UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 TH£ OF GENERAL MEMORANDUM SUBJECT: Superfund Interagency Agreements with the National Bureau of Standards, Department of Commerce Audit Report No. M5BH8-11-Q032-80571 FROM: Ernest E. Bradley III Assistant Inspector General for Audit TO: J. Winston Porter Assistant Administrator for Solid Waste and Emergency Response (WH-562A) At our request, the Office of Inspector General, U.S. Department of Commerce (DOC), performed the subject audit. The final report is attached. The report does not present any information which would warrant corrective action by EPA officials Accordingly, we are closing this report in our Audit Tracking and Control System upon issuance. The Inspector General, DOC, informed us in a separate memorandum that the National Bureau of Standards (NBS) can provide site-specific cost information which can be verified to NBS' accounting system. This can be done if (1) EPA establishes separate interagency agreements for work to be performed at each site and (2) requires cost reporting by agreement. Should your staff have any questions concerning this memorandum, please have them call John Walsh on 475-6753. Attachment to CVJ HEADQUARTERS LIBRARY ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C ?0460 ------- DISTRIBUTION Associate Enforcement Counsel for Hazardous Waste Enforcement (LE-L34S) Director, Financial Management Division (PM-226) Chief, Superfund Accounting Branch (PM-226) Agency Followup Official (PM-225) Attn: Resource Management Staff Director, Grants Administration Division (PM-216) Chief, Grants Information and Analysis Branch {PM-216} ------- \ **»!•<»•' UNITED STATES DEPARTMENT OF COMMERCE Office of Inspector General Wasnmgton Q C 20230 JAN 2 7 1988 MEMORANDUM FOR: FROM: SUBJECT: Dr . Ernest Ambler Director, National Bureau of Standard^, Frank Acting General Audit of Two Interagency Agreements with EPA Report No. 1-176-8-002 Through the use of interagency agreements, the National Bureau of Standards (NBS) performs work on a reimbursable basis for various federal agencies, including the Environmental Protection Agency (EPA). In response to EPA's request, we have completed an audit of NBS costs charged against two of the reimbursable agreements with EPA. We found that NBS's charges, totaling about $62,300 under the two agreements, were adequately supported. However, under one of the agreements, NBS incurred approximately $3,900 of costs which were charged to NBS's appropriation rather than to the EPA agreement, thereby resulting in a corresponding underbilling to EPA. Purpose and Scope of Audit Our audit focused on the following two interagency agreements between EPA and NBS: agreement numbers AD13F2A245 and DW13038301. EPA advised that these agreements were funded with money provided under the superfund legislation. The purpose of our audit was to identify the amounts which NBS charged to these agreements during fiscal years 1984 through 1986 and to ascertain whether these costs were determined in accordance with policies and requirements applicable to reimbursable work performed for other agencies. We evaluated the adequacy of internal controls applicable to the identification and assignment of costs to specific agreements. Also, our work included tests to establish the appropriateness of costs actually charged under the terms of the two agreements. During our review, we examined pertinent records and interviewed selected personnel at NBS's offices in Gaithersburg, Maryland. ------- Two issues regarding the scope of our review should be noted: In reviewing indirect costs, we limited the scope of our work to determining whether these costs were charged in accordance with established NBS overhead rates and on a basis consistent with the rates charged to NBS units and other agencies. We did not assess the accuracy of N'BS's various overhead rate components because such a review would require a major commitment of audit resources, and we could not divert such resources from higher priority audits at this time. We have not determined whether the provisions of the two interagency agreements were consistent with the statutory authority governing EPA's expenditure of superfund monies. We believe such determinations are more appropriate for EPA's Inspector General. Our audit was performed under the authority of the Inspector General Act of 1978 and Department Organization Order 10-13, dated May 22, 1980. The audit was conducted in accordance with generally accepted government auditing standards.' FINDINGS AND RECOMMENDATIONS Pertinent facts about the two agreements are provided below: Agreement Number AD13F2A245 Under this agreement, NBS was to provide a computer readable, digitized data base pertaining to an automated chemical information system. Before project work began, EPA transferred 550,000 to NBS's Working Capital Fund to provide financing for this reimbursable project. Actual NBS charges to the project totaled $50,000. Agreement Number DW13038301 This agreement provided for NBS to perform on-site work at two landfill sites near Bloomington, Indiana. Specifically, NBS personnel were to assess the possibility that buried electric capacitors containing PCB could be perforated by corrosion. The interagency agreement authorized NBS to incur costs up to $25,000 for this work, with payments to be made as costs were incurred by NBS and billed to EPA. Actual NBS billings totaled $12,300. Project Costs were Adequately Supported Based on our evaluations and tests, we concluded that the two agreements were adequately controlled by NBS to ensure that r•(~lo^e i~harrteH *• n fho an r oomon t-c uo r p Hirar«h1v rAl^hoH t-o work costs nents were adequately controlled by NBS to ensur charged to the agreements were directly related ------- performed. We found no evidence of improper charges. We noted, however, that NBS did not identify and bill about 53,900 of costs incurred under one of the agreements, as described later in this report. NBS's controls include separate accountability for funds under each reimbursable agreement. This includes appropriate general ledger accounts for recording both obligations and costs. Entries in the accounts are required to be supported by records showing the basis for charging costs to the agree- ments. For example, the controls provide for direct labor costs to be charged on the basis of staff time expended on the projects, as reported by employees and certified by supervisors. We tested costs charged under that: the two agreements and found The labor charges were supported by appropriate work- sheets and timecards. Charges for travel, were substantiated materials, and other direct costs by supporting documentation. Indirect costs were charged in accordance with established NBS overhead rates and on a basis consistent with the rates charged to NBS units and other agencies. Costs Not Billed Under agreement number DW13038301, NBS incurred about $3,900 of costs which were never charged to the project or billed to EPA. This underbilling resulted because, at the beginning of the project, three NBS personnel traveled to the work site in Bloomington, Indiana but, at that time, an NBS cost center number for the reimbursable project had not yet been established Lacking a cost center number, the costs of direct labor, travel, and overhead applicable to this initial trip were charged to NBS's appropriated funds, rather than to the EPA reimbursable project. This is contrary to NBS's policy which requires that costs be identified with and charged to specific cost centers authorized to cover clearly defined activities. We believe it is important for NBS to ensure that its personnel understand the importance of not performing reimbursable work until a cost center number has been assigned so that costs can be charged to the appropriate organization. Final Billings Not Submitted for Small Amounts In some cases, final project billings are not sent to the reimbursing agency because the amounts due are relatively small. We noted that for agreement number DW13038301, NBS ------- personnel did not issue a final bill for $30 that was due from EPA. In response to our inquiry on this point, N'BS personnel advised that, when the amounts owed are for rela- tively small amounts (under $50), a final billing is waived. However, NBS has no written procedures or other formal approvals governing such waivers. Written procedures should be established to ensure that there is a clear understanding about this matter and to provide for consistency of approach by the current and future employees who may be involved in administering the billing function. Recommendations We recommend that the Director, NBS, provide for the following actions: 1. Emphasize to NBS personnel that no reimbursable project work is to be performed for another organization until NBS's Office of the Comptroller has established a cost center number. 2. Provide NBS personnel with written guidance explaining when it is appropriate to waive the issuance of billings to other organizations. NBS Response -- In reply to our draft report, NBS agreed with our recommendations and described specific implementing act ions. We appreciate the cooperation and courtesies extended by NBS officials during our review. NBS's complete response to our draft report is attached as Appendix I. As required by Department Administrative Order 213-5, please provide us within 90 days an action plan for each of our recommendations. ------- K UNITED STATES DEPARTMENT OF COMMERCE National Bureau of Standards ana 2CS3S APPENDIX I OFC I I tgo,; MEMORANDUM FOR John R. Stpanka Assistant..Inspector General for Auditing ' /^ ^ Froa: Guy W. Chamberlin,\ J^r/' Director of Administration " Subject: Audit of Z?A n In response to the draft audit report, ?TB3 agrees with both recommendations made. Recommendation 1. Emphasize to NBS personnel that no reimbursable project work is to be performed for another organization until NBS's Office of the Comptroller has provided a cost center number to be used in assigning all applicable costs to the reimbursable project. '/e recormend that the word ''provided" be replaced with the words "established in the accounting systen." We will send a ™ezor«iflun to TB3 Executive Officers reninrlir.g thes of this r«quirenent. Recori'Tindation 2. Provide ''33 persor_r:^l with written guidance regarding the circunstances when it is appropriate to waive the issuance of billins documents to other organisations for anounts due under reimbursable agreements. Procedures have been drafted for the Billing and Collections Group regarding the circumstances when it is appropriate to waive the issuance of invoices to other organizations for snail anounts of cost due under reimbursable agreements. These draft procedures are being reviewed. ------- |