UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 204*0
. , , >_. .- OFFICE Of
'UQ *J\ \\ ™<= INSPECTOR GENERAL
""" I 3 I99CT
MEMORANDUM
SUBJECT: Audit Report No. M5BFLO-11-0034-0100428
Audit on Accounting for Reimbursable
Expenditures of EPA
Superfund Money, Office of Environmental
Project Review, Office of the Secretary
i§ ±j «^
FROM: Kenneth D. Hockman 7) s>vvf» &**) P
Divisional Inspector General for Audit
Internal Audit Division (A-109)
TO: Harvey G. Pippen, Director
Grants Administration Division (PM-216)
The Office of Inspector General, Department of Interior,
prepared the subject report which is required by section lll(k)
of the Superfund Amendments and Reauthorization Act of 1986. We
are not making any recommendations to you and are closing this
report upon issuance.
Should your staff have any questions concerning this report,
please have them call Fran Tafer on 475-6753.
Attachment
cc: Director, Office of Program Management (OS-240)v
Chief, Financial and Administrative Management
Section (OS-240)
Chief, Grants Information and Analysis
Branch (PM-216F)
HEADQUARTERS LIBRARY
FNVIRONMENTAL PROTECTION AfcENu
WASHINGTON, D.C. 20460
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United States Department of the Interior
OFFICE OF INSPECTOR GENERAL
WASHINGTON, D.C. 20240
JAN - 2 1990
MEMORANDUM
TO:
FROM:
The Secretary
Inspector General
SUBJECT SUMMARY: Final Audit Report for Your Information - "Accounting for
Reimbursable Expenditures of Environmental Protection
Agency Superfund Money, Office of Environmental Project
Review"
DISCUSSION: This report presents the results of our review of the Office of
Environmental Project Review's accounting for reimbursable expenditures of
Environmental Protection Agency's Superfund money. The objective of our
audit was to determine (1) whether the Office maintained accurate, complete,
and current cost records for reimbursable Superfund projects and (2) the
reasonableness, allowability, and allocability of coses claimed under the
reimbursable agreement during fiscal year 1988. In addition, we reviewed
the disposition of unobligated balances in the Office's Superfund accour.r
for fiscal years 1985 through 1988.
Ue found that the Office did not maintain accurate and complete cost records
of reimbursable expenses charged to Superfund activities. The Office could
not substantiate that about $1.1 million charged to the agreement was only
for Superfund-related work. Without accurate and complete accounting, the
Agency may not be able to recover the costs from responsible parties in
accordance with the Superfund Act.
We also found that the office did not notify the Agency that "no year" funds
of $805,000 authorized under prior Superfund agreements were not obligated
by the expiration date of the agreements. Thus the Environmental Protection
Agency wa» unable to reauthorize the funds to other critical Superfund
program need*.
Ue recommended that the Assistant Secretary for Policy, Budget and
Administration (1) reconstruct the expenditures chargeable to the agreement
for fiscal year 1988, (2) establish a time and attendance reporting system.
(3) annually perfora a financial analysis of the Office's indirect
expenditures, and (4) establish procedures to ensure that unobligated funds
are returned to the Agency upon the expiration of the agreement or request
that the funds be carried over to a current agreement.
Prepared by: Harold Bloom
Extension: 343-4252
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The Office's October 27, 1989, response to the draft report Indicated
agreement and specified actions under w«y to implement the four
recommendations. Accordingly, a response to the final report was not
necessary. "
Fames R. Richards
v
Attachment
cc: Solicitor
Assistant Secretary - Policy, Budget and Administration
Director, Office of Public Affairs
Director, Office of Environmental Project Review
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E-OS-OSS-20-89
U.S. DEPARTMENT OF THE INTERIOR
OFFICE OF INSPECTOR GENERAL
AUDIT REPORT
ACCOUNTING FOR
„ , REIMBURSABLE EXPENDITURES OF
ENVIRONMENTAL PROTECTION AGENCY SUPERFUND MONEY
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
OFFICE OF THE SECRETARY
U.S. Popartmini of MM
, O.C. 20140.
REPORT NO. 90-25
DECEMBER 1989
uATI
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Illegal or wasteful activities should be reported to the
Office of Inspector General by:
Calling
Our 24-hour
telephone HOTLINE
1-800-424-5081
or FTS 343-2424
Sendiog Written Documents to;
WITHIN THE CONTINENTAL U.S.
U.S. Department of the Interior
Office of Inspector General
P.O.Box 1593
Arlington, Virginia 22210
OLTSIDE CONTINENTAL U.S.
Caribbean Are*
1-809-774-8300
or
FTS-809-774-8300
U.S. Department of the Interior
Office of Inspector General
Caribbean Region
P.O. Box 7730
St. Thomas. Virgin Islands 00801
North Pacific Am
1-671-472-7279
or
FTS-550-7279
U.S. Department of the Interior
Office of Inspector General
North Pacific Region
238 Archbishop F. C. Flora Street
Suite 807. PDN Bldg.
Agana, Guam 96910
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United States Department of the Interior
OFFICE OF INSPECTOR GENERAL
WASHINGTON, D.C. 20240
December 26, 1989
MEMORANDUM AUDIT REPORT
To:
From:
Subject:
t : o<
Assistant Secretary for Policy, Budget and Administration
Assistant Inspector General for Audits
Audit Report on Accounting for Reimbursable Expenditures of
Environmental Protection Agency Superfund Money, Office of
Environmental Project Review, Office of the Secretary
(No. 90-25)
INTRODUCTION
This report represents the results of our audit of the Office of
Environmental Project Review's accounting for reimbursable expenditures of
Environmental Protection Agency Superfund money. The objective of our audit
was to determine (1) whether the Office maintained accurate, complete, and
current cost records for reimbursable Superfund projects and (2) the
reasonableness, allowability, and allocability of costs claimed under the
reimbursable agreement during fiscal year 1988. In addition, we reviewed
the disposition of unobligated balances in the Office's Superfund account
for fiscal years 1985 through 1988.
Based on the tests performed during our review, we concluded that the Office
did not maintain accurate and complete cost records of reimbursable expenses
incurred for Superfund activities. As a result, the Office could not
substantiate that incurred costs of approximately $1.1 million charged to
the agreement were only for Superfund-related work. This lack of accounting
could jeopardize the Agency's ability to recover the costs from responsible
parties in accordance with the Superfund Act. In addition, we determined
that a large balance of authorized funding remained unobligated after the
expiration date of the agreements. Consequently, the Agency did not have
the opportunity to reauthorize about $805,000 of "no year" Superfund
appropriations to other critical Superfund program needs.
BACKGROUND
The Office operates under two types of agreements with the Agency. The
first is a memorandum of understanding between the Department of the
Interior and the Agency's Office of Waste Programs Enforcement to conduct
preliminary natural resource surveys. The surveys are performed by the
Department's bureaus and offices under interagency agreements issued by each
of the Agency's 10 regions. The purpose of these agreements is to develop
coordinated Department knowledge of potential injury, If any, to Interior
natural resources at specifically requested and assigned hazardous waste
sites so that a unified United States position can be presented by the
Department of Justice attorneys in Federal enforcement litigation against
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responsible parties. Accounting, billing, and reimbursement are
accomplished by the bureaus involved in the survey.
The second is an interagency agreement between the Agency Administrator's
Office of Solid Waste and Emergency Response and the Department to provide
technical assistance to survey damages to natural resources from hazardous
substances. The Agency provided funding to the Department, through the
Office of Environmental Project Review, for services such as (1)
participating in response management for hazardous substance releases
through the National and Regional Response Teams, composed of Federal and
State officials; (2) coordinating other Federal and state agencies' emergency,
preparedness actions and responses for hazardous waste contingencies; and
(3) providing damage assessment capability so that natural resource losses
can be compensated where eligible. The technical assistance to survey
damages is generally provided by Office of Environmental Project Review
personnel.
Section 107 of the Superfund Act imposes a liability upon responsible
parties for the costs of cleanup and for damages resulting from the release
of hazardous substances. This enables the Agency to recover all costs,
including survey and coordination expenses, from the parties responsible for
the release of hazardous substances. To ensure recovery of these costs,
bureaus and offices are required to maintain detailed accounts and to
document all costs incurred as specified in the interagency agreements. The
Agency reimburses bureaus and offices for allowable costs, including
indirect costs.
The Superfund Amendment Reauthorization Act of 1986 requires the Inspector
General of the Department of the Interior to conduct an annual audit of all
payments, obligations, reimbursements, and other uses of the Superfund
monies in the prior fiscal years.
SCOPE OF AUDIT
The Office of Environmental Project Review had one Superfund interagency
agreement in fiscal year 1988 with the Agency's Office of Solid Waste and
Emergency Response, which provided SI,253,500 in funding authorization. The
Office of Environmental Project Review allocated the funding to the three
functional areas of (1) Response Management ($360,000), (2) Emergency
Preparedness ($437,500), and (3) Damage Assessment Capability ($256,000).
The Office had claimed costs of $1,119,931 against the authorized amount.
In accordance with our interagency agreement with the Environmental
Protection Agency's Office of Inspector General, the review of the Office of
Environmental Project Review's Superfund expenditures was limited to the
fiscal year 1988 funding.
We judgmentally selected $1,065,819 of the $1,119,931 in costs claimed for
fiscal year 1988 for detailed audit. We used the Office's financial reports
and files, including biweekly payroll reports, allocations of personnel
time, and payments made to employees for reimbursable travel costs, to
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determine the accuracy of costs charged against the agreement. Our review
included verifying that the obligated amounts did not exceed authorized
agreement amounts. We also ascertained whether:
- Expenditures were incurred during the interagency agreement period.
- Employees' travel and per diem charges were authorized and coincided
with work times charged to the agreement.
- Expenditures, including allocations of salaries and indirect costs,
were reasonable, supported, and allowable in accordance with the interagency
agreement.
We also reviewed the agreement account maintained by the Office of the
Secretary's Division of Fiscal Services for fiscal years 1985 through 1988
to determine the status of authorized funds.
The audit was performed from June 1989 through July 1989 at the Office of
Environmental Project Review in Washington, O.C. The audit was made, as
applicable, in accordance with the "Government Auditing Standards," issued
by the Comptroller General of the United States. Accordingly, we included
such tests of records and other auditing procedures that were considered
necessary under the circumstances. As part of the audit, we evaluated the
Office's system of internal controls over accounting for expenditures of
funding received from the Environmental Protection Agency through the
Superfund program. We found control weaknesses in the areas of maintaining
adequate cost records and retaining unobligated fund balances. These
weaknesses are discussed in the Results of Audit section of this report.
The recommendations, if implemented, should improve internal controls in
these areas.
PRIOR AUDIT COVERAGE
The Office of Inspector General and the General Accounting Office have not
previously audited the Office of Environmental Project Review's expenditures
under Superfund interagency agreements with the Environmental Protection
Agency.
RESULTS OF AUDIT
The Office of Environmental Project Review did not have adequate support for
the salaries, fringe benefits, and indirect costs allocated to the
agreement. The agreement with the Environmental Protection Agency requires
that the Office provide detailed and accurate records of travel
expenditures, personnel costs, and other costs. However, the Office did not
(1) establish a time and attendance reporting system and (2) perform an
analysis of indirect costs incurred solely for Superfund projects to
substantiate the charges to the agreement. As a result, the Office did not
have adequate documentation to support $1,053,559 of the $1,065,819 in costs
reviewed. Consequently, the Agency's efforts to recover claimed costs
totaling $1,119,931 from responsible parties may be jeopardized. In
addition, the Office did not notify the Agency of an unobligated fund
balance of $804,724 on expired Superfund agreements which could have been
reallocated to other critical Superfund-related purposes.
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/
/
The deficiencies are discussed in the following paragraphs. Summaries of
the costs claimed, unobligated balances, and audit results are presented in
Appendix 1.
\
Allocations of Salaries and Fringe Benefits
The Office claimed expenditures of $946,342 in salaries and fringe benefits
against the Superfund agreement during fiscal year 1988. However, the
Office did not maintain a reporting system which tracked the time personnel
expended performing Superfund activities. Instead, the Office's Director,
by memorandum, directed the Office of Budget, within the Office of the
Secretary, to allocate either 50 percent or 100 percent of personnel time to
the Superfund account when the time was entered into the accounting records.
The Director developed this allocation method primarily using his experience
and knowledge of personnel and the program. We could not determine whether
the Office overestimated or underestimated the actual time spent on
Superfund-related activities using the allocation method because the
available records (activity reports) did not indicate the Superfund
activities the employees worked on during the review period. Since the
allocation of costs based on percentage estimates did not adhere to the
accounting requirements stated in the agreement, we have classified the
$946,342 claimed for salaries and fringe benefits as unsupported.
\ ^/^ ^l&Location. of Indirect Costs
Indirect costs charged to the Office's Superfund account totaling $107,217
were also unsupported. The allocated costs included telephone and utilities
($4,982), printing and reproduction ($16,433). supplies ($9,082), and other
services ($76,720). The allocations (various percentages) were also
developed by the Office's Director based on his experience and knowledge of
the program. The Office of the Secretary, Division of Fiscal Services, was
similarly directed by memoranda from the Director to make these allocations.
The allocation percentages were not supported by a financial analysis of
the Office of Environmental Project Review's indirect costs. The
interagency agreement states that "any indirect costs included in billings
to the EPA [Environmental Protection Agency] represent, in accordance with
General Accounting Office principles, indirect costs that would not have
been otherwise incurred by the Department of Interior." The memoranda
justifying the allocation did not comply with this requirement.
Accordingly, we have classified the $107,217 in claimed indirect costs as
unsupported.
Unobligated Funding
Financial reports from the Division of Fiscal Services showed that the
Office's Superfund account had a balance of $804.724. This amount
represented funding authorizations from interagency agreements which had not
been obligated. The former Director informed us that he thought any
unobligated funding was automatically returned to the Agency at the
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expiration date of each agreement. However, an official in the Division of
Fiscal Services stated that unobligated funding was not returned to other
Federal agencies until the Division was notified of such by the bureau or
office which received the funding. As a result, the Agency was not notified
of the unobligated Super fund money, which could have been reallocated for
other critical Superfund- related purposes.
Re c ontmendat i ons
We recommend that the Assistant Secretary
Administration:
fo
Policy, Budget , and
(_/ ^ >£. :•«*•• ^ • i ""-:
1. Reconstruct the expenditures (direct and indirect) chargeable to
the Superfund interagency agreement with the Environmental Protection
Agency's Office of Solid Waste and Emergency Response for fiscal year 1988
and reimburse the Agency for costs which cannot be supported.
2. Establish a time and attendance reporting system within the Office
of Environmental Project Review to ensure that employees' time is accurately
allocated to the Office's Superfund account.
3. Perform a financial analysis of the Office of Environmental Project
Review's indirect expenditures annually in order to compute the costs
incurred for Superfund-related purposes only.
*
4. Establish procedures which ensure that all unobligated funding
remaining from expired Superfund interagency agreements is returned to the
Agency upon the closeout of obligations posted to the accounts or request
that the Environmental Protection Agency authorize the carryover of the
'funds to a current Superfund agreement.
flf.ffflP ?f Environmental Project Review Response
The Acting Director responded to the draft audit report on
October 27, 1989 (Appendix 2). The Acting Director concurred with all four
recommendations and stated that he had initiated actions to (1) reconstruct
documentation of expenditures charged for fiscal year 1988; (2) establish a
time and attendance reporting system, including implementing interim
procedures to be followed by staff; (3) plan the performance of a financial
analysis of the Office's indirect expenditures; and (4) establish procedures
to ensure that all unobligated funding remaining from expired Superfund
interagency agreements is returned to the Agency. The Acting Director
stated that all actions would be completed by December 31, 1989.
Office of Inspector General Comments
Based on the response, we have classified the four recommendations as
resolved (Appendix 3). Accordingly, no further response is necessary.
The legislation creating the Office of Inspector General requires semiannual
reporting to the Congress on all reports issued, the monetary impact of
/ 5
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audit findings (Appendix 4), actions taken to implement audit
recommendations, and identification of each significant recommendation on
which corrective action has not been implemented.
Harold Bloom
cc: Director, Office of Environmental Project Review
Audit Liaison Officer, Assistant Secretary for
Policy, Budget and Administration
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APPENDIX 1
SUMMARY OF COSTS CLAIMED AND AUDIT RESULTS
FISCAL YEAR
Cost Category Costs Claimed
Salaries
Fringe Benefits
Travel
Indirect Costs
Totals SI
$811,113
135,229
66,372
J.07.217
.119.931
1988
Costs Audited Costs Unsupported
$811,113 $811,113
135,229
12,260
107.217
SI. 065. 819
135,229
0
107.217
SI. 053. 559
SUMMARY OF
AUTHORIZED AND
OBLIGATED FUNDING
FISCAL YEARS 1985 THROUGH 1988
Fiscal Agreement
Year Number
1985 to DW1493-1623-01-6
1987
1988 DW1493-2791-01-0
Totals
Authorized
Funding
$1,349,852
1.253.500
S2. 603. 352
Obligated
gynding
$678,697
1.119.931
SI. 798. 628
Unobligated
£a, lance
$671,155
133.569
S804J724
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Appendix 2
Page 1 of 5
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
WASHINGTON, D.C. 20240
October 27, 1989
To: Office of Inspector General
From: Office of Environmental Project Review
Subject: Reimbursable Expenditures of Bivdjrcnmental Protection Agency
Superfund Money (16 Assignment NO. E-OS-OSS-20-89)
to your draft Memorandum Audit Report on the
of this office for reimbursable expenditures of
This is in
accounting
Environmental Protection Agency Super fund Money. This funding comes to
Interior, as well as other Departments and agencies, under an annual
Interagency Agreement, in accord with the Interagency Budget authorized by
the apprehensive QTvironoental Response, Compensation, and Liability Act
(CERCtA), commonly known as Superfund, and E.O. 12580.
The objectives of the audit, as stated in your introduction to the
ndum report, were to determine
(1) whether the Office maintained accurate, complete, and current
cost i^^'nlff for reimbursable Superfund projects and
(2) the reasonableness, alienability, and allocability of
claimed under the reimbursable njiemimt during fiscal year 1988.
In addition, you reviewed the disposition of unobligated balances in the
Office's Superfund account for fiscal years 1985 through 1988.
You have made four recommendations based on your
cds were not sufficient to show that the incu
that
red costs charged to the
only for Super fund-related work; and that a balance of
iinauthorized funding remained unobligated after the eviration date of past
years1 agreements. We oonrur with your conclusions and reocranendations.
This memorandus win set forth the plans of this office to implement your
recommendations.
we wish also, however, to suggest some additional background factors which
should be considered by other audiences when your report is submitted to
the Err/ircnnental Protection Agency and to the congress, in accordance with
the requirements of the Superfund Amendments and Reauthorization Act of
1986, and your own authorities.
The date for the requested response to the draft report was changed to
October 27, 1989, in discussions with your office. (We had understood
thirty days to be the normal period allowed for such responses, and we
received the report on or about October 6, 1989.)
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Appendix 2
page 2 of 5
As your reputt briefly notes, EPA enters into reimbursable agreements with
many of the Department of the Interior's bureaus and offices for a variety
of kinds of technical assistance. The Office of Environmental Project
Review has two different kinds of interagency agreements (lAGs) with EPA.
one kind of IAG consists of ten individual agreements between OEPR
headquarters and each of 10 EPA regions, executed under one standing
Memorandum of Understanding (HXJ) between the Department and the Office
of Waste Programs Eriforcement. The purpose of the MDU is to allow this
Department to meet EPA sjj^managemant and enforcement schedules by
conducting preliminary natural reauuixe) surveys to determine the potential
Interior natural resource interests at specifically requested and assigned
hazardous waste sites (usually but not necessarily those on the National
Priority List, now numbering just under 1200 sites). This MX and the 10
implementing agreements allow for review of existing documentation for a
particular site, with individual accounting, billing, and reimbursement £s
the bureaus involved in the survey. The basic purpose of these agreements
is to develop coordinated Department knowledge of possible natural resource
injury, if any, at sites, in timely fashion, so that a unified United
States position can be presented by the Department of Justice attorneys in
Federal enforcement litigation against responsible parties. Accounting
under these lAGs is by site, and is governed by a specific request from the
EPA region, reapcndnd to by a woricplaiyschedule from this office. This
site-specific work is accounted by site, using both cur project numbering
system, and EPA's site identification number.
The other IAG, the subject of the audit, is with the EPA Administrator's
Office, the Office of Solid Waste and Emergency Response. This IAG
implements Interior's part of the Interagency Budget rather than an
individual MDU. The Department of the Interior's portion of the
Interagency Budget consists of two elements, (1) resprrw management and
preparedness and (2) damage assessment capability hull fling (e.g. outreach
briefings for State, as wall as other Federal officials). This agreement
only funds activities that are Department-vide in scope, carried out at the
headquarters and regional levels. Similar activities may involve each of
the Department's nine bureaus as a part of their missions. However, bureau
costs are only charged to CEMXA ttfhen they are reimbursable incident-
specific activities, within EPA (or Coast Guard) fund managers' rules.
Also, of course, this Interagency Budget is totally separate from
Interior's own compliance activities relating to removal and remedial
actions at Interior facilities, which are funded by direct appropriations.
The Interagency Budget is provided by EPA, the Super fund manager, to ensure
the traditional key Federal agencies' support of the National Response
, implementing the National Contingency Plan (NCP). The Interagency
is Intended among other things to foster active membership in the
National nespomie lean (NRT) and the thirteen standing Regional Itoepcnae
(SRT). nenponsi mmvujmient support of EPA (and Coast Guard, also
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Appendix 2
Page 3 of 5
partially funded by the Xntsnagsncy Budget) includes not only
rraiiinMen to releases of hazardous materials (as well as discharges of
oil) but also other agencies' support for EPA's iBirmijeiiiHut of the Superfund
program addressing long term responses to releases from hazardous waste
sites, the basic rule for which is also the NCP.
We stress the idea that the role we are implementing under this agreement
is to assist in the establishment and maintenance of a stxmy, effective
nationwide system, with appropriate procedures bringing to bear all
necessary or appropriate Federal jurisdictions and expertise in a
coordinated and cost effective manner, whatever the rmporoo required. It
should be pointed out that in a contingency system, the flow of work is
unpredictable — when an incident occurs, we respond at that time for
whatever hours are necessary to cope with the situation. Tne preparedness
for effective response, updating and exercising plans, writing and
distributing guidance and other technical information transfer, reaching
out to other Federal agencies, State and local responders, improving
ccBBBjnications networks, etc. must be managed in the time between the
events, or threats of incidents. Kay portions of this work are done by
telephone, although there is considerable travel involved because of the
breadth of the regions we cover from our three parson regional offices, and
the range of Interior functions we represent, including access to, the
expertise or jurisdiction of nine bureaus as well as the crosscutting
elements of the Office of the Secretary.
While the audit covers only this interagency agreement transmitting the
interagency Budget funds for support of the response system, we think it is
important to stress the difference between the two kinds of agreements. We
are confident that the audit staff has come to understand the difference,
but feel that the wider audience for the final report might find this more
detailed background useful in understanding which of OEFR's several
Superfund activities are targeted by the recommendations of the Inspector
General. We also underscore the different purposes and outcomes of these
agreements to indicate that we clearly understand the difference between
two different methods of accounting — site specific va. overall piuuiam or
system management.
By contrast with the task* specified under the FNRS-WU, the role of our
office in the Interagency Budget work is very broad and depends much on the
day-to-day initiative and judgment of CEPR staff, rather than the terms of
a specific narrow MDU. Our charter, along with that of thirteen other
participating Federal agencies, is contained in the NCP, at last printing a
document of 126 pages in the Federal Register. In effect, our entire
effort consists of activities that are generally categorized as program
overhead costs, rather than site-specific costs. In general, the tasks
involve administration and irmmijnm* of the overall complex of
contingency planning and preparedness and response, not only making sure
Interior interests are lejiiesenfeil or that specific Interior jurisdictions
or expertise are readily accessible for EPA and system support, but also
assisting EPA and Coast Guard, the co-chair agencies of the NRT and BRZS,
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Appendix 2
Page 4 of 5
in bain? mam that the overall national response system functions
effectively. For example, because of tht natur* of OEPR staff experience,
we currently chair imnmjeHMit or steering acn&ittees at the national and
regional taan levels, and head work group* developing NRT work plans and
periodic reports, among other projects.
The conclusions of the In
±or General are that
— the allocations of salaries and fringe benefits were not
adequately supported by documentation such as tine and attendance records
allocating the budgeted FIE among the personnel sharing the work in OEPR
for headquarters and nine field
ting were
headquarters and nine field locations.
— the allocation of indirect
offices were not adequately documented
— unobligated funds at the end of each fiscal year's
not specifically released for return to EPA, leaving an unobligated
balance.
We concur with these conclusions.
We note, however, that one statement under Results may be misleading when
OEFR's implementation of the recommendations is reviewed.
"Consequently, the Agency's (EPA's) efforts to recover claimed
costs...from responsible parties may be jeopardized."
As the background discussion above makes clear, Interagency Budget costs
are not site-specific, thus to the extent they are recoverable from
responsible parties, it would be through EPA's method of accounting for its
overhead. However, the time and attendance record recommended by the Audit
Report should amply A^**^**- our Superfund ocraniti&ents despite the lack of
attribution to specific sites.
1. "Reconstruct the expenditures (direct and indirect) chargeable to the
Superfund interagency mji mum it for fiscal year 1988. the
Environmental Protection Agency should be reimbursed for costs which
cannot be supported."
He concur with the recommendation.
supported, fie have begun the
expenditures
Me are confident that all costs can be
of reconstructing documentation of
Target completion date for
December 31, 1989
instruction of FY 1988 «
Responsible official: Cecil Hoffmann
Senior Staff — super fund
2. "Establish a time and attendance reporting system within the Office of
QTvironwental Project Review to ensure that employees' time charges
are accurately *1 lr*"Mttwi to the Office's Snjei'fuiil account."
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Appendix 2
Page 5 of 5
m haw" ***** to d«v»lcp
procedures an already being follow^ by affected OEPR staff
effective as of October 2, 1989 (beginning of FY 1990).
Target cospletion date for final guidance on tine and attendance reportim
system : ~*~~ ^*
31, 1989 Responsible official: Cecil Hoffmann
3. "Perform a financial analysis of the Office of Bwirornental Project
Review's indirect expenditures annually in order to congute the costs
incurred for Super fund-related purposes only."
He concur with the reocmnendaticn. One analysis is being planned.
Target coopletion date:
Decanter 31, 1989 Responsible official: OscH Hoffmann
4. "Establish procedures which ensure that all unobligated funding
regaining from expired Superfund interagency agreements is returned to
the Agency upon the closeout of obligations posted to the accounts or
request that the Bwironroental Protection Agency authorize the
carryover of the funds to a current Superfund agreement.11
He concur with the reocmnendation.
Target ocnpletion date for system, plus **i»i*nfr covering past years:
December 31, 1989 Responsible official: Jon Deason
Director, OEPR
We appreciate the opportunity to ajimtaiL on the draft report. He also very
much appreciate the sound iMn*gBm°*^' advice incorporated in the audit
report's conclusions and reocanendations, and the thorough professionalism
of your staff in their conduct of this audit. You have made this a helpful
and constructive experience for our office.
Jonathan P. Deason
Director
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APPENDIX 3
STATUS OF AUDIT REPORT RECOMMEMDATTOMS
Finding/Recommendation
Reference gtatus Action Required
1-4 Resolved None
13
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APPENDIX 4
Finding
Allocation of Costs
Unobligated Funding
Total
CLASSIFICATION OF MONETARY AMOUNTS
Unsupported
Costs
$1,053,559
SI.053.559
Funds To Be Put
To Better Use
S8Q4.724
S804.724
14
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SS&*
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