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I                          UNITED STATES
"^               ENVIRONMENTAL PROTECTION. AGENCY
^                       WASHINGTON, D.C.

             REPORT OF FINANCIAL AND COMPLIANCE AUDIT
                 OBLIGATIONS AND DISBURSEMENTS
                             OF THE
                 HAZARDOUS SUBSTANCE SUPERFUND

                   FOR THE FISCAL YEAR ENDED
                       SEPTEMBER 30, 1967
                            Protection
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                            UNITED STATES
                   ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON,  D.C.

            REPORT OF FINANCIAL AND COMPLIANCE  AUDIT
                   OBLIGATIONS AND DISBURSEMENTS
                             OF THE
                   HAZARDOUS SUBSTANCE SUPERFUND

                     FOR THE FISCAL YEAR  ENDED
                        SEPTEMBER 30,  1987


                        TABLE QF CONTENTS

                                                          PAGE
SCOPE AND OBJECTIVES                                        1

SUMMARY QF AUDIT  RESULTS                                    2-10

BACKGROUND                                                 11-12

AUDITORS' REPORT  QN. THE SCHEDULE QF OBLIGATIONS
   AND. THE SCHEDULE Q£ DISBURSEMENTS                       13-14

AUDITORS' REPORT  ON. INTERNAL ACCOUNTING  CONTROL
   AND COMPLIANCE                                         15 - 1?

FINDINGS AND RECOMMENDATIONS

-  1.  IMPROVEMENTS ARE NEEDED  IN ACCOUNTING
       FOR AND CONTROLLING PERSONAL PROPERTY               18 - 30

x  2.  PROCEDURES FOR ALLOCATING GENERAL SUPPORT
       SERVICES COSTS SHOULD IE MODIFIED                   30 - 36

   3.  EPA NEEDS TQ STRENGTHEN PROCEDURES FOR
       MONITORING LETTERS Q£ CREDIT                        36-39

   4.  EPA HEEDS JQ MAKE IMPROVEMENTS JN. RECORDING
       AND MANAGING ACCOUNTS RECEIVABLE                    39 - 42

   5.  OBLIGATIONS WERE QUESTIONED DUE £Q
       RECORDING ERRORS                                    42 - 49

   6-  DISBURSEMENTS WERE QUESTIONED DUE £Q
       RECORDING ERRORS                                    49 - 52

   7.  RESULTS QF STATISTICAL ANALYSIS QF PERSONNEL
       COMPENSATION AND BENEFITS TRANSACTIONS              52  - 55

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                  TABLE £E CONTENTS (CONTINUED!
BXHIBITfl
                                                          PAGB
       EXHIBIT
       APPBKPTX 2
       APPENDIX
SCHEDULE OF OBLIGATIONS, FISCAL
 YEAR ENDED SEPTEMBER 30, 1967      36 - 59

SCHEDULE OF DISBURSEMENTS, FISCAL
 YEAR ENDED SEPTEMBER 30, 1967      60 - 62
SCOPE AND METHODOLOGY OF
 STATISTICAL SAMPLING               63-74

PROJECTIONS FROM THE SUPERFUND
 AUDIT FOR FISCAL YEAR 1967         73 - 90

AGENCY'S RESPONSE TO DRAFT
 AUDIT REPORT                       91 - 110

AGENCY'S SPECIFIC COMMENTS TO
 OUR DRAFT REPORT AND OUR
 EVALUATION                        111 - 122

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                       UNITED STATES
               ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON, D.C.

          REPORT OF FINANCIAL AND COMPLIANCE AUDIT
               OBLIGATIONS AND DISBURSEMENTS
                          OF  THE
                 HAZARDOUS SUBSTANCE SUPERFUND

                  FOR THE FISCAL YEAR ENDED
                     SEPTEMBER 30, 1987
                    SCOPE
OBJECTIVES
We  have performed a  financial and  compliance  audit  of the
obligations  and  disbursements  of  the  Hazardous  Substance
Superfund   (Superfund)  reported  by  the  U.S.  Environmental
Protection Agency  (EPA) for the fiscal year ended  September 30,
1987.  Our audit was performed in accordance with  generally
accepted auditing  standards and .the standards  for  financial and
compliance audits contained in the U.S. General Accounting Office
Standards fjpr^  Audit   o_£  Governmental Organizations.  Programs.
Activities,  and Functions  (1981  revision). Our examination
included tests of  the  Superfund financial  management records  of
EPA's  servicing finance  offices  located  at the  10  regional
offices, 3  major  laboratory  facilities,  and  EPA  Headquarters;
evaluations of internal accounting control for Superfund at those
locations  and the National Enforcement Investigations Center
(NEIC);  and such  other auditing  procedures  as  we considered
necessary in  the circumstances.   Audit fieldwork  was  performed
from February 16, 1988  through April 29, 1988.

As  a part  of  the  audit,  transactions  which obligated and
disbursed funds  for Superfund activities were selectively tested
using  statistical  samples.  The  scope and  methodology of the
sampling is described in Appendix 1.   The  audit objectives  were
to determine if:

        (1)   The Schedule   of Obligations and the Schedule   of
              Disbursements are presented  fairly  in  accordance
              with applicable laws, regulations, and guidelines;

        (2)   EPA management complied with laws  and regulations
              which, if not  followed,  might have  a material
              effect upon  the  Schedule  of Obligations  and  the
              Schedule   of Disbursements; and

        (3)   EPA  established  an  adequate system of  internal
              accounting control   to ensure  the  reliability  of
              applicable financial  management  records.

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                SCOPE
OBJECTIVES (CONTINUED)
The audit included a study and evaluation of internal accounting
control  for  Superfund,  including  a review  of electronic  data
processing (EDP)  controls.   Our evaluation of EDP  controls  was
limited  to  reviewing systems  documentation  for  the  Financial
Management System  (FMS).   We also  performed  limited  testing of
the  EDP  controls   related  to the  input  of obligation  and
disbursement  transactions  and   the  update   of  the   FMS.
Additionally,   we   reviewed   the   status   of   findings   and
recommendations included in the prior  audit  report  covering the
fiscal year ended September 30,  1986.

It  was not  within  the  scope  of   our  audit  to  determine  the
allowability and  allocability  of  the  general support  services
cost pools that were accumulated and allocated to Superfund or to
verify the bases for these allocations.  Our audit procedures for
cost allocations were limited  to reviewing methodologies, testing
the  mathematical  accuracy, and verifying  that the allocations
were  made in a timely manner.

                    SUMMARY QF AUDIT RESULTS

Based  upon  the results of our  audit,  it  is our opinion  that,
except for the scope limitation in determining the  allowability
and  allocability of  general  support  services costs  described
above,   EPA's   Schedule  of   Obligations   and   Schedule  of
Disbursements,  Exhibits  I  and  II,  are  presented fairly in
accordance with applicable laws, regulations and guidelines.  The
results of our tests for compliance indicated  that EPA management
has  complied  with  laws  and regulations  which might have  a
material  effect  upon the schedules identified above.   Further,
for  compliance items not tested,  nothing came to our attention
which  indicated that EPA  had  not  complied with applicable laws,
regulations and  guidelines.   Although we express no opinion on
the system of internal controls  due to  the limited purpose of our
audit, we believe that EPA has  established an adequate system of
internal accounting control  to  ensure  the reliability  of
applicable financial management  records.

However, our audit disclosed that  improvements are   needed in the
Agency's  systems for  accounting   for  and  controlling  personal
property  and procedures  for allocating general support services
costs.   In addition,  we  noted that monitoring letters of credit
and   recording   and managing  accounts  receivable   require
improvement.   Our review  of  EDP  controls  indicated that,   with
minor exceptions,   the  existing   controls   in the FMS  were
functioning properly.   We recommended  that corrective action be
taken  by the  Assistant  Administrator  (AA)  for  the  Office of
Administration and Resources Management (OARM).  [The AA referred
to  subsequently in  this  report  is  the  AA for  OARM  unless
otherwise specified.]

EPA  obligated $1,015,497,148  and  disbursed $529,833,100  from
Superfund during  the fiscal year ended  September 30,  1987.   in

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              SUMMARY OJE AUDIT RESULTS (CONTINUED)
 our  draft report, we  accepted  $990,819,220   of obligations and
 $526,964,946  of  disbursements.   We  questioned  $567,024  of
 obligations  and  set-aside  $23,215,042  of obligations based upon
 statistical  projections of errors.  The causes of the questioned
 and   set-aside  obligations  were  due  primarily  to  missing
 documentation  and lack   of written  justification  for  charging
 Superfund.   We also questioned $96,445 of  disbursements  and set-
 aside   $1,875,847  of disbursements  resulting  from  lack  of
 supporting  documentation,  based upon statistical projections of
 errors.  In addition,  we questioned  $895,862  of obligations and
 disbursements  due to   over-allocations of  general  support
 services  costs,   resulting primarily  from the  Agency  using
 budgeted  rather than actual bases for some  allocations.

 We  provided  the   Agency  with   opportunities  to respond  to the
 questioned  and set-aside costs  in our draft report.  As  a  result
 of  efforts  by  the Agency  to   locate  missing documentation,  to
 provide  written  Superfund  justifications,  and to make other
 determinations,  we have  revised our projections.   We  accepted
 $1,014,501,781 of obligations  and  $528,927,615 of  disbursements
 for  fiscal  1987.   We questioned  $995,367  of  obligations and
 $905,48^5  of disbursements.    Of  these  amounts,  $99,505  of
 obligations  and  $9,623 of disbursements were questioned due to
 revised  projections  of  errors in  sample  transactions.   We
 questioned  $895,862 of obligations and disbursements due  to over-
 allocations  of general support  services costs,  as noted  above.
 Although  Regions  4 and 5  indicated  that  adjustments were made to
 correct  $135,291   of  the  questioned cost  allocations  after our
 audit,  these  costs  are  included  in  the  obligations  and
 disbursements  presented  in  this  report  and consequently, are
.questioned.

 Note:  Questioned costs are costs that  are unallowable under the
       provisions of  applicable laws, regulations, policies, or
       program guidelines.

       Set-aside  costs are costs that  cannot  be accepted without
       additional information  or evaluations  and  approvals by
       responsible Agency program officials.

 Our  findings are  summarized  below and  presented in  detail  in  the
 Findings  and Recommendations and Exhibits.

 FINANCIAL RESULTS fi£ AUDIT

 Accepted  and questioned costs are summarized as follows:
                        TOTAL

                   $1.015.497.148
FY 1987
 Obligations
FY 1987
 Disbursements  $  529.833.100
  ACCEPTED

11.014.501.781

$  528.927.615
QUESTIONED
  COSTS

 t995.36?

 $905.485

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                 FOLLOW-UP ON PRIOR AUDIT FINDINGS

 The prior audit report,  which  covered  the period from October 1,
 1985 through September  30,  1986,  identified weaknesses related
 to: managing personal  property; allocating support  services
 costs;  and  recording  receivables.   The  report  also identified
 noncompliance  with EPA policies  for:   comparing  authorized
 signatures    on   obligation   documents   with    signature
 lists;  promptly providing  obligation documentation and  recording
 obligations;  obtaining  authorized  officials'  approvals  on
 disbursement documents;  cancelling documents after payment; and
 documenting  Superfund personnel compensation and  benefits.

 The Agency   indicated  in response  to  the prior  audit  that
 corrective actions would  be  taken  in the areas  cited  in the
 report.   However,  the  corrective  actions described  in the
 response generally were  not  scheduled  to take  place until  after
 fiscal  year  (fiscal)  1987.  Our audit  disclosed that corrective
 actions were  still  required in  accounting for  and  controlling
 personal  property,  allocating general support  services costs,
 recording and managing  Superfund  receivables, and complying with
 EPA policies for recording  obligations,  disbursements, and
 personnel compensation and benefits.  Findings in these  areas are
 summarized  below and  further discussed  in  the Findings and
 Recommendations  section  of this report.

 1•  IMPROVEMENTS   ARE  NEEDED  1H  ACCOUNTING  FOR AND CONTROLLING
    PERSONAL  PROPERTY

 Management of the Agency's  personal  property for the  Superfund
 program needs  to be  improved  with regard to  capitalizing the
 costs  in the accounting  system and controlling the  property. The
 accounting   system  did  not  account  for  Superfund  capital
 equipment.  The official property management records, which were
 the basis for capitalizing property on an Agency-wide basis, were
 not adequate or reliable  for  this purpose.  Additionally, some
 Agency property was not  recorded in the property records and some
 personal property could not be located.   We also noted at some
 locations that  no annual physical  inventories  had been  taken.
 Finally,  those  responsible  for the  property  sometimes had not
 properly  accepted custodial responsibilities.  Thus, Agency
 [personnel had not complied with applicable laws, regulations and
 lirectives.
  ^^"  i • i
 We identified several causes of the above  deficiencies  such as:
 .(1) the  absence of  reconciliation of  the  property  records with
 the financial  management  records,  (2) inadequate provision  for
• capitalizing Superfund  personal  property,  (3)  breakdown in  the
 .flow of documentation  for  recording   property,   (4)  data  input
 problems, and  (5)  noncompliance with  existing policies and
 procedures   for  physical  inventories,   sensitive items and
 transferred  property.   We recommended in  our draft  report that
 rthe Agency: supplement the  existing policies  and procedures
 
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               SUMMARY OJF AUDIT RESULTS  (CONTINUED)

 records to  the Personal  Property  Accounting  System  (PPAS);
 emphasize  to Property Accountable Officers   the  importance  of
 complying with existing guidance; provide additional training  to
 property  management  personnel;  review the  new Integrated
 Financial  Management  System (IFMS)  and  the  new PPAS  to ensure
 they will adequately capitalize and account for property; obtain
 certifications that  errors and omissions  from the PPAS  were
 corrected; and  resolve  the difference between an  EPA  Directive
 and  Regional Counsel's opinion  concerning the  need  to  sign  a
 letter of acceptance of custodial reponsibility.
 "5^1*,
 The  Agency  generally concurred with our recommendations and
 indicated  that  corrective  action had been  or  would  be taken.
 However,  the  Agency  indicated  that  an  Agency  policy  for
 reconciling property and accounting records cannot be implemented
 at the present time and a policy for  capitalizing EDP software is
 contingent upon specific  U.S.  General  Accounting  Office  (GAO)
 guidance.   Also,  the Agency did not indicate  that they would
 obtain certifications that corrections of errors in the PPAS had
 been made.   The Agency did not agree that  they needed to resolve
 the  difference between  EPA policy  and  a  Regional  Counsel's
 opinion  regarding  memorandums of   acceptance  of  custodial
 responsibility.

 We are recommending that the Agency:   establish an  interim policy
 for reconciling accounting and property records by  requiring FMOs
 to provide listings of property and  equipment  disbursements  to
 appropriate property personnel for fiscal 1988 and  on a quarterly
 basis for  fiscal 1989.  We recommend that  these listings be used
 by property  personnel to ensure  that all property  items  recorded
 in the  FMS are  recorded in PPAS.  We  are  also recommending that
 the  Agency establish a policy  for  recording and accounting for
 EDP software  based upon existing GAO requirements.   Additionally,
 we  are  recommending  that certifications  be  obtained  to ensure
 that corrections of errors and omissions from the PPAS were made
 based upon information provided by our auditors.  Finally, we are
 recommending that Property  Custodial  Officers  be  advised that
 they are required  to sign the appropriate memorandums  to accept
 custodial responsibility in accordance  with existing Agency
 policies.
  2.  PROCEDURES FOR ALLOCATING GENERAL  SUPPORT  SERVICES COSTS
      SHOULD B£ MODIFIED

/ Improvements  in  procedures  for allocations  of general  support
  services costs need  to be  implemented  to ensure  that costs
  charged  to Superfund represent the actual benefits received.   Our
  audit  disclosed  that  disbursements  were allocated to  Superfund
  based  upon cumulative  obligations  recorded for general  support
  costs  in the  Salaries  and Expenses  (S&E)  appropriation.   we  also
  questioned $895,862 of obligations  and disbursements  for  support
  costs charged  to Superfund  due  primarily  to  Headquarters

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              SUMMARY QF AUDIT  RESULTS  (CONTINUED)

utilizing budgeted in  lieu  of  actual full-time equivalent (FTE)
ratios in the allocation of certain costs.   Regions 4 and 5 made
errors  in  the  calculations  of  allocations  to  Superfund  which
resulted in $135,291  of the questioned costs.   In addition,  we
noted that Region 10  over-allocated  support  costs  and Regions 1
and 3 under-allocated support costs to Superfund by undetermined
amounts.

We recommended in our  draft  report  that  the  allocation of costs
be based on cumulative  obligations and cumulative disbursements,
respectively.   Additionally, recommendations  were made to revise
Agency  policy  to require  that  cost  allocations be  based upon
actual rather  than  budgeted FTE ratios  and  that adjustments  be
made  using  actual FTE ratios.  The Agency disagreed  with  our
recommendations on the basis that the current procedures reflect
the most accurate and practical method  of allocating these costs.
The Agency indicated that it would not be practical to implement
our recommendation  to allocate obligations and disbursements
separately.     Also,   the  Agency  stated  that   their  use
of  budgeted  data  for  certain cost   allocations  was  more
representative of  the  use of  Agency resources  and that  any
adjustments to actual for fiscal 1987 would be  insignificant.

We  disagree  with  the  Agency's  position  that  the  existing
procedures for allocating support services costs  reflect the most
accurate and  practical method of  allocating  costs.   We  are
recommending  that  the  Agency  utilize a  two-step  allocation
process  for  allocating   obligations  and disbursements  to
Superfund.  This method could be implemented  for  disbursements in
the  same  manner  that  obligations  are  now  accumulated  and
allocated.  We also believe  that cost allocations should reflect
actual usage or be  based upon  actual  data  rather than budgeted
information.  Since this information is readily available to the
Agency,  we  are recommending that all  cost  allocations be based
upon actual data.  We  further  believe that adjustments should be
made to  reflect the calculation  of allocations based  upon  actual
data, as indicated in our report, and have recommended that these
adjustments be recorded.
3.  EPA NEEDS  TO  STRENGTHEN PROCEDURES FOR MONITORING LETTERS QF
    CREDIT

Improvements in procedures are needed in  monitoring letters of
credit to ensure that:    (1)   Federal  Cash Transactions  Reports
(SF-272)  are  filed timely;   (2)  recipients do  not have  excess
cash  on  hand; and  (3)  cash  drawdowns  reported  by recipients
reconcile with FMS records.  At Regions 1,  8,  9r  and 10,  we found
that  recipients did not  submit SF-272 reports within the  15-day
period as required.  Also,  we found that  two recipients  in Region
1  had excess  cash on hand totaling  $235,000.   We reviewed   SF-
272s  to   verify  that drawdowns reported by the recipients  were
reconciled  to  the  FMOs'  records.    We  noted  discrepancies at

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              SUMMARY QF AUDIT RESULTS  (CONTINUED)

Regions 1 and 9, amounting to $44,571 and  $581,245, respectively,
as a result of  reconciliations performed by us.  Furthermore, in
Regions 1 and 9,  no reconciliations of the SF-272s to the FMOs'
records were performed by  FMO personnel.   The proper monitoring
of  recipients'  reports  increases  assurance that funds  are
approved for utilization only as actual needs arise.   We believe
that Comptroller  Policy Announcement   88-06,  issued  in February
1988,  provides  the  necessary guidance  for  monitoring  and
reconciling SF-272s and FMO records.

We recommended  in our  draft  report  that the AA for OARM request
the  Regional  Administrator  of  Region   1  to  follow-up  with two
recipients regarding  potential  excess  cash balances.   Also, we
recommended that  the  AA request the  Regional Administrators of
Regions 1, 8,  9 and 10 to notify  recipients  identified as  late
filers of SF-272s of the requirements  for timely filing.  The AA
indicated in  his  response that appropriate  corrective actions
were taken regarding follow-up by Region 1  and notifications  were
sent by Regions 1,8,  9 and 10.   We also recommended  in  our draft
report that noncomplying recipients be  formally notified and the
recipients'  responses and notifications be documented to provide
support for any potential action against the  recipients.  The AA
indicated  that  the Agency  disagreed that guidance requiring
documentation of  follow-up actions with noncomplying recipients
was necessary.  We believe that any follow-up actions  should be
documented and continue to make this recommendation.
4.  EPA NEEDS  ZQ  MAKE IMPROVEMENTS
    ACCOUNTS RECEIVABLE
                                         RECORDING  AND  MANAGING
Improvements  in  recording and  managing  accounts receivable  are
needed  to ensure  that:  (1) all  receivables are  recorded in  a
timely  manner;  (2)  the dollar  value  of  each receivable  is
recorded  and adjusted according  to Agency  policy;  and (3)  the
FMOs are  as  aggressive in collection of debts as they  should  be.
Our examination revealed instances in which: (1) interest was  not
assessed;  (2)  deficiencies  were  found   in  the  monitoring,
management and collection activities of overdue accounts, and  (3)
amounts due  to the Agency for  cost  recovery actions  or penalties
were not  recorded in a timely manner.  Deviations from prescribed
procedures were the result of  misinterpretation of Agency  policy
and reported resource limitations.   Also,  the  accounting records
did not supply  the type  of data needed to  properly  monitor  aged
accounts  receivables.

We made no recommendations in the draft report because the  Agency
was responding  to   a March 1988 audit report from the Office of
the Inspector General (OIG)  on this  matter.   The  AA  for  OARM
indicated that accounts  receivable  issues were  in  the  process of
close out as  indicated  in  the Comptroller's  February 1,  1988
response  to  the OIG report.

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              SUMMARY QF AUDIT RESULTS  (CONTINUED)
5.  OBLIGATIONS
QUESTIONED DUE 2Q RECORDING ERRORS
In our draft  report,  we questioned $567,024  and  set  aside
$23,215,042 of  the  $930,492,580  of  nonpayroll  obligations
recorded in fiscal 1987,  based  upon projections of the results of
statistical sampling.  The obligations were  set  aside primarily
due to the lack of written justification  for charging Superfund.
The questioned  obligations  were a  result of  improper  charges,
duplications and errors in Superfund obligations.  The Agency was
given the opportunity to respond to the questioned and set-aside
costs in  our samples,  and subsequent  to issuance of the draft
report, provided  additional  documentation  and  determinations by
Agency  officials.    Based  upon  the  revised  results  from
statistical sampling of  non-payroll  obligation transactions, we
questioned $99,505  of $930,492,580  recorded in fiscal 1987.
These results were based  upon  projections of the  results of our
examination  of sample transactions.  Obligations were questioned
as a result of duplicate or excessive obligations being recorded.

The  AA  also  disagreed  with our  rationale for   projecting
questioned and set-aside obligations based upon recording errors
and the lack of  written  documentation  to support obligating the
Superfund program, which  were  found  in our statistical  samples.
The  AA  indicated  that  the  Agency  did not believe   that  a
procedural deviation,  such as  lack  of written justification for
charging Superfund, should be the basis for set-aside  costs.

We believe  that  projecting questioned  and set-aside  obligations
from the  results of statistical samples is a valid  and widely
accepted audit technique.  Our rationale for the lack of  written
Superfund  justification  as  a basis for  set-aside  costs  is  that
these  justifications represent  a key  internal control procedure
required  to  support  Superfund  costs.     Without   written
justification to support charges to Superfund,  the Agency  may not
be able to support such costs  as valid Superfund expenditures in
cost-recovery actions.  We have,  however,  given  the  Agency
several opportunities  to  support the  set-aside obligations  with
documentation  that  existed  within the Agency  or determinations
that could be provided by Agency officials.  As a result, all of
the previously set-aside costs have been  resolved  and  this report
reflects projections of questioned costs  based upon  further
information provided by the Agency.


6.  DISBURSEMENTS WERE QUESTIONED DUE T_Q RECORDING ERRORS

We  questioned  $96,445  and  set  aside   $1,875,847   of  the
$447,236,028 of nonpayroll disbursements recorded in  fiscal  1967
in  our draft  report,  based upon  the projection of  results of
statistical  samples.   The questioned  costs  resulted from  c- -^
which  were  incorrectly  allocated  to  Superfund.    Disbursements
were set  aside primarily due to the lack of adequate supporting
documentation.   Based upon  the  revised  results from  statistical
                        8

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              SUMMARY QS. AUDIT RESULTS ICONTINUED)

sampling of non-payroll disbursement transactions,  we questioned
$9,623 of  $447,236,028  recorded  in fiscal 1987.   These  results
were  based  upon  projections  of  the  audit  results  of  our
examination of  sample  transactions.    The questioned  costs
resulted  from costs  which were  incorrectly allocated to  the
Super fund appropri at i on.

The AA disagreed with our basis for the projection of questioned
and set-aside disbursements due to  the  lack  of  documentation to
support Superfund disbursements.   The AA stated that the Agency's
position was that the lack of written Superfund justification was
not sufficient reason to question  or set-aside costs.

He believe that the Agency misinterpreted our basis for set-aside
disbursements.  We indicated in our draft report that these costs
were set-aside due  to  lack  of adequate  documentation.   This was
not  a lack of  written  Superfund  justification  but  missing
supporting documents such as invoices, receiving reports or other
documents required to support Superfund  disbursements.  Again, we
have given  the Agency several opportunities  to  provide  support
for the  disbursements  that resulted in the  projected set-aside
costs.   In  most cases, the Agency  did  locate support for these
transactions and our projections now reflect  revised information.
7.   RESULTS  O£ STATISTICAL ANALYSIS  QF PERSONNEL COMPENSATION
     AND BENEFITS TRANSACTIONS

Based upon  the  results  of our statistical sampling of personnel
compensation and benefits transactions, we accepted the recorded
obligations and  disbursements,  amounting  to $85,004,567 and
$82,597,072,  respectively.    However,  we  also  tested internal
control and compliance  attributes  and found unacceptable levels
of  compliance with Agency policies and procedures for recording
payroll transactions.   We recommended in  our  draft report that
the Agency  re-emphasize the importance of  compliance with Agency
policies and procedures for recording  personnel compensation and
.benefits  transactions.   The AA  for OARM  concurred with our
recommendations.

AGENCY*S COMMENTS

Audit exit  conferences were  held  with EPA  officials  at  the  10
regional  offices,  3  major laboratory  facilities,  the National
Enforcement  Investigations  Center  and  Headquarters   at the
conclusion  of fieldwork at each audit location.   The  purpose  of
the  exit  conferences  was   to   present  the   findings  and
recommendations and to  ensure a clear  understanding of the  audit
by  EPA management.  A conference was held  on June  29,  1988, with
EPA officials  at  Headquarters,  to  discuss  the  consolidated
findings and recommendations in the draft audit report.

On  July 1,  1988,  we  provided  Agency officials  with the  draft

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SUMMARY QS.
                              RESULTS (CONTINUED)
report*    The  Assistant  Administrator  for  the  Office  of
Administration and Resources  Management (OARM)  provided us with
formal written comments on our draft report in a memorandum dated
August 19, 1988.  A formal  exit conference was  held on  September
13, 1988, with  EPA officials at Headquarters,  to discuss their
response  to  the  draft  report.     To   provide  a  balanced
understanding of  the issues,  we have  summarized  the  Agency's
position above and in detail  in the Findings  and Recommendations
section of  this  report.   In addition,  we  have  included   the
Agency's  August  19, 1988 response  as Appendix  3.   We  also
included  our  evaluation  of  the  Agency's  specific  comments
(Attachment II of their response) as Appendix 4.
                        10

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                          BACKGROUND

The  "Superfund"  program  was  established  by the  Comprehensive
Environmental Response, Compensation, and Liability Act  of  1980
(CERCLA), Public Law 96-510, enacted on December 11,  1980.   The
Superfund program was  created  to protect public health  and the
environment from the release,  or threat of release,  of hazardous
substances from abandoned hazardous waste  sites (sites) and other
sources where response was not required by other Federal laws.  A
Trust  Fund was  established by  CERCLA to  provide funding  for
responses ranging  from  control  of  emergency situations  to
provision of  permanent remedies  at uncontrolled sites.   CERCLA
authorized a  $1.6 billion program' financed  by  a  five-year
environmental tax on industry and some general revenues.   CERCLA
requires  that response, or  payment for  response, be sought  from
those  responsible  for  the  problem,  including  property  owners,
generators, and transporters.

The basic regulatory blueprint for the  Superfund Program is the
National Oil and Hazardous Substances Contingency  Plan (NCP), 40
CFR Part 300.  The NCP was first  published in 1968 as part of the
Federal Hater Pollution Control  Plan and  has been substantially
revised to meet CERCLA  requirements.   The NCP lays out two broad
categories of  response:   removals  and  remedial  response.
Removals are  relatively  short-term  responses and modify an
earlier program under the Clean Water Act.  Remedial response is
long-term  planning and action to provide permanent remedies for
serious problems at abandoned or uncontrolled sites.

CERCLA  recognizes  that  the  Federal  government can  only assume
responsibility for remedial response  at a  limited number of sites
representing the greatest public threat.  It,  therefore, requires
the maintaining of  a  National  Priorities  List (NPL),  which must
be updated at  least annually.   The NPL is composed primarily of
sites  which have been  ranked  on  the  basis of a standard scoring
system  which  evaluates their  potential threat to public health.
In addition, each State was allowed to name  its highest priority
site without regard to  the ranking system.

CERCLA Section 104(c)  (3) provides that no remedial  actions shall
be taken  unless the State in which the release occurs  enters  into
a contract or cooperative agreement  with  EPA to provide certain
assurances, including cost sharing.  At privately operated sites,
the  State oust pay 10  percent of  the  costs of remedial action.
Pre-remedial   activities   (preliminary   assessments,   site
inspections), remedial  planning    (remedial investigations,
feasibility studies, remedial designs)  and removals  may be funded
100  percent  by  EPA.    For  facilities  operated by a  State or
political subdivision at  the  time of  disposal of  hazardous
substances,  the  State must pay at  least  50  percent  of all
response  costs,   including  removals and  remedial  planning
previously conducted.
                         11

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                     BACKGROUND (CONTINUED)

CERCLA was revised and  expanded  by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), Public Law 99-499,  enacted on
October 17,  1986.   SARA  reinstituted  the environmental tax and
expanded the taxing mechanisms available  for  an additional  five-
year period.  It authorized an $8.5 billion  program  for the  1987-
1991 period.  The Trust Fund was renamed  the  Hazardous Substance
Superfund.

CERCLA  Section  111(k),  as amended,  states  that  the  Inspector
General shall   conduct  an  annual   audit  of  all  payments,
obligations, reimbursements, or other uses of  Superfund to assure
that Superfund is being properly administered.
                         12

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LEONARD G. BIRNBAUM AND COMPANY
    CERTIFIED PUBLIC ACCOUNTANTS
k(OMA»o O.
Lttl.lt ». ktl»C»
IHVINO J. lAMOklH
OAVI0 SAKO'I
CAHOl A, •CHMCIOtR
ALtlMT N. FVKUOA
                                    41 MlVCft ROAD
                                •UMMIT. NEW JCftBcr 07901
                                    I0l-27>.2«44
    Mr. Ernest  E.  Bradley III
    Assistant Inspector General  for Audit
    Office  of Inspector General
    U.S.  Environmental Protection  Agency
    Washington,  D.C.  20460
                                                            OTHER OFFICES

                                                       •AN rflANCISCO. CA 4IB-t«B.a«l4
                                                        WASHINGTON. O.C. 7O9'»22-7622
                                                            TW«; 710 (Ji-oeea
                                                            CABLE; LllPCft O.C.
     AUDITORS'  REPORT OJJ
     Q£ DISBURSEMENTS
THE SCHEDULE  QF OBLIGATIONS AND THE SCHEDULE
     We  have examined  the  Schedule   of  Obligations  and the Schedule
     of  Disbursements of the Hazardous  Substance  Superfund  (Superfund)
     reported by the U.S.  Environmental  Protection Agency  (EPA)   for
     the fiscal year ended September  30,  1987,  as  presented  in  the
     Exhibits.   Except as  explained in  the following paragraph,  our
     examination was performed  in accordance with generally accepted
     auditing standards and the standards for financial  and compliance
     audits  contained in the U.S. General Accounting Office Standards
     fpr Audit of Governmental  Organizations.  Programs.   Activities.
     and  Functions   (1981  revision).  Additionally,  the  U.S.
     Environmental Protection  Agency   Hazardous Substance Superfund
     Audit Guide  (revised  February  12,  1988) was used  as  a guide  in
     our  examination.    Accordingly,  our  examination  included such
     tests  of  the  accounting records  and such   other  auditing
     procedures as we considered necessary in the circumstances.

     The Schedule  of  Obligations and  the Schedule  of  Disbursements
     contained obligations and disbursements  for  general  support
     services costs which were allocated to Superfund from  another  EPA
     appropriation.   Because of a scope limitation, we did  not  perform
     audit procedures  on the general support  services  cost pools  or
     the calculations of the bases for the  allocations of  these  costs
     to  determine  the  allowability  and allocability of the  general
     support services costs.

     The Schedule  of  Obligations and  the Schedule   of  Disbursements
     were prepared  by the EPA  Financial  Management  Division from
     financial information contained in  the Financial  Management
     System, for  the  fiscal year  ended September 30,  1987.    As
     described  in Exhibits  I and  II,   Note  1,   EPA's  policy is  to
     prepare these  schedules in accordance with accounting  policies
     and  procedures   which  are  legislatively   established   and
     promulgated  through various  Federal  and  EPA  policy   -..-
     procedural standards.   These standards  differ  in  some  respects
     from generally  accepted  accounting principles.     Accordingly,
     these schedules  are not intended to present either the financial
                             13

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AUDITORS' REPORT Ojf THE SCHEDULE Qg OBLIGATIONS AND THE SCHEDULE
QE DISBURSEMENTS (CONTINUED)

position or  the financial results  of operations  in conformity
with generally accepted accounting principles.

In  our  opinion, except  for  the qualification  described above,
with  respect  to  the allowability  and  allocability  of  the
accumulated cost  pools of general support  services and the bases
for the allocations,   the Schedule   of Obligations and Schedule
of  Disbursements  are  presented  fairly   in  accordance  with
applicable Federal  laws, regulations,  policies,  and  program
guidelines for the fiscal year ended September 30, 1987.

This report is intended for use in connection with the schedules
to which it refers and should not be used for any other purpose.
                     xt**1»
                          ^ C*&+
LEONARD G. BIRNBAUM
Summit, New Jersey
April 29, 1988
                      COMPANY
                         14

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LEONARD G, BIRNBAUM AND COMPANY
    CERTIFIED PUBUC ACCOUNTANTS
ILKONAftO «. •IKMBAUM
kUUf A.
IHVINO J.
DAVID •AKOI't
CAKOU A. •CMNtlOIN
*k»C*T M. FUKUOA
    41 KIVCH ftOAO
 •UMMIT. MCW JIKCfy 07001
     Mr.  Ernest  E.  Bradley III
     Assistant Inspector General for Audit
     Office  of Inspector General
     U.S.  Environmental Protection Agency
     Washington, D.C.  20460

     AUDITORS• REPORT Qfi INTERNAL ACCOUNTING CONTROL
                                                            OTHER OFFICES

                                                        •AN PHANCICCO. CA 4IS-M8-S014
                                                        WASHINGTON. O.C, 7O9-«21-7exi
                                                            TWK: 710 e91.0»*9
                                                            CA«UC: UIPM O.C.
COMPLIANCE
     We have examined the Schedule of Obligations and the Schedule  of
     Disbursements of  the Hazardous  Substance Superfund  (Superfund)
     reported by  the  U.S. Environmental Protection  Agency (EPA)  for
     the fiscal year ended September 30, 1987, and we have  issued  our
     Auditors'  Report thereon, dated April  29,  1988.   As part of  our
     examination,  we made a  study and  evaluation  of EPA's system  of
     internal  accounting control  for Superfund to  the  extent  we
     considered  necessary to evaluate the system  as required  by
     generally  accepted  auditing  standards  and the  standards  for
     financial  and  compliance audits  contained in  the U.S.  General
     Accounting   Office   Standards   for   Audit  of   governmental
     Organ i z a t i on s.   Programs.   Activities.   and  Functions   (1981
     Revision).    For  the  purpose of this  report,  we have  classified
     the significant internal  accounting  controls into  the following
     categories:

               Obligations
               Disbursements, including letters of credit
               Cost allocations
               Property and equipment
               Billings and receivables
               Collections

     Our study included all of  the control categories  listed above,
     except  that  we did  not  evaluate the  accounting  controls  over
     payroll obligations.  He considered our evaluation of controls for
     payroll disbursements,  from which obligations  are recorded  and
     adjusted,  sufficient for this transaction category.

     The purpose  of our  study  and evaluation was  to  determine  the
     nature, timing  and  extent  of  the auditing  procedures necessary
     for expressing an opinion on the Schedule  of Obligations and the
     Schedule  of Disbursements.   Our study and  evaluation  was more
     limited than would  be  necessary  to  express an  opinion on  the
     system  of  internal  accounting control  for Superfund  taken  as a
     whole or on any of the categories of controls identified above.
                             15

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AUDITORS'  REPORT QN.  INTERNAL  ACCOUNTING CONTROL
(CONTINUED)
COMPLIANCE
EPA management is responsible for establishing  and  maintaining a
system  of internal  accounting  control.   In fulfilling this
responsibility,  estimates  and   judgments by management are
required to  assess  the expected  benefits  and  related costs of
control  procedures.   The  objectives  of internal  accounting
control are  to  provide reasonable,  but not absolute,  assurance
that assets are safeguarded  against loss from unauthorized use or
disposition,  and  that transactions are  executed in  accordance
with management's authorization and recorded properly  to  permit
preparation of  financial  reports in accordance with  applicable
Federal  laws  and regulations.   The concept  of  reasonable
assurance  recognizes that  the  cost  of  a system of internal
accounting control should not exceed  the benefits derived and
also recognizes that  the evaluation of these factors  necessarily
requires estimates and judgments  by management.

There are inherent  limitations  that should  be  recognized in
considering the potential  effectiveness of any system of internal
accounting control.   Because of inherent limitations in any
system of  internal accounting  control,  errors  or irregularities
may nevertheless occur and  not be detected.   In  the  performance
of  most  control  procedures,  errors can  result  from  misunder-
standing  instructions,  mistakes   of  judgment,  carelessness, or
other personal  factors.   Control procedures .whose effectiveness
depend on segregation of duties can be  circumvented by collusion.
Similarly, control procedures  can be circumvented intentionally
by management, either with respect to  the execution and recording
of  transactions  or with respect   to the  estimates  and judgments
required in  the preparation of  financial  statements.   Further,
projection of  any evaluation of  internal  accounting  control  to
future periods  is  subject to the risks that  the  procedures  may
become inadequate because of changes  in  conditions and that  the
degree of compliance  with  the procedures may deteriorate.

Our study  and evaluation  made  for the limited purpose described
in  the  first  paragraph  would   not  necessarily  disclose all
material weaknesses in  the system.   Accordingly,  we do not
express an opinion on EPA's system of  internal  accounting control
for Superfund  taken  as a whole  or on any of  the  categories  of
controls  identified  in  the first paragraph.

Our study  and  evaluation  disclosed  material  weaknesses  in
accounting  for  and controlling  personal  property.    These
weaknesses resulted  from  the absence  of  control  procedures  and
non-compliance with existing controls.   As  a result, property was
not correctly  recorded  in the  accounting  system or properly
controlled within the personal property system, and is  subject to
waste,  loss,  unauthorized  use and misappropriation.   However,
these  weaknesses do not  materially  affect the Schedule  of
Obligations and the Schedule of Disbursements.
                        16

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AUDITORS'  REPORT  OJg INTERNAL ACCOUNTING  CONTROL
(CONTINUED)
COMPLIANCE
Our examination also disclosed weaknesses in the following areas
that,  although  not  considered  material  in relation  to  the
Schedule  of  Obligations  and  the  Schedule   of Disbursements, in
our opinion warrant the attention  of management:

          Allocating general support services  costs.

          Monitoring letters of credit.

          Recording and managing accounts receivable.

          Recording nonpayroll obligations and disbursements.

          Recording personnel compensation and benefits.

The above  conditions are further discussed in  the Findings and
Recommendations section of this report.

The U. S.  Environmental Protection Agency Hazardous  Substance
Suoerfund Audit  Guide  (revised February 12,  1988)   requires  a
review and evaluation of the adequacy of EPA's system of  internal
accounting control for  Superfund as a basis for reliance thereon
and for the determination of the resultant  extent of the  tests to
which auditing procedures are  to be restricted.  The audit guide
also requires a  review of CERCLA,  as amended; and other Federal
and EPA  regulations, policies, and  guidelines,  to determine if
Federal funds are being expended in accordance with provisions of
CERCLA,  as amended;  and other  Federal and EPA  regulations,
policies, and guidelines.

The results of our tests indicated that for the  items tested, EPA
complied with the provisions  of  CERCLA, as  amended;  and other
Federal and EPA  regulations, policies and guidelines,  except for
the  conditions  described  in  the  Findings  and Recommendations.
Furthermore, for the items not tested, based upon our examination
and procedures referred to  above,  nothing came to our attention
which indicated  that EPA  had not  complied with the  provisions of
CERCLA,  as amended;  and other  Federal and EPA  regulations,
policies, and guidelines, beyond the  conditions described in the
Findings and Recommendations.

This report is intended solely for  the  use  of EPA  management and
should not be used for  any other purpose.
LEONARD G. BIRNBAUM ft COMPANY
Summit, New Jersey
April 29,1988
                        17

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1.
                 FINDINGS  AND RECOMMENDATION^
IMPROVEMENTS ARE NEEDED  £N ACCOUNTING FOR  AND CONTROLLING
PERSONAL PROPERTY
Management of  the  Agency's  personal property for  the  Superfund
program needs  to be  improved  with  regard  to capitalizing  the
costs in the accounting system  and controlling the property.  The
accounting  system  did  not  account  for  Superfund  capital
equipment.  The property management  records, which were used as
the basis for capitalizing property  on an Agency-wide basis, were
not adequate or  reliable for this  purpose.   Additionally,  some
Agency property was  not recorded   in the property  records  and
some personal  property  could not  be located.  We also noted at
some  locations that  no annual physical inventories had  been
taken.  Finally,  those responsible for the property sometimes had
not properly  accepted  custodial  responsibilies.   Thus,  Agency
personnel had not complied with applicable laws,  regulations and
directives.

To  control  property  and serve  as the  basis for  the  amount
capitalized  in the accounting system  for property,  the  Agency
keeps  official property management records  in  the automated
Personal Property Accounting System (PPAS).   The  PPAS,  however,
was not designed  to:    (1) identify  property .with more  than one
appropriation;    (2)  be reconciled to property disbursement data
in  the accounting system; or  (3)  show a book  value,  including
depreciation,  we found errors  in  information about the values of
property,   custodial  responsibilities  for   property,   and
descriptions of  property.   These problems  weaken  control over
property and make  PPAS an inappropriate source for capitalizing
property, particularly by appropriation.  Weaknesses in controls
over  personal  property  have been previously identified  in the
fiscal  1986  audit report.   Corrective  actions  indicated  by the
Agency in  response  to that  report were  not expected  to be
implemented until after fiscal  1987.

At each audit location, we selected samples of Superfund property
and  equipment  items  purchased during  fiscal  1987,  which were
recorded in the Financial Management System  (FMS).   We attempted
to  trace  the items  selected to the  Personal Property Accounting
System  listings,   which  were  the   official  EPA   property
accountability records  and  to verify their  existence.   we  also
selected  samples of  Superfund  property  from  the  PPAS  and
attempted  to physically inspect the items selected.   During our
physical inspections, we selected sample items to trace into the
PPAS  listings.    In  addition,  we reviewed  documentation to
determine  compliance with  Agency policies  for  accountable and
custodial  responsibilities,  annual physical  inventories and  ot:.--
applicable procedures.
                        18

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A.
       FINDINGS AND RECOMMENDATIONS  (CONTINUED)

Incorrect Amounts  Here Recorded  In The  Personal Property
Accounting System
Amounts recorded  for property in PPAS  were  not always correct.
Our examination  of samples of  personal property at  each audit
location identified  30  items  of personal property totaling $2.1
million that were incorrectly recorded in the PPAS,  resulting in
an overstatement of Superfund property.   There were breakdowns in
the flow  of documentation  and problems  with   entering  data  in
PPAS,  which  caused  most of these errors. The  Agency also lacks
policies and procedures requiring the reconciliation of property
purchases  in the FMS with  items entered into  the PPAS.   This
reconciliation would  have  identified the above types  of errors
and would have allowed for timely adjustments by EPA management.

In the examination of Superfund property, we noted the following
errors in amounts recorded in the PPAS:
    Audit
    Location

    Headquarters
    Region 1
    Region 2
    Region 3
    Region 9
    Region 10
    Las Vegas
    RTP
    Cincinnati

        Totals
                     Number Of
                       Items

                         6
                         4
                         3
                         8
                         2
                         1
                         4
                         1
                         1
  Amounts

$   79,920
 2,099,664
     9,987
   (18,615)
       908
     4,715
        80
      (132)
    (1,860)

$2,174,667
    The  above table  represents only  those  items  that  were
    disclosed from our audit samples and does not represent  a
    complete  listing  of  items  that may have  been  incorrectly
    recorded in the PPAS.

Incorrect  amounts were  recorded  in the  PPAS  because  of  a
breakdown  in  the  flow  of  documentation  to  the  Property
Accountable Officers  (PAOs) as well  as  problems with  entering
data  into the system.   For example,  the  documents  used by  the
PAOs  to  record property items  in  PPAS often were the  receiving
copies  of  purchase  requisitions,  which did  not reflect  actual
disbursement  data.   Therefore,  the amounts  entered  in  the
property  records  did not  include  adjustments for price  changes,
freight or discounts.   An example of  entering incorrect  data in
the PPAS  was found at Region  1.   A computer costing  $2,097  was
recorded  as $2,097,029.   in this  case, the PAO  had  attempted to
correct the error, but an  incorrect code caused the adjustment to
be  rejected.    The Agency  indicated   that   this error  was
subsequently  corrected.
                         19

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)

We also noted  that  improvements were  needed  in editing and
reviewing input data.  We found that PPAS data input totals from
the system were verified against input coding sheets rather than
the original  source  documents.   In addition, custodial officers
were not  receiving monthly updated property  listings  to verify
the reasonableness of data.

Our audit disclosed  that  the  information in the property system
was not reconciled with accounting data for  property purchases  in
the FMS.   Such a  reconciliation  is  required by Title  2 of GAP
Policies and Procedures Manual For Guidance of Federal Agencies^
Appendix 1,  Section 13, which states  that Agency  property records
must be integrated with or reconciled with the accounting system.
The existing systems for property and accounting  are not designed
to be  integrated or to allow for  easy  reconciliation.    In
addition, the Agency  did  not  have  any  policies  requiring the
reconciliation or integration of these systems.   A  reconciliation
would have disclosed differences between the amounts in PPAS and
FMS.

In response to our Notifications of Findings and  Recommendations,
officials of Regions  1, 2, 3, 9,  10,  RTP, Cincinnati, Las Vegas,
and Headquarters generally concurred with the findings and stated
that the  corrections have been  or will  be  made to correct the
errors  in  amounts  recorded in  PPAS.    At a June 29,  1986
conference,  Agency officials indicated  that' the new Integrated
Financial Management System  (IFMS)  was  designed  to capitalize
personal property and interface with a property  system to prevent
future reconciliation  problems.   However, officials stated  that
these systems probably would  not be  integrated for  several  years
and, in  the  interim,  the reconciliations would  continue to be a
problem.  We suggested that  each  FMO,  in conjunction with
property personnel compare, property  information recorded in the
FMS to data recorded in PPAS on an item basis.

B.  The  Accounting System Did Not Account  For Suoerfund Capital
     Equipment

The accounting system did not  adequately account  for  Superfund
capital  equipment. Title 2  of the  GAP  Policies and  Procedures
Manual  for  Guidance  of  Federal Agencies requires  that (1)  all
property, plant,  and equipment with  an  initial  acquisition cost
of $5,000 or more  and an estimated  service  life  of 2  years  or
greater be capitalized and reported  in the  financial  statements;
and  (2)  equipment be  capitalized  when placed in service.   when
EPA purchased capital  equipment, disbursements were charged to an
operating expense account,  rather than a  capital  account.   To
adjust  the  capital equipment account, EPA  made  periodic journal
voucher adjustments. To  determine  the amount that should  be
capitalized,  EPA's Financial Management  Division  (FMD)  obtained
computer  listings   from PPAS records of  all EPA equipment  valued
at $5,000 or  more.  FMD used the listings to make adjustments  to
                         20

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            FINDINGS
RECOMMENDATIONS {CONTINUED)
bring previous  capital equipment  balances  into  agreement  with
PPAS records.

We believe the procedure described above did not adequately meet
requirements  for  capitalizing Superfund  property.    First,  the
journal  voucher  adjustments recorded all  capital  equipment,
including Superfund  purchases,  in  another  appropriation.   The
significant effects were that no  capital  equipment  was shown in
the Superfund appropriation and the Superfund operating expense
account was overstated by  the  amount of capital equipment charged
to it.  Second,  these periodic adjustments were based on the PPAS
dollar balance at a  given  date.   There are  a number of problems
with  using  property records  to record accounting transactions.
One  problem  is  that  this  nets  equipment acquisitions  and
disposals into a  single  transaction.  This precludes  proper
accounting treatment of gains or losses on sales or disposals of
capital assets.  Another problem is that PPAS was not an accurate
record  to  be  used  as   a  source of entry   for  accounting
information.  As  previously discussed, PPAS  contains errors in
amounts.  Also,  as addressed later  in  this finding,  property was
not always  recorded in PPAS.   Finally, PPAS does  not have the
capability  to   allocate  the  costs   of  property  between
appropriations.    Therefore,  PPAS  cannot  appropriately identify
property associated with specific  appropriations.

The cause of  the problems  discussed above was that EPA's FMS did
not  include transaction  codes  for  capital  asset  transactions.
There should be a standard transaction  code for  charging capital
equipment  accounts  when disbursements  are  made.   In addition,
specific  object  class codes should  be used to  identify capital
equipment.  This would require identifying capital equipment when
the procurement is initiated.

In response to our Notification of  Findings and  Recommendations,
officials of  the  Headquarters FMD disagreed with aspects of our
finding.     FMD  stated  that   the  disbursement   procedures
appropriately maintain the proper  balances  within  the accounts
in FMS.   Further, FMD believes that  existing internal controls
are   adequate to maintain  accuracy  in  the  obligation  and
disbursement process.   FMD agreed that the  journal  entry to the
capital  equipment account balances  should  not  have  been  a net
adjustment.  Also, FMD agreed that  the adjustment of  the  capital
accounts  made at September  30,  1987,  was  charged  to  another
appropriation, and FMD was looking  into remedies  to this  process
of  recording capital equipment.    FMD  stated that  the new
Integrated Financial Management System, to be phased in beginning
in January  1989, will  improve internal controls  and  will properly
provide for the capitalization of property and equipment.
C.  Property Was Not Recorded Irj The Property Records

Not  all  property  was  recorded in  the  property  records.
                                      we

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)
identified 333 items of personal  property  that  should have been
included  in  PPAS,  but  were  not.    The cost  of  this  property
totaled approximately $2.6  million.   In addition,  there  was no
Agency-wide   system  to  capture  EDP  software   information.
Information was not readily available to determine the amount of
EDP software  that should be  recorded in  the  property  records.
Also,  sensitive  property  items  were  not always covered by
personal property custody cards  as required by Agency directives.

We  selected  samples totaling approximately  1,000 Superfund
property and equipment items purchased during fiscal 1987, which
were  recorded in  the  FMS.   We  attempted  to  trace the items
selected  to   the  PPAS listings  at  each  audit  location.   The
results  of our  testing,  detailed  below,  indicated that  333
property items with a cost of $2,594,986 were not recorded in the
PPAS.  Included in this  amount was $904,954 of Superfund personal
property  that  was purchased by Financial Management Offices for
other EPA locations.  As a result,  the  PPAS did not accurately
reflect all Superfund personal  property and equipment purchased
during fiscal 1987.
 Audit
Location

Headquarters
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
RTP
NEIC
Las Vegas
Cincinnati

   Totals
Number of Items
Not Recorded in
PgAS From Sample

      27
       1
      44
      76
      21
      51
      18
       5
      36
      10
      15
      11
      14
       4

     333
    Cost
  Of Items
Not Recorded

 $  140,887
      6,825
    819,678
    106,297
    112,311
    931,613
    162,755
     36,004
     39,119
     34,226
     13,372
     89,988
     33,434
     68,457

 $2,594,966
    The  above table  represents only  those  items  that  were
    disclosed from our audit samples and does not represent  a
    complete listing of  items that may have  been omitted  from
    the PPAS.

We  also  found  during  our physical  inspections of  personal
property  that  Headquarters and Regions  1,  4, 5 and  10 did not-
maintain  accurate and up-to-date personal property  custody  card
for  sensitive  items.    Sensitive  items  are items of personal
                        22

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            FINDINGS
RECOMMENDATIONS  (CONTINUED)
property  that include,  but  are not limited to  calculators,
cameras and portable computers which, because of their nature and
portability, are  particularly susceptible  to  misappropriation.
The Personal Property Management  Manual states  that the users of
such items shall  assume full responsibility by signing a personal
property custody  card.

EPA  did  not treat EDP  software  as  capital or  accountable
property.   The  Agency  did  not require  EDP  software  to  be
identified  in PPAS  or other property records.  Information was
not readily available to  ascertain the total dollar effect  of not
capitalizing EDP  software  Agency-wide.   However,  we identified
the  purchase of  an EDP  contract  payment system  at  Research
Triangle Park, amounting to $125,000 that was  not  accounted for
or  capitalized.    Additionally,   the  Agency's  policies  and
procedures for property management did not include provisions for
capitalizing EDP software that meet  required Federal agency
capitalization criteria.

Two  of  the major objectives  of  the internal  control standards
issued  by  GAO  pursuant  to  the  Federal  Managers  Financial
Integrity Act  (31   U.S.C.  3512  (b))  are  to ensure  that all
Government-owned assets are  protected  against  waste,  loss,
unauthorized use, and misappropriation,  and  that  accountability
for assets is maintained.   One of the internal control  standards
requires  that transactions be  promptly  recorded  and  properly
classified.  Thus,  pertinent information maintains  its  relevance
to management and is useful in controlling operations and  making
decisions.   Additionally, Title  2  of the GAO  Policies ajid
Procedures Manual for Guidance of Federal Agencies  requires  that
certain  property,  plant  and  equipment,  including software, be
capitalized.

There were various  reasons why EPA property  purchases were not
recorded  in the property records.   Receiving documents were not
sent by contracting offices or custodial officers to PAOs  when
property  was ordered or received.   For example,  we found  that
Superfund  property valued at  $904,954 purchased  by several
locations  for other locations  had  not been  recorded  in  PPAS
because  documents were  not forwarded to the PAOs.  There  were
also omissions and  delays  in  entering data  in PPAS  because  the
system  waa  not  operating  during  a part  of  the fiscal  year.
Finally,  there was  some uncertainty by  EPA's  FMD  regarding  the
requirements  for  maintaining  property records  for  EDP  software.
In  addition, as  previously discussed,  the  Agency  had  no
requirements for reconciling property purchases in FMS  with PPAS
records, thereby reducing the  possibility that omissions  of
property  from PPAS  would be discovered in a timely manner.

In  response to  our findings,  Regions 3,  4,  6,  7,  RTP  and
Cincinnati  have  taken action  to correct the omissions  from the
PPAS.   The Agency  indicated that Region 5,  8  and  NEIC  are also
taking corrective  action.   Regions  2,  4,  9 and Las  Vegas
                        23

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            FINDINGS
RECOMMENDATIONS (CONTINUED)
concurred with our  findings  and indicated that procedures would
be implemented to ensure that all property received from another
FMO  was properly identified and  accounted  for in  the  PPAS.
Region  10 indicated  that 6 items were recorded  in  the PPAS but
not as  Superfund  property  and 4 items were  components of other
property.  In the Agency response, they stated that Regions 1,  4
and 5 have taken  corrective  action regarding the custody  cards.
Additionally, FMD  indicated  that they were  working  with 6AO  on
the capitalization of software and will issue a new policy.

D,   Physical Inventories Were.  Not  Performed An
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            FINDINGS AND RECQMMENPATIONS (CONTINUED)

9 of the 10 items at Region 1 and the  item  at  Region  9  had been
reported  as  missing  during  fiscal  1986.   In  addition,  at
Headquarters,  we found a memorandum,  dated September   1967, from
the PAD to a  custodial  officer  requesting the  custodial officer
to  locate  35  items of  missing property,  valued at  $116,382,
identified during  a physical  inventory.     EPA  Facilities  and
Support Services Manual.  Volume  4830-2  PMR 2-23 contains detailed
procedures to be  followed  when accountable  property  is  lost,
damaged or destroyed, including reporting to a Board  of Survey.
As  of  the end  of  our fieldwork,  no  actions  had been  taken  to
comply with  the existing  requirements for follow-up  on  these
missing items.

EPA  Facilities and  Support  Services Manual.  Volume  4830-2
Personal  Property  Management,  PMR  2-26  states:    "Capitalized
nonexpendable equipment shall  be inventoried at least annually as
prescribed in the  Federal Property  and  Administrative  Services
Act of 1949, as amended."  Failure to conduct annual inventories
and  require  the use  of proper  transfer  documents resulted  in
inaccurate property  records,  thereby increasing the possibility
of  waste,  loss,  unauthorized use  and  misappropriation  of
Superfund property.  Agency officials at the locations which did
not  perform  physical  inventories  indicated  that  inadequate
staffing and  training  of property  personnel and renovations and
relocations of offices and personnel  were  the primary reasons for
noncompliance with this requirement.

In  response to  our findings,  officials at  Regions 5  and  7 have
located the  property or reported  it missing,   and  officials  at
Regions 1, 4,  Headquarters and Las Vegas indicated that  follow-up
procedures would be initiated to locate the  missing property.  In
addition,   officials at  Regions 2,  4  and  5  and Headquarters,
indicated  that  procedures  would be  initiated  to  conduct  annual
physical inventories.

E.     Letters  Oif   Acceptance  Q£   Assumption  Of  Custodial
      Responsibilities Were Not Prepared

Custodial officers  at  RTP  and Regions 1,  2, 4, 6,  9  and  10 had
not accepted custodial responsibilities in the  manner required by
the Agency directive.  Reasons given for this were that  custodial
officers had doubts about the accuracy of  the PPAS records  or did
not have time to fulfill the  responsibilities.  In addition, the
Regional Counsel in Region 2 said the required  acceptance was not
needed.  As  a  result,  responsibility  had not  been  properly
acknowledged.   Consequently,  EPA property  was not under   proper
control,  thereby  increasing the possibility of waste,  loss,
unauthorized  use and misappropriation.

EPA Facilities and  Support Services  Manual.  Volume   4830-2
Personal  Property Management, PMR 2-21 states:

     Each  custodial  area   shall   be  placed  under  the


                         25

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            FINDINGS
    RECOMMENDATIONS  (CONTINUED)
     jurisdiction of a responsible  custodial  officer.   This
     individual shall be designated in writing by  the  head
     of  the   activity  that  has  property  management
     authority	each custodial  officer  shall  sign  the
     assumption  memorandum   indicating   acceptance   of
     custodial  responsibilities  and  submit  it  to   his
     designated  Property  Accountable  Officer.     Each
     custodial  officer	shall be  responsible  for the
     care and protection of all  personal  property assigned
     to his  custodial area,   including sensitive  items  and
     controlled property.

There were several reasons that  custodial officers  did  not sign
assumptions of  custodial  responsibilities.    Custodial  officers
were not  receiving   monthly  updated  property listings.   Also,
some officers  doubted  the  accuracy  of  the PPAS  records.    In
addition, physical inventories of custodial areas were not always
performed  upon  the  change  of custodial  officers.    Therefore,
accurate and complete records  of  property for which the officers
should  be  responsible were not  available.    Custodial  officers
also stated  that  they  had not  assumed  their  responsibilities
because of a lack  of  time and staff resources.  At Region 2,  in
some cases, there were no letters of acceptance or assumptions of
responsibilities.   Region  2  Counsel  issued an opinion  that the
assumption memorandum did not need to be  signed  for the officer
to assume responsibility for reasonable care of  the property for
which he  or  she was  accountable.  As a  result,  some  custodial
officers did not sign their memorandums.

In response to our findings,  officials at Regions 1, 4, 6, 9 and
RTP  concurred  with  the  findings and  indicated  that corrective
action has or will be taken.   Region 2 did  not  concur with our
finding,  based  on the opinion of  Regional Counsel   that the
memorandum does not  need to be signed  by custodial officers for
the official to assume property accountability.

DRAFT REPORT RECOMMENDATIONS

We  recommended  in  our  draft  report  that EPA's  Assistant
Administrator for Administration  and Resources Management:
      o  emphasize  to  Property  Accountable  Officers
         importance of complying with Agency  policies;
                                        the
      o  establish an Agency policy for reconciling property and
         accounting records;
         establish
         software;
an  Agency  policy  for  capitalizing  EDP
      o  provide  additional  training,  as necessary,  to  instruct
         property  management  personnel  'in  their  duties;
                        26

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

      o  obtain  certifications from Property Accountable Officers
         that corrective  actions  have been  taken to  correct
         errors  and omissions from the PPAS;

      o  review  the new Personal  Property  Accounting  System to
         ensure  that  it  will adequately account  for Superfund
         property  and  will  contain  data   elements  to simplify
         reconciliation procedures;

      o  review  the new Integrated Financial Management System to
         ensure  that  it  will  properly   account  for  capital
         equi pment; and

      o  resolve the difference between the  EPA Directive and the
         Region  2  Counsel's opinion concerning the need to  sign a
         letter  of acceptance of custodial responsibility.
AGENCY'S RESPONSE TO

The Assistant Administrator
and  Resources  Management
recommendations that:
REPORT RECOMMENDATIONS

 (AA)  for the  Office of Administration
 (OARM)  stated  in response to  our
       o  The  Director,  Facilities  Management  and  Services
          Division (FMSD),  will send a memorandum to the property
          accountable  officers   re-emphasizing  the  Agency's
          requirements  for  property.

       o  Although  they   agree   with  the  recommendation   to
          establish an  Agency policy for reconciling property  and
          accounting records,   it  cannot be  implemented at  the
          present time.    In fiscal  1989,  the  Agency  plans  to
          retrieve  data from  the Financial Management System
          (FMS) to  capitalize property items.   This  effort will
          be  coordinated  with  the FMSD.   In addition,   the
          Director, Financial Management Division  (FMD),  has
          reviewed  the  capabilities of  the  new  Integrated
          Financial Management  System (IFMS)  to ensure  that  the
          reconciliation function  is  sufficient to  comply with
          the General Accounting  Office's (GAO) requirements.

       o  Using specific GAO guidance relative  to capitalization
          Of Federal Government assets, the  Director,  FMD,  will
          provide  the  appropriate accounting structure  and
          guidance  to  account  for EDP software.   Such guidance
          will  be  incorporated  in  the  Resources  Management
          Directives System during fiscal 1989.

       o  The  Director, FMSD,  has requested  additional property
          management resources  through the  budget process and has
          augmented  resources  through the use  of  task forces.
          FMSD has  established a  Superfund Property  Policy Task
          Force   and  a Property  Management  Roundtable.
                        27

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           FINDINGS
RECOMMENDATIQMS  fCONTINUED)
         addition,  training sessions for property management
         officers  have been  held  in  Cincinnati,   Research
         Triangle Park  (RTF)  and Headquarters in  1967.   Also,
         FMSD will  review the  contents of  current  training
         sessions  to incorporate issues  raised  in  this  audit
         report.

      o  The  Director,  FMSD,  will  be required to correct and
         update the  PPAS based on physical inventories taken by
         property management officers. Each property management
         officer  will  be  instructed   to  provide   written
         confirmation to the FMSD that such inventory has been
         completed.

      o  FMSD is currently reviewing the  new PPAS to ensure that
         the  requirements for Superfund accountability  are being
         met.  The  new  PPAS will be  reviewed for  opportunities
         to streamline the reconciliation process.  The new PPAS
         will be  an   interim  system  until the  Integrated
         Financial  Management  System  is  implemented  in fiscal
         1989  and  will   eliminate the   need  for  manual
         reconciliation.

      o  The  Director,  FMD,  through  the IFMS  taskforce,  has
         worked  extensively with the Director,  FMSD,   to ensure
         that the property module of IFMS meets the needs of the
         Agency.   FMD  held an  extensive  review and comment
         period  to  address  the technical, policy and procedural
         capabilities of IFMS  throughout  OARM and  will continue
         to do so throughout the IFMS implementation process in
         fiscal  1989.

      o  OARM disagrees  that a conflict  exists between the
         Agency Directive and  the  Region  2 General Counsel
         opinion.   Custodial  officers are required to sign for
         property as part  of  their  responsibilities.   In the
         event that custodial  officers do  not  sign for the
         property,   they   are   not   relieved   of   their
         responsibilities.  Therefore, the Director, FMSD, will
         notify  custodial  officers,  in  writing,   of  their
         responsibilities as outlined by the EPA Directive.

OUR EVALUATION O£ THE AGENCY'S RESPONSE

The  Agency's  response  to our  draft  report recommendations
indicated proposed corrective  actions that,  if implemented, were
generally responsive to  our  recommendations for:   (1)  emphasizing
compliance with  Agency policies;   (2)   providing  additional
training for property management  personnel; and (3)  reviewing  the
new PPAS and  the  IFMS to ensure  that Superfund property wili  ~*.
properly accounted  for,  capitalized and  reconciled between  the
two  systems.   Consequently,  we  make  no  further  recommendations
regarding  these  issues.   However,  the Agency's  action on  our
                        28

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            FINDINGS
RECOMMENDATIONS (CONTINUED)
other  recommendations  in the  draft report  were  not considered
sufficient to ensure that appropriate corrective action would be
taken in a timely manner.  In  regard to the  Agency's response to
our  recommendation for establishing  policy  on  reconciling
property  and accounting  records,   we  do  not believe  that the
proposed  interim procedures are  sufficient  to  ensure adequate
accounting records or property  controls.   The data  that FMD  plans
to use in fiscal 1989 is retrievable from  FMS for fiscal 1988 and
prior years.  We believe that this  information should be obtained
for fiscal  1988  and used to ensure the update of    the property
records in the PPAS.   The coordination of these procedures with
subsequent physical inventories  of  property  would  disclose
Superfund property that is unaccounted  for.

The Agency's  response  to our  recommendation on establishing an
Agency policy for capitalizing EDP  software  indicates that  their
policy will be based on guidance that the  U.S. General Accounting
Office  (GAO)  has not as  yet issued.  However,  GAO has  already
issued guidance  requiring EDP  software with  an acquisition cost
of $5,000  or more and an estimated useful life  of two years or
greater be capitalized.   Therefore, we believe the  Agency should
provide guidance to implement the current  GAO policy.

Based  upon the Agency's  response  to our  recommendation  on the
correction of errors and omissions from  the PPAS,  we agree that
the PPAS  should  be  updated  from results of  physical inventories
taken  by  property management  officers when  they are  performed.
However, we believe  that the errors and omissions  identified in
our  audit report  should be  corrected in the PPAS based upon
information provided by our auditors during  the audit  fieldwork.
The results of physical  inventories would  not disclose errors in
recorded amounts in the  PPAS identified by the audit.

Our  recommendation regarding  the  need  for Property Custodial
Officers to sign Memorandums Of Acceptance By Custodial Officers
was  based upon  EPA's  Property Management Regulations. Regional
Counsel in Region 2 indicated that an executed memorandum  was not
essential  in  order  to  assume property accountability nor did it
preclude the Custodial Officers from performing the function.  We
believe that since the requirement has been established as Agency
policy, the  Regions should be consistent  in application of  the
policy.
RECOMMENDATIONS

We   recommend   that   EPA's   Assistant
Administration and Resources Management:
                    Administrator   for
     o  establish an  interim Agency policy  requiring  each FMO to
        provide  listings  of  property  and equipment disbursements
        from  the FMS and  copies  of supporting  documentation to
        the  appropriate  Property Accountable Officers on an
        annual  basis  for  fiscal  1988 and  on  a quarterly  basis
                        29

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2.
       FINDINGS AND RECOMMENDATIONS  (CONTINUED)

   beginning in fiscal 1989;

o  instruct  the   Director,   FMSD,  to  require  Property
   Accountable Officers to utilize the listings of property
   disbursements furnished by  the  FMOs to ensure that all
   property items recorded in the FMS  are  also recorded in
   PPAS;

o  establish an Agency policy  for capitalizing EDP software,
   based upon existing GAO requirements;

o  obtain certifications from Property Accountable Officers
   that corrective  actions have  been taken to correct the
   remaining errors and omissions  from  the PFAS; and

o  instruct the Director,  FNSD, to advise Property Custodial
   Officers  at Region  2   that  they are  required to  sign
   Memorandums Of Acceptance By Custodial Officers according
   to Agency policy.


PROCEDURES  FOR ALLOCATING GENERAL  SUPPORT SERVICES  COSTS
SHOULD SI MODIFIED
Procedures for ^MBOBttB^^MHBgBl support services costs need to
be improved to ensure  that  costs charged to Superfund represent
the  actual  benefits  received.   Our  audit  disclosed  that
disbursements were allocated to  Superfund  based upon cumulative
obligations recorded for  general support costs in  the Salaries
and  Expenses  (S&E) appropriation.   We  questioned  $895,862  of
support costs changed to Superfnnd due primarily to Headquarters
utilizing budgeted in  lieu  of  actual  full-time equivalent (FTE)
ratios  in the allocation  of certain  costs.    The  use  of  this
method of allocation resulted in an over-allocation of $760,571.
Also,  Regions  4  and  5  made errors  in  the  calculations  of
allocations to  Superfund  amounting  to $120,232 and  $15,059,
respectively.   In addition, we  noted Region  10 over-allocated
support costs and  Regions  1 and  3 under-allocated support costs
to Superfund by undetermined amounts.

Agency  guidance  on cost  allocations  did  not   specify  that  the
allocation* of obligations and  disbursements should be calculated
separately. Consequently, when Superfund reimbursed  the  S&E
appropriation  for  allocated costs,  the allocations  were based
upon obligations.   Superfund disbursements  reflecting these
allocations  were  recorded  at  the  same  time   and  in  the  same
amounts as  the obligations.  We  believe  that  to properly match
costs, Superfund disbursements for the allocated costs should be
recorded based  upon  the  disbursements  recorded  in  the  SiE
appropriation.  We did not attempt to determine  the dollar impact
on Superfund disbursements of the Agency's  practice of  allocating
disbursements based  upon obligation data,  but believe  the Agency
should determine the effect.   This finding was  previously
                        30

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)

reported in the fiscal 1986 audit report and the Agency response
indicated that obligations  and disbursements were  allocated
separately.   However, this  was not  the method used  in either
fiscal 1986 or fiscal 1987, although it may have been the intent
of the Agency guidance.

GAP Policy and Procedures Manual for Guidance o_£ Federal Agencies
Title  2  —  Accounting,  Appendix  1  states  that  periodic
recognition of the effects of transactions is fundamental to the
accounting process.   Recognition governs when  the results of an
event are to be included in the financial statements and ensures
that the effects of similar events  and transactions are accounted
for similarly.  One  of  the three principles that form the basis
of recognition  is matching.   Matching involves identifying and
recording costs in the proper period,  i.e.,  the period in which
the costs are incurred.

We also found that  the  Superfund Program was not always charged
its proportionate share of support services costs.  This was due
in part  to  the  Agency's  policy  for  allocating  support costs,
which allowed allocations  to be based upon  authorized  (budgeted)
data.

The Financial Management Manual. Appendix 17-3  "Standard Plan for
Distributing Support Costs  to  the  Superfund Appropriation"
states:

     The two types of allocation  ratios  that may be used are
     the actual FTE  ratio  and the  authorized FTE ratio.  The
     actual  FTE  usage  ratio will  be  used for  allocating
     general support, except  where the use of  the authorized
     FTE ratio has been certified and approved.

EPA  Headquarters  allocated general support costs  to  Superfund
using a combination of both budgeted/authorized FTEs  and actual
FTEs   depending on  the  type of  expenses being  allocated.   He
believe that  allocations of  all general support services costs
should be  based  upon actual  FTE ratios  to achieve an  equitable
allocation.   Based upon  our  calculations,  the  use  of budgeted
ratios resulted in an over-allocation of general support costs to
Superfund by $760,571.

Region  4  over-allocated  support   costs  to  the  Superfund
appropriation by $120,232.  Our review revealed that  Region 4 had
included  prior  months'  allocation  amounts  with general  support
costs to  which  the  FTE  ratio was applied, resulting in an over-
allocation of  $113,398.    Additionally,  Region  4 did not retain
the September 30 reports to document the costs which  were  used  in
calculating the year-end allocations.  Based upon the  13th month
reports,  which were  available, we  determined that  $3,834 was
over-allocated to  Superfund.   Finally, negative cost  allocation
adjustments were  not entered into  the FMS  which resulted in  an
over-allocation  to  Superfund of  $3,000.    We also  found  that
                        31

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)

Region 5 made mathematical errors in calculating allocated costs
resulting in an  over-allocation  of  costs to Superfund amounting
to $15,059.

Region 1 made only  ten  monthly general support cost allocations
because the  ceiling for  charging Superfund  had been  reached.
Information was not readily available to determine the impact of
the resulting under-allocation of support  services costs to
Superfund.   Since regional Superfund ceilings may be adjusted by
EPA's Comptroller, we believe that Region 1 should have computed
the allocations  for  the entire  year  and  requested additional
funding.  The absence of a full  allocation understates Superfund
costs  and  could  result  in  under-recoveries  of  costs  in cost
recovery actions.

After  adjusting  to actual FTE ratios  at  the  end of  the third
quarter,  Region  3 allocated general support  costs based on
authorized FTE  ratios  for  the  fourth quarter of  fiscal 1987.
Region 3 personnel stated that  most of the  costs  allocated to
Superfund were  incurred during the  first  three  quarters of the
year,  and that subsequent adjustments would have been immaterial.
At Region 10, hours related to another program were  not  included
in the  total FTE base  for determining the Superfund FTE  ratio.
The required  information was  not available at Regions  3 and 10
for us  to  determine  the dollar amounts by  which the Superfund
appropriation was mischarged.

In response to our Notifications of  Findings and Recommendations,
Regions  3,  4,  5  and  10  indicated that  procedures would be
implemented  to correct the  disclosed deficiencies.    However,
Region 4 indicated  that the  final September 30 allocation could
not be based on the 13th month report  due  to time limitations of
entering the allocations into  the FMS.  Region 1 stated that EPA
provided the Superfund  ceiling and  costs were only  allocated to
that limit.  Officials  of FMD  at Headquarters disagreed with our
finding  with regard  to allocating  certain  costs on  an  actual
basis  versus an  authorized/budgeted basis.   They  stated  that
adjustments  to  an actual basis  should not be made for  certain
costs  because the  budgeted  amounts  reflected  conditions  that
existed at the  time their operating plan was established.   They
believed that deviations from those conditions should not require
changing the original allocation.

DRAFT REPORT RECOMMENDATIONS

We  recommended  in  our draft  report  that  EPA's  Assistant
Administrator for Administration and Resources Management:


     o  revise the  allocation  methodology of the plan to clarify
        the  requirements  for   allocating  costs  based  upon
        cumulative  obligations  and  cumulative disbursements
        separately;
                        32

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            FINDINGS AND RECOMMENDATIQMS {CONTINUED)

     o  change the policy  to require all cost  allocations  for
        general  support services  to  be based  on actual  FTE
        ratios;

     o  require  FMD  to   recalculate  general   support  cost
        allocations for  Headquarters based on actual FTE  ratios
        and make the appropriate adjustments to Superfund;

     o  require  the  Comptroller  to  request   the  Regional
        Administrator  of  Region 3   to  recalculate   general
        support   costs   using  actual  FTE ratios  and  make the
        appropriate adjustments to Superfund;  and

     o  obtain   written  certifications  from   the  Regional
        Administrators  of Regions 4, 5 and 10 that the  general
        support services cost allocations  for fiscal 1987  were
        recalculated and appropriate adjustments were made.
AGENCY'5 RESPONSE TQ
REPORT RECOMMENDATIONS
The Assistant Administrator for the Office of Administration  and
Resources Management  stated  in response to  our  recommendations
that:

     o  The Agency  believes  the current  procedure  is the most
        accurate and practical way  of allocating  these costs,  so
        they  disagree that  a revision to  the  methodology  is
        necessary.   Further/  the   auditors  suggestion  that
        "Superfund disbursements should be  recorded  based upon
        the disbursements recorded in the  S4E appropriation  for
        the allocated costs"  is not feasible.  The Agency implies
        that the recommended  allocation  of disbursements would be
        tied  to  individual spending  actions,  unlike  the  initial
        allocations of obligations, which  occur at  the  General
        Ledger  level and  are  not tied to  individual  spending
        actions.  It  is highly  impractical  to determine at  the
        time  funds  are actually  disbursed for  any spending
        action,  what  ratio was used to allocate the obligation
        for that spending  action.    Further,  because  the ratios
        are constantly being  adjusted throughout the  year  based
        on cumulative  figures,  the meaningfulness of attempting
        to ti« the allocation of any  particular disbursement back
        to the original obligation  is very questionable.

     o  The Agency  disagrees  that  the existing policy should be
        changed  to  require all cost allocations  to  be based on
        actual FTE  ratios.    The  Agency's  approach  for  using
        authorized FTEs  in certain instances  reflects  those
        circumstances  where  the  use  of  actual FTEs  is  not
        representative  of  Superfund's  use of Agency  resources.
        For  example,  the  acquisition  of space does not  ±ena
        itself  to the  use of  actual FTEs  since space  must be
        determined  in advance based on  a projected needs,  i.e.,
                        33

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

        the budget.   Regardless of whether the space was actually
        used during the year according  to  these projections,  the
        space was available  to  the  Superfund program.    In  this
        instance,  to  apply  actual FTE  ratios  to  determine  the
        allocation would  erroneously  undercharge  the  Superfund
        appropriation for  its share of cost.

        The current  methodology  is  consistent, provides a  fair
        estimate of  costs,  and  does  not materially distort  the
        amount  of  the  Agency's  obligations and  disbursements.
        The  recommendation  that  we  adjust  the  Superfund
        appropriation to reflect  actual ratios would result in an
        adjustment of  .15%  of  total  Superfund obligations  and
        disbursements.   This low  percentage supports our position
        that our methodology does fairly reflect the appropriate
        charges.

     o  The Agency disagrees with the  recommendation to require
        FMD  to  recalculate  and  adjust   Headquarters   cost
        allocations based on actual FTE  ratios,  for   the  same
        reasons stated in  the previous response.

     o  The Agency disagrees with the  recommendation to request
        the Regional Administrator of Region 3  to recalculate and
        adjust cost  allocations  based  on  actual FTE ratios  for
        the same reasons  stated  in  the previous  two  responses.
        The Comptroller will request the  Regional Administrator
        of Region 3 to use Agency  guidelines  for allocating
        general support costs to  the Superfund  appropriation.

     o  The Director,  Financial Management Division,  received
        written confirmation  from  the  Financial Management
        Officers of Regions 4,  5 and 10 that  corrections to the
        general support services cost allocation for fiscal 1987
        have been made.

OUR EVALUATION Q£ THE AGENCY'S RESPONSE

The AA for OARM indicated  that written confirmations from FMOs of
Regions 4, 5 and  10 concerning  corrections  had been received by
the Director, FMD.  Therefore, we make  no further  recommendation
on  this  issue.    However,  the  Agency  disagreed  with  our
recommendations  for:   revising the  Agency's  methodology  to
allocate coats  based upon cumulative obligations  and cumulative
disbursements/  separately;  changing  the policy to require  all
cost  allocations to be based on actual FTE ratios; and  requiring
recalculations  and  adjustments   to  cost allocations for fiscal
1987 based upon actual versus budgeted data.

In  regard  to  the  Agency's   response  to our  recommendation  for
allocating obligations  and  disbursements  separately,  we  do not
believe that the  current  procedure provides either  the  most
accurate or practical method  of allocating support  services
                        34

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

costs.  A more  accurate method would be to allocate obligations
based upon  cumulative  obligations,  and disbursements based upon
cumulative disbursements.  The current method does not recognize
the timing differences between obligations  and disbursements,  the
de-obligation of  funds in subsequent  years, or  that the Agency
does not always disburse the total  obligations  recorded.   As a
result,  Superfund  is  being charged with disbursements which  may
never occur.

As  for  the  Agency's  argument  that a  separate allocation of
disbursement is not feasible, we believe that the same procedures
now being utilized to allocate both obligations and disbursements
could be easily changed  to a  two-step  allocation.  This could be
done  by   allocating  disbursements   based  upon   cumulative
disbursements (instead  of  obligations)  by  sub-object classes at
the General Ledger level.  The calculation  would  involve the same
accounts  for which  cumulative  obligations  were  allocated,  by
applying  the calculation to cumulative  disbursements.   This
method would not require the  allocation of individual spending
actions, but would simply duplicate the current procedures at  the
disbursement level.  The FTE  ratios  would  be applied in the same
manner in  the two-step  allocation  as  is  currently  done  in  the
one-step allocation.

Regarding the Agency's response to our recommendation for the  use
of actual versus budgeted data,  we know  of no circumstance where
the  use  of  actual data is  not representative  of  the  use of
resources.   The example given  to support  the Agency's position
for  using  budgeted  data versus actual  data  relates  to  the
acquisition of space.  We disagree that using projected needs, or
budgeted data,  represents  or approximates  actual usage.   If, in
the Agency example, the space budgeted for  Superfund  was actually
used  by  another program,  Superfund would still  bear the cost.
Whether the basis used for space should be  based  upon FTE ratios,
or  some other measure such  as  square  footage,  does not justify
using budgeted data when actual data would  be more representative
of the utilization of resources.  To utilize a  budgeted FTE ratio
for certain  costs  distorts the  fair  distribution  of  actual costs
to  the benefiting  programs.   We believe that actual data should
be utilized in all cases where the data is  readily available.

In regard to our recommendation that the Agency  make adjustments
of cost allocations based upon actual data, we  believe that  these
adjustments  represent  the use  of  a  method that  is generally
accepted and more easily supportable.    We also believe that an
adjustment  amounting  to $760,571 should be  recorded,  regardless
of the percentage of the adjustment  to Superfund.

RECOMMENDATIONS

We  recommend that  the Assistant Administrator for the Office of
Administration  and Resources Management:
                        35

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3.
        FINDINGS AND RECOMMENDATIQMS (CONTINUED)

 o  revise  the  Agency's  cost allocation plan methodology to
    require  the allocation  of  costs  based  upon cumulative
    obligations and cumulative disbursements  separately;

 o  change  the  Agency policy to  require all  cost  allocations
    for general support services to be based  on actual data;

 o  require  FMD  to  recalculate  general support  cost
    allocations for  Headquarters  based on actual FTE ratios
    and make the appropriate adjustments to Superfund; and

 o  require  the  Comptroller  to  request the  Regional
    Administrator of Region 3 to  recalculate general support
    costs using actual FTE ratios and  advise the  Comptroller
    of the resulting under-charge to Superfund.

EPA NEEDS 2Q STRENGTHEN  PROCEDURES  FOR MONITORING LETTERS QF
CREDIT
Improvements in  procedures  are needed  in  monitoring letters  of
credit  to  ensure  that:   (1)  recipients  file  Federal  Cash
Transactions Reports (SF-272s)  promptly;  (2)  recipients do  not
have  excess  cash  on hand;  and  (3) cash  drawdowns  reported  by
recipients are reconciled with FMS records.  At Regions  1, 8,  9,
and 10, we  found that recipients did  not submit SF-272  reports
within the  15-day period as  required.   Also  we  found that  two
recipients in Region 1 had excess cash on hand totaling $235,000.
We  reviewed  SF-272s  to  verify  that  drawdowns reported by  the
recipients were  reconciled  to the FMOs' records.   In Regions  1
and 9, no reconciliations  of the SF-272s  to  the FMOs'  records
were performed by FMO personnel during fiscal 1987.   Furthermore,
when  we   performed reconciliations, we noted  discrepancies  at
Regions 1  and 9 amounting to $44,571 and $581,245,  respectively.

The EPA ACCOUNTING MANUAL. Chapter 25 states:

      The Financial  Management Office  will monitor the
      financial status of grants by means of:

      Federal Cash Transactions Report  (SF-272) -  This
      report  must be submitted  fifteen  (15)  working
      days following the end  of  each calendar quarter.
      This report  shows cash  on hand at the  end of the
      period.

In  addition,   the  LETTER fiF  CREDIT  -  TREASURY  FINANCIAL
COMMUNICATIONS SYSTEM RECIPIENTS MANUAL, states:

      EPA will  monitor drawdowns  to  ensure   that
      recipient  organizations are  maintaining minimum
      balances  of Federal  funds.   Each  request  for
      funds message  will be  reviewed  by EPA  prior  to
                        36

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED*

      approval to ensure that payment  will not result
      in  excessive  funds  or  violation  of  award
      authority.   Based on  this  review,  EPA will take
      any action necessary to  minimize  outstanding
      Federal cash balances.

We reviewed  the filing dates  on  non-statistical  samples  of
recipients'  SF-272 reports  to determine if  they were filed within
15 working days after the end of  the calendar quarter.  Since SF-
272s are  necessary for  the reconciliation process,  the  15-day
requirement helps to ensure that  discrepancies will be discovered
in a timely  manner  and that immediate corrective action  can  be
taken.    We  found that, in 35  of  55 reports  tested  (64%)  at
Regions 1, 8, 9 and 10, the SF-272s  were filed between 1 and 123
days after   the  required date  of  receipt,  for  an  average  by
Region, as follows:
     Audit
   Location
   Region 1
   Region 8
   Region 9
   Region 10
 Average
Davs Late
   36
    9
    6
   23
Our review of SF-272 reports revealed excess cash on hand for two
recipients of letters of credit in Region  1, totaling $235,000 at
September 30,  1987.   Monitoring of cash 'on  hand increases
assurance that funds are only drawn down by recipients as actual
cash needs arise.   The timing of  drawdowns by recipients  has a
substantial impact on the Treasury Department's management of the
public debt and  financing costs.   Premature  drawdowns result in
unnecessary interest costs incurred by  the Government.

Additionally, we  reviewed  SF-272s to  verify  that drawdowns
reported on  the  SF-272s by  recipients were  reconciled  with the
FMOs' records.  At Regions 1  and 9, there  were no reconciliations
of  the  SF-272s   to the  FMOs' records.   Furthermore,  when  we
performed  these  reconciliations,   we  noted  differences for two
Region  1  recipients,  totaling  $44,571, and  one recipient  in
Region  9,  amounting  to $581,245.   Further,  in  Region 9,  one
recipient's award amount recorded  in the  FMS did not agree with
the Letter of Credit History (EPA Form  2550-15) by $2,742,948 and
the unpaid obligations  differed  by $1,122,070.   Reconciling SF-
272s  to FMOs'  records  is  an  integral  process of  monitoring
letters of credit.    Failure  to  perform  such reconciliations
could  result  in  inaccurate  information  in EPA's financial
records.

The cause of the conditions  cited  above can be partly attributed
to  a  lack of Headquarters  guidance regarding  reconciliation of
SF-272s and  FMO records.  Also,  some Regions indicated  that they
did not have sufficient staff to follow up on SF-272 late filings
and  excess   cash  on  hand  balances.     Comptroller  Policy
                        37

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            FINDINGS AND RECOMMENDATIONS f CONTINUED)

Announcement No.  88-06,  issued  February  12,  T988  provides
additional guidance on  the monitoring of  letter of credit
drawdown  procedures.    Announcement  88-06 adequately  addresses
procedures regarding the reconciliation of the SF-272s  to  FMOs'
records.   However,  procedures  for documenting the follow-up  on
recipient noncompliance with timely filing requirements are not
specified.

As a result of  our  audit,  Region  1  sent  written  requests to the
recipients to reconcile the differences.   In  addition,  Region  1
officials instructed  the staff  to follow-up on late SF-272
submissions.   For  fiscal  1988,  personnel in Regions   1  and   9
stated that these reconciliations  were  being  performed.  Region  9
explained the reconciliation difference of $581,245 as  $590,245
being included  in another letter of credit and a $9,000 posting
error.    Also, Region 9 indicated that the amounts in  the FMS and
the  Letter  of Credit  History  differed because  of  special
conditions restricting  drawdowns to authorized levels.   Officials ,,
at Headquarters, at a June 29,  1988 meeting,  indicated  that they
also monitored letter of credit reporting as part  of  their
quality assurance  reviews.

DRAFT REPORT RECOMMEND AT I QNS

We  recommended in our draft  report  that  EPA's  Assistant
Administrator for  Administration and Resources Management:
                                            •
     o  request the Regional  Administrator of Region 1  to follow-
        up to determine if the two  recipients  identified in the
        finding were maintaining excess cash balances  and,  if so,
        take appropriate corrective action;

     o  request the  Regional Administrators  of  Regions  1,  8,   9
        and 10 to notify in writing the recipients  identified  as
        late  filers  of SF-272s of  the requirements  for  timely
        filing and  the  corrective actions that may be  initiated
        if the compliance problem  is not resolved; and

     o  issue  additional  Agency  guidance  requiring  FMOs  to
        document    follow-up  action   taken   on   recipient
        noncompliance  with  timely filing  requirements  for SF-
        272a.
AGENCY 'S
                  IQ DRAFT REPORT  RECOMMENDATIONS
The Assistant Administrator for the Office of Administration and
Resources Management  stated  in response  to  our recommendations
that:

     o  The  Director,  Financial  Management  Division  (FMD)
        received  written  confirmation  from  the  Financial
        Management Officer of Region 1  that -letters were sent on
        April  7,  1988  to  the  two  recipients  requesting  a
                        38

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)

        reconciliation   of  drawdown amounts.
        reconciliations have been completed.
                                                   The required
     o  The Director, FMD,  received written confirmation from the
        Financial Management Officers of Regions 1,8,  9  and 10
        that  follow-up actions  were  being  taken  with  the
        identified late filers.

     o  The  Agency  disagreed   with  the   recommendation  that
        additional Agency  guidance  should be  issued requiring
        FMOs  to document  follow-up action taken  on recipient
        noncompliance  with timely  filing   requirements for  SF-
        272s.   They further  stated that  most of  the problems
        cited in our draft report were a result of  noncompliance
        with current policies and procedures.

        The  Grants  Administration  Division (GAD)   was  asked to
        develop a Superfund Cooperative  Agreement  management
        improvement plan.  In reviewing each Region's management
        of cooperative  agreements,  the GAD noted  problems with
        recipients filing SF-272s promptly.  GAD recommended that
        each  Region develop a  system to  track  when  required
        reports  are  due and  provide  guidelines  for  appropriate
        actions when recipients fail to submit reports or submit
        reports of substandard quality.

OUR EVALUATION Q£ THE AGENCY 'S RESPONSE

The Agency actions regarding  reconciliations of drawdown amounts
and follow-up action with identified late filers of  SF-272s, when
completed, adequately responds to our  recommendations.  However,
we disagree with the Agency's position that sufficient letter of
credit  guidance currently  exists  for use by the  Regions  and
cooperative  agreement  recipients and  that additional follow-up
procedures are  not warranted.   The existing  guidance  does  not
specify procedures  for  documenting the follow-up  on recipient
noncompliance with timely  filing requirements.   We believe that
documentation  of all  follow-up  action   would  enhance  EPA's
position should more drastic measures be required.

RECOMMENDATION

We recommend that EPA's Assistant Administrator for  the Office of
Administration  and Resources Management issue additional Agency
guidance  requiring FMOs to document  follow-up actions taken in
regard to recipient noncompliance with timely  filing requirements
for SF-272S.
4.   EPA NEEDS  JQ MAKE  IMPROVEMENTS
     ACCOUNTS RECEIVABLE
                                          RECORDING AND MANAGING
Our  review of  accounts receivable  indicated  that  improvements
were needed to ensure that: (1) all receivables are recorded  in a
                        39

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

timely  manner;  (2)  the dollar  value  of each  receivable is
recorded and  adjusted according  to Agency policy; and  (3) the
FMOs are aggressive  in collecting  debts.   Accounts receivable,
for the purposes of this report,  are defined as moneys due to the
Agency,  such  as  refunds   for  overpayments  of  contracts,
cooperative agreements or grants, repayments of travel advances,
penalties,  and cost recovery actions.

A.  Accounts Receivable .Were No.fr Recorded. In & Timely Manner

An  important  prerequisite of  accounts  receivable  management is
the timely recording of all amounts owed to the Agency.  We  found
that  amounts  due  to  Superfund  as  a  result  of  cost  recovery
actions and penalties were not  recorded in a  timely  manner by
Headquarters.   Our tests  at Headquarters of a judgmental sample
of  11  fiscal 1987  collections  totaling $12,563,841,  out  of  a
total collections  universe of $20,577,273, disclosed  that 10,
totaling $11,940,785, were  not  recorded as  receivables   until
after a check in payment was received.  Although this problem has
been reported in two prior Superfund audits,  and  FMD has agreed
to take corrective action to  improve the situation, the problem
persists.

According  to  the  Financial Management  Manual.  Chapter  7, the
Agency's policy is to promptly establish an account receivable in
the accounting records for all amounts  owed. to the Agency.  To
achieve this, program offices  must forward a  copy of all action
documents establishing  a  debt  to the appropriate  FMO.   Further,
the FMO must process bills within one work day after receipt from
the  program office.    Similar requirements  appear in  the EPA
Accounting Manual. Chapter 17.  The problem of not recording the
receivables timely most often  resulted from  the failure of
program offices to forward documents in a timely manner.

Recording  receivables promptly  is  important since it  is not
possible  to  effectively manage  receivables if  they  are not
recorded  in the  FMS.    Also,  a  large  number  of unidentified
receivables could  materially  affect the  financial statements of
Superfund and possibly result in a loss of interest earnings.

B.  Interest Was Nofc Correctly Computed and Recorded

The FMOs did not always correctly compute and  record interest for
receivable* that  were  delinquent.   The  Debt  Collection  Act of
1982 or the Federal Claims Collection  Standards generally  allow
the  Agency to  collect  interest.   Our  evaluation  of  accounts
receivable in Regions 2 and 9 disclosed that 9 receivables  from  a
total of 18 were outstanding  for more  than 30 days and that no
interest was assessed on  these overdue accounts.

Government-wide, as  well as Agency  guidance, permits  additional
charges to be collected  under certain circumstances.   The Debt
Collection Act  allows Agencies to  assess interest.  Regulations
                        40

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

implementing this  Act  became effective  in  April 1984.   Among
these regulations,  4 CFR  102.13  provides  for  assessing  interest.
However,  the Agency  must give the  debtor a written notice that
explains  the charges.  The Financial Management Manual Chapter 7,
Paragraph 5  and  the EPA  Accounting Manual Chapter 17, Sections
17.4, 17.6 and  17.7 also permit collecting interest.

We  have  identified two primary  reasons for  the Agency not
recording interest:  interest charges  were  not included in the
payment  terms  on bills  sent  to  debtors;  or  the FMOs  were
unfamiliar with Agency  directives.  Region 9 was not  aware of the
requirements to  charge  and to  record  interest.    Region   9
indicated  that  corrective action was  taken in fiscal  1988.
Region 2 did not  assess  interest  to States during fiscal  1987.
However,   the   Region  requested  a   clarification  from  EPA
Headquarters in  a memorandum  dated  January 25, 1988,  as to
whether  interest  should be  assessed to States.   Pending  a
response  from Headquarters,  the Region is including an interest
clause on billings to States.

Due  to the omission of the  interest,  the balances of  accounts
receivable were  understated.   We estimated that  the under-
statement of interest accrued was  $1,000  in Region 2, and  $6,243
in Region 9.

C.   Aggressive  Collection  Action Was  Needed To  Ensure That
     Debtors Pav The Agency  In A Timely Manner

Collection  action  was needed  to  ensure that  debtors pay the
Agency  in  a  timely  manner.    We  noted  that  Region  2 and
Headquarters were  generally  not collecting receivables as
aggressively as  Agency  directives   require.  Agency reports
identified  accounts  due  over 30 days  in Regions 2,  10 and in
Headquarters.  Further, the total  balance of  accounts receivable
due over 120 days in Headquarters was $6,028,964 as of the  end of
fiscal 1987.  Deficiencies  in collection activities were,  in most
cases,  closely  related to  the monitoring  and  management of
delinquent  accounts  receivable.    Headquarters  did not  conduct
sufficient periodic management  reviews  of its Superfund accounts
receivable balances during fiscal  1987, to determine whether the
accounts ware valid and collectible, or were invalid, delinquent,
uncollectible,  subject  to deferred payment  arrangements, or
otherwise in need of special management or collection efforts.

The  Agency directives  require  periodic contact with the  debtor
and  regular evaluations of  the collectibility of  the debt.   The
EPA  Accounting Manual. Chapter 17, Section 17.4    requires that
debtors (other than Federal  agencies and  common carriers) be sent
three demand letters if the  debt is not paid within 31 days.  The
letters should be sent to the debtor  31,  61 and 91 days after the
initial  bill.    Unless the  debtor acknowledges  the  debt,  the
debtor should be contacted by telephone before mailing the secc:
and  third  letters.   The  second  and third letters  should  be sent
                        41

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

by  registered  mail,  return  receipt   requested.    Similar
requirements are  found in  the Financial, Management Manual.
Chapter  7,  Paragraphs  5d  and 5k.   In  addition,  Paragraph  5g
requires the FMO to notify certain debtors that,  if payment  is
not  received  within  60  days  of  the due  date,  information
regarding the debt  will be referred to credit bureaus.   Fifteen
days  after  the  third  demand  letter  is  sent,  both  directives
require  the FMO  to  evaluate  the  situation.   At  this  point,
either:  (1) more collection  action should be taken;  (2) the debt
should be written  off by the FMO if the  principal  is  less  than
$150  (less than  $2,000 effective October  1987)  and further
collection  action  would be useless;  or  (3)  the debt  should  be
transferred to another  office for action.  Generally,  the  debts
are transferred to the EPA  Claims Officer.

Collection activity for most  FMOs is very  labor-intensive.   Files
must be  reviewed,  the accounts  requiring  action identified,  and
the action  taken.   Officials in Region   2 indicated  that  staff
turnover prevented  them from performing  the required  action  to
follow up on delinquent accounts.   Region 10 officials indicated
in response to our finding that the problem  had been corrected.
According to  Headquarters,  the periodic aging of  Superfund
accounts receivable  did  not  provide  the  type  of detailed
management  information  needed to determine  whether receivables
over  120 days old were,  in fact, delinquent  and  in need  of
special handling and/or collection  efforts.

Non-performance of the prescribed follow-up procedures  could
result in the loss of the receivables and  interest earnings, or a
potential overstatement of the accounts receivable balance  and a
corresponding understatement  of bad debts.

The Office of the Inspector General issued Audit Report EIA67-11-
0029-80779, dated March 17, 1988,  covering their review of EPA's
accounts receivable activities.   The  report  identified  similar
findings and  made  appropriate recommendations.   The Agency
Indicated  that they  responded  to  the Office  of the  Inspector
General's report, so we make no further recommendations.

5.  OBLIGATIONS WERE QUESTIONED DUE JS  RECORDING ERRORS

Based upon the  results  from our statistical sampling,  we
projected  questioned  costs of  $99,505,   from  a  total  of
$930,492,580  of  nonpayroll  obligation transactions.    Our
projections were made with a 95% confidence  limit,  i.e.,  we are
95% confident that  the  questioned and accepted costs fall within
a range  of  values.   For example,  the  projected questioned costs
fall  within a  range from  $<49,451> to $248,961.  See Exhibit I
and  Appendix 2 for more details.  The projection of  questioned
obligations resulted  from  one sample   transaction  which  was
duplicated,  one  transaction  which was  over-obligated and  one
transaction  for  which  the  Agency  could  not locate property
                        42

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)
charged to the Superfund appropriation.   In addition, the results
of the testa of 11 internal control  and  compliance attributes for
nonpayroll obligations indicated unacceptable levels  (over 5%) of
noncompliance with Agency policies and procedures.

The sampling frame of  nonpayroll  obligations was taken from the
fiscal 1987  allotment  file in  the  FMS.   It was separated into
three subuniverses for contracts, cooperative agreements and all
other object classes, excluding those for personnel  compensation
and  benefits.    We  tested 11  internal control  and  compliance
attributes  to  determine  the  degree  of compliance  with Agency
policies  and procedures.  Our statistical  analysis  of  these
attributes indicated the following estimated error rates  for each
subuniverse, which  exceeded our expected error rate  of five
percent.

Note:  The  estimated error rates in  the  following  table were
       projected  based   upon   the  initial  results  of  our
       statistical sampling.  As a result of the  Agency providing
       additional documentation subsequent  to the issuance of the
       draft  report,  some of  these   attribute  error  rates
       (specifically for  written Superfund justification)  would
       have  changed.   However,  we did not  recalculate  these
       estimated error rates based upon revised data.
Subuniverse
Contracts
Cooperative
Agreements
            Attribute

Receipt of obligating document is  timely
Posting to FMS by FMO is timely
A commitment was previously entered into
  FMS, if obligation is greater than
  $25,000

Name of authorized official agrees with
  official's signature list maintained
  by FMO
Receipt of obligating document is  timely
Posting to FMS by FMO is timely
Other Object Obligation document number agrees with
Classes
  obligating document
Document control number agrees with
  obligating document
Account number agrees with obligating
  document, and account number indicates
  current year source of funds
Object class agrees with obligating
  document
Object class appears reasonable based
  on description of obligation
Appropriation number is Superfund
Estimated
  Error
   Rate

  41.89%
  22.58%
                                                         11.37%
                                                          7.59%
                                                         36.30%
                                                         45.21%
   7.37%

   7.25%


   7.76%

   6.36%

   7.23%
   11 .31%
                        43

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Subuniverse
             FINDING AND RECOMMENDATIONS (CONTINUED)
            Attribute

Written Superfund justification/
  statement of need is  on obligating
  document
Name of authorized official agrees
  with authorized official's signature
  list maintained by FMO
Receipt of obligating document is
  timely
Posting to FMS by FMO is timely
A commitment was previously entered
  into FMS, if obligation is greater
  than $25,000
                                                      Estimated
                                                        Error
                                                        16.64%
                                                        25.25%

                                                        49.21%
                                                        56.62%
                                                        38.59%
The  failure  to properly  follow  Agency policies  and  procedures
related to obligations as  indicated above could result in errors,
inefficiencies and  inappropriate  charges  to  the  Superfund
program.

One of the attributes identified above was an Agency requirement
for written Superfund justification or statements  of need on the
obligating document or procurement  request/order.  EPA Facilities
and Support Services  Manual. Volume  4830-2  PMR  2-20 states that
all procurement requests should include a  statement of  need and
justification that  the  requested items  or  services are required
to meet  the  program's objectives.    In addition,  Chapter  17  of
EPA's  Financial  Management  Manual.  Paragraph  6  states  that
offices will be expected to provide the information which served
as the rationale for  decisions on how to charge items bought for
partial or total Superfund use.  We considered this  requirement a
key  internal control procedures  for charging obligations  to
Superfund.

During  our  audit  fieldwork,  we   reviewed  the  available
documentation to support the charges to Superfund for our sample
items  to determine  if  written  justification and  statements  of
need  were maintained.    We  also  requested program  offices  to
provide  this documentation from  their copies of procurement
requests.    If we  could not  make  a  determination  that  an
obligation should  be Superfund  and no  written  documentation  to
support the charging  of Superfund was provided,  we set aside the
costs  in our  sample.   As  a result, these set-aside transactions
resulted in  the  projection of set-aside  obligations  of $23
million  in  our  draft  report.     Because  this  problem  was
widespread, we reported this condition as a material weakness in
internal controls in the draft report.  Subsequent  to  the release
of  the  draft  report,  the Agency,  upon our  request,  provided
additional  information to  support  these  obligations  as  being
Superfund related.   Therefore, we  have accepted the majority of
the  obligations  in  this  report and  no longer consider  this  a
material weakness.
                        44

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

DRAFT REPORT RECOMMENDATIONS

We  recommended  in our  draft  report  that  EPA's  Assistant
Administrator for Administration and Resources Management:

      o  emphasize the need for FMOs  to follow Agency policies
         for timely recording of obligations in the FMS;

      o  emphasize the need for program offices to follow Agency
         policies  requiring  written  statements of need for
         charging Superfund and providing obligation  documents to
         FMOs in a timely manner; and

      o  request the  appropriate  program  offices  and  FMOs to
         review and resolve the previously provided set-aside and
         questioned sample transactions, which  resulted  in the
         projected questioned and set-aside obligations.

AGENCY'S RESPONSE 2Q DRAFT  REPORT RECOMMENDATIONS

The AA for OARM stated in response to our recommendations  that:

      o  The  Director,  Financial  Management  Division,   will
         prepare a written  memorandum to the FMOs emphasizing the
         requirement for timely recording of pbligations  into the
         FMS.

      o  The  Director,  Financial  Management  Division,   will
         prepare  a  memorandum  to  all  program  offices re-
         emphasizing the requirements for Superfund justification
         for  obligation documents  and the  need  to promptly
         forward  those documents  to  their  servicing  finance
         office.

      o  The Agency  agrees that  the  FMOs should  correct errors
         found  during the audit.   In most  cases, the   FMOs
         resolved or provided the necessary data or correction at
         the  time of  the  auditors'  review and  provided  this
         information to them.   In  some cases,  these questioned
         costs were still reported in this report even though the
         auditors had indicated that responses to the preliminary
         notification of  findings were  acceptable.  Attachment II
         of  the  response  identifies  specific regional or  field
         office comments which  indicate  where corrective  action
         had  been  taken  and  had  not  been recognized  by the
         auditors.

         Concerning the lack  of  Superfund  justification, the
         Agency   acknowledges   that  the   Superfund  support
         documentation procedures  need strengthening in  the area
         of internal recordkeeping.  However, the Agency believes
         that  the  lack of documentation is  not conclusively
         indicative of errors  in the Agency's obligation activity
                        45

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)

         within  the Superfund appropriation.  The Agency strongly
         disagrees that this weakness  in  internal procedures
         represents  a  material weakness  or should be  the  basis
         for set-aside costs.  In  addition, the  projected set-
         aside  obligations  represented  only 2.3%  of  the  total
         universe of  Agency  obligations,  which is considered
         immaterial.

         Finally,  it  is the Agency's position  that the auditors
         did not  conduct  a  sufficient  amount  of fieldwork  to
         conclude  that the Agency  had mischarged  the  Superfund
         appropriation.  Had  the  auditors  used additional  audit
         techniques  such  as  interviews  or  inquiries   with
         knowledgeable   sources   within   the   Agency,    the
         relationship  of the  obligations to Superfund could have
         been resolved prior to issuance  of  the draft report.

         The Agency  referred  to  AICPA Statement on Auditing
         Standards (SAS) #39,  paragraph #34, as follows:

         "34. In  assessing the tolerable rate of deviations, the
         auditor  should consider  that, while deviations from
         pertinent  control  procedures increase the risk  of
         material  errors  in  the  accounting  records,   such
         deviations 49 not necessarily result in errors [emphasis
         added].   For  example,  a recorded disbursement that does
         not show  evidence  of required approval may nevertheless
         be  a  transaction  that  is  properly  authorized  and
         recorded."

         The Agency  also quoted  AICFA Statement on Auditing
         Standards #31,  paragraph #15, as support  for  their
         position, as  follows:

         "15.     Corroborating   evidential   matter  includes
         documentary   material   such  as   checks,   invoices,
         contracts,  and minutes of meetings;  confirmations and
         other  written representations  bv  knowledgeable   people
         [emphasis added);  information  obtained by  the  auditor
         from inquiry,  observation,  inspection, and physical
         examination;  ..."

OUR EVALUATION QF  THE  AGENCY'S  RESPONSE

The  Agency's   proposed   corrective  actions  regarding  the
preparation of memorandums emphasizing the  requirements that FMOs
record obligations in  a timely  manner and program offices prepare
and retain written Superfund  justifications and promptly forward
obligation documents  to FMOs,  when issued, are responsive  to our
recommendations.

We  are  aware that,  in some  cases,  the  FMOs agreed with tv
questioned  costs identified  during the  audit  and made tv._
                        46

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

necessary corrections at  that  time.   However, these  errors  are
included  in  the  obligations  reported  in  this report and,
therefore, are reported  as questioned costs and used as the basis
for  projected  questioned costs.   Where  appropriate  in this
report, we have acknowledged corrective action  taken by  the
Agency.   Appendix  4 provides  our evaluation of the  Agency's
specific comments provided in Attachment II to Appendix 3.

Concerning the costs set aside  in the draft report, we agree that
the lack of Superfund justification is not  conclusive of  error.
If  we had  believed that the Agency  mischarged  the Superfund
appropriation, we  would have  questioned  these costs.   However,
without the written  justification  required by  Agency  policy,  we
could not  conclude that these  were valid Superfund obligations.
Therefore, we  used the  set-aside  classification  for  those costs
that  could not  be accepted without  additional   information  or
evaluations and  approvals by  responsible Agency  officials.   On
June 27, 1988, we sent letters  to Agency program officials giving
them   the  opportunity  to  confirm  whether  the  set-aside
transactions  were valid  Superfund obligations.   Based  upon
responses  to   these  letters  and additional  inquiries,  we  have
accepted the  previously set-aside  costs  from  our  sample,  which
were the basis of the projections in the draft  report.

We  reported  the lack of  Superfund justification  as  a material
internal  control  weakness  in our draft  report because  the
condition  was  widespread  within   the   Agency  (16.64%   of
transactions tested) and  the potential dollar  effect  represented
a  material amount  ($23  million).   An authoritative  source  fcr
audit practitioners suggests that when  the relevant base (such as
obligations)  for  a  governmental  unit exceeds $5 million,  the
threshold  for establishing materiality is 0.7 percent.   As the
Agency indicated  in their response, the  projected set-aside
obligations  represented 2.3 percent  of  the  total obligations.
In  addition,  we believe  that  Superfund  justification is  a  key
internal   control  procedure  which  is  required   by   Agency
directives, in part, to support Superfund costs in cost recovery
actions.   Without  adherence to this control procedure,  there is
limited assurance  that Superfund costs  are properly documented as
"necessary  for" and  "incidental  to"  the Superfund  program,  as
required by Section III (a) of CERCLA.

With  regard  to the  Agency's  position  on relating deviations in
internal  control  procedures to dollar errors, we  recognize that
such  deviations do not necessarily result  in errors.  However,
the  AICPA Professional  Statements on Auditing  Standards state
that  for dual-purpose samples:

      In some   circumstances the auditor may design a  sample
      that will be  used  for dual   purposes:     testing
      compliance with  a  control  procedure  that provides
      documentary evidence of performance  and testing whether
      the   recorded  monetary  amount  of  transactions   is
                        47

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

     correct.

AICPA  standards,  therefore,  support our  position  to set  aside
costs related to internal control deviations because the Agency's
records did not conclusively demonstrate that these  transactions
were Superfund related.   Consequently,  due  to these deviations,
we  could not  readily  determine  if  the  recorded  amount was
correct, partially correct or incorrect.  Only after  we pursued
the matter with the  Agency, were we subsequently presented with
data to enable us to accept  these transactions.

Also/ in assessing the risk  of material errors, auditors evaluate
the risk of control failures based  upon the relative significance
of  the control  procedure  being  tested.   Since  the control
procedure in  this  case was identified as  a high  risk  that
failures  could result in material errors,  the auditors  were
justified in using this as a basis  for set-aside costs.

The Agency  also stated  that additional  audit work should  have
been conducted  to conclude  that the  Agency has mischarged the
Superfund appropriation.  The Agency has  misinterpreted the
purpose of set-aside costs  as defined in  the  audit  report.  Set-
aside costs are costs that cannot  be accepted without additional
information or  evaluations  and approvals by  responsive  Agency
program officials.  Therefore,  the  Agency's presumption that the
auditors  had concluded  that  these costs were mischarged  is
incorrect.   The auditors concluded that  additional information
was  necessary  in order  to  make a determination regarding the
acceptance of these costs.

The  Agency also agreed that  their  compliance with  internal
control procedures require  improvement.   The AICPA Professional
Standards support our action to obtain assurance that accounting
data is reliable before accepting the costs.
RECOMMENDATIONS

He   recommend  that   EPA's   Assistant
Administration and Resources Management:
Administrator   for
     o  obtain  certification  from  the  Director,  Financial
        Management Division,  that  memorandums  were sent  to  all
        FMOs emphasizing the requirement for timely recording of
        obligations in the FMS;

     o  obtain  certification  from  the  Director,  Financial
        Management Division,  that  memorandums  were sent  to  all
        program offices  re-emphasizing the  requirements  for
        Superfund  justifications on procurement requests/orders
        and the need to promptly forward obligation documents to
        servicing FMOs; and

     o  instruct the Director, Financial Management Division, to
                        46

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)

        obtain  certifications  from the FMOs that the  errors
        resulting in  projected  questioned costs  in  this  report
        have been corrected.
6.  DISBURSEMENTS WERE QUESTIONED DUE TQ RECORDING ERRORS

Based  upon  the  results  from  our statistical  sampling,  we
projected questioned costs of $9,623 from a total of $447,236,028
of nonpayroll disbursements.   Our projections  of questioned and
accepted costs  were made  with  confidence  limits  of  95%,
indicating ranges of  values.  See Exhibit  II and Appendix  2 for
more details.   The projected questioned  costs resulted  from a
sample transaction which was over-charged  to Superfund.   We also
examined 10 to  15 internal control and compliance  attributes in
the disbursement process for which we expected  the error rate not
to exceed five percent.  We found that  compliance with several of
the  control  procedures  exceeded an acceptable  level  of  error
rates.

The sampling frame of nonpayroll disbursements  was taken from the
fiscal 1987  detail  history file  of the FMS.   It  was separated
into three subuniverses for contracts,  cooperative agreements and
all  other  object  classes,  excluding  those for personnel
compensation and benefits.   We  tested  internal control and
compliance attributes to determine the degree of compliance with
Agency policies  and  procedures.    Our statistical  analysis  of
these  attributes  indicated that  estimated  error rates  exceeded
five percent for  the following attributes:

Note:  The estimated  error  rates in  the  following  table were
       projected  based   upon  the  initial  results   of  our
       statistical sampling.  As a result of the Agency providing
       additional documentation subsequent to the issuance  of the
       draft report,  some of  these attribute  error rates would
       have  changed.   However,  we did not recalculate these
       estimated  error rates.
                                                      Estimated
                                                        Error
Subuniveraa              Attribute                       Rate
Contracts
(15 attri-
butes tested)
Cooperative
Agreements
(10 attri-
butes tested)
Invoice was paid on time,  but not
  early
Posting of disbursement to FMS by
  FMO was timely
Cash discount,  if available and
  cost effective, was taken
Drawdown request indicates evidence
  of review by technician for cash
  balances and availability of
  funds
Authorized official's approval was
  indicated on drawdown request
52.07%

10.62%

27.87%




25.50%

28.61%
                        49

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            FINDINGS AND RECOMMENDATIONS  (CONTINUED)


Subuniverse              Attribute
               Posting to FMS by FMO was  timely
                                                      Estimated
                                                        Error
                                                         Rate
                                                        33.86%
Other Object
Classes (15
attributes
tested)
               Project officer or approving official
                 is authorized to approve payment and
                 approval is indicated on disbursement
                 document                               12.51%
               Disbursement documents are per-
                 forated and stamped paid and
                 indicate treasury schedule and
                 date                                   11.70%
               Certifying officer is authorized
                 to certify payments and signature
                 is on treasury schedule                  5.17%
               Date approved by project officer or
                 authorized official was prior to
                 date certified by certifying
                 officer                                 7.01%
               Invoice was paid on time, but not
                 early                                  70.94%
               Posting of disbursement to FMS by
                 FMO was timely                         19.46%

The failure to  properly  follow Agency guidelines related to
disbursements, as indicated in the attributes above, could result
in  errors,  lack  of sufficient  documentation  and  the improper
charging of costs to the Superfund appropriation.

During  our  audit  fieldwork,  we reviewed the documentation
available at the FMOs to  support  Superfund disbursements for our
sample items.   Where the  Agency could  not locate documentation
(invoices, receiving reports, etc,) to support the disbursements,
we set aside  the costs in our  sample.  As  a result,  these set-
aside  transactions resulted in  the  projection  of  set-aside
disbursements of $1.88  million  in our  draft report.   Subsequent
to  the  issuance  of  the draft report,  the  Agency  provided
additional  documentation upon  our request  to  support  most of
these Superfund  disbursements.   Therefore,  we  have accepted the
previously set-aside disbursements in  this report.

DRAFT REPORT RECOMMENDATIONS

We  recommended  in  our  draft  report that   EPA's  Assistant
Administrator for Administration and Resources Management:

      o  emphasize to the FMOs the importance of following Agency
         policies and procedures  for disbursements, particularly
         those related  to the timely payment of invoices and the
         timely entry of disbursement  data  i.n the FMS;  and

      o  require  the  FMOs to review and  resolve the  previously
         provided  questioned and set-aside sample  transactions,
                        50

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            FINDINGS
RECOMMENDATIONS  (CONTINUED)
         which resulted  in  the projected questioned and set-aside
         disbursements.

AGENCY'S RESPONSE TJ3 DRAFT  REPORT RECOMMENDATIONS

The AA for OARM stated in response to our recommendations that:

      o  He would direct the  Director,  FMD,  to prepare  written
         memorandum[s]  to the FMOs emphasizing                the
         requirement for timely  payments and  timely entry of  the
         payment activity into FMS.

      o  The FMOs should correct errors found during  the  audit.
         In  most cases,   the  FMOs  resolved or  provided  the
         necessary data or correction at the time of  the  review
         and provided this  information  to the auditors.   In some
         cases,  these  questioned  costs were still reported  in
         this report.   Attachment II of  the  response  identifies
         specific  regional  and  field office  comments  which
         indicate that corrective  action  had  not been  recognized
         by the auditors.

         The lack of justification within the finance offices may
         reflect  a  weakness   in   internal   administrative
         procedures, however,  it is not indicative of mischarges.
         The auditors overlooked  the extensive  approval process
         necessary to establish the obligation  as  well as  other
         alternative audit techniques  for obtaining  evidential
         matter  and that  these controls  do   not have   to  be
         duplicated at the  time  of disbursement.

         The  Director,  FMD, will review  the administrative
         procedures for processing Superfund disbursements to
         determine   where   administrative   procedures  can  be
         strengthened in  the area of Superfund  justification
         documentation.

OUR EVALUATION Q£ THE AGENCY'S RESPONSE

The Agency's proposed  corrective  action indicating that  the AA
for OARM should  direct  the Director, FMD, to prepare memorandums
emphasizing to  FMOs the  requirement for timely payments  and
timely  entry of  payments in  the FMS,  when  issued, is  responsive
to our  recommendation.

We  have  acknowledged  the  FMOs'   corrections  of  errors  as
appropriate  in this report and in  Appendix  4  in  our evaluation of
the Agency's  specific comments  provided in Attachment  II to
Appendix  3.   However,   the  errors  found  during  the  audit  are
included in the disbursements reported  in this report and
therefore, are reported as questioned costs and  used as the bas~.
for the projection of questioned costs  in this report.
                        51

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            FINDINGS AND RECOMMENDATIONS (CONTINUED)

Concerning  the  projected  set-aside disbursements in  the draft
report,   the  Agency  was   mistaken  in  their  belief  that
disbursements were  set  aside  for lack  of  written  Superfund
justification.  The  cause  of the set-aside disbursements was a
lack  of  adequate  documentation,  i.e.,  invoices,  receiving
reports,  etc.,  could not  be  located.    Without  sufficient
documentation,  we could  not determine  that these  were valid
Superfund disbursements.    Therefore,  we  set  aside  these costs
pending further information and evaluations by responsible Agency
officials.  On June 28, 1988, we sent letters  to FMOs  requesting
additional documentation  to support the set-aside costs.  Based
upon  responses  to  these  letters  and  additional  inquiries,  we
reviewed  the  information  provided and  accepted the  previously
set-aside costs.
RECOMMENDATIONS

We   recommend   that   EPA's   Assistant
Administration and Resources Management:
                                       Administrator   for
7.
      o  obtain  certification from  the  Director,  Financial
         Management Division,  that memorandums were sent to  all
         FMOs emphasizing  the  requirements for  timely  payments
         and timely recording of payments in the FMS; and

      o  instruct the Director, Financial Management Division,  to
         obtain  certifications  from the  FMOs  that  the  errors
         resulting in projected questioned costs in  this  report
         have been corrected.
RESULTS (QE  STATISTICAL ANALYSIS Q£  PERSONNEL  COMPENSATION
AND BENEFITS TRANSACTIONS
Based upon the results of  our statistical  sampling  of personnel
compensation  and benefits  transactions, we accepted the recorded
obligations and  disbursements  amounting  to  $85,004,567  and
$82,597,072,  respectively.     The  difference  between   the
$85,004,567 of  recorded  obligations  and the  $82,597,072  of
recorded  disbursements,  is represented by  the  approximate  net
effect  of year-end  accruals.   We  are 95%  confident that  the
personnel compensation and benefits disbursements falls within a
range from  $80,168,408  to  $83,161,966,  with the midpoint  being
$81,665,187.   The  projections  were  based  upon  a sampling
population of  $81,633,631,  which excludes a  small  part of  the
total disbursements.  Because  the  midpoint of the projected range
so closely approximates the sampling population, we  accepted the
total recorded  disbursements.   Further,  since  obligations  are
adjusted  monthly  by  EPA to  reflect  actual disbursements  plus
accruals, and  we accepted  the disbursements recorded,  we  also
accepted  the recorded  obligations.    See  Appendix  1 for  more
details.  The  results of  tests  of  10 key internal  control  and
compliance   attributes  for   payroll  transactions   indicated
                        52

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            FINDINGS
RECOMMENDATIONS ICONTINUED}
unacceptable levels  (over  5%) of  noncompliance with  Agency
policies and procedures.

Our  statistical  analysis of  internal control and  compliance
attributes indicated that the estimated error rates exceeded five
percent for  all  attributes  tested.   One reason for  some  of the
high estimated  error rates  was that  the  Agency was unable to
provide some of  the timesheets  and  tinecards.    These were the
documents used to make original entries  into FMS and were the
primary  source  of  information used  by  us  for  our  testing
purposes.   Agency  procedures  require the program  offices to
review the distribution of time charges made from timesheets for
each pay  period.   During our  review of  internal  controls,  we
found that  this  control procedure was  in  place and  functioning
properly.   Therefore,  we concluded  that  the original documents
must have been  available at  the  time of original  entry and
review, and were subsequently misplaced.
                                                  Estimated
                                                   Error
           Attributes                              Sates
Account number agrees with timesheet
Hours agree with timecard
Hours agree with time sheet
Dollar amount agrees with audited hours
  times pay rate
Timecard certified by timekeeper
Timesheet certified by employee
Timesheet certified by timekeeper
Timesheet certified by supervisor
Leave time supported by application for
  leave or timecard entry initialed by
  employee
Overtime hours, compensatory time worked,
  and premium pay supported by approved
  request for and authorization of
  overtime work
                           18.38% (a)
                            5.31%
                           13.59% (b)

                            5.21%
                           24.36% (c)
                           12.78% (d)
                           21.60% (c)
                           14.19% 
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            FINDINGS AND RECOMMENDATIONS (CONTINUED1

     signature of a timekeeper.   However,  many of the  timecards
     and timesheets were signed by "timekeepers" for whom there
     were no  timekeeper signature cards on  file to verify that
     the  signature was appropriate  and the  individual  was
     approved to  sign  as a  timekeeper.   We  noted  that Agency
     procedures  require designated  agents  to certify  to the
     timekeepers  signature on timecards.

     (d)  Employee  signature  could  not  be  verified because
     timesheets could not be located by EPA.

     (e)  There  was   difficulty  in  determining  employees'
     supervisors  during the audit period.   The Agency  could not
     provide  a listing of  supervisors  and alternative audit
     procedures  to  determine  supervisors  were  not  always
     successful.

     (f) Approvals for leave time, overtime  hours,  compensatory
     time worked, and premium pay could not  be  verified  because
     the appropriate forms could not be located by EPA.

The estimated  error rates  for  the 1987 attributes  were  greater
than the prior year and more control  weaknesses  were noted.  The
types of errors noted could result in a misstatement of personnel
compensation  and  benefits  costs,  or  a  lack   of  adequate
documentary evidence to support charges to the Superfund program.

DRAFT REPORT RECOMMENDATION

We  recommended  in  our  draft  report  that  EPA's   Assistant
Administrator for Administration  and  Resources Management
emphasize  the importance of  compliance  with  EPA  policies and
procedures  for maintaining  adequate  payroll records to  support
charges to Superfund.

AGENCY'S RESPONSE JQ DRAFT REPORT RECOMMENDATION

In  October 1987,  the  Director,  Financial  Management  Division,
issued a memorandum to all concerned  parties.  The memorandum re-
emphasized the  importance  of EPA's  policies  and procedures
regarding timesheets and timecards.   Additionally, the Financial
Management Division has already taken the  following  actions:

      o  trained each  program  office on how to  use the Payroll
         Redistribution System  and to complete timesheets;

      o  initiated a two-hour  timekeeping module  as part of the
         Office  of  Human  Resources  Management's training course
         for new administrative employees;

      o  offered a one-day timekeeping  course for  timekeepers and
         designated agents and  will continue to routinely provide
         training and information to  the Agency's  timekeepers.
                        54

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            FINDINGS AEB RECOMMENPATTOM? (CONTINUED

2HB EVALOATIQtf QF THE AGENCY'S RESPONSE

The   Agency's   corrective  action  is   responsive   to
                                                    e
                       55

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EXHIBITS

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                           UNITED STATES                    EXHIBIT I
                  ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON, D.C.

        HAZARDOUS SUBSTANCE RESPONSE TRUST FUND (SUPERFUNDi
                  SCHEDULE OF OBLIGATIONS (NOTE 1)  *~unu;
                FISCAL YEAR ENDED SEPTEMBER 30, 1987

Description                    Tn4-ai         .
	*±	                    T2ial         Accented       Question^

Personnel Compensation   $   73,792,675   $ 73,792 675   S  
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                       UNITED STATES
               ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C.
                HAZARDOUS SUBSTANCE SUPERFUND

               NOTES TO SCHEDULE OF OBLIGATIONS
            FISCAL YEAR ENDED SEPTEMBER 30, 1987
                                                       EXHIBIT  I
                                                      (CONTINUED)
NOTE
         SUMMARY OJl SIGNIFICANT ACCOUNTING POLICIES
The Schedule   of  Obligations  was prepared by the  EPA Financial
Management Division based on  financial  information  contained  in
the  Financial  Management  System  for the  fiscal  year ended
September 30,  1987.    EPA's  policy is  to prepare  schedules  in
accordance  with  accounting policies and procedures that are
legislatively established and  promulgated through various Federal
and EPA policy  and  procedural standards.   This schedule  is not
intended  to  present  either  the  financial  position  or the
financial results of  operations in  conformity  with  generally
accepted accounting principles.

Obligations  - Nonoavroll

Obligations  an»=aOBDunts  of  orders  placed,. contracts  awarded,
services  received,  "travel performed,  and similar transactions
during a given period that will require payments  during the same
or  future periods.   Such amounts include disbursements for which
obligations  had  not  been  previously recorded  and reflect
adjustments  for  differences between  obligations previously
recorded and actual disbursements to liquidate those obligations.
The  term "obligation"  includes both   obligations that have
matured  (legal  liabilites)  and  those that are  contingent  upon
some future  performance, such  as  providing  services or furnishing
materials.   Obligations  represent  funds  obligated  against  the
current   fiscal  year's  appropriation,  including carry-over
authority for appropriations  from prior years.   Obligations  are
recorded for budgetary purposes by appropriation.

Obligations, as presented in  this Exhibit,  were reported by EPA's
Financial System Branch in a Special Superfund Audit Report from
information  contained  in  the  Financial  Management  System
"Allotment  File".   The  total  obligations  from this  report,
amounting to  $1,015,497,148,  were reconciled  with  the  totals
reported  by  EPA  to  the Office  of  Management  and  Budget  for
appropriations  68*20X8145  and 68-2068145  for the  period ended
September 30, 1987.
                        57

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                                                          EXHIBIT I
                                                         (CONTINUED)
Obligations - Payroll
Payroll obligations are  based  upon actual personnel  compensation
and benefits recorded  monthly in  the payroll subsystem  plus
accruals generated at   month-end.    Personnel  compensation  and
benefits obligations amounted to $85,004,567,  which,  based on EPA
policy,  were  recorded  on an accrual  basis  for  obligation
accounting.

NOTE 2^ OBLIGATIONS QUESTIONED

Questioned  obligations of $995,367  consist  of $895,862  for
general  support  services costs  improperly  allocated to  the
Superfund appropriation,  and $99,505  of obligations,  based on the
projection of exceptions in the statistical  samples.

      a.  General  support services costs  were questioned  due to
      errors in cost allocations as follows:
Description
Region 4,
Transportation of Things  $  5,467
Rent, Communication and
  Utilities                15,067
Printing and Reproduction    1,920
Other Contractual Services   56,238
Supplies and Materials      21,834
Equipment                 19,706
Land and Structures
Grants, Subsidies and
  Contributions
Insurance Claims and
  Indemnities
Region 5.

$

  (2,915)
  (6,003)
  23,977
                                                Headquarters     Total

                                                  $   923   $  6,390
      Totals
$120,232
 $15,059
517,756
92
217,583
6,529
16,735
105
845
3
529,908
(3,991)
297,798
28,363
36,441
105
845
3
                                                  $760,571    $895,862
                        SB3SBS3        8S8BB*         •••BBSS     BSS3SS3
Additional  detail relating to these  cost allocation errors  are
contained in Finding 2.

     b.  Questioned costs of $99,505 consists of  the  following:

               Description                   Amount
     Supplies and Materials
     Equipment
          Total
                       $ 4,103 (i)
                        95.402 (ii)
                       $99,505
       (i)  Represents amounts  questioned  because  of an
            excess  allocation.
                          58

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                                                     EXHIBIT I
                                                    (CONTINUED)

     (ii)  Represents amounts  questioned because  of a
           duplicate obligation of funds and  property
           that could not be located.

Additional details relating  to the testing  of obligations  are
contained in Finding 5.
                        59

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                                                            EXHIBIT
                           UNITED STATES
                  ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON,  D.C.
        HAZARDOUS SUBSTANCE RESPONSE TRUST FUND (SUPERFUND)
                 SCHEDULE OF DISBURSEMENTS (NOTE 1)
                FISCAL YEAR ENDED SEPTEMBER 30, 1987
Description
Personnel Compensation
Personnel Benefits
 Total Personnel Corn -
  pensation & Benefits
Travel and Transportation
  of Persons
Transportation of Things
Rent, Communications,
 and Utilities
Printing and Reproduction
Other Contractual
 Services
Supplies and Materials
Equipment
Land and Structures
Grants, Subsidies, and
 Contributions
Insurance Claiaa and
 Indemnities
  Total Non-Personnel
     Grand Totals
Total
Accepted
Questioned
t 71,998,092
10,598,980
82,597,072*
6,553,164
397,488
14,402,134
632,943
373,226,247
2,180,637
6,594,411
804
43,246,131
2,069
447,236,028
529,833,100
$ 71,998,092
10,598,980
82,597,072
6,543,541
391,098
13,872,226
*
636,934
372,928,449
2,152,274
6,557,970
699
43,245,286
2,066
446,330,543
$528,927,615
••BSSBSBSVO
(NOTE 2)
$
-
9,623
6,390
529,908
(3,991)
297,798
28,363
36,441
105
845
3
905,485
$ 905,485
 The accompanying notes are an  integral part of this schedule
                            60

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                        UNITED STATES
               ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C.
                HAZARDOUS  SUBSTANCE SUPERFUND

              NOTES TO SCHEDULE OF DISBURSEMENTS
            FISCAL YEAR ENDED SEPTEMBER 30, 1987
                                                      EXHIBIT
                                                     ICQNTINUEDJ
NOTE i..  SUMMARY QF SIGNIFICANT ACCOUNTING POLICIES
The Schedule  of Disbursements was prepared by the EPA Financial
Management Division based on  financial  information  contained  in
the  Financial  Management  System  for the fiscal  year  ended
September 30,  1987.    EPA's  policy is  to prepare  schedules  in
accordance  with accounting policies and  procedures that are
legislatively established and  promulgated through various Federal
and EPA policy  and procedural standards.   This schedule  is not
intended  to  present  either  the  financial  position  or the
financial results  of  operations  in  conformity with  generally
accepted accounting principles.

Disbursements - Nonoavroll

Disbursements  represent the  amount of  cash  outlays made  to
liquidate obligations.   They represent funds 'disbursed during the
current   fiscal  year  against  either  prior  years' or  current
year's appropriations.   Disbursements are recorded on  the cash
basis of accounting in EPA's general ledger  by appropriation.

Disbursements,  as  presented  in this  Exhibit, were  reported  by
EPA's  Financial Systems Branch  in a  Special  Superfund  Audit
Report  from information  contained  in  the  Financial  Management
System "Allotment File."  The  total  disbursements from this
report, amounting to  $529,633,100  were reconciled with the totals
reported  by EPA  to   the Office  of  Management  and Budget  for
appropriations  68-20X8145  and 68-2068145  for the  period  ended
September 30, 1987.

Disbursements - Payroll

Personnel compensation  and benefits  disbursements  amounted  to
$82,597,072, which, represented actual personnel compensation and
benefits paid during fiscal 1987  on a  cash basis.
NOTE
        DISBURSEMENTS QUESTIONED
Questioned  disbursements  of  $905,485 consist  of  $895,862  for
general support  services  costs  improperly  allocated  to  the
Superfund appropriation,  and  $9,623  of disbursements based upon
the  projection  of an  exception  from the  statistical  sample
transactions.
                        61

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                                                             EXHIBIT  II
                                                            (CONTINUED)

 General  support  servicing costs were  questioned  due to  errors  in
 cost allocations as  follows:
Description
Region J.
Transportation of Things   $  5,467
Rent,  Communication and
  Utilities                 15,067
Printing and Reproduction     1,920
Other  Contractual Services   56,238
Supplies and Materials       21,834
Equipment                   19,706
Land and Structures
Grants, Subsidies and
  Contributions
Insurance Claims and
  Indemnities
      Total
$120,232
Region £

$

  (2,915)
  (6,003)
  23,977
 $15,059
  X8B3BS
Headouarterg     Total

  $   923    $  6,390
517,756
92
217,583
6,529
16,735
105
529,908
(3,991)
297,798
28,363
36,441
105
                                  645
  $760,571
   mnmamm*
                               845
$895,862
 Additional details relating to these  cost  allocation  errors  are
 contained  in  Finding  2.    Additional  details  relating  to  the
 testing  of disbursements are contained in Finding  6.
                            62

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APPENDICES

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                                     APPENDIX 1

              SCOPE AND METHODOLOGY OF STATISTICAL SAMPLING
              The primary objective of the Hazardous Substance (Superfund) audit was to
determine the dollar reasonableness of reported obligations and disbursements for fiscal year 1987.
The audit was designed to produce valid agency-wide estimates of the total dollar obligations and
disbursements by major object class, the discrepancy between the recorded and actual (audit)
amounts, the total dollar amounts questioned and set aside by the auditors, and the proportion of
transactions recorded in accordance with specified internal control or compliance attributes (e.g.,
the proportion of transactions for which the recording of obligations complied with established
internal controls or EPA policies  and procedures, or the proportion of accounts for which the
recording of disbursements complied with established internal controls or EPA policies and
procedures). Statistical samples were selected for the audit from three separate data files provided
by the EPA Financial Systems  Branch:   (1) the "paymerge" file consisting of personnel
compensation and benefits transactions; (2) the "allotment" file consisting of summary records of
nonpayroll obligations; and (3) the "detail history" file consisting of nonpayroll transactions
recording disbursements. The procedures used to select the audit samples are described below in
Section I. Section 2 summarizes the procedures used to calculate the statistical projections from
the sample.
1.            Sampling Procedures

1.1           Personnel Compensation and Benefits

              The sampling frame (i.e., "universe" file of personnel compensation and benefits
transactions) was constructed from a file of Superfund payroll transactions provided by the EPA
Financial Systems Branch (FMSY.AUDIT.SFFY8713.TAPEJ>AYMERGE). This file is referred
to as the "paymerge'' file and includes over 931,000 individual transaction records representing
$84.546,009* in payroll disbursements.  Records in the frame were initially aggregated by social
'This figure represents the total Superfund personnel compensation and benefits disbursements recorded in the
paymerge file for fiscal year 1987. As explained in Note 2, certain out of scope transactions were excluded from this
universe, reducing the universe to $84,485,884. Further, during the audit, the auditors determined thai it would not
be feasible to test certain types of benefit transactions, which totaled $2,852,253. This resulted in a universe
amounting to 581,633,631. from which projections were made.
                                      63

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security number (SSN) and pay period (PP) to form 93,470 consolidated SSN/PP units.  These
SSN/PP units should represent an employee's Superfund pay distribution for each pay period. On
average, there were 10 transaction records per unique SSN/PP, although the actual number of
transactions varied widely by SSN/PP. These SSN/PP units formed the basic sampling unit for
the audit.

              A decision was made to test certain unusual transactions in their entirety.  Thus, all
SSN/PPs with erroneous dates2, and all SSN/PPs with negative net disbursements were included
in the sample. In addition, a stratified sample of 452 SSN/PPs was selected from the remaining
transactions. The strata from which the samples were drawn were defined on the basis of the sum
of the dollar amounts of the transactions associated with the SSN/PP3. The sample was allocated4
to the strata in a way that was expected to minimize the sampling errors of numeric variables
correlated with the reported dollar amount. Under this allocation, all SSN/PPs with dollar amounts
of $6,000 or more were included in the sample (i.e., sampled with "certainty").  Within each of the
remaining size strata, the universe file of SSN/PPs was randomly sorted, and a systematic sample
of the desired size was selected from the sorted file. Table 1 summarizes the counts of transactions
and SSN/PPs in  the paymerge frame, and the corresponding counts in the sample.
2For this purpose, values of 0000,0186,0386,0986,1044, or 1226 for month and year in the paymerge data record
were considered to be erroneous.
3The dollar amount for an SSN/PP was computed prior to deleting certain transactions having "out of scope* source-
of-fund (SOF) codes (U, SOF codes other than T or "N"). SOF codes of T and "N" represent fiscal year 1987
transactions. Consequently, the size classes used to select the samples may not correspond to the actual size of the
consolidated SSN/PP record. However, this discrepancy was trivial because the number of records with ineligible
SOF codes in the paymerge file was small, and in no way biased the projections from the sample.
4Let Njj denote the total number of SSN/PPs in size stratum h. and let Sj, denote the standard deviation of dollar
amounts (disbursements) of all SSN/PPs in stratum h, where h » 1, 2,.... L. The values of Nh and Sh were
obtained directly from special tabulations of the paymerge file.  Given the total sample size n, the approximately
optimum number of cases to be sampled from stratum h is then given by (e.g., see equation 5-25. chapter 5 in
Cochran (1977): Sampling Techniques, John Wiley & Sons):
                                        64

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    Table 1.
   Distribution of SSN/PP units in payroll trtniaction frune aid sample
Description
of stratum
Total for
site strata
SSNlPPs with
improper data
SSN/PPs with
negative
disbursements
TOTAL
Total disburse*
menu* as
recorded in
paymerge file
J 94, 458.1 83
27.222
479

S 84.48S.884
Number of
SSN/PP units
in universe
93J22
23
125

93,470
Number of
transactions
in universe
929.342
393
1.300

931.03S
Number of
SSN/PPs
in sample
452
23
125

600
Number of
transactions
in sample
5,2 JO
393
1.300

6.903
    The dollar amounts in the table reflect only transactions with source-of-funds (SOF) codes of "7" or "N."
      See footnote 3 in text.
1.2
Nonpavroll Obligations
              The sampling frame of nonpayroll obligations was constructed from a file of
Superfund nonpayroll obligation  records provided by the EPA Financial Systems Branch
(FMSY.AUDIT.MASTSF.FY8713.H6150). This file is referred to as the "allotment" file and
contains over 530,000s individual obligation records. Three separate "subuniverses" were defined
for sampling and analysis: (Al) contracts - major object class 25; (A2) cooperative agreements -
major object class 41; and (A3) all other object classes, excluding object classes 11, 12, and 13
(personnel compensation and benefits). About 90,000 obligation records are included in the three
subuniverses indicated above. With only a few exceptions, each record in the file is uniquely
identified by the obligation document number, document control number, account number, and (4-
digit) object class. The total amount recorded in the FMS (allotment file) for the obligations in the
three subuniverses is S930.492.5806.  The distribution of the sampling units and corresponding
obligations is summarized in table 2 by subuniverse.
5This number includes all source of fund codes. About 160.000 of the 530.000 obligation records have source of
funds codes of "7" and "N," Le., those relating to fiscal year 1987.
     figure excludes personnel compensation and benefits obligations (object class 11, 12. or 13).  These object
classes account for $85,004.567 in the allotment file. When added 10 the amount for the three subuniverses. Uie
total obligations are 51,015,497.148.

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             Approximately 1,600 records related to non-payroll obligations were selected from
the FY87 "allotment" file for the audit A stratified sample of obligation records was selected from
each of the three major object class groups (subuniverses). The strata from which the samples
were drawn were defined on the basis of the obligation as recorded in the allotment file.  The
sample was allocated to the strata in a way that was expected to minimize the sampling errors of
numeric variables correlated with the dollar amount recorded in the allotment file. Under this
allocation, records with the largest obligations were selected with certainty. Thus, for subuniverse
Al, all records with obligations of $600,000 or more were included in the audit sample, whereas
for subuniverse A2, all records with obligations of $100,000 or more were included in the sample,
and for subuniverse A3, all records with obligations of $50,000 or more were included in the
sample.  Within each of the remaining size strata, the universe file of obligation records was
randomly sorted, and a systematic sample of the desired size was selected from the sorted file.
Table 2 summarizes the distribution of the sample by subuniverse. Note that all duplicate records
(cases with the same obligation document number, document control number, account number,
and object class code), and all records with negative dollar amounts were included in the sample
with "certainty."
                                       66

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    Table!
    Distribution of obligation records in the allotment file and in the sample by subunivene
Sufttniverse
Al
Major Object
Class 25
A3
Major Object
Class 41
A3
All Other
Object Classes
Except 11, 12.
and 13
Sat
class
negative

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              Three separate "subuniverses" were defined for sampling and analysis: (Bl)
contracts - major object class 25; (B2) cooperative agreements - major object class 41; and (B3) all
other object classes,  excluding  object classes 11, 12, and  13.  Within each subuniverse,
transactions were stratified by size, and whether the transaction recorded a disbursement (group 1)
or reversed (credited) a disbursement (group 2)8. The counts of sampling units and corresponding
dollar amounts are summarized in table 3 by subuniverse and transaction group.

              Approximately  1,400  transactions  related to nonpayroll disbursements were
selected from the FY87 detail history  file.  A stratified sample of disbursement transactions was
selected from each of the three  major object class groups (subuniverses).  The  sample was
allocated to the strata  in a way that was expected  to minimize the sampling errors of numeric
variables correlated with the dollar amount recorded in the detail history file. Under this allocation,
records with the largest amounts were selected with certainty.  Thus, for subuniverse Bl, all
records recording a disbursement of $600,000 or more, and all records reflecting a reversal of
$400,000 or more were included in the audit sample. For subuniverse B2, all records recording a
disbursement of $150,000 or more, and all records reflecting a reversal of $37,500 or more were
included in the audit sample. Finally, for subuniverse B3, all records recording a disbursement of
$100,000 or more, and all records reflecting a reversal of $25,000 or more were included in the
audit sample. Within each of the remaining size strata, the  universe file  of disbursement
transactions was randomly sorted, and a systematic sample of the desired size was selected from
the sorted file. For each subuniverse, the goal in allocating the sample to the size * type strata was
to achieve a relative sampling error of about 1.5 percent (at the 95 percent confidence level) for an
estimate of total dollar disbursements. Table 3 summarizes the distribution of the sample by
subuniverse and transaction group.
8SpecificaHy. records having transaction codes of 181 or 191 and a reversal code ofi, or a transaction code of 236
and a reversal code of 2 were assigned to transaction group 1. These transaction codes record disbursements in the
FMS. Records having uansaction codes of 181 or 191 and a reversal code of 2. or a transaction code of 236 and a
reversal code of 1 were assigned to transaction group 2. These transaction codes reverse or credit disbursements in
the FMS.
                                       68

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Duiribuiioa of diibuneiDent tnniKtioni ia aniveiw tad in wmpk by nbvnmna


StftaiuwM
Bl
Major
Object
Out 25




B2
Major
Object
O.I.4I




S3
All other
object eUiset
except
II. 12. 13




Transaction
iyp*
Group 1
(Diibune-
•eon)

Gravpl
(RevoMli)


Group 1
(Du bone-


Group 2
(Revert ill)


Group 1
(Dubune-


Group2
(ReveruU)


TOTAL FOR BI, Bl, B3

5iM
c/ocr

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2.
Estimation Procedures
              Two general types of estimates (projections) were made from the audit results: (1)
estimates of total dollars and differences between the audit and recorded amounts, and (2) estimates
of the number or proportion of units with specified attributes. The procedures used to calculate the
sample-based estimates and their corresponding sampling errors are described below.  The
"subuniverses" for which estimates were calculated are summarized in table 4.
              Table 4. Definition of subuniverses (analytic classes)
              Subuniverse
                     Description
                   1
                   2
                   3
                   4
                   5
                   6
                     Al: Obligations, major object class25
                     A2: Obligations, major object class 41
                     A3: Obligations, other non-payroll object
                           classes
                     B1: pisfanaexDtnfs, major object class 25
                     B3: Disbursements, other non-payroll object
                           classes
                     Personnel compensation
2.1
Estimates of Total Dollars
              A "difference estimator" was used to obtain estimates of the total dollar value
(accepted amount) for each of the subuniverses indicated in table 4.  The general form of this
estimator is:
where
                         the estimated total audit amount for subuniverse g;
                                       70

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               L(   a    the number of sampling strata defined for subuniverse g;

               Xgj,  •    the total dollar amount recorded in the FMS for all transactions
                          in stratum h of subuniverse g;

               n.|j   =    the number of sample units in stratum h of subuniverse g which
                          were tested9;
               xjhi  s    the dollar amount recorded in the FMS for the ith5
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sample as:
              dg   =    the estimated total questioned, amount for subuniverse g;
              d.   =    the estimated total set-aside amount for subuniverse g.

              The questioned and set-aside amounts for subuniverse g were computed from the
where
              d«hi  **    the questioned amount for the Jth sample unit in stratum A of
                        subuniverse g;
              dghi  =    the set-aside amount for the ith sample unit in stratum h of
                        subuniverse g.
2.2
Estimates of Attributes
              Attribute variables were coded as 1 (an exception), 0 (no exception), or N (not
applicable)10. Denoting the subuniverse by g, the stratum by h, and the sampled unit by i, the
projected number of exceptions for a particular attribute for subuniverse g, zg", was computed as:
where
              N.
      >   the number of sampling strata defined for subuniverse^;
      3   the total number of sampling units in the FMS in stratum h
          of subuniverse #;
      >   the number of sample units in stratum h of subuniverse g for
          which the given attribute was coded as 0,1, or N.
zghi a*   1 if the given attribute was coded as 1, and equals 0 otherwise.
10In a few cases the sample unit was not tested Although these "nonrcsponses" did not enter into the calculation of
the projections of attributes, they are reflected in the estimates of the number of exceptions.
                                        72

-------
               For a given attribute, the estimated number of units in subuniverse g to which the
 attribute applies was computed as:
 where b^ is the number of sample cases in stratum h of subuniverse g for which the attribute was
 coded as 1 or 0.

              The corresponding estimated proportion of applicable cases which are exceptions
 was computed as:
2,3           C^|pilfrrioi| of Samofing Errors.

              The estimates given in the preceding section (referred to as sample projections) are
based on one particular subset (sample) of transactions, and thus are subject to sampling
variability.  The "standard error" of the estimate provides a measure of this sampling variability,
and was used to construct intervals within which we would expect the "vac" population values to
lie. These intervals are referred to as confidence intervals, and have been computed for the sample-
based estimates described in the previous section.

              For the projected audit amount, yf",  using the difference estimator defined in
section 1.1, 95 percent confidence limits around the "true" population total are given by the
expression yf "± 1.96 s(yf"), where y^" is the sample estimate, and s(yg") is the standard error of
the estimate. The standard error of the estimate was computed from the expression:
                                      73

-------
where
                          N
                            ,h
                                                            *,h)2/(nfh-l)
and where ygh and Xgh refer to the ayjaage. audit and recorded dollar amounts per sample unit in
stratum h of subuniverse g, respectively.

             For attribute variables, 95 percent confidence limits around the total number of
exceptions in the population are given by the expression z,' ± 1.96 sCz,1), where zt' is the sample
estimate defined in section 1.2, and s(zg') is the standard error of the estimate defined by the
expression:
where
and
              For an estimated proportion, ps, the corresponding standard error was computed
as:
where

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                                     APPENDIX 2

                    PROJECTIONS FROM TOE SUPERFUND AUDIT
                               FOR FISCAL YEAR 1987
             The following tables summarize the projections made from the 1987 Superfund
audit The projections include estimates of total dollar obligations and disbursements, by major
object class, and also estimates of the number of exceptions and corresponding error rates for
various attributes.  The error rates shown in tables 4A through 8 for the different attributes have
different bases (denominators) depending on the estimated number of transactions in the universe
to which the particular attribute applied. The formulas used to compute the projections are given in
section 2 of Appendix 1.  Also given in the tables are estimates of sampling precision  for the
various projections (i.e., standard errors and 95 percent confidence limits).
                                     List of Tables
       Table
        1

        1A

        2

        2A

        3

        4A

        4B

        4C
                    Tide
Estimates of accepted, questioned, and set-aside nonpayroll
obligations, by subuniverse.
Estimates of accepted, questioned, and set-aside nonpayroll
obligations, for major object classes 21,23,26,31.
Estimates of accepted, questioned, and set-aside nonpayroll
disbursements, by subuniverse.
Estimates of accepted, questioned, and set-aside nonpayroll
disbursements, for major object classes 21,22,23,31.
Estimates of audit amounts and errors for payroll disbursements.
by major object class.
Projections of error rates for attributes related to obligations
for major object class 25 (contracts).
Projections of error rates for attributes related to obligations
for major object class 41 (cooperative agreements).
Projections of error rates for attributes related to nonpayroll
obligations for all major object classes except 25,41.
                                       75

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                           List of Tables (continued)
Table


 5A


 5B


 5C


 6


 7


 8
                     Tide
Projections of error rates for attributes related to nonpayroll
disbursements for major object class 25 (contracts)

Projections of error rates for attributes related to nonpayroll
disbursements for major object class 41 (cooperative agreements)

Projections of error rates for attributes related to nonpayroll
disbursements for all major object classes except 25,41.

Projections of error rates for attributes related to payroll
transactions.

Projections of error rates for nonpayroll obligations, major
object classes 21,23,26, and 31.

Projections of error rates for nonpayroll disbursements, major
object classes 21,23,26, and 31.  •
                                   76

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Table 1.     Estimates of accepted, questioned, and let-wide nonpayroU obligations, by subuniverse
Major object
f|««y
25
Contracts


41
Cooperative
agreements


Other
object classes
-

Obligations
FMS amount ft)
Accepted (audit) amount
Questioned amount
Set-aside amount
FMS amount
Accepted (audit) amount
Questioned amount
Set-aside amount
FMS amount (2J
Accepted (audit) amount
Questioned amount
Set-aside amount
Sample
estimate!
$719,732*54
$719,732,954
SO
$0
$I66J07J09
$166,207,009
$0
$0
$47J015J97
$46,915,892
$99^05
$0
Standard
—
—
—
—
—
—
76M53
76,253
—
95 paiLciit confidence limits
Lower
limit
—
—
—
—
—
—
46.766.436
-49,951
_
Upper
limit
—
__
—
—
—
—
47,065,348
248.961
—
 fFor the accepted, questioned, and set-aside amounts, entries are projections. The FMS amounts are 'universe' totals obtained from
  files provided by the Financial Systems Branch.
            161 obligation records in "nejanve" stratum.

 [2JExcludes 323 obligation records in "negative' stratum, and 46 obligation records in "duplicate" stratum.
                                                           77

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Table 1 A.   Estimates of accepted, questioned, «nd set-aside nonpayroll obligation*, for msjor object elasiet 21.23,26,31 *
Major object
frlttft
21



23



^26



31



Obligations
FMS amount
Accepted (audit} amount
^jiesBffHBfl amount
Set-aside amount
FMS amount
Accepted (audit) amount
Questioned amount
Set-aride smount
f MS amount
Accepted (audit) amount
Quesiioned amount
Set-aside amount
FMS amount
AoLcpted (ttioit) ttfmmt
i^hwwtWMHlH aMfWVffaf
s*— —
Sample
cstioatet
$7J72,661
$7^72,661
$0
$0
$16J44fl4
$16^44^>14
$0
$0
«,
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Ttble 2.     Estimates of accepted, questioned, and let-wide nonpayroU disbursements, by rabuiivcne
Major object
das*
25
Contracts
41
Coopcn&vc
•jjocmcntf
Other
object classes


Disbursements
FUS amount
Accepted (audit) amount
Set-aside amount
FMS amount
Accepted (audit) amount
Questioned amount
Set'Sftde amount
FMS amount
Accepted (audit) amount
Questioned amount
Set-aside amount
Simple
erttmaur
$373J26J47
$3n&6JA7
$0
SO
t43146J31
$43^46,131
SO
SO
t30,7«3,6SO
$30,754,027
$5,623
$0
SunUrd
cnor
—
—
9360
9,560
—
95 percent confidence limits
Lower
limit
—
—
30,735 .289
-9,115
—
Upper
limit
—
—
30,772.765
28.36}
—
 fFdr die accepted, questioned, and set-aside amounts, entries are projections. The FMS amounts are "universe" totals obtained from
  files provided by the financial Systems Branch.
                                                         79

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Table 2A.   Estimate* of accepted, questioned, and set-aside nonpayrpQ disbursements for major object classes 21,22,23,31
Major object
class
21



22



23
31

Obligations
FMS amount
Accepted (audit) amount
Questioned amount
Set-aside amount
FMS amount
Accepted (audit) amount
Questioned amount
Set-aside amount
FMS amount
Accepted (audit) amount
Oimdifkntvl •mnunf

FMS amount
Accepted (audit) amount
QiMarioMrf •iiaaml
ueauuneu amuuw
CM* • ••!!• MMWM*
dd^avoB aiiHEiin
Sample
estunatef
$6,553,164
$6,543,541
$9,623
SO
$397,4*8
$397,488
$0
$0
$14,402,135
$14,402,135
$0
$0
S6J94,4ll
$«4H4U
$0
$0
StBadVD
—
9^60
9^60
—
—
—
—
—
—
—
—
—
95 uataa confidence limit*
Lower
limit
—
6424.803
-9.115
—
—
—
—
_
_
—
— .
—
Upper
limit
—
6462.279
28461
—
—
—
—
—
—
—
—
—
 tForthe accepted, quecd^oed, and set-aside amounts, entries are projections. The FMS amoimu are "universe" totals obtained from
  file* provided by the Financial Systems Branch.
                                                          80

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Table 3.     Estimates of audit amount ami arm for payroll disbursements, by major object class
Major object
class
11
Compensation

12*
Benefits

TOTAL


Disbursements
FMS amount 1 1]
Accepted (audit) amount
Enw (difference)
FMS amount (I]
Accepted (audit) amount
Emr (difference)
FMS amount (I)
Acorpted (audit) amount
Emr (difference)
Samplt
esUmatef
$73,7S6J08
$73,960,010
$203,102
97JMS34
$7,676,988
(S17L546)
$910)5,441
$81,636,998
$31,556
Standard
eoor
72S.074
725.074
110.118
110.118
*
763.663
763.663
95 percent confidence limits
Low
limit
7Z.538.865
-U18.043
7,461.157
-387 J77
^^
80.140.219
-1,465^23
Upper
limit
75481.155
1.624.247
7.891819
44.285
fU^
83433.777
U28.335
 •Induda cnty object dazset 1210 and 1211.

 tFor accepted amounts and errors, entries an projections. The FMS amounts are "universe" totals obtained from files provided by
  die Financial Systems Branch.

 [IJExchides amounts for 23 SSNjPPi with enoneous dates and 124 SSN/PPs in (be "negative" stratum.
                                                        81

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Table 4 A.   Projections of error rates for attributes related to nonpayroll obligations for major object class 25
            (contracts)



Auributet
A
B
C
D
E
F
G
H
I
J
K

Projected
number of
exceptions
0
97
0
0
0
1
126
294
3,238
1,744
493


Standard
enor
_
77
—
—
—
0
47
294
878
729
90
95 percent confidence limits

Lower
limit
_
0
_
—
—
1
34
0
1417
315
317

Upper
limit
_
248
—
—
—
1
218
870
4.959
3,173
669


Estimated
error rate
0.00%
0.77%
0.00%
0.00%
0.00%
0.01%
1.45%
3.40%
41.89%
22.58%
1U7%
 tDefinition of Attributes:
 A:  Obligation document number agrees with obligating document
 B:  Document control number agrees with obligating document.
 C:  Account number agrees with obligating document, and account number begins with 7 or N.
 D:  Object class agrees with obligating document
 E:  Object class appears reasonable based on description of obligation,
 F:  Appropriation number is Superfund.
 G:  Written superfund justification/statement of need is on obligating document
 H:  Name of authorized official agrees with authorized official's signature list maintained by FMO.
 I: Receipt of obligating document is timely (S 3 days).
 J:  Posting to FMS by FMO is timely (£ 4 days).
 K:  If obligation amount > $25,000, a commitment was previously entered into FMS.
                                                62

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Table 4B.    Projections of enor rates for attributes related to nonpayroll obligations for major object class 41
            (cooperative agreements)



Attribute!
A
B
C
D
E
F
G
H
1
J
K

Projected
number of
exceptions
5
0
5
1
0
6
16
46
220
274
14


Standard
enor
5
—
5
0
—
1
11
15
23
24
0
95 percent confidence limits

Lower
limit
0
—
0
1
—
4
0
17
175
227
14

Upper
limit
15
__
15
1
_
8
38
75
265
321
14


Estimated
error rate
0.83%
0.00%
0.83%
0.17%
0.00%
0.99%
3.01%
7.59%
3630%
45.21%
2.89%
 tDefinition of Attributes:
 A;  Obligation document number agrees with obligating document.
 B:  Document control number agrees with obligating document.
 C:  Account number agrees with obligating document, and account number begins with 7 or N.
 D:  Object class agrees with obligating document.
 £:  Object class appears reasonable based on description of obligation.
 F:  Appropriation number is Supeifund.
 G:  Written superfund justification/statement of need is on obligating document
 H:  Name of authorized official agrees with authorized official's signature list maintained by FMO.
 t Receipt of obligating document is timely (£ 3 days).
 J:  Posting to FMS by FMO is timely (S 4 days).
 K:  If obligation amount > $25.000, a commitment was previously entered into FMS.
                                                83

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Table 4C.   Projections of error rates for attributes related to nonpayrolJ obligations for all major object classes
            except 25,41



Auribulet
A
B
C
D
£
F
G
H
I
J
K

Projected
number of
exceptions
5,153
5,520
5,911
4,770
5,488
6,935
12,341
18,465
34,184
39,238
4425


Standard
error
2,082
2.110
2,132
2,060
2,108
2.386
2,995
3.526
3.981
4.017
2.082
95 percent confidence limits

Lower
limit
1.072
U84
1.732
732
U56
2258
6,471
11354
26381
31365
444

Upper
limit
9.234
9.656
10,090
8.808
9.620
11.612
18.211
25376
41.987
47,111
8,606


Estimated
error rate
737%
725%
7.76%
636%
723%
1131%
16.64%
2525%
4921%
56.62%
3839%
 TDefiniuon of Attributes:
 A; Obligation document number agrees with obligating document
 B: Document control number agrees with obligating document.
 C: Account number agrees with obligating document, and account number begins with 7 or N.
 D: Object class agrees with obligating document
 E: Object class appears reasonable based on description of obligation.
 F: Appropriation number is Superfund.
 G: Wriaeo superfund justification/statement of need is on obligating document
 H: Name of authorized official agrees with authorized official's signature list maintained by FMO.
 t Receipt of obligating document is timely (S 3 days).
 J:  Posting to FMS by FMO is timely (£ 4 days).
 K: If obligation amount > $25,000, a commitment was previously entered into FMS.
                                                 84

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Table SA.   Projections of error rates for attributes related to nonpayroll disbursements for major object class 25
            (contracts)



Attribute!
A
B
C
D
E
F
G
H
I
J
k
L
M
N
O

Projected
number of
exceptions
1,382
0
40
80
222
661
756
40
921
0
0
119
11,241
6,538
660


Standard
error
977
—
39
55
221
659
677
39
696
_
—
119
1,652
1,664
659
95 percent confidence limits

Lower
limit
0
—
0
0
0
0
0
0
0
—
—
0
8,003
3,277
0

qpper
limit
3,297
_
116
188
655
1.953
2,083
116
2,285
—
—
352
14,479
9.799
1,952


Estimated
error rate
2.13%
0.00%
0.06%
0.14%
2.17%
1.61%
1.17%
0.06%
1.51%
0.00%
0.00%
0.65%
52.07%
10.62%
27.87%
 t Definition of Attributes:
 A: Obligation document number agrees with disbursement documents.
 B: Document control number agrees with disbursement documents.
 C: Account number agrees with disbursement documents.
 D: Object class agrees with disbursement documents.
 E: Object class appears reasonable based on description of goods or services on disbursement documents.
 F: Valid obligation was recorded in FMS prior to disbursement
 G: Project officer or approving official is authorized to approve payment and approval is indicated on
                dcuments.
 H: Invoice, receiving reports, approval forms and obligation documents are matched and indicate evidence of
    verification.
 L Disbursement documents are perforated and stamped paid and iiidicaie treasury schedule number and date.
 J: Check amount agrees with treasury schedule amount
 K: Certifying officer is authorized to certify payments and signature is on treasury schedule SF-1 166.
 L: Date approved by project officer or authorized official was prior to date certified by certifying officer.
 M: Invoice was paid on time, but not early (S 30 days but 2 25 days, unless discount was taken).
 N: Posting of disbursement to FMS by SFO was timely £ 4 days).
 O. Cash discount, if available and cost-effective, was taken.
                                                 85

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Table SB.    Projections of error rates for attributes related to nonpayroU disbursements for major object class 41
            (cooperative agreements)



Auributef
A
B
C
D
E
F
G
H
I
J

Projected
number of
exceptions
0
15
7
19
512
583
94
691
0
0


Standard
error
.
11
5
19
88
78
47
97
—
~
93 percent confidence limits

Lower
limit
.
0
0
0
340
430
2
SOI
-
™

Upper
limit

37
17
56
684
736
186
881
—
—


Estimated
error rote
0.00%
0.72%
034%
054%
25.50%
28.61%
4.57%
33.86%
0.00%
0.00%
 tDefinition of Attributes:
 A: Obligation document number agrees with drawdown request for L schedule.
 B: Document control number agrees with grant payment history record or FMO report.
 C: Account number agrees with grant payment history record or FMO report.
 D: Valid obligation was recorded in FMS prior to drawdown.
 E: Drawdown request or L schedule indicates evidence of review by technician for cash balanc
    of funds.
 F: Authorized official's approval was indicated on drawdown request of L schedule.
 G: Authorized official's approval was timely ($1 day).
 H: Posting to FMS by SFO was timely (S 3 days).
 I: Drawdown amount agrees to amount posted to grant payment history or FMO report
 J: Drawdown amount was included in monthly confirmation from treasury.
t and availability
                                                86

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Table SC.   Projections of error rates for attributes related to nonpayroU disbursements for all major object
            classes except 25.41



Auributef
A
B
C
D
E
F
0
H
I
J
K
L
M
N
O

Projected
number of
exceptions
90
1366
1,663
144
16
534
9,918
970
8457
W22
3,729
4,793
22,700
14323
194


Standard
error
78
936
871
79
5
316
2.195
808
2312
1,281
1.479
1.731
3,251
2,644
' 90
95 percent confidence limits

Lower
limit
0
0
0
0
6
0
5.616
0
4.025
0
830
1.400
16328
9.141
18

Upper
limit
243
3,201
3370
299
26
1.153
14,220
2354
13,089
4,833
6.628
8.186
29,072
19305
1 370


Estimated
error rate
0.11%
1.72%
2.04%
0.18%
0.02%
0.72%
1231%
124%
11.70%
3.12%
5.17%
7.01%
70.94%
19.46%
1.77%
 tDefinition of Attributes:
 A: Obligation document number agrees with disbursement docu
 B: Document control number agrees with disbursement documents.
 C: Account number agrees with disbursement documents.
 D: Object class agrees with disbursement documents.
 E: Object class appears reasonable based on description of goods or services on disbursement documents.
 F: Valid obligation was recorded in FMS prior to disbursement.
 G: Project officer or approving official is authorized to approve payment and approval is indicated on
    disbursement documents.
 H: Invoice, receiving reports, approval forms and obligatkm dooin»ents are inatcbed and indicate evidence of
    verification.
 L Dfchinfnft dlHaB1*"^ ff»- perforated and aamped paid and indicate treasury schedule number and date.
 J: Check amount afree* with treasury schedule amount
 K; Certifying officer to authorized to certify payments and signature is on treasury schedule SF- 1166.
 L: Date approved by project officer or authorized official was prior to date certified by certifying officer.
 M:  Invoice was paid on time, but not early (S 30 days but 2 25 days, unless discount was taken).
 N: Posting of disbursement to FMS by SFO was timely (S 4 days).
 O: Cash discount, if available and coa-effecdve, was taken.
                                                 87

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Table 6.     Projections of error rates for attributes related to payroll transactions



Affiibutet
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O

Projected
Dumber of
exceptions
1,743
12,623
1,743
9494
4,622
230
20389
3,721
8,755
14,765
9,692
6,131
1,653
2329
696


Standard
CHUT
676
1334
676
1,660
988
230
2.211
1,174
1.626
2.023
1.689
1,167
649
853
365
95 percent confidence limits

Lower
limit
418
9.028
418
6,040
2,686
0
16455
1.420
5,568
10.800
6382
3,844
381
1,157
0

Upper
limit
3.068
16,218
3.068
1^548
6458
681
25.223
6,022
11,942
18,730
13.002
8,418
2.925
4401
• 1,411


Estimated
error rate
3.83%
1838%
5-31%
1349%
521%
1339%
2436%
434%
12.78%
21.60%
14.19%
16.17%
25.44%
41.63%
20.74%
 tDefinition of Attributes:
 A: Account number agrees with time card.
 B: Account number agrees with timesbeeL
 C: Hours agree with timecard.
 D: Hours agree with time sheet
 E: Dollar amount agrees with audited hours x pay rate,
 F: Dollar amount agrees with audited base amount x benefit rate.
 G: Timecard certified by timekeeper.
 H: Timecard certified by supervisor.
 L Timesheet certified by employee.
 Jt Timesheet certified by rimfV"p*Ti
 K: Timesheet certified by supervisor.
 L: Leave rime supported by application for leave or timecard entry initialed by employee.
 M: Overtime hoori,compensatoiy rime wortod, and pronium pay supported
     authorization of overtime work.
 N: Overtime hours approved by approving official in remarks column on time card.
 O: Correction of previous timesheet entries supported by revised timeshe«an(l/or redistribution of payroll
    charges.
                                                88

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Tabie 7.     Projections or error rales for nonpayroll obligations, major object classes 21.23,26, and 31
Attribute!
A
B
C
D
E
F
G
H
I
J
K
Major object
class 21
7.5%
7.6%
8.2%
6.6%
6.5%
10.5%
15.5%
26.5%
50.8%
60.5%
402%
Major object
Class 23
272%
24.4%
24.4%
24.4%
28.2%
25.0%
30.5%
31.1%
38.9%
63.0%
0.0%
Major object
class 26
0.0%
0.0%
0.0%
0.0%
9.6%
0.0%
11.4%
33%
18.9%
15.8%
0.0%
Major object
class 31
03%
03%
03%
03%
117%
263%
34.7%
2J%
48.8%
20.4%
82%
Total*
7.4%
73%
7.8%
6.4%
72%
113%
16.6%
253%
492%
56.6%
38.6%
-Total for all object classes except 25,41,11,12,13.

tDefinition of Attributes:
A:  Obligation document number agrees with obligating document
B:  Document control number agrees with obligating document
C:  Account number agrees with obligating document, and account number begins with 7 or N.
D:  Object class agrees with obligating document.
£:  Object class appears reasonable based on description of obligation.
F:  Appropriation number is Superfund.
G:  Written superfund justification/statement of need is on obligating document.
H:  Name of authorized official agrees with authorized official's signature list maintained by FMO.
L Receipt of obligating document is timely (S 3 days).
J:  Posting to FMS by FMO is timely (S 4 days).
K:  If obligation amount > $25,000, a commitment was previously entered into FMS.
                                                89

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Table 8.     Projections of error races for nonpayroll disbursements, major object classes 21,23,26, and 31
Attributef
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
Major object
class 21
0.1%
0.7%
2.1%
0.0%
0.0%
0.8%
12.9%
0.0%
10.4%
3.6%
5.5%
5.7%
85.1%
20.1%
0.1%
Major object
class 23
0.0%
0.9%
0.4%
0.4%
0.0%
0.0%
4.1%
32.2%
35.1%
0.0%
12.2%
3.6%
27.7%
1.1%
0.0%
Major object
class 26
0.0%
14.4%
22%
0.0%
0.0%
0.0%
4.0%
0.0%
1.5%
0.0%
0.0%
18%
24.9%
6.1%
0.0%
Major object
class 31
0.2%
0.2%
3.1%
3.6%
0.4%
0.1%
43-5%
8.3%
8.5%
0.5%
0.2%
56.6%
43.9%
21.5%
58.8%
Total*
0.1%
1.7%
2.0%
0.2%
0.0%
0.7%
12.5%
U%
11.7%
3.1%
5.2%
7.0%
70.9%
19.5%
1.8%
•Total for all object classes except 25,41,11,12,13.

fDefinition of Attributes:
A; Obligation document number agrees with disbursement documents.
B: Document control number agrees with disbursement documents.
C: Account number agrees with disbursement documents.
D: Object class agrees with disbursement documents.
£• Object class appears reasonable based on description of goods or services on disbursement documents.
F: Valid obligation was recorded in FMS prior to disbursement.
0: Project officer or approving official is authorized ID approve payment and approval is indicated on
    disbursement documents.
H: Invoice, recdving reports, approval forms and obUgatkmd^oimentssie matched and inolcateevkkoce of
    verification.
t PfcfrTTTPT! lfW«l»""H ft p"*?™***1 •"* «*ampaH paid and mHifCM traa«my «riwfcil
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**  i
-,
/ A
V£E
                             APPENDIX 3
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON, D.C. 20460

                             AU3 I  9  1938

                                                             OFFICE OF
                                                           ADMINISTRATION
                                                           AND RESOURCES
                                                           MANAGEMENT
MEMORANDUM
SUBJECT:
FROM:
TO:
           Response to Draft Audit Report P5EH8-11-0030
           Obligations and Disbursements of the Hazardous
           Substance Super fund fqr->t*ve Fiscal Year Ended
           September 30,
           Assistant/Administrator

           Ernest E. Bradley, III
           Assistant Inspector General  for Audit  (A-109)
     In  response  to your  memorandum of  July l,  1988, we  have
reviewed  the  subject  draft  Superfund  audit  report  and  have
attached our  comments.   Although we  generally agree with many of
the   recommendations,  we  disagree   with  the  conclusions  and
recommendations that are immaterial and have no impact on the fair
presentation of obligations and disbursements.

     We do not agree with the decision to set aside $24 million of
obligations  and  disbursements.    This  set  aside  was  based  on
projections of  errors from statistical samples when the auditors
did  not locate  written Superfund justifications;  however,  other
documents available to support expenditures were not considered.
                                                  s~
     I ^emphasize that  we  maintain and enforce adequate internal
controls  to  ensure  Superfund  monies are   spent appropriately.
Relevant  to  this,  the AICPA,  Statement  on  Auditing  Standards
generally  states  that while  deviations  from pertinent control
procedures increase  the risk of material errors in the accounting
records* such deviations do not necessarily result in errors.  The
Standards also  indicate the relationship of procedural deviations
to  other  related internal controls  should be  considered  (e.g.
approval signatures  on  obligating documents).
                                 91

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                              - 2 -
     We also  question the  summary  conclusion  that the projected
set  aside  costs  represent a  material  weakness  in  the Agency's
schedule of obligations  and disbursements.  The  total set  aside
represents approximately 2.3% of obligations and less  than  0.5% of
disbursements.     we  suggest   that   these  variances   are
"insignificant"  and  "immaterial"  as  indicated  in   professional
reporting  standard,  AICPA,  Statement   of  Financial Accounting
Concepts #2.

     The other recommendations that we do not support are  those
that do not comply with  established  Agency guidelines.    Several
recommendations  require  corrections to  the Financial Management
System  (FMS)  even  though  Agency guidelines were  followed.    For
example, one  recommends that  we revise our existing policy  for
allocating  general  support services costs to remedy incorrect
charges to  the Superfund appropriation.   We developed the Agency
policy  for  cost allocation  to reflect  a  reasonable,  consistent,
and  practical  method for  allocating these costs.    Acceptable
practices  for  large  organizations  are  to  develop estimating
processes which will ensure the best method for achieving a fair
presentation  of financial position.  Our present procedures  and
guidelines,  utilizing budgeted  full-time  equivalents  (FTEs)  in
lieu of actual FTEs, are appropriate for charging  Superfund costs.

     Our allocation method  provides  a  fair presentation  of  our
financial position,  and  again with this  finding,  we believe  the
recommended adjustments  are immaterial.   The  rationale   for  our
current policy should have been considered in conjunction with the
magnitude  of   the  error  to   total  Superfund  obligations  and
disbursements.

     For increased effectiveness in future audits,  we suggest that
particular  attention  be  focused  on the  fair  presentation  of
Superfund obligations and  disbursements,  the  materiality of  the
audit findings, and the compliance with AICPA pronouncements.

     Attachment  I   to  this  memorandum  contains  our   detailed
response  to   each  recommendation  and  Attachment   II   contains
comments  to   the   other  report  information.     We  would   also
appreciate  having our complete comments  included  in your  final
report.   Should  you have  any questions,  please contact  Anthony
Musick in the Financial Management Division on 382-5097.

Attachments
                                92

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ATTACHMENT I
                   RESPONSE TO RECOMMENDATIONS
                DRAFT AUDIT REPORT IP5EH8-11-0030
            Audit of Obligations  &  Disbursements Under
                  Hazardous Substances  Superfund
     This attachment  contains  our  response to each recommendation
in the  draft audit report.   Additionally, we have  the following
general comments concerning the overall audit.

     o  The timing of memos on the entrance conference provided
        little or no notice to the financial management
        officers (FMOs) on the agenda of the entrance
        conference or the nature of the information
        requested by the auditors.

     o  Some preliminary Notification of Findings (PNFs)
        requested only clarification of an issue and were
        subsequently withdrawn after the FMOs provided
        written responses.

     o  Some PNFs were issued after the exit conference which
        did not allow the FMOs time to prepare a response.

     o  At the Headquarters' exit conference, three audit findings
        were raised for the first time.

     o  Auditors made numerous duplicate requests for information
        previously provided.

     o  Requests for auditor space, locking file cabinets,
        telephones, etc. were not made in consideration of our
        available facilities.  We provided what accommodations
        were available, which at a minimum were equivalent to
        those of the finance office staff.  As you are aware,
        space within EPA is at a premium.

     We discussed  this matter with the accounting  firm and your
staff.  We feel that to improve the  effectiveness  of the FY 1988
audit these  foregoing items should be  considered in planning the
audit.    Additionally,  we  must  work  together  on clearer  and
increased  communications between  the  contract  auditors  and the
FMOs.
                                 93

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                               -2-
1.
Our responses to your specific recommendations follow:

IMPROVEMENTS ARE NEEDED IN ACCOUNTING FOR AND CONTROLLING
PERSONAL PROPERTY   ""                              "~~"    '
Recommendations/Responses

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management emphasize to Property
Accountable Officers  (sic) the importance of complying with
Agency policies.

     We agree that the Assistant Administrator (AA) for the Office
of Administration and Resources Management  (OARM) should emphasize
the importance of complying with Agency policies and will direct
the Director, Facilities Management and Services Division  (FMSD),
to send a memorandum  to the property accountable officers re-
emphasizing the Agency's requirements for property.

     We recommend that EPA's Assistant Administrator for
Administration and Resources Managementestablish an Agency policy
for reconciling property and accounting records.

     We agree with the recommendation, but we cannot implement
this recommendation at the present time. 4QBBQlMfeiy« the Personal
Property Accounting System's (PPAS) infoi.i«aLiuflPtarused to capi-
talize items in the Financial Management System  (FMS).  In FY 1989,
the Financial Management Division  (FMD) plans to use the Software
Package for Unique Reports  (SPUR) to retrieve data from the FMS to
make these adjustments.  This effort will be coordinated with the
FMSD..

     In addition, the Director, Financial Management Division, has
reviewed the capabilities of the new Integrated Financial Management
System  (IFMS) to ensure that the reconciliation function is suffi-
cient to comply with  the General Accounting Office's (GAO) Policy
and Procedures Manual for Guidance of Federal Agencies, Title 2.

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management establish  an Agency policy
for capitalizing EDP  software.

     The General Accounting Office will be  issuing specific
guidance relative to  capitalization of the  Federal Government's
assets.  Based on this guidance, the Director, FMD, will provide,
as necessary, the appropriate accounting structure and guidance  to
account for these assets  and will  incorporate necessary revisions
to the Resource Management  Directives  System, Division 2550C,
Chapter 8, Property and Inventory.  This chapter  is scheduled  for
completion during FY  1989.

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                               -3-
     We recommend that EPA1s Assistant Administrator for
Administration and Resources Management provide additional training,
as necessary to instruct property management personnel in their
duties.''

     We agree with the recommendation and we held training sessions
for property management officers in Cincinnati, Research Triangle
Park (RTF), and Headquarters in 1987.  FMSD will also review the
contents of the current training sessions to incorporate issues
raised in this audit report.

     In addition, the Director, FMSD, has requested additional
property management .resources through the Agency's formal budget
process.  The FMSD has also taken opportunities to augment re-
sources whenever possible through the use of task forces.  Speci-
fically, FMSD has established a Superfund Property Policy Task
Force and a Property Management Roundtable composed of two regional
representatives and property officials from Cincinnati, RTP, and
Headquarters.  The latter group is tasked with resolving issues
and improving property management Agencywide.

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management obtain certifications from
Property Accountable Officers  (sic) that corrective actions have
been taken to correct errors and omissions from the PPAS.      ~

     The AA for the OARM will require the Director, FMSD, to
correct and update the PPAS resulting from physical inventories
taken by the property management officers.  Each property manage-
ment officer will be instructed to provide written confirmation to
the FMSD that such inventory has been completed.

     We recommend that EPA's Assistant Administrator for
AdminTstration and Resources Management review the new Personal
Property AccountingSystem  to ensure that it will adequately
account for Superfund property and will contain data elements to
I,
simplify reconciliation procedures.

     The new  PPAS  ia  currently  being  reviewed by FMSD  to ensure
that the requirements for  Superfund accountability are being  met.
The new PPAS  will  also be  reviewed  for  opportunities to streamline
the reconciliation process.   The  new  PPAS  will  be an interim  system
until the  time when the Integrated  Financial Management System  is
implemented in FY  1989.  We  believe IFMS will eliminate the need
for manual reconciliation.

     We recommend  that EPA's Assistant  Administrator for
Administration and Resources Management review  the new I'n teg rated
Financial  Management  System  to  ensure that it will properly account
for capital equipment.

     The Director, FMD, through the IFMS taskforce, has worked
extensively with the  Director,  FMSD,  to ensure  that the property
                                95

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                               -4-
module of IFMS meets the needs of the Agency.  FMD held an
extensive review and comment period to address the technical,
policy and procedural capabilities of IFMS throughout OARM and
will continue to do so throughout the IFMS implementation process
in FY 1989.
     We recommend that EPA's Assistant Administrator for
AdminTstration and Resources Management resolve the difference
between
cj
responsibility.
>etween  the  EPA directive  (sic)  and  the Region  2 Counsel's  opinion
;oncerning the need  to  sign  a  letter of acceptance  of  custodial
     We disagree that a conflict exists between the Agency
Directive and the Region 2 General Counsel opinion.  Custodial
officers are required to sign for property as part of their respon-
sibilities.  In the event that custodial officers do not sign for
the property, they are not relieved of their responsibilities.
Therefore/ the Director, FMSp, will notify custodial officers, in
writing of their responsibilities as outlined by the EPA Directive,

2.   PROCEDURES SHOULD BE MODIFIED FOR ALLOCATION OF GENERAL
     SUPPORT SERVICES COSTS

Recommendations/Responses

     We recommend that EPA's Assistant Administrator for
Administrationand Resources Managementrevise the allocation
methodology of theplanto clarify the requirements for
allocating costs based upon cumulative obligations and cumulative
disbursements separately.

     We disagree with the recommendation that a revision to our
allocation methodology is necessary.  The auditors have correctly
noted that obligations and disbursements are allocated at the same
time and in the same amount.  The first step of the procedure
involves a calculation of obligations to be allocated, using
cumulative obligations and the appropriate FTE ratio.  The dollar
value calculated is then used as the amount of obligations and
disbursements to be charged to Superfund each month.  We believe
that this procedure is the most accurate and practical way of
allocating these costs.

     The auditors  suggest  that "Superfund disbursements should be
recorded based upon the disbursements recorded in  the S&E appro-
priation for  the allocated costs."  That suggestion  is not
feasible because the  initial allocations of obligations occur
at  the General Ledger  level — they are  not tied to  individual
spending actions but  rather to total support cost  obligations  in
certain sub-object  classes.  Thus,  it  is highly  impractical  to
determine at  the  time  funds are actually disbursed for any
                                96

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                               -5-


spending action, what ratio was used to allocate the obligation
for that spending action.  Further, because the ratios are
constantly being adjusted throughout the year based on cumulative
figures, the neaningfulness of attempting to tie allocation of any
particular disbursement back to the original obligation is very
questionable.

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management change the policy to
require all cost allocations for general support services to be
based on actual FTE ratios.

     We disagree that the Agency policy should be modified.  We
feel that it accurately estimates the general support costs to be
allocated to the Superfund appropriation under the current method-
ology.  The current methodology provides for a monthly allocation
of the cumulative Salaries and Expenses  (S&E) appropriation to the
Superfund appropriation based on the cumulative monthly FTE ratio
of Superfund versus total FTEs.  The cumulative FTE ratio
reflects both authorized and actual FTEs depending on the nature
of the cost.

     The Agency's approach for using authorized FTEs in certain
instances reflects those circumstances where the use of actual
FTEs was not representative of Superfund*s use of Agency resources.
For example, the acquisition of space does not lend itself to the
use of actual FTEs since space must be determined in advance based
on a projected needs, i.e. the budget.  Regardless of whether the
space is actually used during the year according to these pro-
jections, the space was available to the Superfund program.  In
this instance, to apply actual FTE ratios to determine the allo-
cation would erroneously undercharge the Superfund appropriation
for its share of cost.

     We also believe that the current methodology is consistent,
provides a fair estimate of costs, and does not materially distort
the amount of the Agency's obligations and disbursements.  You
recommended in this report that we adjust the Superfund appropri-
ation to reflect actual ratios.  The adjustment you proposed is
.15% of total Superfund obligations and disbursements.  This low
percentage supports our position that our methodology does fairly
reflect the appropriate charges.

     We recommend that EPA's Assistant Administrator  for
AdminTstration and Resources Management  require FMD to recal-
culate general support cost allocations  for Headquarters based
on actual FTE ratios and make the  appropriate adjustments  to
Superfund.

     We disagree with the basis  for this recommendation and the
recommended action.  As we stated  in our response  to  the previous
recommendation, we feel that  the current Agency policy for Superfund
                               97

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                               -6-
suppott cost allocation is effective for accurately projecting the
charges to the Superfund appropriation from the S&E appropriation.
We believe the Agency's policy for allocating general support
costs:

     o  provides the most conservative estimate,

     o  provides consistency across the Agency, and

     o  provides reliability of data within the FMS.

     We also believe that any system for estimating costs will
contain some degree of error, however we maintain that adjustment
of .15% of total disbursements is insignificant and indicates in
fact, that our approach is a sound method for distributing general
support costs to the Superfund appropriation.

     We recommend that EPA*s Assistant Administrator for
Administration and Resources Management require the Comptroller
to request the Regional Administrator of Region 3 to recalculate
general support costs using actual FTE ratios and make the appro-
priate adjustments to Superfund.

     We disagree with the recommendation for the same reasons
stated in the two previous recommendations.  We maintain that the
Agency methodology fairly estimates the amount of general support
costs.

     The Comptroller will request the Regional Administrator for
Region 3 to use Agency guidelines for allocating general support
costs to the .Superfund appropriation.

     We recommend thatEPA*s Assistant Administrator for
Administration and Resources Management obtain written certifi-
cations from the RegionalAdministrators of Regions 4, 5 and 10
that the general support services cost allocations for fiscal
2E
iL
1987  (sic) were recalculated and appropriate adjustments were
made.
     We agree that the AA  for OARM  should  request written
certifications from the  Regional Administrators of Regions 4,  5,
and 10 that correcting adjustments  were made  to the general  support
services cost allocations  for FY 1987.  However, subsequent  to
completion of audit fieldwork,  the  Director,  Financial Management
Division, received written confirmation from  the Financial Manage-
ment Officers of Regions 4,  5 and 10  that  corrections have been
made.
                                98

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                                -7-
 3-   EPA NEEDS  TO  STRENGTHEN  PROCEDURES  FOR MONITORING LETTERS
     OF CREDIT""'
 Recommendations/Responses

     We  recommend that EPA*s  Assistant Administrator  for
 Administration and Resources  Management request  the Regional
 Administrator of Region 1  to  followop (sic)  to determine  if "the
.two  recipients identified  in  the  finding were maintaining excess
 cash balances and, if so,  take appropriate corrective action.

     We  agree that the AA  for OARM should request  the Regional
 Administrator of Region 1  to  followup with the two grant  recipients
 maintaining excess cash balances  and to provide  written confirmation
 that follow-up action has  been taken.  However,  subsequent to  the
 completion of audit fieldwork, the Director, Financial Management
 Division,  received written confirmation from the Financial Manage-
 ment Officer of Region 1 that letters were sent  on April  7 ,  1988,
 to the two recipients requesting  a reconciliation  of  drawdown
 amounts.  The required reconciliations have been completed.   In
 addition,  the auditors were notified at the time of  the audit  of
 these  actions by the Financial Management Officer.

     We  recommend that ILPA'^s Assistant Administrator for
 Administration and Re»a»»ec» Management request  the  Regional
 Administrators of Regions  l'f  8, 9 and 10 to jiotijy in writing
 the  recipients identified  as late filers of SF-272s  of the
 requirements for timely filing and the corrective  actions 'that
 may  be initiated if the compliance problem is not  resolvedT
      We agree that the m ior OARM should request the Regional
 Administrators of Regions JL, 8,  9 and 10 to notify in writing
 the recipients identified as late filers of SF-272s and to provide
 them with the requirements for timely filing and subsequent cor-
 rective action which will be taken by the Agency for noncompliance
 with the requirements.  Subsequent to the completion of audit
 fieldwork, the Director, FMD, received written confirmation from
 the Financial Management Officers of Regions 1, 8, 9 and 10 that
 follow-up actions were being taken with the identified late filers
 In addition, the auditors were notified at the time of the audit
 of these actions by the Financial Management Officers.

      We recommend that EPA's Assistant Administrator for
 Administration and Resources Management issue additional Agency
 guidance requiring FMOs to document follow-up action taken on
 recipient noncompliance with timely filing requirements for ~
 SF-272S.                   "
      We disagree with the recommendation and we believe that
 sufficient Letter of Credit  (LOC) guidance currently exists for
 use by the regions and cooperative agreement recipients and that
 additional follow-up procedures are not warranted at this time.
                                 99

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                               -8-
Current LOG guidance includes the following:

     o  Resources Management Directive 2540, Chapter 5,  Cash
        Management - Letter of Credit.

     o  Letter of Credit - Treasury Financial Communications
        System (LOC-TFCS) Recipient's Manual.

     o  Comptroller's Policy Announcement No. 88-06, Letter of
        Credit Reconciliation Procedures.

     Most of the problems cited in the subject report were a
result of noncompliance with current policies and procedures.  We
will continue stressing adherence to all financial operating
procedures, including LOG procedures by regions and cooperative
agreement recipients.

4.   EPA NEEDS TO IMPROVE RECORDING AND MANAGING ACCOUNTS
     RECEIVABLE

Recommendations/Responses

     The Office of the Inspector General issued Audit Report
EIA67^11-0029-80779, dated March 17, 19B8, covering their review
of EPA's accounts receivable activities*  The .report identifiei""
similar findings and made appropriate recommendations. Conse-
quently, we make nofurther recommendations in anticipation
that the Agencywill respond totheOffice ofthe Inspector
General's report.

     Accounts receivable issues are in the process of close out
as indicated in the Comptroller's response dated February 1,
1988, to the Office of Inspector General Audit Report on accounts
receivable.

5.   OBLIGATIONS WERE QUESTIONED DDE TO RECORDING ERRORS AND
     SET-ASIDE FOR LACK OF WRITTEN JUSTIFICATION

Recommendations/Responses

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management emphasize the need for
FMOs to follow Agency policies for timely recording of obligations
in the FMS.

     We agree with the recommendation and the Director, Financial
Management Division, will prepare a written memorandum to the FMOs
emphasizing the requirement for timely recording of obligations
into the FMS.
                                 100

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                               -9-
     We recommend that EPA's Assistant Administrator for
Administration and Resources Management emphasize the need for
program offices to follow Agency policies requiring written
statements of need for charging Superfund and providing obligation
documents to FMOs in a timely manner*
     We agree with the recommendation and the Director,
Financial Management Division, will prepare a memorandum to all
program offices re-emphasizing the requirements for Superfund
justification for obligation documents and the need to promptly
forward those documents to their servicing finance office.

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management request the appropriate
program offices and FMOs to review and resolve the previously
provided set-aside and questioned sample transactions, which
resulted in the projected questioned and set-aside obligations,

     We agree that FMOs should correct errors found during the
audit.  In most cases, the FMOs resolved or provided the necessary
data or correction at the time of the auditors' review and provided
this information to them.  In some cases, these questioned
costs were still reported in this report even though the auditors
had indicated that responses to the preliminary notification of
findings were acceptable.  Attachment II, identifies specific
regional or field office comments which indicate where corrective
action had been taken and had not been recognized by the auditors.

     We strongly disagree with the rationale used to arrive at
the summary conclusion that the projected, set-aside costs of $24
million represent a material weakness in the Agency's schedule
of obligations and disbursements.  The auditors reportedly used a
statistically-based sample and determined that a percentage of
items sampled lacked written justification.  They erroneously
used that percentage to project a dollar amount of incorrect
obligation and disbursement transactions.  In fact, the only logi-
cal conclusion to be made is that a percentage of the total
universe of obligation and disbursement items lack written justifi-
cation, and that this conclusion is indicative of a weakness in
internal procedures.

     We also believe that the lack of documentation is not
conclusively indicative of errors  in the Agency's obligation and
disbursement activity within  the Superfund appropriation.  In
fact, the AICPA Statement on Auditing Standards #39, paragraph
#33, states:

     "In assessing  the tolerable rate,  the auditor should  consider
the relationship of procedural  deviations  to  (a)  the accounting
records being  tested,  (b) any related  internal  accounting  control
procedures  [emphasis  added],  and  (c)  the purpose  of the  auditor's
evaluation."
                                101

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                               -10-
     Paragraphs 134 and 141 of the same reference further re-emphasize
our point by stating:

     "34.  In assessing the tolerable rate of deviations, the
auditor should consider that, while deviations from pertinent
control procedures increase the risk of material errors in the
accounting records, such deviations do not necessarily result in
errors (emphasis added].For example, a recorded disbursement
that does not show evidence of required approval may nevertheless
be a transaction that is properly authorized and recorded."

     "41.  In addition to the evaluation of the frequency of
deviations from pertinent procedures, consideration should be
given to the qualitative aspects of the deviations.  These include
(a) the nature and cause of the deviations, such as whether they
are errors or irregularities or are due to the misunderstanding
of instructions or to carelessness, and (b) the possible relation-
ship of the deviations to other phases of the audit*  The discovery
of an irregularity ordinarily requires a broader consideration of
possible implications than does the discovery of an error  [emphasis
added]."

     Based on the above reference issued by the Auditing Standards
Board of the American Institute of Certified Public Accountants,
it is our position that the auditors have not conducted a suffi-
cient amount of audit work to conclude that this Agency has mis-
charged the Superfund appropriation.  Had the auditors used
additional audit techniques such as interviews or inquiries with
knowledgeable sources within the Agency, they may have verified a
substantial number of the set-aside items.  The following paragraph
taken from the United Stated General AccountingOffice Comprehensive
Audit Manual, AppendixI, pages 8-13 further supports our position:

     "Interviews are sometimes the only means of obtaining basic
information.  Information obtained in interviews may also be used
to supplement, explain, interpret, or contradict information obtained
by other means."
     For example,  one  of  the  items  set-aside
lack of documentation, was  an obligation  for
auditors stated  that the  transaction  was  not
ment document  in the finance  office records.
staff however  provided the  auditors with  the
located in  the official contract  file of  the
by the auditors for
$1 million.  The
supported by a procure'
 The finance office
procurement document
procurement office.
     This example  addresses  our  points  very clearly:  (1)  an
obligation  of  that magnitude could  not  be processed  through the
financial system without several administrative  checkpoints,  (2)
the auditor did  not ask  questions of any staff member  prior to
classifying the  transaction  as  "set-aside," and, in  fact,  (3)  the
supporting  documentation provided,  reflected the highest  level  of
signature authority (office  director).
                                102

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                               -11-
     The AICPA Statement on Auditing standards 131, paragraph 15/
further supports our point:

     "15.  Corroborating evidential matter includes documentary
material such as checks, invoices, contracts, and minutes of
meetings; confirmations and other written representations by
knowledgeable people [emphasis added]; information obtained by the
auditor from inquiry, observation, inspection, and physical exam-
ination; . . . "

     We acknowledge that the Agency's Superfund support
documentation procedures need strengthening in the area of
internal recordkeeping, however, we do not agree that because a
procedure was not followed, that obligations and disbursements
could be erroneously charged to the Superfund appropriation.

     In summary, we do not believe that a procedural deviation
distorts the Agency's obligations and disbursements.  The pro-
jected set-aside obligations represent only 2.3% of the total
universe of Agency obligations.  The percentage is considered
immaterial, and no evidence indicates any inappropriate charges
to the Superfund appropriation.  The conclusion reached by this
audit appears contradictory to the stated audit objectives
and AICPA pronouncements.

6.   LACK OF DOCUMENTATION FOR SOPERFUND DISBURSEMENTS RESULTS
     IN QUESTIONED AND SET-ASIDE COSTS

Recommendations/Responses

     We recommend that EPA*s Assistant Administrator for
Administration and Resources Management emphasize to the FMOs
the importance of following Agency policies and procedures for
disbursements, particularly those related to the timely payment
of invoices and the timely entry of disbursement data in the FMS.

     We agree that the AA for OARM should direct the Director,
FMD, to prepare written memorandum to the FMOs emphasizing the
requirement for timely payments and timely entry of the payment
activity into FMS.

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management request the FMOs" to  review
and resolve the previously provided questioned and set-aside  sample
transactions, which resulted in the projected questioned and  set-
aside disbursements.

     We agree that FMOs should correct errors found during  the
audit.  In most cases,  the FMOs resolved  or provided the neces-
sary data or correction at the time of the review  and provided
                               103

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                               -12-
this information to the auditors.  In some cases, these questioned
costs were still reported in this report.  Attachment II, identi-
fies specific regional and field office comments which indicate
that corrective action had not been recognized by the auditors.

     We disagree with the basis for set-aside costs.  In summary,
our disagreement is based on our position that the lack of Super-*
fund justification within the finance offices is not a basis for
concluding that these costs were inappropriately charged to the
Superfund appropriation.  We acknowledge that the lack of justifi-
cation within the finance offices may reflect a weakness in internal
administrative procedures, however, it is not indicative of
mischarges.  We maintain that the auditors overlooked the extensive
approval process necessary to establish the obligation as well as
other alternative audit techniques for obtaining evidential matter
and that these controls do not have to be duplicated at the time
of disbursement.

     The Director, FMD, will review the administrative procedures
for processing Superfund disbursements to determine where admini-
strative procedures can be strengthened in the area of Superfund
justification documentation.

7.   RESULTS OF STATISTICAL ANALYSIS OF PERSONNEL COMPENSATION
     AND BENEFITS TRANSACTIONS

Recommendations/Responses

     We recommend that EPA's Assistant Administrator for
Administration and Resources Management emphasize the importance
of compliance with EPA policies and procedures for maintaining
adequate payroll records to support charges to Superfund.

     In October 1987, the Director, Financial Management Division,
issued a memorandum to all concerned parties.  The memorandum
re-emphasized the importance of EPA's policies and procedures
regarding timesheets and timecards.  Additionally, the Financial
Management Division has already taken the following actions:

     o  trained each program office on how to use the Payroll
        Redistribution System and to complete timesheets;

     o  initiated a two-hour timekeeping module  as part  of the
        Office of Human Resources Management's training  course
        for new administrative employees;

     o  offered a one-day timekeeping course for timekeepers and
        designated agents.

     FMD will continue to routinely provide training and  information
to the Agency's timekeepers.
                               104

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                                               ATTACHMENT II
                       SPECIFIC COMMENTS TO
               DRAFT AUDIT REPORT NO. P5EH8-11-0030
Summary of Audit Results

o  Page 5

   The reference to Region 7 should be deleted as it is a
   typographical error.

Property

o  Page 16, Bottom of Page

   Region 1 submitted a data input form on February 24, 1988,
   correcting the code and acquisition cost of the computer,
   inadvertently recorded as $2,097,029, costing $2,097.

o  Page 17, Middle of Page

   Inaccurate amounts recorded in the PPAS have been corrected
   by Cincinnati.

o  Page 19, Table

   Cincinnati recorded the missing items in PPAS.

   The RTP Property Officer entered the missing purchases into
   PPAS.

   Region 5 located and recorded 17 of 21 property items into
   PPAS.  They will continue to locate and enter the remaining
   i terns.

   Region 6 collected receiving reports, located the missing items
   and entered the data into the PPAS.  Region 6 stated that they
   have strengthened administrative property procedures.

   The report identified that 18 items are not recorded in
   Region 7'» PPAS.  Mine of the 18 items are non-accountable and
   therefor*, are not required to be recorded in PPAS.  At the
   time of the audit, the remaining 9 items were being entered.
   In fact, the necessary paperwork had been completed, the  items
   all accounted for, in use, and were appropriately marked  with
   decals.

   Region 8 was experiencing computer problems.  These problems
   were corrected.
                               105

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I
                               -2-
   National Enforcement Investigations Center (Center), Region 8,
   acknowledged that a small number of Superfund property items
   were not included in PPAS.  Currently all the Center's property
   is logged into PPAS and steps have been taken to assure its
   weekly input.  Additionally, the Center is working on a system
   to check the property and accounting records.

o  Page 19, Last Paragraph

   Region 1 issued a memo dated March 18, 1988, to each property
   custodial officer to maintain accurate and up-to-date personal
   property custody cards for sensitive items.

   Region 4 initiated and developed new procedures to eliminate
   the problem of missing custody cards in the future.

   Region 5 provided additional training in June 1988.  The
   problem of not maintaining personal property custody cards for
   sensitive items was corrected*

o  Page 21, Second Paragraph

   Region 4 conducted a physical inventory to identify all property
   within custodial area 14.  Efforts are underway to reconcile
   the PPAS with the physical inventory.

   Region 5 performs an average of three local inventories per
   month.  Complete physical inventories are conducted on an
   annual basis.

o  Page 21, Table

   Region 5 stated that the custodial officer located all 23
   property items cited by the auditors.

   Region 7 could not locate one item valued at $300.  They have
   initiated the process for reporting missing items.

o  Page 21, Bottom of Page

   Region 1 completed property reconciliation on March 31, 1988.
   The results are being reviewed.

o  Page 22, Bottom of Page

   RTP is replacing custodial assumption letters that were
   accidentally disposed.

   Region 1 prepared letters of acceptance of assumption of
   custodial responsibilities effective with  the FY  1988
   inventories.
                                106

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                                 -3-
     Region  4 conducted a training  course  for  custodial  officers.
     The  custodial  officers  are  now completing the  Assumption  of
     Custodial Responsibility  forms.   Over  90% of the  forms have
     been signed  and  returned, and  of  the  remaining 10%, physical
     inventories  are  being completed.  Additionally, custodial
     officers will  be given  a monthly  printout to keep them
     informed of  any  changes in  inventories.

 General  Support Services Costs

 o   Page  24,  Middle  of Page

    Comptroller  Policy Announcement 88-01, states,  "If the
    difference is more than $1,000, the offices should process
    an adjusting entry..."  The support costs identified as over-
    allocated in Region 10  was for $188; therefore, it would not
    warrant an adjusting entry.

 o  Page 25, Bottom of Page

    Region 4 concurs that the  Superfund allocation  formula was
    incorrect.  The FY 1987  Superfund allocation has been  recomputed
    and this resulted in $11,900 increase  to Superfund expenses.

    Region 5 provided the auditors  with  documented  evidence  that
    the $15,059 overcharge error was corrected.

 o   Page  26,  First  Paragraph

    Region 1  complied with the procedure.   The allocation  procedure
    in  the Agency's Financial Management Manual  presupposes that
    there are available  funds  in Superfund  to  be able  to affect an
    allocation.   The  ten  allocations were made on a monthly basis.
    At  that point,  they  no longer had  available  Superfund  monies to
    absorb an additional  allocation.   To make  charges which would
    exceed allowances is  not allowable and  could place the Region
    in  an  anti-deficiency position  if  the report recommendation is
    executed.
Letter of Credit

o  Page 28, Third Paragraph
   The auditors have a misunderstanding of Federal grant policy.
   They stated that if excess cash was not held by a recipient, it
   would be available for other users in the region.
                               107

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                               -4-
°  Page 28, Bottom of Page

   Region 1 developed a reconciliation worksheet based on
   Comptroller Policy Announcement No. 88-06.  This action was
   accepted by the auditors during their review and the reference
   should be removed from the report.

   Region 9 explained to the auditors the difference of $581,245.
   To reiterate/ the recipient was previously on another letter
   of credit and the $590,244 was reported on that letter of
   credit.  In order for the letter of credit records to reconcile
   to the FMO records, both letters of credit must be reviewed.
   The remaining $9,000 was a posting error that was corrected in
   January 1988.

   Region 9 disagrees that there is a discrepancy of $1,122,070
   between FMS and the letter of credit file.  Letter of credit
   increases are not always authorized for all amounts awarded
   on the cooperative agreement.  The agreement may contain
   special conditions which restrict the recipient from access
   to cash until certain requirements are met.

o  Page 29, Second Paragraph

   The Assistant Administrator for Administration and Resources
   Management asked the Grants Administration Division  (GAD) to
   develop a Superfund Cooperative Agreement management improvement
   plan.  GAD's initial effort involved reviewing each Region's
   management of its cooperative agreements.  Between August and
   December 1987, GAD and program staff visited every regional
   office.  During those visits, they met with senior regional
   officials, including program, finance, and grants staffs to
   determine how each Region manages cooperative agreements, how
   the program, finance, and grants staffs interact, and what
   regional cooperative agreement management activities need
   improvement.

   One finding of the reviews concerned problems with recipients
   filing Federal Cash Transactions Reports  (SF-272) promptly.
   In response GAD recommended that each Regional Assistance
   Administration Unit  (AAU) develop a  system to track when
   required reports,  including the Federal Cash Transactions
   Reports  (FCTRs), are due  (or  overdue).  The systems will
   provide guidelines for appropriate action when recipients
   either fail to submit reports or  submit reports  of substandard
   quality.
                               108

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                               -5-
Accounts Receivable

0  Page 31, Third Paragraph

   To say that the FMO did not know whether interest should be
   assessed to states is misleading.  The Region had requested
   clarification from PMD on the propriety of charging interest
   receivables due under Intergovernmental Personnel Act.  Pending
   a response, the Region is now including an interest clause on
   all Intergovernmental Personnel Act billings.

o  Page 31, Bottom of Page

   We do not agree that aggressive collection action is not being
   taken by the Agency.  The report did not identify which of the
   $6,028,964 accounts receivable due over 120 days were noncontrol-
   lable, e.g., in appeals, claims or on installment where debtors
   pay on an approved schedule.  In these cases, the subsystem
   would age these receivables based on when the account was
   originally established, not as of the next payment due date.

Obligations and Disbursements

o  Page 34, Table, Attributes

   Currently, Region 6 enters obligations into the system within
   24 to 48 hours.

   Region 6 requires all documents be reviewed for date stamps
   as a part of the data entry process.

o  Page 37, SecondParagraph

   All missing payroll items were accounted for at the Headquarters
   exit conference.

o  Page 38, Reason  (e)

   A listing of employees1 supervisors is not maintained by the
   payroll system, but by the designated agents.

o  Page 40, Exhibit, "Other Contractual Services" and Appendix
   2L Page 6

   Research Triangle Park  (RTF) has the following comments:

   Based on projection of errors, the auditors set aside
   $23,215,042 of which $18,705,204 represent contract payment,,.
                               109

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                               -6-
   The auditors stated the cause for set-aside cost was primarily
   due to missing documentation and lack of written justification,
   However, the referenced appendix shows the highest occurrence
   of error was in attributes I, J and K which relate either to
   timeliness or commitment verification.
   Attribute J:  Timely Posting to FMS by FMO.

   We recognize that internal procedural problems existed to
   preclude timely obligations of contracts in all cases.  These
   problems related to: (1) mail distribution of contracts, (2}
   returning documents to contracting officials for correction,
   and (3) waiting for valid accounting information.  In all
   three situations, we have taken steps to correct problems
   creating delays in recording contract obligations.

o  Appendix 2, Page 9

   RTP provides the following comment on a contract disbursement
   attribute exceeding a 5% error rate:

   ATTRIBUTE M - Invoice was paid on time, but not early.

   Based on the information in the auditors' work papers, the
   210 exceptions noted for this attribute are characterized
   as follows:
        Number of days
       required to pay

            <25
          31-37
          38-45
            >45
                            TOTAL
Number of exceptions
     by category	

         11
        133
         35
         31
        210-
   Of the 210 exceptions, 175 fell within the 23-45 day grace
   period of the Prompt Payment Act.

   Of the 31 late payments, 25 were for contracts which are not
   subject to the Prompt Payment Act.  'Of the remaining six
   payments, two were actually made within the allowable 45 day
   limit and the 4 payments made in excess of 45 days and subject
   to the Prompt Payment Act represent  .92% of the total sample.
                               110

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                                                      APPENDIX 4,


AGENCY'S SPECIFIC COMMENTS JO OUR DRAFT REPORT AND OUR EVALUATION

The following  are the Agency's specific  comments to  our draft
audit  report  and our  evaluation  of these comments.    These
specific comments were generally provided as  Attachment II to the
Agency's  formal  written  response and  are included in  their
entirety in Appendix 3.

Note:   The page numbers referred to  in the Agency's comments were
the draft report page numbers. The final report page numbers are
indicated in parentheses.

AGENCY'S COMMENTS

Summary of Audit Results

o  Pace 5. (6. 7J

   The  reference to  Region  7  should  be deleted  as  it  is  a
   typographical error.

OUR EVALUATION Q£ THE AGENCY'S COMMENTS

We  recognized this  typographical  error  after  our  initial
submission of  the draft report.  The  reference should have been
to Region  1 .   This page  was  revised  and  provided to the Agency
on July 1 1 subsequent to the issuance  of  the  draft report .

AGENCY'S COMMENTS

Property

o  Page 16 (19) . Bottom of Page

   Region  1  submitted a  data input form on February 24,  1988,
   correcting  the code and  acquisition  cost  of  the computer,
   inadvertently recorded as $2,097,029,  costing  $2,907.

OUR EVALUATION Qg THE AGENCY'S COMMENTS

   The submission of  the  data input form was prepared  after this
   error  was  brought  to  the  attention of  Region  1   by our
   auditors.   The corrective action  indicated  is responsive  to
   our  recommendation that certification be obtained to  ensure
   that this error was corrected.

AGENCY'S COMMENTS

o  Page V7 (20). Middle flf Page
   Inaccurate amounts recorded in the PPAS have been corrected by
   Cincinnati .
                        111

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                                                      APPENDIX 4
                                                     (CONTINUED)
OUR EVALUATION OJ1 THE AGENCY'S COMMENTS
   The  corrective   action  indicated  is  responsive  to  our
   recommendation that certification be obtained to  ensure that
   these errors in amounts  be  corrected.

AGENCY'S COMMENTS

o  Page H (22).  Table

   Cincinnati recorded the  missing  items in PPAS.

   The RTP  Property  Officer entered the missing purchases into
   PPAS.

   Region 5  located  and recorded  17  of 21 property  items into
   PPAS.  They will  continue  to locate and enter  the remaining
   items.

   Region  6 collected  receiving  reports,  located  the  missing
   items and  entered the data into the  PPAS.   Region  6 stated
   that   they   have  strengthened  administrative  property
   procedures.

   The report identified that  18  items are  not recorded in Region
   7's  PPAS.   Nine  of  the  18  items  are  non-accountable and,
   therefore,  are not  required  to  be  recorded in  PPAS.   At the
   time of  the audit,  the  remaining 9  items were being entered.
   In  fact, the  necessary paperwork had  been completed,  the
   items all accounted for, in use, and  were appropriately marked
   with decals.
   Region 8  was  experiencing computer problems.
   were corrected.
These problems
   National Enforcement Investigations Center (Center), Region 8,
   acknowledged that  a small number of Superfund property items
   were  not  included  in PPAS.    Currently all  the  Center's
   property  is logged  into  PPAS and  steps have been  taken to
   assure its  weekly  input.  Additionally, the Center is working
   on a system to check the property and accounting records.

OUR EVALUATION QF THE AGENCY'S COMMENTS

   The  corrective  actions  indicated,   if implemented,  are
   responsive  to  our recommendation  that certification be
   obtained to ensure that the errors  and  omissions noted in our
   audit were  corrected.
                        112

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                                                      APPENDIX £
                                                     (CONTINUED)

AGENCY'S COMMENTS

o  Page 19 f?2).  Last Paragraph

   Region 1 issued a nemo dated March 18, 1988, to each property
   custodial officer to maintain  accurate and up-to-date personal
   property custody cards for sensitive  items.

   Region 4  initiated  and  developed  new procedures to eliminate
   the problem of missing custody cards  in the  future.

   Region  5 provided  additional training  in  June  1988.    The
   problem of not maintaining personal property custody cards for
   sensitive items was corrected.
OUR EVALUATION
AGENCY'S COMMENTS
   The  corrective  actions  indicated are  responsive  to  our
   recommendations  that  complying  with  Agency  policies  be
   emphasized  and  additional training  be provided  to property
   personnel.

AGENCY'S COMMENTS

o  Paoe gl (2 4J. Second Paragraph

   Region 4 conducted a  physical  inventory  to identify  all
   property within  custodial area 14.  Efforts are underway to
   reconcile the PPAS with the physical inventory.

   Region  5  performs an average  of  three local inventories per
   month.   Complete  physical inventories  are  conducted  on an
   annual basis.

OUR EVALUATION QE THE AGENCY'S COMMENTS

   The  corrective  actions   indicated are responsive to  our
   recommendation that  the  importance  of complying with  Agency
   policies be emphasized.

AGENCY'S COMMENTS

o  Page H (24). Table

   Region  5 stated  that  the  custodial officer  located  all  23
   property items cited by the auditors.

   Region  7 could not  locate one item valued at $300.  They  have
   initiated the process for reporting missing items.
                        113

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                                                     APPENDIX 4.
                                                    (CONTINUED!
OUR EVALUATION OF THE AGENCY'S COMMENTS
   The  corrective  actions  indicated are  responsive  to  our
   recommendation that  certifications be obtained to ensure that
   errors and omissions from the PPAS were corrected.
AGENCY 'S COMMENTS

o  Pace 21  (25). Bottom
                          Pace (Too of Pace)
   Region 1  completed property reconciliation on March 31,  1988.
   The results are being reviewed.

OUR EVALUATION Q£ THE AGENCY'S COMMENTS

   The corrective action indicated, when completed, is responsive
   to our recommendation  that  certifications  be obtained  to
   ensure that errors and omissions from the PPAS were corrected.

AGENCY'S COMMENTS

o  Pacre 22 ( 25 ) .  Bottom of  Pace

   RTP  is  replacing custodial  assumption  letters that  were
   accidentally disposed.

   Region 1  prepared letters  of acceptance of assumption  of
   custodial   responsibilities  effective  with  the  FY  1988
   inventories .

   Region 4 conducted a training  course for  custodial officers.
   The  custodial  officers  are now completing the  Assumption  of
   Custodial Responsibility forms.  Over  90% of  the forms have
   been signed and returned, and  of the remaining 10%, physical
   inventories are being  completed.   Additionally,  custodial
   officers will be given  a  monthly printout  to keep  them
   informed of any changes  in inventories.

OUR EVALUATION fl£ THE AGENCY'S COMMENTS

   The  corrective   actions indicated,  when  completed,  are
   responsive to our recommendations  that the importance  of
   complying  with   Agency policies   be  emphasized  and  that
   additional training for  property personnel be provided.

AGENCY'S COMMENTS

General Support Services Costs

o  Pace 24  (30).  Middle fif  Page

   Comptroller  Policy  Announcement  88-01, states,  "If  the
                        114

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                                                      APPENDIX 4
                                                     (CONTINUEPJ

   difference is more than $1,000,  the offices should process an
   adjusting entry..."    The  support  costs  identified  as
   overallocated in Region 10 was  for $188;  therefore,  it would
   not warrant an adjusting entry.
OUR EVALUATION
AGENCY'S COMMENTS
   We  did  not calculate the  amount  of  the  reported  over-
   allocation of support costs at Region 10.  We concur that,  if
   the amount was only $188,  no  adjustment would be warranted.

AGENCY 'S COMMENTS

O  Pace 25 (31 ). Bottom o^ Page
   Region  4  concurs that  the Superfund allocation  formula  was
   incorrect.    The  FY  1987 Superfund  allocation  has  been
   recomputed and this resulted in $11,900 increase to Superfund
   expenses .

   Region  5  provided the  auditors with documented evidence that
   the $15,059 overcharge  error was corrected.

OUR EVALUATION Q£ THE AGENCY'S COMMENTS
                                            »
   The  recomputation  and  adjustments  at Regions  4  and  5 were
   prepared based upon the  results of our audit.  Consequently,
   the amounts reported for FY 1967 in our  draft  audit report did
   not  include adjustments made subsequent  to  the audit.   Also,
   Region  4 recomputed  their cost allocations to correct  an
   overcharge of $120,232 to  Superfund,  and this resulted in an
   additional $11,900 being charged to Superfund.  This indicates
   that there were $132,132 of costs that had not been previously
   allocated  to  Superfund  in  the  initial   allocation.

   The  corrective  actions are responsive  to  our recommendation
   that certifications be  obtained that the cost  allocations were
   recalculated and adjusted.

AGENCY'S COMMENTS

o  Pace 2Q (32). First Paragraph  ( Second Paragraph)

   Region  1  complied with  the  procedure.    The  allocation
   procedure  in  the Agency's  Financial Management  Manual
   presupposes that there are available  funds  in  Superfund to be
   able to affect  an  allocation.   The ten allocations were made
   on  a monthly  basis.     At that  point, they no  longer had
   available Superfund monies to absorb an additional allocation.
   To make charges which would exceed allowances  is not allowable
   and  could place  the Region in  an  anti-deficiency position if
   the  report recommendation is executed.
                        115

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OUR EVALUATION OJF THE AGENCY'S COMMENTS
                                                      APPENDIX 4
                                                     (CONTINUED)
   We understand  that  Region 1 complied  with  the Agency policy
   regarding Super fund ceilings.   However,  as we indicated in our
   report,  the absence  of  a  complete allocation  of  costs  to
   Superfund  understates  Superfund  costs.    Also,   Regions  may
   request  additional  funding  to  increase  their  Superfund
   ceilings.  At a minimum,  information on the amounts of under-
   allocations to Superfund should be calculated and reported to
   EPA's  Comptroller  for  a determination regarding  Superfund
   ceilings and anti-deficiency positions.

AGENCY'S COMMENTS
Letter
          Credit
o  Page 28 (?7) .  Third Paragraph ( Second Paragraph )

   The auditors have a misunderstanding of Federal grant policy.
   They stated that  if  excess  cash was not held by a  recipient,
   it would be available for other users in the region.

OUR EVALUATION OF THE AGENCY'S COMMENTS

   The sentence was deleted from this report.   We meant to  convey
   that the use of Federal funds results in interest costs  to  the
   Government. Thus, excess cash held by one recipient  could have
   been used by other recipients without the Government incurring
   interest costs for additional funds.

AGENCY'S COMMENTS

o  Pace 28 (37) .  Bottom o.f Page

   Region 1  developed a  reconciliation worksheet  based  on
   Comptroller Policy  Announcement No. 88-06.   This  action  was
   accepted by the auditors during their review and the reference
   should be removed from the report.

   Region 9 explained to the auditors the difference of $581,245.
   To reiterate,  the recipient was previously  on  another  letter
   of  credit and  the $590,244  was reported  on that  letter of
   credit.    In  order for  the  letter  of  credit records to
   reconcile  to  the FMO records, both letters of  credit must be
   reviewed.   The remaining $9,000 was a posting  error that  was
   corrected  in Janaury 1988.

   Region 9  disagrees  that there is a discrepancy of  $1,122,070
   between FMS and the letter of credit file.   Letter  of  credit
   increases  are not always authorized for all amounts awarded on
   the cooperative  agreement.   The agreement  may contain special
   conditions  which restrict the  recipient  from access to  cash
   until  certain  requirements are met.
                         116

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                                                      APPENDIX 4
                                                     ICQNTINUEDT
OUR EVALUATION Qg THE AGENCY'S COMMENTS
   The Agency  response indicated that  corrective actions were
   taken subsequent to fiscal 1987.  Consequently,  these findings
   should  not  be  removed  from  the  report.    Howevex,  we
   acknowledged in  this report  that  Regions  1  and 9  are  now
   performing reconciliations.  Because of the corrective actions
   indicated during our fieldwork, we  made  no recommendations in
   the draft report.   Concerning  the  $581,245  reconciliation
   problem in Region 9,  we have revised our report to include  the
   Region's explanation of the difference.

   According to our audit  workpapers  from  Region 9, the  unpaid
   obligation per the FMO-6  report in  the FMS did  not agree with
   the SF-1193  (Grant  Payment  History).   Whether the  letter of
   credit amounts  are  authorized or not does not eliminate  the
   need for  reconciliation of  the  award amounts and the  unpaid
   obligations plus drawdowns.

AGENCY'S COMMENTS

o  Page 29 (37). Second Paragraph (Last; Paragraph)

   The Assistant Administrator for  Administration and  Resources
   Management asked the Grants Administration Division  (GAD) to
   develop   a  Superfund  Cooperative  Agreement   management
   improvement  plan.    GAD's  initial  effort  involved  reviewing
   each  Region's  management  of its cooperative  agreements.
   Between  August  and December  1987,  GAD and  program staff
   visited every regional office.    During those visits, they  met
   with senior regional officials,  including  program,  finance,
   and  grant  staffs  to determine  how  each Region manages
   cooperative  agreements,  how  the  program, finance,  and  grant
   staffs  interact,  and  what regional cooperative agreement
   management activities need  improvement.

   One finding of the reviews  concerned  problems with recipients
   filing Federal  Cash Transactions  Reports  (SF-272)  promptly.
   In  response GAD recommended  that  each  Regional  Assistance
   Administration  Unit (AAU) develop  a system  to track when
   required reports,  including  the  Federal Cash Transactions
   Reports  (FCTRs), are due   (or  overdue).   The  systems  will
   provide  guidelines  for  appropriate action when recipients
   either fail to submit reports  or  submit reports of substandard
   quality.

OUR EVALUATION Q£ THE AGENCY'S COMMENTS

   The  corrective  action  indicated  is   responsive  to  our
   recommendation  that  the Agency issue  additional  guidance  for
   follow-up  actions  on   cooperative   agreement   recipient
   noncompliance.   We believe  that  such guidance should require
                        117

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                                                      APPENDIX ±
                                                     (CONTINUED!

   the Agency to  document any  actions taken  when recipients
   either fail to submit reports  or  submit substandard reports.

AGENCY'S COMMENTS

Accounts Receivable

o  Page 3J. (41).  Third Paragraph  {Second  Paragraph)

   To say  that the FMO did not  know  whether  interest  should be
   assessed to states is misleading.   The  Region  had requested
   clarification  from FMD  on  the propriety  of charging interest
   [on] receivables due under [the]  Intergovernmental Personnel
   Act.   Pending  a response, the  Region  is  now  including an
   interest   clause  on all  Intergovernmental Personnel  Act
   billings.
OUR EVALUATION OF
AGENCY'S COMMENTS
   We noted  in our draft  report that the  Region had requested
   clarification  regarding  the propriety of  charging interest.
   We have changed the wording of our report finding to indicate
   that the Region did not charge interest during  fiscal 1987.

AGENCY'S COMMENTS

o  Page 31 (41). Bottom 
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                                                      APPENDIX 4.
                                                     (CONTINUEPJ

AGENCY'$ COMMENTS

Obligations and Disbursements

o  Paoe H (43. 44).  Table.  Attributes

   Currently, Region 6 enters  obligations into the system within
   24 to 48 hours.

   Region 6 requires all documents  be reviewed for date stamps as
   a part of the data entry process.

OUR EVALUATION fi£ THE AGENCY'S COMMENTS

   The corrective action indicated by Region  6  is responsive to
   our recommendation that  FMOs follow Agency policies for timely
   recording of obligations in the  FMS.

AGENCY'S COMMENTS

o  Pace 37 (53). Second Paragraph

   All  missing payroll  items  were   accounted  for  at  the
   Headquarters exit conference.

OUR EVALUATION QF. THE AGENCY'S COMMENTS

   The  results of our attribute  testing  on payroll  items was
   provided  to  Headquarters  Accounting  Operations  Branch
   officials  at  the  Headquarters   exit  conference.     No
   documentation for missing  items was  provided to us  at that
   time.

AGENCY'S COMMENTS

o  Page 38 (54). Reason (ej

   A listing of employees'  supervisors  is not maintained by the
   payroll system, but by the designated agents.


OUR EVALUATION Q£ THE AGENCY'S COMMENTS

   We requested  these lists during our  audit fieldwork and were
   not informed that the designated agents maintained such  lists.

AGENCY'S COMMENTS

o  Page 4JL  (56).  Exhibit.  "Other Contractual Services" and
   Appendix  2. Page £  (80)

   Research  Triangle Park  (RTP) has the following comments:
                        119

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                                                       APPENDIX ,|
                                                      iCONTINUED)
    Based  on  projection  of  errors,  the auditors  set aside
    $23,215,042 of which $18,705,204 represent contract payments.
    The auditors stated the  cause for set-aside cost was primarily
    due   to  missing   documentation  and   lack   of  written
    justification.    However,  the referenced  appendix shows  the
    highest occurrence  of error was in attributes I, J and K which
    relate either to timeliness or commitment verification.

    Attribute J:   Timely Posting fcg FMg bjc FMQ

    We recognize  that  internal  procedural problems  existed  to
    preclude timely  obligations of contracts in all cases.  These
    problems related to:   (1)  mail distribution of  contracts,  (2)
    returning documents to contracting officials for  correction,
    and (3)  waiting for valid  accounting  information.   In  all
    three  situations,  we  have taken  steps to  correct  problems
    creating delays  in  recording contract obligations.

OUR EVALUATION QF THE  AGENCY'S COMMENTS

    We  set-aside  $23,215,042 of obligations  because  of the lack of
    written  Superfund  justification.   As  understood by   our
    auditors  and   Agency   officials   at   RTF,   this  written
    justification  is required  to  be  maintained  by  the program
    office  which  originated  the purchase  request/orders resulting
    in  the obligations.  Therefore,  although  we  set-aside these
    contract  obligations that  were processed by  RTP,  the lack  of
    documentation was  at the program  office  level, where we
    attempted  to  obtain the  written  justifications.  Also, while
    we  noted  a  high  occurrence of  error  for  certain  other
    attributes, these were not the  basis  for set-aside  costs.

    The corrective action  indicated  by RTP is  responsive to our
    recommendation  that the  need  for FMOs  to  follow  Agency
    policies  for  timely recording of  obligations  in  the  FMS be
    emphasized.

AGENCY'S COMMENTS

o  Appendix 2. Page  9. (85)

   RTP provides the following comment  on a contract disbursement
   attribute exceeding  a 5%  error rate:

   ATTRIBUTE M - Invoice was paid on time,  but not earlv.

   Based on the information  in the auditors' work papers, the 210
   exceptions noted for  this attribute  are  characterized as
   follows:
                        120


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•r
                       Number of days
                      required Jfcfi oav

                           <25
                         31-37
                         38-45
                           >45
                                         TOTAL
              APPENDIX 1
             (CONTINUED?

Number of exceptions
    by category

         11
        133
         35
        -21
        210
              Of the  210 exceptions,  175  fell  within the 23-45  day grace
              period of the Prompt Payment Act.

              Of the  31  late  payments,  25 were  for contracts  which are not
              subject  to the  Prompt  Payment Act.    Of  the  remaining six
              payments, two were actually  made  within the  allowable 45 day
              limit and the 4 payments made in excess  of 45 days and subject
              to the Prompt Payment Act represent  .92% of the  total sample.
           OUR EVALUATION QE THE AGENCY 'S COMMENTS

              Our  audit procedures were  designed  to measure  the Agency's
              compliance with its own policies and  procedures, which were to
              pay between 25-30 days from receipt of  an  invoice.  We did not
              analyze  the  exceptions beyond the  stated  criteria.  The
              indicated error rate was substantially  above  5% for compliance
              with Agency policy.


           The  following Agency  comment  was  included  in  Attachment  I  of
           Appendix  3 and is addressed  here  as a specific  comment  to our
           draft report.

           AGENCY 'S COMMENTS

           o  Exhibit I

              One  of the items  set-aside  by the  auditors  for lack  of
              documentation, was an obligation for $1 million.  The auditors
              stated  that the transaction was not supported by a procurement
              document  in the finance office  records.   The finance office
              staff,  however,  provided  the  auditors with the procurement
              document  located  in  the official  contract file  of the
              procurement office.

              This example  addresses our points very clearly:   (1)  an
              obligation  of  that magnitude could  not be  processed through
              the   financial   system  without   several   administrative
              checkpoints,  (2)  the  auditor  did not ask  questions  of any
              staff  member prior  to  classifying  the transaction as  "set-
              aside" and,   in   fact,  (3)  the supporting documentation
              provided,  reflected the highest level  of  signature authority
              (office director).
                                   121

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                                                      APPENDIX 4
                                                      CONTINUED}
OUR EVALUATION fig "THE AGENCY'S COMMENTS
The item identified by the Agency as a $1 million obligation was
set aside  because the written Justification  on the procurement
request indicated that the contract was  for  Superfund and another
EPA  program.    There  was no  allocation or  indication of the
percentage funded by  Superfund  and,  only  after additional
inquiry, were we able to determine  that  the  non-Superfund portion
was obligated in a separate transaction.
                         122

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