United States
Environmental Protection •
Agency
Administration And
Resources Management
(3304)
EPA 205-R-94-004
November 1994
£EPA
Management's Semiannual Report
To The Congress On Audits
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Cover photo: Alaska
by Steve Delaney
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TABLE OF CONTENTS
Table of Contents i
Overview of Audit Management Activities
Accomplishments and Initiatives 1
Overview of Audit Activity 1
Statistical Tables
Table 1: Final Action on Audit Reports With
Disallowed Costs 5
Table 2: Final Action on Audit Reports
With Recommendations That Funds
Be Put To Better Use 6
Table 3: Audit Reports Under Appeal or
Where a Legislative Solution is Sought 7
Table 4: Audit Reports With a Management
Decision But No Final Action 8
After One Year
EPA's Semiannual Report to Congress - Fall 1994
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OVERVIEW OF AUDIT MANAGEMENT ACTIVITIES
This Fall 1994 semiannual report on audits is submitted by EPA management in
response to the requirements of the Inspector General Act Amendments of 1988. It
highlights significant audit management accomplishments and initiatives undertaken at
EPA and provides an overview of audit activity in the previous six-month period.
ACCOMPLISHMENTS AND INITIATIVES
EPA has continued to enhance its system, first released in 1990, to track and
report on audit resolution and follow-up. In December 1992, the system was modified to
operate on a local area network. Report capabilities were broadened and file transfer
was streamlined. The system is easy to use with data quality control edits built-in; and it
is connected to the Office of Inspector General database for data consistency.
ENHANCEMENTS TO AUDIT MANAGEMENT TRACKING
1990 1991 1992 1993 1994 1995
In January 1995, the Agency plans another release of the operating software.
Many suggestions and recommendations from the network of audit followup
coordinators are incorporated. New features will include: greater flexibility for user-
defined reporting; first-time archiving capabilities; expanded on-screen help messages;
more efficient file transfer processing; new user-defined data elements; simplified report
selection; on-screen report viewing; and better tracking of performance audit follow-up.
With this upcoming January release, EPA will sponsor national training for the
audit follow-up coordinators to demonstrate the capabilities of the improved system and
provide updated guidance on various audit management concepts.
OVERVIEW OF AUDIT ACTIVITY
> Audit Reports With Final Action
During the six-month period, April 1, 1994 through September 30, 1994, EPA
completed final action on 257 audits. Of these, 180 were financial audits with
$56,301,275 disallowed costs recovered, 56 were preaward contract audits resulting in
$3,991,634 of funds reported as put to better use, and 21 were performance audits with
internal EPA corrective actions completed.
EPA's Semiannual Report to Congress - Fall 1994
Pagel
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Financial Audits - For the 180 financial assistance audit reports where EPA took
final action this period, the Office of the Inspector General questioned a total of $111.5
million. After careful management review and agreement by the OIG, the Agency
disallowed $56.3 million. Of this, EPA recovered $46.9 million and reinstated or wrote
off $9.4 million.
Costs
120
in
to
to
40
20
OIG QUESTIONED COSTS VS. AGENCY DISALLOWED COSTS
(In millions)
.....
„". -. -. -SU-I-I } » T ...
-
Spring 93
[77] Ola OiMrtpmd Co«t»
HI Agency DJn/fcnwd Ce«l«
Fall 93 Spring 94
Reporting Period
Fall 94
There are several reasons why questioned costs are significantly higher than the
disallowed costs. In many cases, the audited grantees or contractors provide additional
documentation to the Agency after the OIG has completed its audit. This
documentation supports the allowability of the claimed costs. Second, EPA officials may
allow additional costs claimed by the grantee based on further clarification of the
grantee's activities as they relate to the grant regulations.
Prior to issuing the final determination letter to the grantee, Agency officials are
required to reach agreement with the OIG on the amount of disallowed costs associated
with the audit. It is this amount that the Agency then seeks to recover through an offset
against future payments to the grantee, a "cash" collection from the grantee, receipt of
property, or through other means determined appropriate by the Agency. If efforts to
recover these funds are not successful, the Agency may deem the funds uncollectible and
write-off the amount(s).
Preaward Audits - The Agency completed final action on 56 preaward contract
audits. Of these, six audits resulted in $3,991,634 reported as put to better use.
Preaward contract audits evaluate whether the prospective cost or pricing data submitted
were current, accurate and complete.
EFA's Semiannual Report to Congress - Fall 1994
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Internal Performance Audits - The Agency completed corrective actions on 21
performance audits. Many of these audits of internal management operations involved
complex issues and required extensive effort by the responsible office to remedy
deficiencies cited by the OIG. In some cases, EPA's corrective action plans are based
on the need for states or other entities to implement their own corrective actions.
» Audit Reports With No Final Action After One Year
In this semiannual period, there are 53 audits where an audit report has been
issued, management's response has been accepted by the OIG, but corrective actions are
incomplete after one year. This represents a decrease of three audits from the last
reporting period.
AUDITS WITH FINAL ACTION EXCEEDING ONE YEAR
60
40
20
.set
Spring 92 Fall 92 Spring 93 Fall 93
Reporting Period
Spring 94
Fall 94
As illustrated by the chart below, the majority of audits reported this period with
corrective actions exceeding one year are internal performance audits of Agency
operations and external assistance agreement audits.
TYPES OF AUDITS WITH PAST DUE FINAL ACTION
2OExt*rmy
22lnumd
10 ContnatMF Owrt
1 6ln0U
Reporting Period: Fall 1994
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Overall, the reason that internal performance audits remain open one year after
issuance of the management decision is that the majority have lengthy corrective action
plans requiring extended time for full implementation and verification. As for external
grant audits, in most cases the Agency is awaiting monetary reimbursement from the
grantee. Once the Agency collects the federal share of costs owed the government, EPA
closes follow-up action on the audit. The explanations for each of the audits taking the
Agency more than one year to complete final action are listed in detail in Table 4 of this
report.
> Audit Reports In Appeal
During this reporting period, there are 137 management decisions on grant
audits that are the subject of a formal administrative appeal. This is an increase of nine
appealed management decisions over the last reporting period.
APPEALED MANAGEMENT DECISIONS
160
120
80
. 40
0
Spring 92 Fall 92 Spring 93 Fall 93
Reporting Period
Spring 94
Fall 94
Management decisions for grant audits are often appealed by the grantee,
requiring EPA to suspend final action. EPA is expanding the capabilities of its audit
tracking system to allow the Agency to better monitor the status of appealed
management decisions and the results of these appeals.
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TABLE 1: FINAL ACTION ON
AUDIT REPORTS WITH DISALLOWED COSTS
A. Balance reported at the end of previous period.
B. Adjustments to the balance of the previous report.1
C. Audit reports with management decisions on which the final
action had not been taken at the beginning of the period.
D. Audit reports on which management decisions were made
during the period.
(i) Management decisions with disallowed costs.
(ii) Management decisions with no disallowed costs.
E. Total audit reports pending final action during the period.
F. Audit reports on which final action was taken during the
period.
(i) Recoveries
a) Offsets
b) Collections
c) Value of Property
d) Other
(ii) Write-Offs
G. Audit reports needing final action at the end of the period
(subtract F from E).
Number of
Audits
283
-22
261
81
Disallowed
Costs
$178,847,079
1,113.855
179,960,934
35,276,521
54
27
4362
35,276,521
0
215,237,455
180 56,301,275
36,455,500
4,428,399
' 0
6,034,178
9,383,198
256 $158,936,180
Any difference in number of reports and amounts of disallowed costs between this report and our previous semiannual report results from
adjustments made to our audit tracking system. A reconciliation of the previous period's ending balance and this period's beginning balance is
available upon request,
This total includes an additional 94 management decisions issued by EPA on audits for which no costs were questioned.
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EPA's Semiannual Report to Congress - Fall 1994
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TABLE 2: FINAL ACTION ON AUDIT REPORTS
WITH RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE
Number of
Audits Dollar Value
A. Balance reported at the end of previous period.
B. Adjustments to the balance of the previous report.1
C. Audit reports with management decisions on which the final
action had not been taken at the beginning of the period.
D. Audit reports on which management decisions were made
during the period.
(i) Management decisions with funds to be put to better
use
(ii) Management decisions with no funds to be put to
better use
E. Total audit reports pending final action during the period.
F. Audit reports on which final action was taken during the
period.
(i) Value of recommendations that were actually
completed
(ii) Value of recommendations that management decided
should not or could not be completed
G. Audit reports needing final action at the end of the period
(subtract F from E).
60
-6
54
27
21
1252
77
48
$3,318,634
0
3,318,634
2,545,085
2,545,085
0
5,863,719
3,991,634
3,991,634
0
1,872,085
Any difference in number of reports and amounts of funds put to better use between this report and our previous semiannual report results from
adjustments made to our audit tracking system. A reconciliation of the previous period's ending balance and this period's beginning balance is
available upon request.
This total includes an additional 44 management decisions issued by EPA on audits for which no funds were recommended for better use.
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TABLE 3: AUDIT REPORTS UNDER APPEAL OR
WHERE A LEGISLATIVE SOLUTION IS SOUGHT
Under Administrative Appeal
Under Judicial Appeal
Legislative Solution Being Sought
137
0
0
137
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TABLE 4: AUDIT REPORTS WITH A MANAGEMENT DECISION BUT
NO FINAL ACTION AFTER ONE YEAR
INTERNAL AND MANAGEMENT AUDITS
Internal and management audits are independent reviews of Agency programs and operations to determine whether results
and objectives are achieved effectively, resources are management efficiently, and applicable laws and regulations are being
complied with properly. Final actions for an audit occur when all corrective actions have been implemented. Final action
may take longer than one year when corrective actions are complex and lengthy.
Report #0100206 USER CHARGE SYSTEM
Report Date: 03/28/90
Two of three commitments have been met ~ incorporated user system into the Municipal Wastewater Pollution
Prevention Program and pursued legislative changes. The last commitment is to increase emphasis on financial
management reviews in NPDES inspections. A training program is scheduled for early 1995. The program office
expects to integrate this into inspections by the end of 1995.
Report #0100508 LEAD IN DRINKING WATER
Report Date: 09/28/90
Nine of ten commitments have been met. The last commitment - revised National Sanitation Foundation standards
for brass fixtures/fittings rests with the Foundation membership and is beyond EPA control. The membership vote
is anticipated in the fall of 1995.
Report #0400018 OIL AND GAS WASTES
Report Date: 06/14/90
Eleven of thirteen commitments have been met. Final action on the last commitments - development of general
permits and promulgation of coastal oil and gas effluent guideb'nes -- are scheduled for FY 1995 and 1996 respectively.
Report #1100378 PESTICIDES INERTS
Report Date: 09/27/91
Corrective actions are underway. The final corrective actions now planned for 1999 are based on realistic projections
and resource availability. Resolving legal issues relating to confidential business information being released to the
states has also stretched out the corrective action plan.
Report #1100422 DELAWARE BAY & INLAND BAYS Report Date: 09/26/91
The final outstanding corrective action on penalties is dependent upon the State Department of Natural Resources
and Environmental Conservation publishing new regulations. EPA has reviewed and commented on a draft regulation.
The revised completion date is 7/95.
Report #1100434 CWA SEC. 404 CONSOLIDATED Report Date: 09/30/91
One commitment — revised 404(Q) guidance - is complete. A second commitment to develop a strategic plan is
pending. An annotated outline is completed. Final action is anticipated by the end of FY 1995.
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Report #1400064 QA/QC OVER LAB DATA Report Date: 09/30/91
All corrective actions have been completed except for development of a study rejection policy. The draft policy has
been developed and final policy development is expected to be completed by mid-FY 1995.
Report #2100295 EPA MGT OF CSC CONTRACT Report Date: 03/27/92
The close out of this audit is delayed because of a delay in DCAA completing its audit, and the negotiation of other
questioned costs is taking longer than expected because of the large volume of task orders. Completion is expected
on 4/1/95.
Report #2100591 EPA SYS. SOFTWARE INTEGRITY Report Date: 09/22/92
The program office believes that all actions are completed and has asked the OIG to review corrective actions to see
if they meet their expectations. Final action is expected during the first quarter of FY 1995.
Report #2100641 PCIE TASK 1 Report Date: 09/28/92
The remaining milestone for the Chapter 4 recommendation has been postponed from 3/30/95 to 10/30/95 with
validation planned for 12/30/95 to better fit with EPA's planning and budgeting cycles.
Report #2100660 SF FY 91 SF TRUST FUND Report Date: 09/30/92
The last milestone — finishing Resources Management Directive System Chapter 2550 and completion of a Superfund
justification commitment memo — are expected by 12/94.
Report #2100661 REVIEW OF OCM GLP OPER Report Date: 09/30/92
The timetable for completing all corrective actions has been affected by the Agency-wide reorganization of EPA's
enforcement and compliance program. Completion of final corrective actions is expected by mid-FY 1995.
Report #2400032 GLP AUDIT DC Report Date: 03/31/92
All issues have been addressed except for whether an accreditation program for Good Lab Practices (GLP) labs should
be part of the Agency-wide National Environmental Laboratory accreditation program. A decision on this issue is
expected in January 1995.
Report #2400056 WASTE TECH IND (C/I), OH Report Date: 07/15/92
Delay in corrective actions was necessary because of a decision to enhance the credibility of the risk assessment by
subjecting it to review by outside, expert scientists.
Report #2400065 PCB FOLLOW-UP DC Report Date: 08/21/92
The inspection guidance manual is being rewritten to make it more user-friendly. A workgroup composed of EPA
headquarters, regional and state representatives has been formed to do the rewriting. This is expected to be completed
in early 1995.
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Report #3100058 SF DECADE OF SF AUDITS Report Date: 01/04/93
The Financial Management Division believes that the milestones have been completed. FMD is in the process of
verifying that final action can be closed.
Report #3100097 PEST. IMPORTS-FOLLOWUP TX Report Date: 02/10/93
With the recent Agency-wide reorganization of EPA's enforcement and compliance program, the program office
continues to work to expedite the issuance of memorandum of understanding. Efforts continue to determine whether
the U.S. Customs Service's automated data system can partially replace the Notice of Arrival. Resolution is expected
in 1995.
*.
Report #3100114 SF INDDJECT COST RATES 87-88 Report Date: 02/24/93
The indirect cost rates cannot be produced from the existing management accounting reporting system.
Reprogramming is needed. This is underway and is expected to be completed by 3/31/95.
Report #3100152 SUPERFUND CAPPING REPORT Report Date: 03/31/93
Superfund Accelerated Cleanup Model concepts have been integrated into program office strategic goals, targets and
performance measures. National Enforcement Response policy (penalties/compliance) are under development. The
Independent Government Cost Estimate model for enforcement support services contracts and the cost recovery
procedures manual are expected to be completed early in 1995.
Report #3100156 ATHENS ERL-ORD GA Report Date: 03/31/93
Approximately 70% of the corrective actions have been completed. The remaining actions are underway. Final action
is expected on 11/30/94.
Report #3100236 ENV. RES. LAB NARRAGANSETT Report Date: 06/16/93
The program office has completed 66 of the 68 commitments. One of the remaining two open commitments (#34)
will be completed early in FY 1995.
Report #9100467 CHESAPEAKE BAY III Report Date: 09/11/89
Virginia and Maryland have revised corrective action dates to 9/30/95. For Maryland, there is a delay in implementing
the standards and subsequent permit issuance. In Virginia, metals issues have not been resolved due to a
reorganization in the State resulting in a change in personnel.
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EXTERNAL GRANT AUDITS
External grant audits are independent reviews of the records and performance of individual assistance recipients. These
audits generally involve findings which require a repayment of federal funds received for final action. Final action can take
longer than a year as the grantee may appeal, refuse to repay, or be placed on a repayment plan that spans several years.
Report #0200001 SULTANA COMM SER DIST, CA Report Date: 11/22/89 Disallowed Costs: $39,013
The grantee requested a waiver due to financial hardship. The Office of General Counsel is considering the request.
Report #0200007 BRUCE, MS Report Date: 05/07/90 Disallowed Costs: $103,524
The Town of Bruce has remitted the principal amount of $34,989 in FY 1995. The grantee did not pay any of the
interest and has appealed to EPA to write off the interest.
Report #0300008 MONTGOMERY CO SD 2, KY Report Date: 11/02/89 Disallowed Costs: $91,235
The finance office is working with attorneys for the County to develop a payment schedule.
Report #0300063 VENTURA REG SAN DIST, CA Report Date: 06/20/90 Disallowed Costs: $788,161
The region deferred action on resolution and corrective actions pending policy clarification by HO. The Office of
Water issued this clarification on 8/29/94. The region is reviewing the project against the policy. California began its
analysis in September 1994 and a final determination is expected by 12/31/94.
Region #1200001 COAL RIVER PSD, WV Report Date: 10/22/90 Disallowed Costs: $80,282
The regional office anticipates taking final action when the account receivable of $37,864 is paid.
Report #1300012 ATLANTA, GA Report Date: 10/24/90 Disallowed Costs: $3,193,310
The dispute decision was issued on 5/24/94. The finance office has begun to issue demand letters on the revised
amount -- $1,259,708.
Report #1300079 NEW IBERIA, LA Report Date: 06/19/91 Disallowed Costs: $42,722
Delinquent payment notices were sent to the City for debt collection. The delinquent account was referred to HQ.
EPA HQ is sending the second and last request to the City for its financial statements for the last 3 years.
Report #1400037 GARY SD, IN Report Date: 09/09/91 Disallowed Costs: $48,686
The final determination was issued in 1/15/92. A consent decree gives Gary until the end of 1994 to comply.
Report #1400038 GARY SD, IN Report Date: 09/09/91 Disallowed Costs: $2,810,072
The final determination was issued on 3/31/92. The entire grant of $33 million was questioned due to alleged improper
plant operation and violation of the NPDES permit. A consent decree gives Gary until the end of 1994 to comply.
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Report #1400057 IAKEWOOD, OH , Report Date: 09/27/91 Disallowed Costs: $119,975
The region referred the collection of this account receivable to the HQ claims officer. The region anticipates taking
final action after it collects the account receivable.
Region #2200004 GREEN VALLEY PSD WV Report Date: 12/16/91 Disallowed Costs: $228,465
The account receivable of $48,092 was forwarded to the EPA Claims Office on 5/6/94.
Report #2200019 CARYVILLE, TN Report Date: 05/07/92 Disallowed Costs: $321,556
The grantee had requested a deviation. EPA denied the request and is now sending demand letters for repayment.
Report #2200036 EL MIRAGE, CITY OF, AZ Report Date: 09/29/92 Disallowed Costs: $43,188
On 7/24/94, the HQ finance office forwarded the grantee's request for a repayment waiver of debt collection due to
financial hardship to the Office of General Counsel. The OGC is reviewing this request.
Report #2300051 RED JACKET PUBLIC SER. WV Report Date: 05/11/92 Disallowed Costs: $241,555
Region III anticipates taking final action when the account receivable of $105,982 is paid.
Report #2300086 NACO SAN DIST., AZ Report Date: 09/29/92 Disallowed Costs: $38,447
On 7/20/94, the HQ finance office forwarded the grantee's request for a repayment waiver of debt collection due to
financial hardship to the Office of General Counsel. The OGC is reviewing this request.
Report #2400077 GARY SD, IN Report Date: 09/28/92 Disallowed Costs: $366,172
Over $7 million of filter costs and associated engineering fees were questioned because the filters are inoperable.
Consequently, Gary is in violation of its NPDES permit. A consent decree gives Gary until the end of 1994 to comply.
Report #3200039 OZARK UnLITIES BOARD, AL Report Date: 03/19/93 Disallowed Costs: $50,332
The decision on the dispute was issued on 9/30/94. The Region has begun collection procedures.
Report #3400017 OSDBU-NAMC, DC Report Date: 01/25/93
The Quality Action Team is scheduled to meet again in January 1995 to complete the competitive grant award package.
These packages can only be developed when a grant nears expiration. The Superfund grant expires on 6/95. The
asbestos, radon and lead abatement grants expire in 10/95.
Report #5100159 EUCLID, OH Report Date: 07/12/85 Disallowed Costs: $420
Resolution of corrective action depends upon the grantee's satisfactory completion of actions approved by consent
decree. This consent decree allows the grantee until 1996 to complete corrective actions.
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Report #9100165 ESPANOLA, NM Report Date: 01/23/89 Disallowed Costs: $61,772
The region referred the debt to HQ. On 10/22/94, HQ requested additional information from the City.
SINGLE AUDITS
Single audits are external audits which examine the financial operations of a state or local government to ensure a grantee
complies with generally accepted accounting and financial procedures. Single audits are issued on a yearly orbi-yearly basis
on all federally funded grantees. Generally, the findings are non-monetary compliance actions that must be corrected. The
non-monetary corrective actions may take longer than one year to implement if the findings are complex or if the grantee
does not have the resources to take corrective action.
Report # 2500704 EQB, PR Report Date: 04/06/92
EQB is instituting various corrective actions to improve financial management in grant accounting procedures. Region
II will review next year's audit to confirm that EQB's corrective actions adequately address all audit recommendations.
Final action is estimated for 12/31/94.
CONTRACTSISUPERFUND GRANT AUDITS
Preaward contract audits evaluate whether the prospective cost or pricing data submitted were current, accurate and
complete. Final action occurs when the contract is awarded. Interim and final cost audits review the allowability of costs
claimed under the contract and determine compliance with terms and conditions of the award. Final action occurs when
repayments to EPA are received or corrective actions are implemented. Indirect cost audits evaluate whether an assistance
recipient's or contractor's prospective or incurred indirect costs rate properly allocates allowable costs. Final action occurs
when repayments to EPA rare received or corrective actions are implemented.
Report #0300095 OREGON DEQ, OR Report Date: 09/27/90 Disallowed Costs: $25,280
The State of Oregon is working to incorporate the leave allocation issue into its indirect cost rate. The procedures
involved in making leave allocation equitable and viable under the constraints of the accounting system in place are
being worked out.
Report #1300047 WASH. DEPT OF ECOLOGY, WA Report Date: 03/26/91 Disallowed Costs: $1,170
The State of Washington is working to incorporate the leave allocation issue into its indirect cost rate. The procedures
involved in making leave allocation equitable and viable under the constraints of the accounting system in place are
being worked out.
Report #1300101 GUARDIAN EWTR. SVC, DE Report Date: 08/29/91
Many issues contained in the audit report must await final settlement of all delivery orders. These delivery orders are
under various contracts associated with the audit. Settlement of the delivery orders is in process. Final action is
anticipated by 12/31/94.
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Report #1300110 ENVIRONMENTAL HEALTH, KY Report Date: 09/23/91
The contract officer issued a management decision on August 18, 1993 requesting a credit of $61,347 from the
contractor. The program office expects to take final action when it collects the account receivable.
Report #2100276 UNISYS, VA
Report Date: 03/19/94
This report was issued by DCAA to the Department of Defense. DOD is the cognizant agency and EPA can take no
action until DOD completes negotiation.
Report #2300054 EQB-FOLLOWUP REV. SUPERF. Report Date: 06/25/92
Region II continues to provide technical assistance and monitors the Environmental Equity Board (EQB) corrective
actions. EQB has taken various actions regarding audit recommendations. Region II will evaluate the 1994 audit to
see if all necessary actions were fully implemented. Final action is estimated for 12/31/94.
Report #3100085 UNISYS, VA
Report Date: 01/26/93
The unsupported costs are resolved between DCAA and the contractor and will be reflected in the supplemental report
indicating the approval and acceptance of the keypunch costs by DCAA. Final action will occur when the supplemental
report is received.
Report #3300008 SF COOPERATIVE AGREE., MD Report Date: 01/27/93
The final corrective action — to perform a QA review of management control documentation -- is scheduled for 12/94.
Report #3300032 MISSOURI DNR, MO Report Date: 03/30/93 Disallowed Costs: $198,424
The region is awaiting repayment from the grantee which will constitute final action.
Report #4000836 ENV MGT CORP (UTICA), MI Report Date: 03/30/84 Disallowed Costs: $110,106
The U.S. Attorney's Office in Michigan has negotiated a repayment schedule with the contractor. EPA receives
quarterly payments of $7,500.
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