Pollution Liability Insurance >
9. Mobile Ub ——>
10. Subcontractor!
11. Feei
12. Other llemi Checked •
Comment!:
CSC
WAM
PO
CO
1. Direct Ubor -
2. Tnvel
3. Mileriill «nd Equipment •
4. Other Direct Cott» •
5. Overhead. Friniei. Hindlint. OAA
6. Teem Subcontract
7. Ub Servicei-
I. SubcontractoB-
9. Fee.
10. Other Itemi Checked-
(Vt» revert* Tor iddilional commenU)
Reviewed by:
CSC Contractor
Work Auifnment Mini|er
Revievedby:
Comraclinf Officer
• require* • check-mirk or inilieli fjM * doe* not require • check-merk or inilieli
Project Officer
-------
-------
Attachment B
Page Iof4
ARCS Public Voucher Validation Review
for Program Management
1. Direct Labor:
a. Are direct labor rates charged for each P/T category in accordance with the
negotiations of the contract?
Primary review responsibility: CO
b. Are the number of hours for Program Management (PM) reasonable?
Primary review responsibility: PO
c. Are the number of hours aUocable to PM?
Primary review responsibility: PO
d. Is the skill mix consistent with PM accomplishments?
Primary review responsibility: PO
2. Travel:
a. Are the travel expense charges reasonable and in accordance with the Federal
Travel Regulations (FTR)?
Primary review responsibility: CO and PO
b. Is the travel necessary to support PM functions?
Primary review responsibility: PO
c. Was out of state travel previously approved by the PO?
Primary review responsibility: PO
3. Relocation:
a. Has the relocation been approved by the CO?
Primary review responsibility: CO
b. Are the relocation charges within the negotiated allowance?
Primary review responsibility: CO
c. Are the relocation charges reasonable?
Primary review responsibility: CO
-------
ARCS Public Voucher Validation Review
far Program Management
Attachment B
Page 2 of 4
4. Materials and Equipment:
a. Has prior approval been obtained by the contractor from the CO for materials
and equipment?
Primary review responsibility: CO and PO
b. Are the purchases allocable to PM and not to an individual Work Assignment
(WA)?
Primary review responsibility: PO
5. Other Direct Costs:
a. Are the costs broken out for a complete review?
Primary review responsibility: CO and PO
b. Are the costs consistent with the rates I ceilings negotiated for the contract?
Primary review responsibility: CO
c. Are the costs necessary for PM and reasonable for the work provided?
Primary review responsibility: PO
Are the percentages charged consistent with the current contract approved rates?
Primary review responsibility: CO
7. TV fffff Subcontract:
a. Are the labor rates charged for each P/T category in accordance with the
negotiations of the contract?
Primary review responsibility: CO
b. Are the hours reasonable for the PM support provided?
Primary review responsibility: PO
c. Are the hours allocable to PM?
Primary review responsibility: PO
-------
Attachment B
Page 3 of 4
ARCS Public Voucher Validation Review
for Program Management
8. Pollution Liability Insurance:
a. Does the contractor have an approved pollution liability policy?
Primary review responsibility: CO
b. Are the allocation of charges for the insurance a correct allocation for multi-
year/Region contracts?
Primary review responsibility: CO
c. Are the charges reasonable?
Primary review responsibility: CO
9. Mobile Lab:
a. Was the purchase of the mobile lab previously approved by the CO?
Primary review responsibility: CO
b. Are the charges of the mobile lab within the allowances of the contract?
Primary review responsibility: CO
c. Is the mobile lab necessary to support the work assignments?
Primary review responsibility: PO
d. Are the charges reasonable?
Primary review responsibility: PO
10. Subcontractors:
Are the charges of the subcontractors consistent with the provisions of the subcontract
and for the work provided?
Primary review responsibility: CO and PO
11. Fees:
a. Are the base and management fees correctly calculated by the contractor?
Primary review responsibility: CO
-------
Attachment B
Page 4 of 4
ARCS Public Voucher Validation Review
for Program Management
b. Are the award fees charged in agreement with the FDO award/contract
modification?
Primary review responsibility: CO
12. Other Items Checked:
a. Is the contractor charging to the appropriate account numbers for PM?
Primary review responsibility: PO
b. The reviewer may have no prior experience with the contractor, or situations
may arise where there is reason to question the validity or accuracy-of the contractor's
public voucher. A reviewer is not limited to only the categories listed above.
Primary review responsibility: CO and PO
-------
Attachment B
Page I of 3
ARCS Public Voucher Validation Review
for Remedial Work Assignments
1. Direct Labor:
a. Are direct labor rates charged for each P/T category in accordance with
negotiations for the contract?
Primary review responsibility: CO
b. Are the hours charged reasonable for the support provided?
Primary review responsibility: WAM
c. Is the labor mix consistent with the WP and WA accomplishments?
Primary review responsibility: WAM
2. Travel:
a. Is the travel necessary to support the work assignment?
Primary review responsibility: WAM
b. Are the charges reasonable?
Primary review responsibility: WAM
i
3. Materials and Equipment:
a. Have prior approvals been obtained?
Primary review responsibility: WAM and PO
b. Is the purchase aUocable to the WA and not to PM?
Primary review responsibility: PO
c. Is the purchase necessary to support the WA?
Primary review responsibility: WAM
4. Other Direct Costs:
a. Are the costs broken out for a complete review?
Primary review responsibility: WAM
b. Are the costs necessary for the WA and reasonable for the work provided?
Primary review responsibility: WAM
-------
Attachment B
Page 2 of 3
ARCS Public Voucher Validation Review
for Remedial Work Assignments
c. Are the other direct costs in accordance with the negotiated ceilings?
Primary review responsibility: CO
d. Are the costs in accordance with the negotiated rates?
Primary review responsibility: CO
5. Overhead. Fringe. Handling and G&A:
Are the percentages charged consistent with the current contract approved rates?
Primary review responsibility: CO
6. Team Subcontract:
a. Are the labor rates charged for each PIT category in accordance with the
negotiations?
Primary review responsibility: CO
b. Is the work provided by the team subcontractor consistent with the WP?
Primary review responsibility: WAM
c. Are the hours reasonable for the support provided?
Primary review responsibility: WAM
7. Lab Services:
a. Are the charges within the contract allowances?
Primary review responsibility: CO
b. Are the costs charged to the appropriate work assignment?
Primary review responsibility: CO
c. Are the charges consistent with the services provided for the WA?
Primary review responsibility: WAM
8. Subcontractors:
a. Are the charges consistent with the support provided?
Primary review responsibility: WAM
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Attachment B
Page 3 of 3
ARCS Public Voucher Validation Review
for Remedial Work Assignments
b. Is the work provided by the subcontractor consistent with the WP?
Primary review responsibility: WAM
9. Fees:
a. Are the base and management fees correctly calculated by the contractor?
Primary review responsibility: CO
b. Are the award fees in accordance with the FDO award / contract
modification?
Primary review responsibility: CO
10. Other Items Checked:
a. Is the contractor citing the appropriate account numbers for the work
assignment?
Primary review responsibility: PO
b. The reviewer may have no prior experience with the contractor, or situations
may arise where there is reason to question the validity or accuracy of the contractor's
public voucher. A reviewer is not limited to only the categories listed above.
Primary review responsibility: CO, PO and WAM
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Attachment C
COST SUSPENSION/DISALLOWANCE FORM
CONTRACTOR:
VOUCHER #:
CONTRACT /:
VOUCHER DATE:
I. ARCS PROJECT OFFICER Name/Date:
PROGRAM MANAGEMENT/
OR WA NUMBER
INVOICE
DCN
INVOICE
ACN
SUS/
DIS
TOTAL
1.
2.
3.
4.
5.
1.
REASONS/ACTION REQUIRED
2.
3.
4.
5.
GO'S CONCURRENCE
Signature/Date: '
II. CONTRACTOR'S RESPONSE
Name/Date:
III.
ARCS PROJECT OFFICER - FINAL DETERMINATION
Items
Items
Items
, Approved for resubmittal.
, Require add'l. information (see back of sheet)
, Disallowed and forwarded to CO.
PO Signature:
Date:
IV. CONTRACTING OFFICER (FOR DISALLOWANCE ONLY)
The costs recommended for disallowance are disallowed based on
information I have received.
CO Signature: Date:
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Attachment D
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
ADMINISTRATION
rr~ \ 0 :~~ AND RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT: Public Voucher Validation Procedures for Regional Contracting Officers
FROM: David J. O'Connor, Director
Procurement and Contracts Management/Division (PM-214-F)
TO: See Below
The purpose of this memorandum is to provide guidance and outline procedures
for performing public voucher validation reviews for EPA Regional Contracting Officers.
The attached procedures (Attachment A) apply to EPA's Alternative Remedial
Contracting Strategy (ARCS), Emergency Response Geanup Services (ERCS), and other
types of contracts with cost-reimbursable provisions. This guidance is prepared in
response to the Administrator's Task Force on Implementation of the ARCS which
recommended spot checks of contractor vouchers. It is important that the reviews are
performed using a consistent approach which is coordinated with our invoice review,
financial monitoring and audit processes. As with any new procedure, certain
implementation problems may arise, and we will work with you to resolve them.
These reviews, in combination with other financial management tools such as
financial monitoring reviews and voucher audits (Attachment B) that will be requested
from the Defense Contract Audit Agency and the Office of Inspector General will result
in better managed contracts. It is important for all of us to work together and to
communicate the findings from these validation reviews to the Headquarters Financial
Analysis Section. The results of these public voucher validation reviews will be very
beneficial in planning and performing financial monitoring reviews, annual incurred cost
audits and voucher reviews performed by the cognizant auditor.
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Attachment D
If you have any questions regarding this issue or the following procedures, please
call Dale Roberson, Chief of the Financial Analysis Section at (FTS) 260-3194.
Attachments
Addressees!
Hillary Kelky, Chief, Superfund Contracts, Region I
Ted Riverso, Chief, Contracts Section, Region H
frank Snock, Chief, Superfund Financial Management Section, Region HI
Jane Singley, Chief, Contract Negot.,and Mgt. Section, Region IV
Patricia Bamford, Chief, Contracts Section, Region V
Shirley Bruce, Chief, Procurement Section, Region VI
Alma Eaves, Director, Superfund Contracts Office, Region VH
[Martha Nkodemus, Chief, Grants Management Branch, Region VHI
Tom Warner, Chief, Contracts Management Section, Region IX
Jonell Allamano, Chief, Support Services, Region X
William Topping, Chief, Regional Contract Placement Branch, (PM-214-F)
Pat Patterson, Staff Chief, Superfund/RCRA Program Management Staff (PM-214-F)
William WOfong, Chief, Superfund/RCRA Headquarters Operation Branch (PM-214-F)
Sue Anderson, Acting Chief, Regional Contract Management Branch (PM-214-F)
Tom McEntegart, Chief, Procurement Operations Branch (PM-214-F)
Dca Joiner, Acting Superfund Acquisition Program Manager (PM-214-F)
Joan Barnes, Contract Operations Review and Assessment Staff
Ken Ayers, Design and Construction Management Branch
cc: Assistant Regional Administrators Patricia L. Meaney, Region I
Herbert Barrack, Region H William J. Wisniewski, Region
Joseph R. Franzmathes, Region IV Robert L. Springer, Region V
William Hathaway, Region VI Susan C. Gordon, Region VH
Kerrigan G. Clough, Region VHI Nora L. McGee, Region IX
Barbara F. McAllister, Region X Mark Kelknnan, CINN
John Gherardini Mike Bower, RTF
Edward Hanley John Chamberlin
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Attachment D
ATTACHMENT A
PAGE 1 OF 3
PUBLIC VOUCHER VALIDATION REVIEW PROCEDURES
The following is an outline of procedures and guidelines for Contracting Officers
or their representatives to follow when performing a public voucher validation review
under EPA's ARCS, ERCS and other contracts with cost-reimbursement provisions. The
primary scope of the review involves limited testing of costs on invoices to ensure that
hillings are prepared in accordance with contractual terms and are adequately supported
with accounting books and records. The extent of the review should depend upon the
invoiced amount timeliness, and degree of known issues or concerns as well as the
reviewer's judgement and familiarity with the contractor's billing operations.
In those cases where the reviewer is satisfied that the contractor's cost
documentation and records are reliable, it will generally be sufficient to limit the
verification to the procedures listed. In .other instances, where the reviewer or EPA has
no prior experience with the contractor, or situations arise where there is reason to
question the validity or accuracy of the contractor's public voucher, the reviewer should
notify the Financial Analysis Section who will request an audit of the contractor's
accounting system and billing procedures. In addition to these voucher reviews, other
types of audits and reviews are being performed as shown on Attachment B. All
requests for audits should be sent to EPA's Chief of the Financial Analysis Section
located at Headquarters.
Review procedures for public voucher validation reviews are as follows:
OBJECTIVE
The objective of the review is to periodically ensure that billings are made in
accordance with contractual terms and are adequately supported. The objective of the
voucher validation review differs from the currert monthly voucher review and approval
process performed by Project Officers and Contracting Officers. A major difference is
the depth of the reviews. For maximum coverage it is recommended that these reviews
be performed on-site at the contractor's offices to verify costs to contemporaneously
available source documents and accounting
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Attachment D
ATTACHMENTA
PAGE 2 OF 3
records (i.e. invoices, labor distribution, payroll register, job cost ledgers, accounts
payable, vendor files, subcontract files, etc.). However, in many cases the reviews will
need to be performed as desk reviews using information mailed/faxed to the reviewer
due to lack of travel funds or available staff resources.
TIMING
These reviews should be performed when questions arise from the Project Officer
or from other sources which suggest the need for validating invoiced costs and other
sources of invoice review are not available (financial monitoring reviews, voucher audits
by DCAA or OIG, current annual incurred cost audits, etc.).
SELECTION OF VOUCHERS
1) One or more public vouchers per contract should be selected for review. A
sample of costs from all cost elements where amounts billed are material
should be reviewed.
2) The public vouchers selected for review should not be' the same vouchers
reviewed by the Financial Analysis Section (FAS) in the financial
monitoring report or DCAA's voucher review requested by FAS. A copy of
reports from these reviews will be sent to regional CO's and PO's within 1
to 2 months after the review. CO's should send copies to the PO's.
SCOPE OF REVIEW
After invoices for review have been selected, but prior to invoice review, special
considerations should be given to reviewing transactions involving: 1) any unusual
items being claimed or any costs that stick out as unusual based on the scope of work
being performed, 2) high dollar items, and 3) testing transactions from each cost
element from multiple WA's,or DO's. In reviewing the reasonableness of charges, the
reviewer is not expected to know exact market values of various direct costs; however,
past experience and common sense can assist hi confirming the reasonableness of
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Attachment D
ATTACHMENTA
PAGE 3 OF 3
charges for each cost element examined. Invoices are to be reviewed on a sample basis
only; it is not the intent of these procedures to suggest that a 100% review is needed.
We have identified specific areas and line items that should be examined when reviewing
an invoice.
REPORTING
All findings or problems discovered as a result of the voucher validation review
should be reported by or thru the Contracting Officer to the Chief, Financial Analysis
Section (FAS). The CO should also notify the Project Officer of findings and any action
required during the monthly voucher payment approval process.
Actions taken or proposed by the CO should be included in the report along with
a time frame for resolution. Cross cutting issues affecting multiple contracts may be
referred to the Financial Administration Contracting Officer (FACO) through the Chief,
FAS. Questions regarding these procedures should be referred to the Chief of the
Financial Analysis Section. Copies of the report and related documents must be
maintained in the official contract file.
DOCUMENTATION
Attachment A is a review checklist which should be used to document
performance of the review. The completed checklist along with the review report and
any workpapers should be retained together as part of the contract file.
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Attachment D
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Attachment D
CHECK LIST FOR VOUCHERVALIDATION REVIEW
CONTRACTING
CONTRACTOR NAME: PROGRAM:
CONTRACT NO.: REGION:
REVIEWERS NAME: REVIEW COMPLETION DATE:
VOUCHER NUMBER(8) REVIEWED:
VOUCHER PERFORMANCE PERIOD(8)1
STEP
PERFORMED REVIEWERS
(Y/N) INITIALS DATE
REVIEW PROCEDURES
1) Review the public voucher for
completeness (i.e. company name, total
costs, signatures, dates, contract
number, period of performance, etc.)
determine if costs are presented in t.
format required by the contract and
billed in accordance with government
regulations. Also determine the
following:
a. Are individual cost elements
adequately shown?
b. Are cumulative costs
adequately shown?
c. How often are vouchers submitted
for payment?
d. Is there evidence in the
contract file that the voucher
was reviewed and approved by the
PO?
2) Ascertain that claimed costs have
been incurred, or actually paid,
dependent upon the terms of the p«v»«nt
clause of the contract. Also determine
if the contractor maintains adequate
supporting records for all claimed
costs.
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Attachment D
CONTRACTOR NAME:
CONTRACT NO.
STEP
PERFORMED
(Y/N1
REVIEWERS
INITIALS
DATE
3) Make a quick check of the
mathematical accuracy of the public
voucher.
4) Verify that billed costs were
incurred within the period of
performance authorized under the
contract/delivery order/etc.
5) Review cumulative costs claimed, to
assure that the amount claimed does not
exceed the total estimated cost
(excluding fee) authorized under the
contract, WA or DO if appropriate.
6) Review and verify that indirect
costs claimed are being billed at
contractually established rates. Assure
that you have the latest rate agreement
issued by the cost Policy and Rate
Negotiation section for the contractor.
7) Verify that the fee billed is in
accordance with contractual provisions
and that fee withheld complies with
requirements of the contract.
8) Review any special contract .
provisions for payment restrictions such
as ceilings, etc.
9) Review and determine if site
specific costs are correctly accumulated
and billed.
10) Review and determine whether there
are or has been a history of suspended
or disallowed billings, if so, what is
the current status?
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Attachment D
CONTRACTOR NAME: CONTRACT NO.:
LABOR
Specific emphasis should be given to labor costs. The
reviewer should assure answers to the following questions.
STEP
PERFORMED REVIEWERS
fY/N) INITIALS DATE
1) Will the total LOE be exceeded
before the contract performance period
expires?
2) Did the contractor charge premium
for overtime worked? Was it authorized
by the Contracting Officer in advance?
Was it charged consistent with the
.contractor's established practice?
3) Are the hours charged within the
estimates specified in the work
pian/delivery order?
4) Do the employees billed meet the
contract requirements for the category
in which they are billed? (You can asfc
the contractor for specific employee's
resumes and compare them to the labor
category requirements)
5) Does the labor mix appear to be
appropriate.
6) Are labor hours and rates supported
by timesheets and the payroll register?
7) Are there any dollars being charged
to direct labor that are not being
charged to LOE? (clerical & mgmt) /
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Attachment D
4
-TRACTOR NAME: CONTRACT NO.:
TRAVEL
STEP
PERFORMED REVIEWERS
(Y/N) INITIALS DATE
1) Determine that travel expenses are
adequately justified by supporting
documentation and were related
specifically to a contract requirement.
2) Determine if the sample travel
expenses reviewed comply with
contractual limitations, the
contractor's policies and the Government
Travel Regulations (GTR).
OTHER DIRECT^COSTS
In the area of ODC's the reviewer must thoroughly review
supporting documentation to ensure that all ODC's sampled are adequately
<=--sported and do not exceed any contract dollar ceilings. Also review any
contract ODC's for ceiling limitations. In addition determine the
following:
STEP
PERFORMED REVIEWERS
(Y/N) INITIALS DATE
1) Carefully sample any charges .in the
miscellaneous and transactions in other
categories.
2) Ascertain whether the contractor
charges similar costs direct to all
other clients.
3) Derermine if any expenses that
should have been charged to overhead
were charged as ODC expenses.
4) Validate direct purchases of
supplies, materials, equipment, etc. and
determine whether property has been
purchased and properly approved under
the contract.
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Attachment D
"CONTRACTOR NAME: ~
STEP
PERFORMED
(Y/N)
REVIEWERS
INITIALS
DATE
CONTRACT NO,
5) Review the purchase document
(purchase order, etc.) to see who
authorized the purchase.
6) Compare the purchase document with
the vendor's invoice. This should then
be compared with the contractor's
voucher to EPA. Determine the reason
for any differences.
SUBCONTRACTS
STEP
PERFORMED
DATE
1) Verify a sample of subcontract costs
claimed. Ascertain that items and
services claimed were purchased directly
for the contract. Verify that
subcontractor's costs are properly shown
on the prime contractor's vouchers.
Assure that the contractor monitors
subcontractor costs by cost element as
well as by entity. Assure that indirect
cost rates on subcontracts are
periodically adjusted to reflect actual
rates incurred, validate support for
subcontractor invoices.
2) Assess the adequacy of the Prime
Contractor's monitoring of the
performance of subcontractors.
3) Determine whether the subcontractors
sampled have been properly approved by
the Contracting Officer or appropriately
notified to the CO in accordance with
the terms of the contract. Review the
contract agreement between the prime 1
subcontractor. Be aware of any
potential conflicts of interest.
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AttachmentD
ITRACTOR NAME: CONTRACT NO.:
REPORT PREPARATION
STEP
PERFORMED REVIEWERS
(Y/N) INITIALS DATE
1) Summarize the results of the review.
2) Discuss results with the Contracting
Officer, Chief of the Financial Analysis
Section and FACO (when applicable ) for
assurance of a thorough understanding of
the issues.
3) Disclose financial and contracting
issues that need interpretation or
clarifications.
4) Prepare file notes for
identification of problem areas to be
included in future and follow-up
reviews.
5) Prepare draft report and obtain
necessary approval of the draft.
6) Prepare and issue the final report.
DOCUMENTATION
STEP
PERFORMED REVIEWERS
(Y/N1 INITIALS DATE
1) Complete the review checklist.
2) Package the report, checklist,
correspondence and workpapers into a
file to be maintained as part of the
contract file.
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Attachment D
ATTACHMENT B
PAGE 1 OF 2
THE POST-AWARD AUDIT PROCESS
Financial Monitoring Review (FMR) -
The FMR is a review of contractor billings associated with an
individual contract to ensure compliance with contract
requirements and to ensure that billed costs are adequately
supported by appropriate systems and records. Reports are
issued to the CO and the Financial Administrative
Contracting Officer (FACO) for resolution of findings. These
reviews are performed by the PCMD Financial Analysis
Section on contracts in excess of $5 million. Current PCMD
policy stipulates that the reviews should be scheduled for
each appropriate contract after at least 6 months of
performance has been completed.
Incremental closeout audit • (ARCS contracts only)
These audits, once the instructions and procedures have been
agreed to and finalized, will be performed incrementally
when the final incurred cost audits are completed for a given
contractor fiscal year. The audit will provide the Contracting
Officer with the recommended allowable direa and indirect
contractor fiscal year costs claimed by the contractor for the
particular ARCS contract The objective of the close* out
audits will be to close the ARCS contracts incrementally so
that after the 10 year performance period, there will not be a
need to close out contractor fiscal years all at once.
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Attachment D
ATTACHMENT B
PAGE 2 OF 2
Annual Incurred Cost Audits -
The Annual Incurred Cost Audit is a comprehensive audit of a contractor.
The review includes an audit of the allowability of direct and indirect costs
for all government contracts and is performed for each of the contractor's
fiscal years. Upon receipt of the contractor's submission, the Cost Policy
and Rate Negotiation Section (CPRNS) will arrange for an audit by the
cognizant audit agency. The audit report from the cognizant audit agency
is used by CPRNS to negotiate the final indirect rates. The incurred cost
audit is also used, as discussed above, as a basis for the ARCS
annual/incremental close-out audit report received from the cognizant
audit office.
Voucher Audits -
A voucher audit may be conducted by the cognizant audit
activity for a specific contract during the performance period
of the contract This audit may be requested by PCMD's
Financial Analysis Section, based upon concern about the
reliability of the costs claimed, a suspicion that there may be
problems with contractor performance, or upon completion
and determination of need as a result of an FMR. We will
be requesting voucher audits on each ARCS contract as
appropriate.
Contract Audit Closing Statement -
The closing statement, sometimes called a final audit, is a summarization
of the amounts claimed and accepted in the annual incurred cost audits for
the contract Normally, no added audit work is performed.
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Attachment E
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CASHING TON DC 20460
RECEIVED
•• -T, . , Ft8 - 7 1992
MEMORANDUM
SUBJECT: Superfund Contracts Management Issues
/
OSWER Directive 92
«
FROM:
Don R. Clay, Assistant Administrator _
Office of Sclid Waste and Emergency Response
TO:
ristian Holmes, Acting Assi
Office of Administration and
Regional Administrators
istrator
nagement
PURPOSE
To initiate new requirements regarding the development of
independent government cost estimates (ICE), review of contract'
invoices, and the appropriate-partioip»ti-on—on-Performance
Evaluation Boards.
BACKGROUND
within the last 6 months, the EPA Inspector General, the
General Accounting Office and the Administrator's Task Force on
the Implementation of Superfund Alternative Remedial Contracting
Strategy (ARCS) have issued findings and recommendations
regarding several issues including deficiencies in the areas of
IGEs, the adequacy of our review of contractor invoices, and the
performance of the award fee proceus. While the comments were
directed at specific contracting programs within Superfund, they
affect and are a concern across all OSWER contracting programs.
This directive establishes new policy regarding these issues.
OBJECTIVE
Independent Government Cost Estimates
The Federal Acquisition Regulations require that IGEs be
prepared for each new contract or modification that is expected
to exceed $25,000. Currently, there is no Federal or Agency
policy that requires IGEs prior to the issuance of independent
work assignments under existing contracts. A recent GAO report
compared the work plan negotiation results for work assignments
where IGEs were prepared against results where IGEs were not
prepared. The conclusion of this comparison demonstrated that
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Attachment E
considerable negotiation leverage is achieved when realistic IGEs
are developed prior to work plan negotiation. In all cases where
an IGE was prepared, the negotiated amounts were considerably
below the initial work plan amounts presented by the contractor.
The exercise of developing independent government cost estimates
also demonstrates to our contractors that the government
negotiation team is fully prepared to discuss, and to negotiate
realistic costs for the work to be performed.
Both the GAO report and the A3CS Report of the
Administrator's Task Force recommend that Regional Administrators
develop a capability for contract managers in generating
independent government cost estimates. The objective of this
Directive is to establish policy to implement this recommendation
across OSWER.
»
Review of Contractor Invoices
The objective of this directive is to clarify the role of
contract managers (POs, WAMs and RPMs) in the voucher review
process and to establish policy regarding these activities.
Under cost reimbursable contracts, allowabie-r-allocable—and-
reasonable costs are paid up to the estimated cost of the
contract or the expenditure limit for—the work-assignmentT—as
appropriate. Contract managers are required to assure that the
direct costs on vouchers that they approve are appropriate and
reasonable for the work performed and that the amount of-work-
performed is reasonable for the task. Contracting Officers will
periodically look at a representative sample of the billed costs
and determine allowability and allocability. In addition,
professional auditors, at the request of the Contracting
Officers, perform annual comprehensive incurred cost audits and
provide recommendations to the CO. Any concerns raised by the
auditors will be conveyed to the .appropriate Project Officer.
However, the contract manager, that person most familiar with,
and closest to the work being performed (e.g., RPM, WAM, PO,
etc.), has the ultimate responsibility for determining the
"reasonableness" of the costs being invoiced. A "reasonable"
cost is one that would seem to be justified and legitimate and
what a prudent person would pay under like circumstances in the
conduct of competitive business.
In reviewing the reasonableness of charges, contract
monitors are not expected to know the exact market values of
various direct costs; however, past experience arid common sense
can assist in making a determination for each cost element
examined. If unreasonable charges are approved for payment, it
is doubtful that anyone reviewing the costs later will possess
the knowledge to disallow those costs. Therefore, the contract
manager is the most logical person to question, identify and
recommend disallowance of unreasonable charges.
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Attachment E
3
Participation on Performance Evaluation Boards
One of the benefits of an award fee contract is that it
provides a means of periodically involving senior contractor and
government management in the oversight of contractor performance.
To reinforce this position, the Environmental Protection Agency
Acquisition Regulations (EPAAR) require that the Performance
Evaluation Boards (PEB) be chaired at the division director level
of the program initiating the procurement. Any changes to the
chairperson appointment must be approved by the Fee Determination
Official.
The composition cf personnel participating in the
performance evaluation process must represent those employees
most experienced and knowledgeable of contractor performance
issues. In many cases, fi-rst and second line supervisors
represent the most experienced managers and, as such, are
expected to take an active role in the performance evaluation
process. In addition, PEB chairpersonship is occasionally
delegated to positions below the Division Director level, or even
to the branch chief level. Both of these situations erode some
of the benefits of the award fee process. The objective of this
directive is to reinforce the -intent—of—the—EPftAR in the area of
roles and responsibilities associated with the performance
evaluation process.
IMPLEMENTATION _. . . .
Independent Goverr.nent Estimates
Effective February l, 1992, an independent government cost
estimate must be developed by the technical program office (WAM
or RPM) generating the requirement prior to the issuance of any
work assignment estimated to exceed $25,000 under contracts that
utilize a work assignment/work plan administrative process. This
requirement is applicable to both new work assignments and to
increases in existing work assignments. The IGE will be
prepared, at a minimum, at the element of cost level (e.g.,
direct labor, subcontracts, equipment, other direct costs, etc.
and by major task, when practicable. While the responsibility
for IGE development rests with the technical program office, :t
is expected that the technical office will work in concert with
the contract specialists in the management offices in this effrrt
and that the IGEs must be developed independently without ..-.put
from the contractor receiving the work assignment. The IGE w;.:
be used by the RPM/WAM, PO and CC is a tool in negotiating the
workplan budget with the contractor and for documenting the
resulting agreements in the contract file. We recognize that
additional guidance may be required to develop the best poss.c.-^
IGEs. OSWER and PCMD will assess that need and assist in any -.
they can. However, in the meantime, it is expected that t.-.e
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Attachment E
Regions and Headquarters offices will proceed to implement this
policy.
In addition to estimating systems already developed in some
Regions and at Headquarters, you are reminded of two tools that
have been distributed to assist in preparing Superfund IGEs. The
first, the Superfund Cost Estimating Expert System, is a computer
model that uses site-specific data to develop independent
government estimates. The second, Scoper's Notes, is a guide to
RI/FS costing and is used to develop ballpark cost estimates.
You are encouraged to utilize these tools in developing your
estimating capability.
Review of Contractor Invoices
Effective immediately* those contract managers (WAM or RPM)
that are most familiar with the contractor work will be
responsible for reviewing monthly invoices as directed by the
Project Officers. Contract managers are responsible for
providing written recommendations on cost reasonableness or
unreasonableness to the Project"Officers. When further
contractor documentation is required before a determination can
be made, payment of invoiced costs, or any portions thereof-r—may-—
be suspended by the Project Officer until the documentation is
-submitted—and-a -reasonableness -determination-can-be made.—When
charges are determined to be improper or unreasonable, the
Contracting Officer has the authority to disallow payment of
those charges. Contractor charges or portions of those charges
that are inadvertently paid and .later determined to be improper
or unreasonable, should be disallowed on subsequent invoices.
Guidance on voucher review can be obtained from the
Contracting Officer, Project Officer or any member of the
Contract Operations Review and Assessment Staff (CORAS). Consult
the CORAS Bulletin series on Financial Oversight for additional
written guidance on the steps associated with the voucher review
process. More specifically, Issue No. 4, dated May of 1989,
contains an article on contractor voucher review. Contract
managers are encouraged to read this guidance and to use the
Invoice Review Checklist in Exhibit 1. Once the Checklist is
completed, it should be attached to the contract manager's copy
of the invoice to document the review. Copies of Issue No. 4 can
be obtained from Superfund Project Officers or from CORAS in OERR
at mail code OS-240.
Participation on Performance Evaluation Boards (PEBs)
Effective immediately, all official PEB chairpersons shall
review the membership of their PEBs and make whatever adjustments
are necessary to involve the most Knowledgeable and experienced
personnel in the award fee process.
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Attachment E
Only in unusual circumstances, and when absolutely
necessary, may official chairpersons delegate their
responsibilities. In the event that delegation becomes
necessary, the official chairperson shall contact the Fee
Determination official, prior to tne convening of the PEB, and
obtain verbal approval to delegate. In no event will the
chairperson responsibilities be delegated below the Branch Chief
level.
Many tools have teen provided over the years to address
these issues. They have taken the form of training, CORAS
Bulletins, guidance documents, Award Fee Guides, computer models,
exit conferences (conducted by GAO, IG and CORAS), program
conferences, and even IG audits and GAO reports. We feel that
the policy presented in this directive is critical to achieving
improvements to our contracts management activities, and
represents the first steps in implementing meaningful
recommendations presented in review documents. It is requested
that each region (a single coordinated response from each region)
inform us as to the action taken in regards to implementing this
Directive. It is requested that the implementation information
be submitted within 30 days from the date of this Directive to
the Superfund Acquisirion Manager, OS—100,—OSWER;
Any questions regarding this policy should 'be-direeted-to—
Ika Joiner, Acting Superfund Acquisition Manager, at FTS
260-0840.
cc: Regional Deputy Administrators
Assistant Regional Administrators
Henry L. Longest II, Director, Office of Emergency and
Remedial Response
Bruce M. Diamond, Director, Office of Waste Programs
Enforcement
Sylvia K. Lowrence, Director, Office of Solid waste
David w. Ziegele, Director, Office of Underground
Storage Tanks
John C. Chamberlin, Director, Office of Administration
David J. O'Connor, Director, Procurement and Contracts
Management Division
Directors, Waste Management Division
Regions I, IV, V, and VII
Director, Emergency and Remedial Response Division
Region II
Directors, Hazardous waste Management Division
Regions III, VI, VIII. IX, and X
Directors, Environmental Services Division
Regions I-VIII, and X
Chief, Environmental Services Branch
Region IX
Director, Hazardous Site control Division (HSCD)
Director, Hazardous Site Evaluation Division (HSED)
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Attachment E
Director, Emergency Response Division
Director, Office of Program Management
Director, CERCLA Enforcement Division (CED)
Office of Waste Programs Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII ATTACHMENT 2
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2466
Ref: 8PM-IM
March 26, 1992
MEMORANDUM
TO: All Supervisors, Contracting Officers, Project
Officers, Delivery Order Project Officers, Assistant
Delivery Order Project Officers and Work Assignment
Managers
?x
FROM: Jack McGraw, Acting Regional Administrator/kvw
SUBJECT: Contract Management Guidelines
I am sure that most of you have heard that Region VIII'a and
EPA Headquarter's management of the CSC contract was audited. In
addition to the audit of Region VIII, a nation-wide audit of the
management of the CSC contract was also made. The audits were
not very complementary and require that many of our existing
procedures related to the contract be changed. Probably the most
significant is the way we work with contract staff. We realize
how important our contract staff have been in allowing us to do
our work and have treated them as part of the team and have
worked very closely with them. This relationship can be
construed as being a personal service and is prohibited by the
Federal Acquisition Regulations. This does not mean that we can
not be cordial to the contract staff, it simply means that we
must treat them in a business-like manner.
Region VIII is committed to maintaining the highest
standards of contract management for all contracting activity
within the Region. We all have a responsibility to understand
and apply proper contract management practices. In order to
clarify what is proper, we have developed the attached document:
REGION VIII CONTRACT MANAGEMENT GUIDELINES. It contains simple
recommendations, prohibitions, and definitions in regard to
contracting in Region VIII. In addition, we have attached a
series of questions and answers for your guidance.
Please discuss and provide a copy of these guidelines to
your staff members who have day-to-day working relationships with
contract employees.
Please contact Al Vigil at X7547 if you have questions or
comments about this document.
Attachments
Prinlfd on Rtcycled
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REGION VIII CONTRACT MANAGEMENT GUIDELINES
Working Relationships
EPA employees are expected to be impartial and objective in their dealings
with contractors. Employees should be prepared for public scrutiny and
must avoid any situation which gives even the appearance of favoritism or
conflict of interest. This requires use of common sense in these
situations. EPA employees should be cordial in their working relationships
with contractors, but the relationship must always be a business-like,
arm's length relationship.
Identification of Contractors
Our Administrative Services Branch will be obtaining identification badges
for all contract staff working in EPA space. When received, contractors
shall wear identification badges clearly visible showing that they are
contractors. Contractor work space must have signs to identify the company
name. Contractors must always clearly identify themselves as contractors
in any situation where it might be assumed that they were representing EPA
(such as when they answer the telephone or are involved in meetings).
Contractor Workspace
./e are reviewing the functions that contractors perform to determine which
functions can only be performed in EPA space. Every effort will be made to
house all other contractors in separate space from EPA employees. In chose
cases where we have determined that work can only be done in EPA space,
contractors will be physically grouped together in their own work area and
be clearly identified as contractors.
EPA Furnished Property
EPA is in the process of making an inventory of the EPA property which is
presently being used by contract staff. When guidance is received from EFA
headquarters, the property will be transferred to the property records
maintained in headquarters by the EPA Contract Property Management Officer.
Actual responsibility for the property will rest with the contractor and
will be included on their property records.
Awards/Recognition
EPA will not present awards or other formal recognition including letters
of appreciation and commendation to contractor staff. EPA employees may
provide information on individual contractor performance to the Delivery
Order Project Officer or the contractor site managers.
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:tendance at EPA Functions and Meetings
Contractors are not-allowed to attend EPA meetings, retreats, social
events, and training sessions unless their presence is required to perform
work authorized under the contract. Contractors may attend "Brown Bag"
presentations of general interest as long as they do not charge time to the
Government for their attendance time. Again, contractors are prohibited
from routinely attending EPA staff meetings. Contractor personnel are
authorized to attend meetings only for specific work authorized under the
contract. This does not prohibit regular meetings between EPA staff and
contractors to review work products. Contract staff will not belong to
Quality Action Teams. If their expertise is needed, they can be invited to
attend specific meetings to present information related to their work.
Training
Contractors are expected to have the skills they require to perform their
jobs. Therefore, EPA will not provide training which is commercially
available (this would include training such as Total Quality Management and
PC software packages). EPA can provide training in those instances where
the training is somehow unique to EPA's environment or required for
specific performance under the contract and if there is no direct charge to
the contract.
Supervision/Work Assignment
' A employees cannot supervise contract employees. Contract employees are
pervised by contract supervisors. EPA employees may share information
with contractors to perform the required work. Only certain specially
trained Government employees, such as Delivery Order Project Officers or
Work Assignment Managers, may assign work to contractors. Work assignments
must fall within the scope of the contract as described in the statement of
work. Even in those cases where EPA personnel are authorized to assign
work under a contract, they cannot supervise the contractor staff.
Personal Services
Personal Services contracts are not allowed. A personal services
relationship exists when a contractor is treated essentially as another EPA
employee. The Federal Acquisition Regulations provide guidance as to what
might constitute personal services. In particular, there are some things
we must not do. These are: 1. We must not have EPA and contract staff
doing comparable services or meeting comparable needs; 2. We must not
assign work to the contract staff which by the inherent nature of the
service, or the manner in which it is provided, reasonably requires
directly or indirectly, Government direction or supervision of contractor
employees. Government supervision must be avoided. Contractors may not
perform work which is considered inherently Governmental.
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Position Descriptions and Performance Standards
EPA employees who are authorized to provide technical direction and accept:
deliverables from contractors must have specific language in their position
descriptions and performance agreements describing these duties.
Required Training for EPA Employees
Every EPA employee in Region VIII who is working with the CSC or other
contracts must be trained in contracts management. This training will be
offered in July 1992.
Questions/Contract Management Reference Material
Questions on contract management should be directed to the Contracting
Officer, Project Officer, Delivery Order Project Officer, Alternate
Delivery Order Project Officer, or Work Assignment Manager for the specific
contract. Contracting information and guidance may also be found in the
following documents: Federal Acquisition Regulation (FAR), Environmental
Protection Agency Acquisition Regulation (EPAAR), EPA Contracts Management
Manual, and the Acquisition Handbook.
Audits
Requests by any office for Region VIII contract management information in
association with an audit or inspection should be referred to the Region
VIII Grants and Superfund Contracts Branch. All Regional audit activity
coordinated through that branch.
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DEFINITIONS OF
CONTRACTING ACRONYMS AND TERMS
CO Contracting Officer. Is the agent of the Federal government for
a specific contract. Only the CO has the authority to sign a
contract, obligate funds, issue work assignments*, modify
contract terms or conditions, terminate a contract and accept
supplies and services*.
*(These functions can be delegated to a Project Officer).
PO Project Officer. Is the primary technical representative of the
CO. The PO monitors overall contract performance, reviews
technical and financial progress reports, provides technical
direction to Delivery Order Project Officers, monitors use of
Government property, certifies vouchers and recommends contract
modifications to the CO.
DOPO Delivery Order Project Officer. Defines work requirements,
prepares the Statement of Work (SOW), and monitors contract
performance under indefinite quantity/indefinite delivery
contracts. The DOPO performs duties equivalent to a PO for
specific delivery orders. All technical direction should be
provided to designated contractor managers by the DOPO.
ADOPO Alternate Delivery Order Project Officer. Performs the duties cf
the DOPO in conjunction with, or in the absence of, the DOPO.
WAM Work Assignment Manager. Serves as the on-site technical and
administrative representative of the DOPO. Assists the DOPO in
preparing the Statement Of Work, provides technical clarification
when necessary and reviews work products. Provides
administrative oversight of performance schedules and task
completions.
SOW Statement Of Work. A precise description of the work that ig to
be accomplished and/or the products that are to be delivered by a
contractor. The SOW additionally defines criteria for
acceptance, lists of deliverables, delivery schedules, reporting
requirements and other performance and contractual requirements.
Total work requirements may be subdivided into discrete tasks.
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QUESTION
1. Does EPA train. Contractors?
2. Does EPA give Contractors
Awards/Recognition?
3. Can Contractors be QAT team
members?
4. Can Contractor be invited
to be presenter in QAT?
5. Do all WAMs & DOPOs need PD
Mods?
6. Will R8 staff be consulted
before contract staff is
relocated off-site?
7. How do we communicate
with contract staff?
8. How do we verify contractor
performance and costs?
9. What is the difference
between a WAN and an alternate
DOPO?
10. What training will be
provided for WAMs?
11. Does EPA cover for contract
staff absences?
12. When can SOW be changed
and who changes?
13. Can we provide developmental
assignments for contract staff?
14. What is the working
relationship between EPA and
contractors?
CONTRACT MANAGEMENT GUIDELINES
ANSWER
No, if commercially available
Yes, if EPA specific.
No, letters addressing performance
sent to DOPO & Site Manager.
No, creates appearance or perception
that contractors are making policy
or establishing procedures.
Yes, if presentation is specific to
work assignment.
Yes, to show delegation of
responsibility.
Yes.
Through the SOW, the DOPO and the
site manager.
WAMs to verify T&A and deliverable
to DOPO.
WAM verifies as above; only DOPO or
Alt. DOPO can approve payment or
request changes to SOW from Project
Officer.
Contract Mgmt & Project Officer
training will be offered in July
1992.
No.
As needed WAM requests changes
from DOPO (see special tasks form
attached)
No, contractors must be qualified
for the position. Training must be
provided by contractor.
Impartial, objective and business-
like.
15. Can contractors use the
Fitness Center?
16.-Can contractors belong to
Special Emphasis groups or
participate in Special Emphasis
programs?
No.
No.
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CSC AUDIT ACTION PLAN
LIST OF ACTION ITEMS
EPA REGION VIII
ACTION ITEM
Revise Statement of Work to provide speicific tasks and measurable
criteria
Train staff involved in contracts management
Recertify DOFO and ADOPO
Train Work Assignment Managers
Train SES members
Amend Position Descriptions and Performance Agreements
Amend PD's for DOPO and ADOPO
Amend PA's for DOPO and ADOPO
Amend PA's for WAM's
Develop plan for monitoring contractor progress and costs
Discontinue CSC participation in EPA functions
Inform EPA staff of prohibition
Establish policy on training of contractors
Issue policy on training and participation in TQM by contractors
Review contractor positions and determine whether they should be
filled with EPA staff
Gather data to allow decision on Library
Decide on whether to staff Library with all contractors or all EPA
WHO IS
RESPONSIBLE?
Vigil
Headquarters
Headquarters
Headquarters
Vigil
Vigil
Supervisors
Vigil
Vigil
Vigil
Vigil
Vigil/Wagner
McGraw
STATUS OF
ACTION
Submitted
1-29-92
Completed 11-92
Completed 11-92
Unknown
Completed 3-92
Completed 3-92
In process
In draft
In draft
In draft
In process
DUE
DATE
Complete
Complete
Continuing
FY92 EOY
Complete
Complete
3-31-92
4-30-92
3-26-92
3-26-92
3-26-92
3-27-92
4-17-92
ft
rt
ft!
n
•y
D
n
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Provide identification to assure that contractors are properly identified
as contractors
Provide name badges
Provide signs for contractor work spaces
Develop telephone protocol for contract staff
Reissue telephone book to separate contractors from EPA staff
Discontinue supervision of CSC employees
Advise all staff of prohibition
Institute "Special Task Request" form to assign special tasks
Physically separate CSC from EPA staff
Identify current state of contract staff
Identify contract staff that must remain in EPA space
Define criteria for relocating
Impact on productivity
Cost
Source of funds (Regional Support or Building & Facilities)
Select appropriate option (EPA or CSC provided space)
Make decision
Implement decision
Issue guidance to staff
Issue Region VHI Contract Management Guidelines
Issue Questions and Answers (Q&A) to staff
Establish senior level procurement responsibilities
Designate ARA for Policy and Management as the Senior
Procurement Officer
SES members attend special seminar on their roles
C.Martinez
C.Martinez
99
McCottry
Vigil
Vigil
R. McKenry
Program Mgrs
P&M Team
P&M Team
B. Tipton
P&M Team
P. Riederer
Vigil
Vigil
Vigil
McGraw
Headquarters
Ordered
In process
In process
In draft
Completed
Complete
Draft
Draft
Complete
Unknown
4-30-92
4-30-92
4-30-92
4-30-92
'
3-26-92
Completed
Complete
4-30-92
4-30-92
4-30-92
4-30-92
4-30-92
4-30-92
3-26-92
3-26-92
3-15-92
FY92EOY
Data current as of: MARCH 20, 1992
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REGION VIII
ARCS STUDY IMPLEMENTATION PLAN
II.
TASK
ARCS Program Management
A. Implement contract-specific
cost expenditure targets established by Zone
B. Establish TQM Workgroup to develop and
monitor cost control measures
C. Monitor PM cost targets through
monthly reports
D. Utilize award tee process to
to recofjnize contractor's success
in meeting expenditure target goals
ARCS Capacity and Utilization
•
A. Notify Super fund management
and RPMs of revised fund-lead remedial •
design/remedial action distribution
policy and ensure implementation in Region 8
B. Monitor and assess contractor capacity
Identify capacity shortfall/excess to OARM
and OSWER for appropriate action
(' fUftjiiti.itf ifttuction in construction
RESPONSIBLE
OFFICE/
GSC/SMB
GSC/SMB/ZCO
GSC/SMB/ZCO
Dep. Dir. HWMD
Dep. Dir. HWMD
SMB/ZCO
COMPLETION
PLANNED
Ongoing
1/92
Ongoing
PEB's
(every 6 mos.)
3/1/92
3/30/92
ACTUAL
1/92
Redistributed
directive 3/2/92.
r>
rr
a
»
D
GSC/SMB
9/92
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TASK
RESPONSIBLE
OFFICE/
COMPLETION
PLANNED
ACTUAL
III. ARCS Contract Controls
A. Review and strengthen internal
control documentation for 'ARCS Contract
Administration Process* as follows:
1. Perform independent government cost
estimates in sufficient detail to be used
as a tool for evaluating workplans
1
2. Require comparison of workplans to
independent government cost estimates and
preparation of negotiation memorandum as
prescribed in FAR 15.807
3. Include RCO in negotiations of workplans
with technical support provided by the RPM as
deemed necessary
B. Develop and conduct training for
WAMs, POs. and COs in areas of (develop
training plan):
1. Work assignment development
and processing
2. Invoice review
3. Management of work assignment costs
GSC/SMB/SRB
Ongoing
SMB/SRB/GSC
5/31/92
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TASK
4. Work plan negotiation
5. Cost estimating
C. Utilize cost estimating tools developed
by OSWER
D. Implement Zone procedures for invoice
reviews in accordance with OERR directive
£. Assess and review contract management
vulnerabilities
IV. j ARCS Financial Audits and Review
A. Request incurred cost and close out
audits in accordance with contract
requirements
B. Conduct periodic spot checks of
contractor's financial records and monthly
voucher supporting documentation
t. Develop strategy and implementation
plan that provides coverage at least
every six months
2. Develop strategy and implementation
plan that tracks and monitors results of
spot checks
RESPONSIBLE
OFFICE/
GSC/SMB/SRB
GSC/SMB/SRB
GSC/SMB/SRB
GSC
GSC/SMB
COMPLETION
PLANNED
Ongoing
Ongoing
Ongoing
Ongoing
Ongoing
4/30/92
ACTUAL
-------
TASK
RESPONSIBLE
OFFICE/
COMPLETION
PLANNED
ACTUAL
V. ARCS Award Fee /Voces*
A. Develop options to streamline the current
process
B. Implement new recommendations made by
ARCS Award Fee Task Force
C. Distribute work to contractors for FY92
work assignments for new sites based on overall
performance within the constraints of the contract
D. Involve Zone Management in award fee
process
VI. Management Process and Organization
A. Establish a regional ARCS Council to ensure
successful contract management
B. Develop or enhance existing information
systems to provide needed contract management
information
C. Identify improvement of the ACT system
GSC/SMB
GSC/SMB/SRB
ZCO/SMB/SRB
-\
zco
RA/DRA/Dir.HWMD
GSC/SMB
GSC
2/3/92
Ongoing
Ongoing
Ongoing
03/1/92
05/01/92
3/92
2/3/92
3/18/92
3/10/92 Region 8
ACT up and running.
Some data is entered.
identified some problems
with the system.
Reported them to HO.
-------
TASK
D. Utilize TQM concepts to address contract
management issues
RESPONSIBLE
OFFICE/
GSC/SMB/SRB
COMPLETION
PLANNED
ongoing
ACTUAL
Cost control OAT formed
1/92.
GSC = Grants and Superfund Contracts Branch
8MB = Superfund Management Branch
SRB = Superfund Remedial Branch
ZCO = Zone Contracting Officer
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v
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
J REGION IX
"' **"* 75 Hawthorne Street
San Francisco, CA 94105
March 26, 1992
OFFICE OF THE
MEMORANDUM REGIONAL ADMINISTRATOR
SUBJECT: Contract Management Review
FROM: Daniel W. McGovern ^J&%~. (A)
Regional Administrator
.TO: William K. Reilly .
Administrator
Region 9 shares your concerns on the Inspector General ' s
(IG) criticisms of this Agency's contract management practices.
We also share your commitment to instituting the reforms
necessary to eliminate vulnerabilities and realize long term
improvement in our administrative performance. As a consequence
of the IG's Draft Audit Findings on Region 9's Administration of
CSC Delivery Orders (September 1991) , Region 9 evaluated contract
management practices and took immediate action to address and
correct the issues raised within its purview.
At the exclusion of national Level of Effort contracts
administered by EPA Headquarters, Region 9 is directly
responsible for a total of eighteen contracts. Six are on-site
contracts, including the Computer Sciences Corporation (CSC) ,
which provide for 96 contractor positions. Twelve are off -site
contracts, which comprise Alternate Remedial Contracting Strategy
(ARCS), Emergency Removal Clean-up Services (ERCS) , and several
site-specific contracts. While the IG's draft audit findings
primarily address the CSC contract, our Office of Policy and
Management has identified and addressed contracting issues on a
broader scale. Through a survey of regional Project Officers, we
have examined control and oversight issues for all on-site Region
9 contracts and will address the findings in our contract
management plan.
As you have underscored, many of our contracting liabilities
are characteristic of a need to ensure accountability and an
impartial, "arms length relationship" with our contract
employees. The findings of both the IG's CSC audit and Region
9's internal review reflect two main areas of potential concern.
pertaining to on-site contractors: 1. misconstruing these
contracts as a personal services contract; and 2. inadequately
qualified contractors. For off-site contracts, such as our
Super-fund-related orders, the Region will ensure that the issues
raised will not become vulnerabilities.
Aside from the specific remedies referenced in the attach-
ment, the Region has taken the important step of appointing our
Assistant Regional Administrator as Senior Procurement Officer to
Primed on Recycled Paper
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ensure that all Delivery Order Project Officers (DOPOS) and
Alternate DOPOS are properly trained in contract administration
to carry out their contracting responsibilities. Furthermore, we
have appointed a Region 9 employee to assume the role of CSC
contract coordinator. Toward our long-term objective of assuring
management controls, the Region has initiated the formation of a
Quality Action Team charged with the task of identifying, ad-
dressing, and preventing any vulnerabilities in our contract
management procedures.
Furthermore, we have observed that Agency resources in the
management program elements (P.E.s) have not kept pace propor-
tionately with the significant growth in programmatic P.E.s.
During the past five years in this Region, program growth has
expanded by an increase of forty-two percent, while management
support has expanded by only nine percent. In addition, the
added responsibilities in the areas of contracting, Chief Finan-
cial Officer (CFO), and expansion of information technology and
security needs have placed a premium on sound management practic-
es and oversight. Because of the growth in both resources and
responsibilities, the Regions must significantly stretch to do
the oversight that these changes demand. This could be a source
of vulnerability. For a modest investment in regional management
resources (e.g., finance, contracts) the Agency could reap a
significant assurance of protection.
We recognize that our commitment to improvement in our con-
tract practices will require resources, and a clear dedication of
effort. We look forward to your Office's continued guidance and
support as we make the organizational adjustments necessary to
achieve a contracting process worthy of praise.
Attachment
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ATTACHMENT
CONTRACT MANAGEMENT REVIEW, REGION 9
I. On-Site Contractor Issues and Region 9 Responses
Personal Services
The IG's draft audit cited the following six indicators of
personal services as a focus for regional attention.
1. Contract employees perform their tasks on site.
* While the on-site arrangement for our contractors will be ad-
dressed at the level of EPA Headquarters, we have taken precau-
tions to reduce the appearance of personal services in the
Regional Office. In an effort to differentiate between EPA and
contractor employees, we have clearly marked Contractor cubicles
with the name of their employer in order to identify them as non-
EPA employees.
* We have also instructed CSC ) and one other contractor providing
telephone support to identify themselves as contractors when
placing or receiving calls.
* We have always distinguished contractors from EPA employees in
the telephone directory and will continue this practice.
* We understand that Headquarters' Security and Property Manage-
ment Branch is pursuing an Agency-wide standard on
badge/ identification of contractors. We will promptly follow
through on the implementation of this standard, once issued.
2 . Tools and equipment are furnished by the Government .
* Any tools and equipment furnished are property belonging to an
office cubicle. Upon the contractor's termination, Region 9
retains the tools and equipment on-site. This particular issue
will require close oversight for as long as contractors are hired
to work on-site.
3 . The contractor is performing critical functions .
* Our Information Resources Management Branch is the primary ~-
client of CSC services in Region 9. For the last two years, we
have assigned all critical functions within this Branch, such as
our Local Area Network support functions, exclusively to EPA
employees .
-------
4. Contractors and EPA staff perform comparable services.
J I-/ i-K;-i-.? ''-'JU-' ..•' r . '-*. .
* Our Information Resources Management Branch (IRMB), with over-
sight responsibilities for a majority of CSC contract employees,
has re-written its Statement of Work (SOW) to clearly identify
the tasks appropriate to the contractors' role.
5. The need for the service will last beyond one year.
* The terms of this contract, negotiated for national use,
provide for 5 years of on-gbing support and are not within the
Region's scope of authority to change.
6. Contractor employees are supervised by EPA staff.
* We have discontinued the practice of including contractors in
weekly EPA staff meetings, of recommending hirees to CSC, of
requesting promotions for CSC staff, and of providing CSC Site
Management with individual and personal evaluations of contractor
staff.
* The revision to the CSC SOW mentioned will obviate the need
for constant interaction between EPA and contractor staffs.
Contract Employee Qualifications
An additional concern raised in the Draft CSC audit is the
contractor's lack of qualifications to perform Delivery
Order assignments.
* Our Information Resources Management Branch reviewed the
resumes ofvail CSC contract employees according to Delivery Order
requirements", and approached CSC for reimbursement of personnel
expenses paid for contractors whose qualifications were misclas-
sified. CSC has agreed to credit Region 9 for some of the
discrepancies. We will work closely with EPA Headquarters to
resolve any remaining disagreements.
Other Region 9 Draft Audit Issues
The IG's Draft Audit also cited the following three issues on the
subject of contract monitoring.
1. Delivery Order Project Officers did not monitor
contractor performance adequately.
* CSC monthly progress reports will be reviewed against SOWs for
adherence to the Project Plan as well as the SOW. All Alternate
Delivery Order Project Officers (DOPOs) have received a copy of
the SOW.
-------
* Informal timesheets of contractor hours are being reviewed
weekly by the Alternate DOPOs to make sure that time charges are
appropriate.
* We have separated the Region's CSC Delivery Order into
smaller, more manageable components to facilitate contract
oversight.
* We submitted a request for restitution of charges billed
inappropriately to the Region's Delivery Order. CSC is not in
agreement with the request, however. We are working with Head-
quarters to resolve the disagreement.
2. Delivery Order Project Officers hired, promoted, and
evaluated contractor employees.
* We have issued copies of the draft audit findings and guidance
on the subject to DOPOS, instructing them to refrain from re-
questing CSC promotions and evaluating CSC personnel.
3. Delivery Order Project Officers approved inappropriate
travel and training requests.
* We have excluded contractors from training in areas which
correspond to their expected qualifications.
* We have disallowed the use of our facility for training that
is unrelated to tasks in the SOW.
* We have ensured that Region 9 will not be billed for training
or travel that ±s not specifically supported by the SOW.
Additional Contract Management Issues Which Region 9 is Resolving
In response to the IG's draft findings, the Assistant
Regional Administrator initiated a study to identify the entire
spectrum of contracting strengths and contracting concerns in our
Region. The results revealed some of the same issues identified
in the CSC audit. In addition, the Region has expanded its
efforts in the following ways to address the issues which sur-
faced in our review.
1. Region 9 will re-examine check-out provisions and
security clearance procedures in the SOWs for contract
employees.
2. We recognize that some on-site contract employees are
working with confidential or sensitive information, and
we will reinforce careful oversight for those assign-
ments .
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3. Region 9 employs contract personnel in work activities
that require frontline interaction with the public. We
will ensure that they continue to be clearly identified
as contract personnel.
4. We will reinforce use of the Delivery Order
as the means of communicating service needs to
contract employees.
II. Off-site Contractor Issues and Region 9 Responses
Superfund Alternate Remedial Contracting Strategy Issues
The Agency's Task Force on Implementation of the Superfund Alter-
nate Remedial Contracting Strategy (ARCS) developed thirty-two
recommendations stemming from related contract management issues.
Of the issues raised for Agency attention, two are specific to
Region 9's contracting performance. For each of these issues,
Region 9 is actively pursuing the corresponding Task Force
recommendations.
1. The workload capacity planned for ARCSWEST (pertaining
to Regions 9 and 10) coverage appears to exceed the remedial
workload projected.
* Regions 9 and 10 responded to the Task Force recommendation
with an analysis of current and projected demand for ARCSWEST
services. We jointly concluded that the existing projections of
the proportion of capacity to demand do not result in contract
inefficiencies or excess program management costs. We recommend-
ed continued monitoring of capacity requirements.
2. Government-owned equipment used by contractors at
Superfund sites is inadequately controlled.
* Region 9 was the first to introduce, and is voluntarily
participating in, the Agency's new equipment warehouse pilot
(Eqiuipment Management Facility, or EMFAC). This program will
establish an ARCS equipment pool for contractors to share at a
central warehouse. The storage facility, located in Emeryville
California, is operational and the pilot will run for an eigh-
teen-month period. This pooling arrangement should provide for
more efficient use of equipment and elimination of duplicate
purchases of the same equipment by different contractors.
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KA/iii'A REO 10 -»-»-» HQ-ADM ©002/007
United States Region 10 Alaska
Environmental Protection 1200 Sixth Avenue Idaho
Agency Seattle WA 98101 Oregon
_ _^ _ Washington
MAR 2 6 1992
Reply to
Attn of: MD-141
MEMORANDUM
SUBJECT: Region 10 Contracts Management Assessment
FROM: Dana A. Rasraussen
Regional
TO: William K. Reilly
Administrator
This memorandum responds to your memorandum dated March 10,
1992, regarding contracts management in EPA. Specifically you
asked for present and potential problems and a proposed action
plan for addressing these problems.
Present and Potential Problems: Most of the problems I have
identified in Region 10 are similar to those encountered in other
Agency locations, specifically:
1. The regional culture sometimes places contractors in a
co-worker mode.
2. Additional training is necessary for Technical Task
Leaders and others who interact with contractors daily.
3. Statements of Work are inconsistently detailed allowing
for too much leeway in performance.
4. The lack of contracts oversight resources both nationally
and regionally has resulted in an untimely decision process.
5. The uncertain budget approval process has caused "start-
of-year" problems.
6. Contractor's Property Management accountability for
government-furnished equipment is not consistently adequate.
7. Contractor conflict of interest issues have been raised
with some of our Superfund contracts
8. Audit support has not been able to handle the Superfund
Contract workload.
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-2-
Action Plan: Considerable work has already been done on the
above problems and upon receipt of Christian Holmes' February 28
memorandum. Jerry Emison and I directed that efforts to correct
the remaining problems be elevated to highest priority. Our
proposed Action Plan therefore includes the continuation of
existing efforts and a new effort specifically aimed at the
recently raised concerns:
1. For the onsite Contractors, our ARA has proposed an
Action Plan to quickly implement necessary changes (this
plan and my response to it are attached). The effort
includes immediately implementing Mr. Holmes directives and
placing one of our Branch Chiefs on a 90-day detail to
follow through on the long term items.
2. The proposed Action Plan is dynamic and open-ended. We
will aggressively seek out problem areas and respond quickly
if the HQ Contracts Task Force raises new issues.
3. In the Superfund arena, an ARCS Management Team has been
formed that continuously monitors those contracts and works
proactively to improve our processes.
4. Our Contracting Officers and Project officers are
carrying over some of the improvements made in ARCS
contracts to the other superfund contract programs.
5. A team of lawyers and Contracting Officers is actively
addressing Conflict of Interest cases.
6. The Property Management systems in Region 10 will be
examined and updated to complete compliance status during
the next two months.
Contractors have performed effectively for EPA and the
public over the years and provided excellent value for the money
we've paid. I assure you that I will personally oversee the
current concerns to ascertain that we continue to make
appropriate, legitimate use of contractors in the future.
Attachments
cc: P. Henry Habicht II
Deputy Administrator
Christian R. Holmes
Acting Assistant Administrator/OARM
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1U ->-r-» Htl'AI>M
United Slates Region 10 Alaska
Environm:-, iial Prowciion "200 Sixth Avenue Idaho
Agency Scanic WA 96101 Oregon
Washington
>EPA
March 13, 1992
Reply to
Attn of: MD-141
MEMORANDUM
SUBJECT: Contract Management in EPA
Region 10 Action Plan
FROM: Barbara McAllister
Acting Assistant Regional Administrator
for Policy and Management
TO: Dana A. Rasmussen
Regional Administrator
Gerald A. Emison
Deputy Regional Administrator
In response to the February 28, 1992, memorandum from
Christian R. Holmes, it is clear that additional prompt, decisive
action must be taken in Region 10 to support the overall Agency
effort to improve Contract Management. Therefore 1 recommend the
following actions in response to Mr. Holmes specific comments:
l. Management Accountability. I recommend that Region 10's ARA
be appointed the "Senior Procurement Officer." As Acting ARA, I
will personally coordinate with the Headquarters Standing
Committee described in the memo to schedule training for all
Region 10 SES staff as required.
2. clear Distinction Between Contractors and EPA. As the memo
states this issue involves "deeply embedded attitudes" and "will
require a long term effort" to correct. We currently have 4
major contractors in the Region: Computer Sciences Corporation
(CSC)—29 staff; Labatt-Anderson—15 staff; ESAT (ICP)— 37 staff;
and Merman Development Corporation—6 staff. Because of the
importance and scope of the necessary effort, I propose to
appoint Jim Peterson, the current CSC Delivery order Project
Officer, to a special detail for 90 days to plan, recommend, and
implement actions which will address short term and long term
change.
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03.27/92 09:41 FAX 206 553 1809 RA/EPA REG 10 ---» HQ/ADM ElOOS 007
-2-
In response to Mr. Koines specific directions in this area of
concern:
We will immediately direct the Contractor site managers
to have their employees begin wearing identification
badges within 60 days; to have all Contractor work
space clearly identified; and to identify themselves as
Contractors in all ambiguous situations.
Jonell Allamano and Jin Peterson will prepare a Guide
sheet on proper interaction with contractors. The
initial Guide will be developed within 2 weeks and will
address allowable training and travel as well. I
recommend that using this Guide you then meet with the
Region 10 managers to stress the importance of proper
contract management.
When the initial Guide is ready we will send letters to
the Contractor site managers reiterating the procedures
described in the Guide.
Jim Peterson will begin an immediate study to determine
whether any current contract assignments violate the
ban on personal services. It is anticipated that this
study will suggest additions/changes to the initial
Guide.
- He will also lead a study on the possibilities of
physically segregating contract workspace from EPA
employee workspace.
These longer-term studies will involve cooperative
efforts with the EPA groups where Contractors are
performing work. The goal will be to continue to
accomplish the work within proper Contractor/Agency
relationships. Jim will produce a summary report at
the end of the 90 day detail describing the study and
recommending additional actions as necessary.
3. Contract Policy Review. While this item will be largely
addressed at the Headquarters level, I will work closely with the
Office of Administration to provide Region 10 input. 1 have
directed Jim Peterson to evaluate whether a training program is
necessary to assure that there is a consistent regional posture
throughout all of the regional staff in working with contractors.
4. Organizational Accountability. This item speaks to the
Organizational Accountability of Region 10 as a whole and will be
orchestrated at the Headquarters level. The purpose of this item
is to inform us that if we fail to follow national guidelines,
our ability to use contractors and our procurement authorization
will be curtailed.
5. Elevation of the Agency's Procurement Functions. This item
will be coordinated at the HQ level. We will continue to work
closely with our HQ counterparts to ensure procurement integrity.
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te i • t» *.
iOb ooJ i»uy RA/EPA REG 10 -»-»-» HQ/ADM ®006-'007
-3-
Contractors have performed effectively for EPA and the
public over the years and provided excellent value for the money
we've paid. I assure you that I will personally oversee the
current concerns to ascertain that we continue to make
appropriate, legitimate use of contractors in the future.
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10
•»-»-» HQ/ADM
® 007 -'007
Unitad States
Environmental Protection
Agency
Region 10
1 200 &*tn Avonue
Seattle WA9S101
Alaska
Idario
Oregon
Washington
MAR 1 8 1992
Reply to
Attn of: MD-141
MEMORANDUM
SUBJECT:
FROM:
TO:
Contracts Management in Region 10 ,
Action Plan
/s/Dana A. Rasmussen
Dana A. Rasmussen
Regional Administrator
, „ » «„ • /s/Qerald A. Emison
Gerald .A. Emison «-»iw»wu
Deputy Regional Administrator
Barbara McAllister
Acting Assistant Regional Administrator
for Policy and Management
Thank you for your suggested Region 10 Contracts Management
Action Plan dated March 13, 1992 which responds to Christian R.
Holmes' February 28, 1992, memorandum. We whole-heartedly agree
that prompt, decisive action must be taken in Region 10 to
support the overall Agency effort.
Without detracting from the many fine contractor work
products delivered to EPA, we believe that as a Federal Agency we
have a special trust to safeguard the public's money and to
follow all laws and regulations. We concur with the
recommendations you have made in the Action Plan including:
.Detailing Jim Peterson to implement the plan
.Developing a Region 10 Contracts policy
.Requiring contractors to properly identify themselves
.Preparing a Contracts Management Guide
.Eliminating any situations which appear to be
"Personal Services"
.Studying space reorganizations to segregate
contractors
.Studying and implementing any additional training
needs
Furthermore we invite you to involve us personally to effect
any necessary changes. Please keep us informed on a regular
basis of your efforts to implement the Action Plan.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR 27 1992
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
ent
MEMORANDUM
SUBJECT: Contract Man
FROM: Don R. C
Assistant AdmThist
TO: William K. Reilly
Administrator
As requested in your memo of March 10, I am submitting an
assessment of all present or potential contract management
problems in OSWER, as well as our proposed plan to address them.
Because the programs in OSWER are so highly leveraged with extra-
mural dollars, and have been subject to such intense scrutiny, we
have undertaken a number of internal reviews and established
significant internal controls for contracts management across all
programs. We will continue to need mission support type of
contracts, and are committed to continuous improvement in the
management of these contracts.
Many aspects of the Superfund program have been declared as
Agency material weaknesses under FMFIA. Implementation plans for
corrective actions have been developed, and are being implemented
and routinely monitored (Attachment 1). The ARCS review resulted
in very comprehensive recommendations, and we have developed an
implementation plan for these (Attachment 2). The 30-day review
also generated some recommendations for improving certain aspects
of SF contracts management, and these recommendations are also
being implemented (Attachment 3). The Office of Solid Waste
(OSW), in response to an OIG investigation in 1988, has also
instituted a number of internal controls (Attachment 4) to ensure
proper management and evaluation of contracts. The Office of
Underground Storage Tanks (OUST) was the subject of an in-depth
"Blue Team" review by PCMD in January 1991, and a follow-up
review in January 1992. As a result of these reviews, a number
of internal controls were established or upgraded (Attachment 5).
I have been meeting with my office directors to discuss a
comprehensive approach to your call for re-examination of
existing contracts and management practices. Although our
programs have made significant improements in contracts
management over the past few years, I share your concern that
the EPA culture may be fostering certain attitudes that need to
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- 3 -
In preparing this response, and establishing the QAT and
internal review schedule, I have compiled extensive information
on all of the contracts and internal controls in place in OSWER.
Contract management procedures, manuals and guidance currently in
use in OSWER will be reviewed and updated as part of the internal
review. In addition to the Senior Procurement Official, I intend
to establish a high level position to oversee contract management
activities across all of OSWER.
There are several other issues that I have identified as
agency-wide issues (Attachment 7). These are issues that are
critical to improving the both the way we manage contracts and
some of the public perceptions of the agency. These issues may
be best handled by the Standing Committee on Contracts
Management.
We are continuing to provide information on OSWER partici-
pation in a number of contracts that have been identified as
the subject of upcoming hearings or investigations. We have
identified the amount of our investment in these contracts, and,
as appropriate, provided information on the impact of terminating
these contract vehicles.
In summary, there is a high level of commitment across OSWER
to continuous improvement in pur management of contracts. We are
highly leveraged with extramural dollars, and recognize the
additional responsibility that comes with these resources. Many
internal controls are already in place, and we are working to
empower our workforce, both here and in the Regions, to get the
best possible value for each dollar spent. I will keep you
informed of our progress.
Attachments
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eg-
Attachment 1
Attachment 0
PART TWO; DESCRIPTION OF UNCORRJCTZD MATIRIAL W1AKNISS1S
CATS Track j nf vnaiH^r1 ; Not Assigned
Assessable Unit/AU f; OERR/HSED/1901
Title of Material Weakness: Contract Lab Program; Improvements of CLP Audi
Corrective Action Follow-up Tracking Procedures
Description of Material Weakness and its Impact on Aqancv Operations: As part
of the CLP's Quality Assurance/Evidentiary Audit (QA/EA) program, the
Analytical Operations Branch in coi'mev,Lit-m with EMSL-LV, NEIC, the CLP
Technical Project Officer and CMD monitors and evaluates the performance of CLi
laboratories' performance on their contracts. Key components of the QA/EA
program are: Performance Evaluations Sample Program, Data Package Audit
Program, Quality Assurance On-Site Program, and the Evidentiary Audit Program.
Each of these components generate an audit report which documents the
deficiencies in performance which the contractor will need to address. This
workplan documents a timetable to be met to evaluate the effectiveness of the
CLP audit corrective action follow-up tracking procedures.
Work Plan »; 01392
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
f ;.nistrative Activity /Program Activity: Program Activity
Year Identified; 1991
Source of Discovery: DIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: In progress
Targeted Correction Date in Last Year's Report: N/A
Current Target Date; In progress
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Act ions /Events :
M/S # MILESTONE TITLE ORIG FLAN ACTUAL DOLLAR/FTE
M OCI INITIATE EFFECTIVENESS REVIEW 09/01/91 09/01/91 09/01/91
D-7
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HttacnmenCi
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTBP MATERIAL WEAKNESSES
B. Planned Actions/Events (Short-Tann - Next 12 Months):
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLAR/FTE
M 002 COMPLETE EFFECTIVENESS REVIEW 09/01/92 09/01/92 / /
C. Planned Actions/Events (Longer Term);
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLAR/FTE
M 003 BRIEF MANAGEMENT OF FINDING 10/01/92 10/01 92 / /
M 004 REVISE PROCEDURES 02/01/93 02/01/93 / /
M 005 IMPLEMENT REVISED PROCEDURES 03/01/93 03/01/93 / /
M 006 MONITOR EFFECT OF MOD. PROC. 03/01/94 03/01/94 / /
M 007 VERIFICATION OF COMPLETION 06/01/93 06/01/93 / /
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Report is still confidential as u^
09/30/91 and will not be released until mid-October. At that time, a nv <
definite workplan will be prepared and will be outlined in Ql CATS updc.
o December 31, 1991 Status Update: Effectiveness review in progress
scheduled for completion in September 1992.
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-8
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Attachment 1
•^ Attachment D
PART TWO; DBSCRIPTION OF UNCORRECTED MATERIAL WSAlQgESSISS
CATS Track 3 nij u
-------
Attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 005 START CORRECTIVE ACTION 10/30/92 10/30/92 / /
IMPLEMENT
M 006 COMPLETE CORRECTIVE ACTION 12/30/92 12/30/92 / /
IMPLEMENT
M 007 VERIFICATION OF COMPLETION 12/30/92 12/30/92 / /
C. Planned Actions/Events (Longer Term);
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mor<
definite worlcplan will be prepared and will be outlined in Ql CATS update
o December 31, 1991 Status Update: No activity occurred during this
quarter. Work will commence in February.
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-10
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r o •
attachment 1
Attachment O
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
cATS Tracking Number; Not Assigned
Assessable Dnit/AO f: OERR/HSED/1901
Title of Material Weakness: Contract Lab Program: Development of National
Guidance on Use of Minimum Required Performance Evaluation Samples in SF
Description of Material Weakness and its Impact on Agency Operations; The
Analytical Operations Branch through it's Quality Assurance Technical Support
Lab. (QATS) has developed a variety of multimedia, multi-concentration
Performance Evaluation Samples (PES), which can be used by the regions as
single or double-blind PES. They are in the process of developing indicator
compounds to prevent cheating on ampule PE samples, a wide-spread problem in
EPA programs. They are working with the regions to develop real world matrix
double blind solid PE samples. While praised for these efforts, both the OIG
and the FMFIA audits noted lack of uniformity in these efforts among the
Regions. It was recommended that national guidance was needed to ensure
uniformity in a minimum required use of these materials.
Work Plan f: 01391
Functional Category in Statistical Summary: Program Management
ippropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
X Identified; 1991
Source of Discovery; OIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: 06/01/94
Targeted Correction Date in Last Year's Report; N/A
Current Target Date; 06/01/94
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events:
M/S # MILESTONE TITLE PLAN ORIG ACTUAL DOLLARS/FTE
M 002 QATS LAB SET UP TO PRODUCE C2/01/89 02/01/89 02/01/89
PES
D-ll "
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attachment!
Attachment D
PART TWO; DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE PLAN ORIG ACTUAL DOLLARS/FTE
M 003 PEACTOOLS DEV., ASSISTS PE 01/01/91 01/01/91 01/01/91
SCORING
B. Planned Actions/Events (Short-Term - Next 12 Months):
M/S I MILESTONE TITLE PLAN ORIG ACTUAL DOLLARS/FTE
M 004 WORKGROUP SET UP DEVEL. PE 10/01/91 10/01/91 / /
GUIDANCE
M 005 FINAL REPORT ON INDICATOR 10/03/91 10/03/91 / /
COMPOUNDS
M 006 WORKSHOP ON SITE-SPECIFIC 04/01/92 04/01/92 / /
QA MATERIAL
M 007 REGIONAL PE REPOSITORIES 06/01/92 06/01/92 / /
SET UP
M 008 MULTI-LAB STUDY OF INDICATOR 06/01/92 06/01/92 / /
COMPOUNDS
M 009 QATS REGION 10 WORK ON SPIKED 09/01/92 09/01/92 / /
DOUBLE BLINDS
C. Planned Actions/Events (Longer Term):
M/S # MILESTONE TITLE PLAN ORIG ACTUAL DOLLARS/FTE
M 010 REGION 10 AND EMSL-LV WORK 10/01/92 10/01/92 / / •
ON DOUBLE BLINDS
M Oil DRAFT GUIDANCE ON UNIFORM 10/01/92 10/01/92 / /
PE USE
M 012 FINAL GUIDANCE DOCUMENT 10/01/92 10/01/92 / /
ON PES USE
M 013 QATS DEVEL. SITE CATEGORY 02/01/94 02/01/94 / /
PES
M 014 VERIFICATION OF COMPLETION 06/01/94 06/01/94 / /
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
D-12
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pg- 1
attachment 1
Attachment D
PART TKO; DBSCRIPTION OF UNCORMCTTO MATERIAL KEAKNISSKS
o September 30, 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mor<
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31, 1991 Status Update: Final report on indicator compounds
was reported.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 004 WORKGROUP SET UP 10/01/91 10/01/91 10/01/91
DEVEL. PE GUIDANCE
M 005 FINAL REPORT ON INDICATOR 10/03/91 10/03/91 10/03/91
COMPOUNDS
o March 31. 1992 Status Update:
o June 30. 1992 Status Update:
o September 30. 1992 Status Update:
D-13
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Pg- 8
attachment 1
Atttciaent D
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Tracking Number: Not Assigned
Assessable Unit/AU i; OERR/HSED/1901
Title of Material Weakness; Contract Lab Program: Laboratory Self-Screenir
for Contract Compliance
Description of Material Weakness and its Impact on Agency Operations: One of
the recommendations of the CLP FMFIA audit was to "shift greater responsibilit
for data accuracy and timeliness to contract laboratories." This workplan is
for turning over the responsibility of "Contract Compliance Screening" to the
contractor labs, instead of being performed by EPA/SMO. In addition, a QA
plan/audit process must be established for EPA to assure the integrity of the
lab self-CCS.
Work Plan •; 01383
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: DIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: 01/01/94
Targeted Correction Date in Laat Year's Report: N/A
Current Target Date; 01/01/94
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short-Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/F'
M 001 DIST. OF SOFTWARE FOR CCNT. 06/15/S2 06/15/92 / /
• COM. SC.
D-14
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PS-
attachment 1
Attachaaat 0
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
C. Planned Actions/Events (Longer Term):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 002 IMPL. OF AG. STND. FOR DATA 10/01/92 10/01/92 /. /
DELIV.
M 003 MOD. CONTRACTS FOR SELF-CCS 10/01/92 10/01/92 / /
M 0(M IMPL. LAB SELF CCS/EPA 10/01/93 10/01/93 / /
OVERSIGHT
M 005 VERIFICATION OF COMPLETION 01/01/94 01/01/94 / /
Validation Process to be Used; To be determined.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update; Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a more
definite workplan will be prepared and will be outlined in Ql CATS update.
o December 31. 1991 Status Update: No activity occurred during this
quarter. Work due to commence in June.
o March 31. 1992 Status Update:
c June 30, 1992 Status Update;
o September 30, 1992 Status Update:
D-15
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attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTZD MAT»RIAL WEAKKISS1S
CATS Tracking Number: Not Assigned
Assessable Onit/AU f; OERR/HSED/1901
Title of Material Weakness: Contract Lab Program: Ensure Top Management
.Support for SAS Workgroup
Description of Material Weakness and its Impact on Agency Operations; The goal
of this project is to improve Special Analytical Services to address AOB
'concerns regarding laboratory performance and payment to laboratories for non-
compliant data.
Work Plan »: 01390
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery; DIG Audit: FMFIA Audit of the CLP (Willis Greenstree1"
Repcrt)
Original Target Correction Date: 12/15/92 -
Targeted Correction Date in Last Year's Report; N/A
Current Target Date: 12/15/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. ' Planned Actions/Events (Short-Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 CONFERENCE CALL 01/22/92 Cl/22/92 / /
M 002 WG REPORT ON STAGE I 02/15/92 02/15/92 / /
ACTIVITIES
M 003 FIRST STAGE II MEETING 03/31/92 03/31/92 / /
M.OC4 STAGE II MEETING REPORT 04/30/92 04/30/92 / /
D-16
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attachment 1
Attachment D
PART TWO; DESCRIPTION OF OKCORRECTED MATERIAL WEAKNESSES
/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 005 CONFERENCE CALL 06/15/92 06/15/92 / /
M 006 SECOND STAGE II MEETING 07/30/92 07/30/92 / /
M 007 WG REPORT ON STAGE II 09/15/92 09/15/92 / /
ACTIVITIES
C. Planned Actions/Svert; (Longer Term);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 008 BRIEF HSED DIRECTOR 10/30/92 10/30/92 / /
M 009 VERIFICATION OF COMPLETION 12/15/92 12/15/92 / /
Validation Procasa to be Used; To be determined.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update; Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mor
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31, 1991 Status Update: No activity occurred during this
quarter. Work due to commence in January 1992.
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-17
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Attachment 0
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Track.1* nij utmi*>er ; Not Assingned
Assessable Onit/AU i: OERR/HSED/1901
Title of Material Weakness; Contract Lab Program; Implement Non-CLP Tracking
System for Fund-Lead activities
Description of Material Weakness and its Impact on Agency Operations: The non-
CLP Tracking System is to track and monitor non-CLP analytical service
activities as required in CSWER Directive 9240.0-2.
Work Plan I: 01385
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element : Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: OIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: 02/15/93
Targeted Correction Date in Last Year's Report; N/A
Current Target Date; 02/15/93
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Act ions /Events: None
B. Planned Actions/Events (Short-Term - Next 12 Months) :
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 INITIATE SYSTEM IMPLEMENTATION 10/01/91 10/01/91 / /
M 002 COMPLETE SYSTEM IMPLEMENTATION 09/30/92 09/30/92 / /
C. Planned Actions/Events (Longer Term)-;"
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
D-18
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Ffe- J.-I
attachment 1
Attachment D
PART THO: DESCRIPTION OF ONCORR1CTED MATERIAL WEAKNESSES
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 003 DRAFT AICR REPORT ON SYSTEM 11/30/92 11/30/92 / /
M 004 FINALIZE AICR REPORT ON SYSTEM 01/15/93 01/15/93 / /
M 005 VERIFICATION OF COMPLETION 02/15/93 02/15/93 / /
Validation Proce»« to be Used: To be determined.
Correctiv* Action Plan Status Updates:
o September 30, 1991 Status Dpdate: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mor<
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31. 1991 Status Update: Implementation of the non-CLP
tracking system, developed to track and monitor non-CLP analytical
service activities has been initiated in nine regions.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 INITIATE SYSTEM 10/01/91 10/01/91 10/01/91
o March 31, 1992 Status Update:
June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-19
-------
attachment 1
Attachment D
PART TWO: DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
CATS Trackj nij MumH^r; Not Assigned
Assessable Unit/AU f: OERR/HSED/1901
Title of Material Weakness Contract Lab Program; Consider Usefulness of
GOCO's to Provide Analytical Services
Description of Material Weakness and its Impact on Agency Operations: A
National Task Force was established in April 1991 to develop a long-term
strategy for the delivery of analytical services. The task force determined
that three workgroups were necessary for the initial stages of the strategy
development. These workgroups were established to provide assistance to the
task force in issue definition, data gathering, analysis on collected data; anc
presentation of the findings on topic areas. The task force will then identify
options or alternative delivery systems for analytical services. The
alternatives will be evaluated utilizing criteria that will include pros and
cons of each of the alternatives. It is anticipated that the usefulness of
GOCOs will be evaluated in this process.
Work Plan »: 01394
Functional Category in Statistical Summary: Program Management
Appropriation/Proaram Element: Superfund; 68/20X8145/TFAY9A
.Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: DIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: 03/30/93
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 03/30/93
Reason for Change in Date(s); N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short-Term - Hext 12 Months):
D-20
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Pg. 15
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S I MILESTONE TITLE
M 001 TASK FORCE SCOPE
ALTERNATIVE
M 002 TASK FORCE EVALUATE
ALTERNATIVES
M 003 TASK FORCE RECOMMEND
ALTERNATIVE
ORIG
04/15/92
06/30/92
07/30/92
M 004 STEERING COMMITTEE REVIEW 08/15/92
ALTERNATIVE
M 005 CONCURRENCE ON ALTERNATIVE 08/30/92
M 006 DELIVERY OF ANALY.SERV 09/30/92
STRAG COMPL
PLAN ACTUAL
04/15/92 / /
06/30/92 / /
07/30/92 / /
08/15/92 / /
08/30/92 / /
09/30/92 / /
DOLLARS/FTE
DOLLARS/FTE
C. Planned Actions/Events (Longer Term):
M/S I MILESTONE TITLE ORIG PLAN ACTUAL
M 007 VERIFICATION OF COMPLETION 03/30/93 03/30/93 / /
Validation Process to be Used: To be determined
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update; Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a more
definite workplan will be prepared and will be outlined in Ql CATS update.
o December 31, 1991 Status Update: No activity occurred during this
quarter. Work scheduled to commence in April 1992.
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-21
-------
pg. ID
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Tracking Number; Not Assigned
Assessable Dnit/AU i: OERR/HSED/1901
Title of Material Weakness: Contract Lab Program: Study Potential Conflict o
Interest issues in Delivery of Analytical Services Contract
Description of Material Weakness and its Impact on Agency Operations; A
National Task Force was established in April 1991 to develop a long-term
strategy for the delivery of analytical services. The task foiue ueLerruined
that three workgroups were necessary for the initial stages of the strategy
development. These workgroups were established to provide assistance to the
task force in issue .definition, data gathering, analysis on collected data/ an
presentation of the findings on topic areas. The task force will then identif
options or alternative delivery systems for analytical services. The
alternatives will be evaluated utilizing criteria that will include pros and
cons of each of the alternatives. It is anticipated that conflict-of-interest
issues will be part of the evaluation criteria.
Work Plan »: 01395
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: -Program Activity
Year Identified: 1991
Source of Discovery: DIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: 12/30/92
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 12/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short-Term - -Wext 12 Months):
M/S # MILESTONE TITLE ORI3 FLAN ACTUAL DOLL' 'FT:
D-22
-------
Pfe- A'
attachment 1
Attachment O
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT
M 001 TASK FORCE SCOPE ALTERNATIVE 04/15/92 04/15/92 / /
M 002 TASK FORCE EVALUATE 06/30/92 06/30/92 / /
ALTERNATIVES
M 003 TASK FORCE RECOMMEND 07/30/92 07/30/92 / /
ALTERNATIVE
M 004 STEERING COMMITTEE REVIEW 08/15/92 08/15/92 / /
ALTERNATIVE
M 005 CONCURRENCE ON ALTERNATIVE 08/30/92 08/30/92 / /
M 006 DELIVERY OF ANALYT SERV 09/30/92 09/30/92 / /
STRAG COMP
C. Planned Actions/Events (Longer Term):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT:
M 007 VERIFICTAION OF COMPLETION 12/30/92 12/30/92 / /
Validation Process to be Used: To be determined
r 'rective Action Plan Status Updates:
o September 30. 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mor<
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31, 1991 Status Update: No activity occurred during this
period. Work scheduled to commence in April 1992.
o March 31. 1992 Status Update:
i
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-23
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF DNCORRECTED MATERIAL WEAKNESSES
CATS Tracking N*""^a3r: Not Assigned
Assessable Onit/AU •; OERR/HSED/1901
Title of Material Weakness; Contract Lab Program: Review Paperwork Burden in
the CLP to Eliminate Duplicate and Unnecessary Paperwork
Description of Material Weakness and its Impact on Agency Operations; In
October 1991, AOB tasked Sample Management Office to reduce duplicate and
unnecessary paperwork related to the CLP. This task has resulted in a 50%
reduction in paper at the WIC related to the CLP. In 1990, AOB initiated a
similar request to NEIC, which resulted in reducing the CLP data package
paperwork. In October 1991, AOB requested NEIC to reassess the documentation
needed for evidentiary purposes. AOB has also begun to implement a new
analytical service, which uses electronic data largely in place of hardcopy
data. AOB will review other sources of paperwork burden related to accessing
analytical services, quality assurance, and data review.
Work Plan »: 01414
Functional Category in Statistical Summary; Program Management
Appropriation /Program Element ; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified: 1991
Source of Discovery: OIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: In progress
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: In progress
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Act ions /Events : None
B, Planned Actions/Events (Short-Term - Next 12 Months) :
M/S * MILESTONE TITLE ORIG PLAN ACTUAL DCLLARS/FTE
D-24
-------
attachment 1
, Attachment D
PART TWO: DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
ACTUAL DOLLARS/FTE
DOLLARS/FTE
M/S # MILESTONE TITLE ORIG PLAN
M 001 EVALUATE PAPERWORK REDUCTION / / / / / ,
OPPORTUNITIES
M 002 IMPLEMENT RECOMMENDATIONS / / / / / ,
M 003 COMPLETE CORRECTIVE ACTION / / / / / ,
IMPLEMENTATION
C. Planned Actions/Events (Longer Term);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 004 COMPLETE TQM PILOT 10/30/92 / / / /
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a more
definite workplan will be prepared and will be outlined in Ql CATS update.
o December 31. 1991 Status Update: Completion of this workplan
requires additional resources. We are committed to completion of the
workplans and expect to have resources available in the near future.
Specific milestone dates will be provided by October 15, 1992.
o March 31, 1992 Status Update;
o June 30, 1992 Status Update:
o September 30. 1992 Status Update:
D-25
-------
pg-
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Tracking N\*T"**er: Not Assigned
Assessable Unit/AU f: OERR/HSED/1901
Title of Material Weakness: Contract Lab Program: Consider Use of a Regional
Analytical Budget to Act as an Incentive to Collect only Needed Data
Description of Matarial Weakness and its Impact on Aoancv Operations: in 1986,
the Agency instituted the DQO process to plan for the collection of
environmental data, and which results in an optimized sampling and analysis
plan. The current use of the DQO process already ensures that only needed data
is collected, regardless of where the analytical services budget is located.
AOB can currently provide the Regions with information on what they are
spending, on a site-specific basis, since all CLP invoice processing is on a
site-specific basis as needed for cost recovery purposes. AOB will evaluate
the pros and cons of Regional analytical services budgets.
Work Plan »: 01410
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: OIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date: In progress
Targeted Correction Date in Last Year's Report: N/A
Current Target Date; In progress
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events; None
B. Planned Actions/Events (Short-Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 INITIATE EVALUATION STUDY / / / / / /
D-26
-------
attachment 1
Attachment O
PART TWO: DESCRIPTION OF UKCORRZCTZD MATERIAL WKAKMISSES
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 002 DETERMINE OPTIONS / / / / / /
M 003 MAKE RECOMMENDATIONS / / / / . / /
M 004 CONSULT WITH ASAC / / / / / /
M 005 DRAFT EVALUATION REPORT / / / / / /
M 006 FINAL EVALUATION REPORT / / / / / /
M 007 IMPLEMENT RECOMMENDATIONS / / / / / /
M 008 COMPLETE CORRECTIVE ACTION / / / / / /
IMPLEMENTATION
M 009 VERIFICATION OF COMPLETION / / / / / /
C. Planned Actions/Events {Longer Term):
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
September 30, 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a more
definite workplan will be prepared and will be outlined in Ql CATS update.
o December 31, 1991 Status Update: Completion of this workplan
requires additional resources. We are committed to completion of the
workplans and expect to have resources available in the near future.
Specific milestone dates will be provided by October 15, 1992.
o March 31. 1992 Status Update;
o June 30. 1992 Status Update:
o September 30, 1992 Status Update:
D-27
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
CATS Track?"'! MmnK^r; Not Assigned
ssable Unit/AU t: OERR/HSED/1901
Title of Material Weakness ; Contract Lab Program: Develop Process to Insure
Laboratories are not Paid for Unusable Data or Data in Error
Description of Material Weakness and its Impact on Aoencv Operations; In 1988,
AOB incorporated liquidated damages provisions into CLP contracts which ensure
that full payment is not made for non-compliant data. In addition, AOB has
instituted a process by which further deductions can be made than allowed by
liquidated damages (called the "Reduced Value" process) . AOB will review its
present systems for effectiveness and revise if necessary.
Work Plan *; 01409
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element : Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: OIG Audit: FMFIA Audit of the CLP (Willis Greenstre^
Report)
Original Target Correction Date: In progress
Targeted Correction Date in Last Year' a Report : N/A
Current Target Date: In progress
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. - Completed Act ions /Events : None
B. Planned Act ions /Events (Short-Term - Next 12 Months) :
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS /FTE
M 001 EVALUATE CURRENT SYSTEM / / / / / /
M 002 OBTAIN DATA ON NON-COMPLIANCE / / / / / /
M 003 IMPLEMENT CHANGES / _i II ; /
D-28
-------
attachment 1
Attachment 0
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE ORIG " PLAN ACTUAL DOLLARS/Fl
M 004 COMPLETE CORRECTIVE ACTION / / / / / /
IMPLEMENTATION
M 005 VERIFICATION OF COMPLETION / / / / / /
C. Planned Actions/Events (Longer Tern);
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mor
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31. 1991 Status Update; Completion of this workplan
requires additional resources. We are committed to completion of the
workplans and expect to have resources available in the near future.
Specific milestone dates will be provided by October 15, 1992.
o March 31, 1992 Status Update:
o June 30, 1992 Status Update:
September 30, 1992 Status Update:
D-29
-------
atttachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTEP MATERIAL WEAKNESSES
CATS Tracking Nitw|*^r : Not Assigned
Assessable Unit/AU t; OERR/HSED/1901
Title of Material Weakness: Contract Lab Program; Investigate Use of
Performance Bonds to Increase Laboratory Accountability
Description of Material Weakness and its Impact on Agency Operations: CLP
contracts are IFB contracts. IFBs were determined to be the most appropriate
contracts for acquiring labOiaLwry services on an "as needed" basis. In mid-
1990, AOB was informed by CMD that performance bonds are for construction
contracts and not appropriate for IFB contracts. AOB will again seek an
interpretation from CMD and evaluate the pros and cons requiring laboratories
to post performance bonds.
Work Plan »: 01408
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element ; Superfund; 68/20X8145/TFAY9A
j^rftn^ nistr at ivc Activity/Proof*"* Activity; Program Activity
Year Identified; 1991
Source of Discovery: DIG Audit: FMFIA Audit of the CLP (Willis Greenstreet
Report)
Original Target Correction Date : In progress
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: In progress
Reason for Change in Date(s); N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short -Term - Next 12 Months) :
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS /FT!
M 001 OBTAIN CMD POSITION ON /' / / / / /
APPLICABILITY
M 002 EVALUATE PROS AND CONS /_ / / / / /
D-30 "
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT!
M 003 DRAFT AICR / / / / / /
M 004 FINAL AICR / / / / / /
M 005 COMPLETE CORRECTIVE ACTION / / / / / /
IMPLEMENTATION
M 006 VERIFICATION OF COMPLETION / / / / / /
C. Planned Actions/Events (Longer Term);
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mon
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31, 1991 Status Update: Completion of this workplan
requires additional resources. We are committed to completion of the
workplans and expect to have the resources available in the near
future. Specific milestone dates will be provided by October 15,
1992.
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update;
D-31
-------
ffa • -
attachment 1
Attachment D
PART TWO; DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
T an
Not Assigned
Assessable Unit/AU i: OERR/HSED/1901
Title of Material Weakness: Contract Lab Program; Improve Communications wit!
Regions on Non-Compliance with CCS Requirements
Description of Material Weakness and its Impact on Agency Operations; AOB has
been providing the CCS reports to the Regional CLP TPO three times a week
immediately after the screening is completed foi the past several years. AOB
will evaluate its present procedures for effectiveness and implement any needec
changes.
Work Plan f ; 01407
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element ; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery: OIG Audit: FMFIA Audit of the CLP (Willis Greenstr'
Report)
Original Target Correction Date: In progress
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: In progress
Reason for Change in Date (a): N/A
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events : None
B. Planned Actions/Events (Short-Term - Next 12 Months) :
M/S # MILESTONE TITLE ORIG- PLAN ACTUAL DOLLARS /FTE
M 001 INITIATE EFFECTIVENESS STUDY / / / / / /
M 002 COMPLETE SURVEY INSTRUMENT /' / / / / /
M 003 SEND SURVEY INSTRUMENT / / / / / /
TO REGIONS
D-32
-------
Pg- 27
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT:
M 004 EVALUATE SURVEY FINDINGS / / / / / /
M 005 FINAL REPORT / / / / / /
M 006 IMPLEMENT FINDINGS / / / / / /
M 007 COMPLETE CORRECTIVE ACTION / / / / / /
IMPLEMENTATION
M 008 VERIFICATION OF COMPLETION / / / / / /
C. Planned Actions/Events (Longer Term):
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Report is still confidential as of
09/30/91 and will not be released until mid-October. At that time, a mon
definite workplan will be prepared and will be outlined in Ql CATS update
o December 31. 1991 Status Update: Completion of this workplan
requires additional resources. We are committed to completion of the
workplans and expect to have the resources available in the near
future. Specific milestone dates will be provided by October 15,
1992.
o March 31, 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
D-33
-------
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Complete draft AICR report
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Implement findings
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» ('iini|»lftf final guidance on PES u
» Dcvflnp silc-tiilegory PES
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-------
RECOMMENDATIONS
4. Improve communications with Regions on non-
compliance with Contract Compliance Screen
(CCS)requiremenls.
Key Milestones:
Initiate effectiveness study
Complete survey instrument
Evaluate survey findings
Complete final report
Implement recommendations
5. Support EMSL-LV to develop trend analyses which
can he used to identify problem laboratories.
Key Milestones:
Initiate dataha.sc construction
Identify laboratory performance parameters
Develop prototype system
Test prototype laboratory performance data base
system
Issue status reports
Issue annual report
Participate in Hazardous Waste Research
Committee Meeting
6a. Shift greater responsibility for data accuracy and
timeliness to contract laboratories.
Key Milestones:
Begin implementation of Agency Standard
Distribute CCS software
Complete implementation of Agency Standard
Incorporate sdf-CCS requirements in contracts
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Cey Milestones:
Initiate evaluation study
Delermine options and make recon
Consults with ASAC
Draft evaluation report
Final evaluation report
Implement recommendations
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issign national program leadership 1
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Cey Milestones:
» IVcpare orgaiiiuition plan
> Approve organi/^ilion plan
» Implement organization plan
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Cey Milestones:
» Identify reporting elements and fo
» Develop draft senior level managa
» Obtain approval for senior level m
reports
• Implement national reporting sysl<
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Cey Milestones:
> Determine staffing levds and organizational
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> Submit draft staffing •ssessment to OC/Budge
review
> Seek approval for organization plan
» Implement staffing/organizational
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Ley Milestones:
» Participate in EMMC workgroup and steering
committee meetings
Develop five pilot standardized methods
Issue five final standardized methods
Sdect new group of candidate methods
Develop new standardized methods
Issue new standardized methods
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Develop scope of alternatives for delivery of
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Evaluate pros and cons of alternatives
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Initiate non-CLP tracking system
Conduct Non-CLP Coordinator meeting
Brief ASAC
Incorporate PRP data
Complete Regional implementation
d
-------
pg. 1
attachment 1
Attactuaaat. D
PART TWO: DESCRIPTION OF DNCORRKCTED MATERIAL MKAKMESSES
CATS Tracking Mm«H*»-- 92-6
Assessable Unit/AU f: OERR/HSCD/1902
Title of Material Weakness; Accelerating Remedial Cleanups: Expand Flexibilit;
of Design/Construction contracts
Description of Material Weakness and Its Impact on Agency Operations; Expand
flexibility of design/construction contracts. This project will develop and
pilot methods to accelerate the pace of remedial actions by proceeding directl;
with on-site cleanup activities following the ROD. Methods to limit the desig^
effort and cost reimbursement remedial action contracting will be examined.
Workplan »; 1343
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: The Superfund 30 Day Study Task Force
0 'qinal Target Correction Date: 09/30/93'
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 09/30/93
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events; None
B. Planned Actions/Events (Short-Term - Next 12 Months):
M/S I MILESTONE TITLE GRIG PLAN ACTUAL DOLLARS/FTE
M OC1 ESTABLISH WORKGROUP 11/30/91 11/30/91 / /
M 002 SCREEN RD CANDIDATES 01/31/92 01/31/92 / /
D-40
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRZCTED MATERIAL WZAKNTSSES
M/S # MILESTONE TITLE
M 003 DEVELOP
DESIGN/CONSTRUCTION
OPTIONS
M 004 INITIATE WORK AT
SITES
ORIG PLAN ACTUAL
03/31/92 03/31/92 / /
04/30/92 04/30/92 / /
DOLLARS/FTE
C. Planned Actions/Events (Longer Term):
M/S # MILESTONE TITLE
M 005 EVALUATE EFFECTS CF
PILOTS
M 006 VERIFICATION OF
COMPLETION
ORIG PLAN ACTUAL DOLLARS/FTE
C9/01/93 09/01/93 / /
09/30/93 09/30/93 / /
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
$50k/2.0
TOTAL $50k/2.0
September 30, 1991 Status Update: Report was just published October 1,
1991.
December 31, 1991 Status Update: Workgroups were formed and composed
of OERR (HSCD and ERD), PCMD, Regional representatives, and COE. The
workgroup developed criteria, screened candidate sites, and selected
several projects to pilot the new procedures. The workgroup made
final recommendations based upon an evaluation of the pilot projects.
M/S # MILESTONE TITLE
M 001 ESTABLISH WORKGROUP
ORIG PLAN ACTUAL DOLLARS/FTE
11/30/91 11/30/91 12/17/91
o March 31, 1992 Status Update:
o June 30. 1992 Status Update:
o September 30, 1992 Status Update:
D-41
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
cATS Tracking Number: Not Assigned
Assessable Onit/AU i: OERR/HSCD/1902
Title of Material Weakness; ARCS Contract Management: Facilitate
implementation of revised policy
Description of Material Weakness and Its Impact on Agency Operations: To
facilitate implementation of this revised policy, within 90 days EPA should
issue guidance to the regions to help them make assignments LO ARCS contractor
and the Corps. This guidance should include:
- Site specific technical, quality, and performance criteria;
- Emphasis on the Corps' ability to review the design and construction
activities of ARCS contractors; and
- Requirements to ensure substantive Corps role in remedial designs conducted
by ARCS contractors where the Corps will carry out the clean-up phase.
Worfcplan »: 01365
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified; 1991
^ .-co of Discovery: Superfund Management Task Force
Original Target Correction Date; 09/30/92
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 12/31/92
Reason for Change in Date(s); N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 PREPARE FIRST DRAFT 11/30/91 11/30/91 / /
OF GUIDANCE
M CC2 INCORPORATE COMMENTS 12/21/91 12/31/91 / /
ON CRAFT
D-44 "
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
B. Planned Actions/Events (Short Tarn - Next 12 Months!:
M/S # MILESTONE TITLE
M 003 ISSUE REGIONAL
GUIDANCE
M 004 HSCD WILL MONITOR
REMEDIAL DESIGN
M 005 VERIFICATION OF
COMPLETION
ORIG
01/02/92
PLAN ACTUAL
01/02/92 / 7
C.
01/30/92 01/30/92 / /
09/30/92 09/30/92 / /
Planned Actions/Eventa (Longer Term): None
DOLLARS/FTE
Validation Process to be Used; HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30. 1991, Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a mo^
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31, 1991, Status Update: First draft of guidance has been
prepared.
M/S # MILESTONE TITLE
M 001 PREPARE FIRST DRAFT
OF GUIDANCE
M 002 INCORPORATE COMMENTS
ON DRAFT
ORIG PLAN ACTUAL
11/30/91 11/30/91 11/30/91
12/31/91 01/15/92 / /
DOLLARS/FTE
o March 31, 1992. Status Update:
o June 30, 1992, Status Update:
o September 30, 1992, Status Update:
D-45
-------
attachment 1
Attachment D
PART TWO: DESCRIPTION OF ONCORRECTED MATERIAL H1AKMESSES
Tracking Number; Not Assigned
Assessable Unit/AU I: OERR/HSCD/1902
Title of Material Weakness; ARCS Contract Management: Establish a National
Target of 15 Percent or Less as Ratio of ARCS Program Management $ to total
ARCS $
Description of Material Weakness and Its Impact on Agency Operations: EPA
should establish a national target of 15 percent or less as the ratio of
program management expenditures to total contract expenditures under ARCS
contracts. To accomplish this, contract-specific cost expenditure targets and
contractor-specific targets should be developed by the regions with OSWER/OARM
help.
Workplan t: 01357
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
fear Identified; 1991
Source of Discovery; Superfund Management Task Force
C. .inal Target Correction Date: 09/30/92
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 09/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 PREPARE POLICY LETTER 12/31/91 ' 01/31/92 / /
M 002 CONTRACT AND 01/30/92 02/28/92 / /
CONTRACTOR TARGETS
M C03 DEVELOP PROGRAM 01/30/92 C3/27/92 / /
MANAGEMENT REPORT
D-46
-------
attachment 1
PART TWO; DESCRIPTION OF ONCORRECTgP MATERIAL WBAKNBSSES
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 004 EVALUATE COSTS VERSUS 04/30/92 04/30/92 / /
TARGETS
M 005 VERIFICATION OF 12/31/92 12/31/92 / /
COMPLETION
C. Planned Actions/Events (Longer Tarn): None
Validation Process to be Used; HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30. 1991, Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information
o December 31, 1991, Status Update; A policy letter will be prepared
and sent to regions establishing national target and directing
development of regional targets.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 PREPARE POLICY LETTER 12/31/91 01/31/92 /' /
o March 31. 1992, Status Update:
o June 30, 1992, Status Update:
o September 30, 1992, Status Update:
D-47
-------
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRJBCTED MATERIAL WEAKNESSES
Tracking Number: Not Assigned
sable Unit/AU f ; OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Revise the Program
Management Concept
Description of Material Weakness and Its Impact on Agency Operations: EPA
should revise the program management concept so that start-up costs,
administrative costs, and other clean-up support costs are classified
separately in future Superfund contracts.
Worfcplan »; 01362
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund/ 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified; 1991
Source of Discovery; Superfund Management Task Force
Original Target Correction Date: 09/30/92
T^-qeted Correction Date in Last Year's Report: N/A
Current Target Date: 09/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 PROGRAM MANAGEMENT 01/30/92 01/30/92 / /
STRUCTURE
M 002 PREPARE OPTION PAPER 02/01/92 02/01/92 / /
FOR REVIEW
M 003 DEVELOP POSITION C3/3C/92 C3/30/92 / /
PAPER
D-48
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF DNCORRgCTBD MATERIAL WEAKNESSES
\
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 004 BRIEF LTCS COMMITTEE 04/30/92 04/30/92 / /
M 005 VERIFICATION OF 09/30/92 09/30/92 / /
COMPLETION
C. Planned Actions/Events (Longer Term): None
Validation Process to be Usad: HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30. 1991. Status Update; The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31. 1991, Status Update: No activity occurred during this
quarter. Work due to commence in January 1992.
o March 31. 1992. Status Update:
o June 30, 1992, Status Update:
o September 30. 1992, Status Update:
D-49
-------
pg. 43
attachment 1
Attachment D
PART TWO; DESCRIPTION OF DNCORRECTED MATERIAL WEAKNESSES
cATS Tracking Number: Not Assigned
Assessable Dnit/AO f; OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Encourage effective
of ARCS resources
Description of Material Weakness and Its Impact on Agency Operations: To
encourage more effective use of available ARCS resources, within 60 days EPA
should leviae Supeifund policy to allow regions to select ARCS or U.S. Army
Corps of Engineers (Corps) contractors to do design work at any site and to
select ARCS or Corps to perform remedial actions with a value up to $15
million. Under current policy ARCS cannot be selected to carry out remedial
actions with a value over $5 million.
Worfcplan »: 01363
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
fear Identified: 1991
Source of Discovery: Superfund Management Task Force
(^ .final Target Correction Date: 09/30/92
Targeted Correction Date in Last Year's Report: N/A
Current Target Date; 12/31/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DCLLARS/FTE
M 001 MEET WITH HEADQUARTERS 12/02/91 12/02/91 / /
OFFICE
M 002 ISSUE POLICY MEMO TO 12/31/91 12/31/91
REGIONS
D-50 "
-------
attachment
PART TWO: DESCRIPTION OF UNCORREC
M/S # MILESTONE TITLE ORIG
Attachment D
ESSES
M 003 VERIFICATION OF
COMPLETION
09/30/92
C. Planned Actions/Events (Longer Term): None
PLAN ACTUAL
09/30/92 / /
DOLLARS/FTE
Validation Process to be Used: HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o
September 30. 1991. Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
December 31. 1991, Status Update:
M/S # MILESTONE TITLE
M 001 MEET WITH HEADQUARTERS
OFFICE
M 002 ISSUE POLICY MEMO TO
REGIONS
ORIG
PLAN
ACTUAL
DOLLARS
12/02/91 12/02/91 12/02/91
12/31/91 12/31/91 12/10/91
o March 31. 1992. Status Update:
o June 30. 1992. Status Update:
o September 30, 1992, Status Update;
D-51
-------
attachment 1
Attachment D
PART TWO; DESCRIPTION OF ONCORRECTED MATERIAL WEAKNESSES
CATS Tracking Number; Not Assigned
Assessable Unit/AU f; OERR/HSCD/1902
Title of Material Weakness; ARCS Contract Management; Ensure, a Balanced
Construction Management System
Description of Material Weakness and Its Impact on Agency Operations; To
ensure a balanced construction management system, EPA should work with the
regions and Corps to imprcvc Ccrpc responsiveness to regional needs during
project design, maintain effective communications between EPA and the Corps,
and ensure a substantial and predictable workload for the Corps to facilitate
workload planning.
Workplan »; 01366
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: Superfund Management Task Force
' ?inal Target Correction Date: 09/30/92
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 12/31/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. . Completed Actions/Events; None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 ESTABLISH AN INTERAGENCY 01/31/9-2 01/31/92 / /
WORK GROUP
M 002 DEVELOP IMPLEMENTATION 04/30/92 04/30/92
PLAN
D-52
-------
r o •
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 003 VERIFICATION OF 12/31/92 12/31/92 / /
COMPLETION
C. Planned Actions/Events (Longer Tarn); None
Validation Process to be Used: HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates;
o September 30, 1991, Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31, 1991, Status Update: Activities will begin in January
1992. No activity occurred during this quarter.
o March 31. 1992. Status Update:
o June 30. 1992, Status Update:
o September 30, 1992. Status Update:
D-53
-------
pg-
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRECTBD MATERIAL WEAKNESSES
Trackin Nu
Not Assigned
Assessable Pnit/AU f; OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Assess the Accuracy of
Current Workload Assumption
Description of Material Weakness and Its Impact on Agency Operations; In ordei
to assess the accuracy of current workload assumptions, EPA should continue to
monitor the extent to which ARCS contractor capacity is utilized annually. If
actual utilization differs substantially from the projections, EPA should take
action to correct under- or over- capacity problems.
Workplan f: 01367
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element : Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery; Superfund Management Task Force
Original Target Correction Date: 09/30/92
T ated Correction Date in Last Year7 s Report ; N/A
Current Target Date: 11/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Act ions /Events: None
B. Planned Actions/Events (Short Term - Next 12 Months) :
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 VERIFY FY91 ARCS 12/31/91 01/24/92 / /
CAPACITY
M 002 REVISE FY92 ARCS 01/31/92 01/31/92 / /
PROJECTION MOCE1
M CC3 EXPAND ARCS PROJECT: ON C3/21/22 C 3/31/92 / /
MCDE1
D-54
-------
Attachment D \
PART TWO; DESCRIPTION OF ONCORR1CTED MATERIAL WEAKNESSES v
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTi.
M 004 MONITOR ARCS PROJECTION 04/30/92 04/30/92 / /
ACCURACY
• M 005 VERIFICATION OF 11/30/92 11/30/92 / /
COMPLETION
C. Planned Actions/Events (Longer Tarn): None
Validation Process to be Used: HSCD staff will -conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30, 1991. Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31. 1991, Status Update: In process of verifying FY 1991
ARCS utilization. Difficulty in gathering actual workload data frv
the Regions.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS,
M 001 VERIFY FY91 ARCS CAPACITY 12/31/91 01/24/92 / /
o March 31. 1992. Status Update;
o June 30, 1992, Status Update:
o September 30, 1992, Status Update:
D-55
-------
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRBCTED MATERIAL WEAKNESSES
wATS Tracking N'Tmber: Not Assigned
Assessable Onit/AD f: OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Assess the Apparent
Excess "LOE" Capacity
Description of Material Weakness and Ita Impact on Agency Operations: EPA
should assess the apparent excess "level of effort" capacity of ARCS
contractors in the Region 9/10 western zone. The Agency shuulu consider
selective terminations and assess the feasibility of making excess capacity
available to other regions that may have a shortfall.
Workplan f: 01368
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: Superfund Management Task Force
Original Target Correction Date: 09/30/92
jeted Correction Date in Last Year's Report: N/A
Current Target Date: 09/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events; None
E. Planned Actions/Events (Short Term - Next 12 Months);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 INTERVIEW WITH REGION 01/31/92 01/31/92 / /
9/10
M 002 HEADQUARTERS PREPARE Cl/31/92 --01/31/92 / /
POSITION PAPER
D-56
-------
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL MIAKNISSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 003 COMPLETE REGION 9/10 02/29/92 02/31/92 / /
ANALYSIS
M 004 EXPLORE FEASIBILITY OF 03/31/92 03/31/92 / /
ADJUSTMENT
M 005 VERIFICATION OF 08/31/92 08/31/92 / /
COMPLETION
C. Planned Actions/Events (Longer Term): None
Validation Process to be Used: HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30. 1991. Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time
The first quarter CATS report will contain more detailed information
o December 31. 1991, Status Update; Interview with Region 9/10 during
regional visit. Assess the apparent excess "level of effort"
capacity of ARCS contractors in the Region 9/10 western zone.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 INTERVIEW WITH REGION 01/31/92 01/31/92 12/18/91
o March 31, 1992. Status Update:
o June 30, 1992, Status Update:
o September 30, 1992, Status Update:
D-57
-------
attachment 1
Attacbvaat I)
PART TWO; DESCRIPTION OF DKCORREC
.*TS Tracking Number; Not Assigned
ssesaable Unit/AO f; OERR/HSCD/1902
Title of Material Weakness; ARCS Contract Management; Report ARCS Contract
Management as a Weakness
Description of Material Weakness and Its Impact on Agency Operations; OSWER
should report ARCS contract management as a material weakness in its FY 1991
Federal Managers' Financial Integrity Act (FMFIA) submission. In addition. r*<
EPA office responsible for this report should:
- Implement corrective actions;
- Establish a format tracking system that projects action dates and monitors
whether actions are taken as scheduled;
- Report quarterly to EPA Senior Council on Management Controls on the status
of implementation; and
- Convene a work group to evaluate regional issues, vulnerability assessments
and previous reviews. Work group efforts will meet the FMFIA corrective actioj
and follow-up requirements.
Workplan »: 01369
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
^.*r Identified: 1991
Source of Discovery; Superfund Management Task Force
Original Target Correction Date; 09/30/92
Targeted Correction Date in Last Year's Report; N/A
Current Target Date: 09/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE CRIG PLAN ACTUAL DOLLARS/FT!
M OC1 OSWER IDENTIFIES PROCESS 12/31/91 12/31/91 / /
D-58 "
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attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRBCTBD MATERIAL KEAKNBSSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 002 ARCS COUNCIL TO EVALUATE 01/31/92 01/31/92 / /
ISSUES
M 003 TRACKING SYSTEM 01/31/92 01/31/92 / /
ON ACTIONS
M 004 TARGET DATES FOR ACTIONS 04/30/92 04/30/92 / /
M 005 REPORTS DOCUMENTING 04/30/92 04/30/92 / /
STATUS
M 006 VERIFICATION OF 09/30/92 09/30/92 / /
COMPLETION
C. Planned Actions/Eventa (Longer Term): None
Validation Process to be Used; HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30, 1991, Status Update: The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of '""*"
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31, 1991, Status Update; Workplan slightly behind schedule.
No activity occurred during this period.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 OSWER IDENTIFIES PROCESS 12/31/91 12/31/91 / /
o March 31. 1992, Status Update:
o June 30, 1992. Status Update:
o September 30. 1992, Status Update:
D-59
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Pg-
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRECTED MXTERIAL WEAKNESSES
CATS Tracking M«»>^T" Not Assigned
Assessable Unit/AD f; OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Regional Administrator
Establish a Capacity
Description of Material Weakness and Its Impact OB Aaencv Operations;
Regional Administrators should act immediately to establish a regional capacit
for providing independe/iL y^vej.nment cost estimates to ARCS contract managers.
Worfcplan #: 01370
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified; 1991
Source of Discovery; Superfund Management Task Force
Original Target Correction Date: 09/30/92
Targeted Correction Date in Last Year'a Report; N/A
i .rent Target Date: 06/30/93
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 TEAMS MONITOR PLAN 05/31/92 04/31/92 / /
TO COMPLIANCE
M 002 ISSUE OERR DIRECTIVE 12/31/91 02/14/92 / /
M 003 REGIONS IMPLEMENT Cl/31/92 02/14/92 / /
REQUIREMENTS
M CC4 OERR ASSESS COST ESTIMATE Cl/31/92 02/14/92 / /
TCC1S
D-60
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attachment 1
Attachment D ^
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT!
M 005 OERR ISSUES DESIGN 08/31/92 08/31/92 / /
GUIDANCE
M 006 IMPLEMENTATION OF REVISED 09/30/92 09/30/92 / /
COST
C. Planned Actions/Events (Longer Term):
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 007 VERIFICATION OF 06/30/93 06/30/93 / /
COMPLETION
Validation Process to be Used: HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update; The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31. 1991. Status Update; OERR directive expected to be
issued in February 1992.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 002 ISSUE OERR DIRECTIVE 12/31/91 02/14/92 / /
o March 31. 1992. Status Update;
o June 30. 1992. Status Update:
o September 30. 1992, Status Update:
D-61
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pg- 3
attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Tracking Kumher; Not Assigned
Assessable Unit/AU #: OERR/HSCD/1902
Title of Material Weakness; ARCS Contract Management: Evaluation of the
Quality of Program Management and Reinforce its Policy on the use of Award Fees
Description of Material Weakness and Its Impact on Agency Operations;
Contractors should be evaluated on the quality of both their program management
and remedial work. The ability of contractors to reduce program management
costs and meet national targets should receive significant consideration in the
award fee process. EPA should reinforce its policy on the use of award fees to
influence contractor performance by:
- Suspending the issuance of new site assignments to contractors with
unresolved unsatisfactory performance on prior work assignments;
- Imposing appropiate sanctions, including termination, on contractors who
persist in their failure to correct deficiencies; and
- Assigning new site work in FY 1992 to contractors in relation to their
overall performance.
Workplan #'. 01372
Functional Category in Statistical summary- Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
7 inistrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; Superfund Management Task Force
Original Target Correction Date; 09/30/92
Targeted correction Date in Last Year's Report; N/A
current Target Date; 09/30/92
Reason for Change in Date(s); N/A
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events; None
B. Planned Actions/Events (Short Term - Next 12 Months);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 TEAM DEVELOP MONITORED PLAN 05/31/92 05/31/92 / /
D-62
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attachment 1
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S I MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT
M 002 GUIDANCE TO MAKE FEE 05/31/92 05/31/92 / /
CONSISTENT
M 003 GUIDANCE TO REMEDIAL MANAGERS 06/30/92 06/30/92 / /
M 004 VERIFICATION OF COMPLETION 09/30/92 09/30/92 / /
C. Planned Actiona/Events (Longer Term); None
Validation Process to be Used; HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates:
o September 30, 1991, Status Update; The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information
o December 31, 1991, Status Update; No activity occurred during this
period. Work due to commence in May 1992.
o March 31. 1992, Status Update;
o June 30, 1992. Status Update:
o September 30, 1992, Status Update:
D-63
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Pg- 57
attachment 1
Attachment D
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Tracking Number; Not Assigned
Assessable Onit/AU f : OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Examine the Division o
Headquarters and Regional Management Responsibilities
Description of Material Weakness and Its Impact on Agency Operations: EPA
should examine the division of headquarters and regional management
responsibilities to identify steps needed to create an effective central
mechanism for monitoring, evaluating, and formulation ARCS policy. An
implementation plan based on the results of this examination should be
submitted to the Administrator within the next 120 days.
Workplan »; 01375
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified: 1991
Source of Discovery: Superfund Management Task Force
'qinal Target Correction Date: 09/30/92
Targeted Correction Date in Last Year's Report: N/A
Current Target Date: 09/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. . Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 FLOW CHART OF ARCS 01/13/92 01/13/92 / /
RESPONSIBILITY PROCESS
M 002 EXAMINE RESPONSIBILITIES 12/31/91 12/31/91 / /
D-64
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attachment 1
Attachment D
PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT*.
M 003 IDENTIFY WEAKNESS AND 12/31/91 12/31/91 / /
STRENGTH
M 004 DRAFT RECOMMENDATION 01/31/92 03/30/92 / /
M 005 FINAL IMPLEMENTATION PLAN 02/03/92 03/30/92 / /
M 006 VERIFICATION OF 09/30/92 09/30/92 / /
COMPLETION
C. Planned Actions/Events (Longer Term): None
Validation Process to be Used; HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update; The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a mor'
specific workplan of corrective action is not available at this time.
The first quarter CATS report will contain more detailed information.
o December 31. 1991. status Update; Workplan slightly behind schedule
due to staffing change. Work Assignment issued to develop a flow
chart of ARCS process.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 002 EXAMINE RESPONSIBILITIES 12/31/91 02/28/92 / /
M 003 IDENTIFY WEAKNESS AND 12/31/91 03/30/92 / /
o - March 31. 1992. status Update;
o June 30. 1992, Status Update;
o September 30, 1992. Status Update;
D-65
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attachment 1
Attachment D
PART TWO; DESCRIPTION OF ONCORRgCTED MATERIAL WEAKNESSES
Tracking Number: Not Assigned
Assessable Unit/AU f: OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management: Employ TQM Concept to
Establish an ARCS Council
Description of Material Weakness and Its Impact on Aqancv Qparatioos: Total
Quality Management (TQM) concepts should be employed to establish an ARCS
Council consisting of headquarters and regional personnel. This council,
chaired by the Superfund Acquisition Program Manager, should meet regularly to
identify and implement improvement in ARCS contract management.
Workplan f: 01376
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: Superfund Management Task Force
Original Target Correction Date: 09/30/92
jeted Correction Data in Last Year's Report: N/A
Current Target Date: 10/31/92
Reason for Change in Date (a): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FT!
M 001 ESTABLISH ARCS COUNCIL 12/31/91 12/31/91 / /
M 002 ARCS COUNCIL FORMULATE 01/31/92 01/31/92 / /
OBJECTIVES
M 003 ESTABLISH TQM MILESTONES 01/31/92
D-66
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attachment 1
Attachment D \
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES >t
M 004 ESTABLISH ARCS COUNCIL 12/31/92 01/31/92 / /
M 005 ARCS COUNCIL FORMULATE 01/31/92 02/19/92 / /
OBJECTIVES
• M 006 FIRST ARCS COUNCIL MEETING 02/20/92 02/20/92 / /
M 007 EXECUTE RECOMMENDATIONS 07/31/92 07/31/92 / /
M 005 VERIFICATION OF COMPLETION 10/31/92 10/31/92 / /
C. Planned Actions/Events (Longer Term): None
Validation Process to be Used: HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates;
o September 30, 1991. Status Update; The Superfund Task Force (Dunne
Workgroup) has reviewed the ARCS program and will issue a report on
10/02/91. This report will include a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a more
specific workplan of corrective action is not available at this tiir
The first quarter CATS report will contain more detailed informatio
o December 31. 1991, Status Update: An acting acquisition program
manager has been nominated.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL DOLLARS/FTE
M 001 NOMINATE ACTING AQUIS. 12/31/91 12/13/91 12/13/91
PRO. MANAGER
M 004 ESTABLISH ARCS COUNCIL 12/31/91 01/31/92 / /
o March 31. 1992. Status Update:
o June 30, 1992, Status Update:
o September 30, 1992, Status Update:
D-67
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attachment 1
Attachment D
PART THREK: DESCRIPTION OF CORRECTED MATERIAL WEAKNESSES
ATS Trackin
92-3
OERR/HSCD/1902
ARCS Contract Management
Assessable Unit/AU f ;
Title of Material Weakness
Description of Material Weakness and Its Impact on Agency Operation*:
Weaknesses identified through the Administrator' s Task Force on ARCS Contract
Management. EPA has been subjected to serious and public criticism for its
management of the Super fui'icl program. EPA has been accused of allowing certain
Superfund contractors to spend public funds on activities other than the direc
site cleanup of Superfund sites.
Workplan »: 01222
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element : Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified: 1991
Source of Discovery: Superfund Management Task Force
Original Target Correction Date: 09/30/92
qetcd Correction Date in Last Year's Report; N/A
Current Target Date: 09/30/92
Reason for Change in Date(s): N/A
Critical Milestones in Planned Corrective Action:
A. Completed Actions /Events:
M/S f MILESTONE TITLE ORIG PLAN
M 001 PARTICIPATE IN TASK
FORCE
09/20/91 09/20/91
ACTUAL
09/20/91
B.
Planned Actions/Events (Short-Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 002 TASK FORCE ISSUES 10/C2/91 10/02/91 / /
REPORT
DOLLARS/FTE
Unknown
DOLLARS/FTE
D-72
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MILESTONE TITLE
ORIG
PLAN
ACTUAL
attachment 1
DOLLARS/FTT
M/S #
M 003 DRAFT HSCD
IMPLEMENTATION PLAN
M 001 VERIFICATION OF
COMPLETION
11/15/91 11/15/91
09/30/92 09/30/92
/ / Unknown
/ / $100k/3.0
TOTAL $100k/3.0
C. Planned Act ions /Events (Longer Term) ;
None.
Validation Process to be Used; HSCD staff will conduct onsite review of
Regional ARCS project management process.
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update; The Super fund Task Force (Dunne
Workgroup) has reviewed the ARCS program on and issued a report.
This report included a discussion of ARCS areas of vulnerability.
Because of the recent issuance of this report, a more specific
workplan of corrective action is not available at this time. The
first quarter CATS report will contain more detailed information.
o December 31. 1991, Status Update; Task force report was issued
10/02/91. Implementation plan was issued 11/27/91. This completed
all work under this workplan. Additional activities will be covered
under specific ARCS workplans.
M/S # MILESTONE TITLE
M 002 TASK FORCE ISSUES
REPORT
M 003 DRAFT HSCD
IMPLEMENTATION PLAN
ORIG
PLAN
ACTUAL
DOLLARS/FTE
10/02/91 10/02/91 10/02/91
11/15/91 11/15/91 11/27/91
o March 31. 1992. Status Update;
o June 30. 1992. Status Update;
o September 30. 1992. Status Update;
D-«73
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attachment 1
AT Tr
Assessable Unit/AU » :
ESSES/IMC
90-5
OERR/ERD/1900
Attachment X
ACTIONS
Title of Aoenev-level Weakness and Description: Develop Tasking Assignment
Records (TARs) Guidance. Use of TARs not supported by program guidance.
Work Plan f: 743
Year Identified: 1989
Source of Discovery: Regional TAT management reviews and DIG audit of
Region III TAT management.
Critical Milestones in Corrective Action:
M/S # MILESTONE TITLE
M 004 DEVELOP TARS GUIDANCE
M 006 TEST TDD GENERATOR SYSTEM
M 007 INITIATE REGION 4 AND 6 PILOTS
M' 008 LIFE CYCLE/CONFIG. MGMT . APPROVAL
M 010 COMPLETE TAR GUIDANCE
M Oil VERIFICATION OF COMPLETION
Validation Process to be Used Regions will
ORIG
03/31/90
05/09/90
08/02/90
09/30/90
03/31/90
08/15/91
PLAN
06/22/91
05/09/90
08/02/90
09/30/90
07/31/91
01/31/92
be contacted to veri
ACTUAL
06/24/91
05/09/90
08/02/90
10/15/90
12 /oi /T|
/ /
fy their
receipt of completed User's Manual which explains the TAR procedures.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: This has been incorporated into the
TAT User's Manual.
o December 31, 1991 Status Update: The guidance, which is part of
the TAT User's Manual, is dated December 1991. Completion of the
workplan is now estimated for 1/31/92.
o March 31, 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
E-l
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attachment 1
Attachment E
AGENCY-LEVEL WEAKNESSES/INCOMPLETE CORRECTIVE ACTIONS
CATS Tracking Number: Not yet assigned
Assessable Onit/AU t: OERR/HSED/1901
Title of Agency-level Weakness and Description: OI6 Audit: Superfund
QA/QC of the Contact Lab Program: Retrieval of CLP Documentation per OIG
Recommendation in. Audit Report: OIG Audit Report # E1SKE9-0047-1100411 was
concerned that all "Case File Purposes" had not been delivered from CLP
labs and that they might be needed for legal purposes. In addition, they
were concerned with lack of consistency ir. Regional handling of the planned
retrieval.
Work Plan I: 01402
Year Identified 1991
Source of Discovery:
Program
OIG Audit: Superfund QA/QC of the Contract lab
Critical Milestones in Corrective Action:
M/S I MILESTONE TITLE
M 001 DESIG. MANAG. OFFIC. TO GET
DOCUMENT
M 002 ESTIMATE DATES FOR MILESTONE
IMPLEMENTATION
M 003 PLANNING MEETING OE/NEIC/AOB
M 004 DELIVERY OF LIST OF MISSING
FILES
M 005 DESIGNATION OF RESOURCES FOR
PLAN
M 006 DRAFT GUIDANCE FOR DOCUMENT
RETRIEVAL
M 007 FINAL GUIDANCE INCLUDING
NEEDED DOCUMENTATION.
M 008 DELIVERY OF FILE RETRIEVAL
LISTS
M CC9 ASSIS REGIONS IMPL. CF GUIDANDC
ORIG
PLAN
ACTUAL
08/21/91 08/21/91 08/21/91
10/31/91 10/31/91 / /
11/11/91 11/11/91 / /
11/30/91 11/30/91 / /
12/05/91 12/05/91 / /
06/30/92 06/30/92 / /
09/30/92 09/30/92 / /
09/30/92 09/30/92 / /
12/30/92 12/30/92 / /
E-19
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attachment 1
Attachment E
AGENCY-LEVEL WEAKNESSES/INCOMPLETE CORRECTIVE ACTIONS
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 009.1 PROVIDE LIST OF UNDELIVERED 12/30/92 12/30/92 / /
DOCUMENT
M 010 COMPLETE RETRIEVAL OF FILES 09/30/93 09/30/93 / /
M Oil VERIFICATION OF COMPLETION 12/30/93 12/30/93 / /
Validation Process to be Used: This report was just recently published.
The validation process will be determined after completed workplan has been
prepared.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update: Workplan is being prepared.
o December 31, 1991 Status Update: Plan for retrieval of CLP
documentation has begun and draft guidance for implementation is
expected in 6 months.
M/S I MILESTONE TITLE ORIG PLAN ACTUAL
M 002 EST. DATES FOR MILESTONE 10/31/91 10/31/91 10/29/31
IMPLEM.
M 003 PLANNING MEETING 11/11/91 11/11/91 11/11/91
OE/NEIC/AOB
M 004 DELIVERY OF LIST OF 11/30/91 11/30/91 11/30/91
MISSING FILES
M 005 DESIGNATION OF RESOURCE 12/05/91 12/C5/91 12/05/91
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
E-20
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attachment 1
AGENCY~T-1gVEL
CATS Tracking Number; Not yet assigned
Assessable Unit/AU »: OERR/HSED/1901
Title of Agency-level Weakness and Description; OIG Audit: Superfund
QA/QC of the Contract Lab Program: National Guidane on the Uniform Use
of Performance Evaluations (PE) Samples in Superfund
Work Plan #: 01403
Year Identified 1991
Source of Discovery: OIG Audit: Superfund QA/QC of the Contract lab
Program
Critical Milestones in Corrective Action:
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 WORKGROUP MEETING ON PE 01/27/92 01/27/92 / /
GUIDANCE
M 002 WORKSHOP ON SITE CHARAC. 04/17/92 04/17/92 / /
PE SAMPLES
M 003 2ND WORKGROUP MEETING ON 04/18/92 04/18/92 / /
PE GUID.
M 004 DRAFT GUIDANE OF UNIFORM 06/30/92 06/30/92 / /
PE USE
M 005 FINAL GUIDANCE ON UNIFORM 11/01/92 11/01/92 / /
Validation Process to be Used: This report was just recently published.
The validation process will be determined after completed workplan has been
prepared.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Workplan is being prepared.
o December 31. 1991 Status Update: No activity occurred during
this quarter. Meeting of workgoup to discuss performance
evaluation guidance is planned for January 1992.
o March 31. 1992 Status Update:
o June 30, 1992 Status Update:
o September 30, 1992 Status Update:
E-21 *
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• attachment 1
Attachment E
AGENCY-LEVEL WEAKNESSES/INCOMPLETE-CORRECTIVE ACTIONS
CATS Tracking Number; 92-13
Assessable Unit/AU »: OERR/HSED/1901
Title of Aqencv-level Weakness and Description; OI6 Audit: Superfund QA/QC
of the Contract Lab Program: All Superfund analytical data generated
through the Contrat Lab Program undergoes a review process in the regions.
This includes both the routine and special analytical services managed for
AOB by the Sample Management Office. While the regions provide training
for the contractors, oversight of the contractors work varies fvnm r-egion
to region. A task has been initiated to collect regional guidances,
directives and SOPs in this area to produce a national guidance for uniform
oversight of Data Validation Contractors.
Wor* Plan *: 01404
Year Identified 1991
Source of Discovery; OIG Audit: Superfund QA/QC of the Contract lab
Program
Critical Milestones in Corrective Action:
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 SURVEY OF EXISTING PRACTICES 04/01/92 04/01/92 / /
002 REVIEW OF EFFECT. OF GUID. 06/01/92 06/01/92 / /
BY ASAC
M 003 DRAFT GUID. MINIMUM OVERSIGHT 09/01/92 09/01/92 / /
M 004 FINAL GUID. MIN. OVERSIGHT 06/01/93 06/01/93 / /
Validation Process to be Used: This report was just recently published.
The validation process will be determined after completed workplan has been
prepared.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Workplan is being prepared.
o December 31, 1991 Status Update: An initial meeting was held
with the contractor to outline the project. A letter was sent
out to Regional QAOs asking them to cooperate with data Review
Oversight Contractor, by providing .any available regional
directives, guidances, and SCPs for oversight cf the regional
data review ccr.tractcrs.
E-22 -
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attachment 1
AGENCY-LEVEL
o March 31. 1992 Status Update:
o June 30. 1992 Status Update;
o September 30. 1992 Status Update:
Attachment E
ES/INCOMPLETE CORRECTIVE ACTIONS
E-23
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attachment 1
Attachment E
AGENCY-LEVEL WEAKNESSES/INCOMPLETE CORRECTIVE ACTIONS
CATS Traclcinq N""|*">er: Not yet assigned
Assessable Unit/AU «: OERR/HSED/1901
Title of Agency-level Weakness and Description: DIG Audit: Superfund QA/QC
of the Contract lab Program: SAS OIG Audit Follow-Up
Work Plan i: 01416
Year Identified 1991
Source of Discovery; OIG Audit: Superfund QA/QC of the Contract lab
Program
Critical Milestones in Corrective Action:
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 REVISE SAS SUBCONTRACT 10/30/91 10/30/91 / /
M 002 PERFORMANCE EVALUATION REVIEW 11/21/91 11/21/91 / /
M 003 CONDUCT BOA CONFERENCE 12/11/91 12/11/91 / /
M 004 LETTER ON ELIGIBILITY FOR SAS 12/30/91 12/30/91 / /
•' 005 PUBLISH GUIDANCE ON DATA 12/30/91 12/30/91 / /
REVIEW
M 006 VERIFICATION OF COMPLETION 06/30/92 06/30/92 / /
Validation Process to be Used: Contact the regions to assess usefulness of
data review guidance.
Corrective Action Plan Status Updates:
o September 30, 1991 Status Update: Workplan is being prepared.
o December 31, 1991 Status Update: Guidance for data review was
published 12/30/91.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 REVISE SAS SUBCONTRACT 10/30/91 10/30/91 10/15/91
M 002 PERFORMANCE EVALUATION REVIEW 11/21/91 11/21/91 11/21/91
M CC3 CONDUCT BOA CONFERENCE 12/11/91 12/11/91 12/11/91
E-24 -
-------
attachment 1
Attachment 2
AGENCY-LEVEL WEAKNESSES/INCOMPLETE CORRECTIVE ACTIONS
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 004 LETTER ON ELIGIBILITY FOR SAS 12/30/91 12/30/91 12/30/91
M 005 PUBLISH GUIDANCE ON DATA 12/30/91 12/30/91 12/30/91
REVIEW
o March 31. 1992 Status Update;
o June 30, 1992 Status Update;
o September 30, 1992 Status Update;
E-25
-------
Pg- 71
attachment 1
Attachment X
CONS
BNCY-1
CATS Tracking Number; 91-20
Assessable Unit/AU f: OERR/OPM/1911
Title of Aaancv-Level Weakness and Description: Contract Financial
Oversight
Work Plan •; 00890
Ysar Identified: 1989
Source of Discovery; Internal Assessment
Critical Milestones in Corrective Action;
M/S # MILESTONE TITLE ORIG ' PLAN ACTUAL
M 001 REV. INVOICE WRKSHP. DEV. STATUS 11/02/90 11/02/91 / /
M 005 TARGET 4 REGIONS FOR FIN. ASSESS. 11/05/90 11/05/91 / /
M 010 ID. NAT'L MTG. FOR WRKSHP. PILOT 01/07/91 01/07/92 / /
M 002 ID. WRKSHP.DELIVERY STRATEGY 02/15/91 02/15/92 / /
M 017 ID SCOPE OF REG. FINANCIAL ASSESS 02/18/91 02/18/92 / /
.1 019 CONDUCT ASSESS. IN WEST. ZONE 03/15/91 03/15/92 / /
M 012 COMPLETE DRAFT WRKSHP. COURSE 04/12/91 04/12/92 / /
M 024 PRELIM.FEEDBACK TO W. ZONE REGS. 04/26/91 04/26/92 / /
M 020 CONDUCT ASSESS. IN EAST. ZONE 05/17/91 05/17/92 / /
M 026 PRELIM.FEEDBACK TO W. ZONE REGS. 06/22/91 06/22/92 / /
M 028 BRIEF DD ON REG. FIN. ASSESSMENTS 07/12/91 07/12/92 / /
M 029 FINAL RPT. TO REGS. ON ASSESSMENTS 08/02/91 08/02/92 / /
M 014 COMPLETE WRKSHP. PILOT 08/30/91 08/30/92 / /
M 015 FINALIZE WKSHP COURSE & DELIVERY 09/30/91 09/30/92 / /
M 016 VERIFICATION OF COMPLETION .- 10/30/92 10/30/92 / /
Validation Process to be Used: Assessment of GAO/IG comments regarding
vulnerabilities in financial oversight are significantly reduced.
E-37 -
-------
attachment- 1
Attachment E
AGENCY-LEVEL WEAKNESSES/INCOMPLETE CORRECTIVE ACTIONS
Corrective Action Plan Status Updates;
o September 30, 1991 Status Update; Work has been significantly
delayed. Milestones revised to reflect new course of action.
o December 31. 1991 Status Update; The ARCS workgroups and the
Superfund revitalization team will be conducting work which makes
this workplan redundant. This workplan will close this quarter,
-------
OSWER Directive 9201.0-01
ARCS Study- lapleneitalio!
Status as of 2/19/92
Task Force Recommendation
1. Proeram Manaeeneat
1. EPA should establish a national
target of 15% or less for program
management expenditures.
a. Policy to regions establishing
target and directions
b. Review contract/contractor
targets established by Regions
c. Develop standard program
management tracking reports
d. Evaluate actual cost targets
2. Regions pursue cost reductions and
strengthen cost controls per guidance
developed by PCMD. Contractor
effectiveness in controlling costs
considered significant factor in
award fee evaluation process.
a. Guidance provided to Regions
b. Regional Plan to implement
control measures
WANo.
01357
01437
Lead
Organization
HSCD
HQ/Region
Region
PCMD
Region
Contact
Person
S. Chang
D. Stutz
S. Alvi
Type of
Delivery
Directive
Memo
I
Original
••••••••••i
12/91
1/30/92
1/30/92
4/30/92
2/3/92'
4/92
Completion Da
Cnrrent
••••»••••••
1/31/92
2/28/92
3/27/92
4/92 A
quarterly
thereafter
2/28/92
ites
Actnal
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make assignments to ARCS and
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assignment distribution
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Reduce $2 Billion in
construction capacity of ARCS
sub-pool
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-------
AR 'tudy Implementation
Task Force Recommendation
b. Complete draft guidance
c. Final guidance and sample
modification
d. Regional Contracting Officers
issue modifications
4. To ensure balanced construction
management system to improve
Corps responsiveness to regional
needs during project design,
maintain effective communication
and ensure substantial/ predictable
work load for Corps to facilitate
workload planning.
a. Establish interagency work
group
b. Develop implementation plan
and schedule
5. Monitor ARCS "LOE" and correct
underover capacity utilization
a. Verify FY9I LOE capacity
projections
b. Revise/refine FY92 capacity
projection model
WANo.
01366
01367
Lead
Organization
PCMD
PCMD
RCOs
HSCD
HSCD
Contact
Person
D. Stutz
D. Stulz
D. Stutz
H. Snyder
H. Snyder
B.
McDonough
N.
Livingstone
Type of
Delivery
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Memo
Memo
Mods
Workgroup
next mtg.
Plan
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Tables
<
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-------
ARCS-Stndy Implementation
Task Force Recommendation
c. Expand/refine ARCS capacity
projection to include remedial
LOE dollars, program
management dollars & sub-pool
dollars
d. Monitor/confirm accuracy of
project.
6. Assess Region 9/10 capacity and
consider terminations or provide
excess to other regions
a. Interview
Region 9 & 10
b. Complete 9/10 capacity analysis
c. Explore capacity adjustment A
capacity availability to other
regions
III. ARCS Contract Controls
1 . OSWER report ARCS as material
weakness in FY 91 FMFIA
a. OSWER and OARM identify
Senior Manager responsible for
ARCS (Process owners)
b. Process owners report to Senior
Council on Mgmt Controls
quarterly
WANo.
01368
01369
Lead
Organization
•i
HSCD
HSCD
OERR
Contact
Person
S. Chang
U. Joiner
Type of
Delivery
••mmmmmmi
Visit to
Region 9 &
10
Analysis
Analysis
Memo
<
Original
•nmmmmmmi
3/31/92
4/30/92 A
quarterly
thereafter
12/31/91
2/29/92
3/31/92
12/31/91
1/31/92
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Current
mmmmmmmmi
3/31/92
4/30/92
12/18/91
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2/19/92
2/14/92
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ARC*" 'turfy Implementation
Task F«!!"- Recommendation
c. Develop tracking system to
follow up
d. Establish target dales for
implementing actions
e. Prepare report documenting
implementation status
2. Regional administrator establish
regional capacity for independent
government cost estimates
a. Issue OSWER Directive
b. Regions implementation
c. OERR assess existing cost
estimating tools for regional
usability
d. OERR issues des. scoping
guidance & revised tools
e. Regional implementation of
revised tools
f. ARCS Council, Regional
Managment Term & Acquistion
Manager develop monitoring
plan to ensure compliance
WANo.
01370
SRT
Lead
Organization
Region/
CORAS/
HSCD
CORAS
Region
OERR
1. Joiner
1
Contact
Person
J. Comstock
HWDD
K.Skahn
Type of
Delivery
Directive #
9242-2-06
IGEs
Guidance
Tools
(
Original
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4/30/92
4/30/92 &
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Within
90 days of
ARCS
Council
formation
rompletion Da
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a
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Strengthen ARCS Administrative
process in vulnerability assessmen
i.e., optional scope of work and
invoice review
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resulting from study of controls o
government owned equipment usec
by contractors al sites.
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ensure compliance
-------
AR Itady Implementation
Task Force Recommendation
V. Award Fee Process
1. Establish teams to
evaluate/streamline fee system,
reduce paperwork and resolve issues
of national consistency.
a. Establish Regional Managment
Team
b. Evaluate fee system to include
performance rating scoring
c. Submit recommendations to lead
region
d. Lead region presents
consolidated recommendations
to Fee Determination Official,
Council and Acquisition
Manager
2. EPA reinforce policy to use award
fee to influence contractor
performance
a. Contractor performance
guidance
b. Revisions/modifications made to
award fee process
c. Acquisition Manager, RMT &
ARCS Council devolpment plan
WANo.
01449
01371
Lead
Organization
Region
Region
Region
Region
Region 2
HSCD/PCMD
HSCD/PCMD
SRT
Contact
Person
S. Alvi
J. Comstock
W. Topping
U. Joiner
Type of
Delivery
naanananaMBBi
Issue
Paper
Plan
(
Original
•••••••••••
12/31/91
1/31/92
1/31/92
2/3/92*
5/31/92
6/30/92
Within
90 days of
ARCS
Council
formation
Completion Di
Carreat
•••••••••
1/31/92
3/31/92
4/30/92
5/31/92
5/31/92
6/30/92
Same
ites
Actual
IMBMMMBBBBiH
Denotes mandated data in the study.
II
-------
ARCS-StHdy Implementation
Task Force Recommendation
3. Contractor evaluated on quality of
both program management and
remedial work
a. Draft guidance to make award
fee consistent
b. Issue guidance
c. Acquisition, Council It RMT
develop monitoring plan to
ensure compliance
4. Supervisors held accountable and
fully participating in the
implementation/oversight of award
fee process
a. Issue guidance to regions on
PEB responsibilities
b. Acquisition Manager, Council
and RMT develop monitoring
plan to ensure compliance
VI. E3*A Manaeemenl Processes and
Organization
1. EPA establish Superfund Acquisition
Program Manager to oversee
acquisition activities & decisions
a. Name Acquisition Manager
WANo.
01372
01373
01450
Lead
Organization
HSCD/PCMD
PCMD
CORAS
CORAS
OSWER
OSWER
Contact
Person
J. Comslock
W. Topping
W. Topping
J. Comslock
J. Comslock
S. Lufling
S. Luffing
Type of
Delivery
nBBBBMMMBBl
Guidance
Directive #
9242.2-06
Plan
Apptrat.
i™^— ^•••i
.
OrigiiaJ
••••••••••
5/31/92
6/30/92
Within 90
days of
ARCS
Council
formation
12/31/91
Within 90
days of
ARCS
Council
formation
12/13/91
Completion Di
Cnrrent
•«••••••••
5/31/92
6/30/92
Same
.
12/31/91
Same
12/31/91
ites
Aetna!
••••••••B
1/7/92
12/13/91
-------
ARC* dy Implementation
Task Force Recommendation
2. EPA examine division of
responsibilities of HQ and regions
management responsibilities to
identify steps needed to create
effective mechanisms for
monitoring, evaluating and
formulating ARCS policy
a. Examine current HQ/Regional
managment responsibilities
b. Identify strengths/weakness
c. r»-afl recommendations
d. Final implementation plan
3. TQM employed lo establish ARCS
Council consisting of HQ and
Regional personnel
a. Establish ARCS Council
b. Convene Council to form
objectives
c. Establish TQM milestones
d. Execute recommendations
4. Create Regional Managment Teams
a. OSWER/OARM issue directive
b. Regions establish teams
WANo.
01375
01376
01451
Lead
Organization
HSCD
HSCD/PCMD
/ SRT/Region
HSCD/SET
SET
SET
Regions
HSCD
Region
Contact
Person
N.
Livingstone
S. Anders
U. Joiner
S. Alvi
N. Barmaki
N.
Livingstone
N.
Livingstone
U. Joiner
U. Joiner
U. Joiner
W. Zobel
Type of
Delivery
mmmtm^mm
Memo
Memo
<
Original
••••••••••
12/31/91
12/31/91
12/31/91
1/31/92
2/3/92*
12/31/91
1/31/92
1/31/92
7/31/92
11/30/91
12/31/91
:ompletion Da
Cnrrent
••••••••••
1/31/92
2/20/92
2/20/92
3/14/92
4/30/92
1/31/92
2/19/92
2/19/92
12/30/91
1/31/92
tes
Actnal
••••••••••••
1/31/92
2/19/92
2/19/92
1/10/92
13
h-*
LO
Denotes mandated data in the study.
13
-------
ARCS-Stndy Implementation
Task Force Recommendation
c. RMT routinely report to ARCS
Council
5. EPA establish coordinated ARCS
management information system to
serve Regions & HQ
a. ACT Steering Committee
establishment
b. PO identify data needs at Dallas
meeting
c. Memo on minimum acceptable
invoice data requirement signed
by PCMD/OERR
d. ACT HQ lest model developed
and implemented
6. Acquisition Manager designs/delivers
to each region a tailored employee
developmental/training program for
ARCS personnel
a. Establish work group to develop
training program
b. Present proposal to Waste
Management Division Directors
7. Regional Administrators form TQM
teams using Region 5 model
a. Distribute Region 5 model
b. Regional teams established
WANo.
01452
01453
01454
Lead
Organization
PCMD
OSWER
STR
Region
Region 2
Contact
Person
D. Boyd
U. Joiner
L. Garczyn
N. DiForte
Type of
Delivery
••HiiHMMM
' ' - i •
' ' -!•
Memo
— — — — _ _ — _
<
Orieinal
•••••••••••
Frequency
to be
established
by Council
11/30/91
12/12/91
3/31/92
9/30/92
'
1/31/92
2/28/92
1/31/92
6/30/92
••
Completion Dt
Cnrrent
•••••••••i
Same
12/31/91
Cancelled
1/13/92
— — — ^— — —
9/30/92
2/28/92
3/31/92
1/31/92
6/30/92
ites
Actual
••HMMBHBM
"^^— — «— — — ^— .— „
1/2/92
• — - - __
1/13/92
rr
(a
O
g"
(D
a
-------
AR Study Implementation
Task Force Recommendation
c. Regional teams report progress
to RMT
8. Evaluate feasibility of establishing
Office of Acquisition Management
to include: Policy leadership related
to procurement financial assistant.,
and interagency agreements; and
policy leadership on major system
acquisition for EPA
a. Review of Contract Management
Program, with study of
Acquisition Management
Organization structure.
WANo.
014SS
Lead
Organization
M
OARM/M&O
Contact
Person
*
R. Rizzo
Type of
Delivery
<
Original
To be
determined
by RMT
12/3/91
:om»letion Da
Cnncnt
Waiting
for Contr.
support
tes
Actual
01
o
I"
ID
3
rr
•a
»--
ui
15
-------
-------
30-DAY STUDY IMPLEMENTATION
Status as of 2/11/92
RECOMMENDATION
LEAD
CONTACT
STATUS
A. Site Completion Targets
B. Streamline the Superfund Process
1. Standardized Remedies
2. Expand Flexibility of Design
and Construction Contracts
C. Elevate Site-Specific Issues
D. Accelerate Private Party Cleanups
1. Limit Midstream Takeovers
2. Begin Design Before Consent
Decree Entry
E. Refocus Superfund Debate
1. Expand Measures of Success
2. Distinguish Federal Facilities
on the NPL
OERR
Ross
OERR
OERR
OERR
OWPE
OHPE
OWPE
OERR
OERR
Smith
Zobel
Nadeau
Connor
Connor
Connor
Matthews
Reed
Completion targets revised
Revising completion definition
Workgroup has met twice
Workgroup established
Met with DOJ and State/EPA Forum
to review issues
Policy issued 11/14/91
Draft memo circulated to Regions
Implementation underway
Released Environmental Indicators
Report on 11/25/91
Communications team formed and
drafting strategy
Draft Fed Reg notice and strategy
submitted to OMB
(U
n
a
3
U)
-------
RECOMMENDATION
F. Review Risk Policies
1. Review Superfund Risk
Assessment Guidance
2. Develop Risk Management Guidance
LEAD
ORG.
OERR
OERR
CONTACT
PERSON
Reed
Reed
STATUS
Briefed SAB on 11/8/91
Initiated review of all FY91
Superfund risk assessments
Developed communication plans
for risk assessment guidances
Planning Hill briefings
rt
rt
pi
O
r
•d
to
-------
Attachment 4
AGENCY-LEVEL WEAKNESSES/CORRECTIVE ACTIONS
CATS Tracking Number:
91 - 30
Assessable Unit/AU *;
1903 - PSPD; 1904 - WMD; 1905 - CAD;1913 - MISWD;1914 - CABD
Title of Ag£ncv-level Weakness and Description:
CONTRACT MANAGEMENT: OSW will develop and implement
standardized recordkeeping procedures for Work Assignment
Managers.
Year Identified and Source of Discovery;
OIG Audit: Management of Contracts Supporting the Office of
Solid Waste; E1XM*8-11-047-9100209; 03/89
Critical Milestones in Corrective Action;
PROJECTED
I
1
2
3
4
MILESTONE
Evaluate current practices
Develop standardized record-
keeping procedures
Train OSW staff
Implement new procedures
5 Review implementation to
assess effectiveness
Budcret Implications. If Anv:
COMPLETION
12/90
4/91
8/91
9/91
4/92
STATUS
COMPLETED
COMPLETED
COMPLETED
COMPLETED
ON SCHEDULE
N/A
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update; No Change
o December 31. 1991. Status Update: No Change
o March 31. 1992. Status Update; No change
o June 30. 1992. Status Update:
-------
-------
Attachment 5
OUST INTERNAL CONTROLS
OUST has a number of internal controls in place which apply
to all of our contracts. Listed below are the types of controls
OUST exercises in managing our contracts.
Work Assignment Managers
routinely provide input to the project officers on
contractor's performance (technical quality of products,
timeliness of delivery, compliance with budget) on specific
work assignments
maintain frequent communications with contractor's project
managers to provide clear direction on work assignment
requirements and feedback on contractor's performance under
the work assignment
Project Officers
have all taken the required project officer training offered
through the EPA Institute and are certified to serve in that
capacity
are senior level employees with extensive contracts
management experience
communicate regularly with the contracting
specialist/officer to keep abreast of issues and events
germane to OUST's contracts
have clear understanding of OUST's expectations for project
officers—standards are detailed in each project officer's
performance agreement
conduct monthly meetings with contractor's project managers
and an OUST Branch Chief who represents our Management Team
to review performance on work assignments, identify issues,
and take remedial action to ensure quality work is performed
on a timely basis at a reasonable cost
review work assignments, work plans, and modifications to
ensure the effort requested of the contractor fits within
the scope of work of the contract and does not request
contractors to undertake work which is prohibited or
inappropriate
Work Assignment Managers and Project Officers
review monthly progress reports against invoices prior to
actual payment, ensuring that charges are correct,
appropriate, and conform to requirements in the contract
-------
Attachment ^> Cp.ii)
issue and track specific subtasks under broader work
assignments to allow closer management of work and ensure
that deliverables are of high technical quality, within
budget, and on time
Branch Chief/Operating Funds Officer/Management Team Advisor on
Contracts Management
meets with project officers to discuss performance of
contractors, identify issues and potential problem areas,
and determine renedi»l steps so as to ensure OUST receives
high quality deliverables which are reasonably priced on a
timely basis
ensures internal controls for sound financial management are
followed
o reviews and approves work assignments to ensure
obligation of funds is consistent with OUST's FY92
operating plan as developed and approved by OUST's
Management Team
meets with OUST's Office Director and other senior managers
to discuss significant activities and issues related to
OUST's contracts management
reviews and signs all Action Request Forms (for issuing work
assignments and modifications and approving work plans) as
part of the standard review and approval chain, which also
includes: work assignment manager, Branch Chief/Management
Team advisor, officers for automated data processing
ramifications, project officer, and contracting officer
Office Director
provides clear guidance to staff on process to access a
contractor
dedicates staff resources to a "procurement team" tasked
with developing an unambiguous request for proposals and
establishing clear evaluation criteria. OUST's new
procurements will be offered in a full and open competitive
process to solicit proposals from a wide variety of
offerers.
reviews new contract procurements and certifies they have
adequate evaluation criteria and conform to Agency
requirements; OUST works closely with EPA's Procurement and
Contracts Management Division (PCMD) in developing
procurement packages
-------
Attachment 6
PLANNED INITIATIVES TO IDENTIFY AND CORRECT POTENTIAL
VULNERABILITIES IN CONTRACTS MANAGEMENT IN OSWER
In addition to the corrective actions already preceding
under FMFIA requirements and as a result of recent audits or
internal reviews, several areas in OSWER have been identified as
needing a more in-depth evaluation to assess vulnerability. The
internal reviews will focus on these specific issues.
1. Re-examine resource needs to reduce reliance on contractors
In FY 1990, the Superfund program conducted a detailed study
of work being performed under SF headquarters support contracts.
The study was done in response to a recommendation contained in
the Management Review of the Superfund Program that EPA begin
increasing in-house staff to reduce dependence on contractors for
policy and regulatory development support work.
Additional FTE were requested in the FY 1993 budget to
decrease reliance on contractors for: analysis of regulatory,
policy, and legislative issues; compilation of guidance to
implement EPA policy; and compilation/analysis of responses to
comments on notices published in the Federal Register. These
FTEs were not included in OMB's passback on the FY 1993 EPA
budget. We are re-examining the need for these in the FY 1994
budget process.
Recognizing that other OSWER programs are also highly
leveraged, we will examine the need to reduce reliance on
contractors for similar types of activities in each of our
program offices when we conduct our reviews.
2. Re-examine adequacy of resources devoted to contracts
management
We are analyzing the current distribution and utilization of
contract management resources in HQ and the Regions. This
analysis is necessary to update distributions that may have been
significantly impacted by the workload model freeze, and the
implementation of the new long-term contracting strategy in
Superfund. The reviews will examine the extent to which current
resource allocaitons are being actually being devoted to
contracts management.
One particular area we will look closely at is the review of
invoices. Project Officers are able to spend little time on this
and there are few written procedures in place for this effort.
-------
Attachment 6 (p.2)
3. Conduct internal review of selected contracts to ensure no
"inherently governmental functions" or activities that give
the appearance of being inherently governmental, are being
performed by contractors.
We intend to examine the CLP sample management office
contract, and the analytical/technical support contract for
reportable quantities to ensure there is no potential for
the appearance of inherently governmental functions being done
under these two contracts.
4. Co-location of contractors with EPA employees.
We are examining the need for and physiscal identification
of any on-site contractors in HQ and the Regions. Wherever
possible, we will have contractor employees located off-site. As
a result of our quick reassessment, an additional contractor
employees have been removed from EPA premises. Any remaining
contractor employees in HQ are clearly located in separate
locations from EPA employees, and are readily identifiable as
contractors. We still need to evaluate the potential for
vulnerability to personal services in two areas where employees
are co-located (ESAT and TAT contractors) .
5. Working with subcontractors.
We will examine how staff should interact through the prime
contractor when working with subcontractors, and reinforce proper
chains of communication. There exists some potential for the
appearance of directed subcontracting if proper procedures are
not followed.
6. Clarifying the roles and responsibilities of Project
Officers, Work Assignment Managers and supervisors/managers.
As discussed in the transmittal letter, we have been
developing a comprehensive training initiative to complement
our existing training, reinforce practical tools, and increase
senior management understanding of and involvement in contract
management.
-------
Attachment 7
AGENCY-WIDE ISSUES
In addition to the areas identified as requiring additional
examination within OSWER, there are three areas we would like to
highlight as Agency-wide concerns:
1. Tremendous time lags in incurred costs and indirect cost
audits.
OSWER has been concerned about the slowness of financial
audits, and has requested DIG support in conducting these audits.
However, the DIG has been experiencing seious audit backlogs.
There is no way for the programs to know what is contained in the
indirect costs — they are billed as a percentage. Only auditors
see these costs.
2. Fixed fee nature of HQ contracts
Using fixed fees limits the ways in which we can provide
incentives to improve contractor performance. The perception is
that award fees constitue "bonuses" to the contractors.
3. Guidance on reasonable costs/roles and responsibilities in
reviewing expenditures
Given the ambiguity of the FAR in certain areas, PCMD should
consider issuing some "common sense" guidance regarding what may
be regarded as a reasonable business cost. As far as possible,
these parameters should be very clear at the initiation of a
contract. The roles and responsibilities of COs, POs and
managers and auitors in monitoring expenses should also be more
clearly delineated. Other agencies, such as DOE, require their
financial management people to sign off on monthly progress
reports and other financial documents. Given that most of EPA's
work assignment managers are technical staff, there may be some
merit to considering this type of approach.
-------
-------
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
.,,„ OFFICE OF
MAR 3 I '992 AIR AND RADIATION
MEMORANDUM
SUBJECT: OAR Contract Management Review
FROM: William G. Rosenberg, Afe^tari
for Air and Radiation F^
TO: William K. Reilly, Administrator
In response to your memorandum dated March 10, 1992, attached is OAR's Contract
Vulnerability Assessment Report. This report presents an assessment of potential contract
vulnerabilities and outlines a plan of action for review of each issue identified. I will keep
you, Hank Habicht, and Chris Holmes apprised of OAR progress. I agree this matter
should be viewed with the utmost seriousness and will get the message to all OAR
employees that sound contract management practices such as those identified in my repot
are to be followed.
Attachment
cc: Hank Habicht
Deputy Administrator
Christian Holmes
Acting AA/OARM
Prmed ci Rec, lei Pap*
-------
-------
OFFICE OF AIR AND RADIATION
CONTRACTS ASSESSMENT REPORT
March 1992
-------
-------
OFFICE OF AIR AND RADIATION
CONTRACTS ASSESSMENT REPORT
I. BACKGROUND
On March 10,1992, the Administrator requested each office undertake a thorough
review of the strengths and weaknesses of its contract and project management efforts. In
response to this request, on March 12 OAR established a Contracts Management Work
Group. Its membership, comprised of senior managers from each of OAR's program offices
who report directly to the Office Directors, includes:
Michael Shapiro, Deputy Assistant Administrator OAR, Chairman
Laszlo Bockh, Office of Mobile Sources (OMS)
Ed Callahan, Office of Atmospheric and Indoor Air Programs (OAIAP)
Jeff Clark, Office of Air Quality Planning and Standards (OAQPS)
Jerry Kurtzweg, Office of Program Management Operations (OPMO)
Bill Laxton, Office of Air Quality Planning and Standards (OAQPS)
Katherine Moore, Office of Policy Analysis and Review (OPAR)
Lori Stewart, Office of Radiation Programs (ORP)
In addition, OAR has appointed a senior official to oversee contracts management
at remote sites as follows:
Charles Gray, Director for Regulatory Programs and Technology, OMS, Ann
Arbor, MI
Jed Harrison, Acting ORP Lab Director, Las Vegas, NV
Bill Laxton, Director, OAQPS Technical Support Division, Durham, NC
Sam Windham, ORP Lab Director, Montgomery, AL
Based on the urgency of the messages contained in the Inspector General's report,
OAR spent the bulk of its time between March 12 and March 26 identifying possible OAR
weaknesses. To aid in the review, OAR used Agency directives such as EPA Order 1900.2 -
Contracting At EPA. EPA Order 1900.1 - Use of Contractor Services, and the Agency's
Contracts Management Manual were used. Upon completion of OAR's preliminary review,
several areas of potential vulnerabilities in our contracting practices were identified.
OAR's initial review was based largely upon personal observations and judgments
of senior EPA staff as well as information obtained from a number of OAR project officers.
While not conclusive, this initial review suggests parts of OAR are potentially vulnerable
to a number of problems. This is because the nature of OAR's contracting efforts resemble,
in certain respects, circumstances that have led to problems elsewhere in the Agency.
Examples include:
-------
o Rapid growth and heavy workload demands as well as severe time pressures to
complete critical projects.
o Heavy workload demands on OAR contract management personnel.
o Use of on-site contractors.
o Growing reliance on fewer, larger contracts over time.
o Separation of project officer from location where work is performed.
OAR is working aggressively to determine and, if found, address potential concerns.
The following are examples of actions already underway in OAR program offices:
o On March 23 Michael Shapiro in his role as OAR's Senior Procurement Official met
with contract project officers and other personnel involved in contracts management
at the National Vehicle and Fuels Emissions Lab in Ann Arbor, MI. He also is
scheduled to meet with OAR Project Officers in Durham, N.C. and Headquarters
before the end of April. Project Officer participation is critical to our correctly
identifying potential problems and implementing reforms. These meetings provide
an opportunity to educate OAR contracts management employees on the findings of
the I.G. audit report, make them aware of steps taken to begin our own reyjew^of
OAR contract practices, give them an opportunity to raise issues important to them,
and to demonstrate senior management commitment to this process.
o The Office of Atmospheric and Indoor Air Programs (OAIAP) has worked with the
Office of Administration and Resources Management, Contracts Management
Division in RTF, NC, to implement a management review of office contracting. In
addition, the OAIAP has worked with CMD to develop a two-day contracts
symposium for all OAIAP project officers, delivery order officers and work
assignment managers. The symposium has been scheduled for May 27 and 28 in
Washington, D.C. The purpose of the symposium would be to supplement existing
Agency-wide contracts training for the office staff.
o The Office of Mobile Sources (OMS) established a check list for use by project
officers in a review of all contracts. This form required verification by Division
Directors, and an additional review and followup by Laszlo Bockh, Director of the
Program Management Office, and his staff. The review to date has resulted in: 1)
identification of the need to followup to make sure procedures for accounting for
property that is in the hands of the Contractors are in place so the equipment
reverts to the Government when the contract is completed; and 2) identification of
the need for better identification of on-site guards and other support personnel.
Review is now being extended to specific tasks and delivery orders under all
contracts.
-------
The Office of Radiation Programs (ORP) has asked all Division Directors to review
the work assignments managed by their staff to ensure the contractor is not
providing work outside of the scope or work and that no personal services are being
provided. An initial questionnaire, focusing on inherent government services, has
been completed for ORP's major LOE contract to determine potential problem
areas. This information is currently under review by ORP management.
Additionally, the Deputy Office Director is meeting with contracts management
employees to review contract management policies and procedures.
The Office of Air Quality Planning and Standards (OAQPS) has established an
internal workgroup comprised of key contract managers and project officers to
coordinate our review of contract management activities, address issues raised, and
recommend improvements. On-site contractor space has been reviewed and a
certification that all space occupied by contractors is clearly designated as such is
required. They are also conducting meetings as needed with all PO's, DOPO's, and
WAM's and their supervisors and managers to brief them on current Agency and
OAR contract management initiatives. These meetings are also being used as an
opportunity to obtain their assistance in identifying contract management
weaknesses and in initiating corrections and improvements.
OAR has also developed a contract assessment checklist to aid in the review of all
OAR contracts. This checklist will be used by all project officers to assess the contracts
under their purview. The information provided by this checklist should give us a good start
on identifying and targeting our analyses. While it is unclear at this time where
improvements might be needed, it is important to get the message to all OAR employees
that sound contract management practices such as those identified in this report are to be
followed.
II. ACTIONS TO BE UNDERTAKEN IMMEDIATELY
OAR's list of potential weakesses has been divided into two broad categories. The
first identifies issues where immediate action can be taken. The second contains a list of
issues which must be addressed before OAR can determine what additional problems, if
any, exist.
Actions Relating to CSC Delivery Orders;
Of immediate importance was an extensive project-by-project review of CSC delivery
orders to determine what issues, if any, apply to OAR managed delivery orders. OAR's
review resulted in measures taken to provide a clear physical delineation of on-site
contractors and action to provide for a clear-cut physical location for CSC support
-------
personnel. We have also taken immediate action to ensure that no personal services are
being provided. An education process has begun to ensure all employees understand the
proper role of CSC and have requested CSC do the same for its employees. At the Ann
Arbor lab, CSC issued specific guidance to its employees on relations with EPA as early as
last fall.
Actions Relating to All Contracts :
In addition, OAR Office Directors have been requested to take immediate action to
ensure their staff is applying the following sound contracting practices:
1. Emphasize to all OAR contracts management employees that contractors are not to
be providing assistance/input in the preparation of work assignments, delivery
orders and/or contract statements of work.
2. Emphasize the importance of writing definitive statements of work. This is essential
if OAR is to avoid entering into prohibited contract management practices such as
personal services, or having a contractor work beyond the provisions contained in
overall contract.
3. Assure the contractor does not begin work before a fully executed work
assignment/delivery order is in place.
4. Assure OAR employees are not directing prime contractor selection of a
subcontractor.
5. Perform an immediate review of on-site contractors and take whatever immediate
measures are possible to establish a clear distinction between contract and EPA
employees, including physical separation to the extent possible. Upon completion
of OARM's review of Agency security measures, move to implement recommendations
as expeditiously as possible.
6. Submit a justification of need for all existing on-site contractor support for the
approval of the Senior Procurement Official. This justification must be received no
later than April 17,1992. All future requests for on-site contractor support must be
cleared by the Senior Procurement Official before submittal to OARM Contracts
Management Division.
7. Take necessary steps to assure employees providing contractor technical oversight
have required certification.
8. Assure that contract vehicles are not used as a means to bypass hiring procedures.
-------
9. Assure that contractors providing support to others outside of EPA are being
adequately monitored by EPA contract managers. Contracts funded through
reimburseable and other agreements with Federal agencies may present problems of
appropriate EPA oversight.
The following course of action will be undertaken to make certain OAR employees
are aware of and take immediate steps to comply with these issues:
A. DAA meetings with all OAR Project Officers to be completed no later than
April 30, 1992.
B. Meeting with all Office Directors no later than March 30. The purpose of
this meeting will be to discuss the contents of this report, emphasizing
immediate compliance with the assurances listed above, and to initiate
further management improvement actions.
C. Memo to Office Directors no later than March 31, 1992. This memo will
require each office to outline the specific steps being taken to comply with
each of the areas listed above.
D. Memo to all OAR employees no later than April 10,1992. This memo will be
used to transmit a copy of this report to all OAR employees, along with a
reaffirmation of senior management commitment to sound contracting
practices in OAR. It will outline further steps to be taken to fully investigate
the issues contained in the next section.
HI. AREAS FOR FURTHER REVIEW
This section identifies areas where OAR feels improvements may be necessary but
for which more time, beyond the March 26 deadline for this report, is needed to investigate
fully. As emphasized in Chris Holmes* memo, we should not respond to criticism with a
flurry of short term corrective actions, only to have the problem crop up in the future. It
is important that OAR's review of its contracting practices be thorough. Therefore, OAR
is establishing a Quality Assessment Team to continue our review. Based on the findings
of this Assessment Team, OAR program offices will prepare a five year strategy for
improving their contracting practices. This Quality Assessment Team will be comprised
of representatives from each of OAR's program office and will represent a wide range of
contract experience. This team will report directly to the OAR Contracts Management
Work Group and will perform a review of the contracting "culture" in OAR. That
examination should include questions such as:
-------
6
1. Do we have sufficient controls in place to effectively monitor contractor work?
2. Is the contractor performing work outside of the contract scope?
3. Do contract management personnel have position descriptions and meaningful
performance standards in place?
4. Are OAR contracts which furnish government property for contractor use in
compliance with Chapter 5 of the Contracts Management Manual?
5. What steps are being taken to assure contractors are not unduly influencing EPA
policy?
6. Are contract employees presenting EPA policy?
7. Do we have sound fiscal accountability measures established throughout OAR?
adequate control over mixed appropriations .
- adequate validation of contractor invoices
adequate control of funds received from different programs
8. Are contracts with large subcontractor teams the most efficient use of EPA resources
9. Are there ways to enhance contractor competition in order to obtain a larger pool
of eligible contractors?
10. Is OAR becoming dependent on contractors working in high risk data/sensitive
areas?
11. Are sufficient resources dedicated to contract management?
12. Is the training received by contracting personnel adequate?
13. Has the training received by contract management employees been sufficient to
assure no actual conflict of interest or the appearance thereof?
These issues were selected based largely upon personal observations and judgments
of senior EPA staff and information obtained from project officers, and may be changed to
reflect new priorities established by the Agency's Standing Committee, the OAR Contracts
Management Work Group, or at the request of the Quality Assessment Team.
-------
7
SCHEDULE FOR COMPLETION OF QUALITY ASSESSMENT TEAM REPORTS
A. Copies of contract assessment questionnaire submitted to all OAR project
officers no later than March 30,1992, with completed forms returned to OAR
Senior Procurement Official no later than April 7.
B. Quality Assessment Team protocol for study which identifies the scope of
their review to be submitted to OAR Senior Procurement Official no later
than April 27,1992.
C. Draft report of Team findings including recommendations, if needed, to
correct potential vulnerabilities due to OAR Senior Procurement Official no
later than June 15,1992.
D. Recommendations to be reviewed by OAR Contracts Management Work
Group and final report to be submitted to AA/OAR no later than June 30,
1992.
^ E. Schedule for implementation of recommendations will be determined on a
\ case-by-case basis. However, the Administrator and the AA/OARM will be
kept informed of the results of our reviews and copies of materials provided
as appropriate.
-------
-------
-------
-------
s TV—r^, £ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
j AAlZZ g WASHINGTON, D.C. 20460
V^^^^TJ?
OFFICE OF
PESTICIDES AND TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT: Contract Management Review
FROM: Linda J. Fisher ^
Assistant Administrator
TO: William K. Reilly
Administrator
As requested in your memorandum of March 10, 1992, OPPTS has
initiated a review of contract management practices in general with
particular attention to the issues raised by the Inspector General.
During the last two weeks, OPPTS senior managers have met on a bi-
weekly basis to review the findings of the Inspector General's
report and its application to OPPTS, to assess the current state of
all of our contracts with special emphasis on national delivery
orders and CSC delivery orders, and to determine the steps we
should take to ensure our compliance with the letter and spirit of
the procurement regulations.
The results of our review thus far indicate that our primary
vulnerability appears to involve a national delivery order for data
entry of enforcement information in each Region. To begin to deal
with this vulnerability, we have brought the need for increased
oversight of this contract effort to the attention of our Regional
staffs; headquarters staff will intensively manage contractor
performance in close consultation with the Regions. In addition,
we are looking at opportunities to move contract personnel off-
site, where possible, or physically separate them from EPA
employees. We are obtaining distinguishing badges or nameplates
for all contractor personnel who will remain on-site. We are
reviewing office operational procedures to ensure that only
authorized personnel provide work assignments to designated
contractor personnel, and we are verifying that all contractor
personnel have the necessary clearances to handle CBI. In the very
near future, we will begin a more detailed vulnerability assessment
of all OPPTS contracts.
We can move quickly to make certain kinds of changes in our
contract management practices that will help to respond to some of
the criticism. However, other long-term changes in the way we do
business and the way we, as an Agency, approach procurement and
Printed on Recycled Paper
-------
contract management also need to be considered at this time. We
need to move on both levels so that our actions fully comply with
the letter and spirit of the procurement regulations.
With this in mind, we are developing a comprehensive strategy
to raise the consciousness, sensitivity, and knowledge of senior
executives, managers, and project officers regarding procurement
and contract management. As a starting point, I will meet with
all office directors, division directors, project officers, and
appropriate branch chiefs in the first week in April. This
meeting has many purposes which include stressing the Agency's
commitment to total compliance with contract management policies as
well as soliciting the ideas of these managers for additional
training, procedures, and other improvements they believe will help
to improve contract management practices and deliver important
contract services to OPPTS. I believe we, as an Agency, can do
more to educate managers about proper contract management and our
executives need to have a working knowledge of contract management
regulations and enforce accountability throughout their
organizations. In consultation with contract experts within the
Agency, we intend to develop tiered contract management training
courses that each manager will be required to attend. In too many
cases, managers need to know more than they do, or at least need a
refresher, regarding appropriate contract management principles and
practices.
During the upcoming months as we work on detailed responses to
the Inspector General's report and as we revise our procurement
procedures, there are two major considerations that we need to keep
in mind. First, EPA and OPPTS are very highly leveraged in that we
rely on contractor support to assist with important aspects of our
programs. The chances of reducing our dependency on contractors are
slim because we cannot secure the required FTEs (and we cannot pay
for all the FTEs authorized) while our budget for contracts
increases.
Second, we need the large mission-support type contracts.
Without this mechanism or some viable alternative, important
aspects of program implementation would experience unacceptable
delays. Admittedly, all levels of management need to give more of
their time and attention to development of statements of work and
oversight of contractor performance. However, with increased
management and accountability on the part of EPA personnel and by
keeping mission support contracts to a reasonable size, we believe
we can properly utilize this mechanism to provide important
services.
I would be happy to discuss any aspect of our contract
management review with you.
cc: F. Henry Habicht
Christian Holmes
OPPTS Office Directors
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 3 1992
OFFICE OF
PESTICIDES AND TOXIC SUBSTANCES
MEMORANDUM
SUBJECT: Designation of Senior Procurement Officer
Y7~}l/ /
FROM: Linda J. Fisher /? £, //^^^-^ /O
Assistant Admin istratiyr /y /
TO: Christian R. Holme^
Acting Assistant Administrator for Administration
and Resources Management
Victor. J. Kimm will serve as the Senior Procurement Officer
for the Office of Prevention, Pesticides, and Toxic Substances.
-------
-------
UNITED STATES ENVIRONMENTALPROTECTION AGENCY
WASHINGTON.D.C. 20460
OFFICE OF
PREVENTION, PESTICIDES.
AND TOXIC SUBSTANCES
April 17, 1992
MEMORANDUM
SUBJECT: Contract Management Follow-up
FROM: Linda J. Fisher Q '^dc^z**^ fc->— ^r^'l
Assistant AdministratOTaor Prevention, Feticides,
and Toxic Substances^•' ^
TO: Christian R. Holmes
Acting Assistant Administrator for Administration
and Resource Management
As discussed in my memo to the Administrator dated March 27,
1992 (copy attached), OPPTS is pursuing a number of activities to
improve our management of contracts. These issues are receiving the
full attention of our senior leadership. In addition to the March
27th memorandum, the following information is provided in response to
your request of March 31, 1992:
I. Vulnerabilities that were identified in any program,
tanagement or other audit (e.g., by OIG or GAO) during the last five
years.
OPPTS responses to OIG and GAO audits as they are completed
and initiates appropriate action, as necessary, to correct any
problems brought out by the OIG/GAO review. Over the last five years,
no vulnerabilities were noted other than those currently reported and
tracked in the FMFIA process. They are weaknesses of a
programmatic/management nature and none are directly related to
contract management issues.
II. Vulnerabilities that were identified in any internal
control review pursuant to FMFIA requirements during the last five
years.
Over the past five years, internal reviews have revealed
certain vulnerabilities of a programmatic or management nature. None
of them were associated with contracting issues. All of the planned
corrective actions have been completed except for two (Agency-level
weaknesses) currently identified and tracked in the FMFIA process.
They are:
Data Systems - Generic Chemical Review and Registration. The
ability of the systems to effectively assist in the managing and
tracking of pesticide regulatory decision making activities.
-------
-2-
Export Policy - A review of the PIC notification process for
its effectiveness in achieving Agency objectives.
III. Corrective actions initiated or completed to address
such vulnerabilities.
Corrective action plans for OPPTS1 Material Weaknesses and
Agency-level Weaknesses are inplace to address reported
vulnerabilities. Audit follow-up corrective actions in response to
OIG and GAO audits are also underway. Vulnerabilities identified by
internal reviews are complete except as reported above in item II.
IV. Implementation schedules for any corrective actions not
yet completed.
Corrective actions and a schedule of the planned completion
dates are reported in our individual responses to OIG/GAO audits.
Our progress towards the scheduled achievement of these corrective
actions is the subject of status updates in the Agency's Management
Action Tracking System (MATS). Likewise, planned schedules for
completing corrective actions of FMFIA reported weaknesses are
reported in the Agency's Corrective Action Tracking System (CATS).
V. The attached charts show the number of contracts managed
by each office in OPPTS, the type, dollar value, and purpose, as well
as the staff members involved in the management of these contracts.
As stated before, OPPTS is committed to increasing senior
management's involvement in the area of contracts management. To this
end we are negotiating with Procurement and Contracts Management
Division (PCMD), for technical assistance in developing a diagnostic
approach to evaluating current practices, and developing training
modules for OPPTS personnel for continuous contracts management
improvement.
One final note, I believe that it is crucial to keep in mind
that OPPTS is highly leveraged and underfunded in S&E. The AC&C
component of the OPPTS programs is increasing while the number of FTEs
remains relatively static. This difficult situation is exacerbated
by our shortfall in S&E because we cannot pay for the number of FTEs
allocated to us. Hopefully this problem, which is Agency-wide in
nature, can be addressed in the FY 1994 budget process.
Attachments
cc: OPPTS Office Directors
Dick White
Joyce Hay
-------
ract Sunmary
Contractor
HI ine A Co. (Sole Sourc*)
K«vric Coapeny (M Flra)
Procure. Request Proposal
Research Triangle Inst.
loane Hark* ting Research
tynaMC
ON Engineering
italcoff * Associates. Inc.
Labat- Anderson, Inc.
Laidlau fnviroraent Service
Acurex. Inc.
Veraar, Inc. (OTS)
we
Clement
> URC (OHRH)
U«C (OHM)
DPRA. Inc.
Equity Associates (Cin.)
ICF, Inc.
Computer Science* Corp.
Computer Sciences Corp.
Computer Science* Corp.
Computer Science* Corp.
Computer Sciences Corp.
UNISYS
SU
SAIC
Labajt Anderson
Labat Anderson
MMI
Ultra Tech.. Inc.
Contract ff
68020016
6BUD-0032
68090058
6B-1M01
68010006
6BU9-0052
68-020010
68-00-0142
68-D8-0166
68 MB 0104
68-01 0075
08-V80104
68-M-OI04
60010134
68-CO-M13
68-08-006
68-WO-0043
68-WO-Q043
68-MO-0843
68 UC 0043
68 WC- 0043
68-01-7437
68-09-0152
68-CB 62
68 C2 0100
68 U» 0115
68-01-0017
C.
c.
E.
C.
J.
a.
H.
A.
S.
H.
B.
C.
C.
J.
J.
H.
J.
C.
J.
D.
J.
F.
P.
P.
F.
«.
K.
H.
J.
J.
t.
EM
Project Officer
Brandt
SzywwM
•upuy
•randt
NoffAM
Conerky
Craven
•reedlove
Lawrence
Nunbaugh
Boodee
Gordon (IMM)
Gordon
Scott
Hoyer
Jaaanon
Faulkner
Parker
Noyer/l. C«lvert
Hills
Lieb
Kowell
Johnson
Johnson
Mowell
Sherrill
Souve'
Coliim
fry
BUI ings lea
Joriosoa
Trainipg
Status
CERT IF 160
CERTIFIED
CERTIFIED
CERTIFIED
CERriFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERT HIED
CERT HIED
CERTIfI£D
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
On/Off Fund
Site Type
OfF
Off
OFF
OFF
OfF
OFF
OFF
OFF
ON
OFF
OFF
OFF
OfF
OFF
OFF
OFF
OFF
OFF
OFF
ON
OFF
Ok
Off
OFF
OH
OK
Off
OFF
OFF
OF*
OFF
FF
CPff
CPFF
CPFF
FF
FF
FF
CPFF
CPFF
CPFf
CPFF
CPFF
CPAF
FF
FF
FF
FF
FF
ff
CPAF
CPFf
* 10' S FY92 C/0
Deliverable if Cent or To Date
lype Per*. * DO'S ($000)
TEtM/lOE
TERH/LOE
TEW/LOE
SPECIFIED
TEXM/IOE
TERH/LOE
Tine t Hater iais
TERH/LOE
Tiae < KateriaU
Tine t Materials
LOE
LOE
LOE
LOE
LOE
Loe
LOE
Specific Delivery
LOE
ferm/LOE
81.5
150.0
410.0
18.0
10.0
410.0
600.0
125.0
7 70.3
3.5'.5.0
249.0
3M.O
Z3.8
2
00 #35 15.5
23.0
190.0
24.0
118 .5
2 DO 4385 139.3
DO «:S2 1400.0
3 00 «283 292.0
DO *43 557.0
DO #444 317.4
4 245.0
20
75.0
40.0
2.0
?5.5
275.0
Contract
Capacity
(WOO)
S
2
5
4
4
2
5
34
34
14
S4
34
1
2
,000.0
,670.0
753.0
,771.0
.500.0
,500.0
,921.0
.265.0
,800.0
,600.0
,800.0
.800.0
.800.0
503.8
,500.0
,260.0
Contract
Description
Furchase orders
OPP Reg. develop.
Env. Che*. Hetkoctt
Feat. Usage Survey
Subscrip. to Database
Science Support
Science Support
Comunicfction
info Ngmt.
Pesticide Storage
Science Support
Science Support
Org. D eve I cement
Science Support
Org. Development
Org. Development
Decision Model
Worker Protection
MPS
Info Kgmt.
Info Hgnt.
Info Hgnt.
Info Mgmt.
Info Hgn.
Info Hgnit.
Info Hgnt.
Info Mgmt.
Disposal Seaport
Endang. Spec. Sipp.
Voice Hiil
Science Support
ro
ru
o
o
dRAND TOIAL :
X
-I
m
o
i.i
-------
MAR i o 1992
• ' .. •-.. (ON-SITE) * ol TASK/ AMOUNT FUNDED
EPA TRAINING ON FUNDING DELIVERABLE I CONTRACTOR DaiVERY FY-92COMM.- Fr92 TOTAL TOTAL $$
1 STATUS «!ITP TVPC- TVPC"' ocnor*».ici rvw^r. I ---
CONTRACTOR
DIVISION: EED
ALLIANCE
Battelle Mem.
Clement (OPP)
Cox a Assoc.
Cox a Assoc.
Gen. Sciences
Corp.
ICF (OGWP)
Midwest
Research Insl.
Research Triangle
Institute (ORD)
Versar Inc.
Woslal, Inc.
DIVISION: ETD
AST. Assoc.
ABT, Assoc.
Hampshire
ICF
Malhloch
SAIC
TRI
CONTRACT #
68-DO-8180
68-00-0126
68-01-0075
68-00-0061
68-00-0099
68-00-0080
68-CO-0083
68-00-0137
68-01-0099
68-D9-0166
68-09-0174
68-00-0020
6B-D9-0160
68-DO-0165
68-08-0116
6B-D8-0112
68-01-0156
68-09-0176
PROJ OFFICER STATUS
E
. Sterreit
E. Sterretl
WAM:J. Scoll
E
E
L
Sterren
Sierrell
Delplre
Cerlllled
Cerlllled
Cerlllled
Cerlllled
Cerlllled
Cerlllled
W:M. Romblad Cerlllled
J.
Breen
Certified
WAM: R.Rollln Certified
T.
E.
E.
C.
P.
C.
C.
C.
R.
Murray
Sierrell
Fesco
Rawlo
Bennett
Rawle
Rawlo
Rawle
Rakshpal
Cerlllled
Cerlllled
Certified
Certified
Cerlllled
Certified
Cerlllled
Certified
Cerlllled
SHE TYPE1
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
CPFF
CPFF
CPFF
CPFF
CPFF
CPFF
CPAI
CPAF
CPFF
CPAF
CPFF
CPAF
CPFF
CPFF
CPFF
CPFF
CPFF
CPFF
TYPE"
LOE
LOE
LOE
LOE
LOE
Time a maier.
LOE
LOE
LOE
Time a mater.
LOE
Spec, dellvrbl
Spoc. dollvihl
Spoc. dollvrbl
Spec, dellvrbl
Spoc. dollvrbl
Spec, dollvrbl
Spec, dellvrbl
PERSONNEL ORDERS OBLIGATE!}
1 PLANNED 1 IN CONTRACT
1 175.000 175000
0 26 612.00C
1 n/a 20.000
0 1 1 83,000
0 21 135.000
0 12 162.000
1.400.00C
20.00C
200.000
300,000
504.000
2.200.000
20.000
500.000
600,000
834.000
1 150,000 150.000 150.000
0 33 1,132.500
1 250,000
-••?.*'.
•A.
0 35 540.000
0 20 105.000
3,200.000
250,000
. "2.500.000
••• 800.-000
6.565.000
250,000
• «'
6.200.000
1,800.000
0 118 621.275
0 104 345.000
070
0 151 324.517
0 71 125.000
0 9 240.000
080
2.000.000
1,220,000
0
1.100,000
830,000
787.000
463.000
5.381,942
3.500.690
800.427
5,156.990
1.869,909
3.600.231
1.362.997
BHiei-
DESCRIPTION
Lead Prev.Handbook
Survey Design
Support
PCB Seminar
Slat Anal.Suppon
Slat. Anal. Support
Model Sup. Exposure
Rule SupVPCB
Sampling/Ana.
ol selected subs.
RESEARCH/LEAD
. EXP. ASSESS.
*;«C '
STAT,ANAL
Gen. Tech. Support
Economic Analysis
TRI Dam Analysis
Gen. Tech. Support
Economic Analysis
Engineering Suppor
Chemistry Support
-------
fXpNTOACTOR
TRI
DIVISION: IMD
CSC - CBI Center
(OIRM)
CONTRACT «
68-D1-0161
PRC/ATI -CBI Imaglns
CAS - TSCA Inventor} 68 -WO-0028
CRMI
(OARM) .:•-
PRC
CSC/NMI
(OIRM)
CSC (Non-CBI)
(OIRM)
Computer Based
Systems. Inc.
Labal-Anderson. Inc.
(OIRM)
MDL
(OARM)
PRC/Sycom
Booz-Allen
(OIRM)
SVOCM
Viar 4 Co.
68-D1-0026
68-01-7361
68-WO-0043
68-WO-0043
68-08-0013
68-W9-0052
68-WO-0007
68-01-7361
68-W9-7361
68-W1-0050
68-W8-0083
EPA. TRAINING
PROJ OFFICER STATUS
o'
R. Rakshpal Cerlllled
J. Geer Cerlllled
J. Martin Cerlllled
H.Lau Cerlllled
Y. Klnney Corlllled
Y. Klnney Cerlllled
Y. Klnney Cerlllled
D. Sellers Cerlllled
D. Sellers Cerlllled
:G.Brown .... Cerlllled
(WAM)
Y. Klnnoyh Corllllod
Newburg-RlnnCerlllled
Newburg-RInn Cerlllled
Newburg-RlnnCerlllled
C. Drew Cerlllled
ON
5JIE
No
Yes
Yes
No
No
Yes
Yes
Yes
No
No
to
to
to
to
to
FUNDING
TYPE*
CPFF
IDIQ
IDIQ
LOE-CR
IDIQ
IDIQ
IDIQ
IDIQ
IDIQ
IDIQ
IDIO
IDIQ
IDIQ
DELIVERABLE ((CONTRACTOR
JYj>F" pFRSONNEL
Spec. dollvrbl 0
Service 43
Service 1
Service 1
Service
Service 1
Service 1
Service 6
Service 0
Service 0
Service
Service 0
Service 0
Service 0
Service 0
DELIVERY FY92COMM.- FY92 TOTAL TOTAL $t
ORDERS OBLIGATED |
ELAbftlEQ |
IN CONTRACT
2 260.000
200,000]
1.330.172
1 1.377.100
1 65,000
1 598.000
21.000
1 17.800
1 182.000
1 1 1 B.tfb.0
'
1 2,760.000
1 97,100
50,000
4 300,000
2 25,000
1 300.000
1 32.000
1.377.100
65.000
625.000
21.000
17.800
182.000
215.000
4.100.000
337.500
50,000
495,000
75.000
310.000
33.000
1377100
65000
625000
21000
17800
182000
21500Q-
.
4100000*
337500
50000
495000
75000
310000
33000
BRIEF
DESCRIPTION
Chemistry Support
Doc. Proc. Center
CBI Imaginary
TSCA Inventory
"» •. *•
"f '. •
f
• *£*.**'** ''
Journal Subse.
-------
.;••:>;• ' .-•• . (ON-SITE) » ol TASK/ AMOUMT FUNDED
EPA TRAINING ON FUNDING- DELIVERABLE »CONTRACTOR DELIVERY FY92COMM.- FT92 TOTAL TOTAL$$
CONTRACT» PRO.I OFRCER STATUS SUE TYPE' TYPE"' EEBSQUbO. CBQEBS CBUGAJEfl | ELANNJEQ I IN CONTRACT
UNISYS 68-01-7347
DIVISION: EAD
CSC(OIRM) 68-WO-0043
Rll 69-D1-0011
DIVISION: PPD
ICF. Inc. (OPPE) 68-W9-0080
SAIC (Clnnclnnall) 6B-CB-0062
Cadmus ,[OW)
Ballelle ( ) 6B-CO-0063
Booi-Allen (OPM) 90-01-706
Nowburg-RlnnCerlHIed Yes IDIQ
t
S. Davis Cerlllled No
(WAM)
W. Woodbum Cerlllled Yes
J. Krleger Cerlllled
(WAM)
P. Flattery Cerlllled
(WAM)
P. Flattery Cerlllled
E. Yang (WAM) Cerlllled
J. Edward Cerlllled
(WAM)
Service
LOE
LOE
OPPT TOTALS B
0 ol OPPT Contract!
ol OPPT Contractors
ai
4 1 396,900) 451,000
0 1 • 691,175 2230000
12 n/a 809.900 1200000
BRIEF
DESCRIPTION
75.0001
40.000
30.000
25.000
75.000
•6 746 14395167 31105500 72195865
451000
2.230,000 ASHAA Loans/grant
4,800,000 TSCA Hotline
P.P. Slale Demo.
Analytical and
Logistical Suppor
LCA Impact Assess.
TCM
.VI" •
.. #
-------
c
CONTRACTOR
CONTRACT *
UAM/DOPO
TRAINING
ON/OFF FUND/DEL IV ON -SITE
SITE TYPE CONTRACTOR
TASK ORDERS
DEL ORDERS
AMOUNT FUNDED PURPOSE
FY 91/92 TO DATE TL ADD'NL PLANNED
PERSONNEL
URC
AST ASSOC
ABT ASSOC
CSC
SAIC
AMS
SRA
SRA
ABT ASSOC
SAIC
VIAR
CSC
SAIC
VIAR
VIAR
CSC
CSC
CSC
VIAR
HRA
INTEG LAB
ABT ASSOC
CSC
CSC
SAIC
VI CYAN
VIAR
UIC/OSA
68-W8-0104
68-DO-0020
68-D9-0169
68-WO-0043
68-C8-0062
68-U9-0039
68-08-0017
68-D8-0017
68-DO-0020
68-WO-0025
68-W8-0083
68-WO-0043
68- C8- 0066
68 -WO- 0083
68-WO-0083
68-WO-0043
68- WO- 0043
68-UO-0043
68-W8-0083
K.
K.
K.
P.
P.
P.
V.
P.
P.
P.
P.
0.
P.
0.
D.
J.
D.
C.
H.
68-DOO-0165B.
68-01-0159
68-08-0112
68-WO-0043
68-WO-0043
68-C8-0062
68-01-0007
68-W8-0083
68-01-7437
C.
B.
D.
D.
F.
F.
R.
F.
CHERRY
CHERRY
CHERRY
SAUNDERS
SAUNDERS
SAUNDERS
LATHROP
SAUNDERS
SAUNDERS
SAUNDERS
SAUNDERS
MEREDITH
SAUNDERS
MEREDITH
MEREDITH
MASON
MEREDITH
SECREST
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
PODNIESINSKICERTIFIED
SULLIVAN
FLETCHER
SULLIVAN
DYSON
DYSON
SMITH
SMITH
ZISA
SMITH
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
CERTIFIED
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
YES
NO
NO
NO
NO
NO
NO
YES
YES
NO
NO
NO
YES
LOE
LOE
LOE
FP/IQ
AWARD FEE
ID/10
LOE
LOE
AWARD FEE
AWARD FEE
LOE
FP/IQ
C+AWARD
LOE
LOE
FP/IQ
FP/IQ
FP/IQ
FP/ID
LOE
LOE
LOE
IQ
IQ
LOE
LOE
LOE
LOE
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
1
2
0
0
0
2
DO
WA
WA
DO
WA
DO
WA
WA
WA
WA
WA
DO
WA
DO
DO
DO
DO
DO
DO
#45
#3-02
013-06
#481
#3-81
#70
#31C-1
#31C-2
#2-65
#53
#208
#316
#C-3-84
#232
#227
#310
#070
#179
#0206
WA* 2-03
00100841
WA
00
DO
WA
WA
DO
DO
#P3-1
#368
#369
#3-40
#1-11
#219
#300-92
$9,029.00
$50,000.00
$15,000.00
$299,000.00
$136,000.00
$50,000.00
$240,000.00
$195,000.00
$100,000.00
$579,700.00
$37,000.00
$280,000.00
$200,000.00
$426,000.00
$100,000.00
$60,000.00
$339,000.00
$55,028.27
$35,000.00
$40,000.00
$100,000.00
$115,000.00
$65,000.00
$58,869.20
$40,000.00
$80,000.00
$275,000.00
$96,250.00
STRATEGIC PLANNING
MEETING PLANNING
TRACKING SYSTEM
FIFRA,TSCA,EPCRA TRACK
FIFRA SEC7 PROCESSES
SEC7 SYS EVAL
PESTICIDES DATABASE
WRK SHOP 6G INFO
TRI DATABASE
TECH OUTREACH SUPP
TEXT IMAGE PILOT
$124,000.00 DATA ENTRY SSTS/FTTS
$112,000.00 TECH INSPEC DOCUMENTS
FTTS TO LAN SYS
$200,000.00 SYSTEM ENHANCEMENTS ETS
$12,000.00 TSCA/CBI TRACKING
DATA ENTRY SSTS/FTTS
POLICY ACCESS SYSTEM
ST. LAW & SURVEY DATABAS
EPCRA SEC 313
$101,016.00 DATA AUDIT REVIEW/FIFRA
TECH&FINANCE ANAL OF P2
$41,105.15 ADP/DATA ENTRY
$40,469.92 ADP/DATA ENTRY
$20,000.00 FILE MANAGEMENT
$62,000.00 CMS SYSTEM
$185,000.00 COMPUTER SYS ENHANCEMENT
ON-SITE PC/LAN SUPP
TOTAL
$4,075.876.47
$712,591.07
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
27 1992
"WiP
MEMORANDUM
SUBJECT: Office of Water Contract Management Review -
INFORMATION MEMORANDUM
FROM: <\£-LaJuana S. Wilcher
Assistant Administrator
TO: The Administrator
THRU: AX
The Deputy Administrator
In response to your memorandum of March 10, 1992, I am
pleased to submit the attached preliminary assessment of present
or potential concerns regarding contract and project management
within the Office of Water (OW) and our plan of action to address
these concerns.
I can assure you that the Office of Water has approached
this review as a very serious matter that requires senior
management attention. In December 1991, senior OW managers and I
met with David O'Connor, Director, Procurement and contracts
Management Division, to discuss potential vulnerabilities in OW's
contract management practices. Before your memorandum, on
March 2, 1992, I directed that a work group be formed to review
OW contract and grant management practices, and to recommend
improvements. This work group is led by an OW SES executive and
includes (91-15 level representatives from all OW offices, OARM,
OGC, and two regional offices. The work group has not yet
completed its activities, but its findings to date are reflected
in the attached preliminary assessment.
The preliminary assessment indicates several areas of
concern regarding OW contract management practices. These
concerns are similar to many of those identified Agency-wide as
"cultural." The root causes of these concerns seem to be time
pressure to get quick results (and thus a tendency to cut corners
during the contract management process) and /lack of adequate
training about and attention to the details/ of the contract
management process by both supervisors and staff.
-------
A fundamental problem is that the OW staff is becoming
increasingly overloaded with contract and project management
activities. OW's AC&C budget has increased 62 percent from FY
1989 to FY 1992, but our headquarters staff FTE has increased
less than one percent in that time. Our workload continues to
grow and a great deal of it is governed by statutory deadlines,
many of which were known to be unreasonable and unachievable at
the time of enactment. In light of these challenges, it is
important that we find ways to empower our contracts management
personnel to identify and find solutions to the process problems
they face.
I intend to take several actions to address these concerns
in the near term, and will respond to the recommendations for
improvement forthcoming from the work group I mentioned earlier.
The attached assessment from our work group reflects our
preliminary findings on areas needing long term attention. In
the short term, I will be convening a special forum of all OW SES
personnel to discuss their roles in contracting matters and to
explore areas of improvement in OW contract management practices.
Further, I will recruit a full time contract management
specialist for my "front office" staff (the Policy and Resources
Management Office) to evaluate and develop methods to improve OW
contract operations, and to strengthen our office-wide contract
management capabilities. Improvements will include, at a
minimum, a more sophisticated contract tracking system (in
concert with the Agency's new Integrated contract Management
System) and revised written procedures for contract processes
(such as checkoff lists for work assignment managers to assist
them in meeting all applicable requirements). We have recently
distributed a list of contract do's and don'ts for all OW staff.
Clearly, EPA senior management needs to pay more attention
to contract management. At this time, I am asking Martha
Prothro, Deputy Assistant Administrator for Water, to serve as
our Procurement Officer as requested in Chris Holmes' February 28
memorandum. (We are, however, considering whether another
arrangement would be preferable for the long term.) Jack
Lehman's leadership in conducting this initial assessment has
been most valuable in meeting our immediate needs.
I fully support the Agency's efforts to address this
important issue. I will ensure that OW carries out the immediate
steps to improve contract management mentioned in Chris Holmes'
memorandum. I also support the efforts underway to establish
Agency-wide teams to address broad contract management issues,
such as improvements to training curricula for project officers
and work assignment managers, and improvement in the processing
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of contracting actions. These steps will help all of us meet our
programmatic responsibilities with careful adherence to good
contract management principles.
Attachments
cc: Chris Holmes
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