UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, O.C. 204(0 DEC 12)968 OFFICE OF THE INSPECTOR GENERAL MEMORANDUM SUBJECT: Audit Report No. M5BFL9-11-0020-9100096 Audit of EPA' s Interagency Agreements with the Department of Justice for Superfund Activities Fiscal 1987 FROM: TO: Kenneth D. Hockznan Divisional Inspector General for Audit Internal Audit Division (A-109) Harvey G. Pippen, Director Grants Administration Division (PM-216) We requested the Audit Staff, Justice Management Division, Department of Justice (DOJ) to perform a financial and compliance audit of two Superfund Interagency Agreements (IAA) entered into between EPA and the DOJ, Land and Natural Resources Division (LNRD). The DOJ report of September 1988 is attached. The report addresses obligations and expenditures during fiscal 1987. The audit disclosed a need for improvements in the preparation of expense reports, internal controls, and the methodology used to compute employee costs. Specific problem areas are addressed below. Superfund cost information was not reported to EPA in a manner consistent with the budgetary classifications provided in the lAAs, or the object classes used by the DOJ to account for LNRD costs. Furthermore, amounts reported on expense reports could not be readily traced to accounting records. As a result, the financial reports did not provide sufficient cost data to assure that the costs incurred were within cost category limitations of the lAAs. The LNRD system of internal accounting controls needs strengthening to improve the quality and accuracy of financial representations in reports and records. As a result of weak- nesses in LNRD's system of internal accounting controls, management was not provided with reasonable assurance that transactions were executed in accordance with management's authorization and were recorded properly. in WASHINGTON. O.C. 20460 ------- Hourly employee rates used to allocate employee costs between the various direct and indirect cost centers were not in compliance with the terms and conditions of the lAAs. As a result, direct employee costs distributed to individual cost centers may not have represented actual LNRD costs. DOJ, LNRD has taken corrective action by informing managers and staff that controls must be strengthened to ensure: (1) expense reports reconcile with accounting cost data and the format for expense reporting is improved; (2) plans are developed to improve internal controls on its timekeeping system and cost records manage* ment procedures; and (3) hourly employee rate corrective measures are instituted to ensure compliance with the requirements of the lAAs. EPA can take action by following up on the DOJ, LNRD's corrective actions and obtaining corrected expense reports and cost data for the two lAAs from the LNRD. Accordingly, we are making the following recommendations. RECOMMENDATIONS We recommend that the Director, Grants Administration Division: 1. Request a status report on the corrective measures instituted by the DOJ, LNRD, to ensure that costs reported to EPA are (1) readily reconcilable with amounts recorded in LNRD's accounting records, (2) and in a manner consistent with the budgetary limitations of the lAAs. 2. Obtain assurance from DOJ, LNRD, that hourly employee rates used to allocate employee costs between the various direct and indirect cost centers are in com- pliance with the terms and conditions of the lAAs. 3. Obtain for accounting control and accuracy purposes, corrected expense reports and cost data for the two audited lAAs. ACTION REQUIRED In accordance with EPA Directive 2750, the action official is required to provide this office with a copy of the proposed determination on the findings within 150 days of the audit report date. The Director, Grants Administration Division is the action official for this report. Should your staff have any questions concerning this report, please have them contact John Walsh on 475-6753. Attachment ------- APPENDIX DISTRIBUTION OF REPORT Assistant Administrator for Solid Waste and Emergency Response (WH-562) Comptroller (PM-225) Chief, Financial and Administrative Management Section, Office of Emergency and Remedial Response (WH-548D) Director, Financial Management Division {PM-226) Chief, Grants Information and Analysis Branch (PM-216F) Agency Followup Official (PM-208) Agency Followup Official {PM-225) Attn: Resource Management Division Agency Followup Coordinator (PM-208) Attn: Program Operations Support Staff ------- U.S. DEPARTMENT OF 1USTICE Audit Report AUDIT REPORT Oil THE ENVIRONMENTAL PROTECTION AGENCY'S EJTERAGENCY AGREEMENTS WITH THE DEPARTMENT OF JUSTICE FOR suPERFUiro AcrrvmES FISCAL YEAR 193? «*«*»*«***»tt*«»**«t*ft***««*«****«»*«**ft******* SEPTEMBER 1988 88-23 Prepared by Audit Staff Justice Management Division ------- AUDIT REPORT ON THE ENVIRONMENTAL PROTECTION AGENCY'S INTERAGENCY AGREEMENTS WITH THE DEPARTMENT OF JUSTICE FOR SUPERPUND ACTIVITIES FISCAL YEAR 1987 EXECUTIVE DIGEST The Audit Staff, Justice Management Division (JMD), performed a financial and compliance audit of the Environmental Protection Agency's (EPA) Interagency Agreements (IAA) with the Department of Justice (DOJ) Land and Natural Resources Division (LNRD) under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA or Superfund), and the Superfund Amendments and Reauthorization Act of 1986 (SARA). The purposes of our audit were to determine: (1) the accuracy and reliability of Superfund cost reports submitted by the LNRD to the EPA, (2) the adequacy of internal controls in LNRD's system of accounting for Superfund costs, and (3) LNRD compliance with the terms and conditions of the lAAs and applicable Federal regulations. The audit covered the period October 1, 1986 through September 30, 1987 and two lAAs, as amended, as follows: Jjumber DW 15932400-01-0 DW 15932401-01-0 DW 15932401-01-1* Period of Agreement 10/01/86 - 09/30/87 10/01/86 - 09/30/87 10/01/86 - 09/30/87 Total Amount $ 1,000,000 4,481,300 6.068.700 S11.55Q.OQQ *Amends agreement no. DW 15932401-01-0 The audit disclosed a need for improvements in the preparation of expense reports, internal controls, and the methodology used to compute employee costs. The weaknesses associated with the audit recommended improvements are summarized as follows: Expense Reports - Pace 4 Superfund cost information was not reported to EPA in a manner consistent with the budgetary classifications provided in the lAAs, or the object classes used by the DOJ to account for LNRD costs. Furthermore, the expense reports did not apply cost information from the Expenditure and Allotment Reports uniformly. As a result, the financial reports did not provide sufficient cost data to assure that the costs incurred were within cost category limitations of the lAAs. ------- Internal Controls - Page 9 The LNRD system of internal accounting controls needs strengthening to improve the quality and accuracy of financial representations in reports and records. As a result of weaknesses in LNRD's system of internal accounting controls, management was not provided with reasonable assurance that transactions were executed in accordance with management's authorization and were recorded properly. Computation of Employee Costs - Page 12 Hourly employee rates used to allocate employee costs between the various direct and indirect cost centers were not in compliance with the terms and conditions of the lAAs. As a result, direct employee costs distributed to individual cost centers may not have represented actual LNRD costs. - ii - ------- TABLE OF CONTENTS INTRODUCTION Audit Objectives , Audit Scope , Summary of Audit Results , Background , FINDINGS AND RECOMMENDATIONS , I. EXPENSE REPORTS , Recommendations , II. INTERNAL CONTROLS , Recommendations , III. COMPUTATION OF EMPLOYEE COSTS , Recommendation STATEMENT ON INTERNAL ACCOUNTING CONTROLS STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS . . OTHER REPORTABLE MATTERS , APPENDIX I - LNRD RESPONSE APPENDIX II - SUMMARY OF RECOMMENDATIONS AND ACTIONS, Pagg 1 1 1 2 2 4 4 8 9 11 12 13 14 15 16 17 29 ------- AUDIT REPORT ON THE ENVIRONMENTAL PROTECTION AGENCY'S INTERAGENCY AGREEMENTS WITH THE DEPARTMENT OF JUSTICE FOR SUPERFUND ACTIVITIES FISCAL YEAR 1987 INTRODUCTION The Audit Staff, Justice Management Division (JMD), has completed a financial and compliance audit of the Environmental Protection Agency's (EPA) Interagency Agreements (IAA) with the Department of Justice (DOJ), Land and Natural Resources Division (LNRD) under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA or Superfund), and the Superfund Amendments and Reauthorization Act of 1986 (SARA). Audit Objectives The purposes of the audit were to determine: (1) the accuracy and reliability of Superfund cost reports submitted by the LNRD to the EPA, (2) the adequacy of internal controls in LNRD's system of accounting for Superfund costs, and (3) LNRD compliance with the terms and conditions of the lAAs and applicable Federal regulations. Audit Scope Beginning with fiscal year 1987, the LNRD instituted a system of accounting for all LNRD costs by cost center. In this regard, the LNRD contracted with the Certified Public Accounting firm of Rubino & McGeehin, Chartered, (CPA firm) to develop expense reports which summarized direct and indirect LNRD costs for each Superfund case litigated by the LNRD. For the purposes of the lAAs, LNRD identified costs as belonging to one of three major groups: (1) direct Superfund costs, (2) direct costs other than Superfund, and (3) indirect costs. Direct costs were further broken down between direct labor costs and all other direct costs. Indirect costs were calculated as a percentage of total direct labor costs. In accordance with LNRD's decisions, the CPA firm used the proportion of direct Superfund labor to total direct labor to allocate indirect costs to each. EPA approved the costing methodology used by the LNRD in IAA No. DW 15932400-01-0. As part of our examination, we evaluated attorney time reports entered into the Attorney Time System (ATS), the resultant reports from the ATS, the LNRD employee salary rates as calcu- lated by the CPA firm, the identification and recording of direct costs, and the indirect costing methodology. We selected direct - 1 - ------- costs on a random basis to determine: (1) the accuracy and relationship of accounting entries vis-a-vis source documenta- tion, (2) the allocability of direct Superfund charges, and (3) the allowability of costs based on Federal regulations. We reviewed all quarterly expense reports submitted to EPA for fiscal year 1987. This provided the basis for the audit opinion statements and recommendations covered by this report. Our examination was conducted in accordance with generally accepted government auditing standards and included such tests of the accounting and management records as were considered neces- sary in the circumstances. The audit covered the financial activities for the period October 1, 1986 through September 30, 1987 for the following lAAs: Number DW 15932400-01-0 DW 15932401-01-0 DW 15932401-01-1* Period of Agreement 10/01/86 - 09/30/87 10/01/86 - 09/30/87 10/01/86 - 09/30/87 Total Amount $ 1,000,000 4,481,300 6.068.700 S11.550.0QQ *Amends agreement no. DW 15932401-01-0 Summary of Audit Results Costs reported to the EPA were not readily reconcilable with amounts recorded in LNRD's accounting records due to differences in the methodology of expense classification and were not reported in a manner consistent with the budgetary limitations of the XAAs. In addition, we found weaknesses in internal controls which could result in a higher risk that material errors could occur and not be detected in a timely manner. Furthermore, hourly employee rates used to allocate employee costs between the various direct and indirect cost centers were not in compliance with the terms and conditions of the lAAs. Background On December 11, 1980, CERCLA was signed into law. It provided for liability, compensation, cleanup, and emergency response for hazardous substances released into the environment and uncontrolled and abandoned hazardous waste sites. This legislation was subsequently amended by SARA. Implementing procedures were contained in the National Contingency Plan set forth in Executive Order (EO) 12316 of August 14, 1981. This EO provided that the Attorney General was responsible for the conduct and control of all litigation arising under Superfund. To fund these activities, EO 12316 required the Administrator, EPA, to transfer appropriation accounts to other agencies from the Hazardous Substance Response Trust Fund. - 2 - ------- For fiscal year 1987, the Office of Waste Program Enforcement (OWPE), EPA, issued two lAAs, as amended, to LNRO for conducting litigation and other activities related to EPA Superfund as authorized by CERCLA, SARA and EO 12316. The lAAs authorized the DOJ to be reimbursed for LNRD's costs based on its professional employees' level of effort. Accounting for LNRD costs and preparation of expense reports was provided by the CPA firm of Rubino & McGeehin, Chartered. The CPA firm designed a system for distributing costs to the major groupings discussed in the Audit Scope paragraph of this report. This system was predicated on the identification and allocation of direct costs to specific cases, which were subsequently designated as either "Superfund" or "Other." Both direct labor and other direct costs were then subtracted from total LNRD costs, and the balance was allocated in proportion to direct labor costs. This method of deriving actual and allocable costs was generally consistent with the costing methodology stipulated by the EPA under applicable provisions of the lAAs. Site referrals were the primary means by which EPA authorized other Federal organizations to incur reimbursable costs. Accordingly, reconciliation of cost data with site referral information is critical for determining the allocability of incurred costs. In fiscal year 1987 the LNRD provided cost information on 773 Superfund related cases. However, since the cost information on the 773 cases could not be confirmed with EPA site referral information, our audit is qualified to the extent that the cases contained in the expense reports may not represent all Superfund related cases being litigated by the LNRO. Notwithstanding this qualification, LNRD provided EPA cost information on a case by case basis; thus, discrepancies between case referrals and LNRD cost claims should have been readily identifiable by EPA officials. - 3 - ------- FINDINGS AND RECOMMENDATIONS EXPENSE REPORTS Superfund cost information was not reported to EPA in a manner consistent with the budgetary classifications provided in the XAAs, or the object classes used by the DOJ to account for LNRD costs. Also, the expense reports did not apply cost information from the Expenditure and Allotment (E&A) Reports uniformly. This occurred because the system used to accumulate and distribute Superfund case cost information compressed all direct costs into one of two categories: (1) Direct Labor, and (2) Other Direct. The lAAs between LNRD and EPA required that cost reports reflect costs by object class and budget line item for each agreement. Furthermore, organization- wide cost information used in the preparation of expense reports should have been obtained from the final E&A report, and not preliminary reports thereo'f. As a result, the financial reports did not provide sufficient cost data to assure that costs incurred were within the individual cost category budget limitations of the lAAs. Identification of Costs bv Expense Categories The governing lAAs required the LNRD to report expenses both by IAA and object class, our review of the two lAAs, as amended, disclosed that cost estimates were established by budget category, and no provision had been made for indirect costs. By special condition to DW 15932400-01-0, however, direct costs allocable to the EPA were to be determined by the proportion of direct labor expended on Superfund related activities. Accordingly, to comply with these agreements LNRD should have accounted for all direct costs by budget line item, then allocate costs on a line by line item basis, not by indirect cost pool. The LNRD, however, established procedures to account for all direct labor, expert witness, automated litigation support, transcript, and travel costs. All other costs were included in an indirect cost pool. The governing lAAs required the reporting of expenses by ten separate object classes, as appropriate to the individual IAA. The expense report for fiscal year 1987, on the other hand, was comprised of direct labor, other direct costs, indirect costs, and unpaid obligations. As a result, the following differences were noted between the reporting categories required by the lAAs and the LNRD fourth quarter expense report. - 4 - ------- Budgeted Costs Per lAAs Amount IAA Exense (a) Personnel (b) Fringe Benefits (c) Travel (d) Equipment (e) Supplies (f ) Pl'm .i tt qfl itfj tt Assistance (g) oaa»ttucticn (h) Other (i) Total Direct (j) Indirect Costs DW15932400-01 CW159324Q1-O1 $ 0 $ 4,952,000 0 0 0 0 1,000,000 0 0 0 681,000 709,000 45,000 65,000 3,067,000 0 1,031,000 0 Ccnbjjied $ 4,952,000 681,000 709,000 45,000 65,000 4,067,000 0 1,031,000 0 S 1.000.000 610.S50.QQQ (k) Total I/ As amended Reimbursable Superfund Costs Per Expense Reports Category Direct Labor 9/ Other Direct Costs ** Indirect Costs Subtotal Unpaid Obligations Total Superfund Allocation of fiscal year 1987 LNRD obliga- tions Amount $ 2,517,609 2,325,929 6.306.723 $11,150,261 1.160.850 gl3.311.lll a/ 2J Includes Expert Witness Costs, Automated Litigation Support Costs, Transcripts, and Travel. 3_/ From case cost summary. Per page 1 of 2 of the September 30, Expense Report. 1987 Although the EPA has reimbursed LNRD without requiring additional IAA or object class identification, the reporting format used by LNRD was not responsive to the requirements of the lAAs. Reporting of LNRD Costs Amounts could not be readily traced from the accounting records constructed by the CPA firm to the expense reports sent to EPA. This occurred because costs were not reported - 5 - ------- by the sane cost categories used in the DOJ accounting records. In addition, contrary to the design for reporting, the expense reports did not reflect all non- Superfund costs. Because the expense reports used LNRD's total expenses and obligations for allocating costs, all direct costs should have been identified in order to support indirect cost pool determinations. Since the expense report did not reflect all direct expenses, there existed an unreconciled difference of $6,180,480 in costs between the accounting records and the report. These differences are summarized as follows: As of September 30. 1987 Expense I. Direct labor Superfund Other Cases Total Part I II. Other Direct Superfund other Cases Adjustments Total Part H III. Section 1595 *f. Section 1596 *f. Section 1598 ** Total Part HI IV. indirect labor fringe Benefits Indirect Travel Freight Space, Lights, Utilities Printing Training Supplies Non-capital Equipment Other Total Part IV Total Accounting $ 2,517,546 7.257.038 S 9.774.584 $ 1,045,439 1,047,977 10.451 $ 3,230,232 476,454 2.695.856 S 6.402.542 $ 8,954,626 2,406,682 59,299 319,572 3,397,903 260,076 1,309,293 367,042 304,007 286 S17.378.786 $ 2,517,546 7.257.038 S 9.774.584 $ 2,325,929 0 Q S 2.103.867 6 2.325.929 0 0 0 $ 8,954,626 2,406,682 59,299 319,572 3,397,903 260,076 1,309,293 367,042 304,293 Q S17.378.786 $2 Difference 0 0 $ (1,280,490) 1,047,977 10.451 S (222.0621 $ 3,230,232 476,454 2.695.856 S 6.402.542 $ 0 0 0 0 0 0 0 0 (286) 286 $ Q fi 6.180.480 This amount, used in the computation of the proportion of Superfund direct labor to INRD direct labor, does not agree with the amount reported in the case cost summary. - 6 - ------- Section 1595 relates to reimbursable amounts from agencies other than EPA. Section 1596 relates to non-Superfund litigation support and office automation. I/ Section 1598 relates to charges which are Superfund specific. As a result, the report did not provide either a complete summary of all costs incurred by the LNRD or a systematic means of determining the allocability of those costs charged to the EPA as Superfund related. Use of Expenditure and Allotment Cost Information Amounts of unliquidated obligations presented in the expense report were not extracted consistently from LNRD's E&A Report. Two E&A Reports, one printed October 8, 1987 and the other on October 23, 1987, were used to compute "Net Unliquidated Obligations," as depicted below: "EPA Billing Pace 2 of 2 IKRD Fiscal Year 1987 unliquidated obligations at September 30, 1987 Less - unliquidated obligations: Section 1595 Section 1596 Section 1598 Net unliquidated obligations - IKRD (a) Superfund percentage -^ (b) Superfund portion of unliquidated obligations (a) x (b) Add * Section 1598 unliquidated obligations Total Super fund unliquidated obligations Adjustment for Superfund portion of payments on prior fiscal years' unliquidated obligations Total Superfund unliquidated obligations less: Amounts previously billed Met Superfund unliquidated obligations - fourth quarter Per Expense Report Corrected Per 10/23/87 Recort $ 5,952,590 (2,468,685) ( 375,848) fl.322.2281 2/ I/ I/ $ 5,952,590 (2,481,131) ( 659,161) fl.323.4711 2/ 2/ S 1.785.829 6 1.488.827 $ 459,959 1.322.228 1,782,187 (621.3371 1,160,850 (1.900.9611 $ 383,462 1.323.471 1,706,933 (621.3371 1,085,596 fl.900.9611 S r740.1111 S (815.3651 I/ FY 1987 E&A Report printed 10/08/87 2/ FY 1987 E&A Report printed 10/23/87 Difference $ 0 12,446 283,313 1.243 S297.0Q2 $ 76,497 fl.2431 75,254 S 75.554 - 7 - ------- I/ Superfund 's percentage of unliquidated obligations was calculated by dividing year to date Superfund direct labor as of September 30, 1987 by the total direct labor for the period ($2,517,608 / $9,744,584 - 25.7561). Because the expense report was not prepared from the most recent E&A Report, both "Net Superfund unliquidated obligations - fourth quarter" shown above and the $12,311,111 reported for "Total Superfund Allocation of fiscal year 1987 LNRD Obligations" (See page 5 of this Report) were overstated by $75,254. The Audit Staff recommends that the LNRD: 1. Revise the system used to accumulate Superfund costs to permit the reporting of costs in a manner consistent with the budgetary categories of the lAAs. 2. Prepare an amended final report using E&A Report information that identifies costs in a manner consistent with the accounting records, and include sufficient information to permit the reconciliation of all costs claimed to LNRO's E&A Reports. - 8 - ------- II. INTERNAL The LNRD system of internal accounting controls needs strengthening to improve the quality and accuracy of financial representations in reports and records. The system weaknesses vere: (1) the attorney time reporting system lacking effective quality and supervisory controls, (2) direct costs being allocated among Superfund cases on a computed rather than actual basis, and (3) adjusting entries not providing adequate referencing to locate source documentation. Accordingly, the LNRD's system of internal accounting controls did not provide management with reasonable assurance that transactions vere executed in accordance with management's authorization and were recorded properly. The Budget and Accounting Procedures Act of 1950 established the principles and standards governing the - accounting of governmental activities. The standards vere promulgated by the General Accounting Office's Policies and Procedures Manual for Guidance of Federal Agencies, and set forth guidance pertaining to technical compliance elements and the usefulness of financial data. The Office of Management and Budget circular No. A-123 further defines the responsibilities of administering agencies to include the development and use of systems of internal control. The policies and standards set forth under this circular make it incumbent upon individual organizations within an executive agency to ensure that: (1) all transactions and other significant events are documented and readily available for examination, and (2) transactions and significant events are accurately recorded. In addition, Generally Accepted Accounting Principles require the accurate and complete reporting of financial information. Attorney Time Reports Allocation of direct labor costs vas based upon attorney time reports vhich identify hours worked by specific case. Time reports were adjusted for mathematical and case number errors, if any, by LNRD system analysts then entered into the Attorney Time System by contract data entry personnel. Attorney case hours were subsequently entered into the cost accounting system for computation of direct and indirect labor costs. LNRD supervisory personnel did not approve individual attorney time reports, and attorneys charged with the overall responsibility for cases did not verify case hours reported on the attorney time reports. Also, time report corrections made by systems analysts were not returned to - 9 - ------- and approved by responsible case attorneys before their input into the data base. These weaknesses precluded LNRD from having the necessary assurance that case hours represented in attorney time reports were an accurate reflection of the attorneys1 work. Allocation of Direct Costs Direct costs other than personnel were not allocated on a basis consistent with actual effort or actual cost. For example, one-third of the dollar amount of Batch Number 2170IX - Voucher Number 017, or $333.17, was incorrectly allocated to case 90-11-2-156. This occurred because the total voucher amount was allocated evenly among the three cases initially authorized on the travel request without regard to the fact that travel in relation to case 90-11-2- 156 had been subsequently cancelled. Allocation of direct costs by this method did not provide LNRD with accurate Superfund case specific costs although total Superfund direct costs may have been stated fairly. Adjusting Entries Adjusting entries for direct costs other than personnel did not provide adequate referencing to source documents. For example, in our sample of 105 adjusting vouchers, five could not be traced to source documents due to inadequate referencing. These are identified as follows: Batch Kefr 1031 1065 1121 1128 3099 42301V 52601V 6290LR 62901R 91806H Voucher Number 005 001 on 022 051 Total Amount $ (27.90) (3,796.88) (1,667.25) 71,324.29 f763.991 S65.068.27 Travel Expert witness ADP services Automated litigation Court reporter/tran- script Each of the above vouchers was an adjusting voucher used to reclassify expenses between object classes. Because of inadequate referencing, we were unable to examine the original voucher or the original obligation document to determine the allowability or allocability of these charges. - 10 - ------- Recommendations The Audit Staff recommends that LNRD: 3. 4. 5. Develop and implement procedures for the strengthening of supervisory controls to include: (a) approval of attorney time reports by supervisory personnel, (b) requiring attorneys with overall responsibility for Superfund cases to verify case hours represented on attorney time reports, and (c) returning time reports corrected by LNRD systems analysts for approval by case attorneys. Adopt procedures for allocating direct costs other than personnel on a basis consistent with actual effort or actual costs. Provide assurance that adjusting entries are adequately referenced and supported with documentation evidencing authorization and approval. - 11 - ------- III. COMPUTATION OF EMPLOYEE COSTS Hourly employee rates used to allocate employee costs between the various direct and indirect cost centers vere not in compliance with the terms and conditions of the lAAs. This was because: (1) costs for attorneys vere based on rates of pay, and not actual earnings; and (2) hours worked were adjusted to reflect a minimum average of 8 hours for each work day during a given month. The costing methodology set forth in the governing lAAs required that actual costs be used as the basis for reimbursement. As a result, direct employee costs distributed to individual cost centers may not have represented actual LNRD costs. The EPA approved costing methodology for determining reimbursable costs required that the LNRD use the level of effort expended by its professional employees, as deter- mined by comparing Superfund case hours to total case hours, to allocate all LNRD costs. To implement, a costing methodology which would comply with the lAAs while provid- ing the most accurate accounting of direct costs possible, the LNRD decided to weight the hours worked by professional employees by their respective levels of remuneration. This was accomplished by applying an employee's rate of pay to the hours worked in a given month. This procedure may result in incorrect rate computations whenever changes occur in employee salary rates, or where employees are on work schedules which do not result in an average of 8 hours worked for each workday in a given month. In either circumstance, the use of employee pay rates and not actual remuneration may result in incorrect cost allocations. In computing rates for the month of December 1986, for example, the LNRD appeared to have used January 1987 salary rates which included a 3 percent cost of living adjustment not applicable to the December period. Compounding this problem, the LNRD engaged in a practice of adjusting employee time reports to reflect hours normally charged for a month. For instance, the hours worked in June by employee number 302 appear to have been increased from 114 hours to the 176 hours normally charged by an employee for that month. The addition of indirect work hours to compensate for unreported time had the dual effect of lowering the employee rates used to determine direct time charges while increasing costs retained as indirect costs. Because the quarterly expense reports used actual LNRD costs reported on the E&A Reports as a basis for determining total costs, and derived indirect costs by deducting direct costs from total LNRD costs, variances in direct charges were offset by corresponding changes in the - 12 - ------- indirect cost pool. Since both direct Superfund and direct non-Superfund costs were treated in a like manner, this practice should have had no material effect on the total costs reported to the EPA. This practice, however, may have had some effect on the allocation of costs among the individual cases. Although rates determined by use of employee earnings varied only marginally from those rates developed by LNRD from employee salary rates, our test of 93 computations disclosed variances in 49. In each instance the variance appeared to have been due to either the rate or hours adjustment issues disclosed herein. Since the governing ZAAs required the LNRD to use actual costs, actual employee earnings and actual hours should be used to allocate employee costs. Recommendation The Audit Staff recommends that LNRD: 6. Ensure that actual employee earnings and hours are used for computing distributable direct labor costs. - 13 - ------- STATEMENT ON INTERNAL ACCOUNTING CONTROLS He have reviewed the system of internal accounting controls as required by the Standards for Audit of Governmental Organiza- tions. Programs. Activities and Functions, issued by the Comptroller General of the United States. Accounting control comprises the procedures and records that are concerned with the safeguarding of assets and the reliability of financial records. LKRD is responsible for establishing and maintaining a system of internal controls. The objectives of a system of internal controls are to provide the management of LKRD with reasonable, but not absolute, assurance that assets are safeguarded against loss, unauthorized use or disposition, and that transactions are executed in accordance with management's authorization and are recorded properly. Because of inherent limitations in any system of internal controls, errors and irregularities may nevertheless occur and not be detected. Also, projection of any evaluation of the system to future periods is subject to the risk that proce- dures may become inadequate because of changes in conditions or that the degree of compliance with the procedures may deterio- rate. Our study and evaluation, made for the limited purpose described previously, would not necessarily disclose all material weak- nesses in the system. Accordingly, we do not express an opinion on LNRD's system of internal controls taken as a whole. However, our study and evaluation disclosed conditions that could result in a higher risk that material errors or irregularities may occur and not be detected within a timely period. These conditions are discussed in the Findings and Recommendations section of this report. - 14 - ------- In our opinion, the LNRD complied with the applicable laws and regulations for the transactions tested which could have a material effect on the cost of litigative services provided to the EPA. For those transactions not tested, nothing came to our attention during the examination that caused us to believe that the LNRD was not in compliance with applicable laws and regulations. - 15 - ------- OTHER REPQRTAPLE MATTERS 1. Cost centers have been established for the accumulation of LNRD costs which are related to the provision of legal services to the EPA, but which are not related to ongoing Superfund litigation. As these costs are not treated as overhead expenses, they may not be recovered by the EPA through subsequent litigation. 2. Beginning with the fiscal year ended September 30, 1987, the indirect rate calculation included all indirect costs paid (liquidated obligations) during the current fiscal year in lieu of obligations to calculate the indirect cost rate. Payments were used instead of obligations because the CPA firm determined that payments of obligated amounts were often made significantly later than when obligated. As a result, when calculating the indirect cost rate for the current fiscal year, the payments made on the prior year's obligations were included as part of the indirect cost pool for the current year. For fiscal years ending September 30, 1986 and prior, LNRD used all obligated amounts, whether paid or unliquidated, to calculate the cost associated with work performed by the LNRD for the EPA. For 1987 and subsequent years, LNRD needs to credit the Superfund account to reduce the amount requested for obligations paid in one year but already charged in those prior years when unliquidated obligations were used in the billing formula. With respect to EPA reimbursement, this credit is reported on page 2 of 2 of the EPA Billing Summary, and is described as "Adjustment for Superfund Portion of Payments on Prior Fiscal Years' Unliquidated Obligations." In submitting claims against responsible parties under CERCLA, the entire issue of how past costs would be handled was being explored between LNRD and the CPA firm. In the interim, a credit was being applied based on a charged hours percentage for the prior years relating to a particular case. - 16 - ------- APPENDIX I U.S. Department of Justice Land and Natural Resources Division Executive Office , D.C 20530 MEMORANDUM TO: FROM: SUBJECT: Guy K. Zimmerman Director Audit staff Justice Management Division vRoger J. Marzulla sistant Attorney General Land and Natural Resources Division Draft Audit Report on the Environmental Protection Agency's Interagency Agreements with the Department of Justice for Superfund Activities Thank you for the opportunity to respond to the subject audit. Audits of this nature are useful and constructive, and significantly benefit the government's efforts to recover from polluters federal funds spent to clean the environment. I am particularly pleased that corrective actions for the audit's findings can be implemented quickly, and that our system of accounting for cost recovery cases has passed this critical first test. For your convenience, our detailed responses to the six recommendations are attached. However, I would like to respond briefly to the summary of audit results. The Land and Natural Resources Division agrees with the audit about the need to better reconcile expense reports with accounting data, and our / format for expense reporting has been revised accordingly. In addition, the internal control issues outlined in the audit are basically accurate, and the Division has developed plans to improve internal controls on its timekeeping system and cost records management procedures. Our position on the issue of hourly employee rates was made known to your staff at a meeting held Wednesday September 7, 1988, and we have instituted corrective measures for those few calculation errors noted in the audit. Overall, I believe that this audit is best read in light of the problems which were not found to be present — no major internal control weakness which would prejudice an independent opinion about the costs was identified, nor were - 17 - ------- Mr. Guy K. Zimmerman Page 2 flaws in the accounting system design unearthed. While this was an "exception* audit, and thus its mandate was limited to preclude an opinion about the reasonableness of costs, the report would nonetheless have included a negative statement about the overall cost system had your audit discovered major flaws. The lack of a negative statement of this ilk can be read as an endorsement of the Lands Division's systems for cost accounting. Please pass along our thanks to the audit team for their fine work and cooperation. We look forward to working with you and your staff in the future. Attachment - 18 - ------- D«tail«d Responses to Audit Recommendations I. Expense Reports 1. Consistent with the budgetary estimates listed in each of the Superfund Interagency Agreements, the Land and Natural Resources Division's format for Superfund expense reporting to the EPA will be revised to include summary expense information listed by object classification (see Appendix A). 2. An emended final report for fiscal 1987 will be prepared by September 30, 1988, and a copy forwarded to the Audit Staff for review. This final report, and all subsequent expense reports prepared by the Division, will include a new schedule designed to facilitate the reconciliation of the Superfund expense reports with the Department of Justice's 'Expenditure and Allotment* accounting reports (see Appendix A). II. Internal Controls 3. The Lands Division intends to take several steps over the next six months to strengthen and improve internal controls over it's time keeping system (see Appendix B). In sum, these measures will provide additional quality control over the time data, and supervisory review of the reported information. 4. For the allocation of direct travel to cases, the Division now requires staff to list on their travel vouchers (as well as the travel authorizations) the proper allocation of costs when multiple cases are involved (see Appendix C). The allocation information provided on the actual payment voucher will be used as the basis for allocating costs to individual cases. An adjusting entry has been made to correct the erroneous allocation identified by the audit for batch number 21701X voucher 17. 5. The problem identified by the audit involves record keeping practices when adjusting entries which affect direct charges are made within the Department of Justice accounting system. Most of these adjusting entries involve corrections to the sub-object classification or the accounting classification, and thus have little impact on the cost system. With the cooperation of the Justice Management Division's Finance Staff, the Lands Division will collect copies of all paper documents related to both the adjusting entry, and to the source document which was adjusted, and maintain these records to support costs. II. Computation of Employee Cost^s 6. The Lands Division's views and supporting papers on employee earnings were provided to the Audit Staff on September 7, 1988. The emended final expense report for 1987 will include corrections for each of the computations which were erroneous, and a copy of the final report will be provided to the Audit Staff for review. - 19 - ------- Appendix A Page 1 of 2 EPA Billing Summary Reconciliation of Total LHRD Expenses Total LNRD expenses per Expenditure and Allotment Report dated September 30. 1987 Less: Total direct Superfund labor Total direct non-Superfund labor Subtotal $ $" Total other direct Superfund costs $_ Total other direct non-Superfund costs $~ Subtotal $_ Net direct expenses Net indirect expenses Overhead payments - prior f/y obligations Total Indirect Expenses - 20 - ------- Appendix A Page 2 of 2 EPA Billing Suamary Superfuad Coats by object classification Object Class 11 12 21 22 23 24 25 26 31 Description Salaries Benefits Travel Freight Rent Printing Services Supplies Equipment Direct Expenses $ $ $ $ $ $ $ $ $ Indirect Expenses $ $ $ $ $ $ $ S $ Total $ $ $ . $ $ $ $ $ $ Total - 21 - ------- Appendix B Page 1 of 6 Our comments on the attorney tine system internal controls consist of three parts: (1) suggested clarifications to the audit report, (2) our statement of intention regarding compliance with the recommendations in the report, and (3) a timetable setting forth the compliance schedule. I. Suggested chancesi Page 15, Attorney Time Reports, third line, reads: Time reports were adjusted for mathematical and case number errors, if any, and entered into the Attorney Time System by systems analysts. We suggest: Time reports were adjusted for mathematical and case number errors, if any, by systems analysts in the Lands Division and entered into the Attorney Time System by contract data entry personnel. Page 15, Attorney Time Reports, second paragraph, reads: LNRD supervisory personnel did not approve individual attorney time reports, and attorneys charged with the overall responsibility for cases did not verify case hours reported on the attorney time reports. Also, time report corrections made by systems analysts were not returned to and approved by responsible case attorneys before their input into the data base. We suggest: LNRD supervisory personnel did not approve individual attorney time reports prior to data entry. However, after data entry, each section chief was furnished with computer generated reports which indicated the total case and category hours reported by each attorney and paralegal in his or her section. Also, time report corrections made by systems analysts were not returned to and approved by the timekeeper before their input into the data base under the following circumstances: date was incorrect timekeeper's ID number was incorrect section ID was incorrect - name was incorrect - math was incorrect decimals were added to whole numbers decimals .2, .7 were changed to .25, .75 decimals .3, .8, .9 were changed to .25, .75, 1.00 overtime was not recorded for hours in excess of normal work week corrections were made for clarity, i.e., handwriting was illegible, hours were written above or below the box - 22 - ------- Appendix B Page 2 of 6 provided, case hours were written in the lines provided for categories - file number was incorrect, i.e., dash was omitted, '9" was written instead of *90,» »5* was written instead of *s,' numbers were omitted in file number - when a zero was listed for a case or category,it was eliminated so that it would not be keyed DJ file number was reported with no hours - total column was blank but time was noted per day (time was written in the total column.) - wrong color timesheet was used (Timesheet was copied on the appropriate colored paper.) However, time reports were returned for corrections or corrections were verified by telephone or electronic mail when: - case name was noted instead of DJ file number - file number was incorrect - hours were reported with no DJ file number - one timesheet was received instead of the two that are required when the month does not end on Saturday timesheet was unsigned - holiday was not noted - 40 hours were not reported by full time employees After data entry, reports containing any incorrect DJ file numbers used were produced and forwarded to the attorneys or paralegals for correction. The corrected reports were subsequently returned to the Systems Group for entry into the data base. Page 17-18, Recommendations. reads: 3. Develop and implement procedures for the strengthening of supervisory controls to include: (a) approval of attorney time reports by supervisory personnel, (b) requiring attorneys with overall responsibility for Superfund cases to verify case hours represented on attorney time reports, and (c) returning time reports corrected by LNRD systems analysts for approval by case attorneys. We suggest: Develop and implement procedures for the strengthening of supervisory controls to include: (a) approval of attorney and paralegal timesheets by supervisory personnel, and (b) returning time reports corrected by LNRD systems analysts for approval by case attorneys. yi. Statement ofintention: In its report, the Audit Staff of the Justice Management Division concludes that the Division needs to implement procedures for - 23 - ------- Appendix B Page 3 of 6 strengthening internal controls over the timekeeping forms, and that time reported must be verified by a supervisory person. We intend to comply with the recommendations for strengthening supervisory controls by establishing levels of review for the timekeeping forms. As a first step, the Division will implement a procedure whereby the Section Chiefs will delegate authority to review and correct timesheets to the Case Management Specialists and designated supervisory person(s). Second, the Assistant Attorney General or Deputy Assistant Attorney General will delegate to the Systems Group limited authority to review and correct timesheets for the entire Division. After these delegations have been established, the following review process will be implemented: A. Case Management Specialist Responsibilities The Case Management Specialist in each section will collect timesheets every Monday, review each timesheet for completeness and accuracy, and be authorized to independently make the following changes to assure that the: - timesheet is legible - timekeeper used the proper color timesheet - timekeeper's ID number is correct - timekeeper's name is correct - section indicator is correct - week ending date is correct - DJ case numbers are correct - math is correct _ decimals are indicated for whole hours (8.0) - time is reported in 15-minute segments - overtime is recorded for hours in excess of normal work week - holiday is recorded under leave category - zero or blank hours are not reported for any case or category - daily time also appears in the total column The following problems will be returned to the timekeeper for correction, and then re-submitted to the Case Management Specialists: - time sheet is not signed - case name is noted instead of DJ file number - file number is incorrect and Case Management Specialist is unable to determine correct number - hours are reported with no DJ file number - one month-end timesheet is submitted instead of two when the month does not end on Saturday - holiday is not noted ------- Appendix B Page 4 of 6 - total hours are less than the timekeeper's normal work week (40.0 hours if full time employee) The Case Management Specialist will review time sheets for completeness and accuracy.1 The Case Management Specialist will sort and batch the timesheets. A check-sheet will accompany the timesheets and will be placed on top of the verified timesheets, specifying the name of each attorney or paralegal who is required to submit a timesheet and, indicating those who have submitted a timesheet for the current week and those who have submitted delinquent timesheets for prior weeks. The Case Management Specialist will submit the batched timesheets to a designated supervisory person(s) for review and approval. B. Supervisory responsibility After review, designated supervisory person(s) in each section will sign the cover sheet and return the package to the Case Management Specialist for submission top the Systems Group by noon each Wednesday. 1 Verification of the accuracy of time reports includes assurance that: 1. Total hours are filled in and represent "at least* the number of hours that a particular employee normally works during the work week (i.e., 40.0 hours for full time). 2. The employee's name, section, ID number and week ending date are correct. 3. The case numbers reported on the timesheet are assigned to the timekeeper. If the case is not assigned to the timekeeper, the Case Management Specialist will verify that the timekeeper is working on the case. 4. The timesheet is signed by the timekeeper. The verifier is not responsible for attesting to the number of hours reported for each case nor the total time worked if it is beyond the normal work week. ------- Appendix B Page 5 of 6 C. Systems Group responsibility The Systems Group will perform a second quality assurance review, and may independently correct timesheets within the limits established for Case Management Specialists in paragraph A. The Systems Group will submit the timesheets for Keypunching, verify their return, and maintain locked files for the timesheets until they are permanently stored on microfilm. III. Timetable; The timetable for implementing the new review procedures for the timesheets is below: Milestones Draft delegation of authority from Section Chiefs to Case Management Specialists and other supervisory person(s) to review and correct timesheets. Forward draft to Section Chiefs for review and comments. Incorporate comments of Section Chiefs. Forward final delegation of authority to Section Chiefs for signature. Draft delegation of authority from Deputy Assistant Attorney General or Assistant Attorney General to Systems Group to review and correct timesheets for the entire Division. (Include copy of signed delegation from Section Chiefs.) Forward draft to Deputy Assistant Attorney General for review and comments. Incorporate comments of Deputy Assistant Attorney General. Forward final delegation of authority to Deputy or Assistant Attorney General for signature. Contact sections to establish supervisory processing points. Completion Date 9/30/88 10/3/88 10/2/88 10/24/88 10/31/88 11/1/88 11/18/88 11/21/88 11/30/88 - 26 - ------- Appendix B Page 6 of 6 Draft list of supervisory processing points, Forward list to Section Chiefs for review. Incorporate comments of Section Chiefs. Draft new timekeeping policy guidelines setting forth the above delegations, new supervisory review functions, and how amendments to timekeeping form will be handled. Forward draft of policy guidelines to Section Chiefs for review and comments. Incorporate comments of Section Chiefs. Forward draft of policy guidelines to Deputy Assistant Attorney General for review and comments. Incorporate comments of Deputy Assistant Attorney General. Forward final of policy guidelines to Deputy Assistant Attorney General for approval. Forward guidelines to Assistant Attorney General as a Division directive. Review process with Case Management Specialists. Implement new procedures. 12/7/88 12/8/88 12/19/88 12/30/88 1/3/89 1/20/89 1/30/89 2/13/89 2/20/89 2/27/89 3/6/89 3/13/89 - 21 - ------- U.S. Department of Justice Land and Natural Resources Division WaiftinfTon.D.C. 20530 Appendix C Page l of l MEMORANDUM From: Gary M. Peterson Executive Assistant To: All Employees Land and Natural Resources Division Subject: Allocating Costs for Multi-case Travel Effective immediately, all personnel in the Land and Natural Resources Division are required to list on each travel voucher an allocation of the total amount claimed to each of the cases or projects for which you traveled. You may make this allocation based on any of the folowing criteria: Number of hours worked on each case or prelect This would be appropriate if you visit one city, but work on several cases. If you work 10 hours on Case A and 20 hours on Case B, the allocation would be 33% for Case A and 67% for Case B. Cost of airfare when separate cites are visited If you visit Philadelphia for Case C (airfare is 20% of total cost), then fly to San Francisco to work on Case D (airfare is 80% of total cost), the allocation could be 20% for Case C and 80% for Case D. Cost of airfare and number of hours worked Should you visit New York for six days, and Los Angeles for one day, a hybrid approach might be appropriate, counting the costs of airfare as well as the number of hours worked. Primary purpose of travel If you must fly to San Fransisco for Case E, and then stop by Denver for Case F as an afterthought, you might allocate 90% of the trip's costs to Case E and 10% to Case F. Your allocation is not intended to be an exercise in higher mathematics; you are asked only to provide a good faith estimate of the costs allocable to each case or project. Should you have any questions about cost allocations on travel vouchers, please call Kyra O'Kieffe in the Financial Management Group on 272-5977. - 28 - ------- APPENDIX II SUMMARY OP RECOMMENDATIONS AND ACTIONS Recommendation Number: X. 2. 4. 5. 6. Resolved. No further action required. Resolved. Subsequent to our receipt and review of the amended final Fiscal Year 1987 financial report, we shall consider this recommendation for closure. Resolved. Closure of this recommendation is dependent upon successful completion of the scheduled corrective actions. Resolved. No further action required. Resolved. No further action required. Resolved. No further action required. The information provided to the Audit Staff on September 7, 1988, by the contractual CPA firm was sufficient to remedy the finding and recommendation. The information demonstrated that the CPA firm was using a methodology which appeared to compute and allocate actual labor costs on a fair and equitable basis. Though alternatives exist, the method used by the CPA firm, thus LNRO, appears reasonable. - 29 - ------- I t«*7 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 APR I I 1988 THE INSPECTOR GENERAL MEMORANDUM SUBJECT: Audit Report Summaries for Semiannual Report to Congress TO: See Attached List The Office of Inspector General is required to provide a semiannual report to Congress. In this report, we provide summaries of some of the significant audits which we have performed. Attached are copies of report summaries relating to your office which we plan to include in the next semiannual report. These summaries are as close as possible to the final versions that will appear in .the semiannual report to be issued to the Administrator cgT'^gril 29, 19QB.^ Should you or your staff have any comments regarding the factual content of the report summaries, please submit your comments in writing to Ernest E. Bradley III. ^Assistant Inspector General for~~A~ucTit^ To consider youiT comments, we must receive them no later than April 20, 1988. We appreciate your prompt attention to this matter. Jo Attachment o»i OL Martin ------- Addressees: A. James Barnes Deputy Administrator Robert S. Cahill Associate Administrator for Regional Operations Charles L. Grizzle Assistant Administrator for Administration and Resources Management Sheldon Meyers Acting Associate Administrator for International Activities John A. Moore Assistant Administrator for Pesticides and Toxic Substances Rebecca W. Hanmer Acting Assistant Administrator for Water Thomas L. Adams, Jr. Assistant Administrator for Enforcement and Compliance Monitoring J. Craig Potter Assistant Administrator for Air and Radiation J. Winston Porter Assistant Administrator for Solid Waste and Emergency Response David Kling, Acting Director Asbestos Action Program Charles W. Elkins, Director Office of Toxic Substances David P. Ryan, Comptroller Office of the Comptroller Harvey Pippen, Director Grants Administration Division Vincette L. Goerl, Director Financial Management Division Nelson Hallman, Acting Director Facilities Management and Services Division ATTACHMENT Page 1 of 2 ------- ATTACHMENT Page 2 of 2 Gerald A. Byran, Director Office of Compliance Analysis and Program Operations John Seitz, Director Stationary Source Compliance Division Paul F. Nadeau, Acting Director Hazardous Site Control Division James R. Elder, Director Office of Water Enforcement and Permits Gene A. Lucero, Director Office of Waste Programs Enforcement John Chamber1in, Director Office of Administration Lloyd Guerci, Director CERCLA Enforcement Division Henry L. Longest II, Director Office of Emergency and Remedial Response (Superfund) Joseph Carra, Director Waste Management Division Steve Allbee, Acting Director Municipal Construction Division Michael R. Deland Regional Administrator, Region 1 Christopher J. Daggett Regional Administrator, Region 2 James M. Self Regional Administrator, Region 3 Greer C. Tidwell Regional Administrator, Region 4 Valdas V. Adamkus Regional Administrator, Region 5 Robert E. Layton, Jr. Regional Administrator, Region 6 Daniel W. McGovern Regional Administrator, Region 9 ------- MORE IMPROVEMENTS ARE NEEDED TO ENSURE SUPERFUND ACCOUNTING Problem Although Agency guidance on accounting for Superfund costs has significantly improved, further improvements are needed to ensure accurate accounting for property management, cost allocations, receivables, obligations, disbursements and personnel compensation. We Found That Humerous weaknesses existed in property controls. For example: o 140 items purchased in fiscal 1986, costing about $736,000, were not recorded in the Personal Property Accounting System. o 103 sample items, valued at about $252,000, that were selected for physical inspection could not be located. A significant procedural weakness contributing to these deficiencies was the lack of Agency policies and procedures requiring the reconciliation of property and equipment purchases recorded in the Financial Management System with items entered into the Personal Property Accounting System. We also found that the Agency's procedures for allocating general support services costs to Superfund were not clearly defined. At Headquarters, disbursements were allocated improperly, and at Region 3, general support services cost allocations were overstated because an incorrect personnel ratio was used. In addition, the Superfund program was not always charged its proportionate share of support services costs due to cost and personnel ceilings. As a result, distribution of support services costs between Superfund and EPA's other program was inaccurate. Additionally, we found that amounts due Superfund from cost recovery decrees and State cost-sharing agreements were not being recorded timely. This occurred because various EPA offices failed to properly coordinate and communicate cost recovery decrees and agreements as required by existing Agency guidance. This precluded the Agency from adequately managing receivables and collections and could result in a material amount of lost interest. While we accepted the majority of fiscal 1986 recorded obligations of $393,272,582 and disbursements of $416,685,493, a statistical analysis of key internal control and compliance attributes dis- closed a higher than expected error rate of nonpayroll obligations, nonpayroll disbursements, and personnel compensation transactions. This could result in: unauthorized or misstated obligations being recorded, improper or duplicate disbursements, and misstated personnel compensation costs. ------- We Recommended Thr.t The Acting Assistant Administrator for Administration and Resources Management: o Establish policies and procedures requiring (1) reconciliation of the personal property account in the Financial Management System with property recorded in the Personal Property Account- ing System, and (2) annual physical inventories. o Clarify cost allocation procedures and ensure that appropriate adjustments are made to reflect proper allocations. o Require cost settlement documents and State cost-sharing agree- ments be forwarded immediately to the appropriate finance office. o Reconcile receivables with the Office of Waste Program Enforce- ment's Case Management System to ensure that all settlement documents are recorded. What Action Was Taken The final audit report was issued to the Acting Assistant Admini- strator for Administration and Resources Management on QctLgber 7, 1987. On January 15, 1968, the Acting Assistant Administrator yruvided a btatus report on corrective actions that were underway when we issued the draft audit report, and responses to the final audit report's recommendations. The status report and the response indicated that the Assistant Administrator implemented our recommendations. As part of our audit of EPA's fiscal year 1987 portion of the hazardous Substance Superfund, we will follow up on these findings and recommendations to determine the adequacy of the corrective actions implemented. ------- |