OFFICE OF INSPECTOR GENERAL
( dlcilyst for /tnprarinff ihc Etn'iroiiniettt
Attestation Report
Association of State and Interstate
Water Pollution Control
Administrators Incurred Costs for
Seven EPA Assistance Agreements
Report No. 2006-4-00122
July 31,2006
EPA
350/
2006-
4-
OOL22
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Report Contributors: Keith Reichard
Richard Valliere
Abbreviations
CFR Code of Federal Regulations
EPA U.S. Environmental Protection Agency
OIG Office of Inspector General
OMB Office of Management and Budget
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2006-4-00122
July 31, 2006
Cntitly\tff>r Iniftrin'insf (he Environment
Association of State and Interstate Water
Pollution Control Administrators Incurred
Costs for Seven EPA Assistance Agreements
What We Found
The Association did not comply with the financial and program management
standards and the procurement standards promulgated in Title 40 Code of Federal
Regulations (CFR), Subchapter B, Part 30. Specifically, the Association (1) could
not provide support for any of its general journal entries; (2) included duplicate
recorded costs in its accounting system; (3) could not always trace grant draws to
the accounting records; (4) could not always support labor charged to the EPA
grants; (5) could not support the recorded indirect costs; (6) did not record all of
its program income; (7) did not have adequate written procedures for determining
reasonable, allocable, and allowable costs; (8) drew EPA grant funds in excess of
the funds needed; and (9) did not complete the required single audits for fiscal
years ended June 30, 2004, and June 30, 2005.
The Association's procurement system did not comply with the procurement
standards. The Association awarded contracts to the America's Clean Water
Foundation, contrary to the requirements of Title 40 CFR 30.42 and 30.45.
Because the Association did not adequately document its costs and did not
comply with the EPA regulations, we questioned $1,883,590 paid to the
Association.
What We Recommend
We recommend that EPA (1) recover $1,883,590 paid unless the Association is
able to reconstruct its accounting records to meet the minimum financial
management standards required in Title 40 CFR 30.21; (2) disallow contract costs
procured in violation of Title 40 CFR 30.42 and 30.45; (3) rescind provisional
indirect cost rates for the fiscal years ended June 30, 2005, and June 30, 2006;
(4) stop work on all active grants and do not award any new grants until EPA has
assurances that the Association meets minimum financial management
requirements; (5) keep the Association on the reimbursement payment method
until the Association meets minimum financial management requirements, settles
current Federal liabilities, and repays all disallowed costs; and (6) require the
Association to comply with single audit requirements for fiscal years ended
June 30, 2004 and June 30, 2005. The Association stated many improvements
have already been implemented and will continue to work to implement and
address any remaining concerns.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
% .XU^Z 5 WASHINGTON, D.C. 20460
^i.
OFFICE OF
INSPECTOR GENERAL
July 31,2006
MEMORANDUM
SUBJECT: Association of State and Interstate Water Pollution Control Administrators
Incurred Costs for Seven EPA Assistance Agreements
Report No. 2006-4-00122
TO: Richard Kuhlman
Director, Grants Administration Division
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the
problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determination on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
On April 13, 2006, we issued a draft report to the Association of State and Interstate Water
Pollution Control Administrators (Association) for comments. The Association responded and
generally agreed with our findings, and outlined numerous corrective actions completed or
underway. The Association's response and the OIG's comments are included in Appendix B.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $88,404.
Action Required
In accordance with EPA Manual 2750, Chapter 3, Section 6(f), you are required to provide us
your proposed management decision for resolution of the findings contained in this report before
any formal resolution can be completed with the Association. Your proposed decision is due on
November 28,2006. To expedite the resolution process, please email an electronic version of
your proposed management decision to reichard.keith@epa.gov.
We have no objections to the further release of this report to the public. For your convenience,
this report will be available at http://www.epa.gov/oig. We want to express our appreciation for
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the cooperation and support from your staff during our review. If you have any questions about
this report, please contact Keith Reichard at (312) 886-3045.
Sincerely,
rTRoderick
Acting Inspector General
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Association of State and Interstate Water Pollution Control Administrators Incurred
Costs for Seven EPA Assistance Agreements
Table of Contents
Background 1
Independent Auditor's Report 4
Results of Examination 6
Recommendations 12
Status of Recommendations and Potential Monetary Benefits 13
Schedule 1: Comparison of Grant Payments with Incurred Costs 14
A Scope and Methodology
B Recipient Response and OIG Comments.
C Distribution
15
16
26
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The U.S. Environmental Protection Agency (EPA) awarded seven assistance agreements1
(grants) to the Association of State and Interstate Water Pollution Control Administrators
(Association) totaling $2,020,696. The Association, which is located in Washington, DC, was
formed in 1961, and is a Section 501(c) (3) not-for-profit organization (per Internal Revenue
Code requirements). The following table provides some basic information about the authorized
project periods and funds awarded under each of the seven grants:
X82919901
08/09/2001
$125,000
$125,000
07/28/2003
07/01/2001-10/01/2003
X82973401
05/02/2002
$240,000
$171,339
10/12/2005
04/01/2002-03/31/2006
X783105101
06/09/2003
$360,000
$360,000
05/24/2004
05/15/2003-05/14/2006
CP83106901
08/11/2003
$200,000
$200,000
05/05/2004
07/01/2003-06/30/2005
CP83107001
08/18/2003
$440,000
$440,000
05/12/2005
06/01/2003-05/30/2006
X783164601
03/24/2004
$206,892
$206,892
11/15/2004
02/19/2004-08/19/2005
X783173901
09/24/2004
$448,804
$380,359
11/01/2005
05/15/2004-05/14/2006
Total
$2,020,696
$1,883,590
* The EPA share for all seven grants was 100 percent of allowable project cost.
All seven grants were awarded under the authority of the Clean Water Act. The scopes of work
for the seven agreements are summarized as follows:
Agreement X82919901: Helped States improve monitoring programs required by the Clean
Water Act for a full range of purposes including (1) improving the accuracy and completeness of
impaired waters lists and comprehensive State water quality assessments reports,
(2) streamlining the reporting requirements, and (3) enhancing public understanding and use of
the reports.
Agreement X82973401: Provided a State/Federal work group to improve water quality
standards development and implementation.
Agreement X783105101: This 3-year grant provided $360,000 for technical support to assist
States, Indian Tribes, and territories in complying with the total maximum daily load
1 EPA's assistance to the Association was either a grant or cooperative agreement. For reporting purposes, all
assistance will be referred to as a grant.
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requirements. The scope of work is identical to Grant X783173901, listed below, and has an
overlapping project period.
Agreement CP83106901: The purpose of this grant was to improve integrating point and
nonpoint source control problems on a national scale through improved communications and
coordination with State water quality agencies responsible for implementing water quality
monitoring and assessment, and data management requirements.
Agreement CP83107001: Created State work groups for (1) permit program integrity and (2)
prioritization and streamlining. The grant also provided a forum for national pollutant discharge
elimination system managers to conference with EPA to address priority State concerns with
point source-related water quality issues.
Agreement X783164601: Provided planning, support, and facilitation for three regional forums
to create and enhance a multi-agency approach to implement nonpoint source pollution
management measures at the watershed level.
Agreement X783173901: This 2-year grant provided $448,804 for technical support to assist
States, Indian Tribes, and territories in complying with the total maximum daily load
requirements. This grant provided the same services and overlaps the project period for Grant
X783105101 listed above.
Single Audit Activity
On September 12, 2005, our office issued the Association's single audit report for the year ended
June 30, 2003. Nonfederal entities that expend $300,000 ($500,000 for fiscal years ending after
December 31, 2003) or more in a year in Federal awards are required by Title 40 Code of
Federal Regulations (CFR) 30.26 to have a single audit conducted in accordance with applicable
requirements of the Office of Management and Budget (OMB) Circular A-l 33. The single audit
report disclosed four findings that pertained to EPA grants:
1. The Association did not have adequate procedures in place to accurately track and record
grant balances. The auditor required significant adjustments after the end of the fiscal
year to properly report grant balances.
2. The Association's books of accounts were not accurately maintained on an accrual basis.
The auditor required significant adjustments to accrue account balances in accordance
with generally accepted accounting principles. As a result, the audited financial
statements reflected results that were significantly different from internal management
reports.
3. There were discrepancies in the net disbursements reported on the Financial Transaction
Reports, SF-272, for several grants for the reporting periods ended December 31,2002,
and June 30, 2003. Cumulative disbursements reported for the same grants did not
reconcile with the general ledger for these same periods.
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4. The Association did not have adequate procedures to ensure that payments to hourly
employees were correct and adequately supported. Timesheets for several off-site
employees were not signed by either the employee or a supervisor with knowledge of the
activities.
The single audit report disclosed that as of June 30, 2003, the Association drew advances from
EPA in excess of expenditures resulting in a payable of $141,289 due EPA.
Subsequent to the completion of the single audit for the fiscal year ended June 30, 2003, the
Association hired Raffa & Associates to complete the Association's single audit for the year
ended June 30, 2004. However, Raffa & Associates discontinued audit work after identifying
accounting irregularities that might extend back to prior years, including the year ended June 30,
2003. Subsequently, the Association contracted with Raffa & Associates to provide accounting
services and advice. After identifying the accounting irregularities, both the managing partner
for Raffa & Associates and the Association's Executive Director met with EPA officials to report
the accounting irregularities. On July 18, 2005, after being notified of the accounting
irregularities, EPA temporarily placed the Association on the "reimbursement" method of
payment as authorized by Title 40 CFR 30.14 and 30.22(h)(l). EPA took this action pending
completion of corrective action to comply with Title 40 CFR Part 30.
Consequently, the single audit for the fiscal year ended June 30, 2003, remains unresolved, and
the Association has not completed the single audits for the years ended June 30, 2004, and June
30, 2005.
To assist the reader in obtaining an understanding of the report, key terms are defined below:
Incurred Costs:
Questioned Costs:
Expenses or outlays identified by the Association and
recorded in the Association's accounting system.
Costs that are (1) contrary to a provision of a law,
regulation, agreement, or other documents governing the
expenditures of funds; or (2) not supported by adequate
documentation.
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We have examined the Schedules of Budgeted & Reported Outlays by Assistance Agreement
prepared by the Association for each of the seven EPA grants: X82919901, X82973401,
X783105101,CP83106901,CP83107001,X783164601,andX783173901. Preparing these
schedules was the Association's responsibility. Our responsibility is to express an opinion on
these schedules to determine the allowable costs incurred in accordance with the terms and
conditions of the grants and applicable EPA regulations.
We conducted our examination in accordance with the Government Auditing Standards issued by
the Comptroller General of the United States, and the attestation standards established for the
United States by the American Institute of Certified Public Accountants. We also followed the
guidelines and procedures established in the Office of Inspector General Project Management
Handbook, dated January 14,2005. We examined, on a test basis, evidence supporting the costs
incurred, and performed such other procedures as we considered necessary in the circumstances
(see Appendix A for details). We believe that our examination provides a reasonable basis for
our opinion.
In our opinion, because of the effects of the deficiencies discussed in the Results of Examination,
the Schedules of Budgeted & Reported Outlays by Assistance Agreement do not present fairly, in
all material respects, the allowable costs incurred in accordance with the terms and conditions of
the grants and applicable EPA regulations. Accordingly, we questioned $1,883,590 paid to the
Association because the Association's financial management system was not adequate to account
for grant funds in accordance with Title 40 CFR Part 30.
Office of Inspector General
U.S. Environmental Protection Agency
January 20,2006
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Financial and Program Management, and Procurement Systems Did
Not Comply with Standards
The Association did not comply with the financial and program management standards and the
procurement standards promulgated in Title 40 CFR, Subchapter B, Part 30. Because the
Association did not to meet its fiduciary responsibilities under the regulations, the incurred costs
are not allowable.
When applying for grant assistance, the Association certified that it had the institutional,
managerial, and financial capability to ensure proper planning, management, and completion of
the project described in the grant application, and that it would comply with all applicable
requirements of all Federal laws, executive orders, regulations, and policies governing the grant.
EPA's administrative grant regulations for nonprofit organizations are codified in Title 40 CFR,
Subchapter B, Part 30. Under the provisions of Title 40 CFR Part 30, the Association was
required to follow (1) the financial and program management standards codified in Title 40 CFR
30.21 through 30.28, and (2) the procurement standards codified in Title 40 CFR 30.41 through
30.48.
The Association's financial and program management system (1) could not provide support for
any of its general journal entries; (2) included numerous duplicate recorded costs in its
accounting system; (3) could not always trace grant draws to the accounting records; (4) could
not always support labor charged to the EPA grants; (5) could not support the recorded indirect
costs; (6) did not record all of its program income in the general ledger; (7) did not have
adequate written procedures for determining reasonable, allocable, and allowable costs; (8) drew
EPA grant funds in excess of the funds needed; and (9) did not complete the required single
audits for fiscal years ended June 30, 2004, and June 30, 2005.
The Association's procurement system did not comply with the procurement standards. The
Association awarded contracts to the America's Clean Water Foundation, a related organization,
without competition or a cost analysis contrary to the requirements of Title 40 CFR 30.42 and
30.45.
The provisions of Title 40 CFR 30.62 provides that if a recipient does not comply with the terms
and conditions of an award, whether stated in a Federal statute, regulation, assurance,
application, or notice of award, EPA may disallow all or part of the cost of the activity or action
not in compliance. Because the Association did not adequately document its costs and did not
comply with the grant regulations, we questioned $1,883,590 paid to the Association. Details on
our findings follow.
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Unsupported General Journal Entries
The Association did not provide any documentation to support and sufficiently explain
any of its general journal entries for any grants as required by Title 40 CFR 30.21. The
provisions of Title 40 CFR 30.21 (b) (7) require the Association's financial management
system to have accounting records that are supported by source documentation. The
Association used general journal entries to (1) record accruals such as payroll costs, (2)
reverse posting entries, (3) correct errors made in recording cash receipts or expenditures,
(4) allocate indirect costs, (5) record revenue, and (6) post transactions which were not
recorded in the general ledger by other means. However, the Association could not
provide supporting documentation to explain and support these general journal entries.
For the audit period from July 1, 2001, through November 30, 2005, the Association
could not support or justify any general journal entries. For example, during the fiscal
year ended June 30, 2005, the Association made a general journal entry to record almost
$255,000 in labor and fringe benefit costs incurred during a 5-month period beginning in
January 2005. However, the Association could not provide the supporting documentation
for the general journal entry. The Association's Executive Director indicated that the
accounting was not done timely because the Association's Comptroller passed away
during the first part of 2005. The Executive Director also could not explain why the
supporting documentation for any of the general journal entries was not available. As a
result, the Association did not have sufficient records to support the allowability of the
incurred costs.
Duplicate Recorded Costs
During the fiscal year ended June 30, 2005, the Association used two different databases
to record grant expenditures in the general ledger. Based on our review of these
databases, we noted numerous duplicate recorded costs. The provisions of Title 40 CFR
30.21 require the Association to maintain a financial management system that is accurate,
current, and complete, and provide for the effective control over and accountability for all
funds. The Executive Director could not explain why the dual data bases were used, and
why there were duplicate recorded costs. Because of the duplicate recorded costs, the
Association's financial management system was not accurate, and the incurred costs were
incorrect and overstated.
Unsupported Grant Draws
Contrary to the provisions of Title 40 CFR 30.21, the Association could not always show
the receipt of Federal cash draws in the Association's accounting records. The provisions
of Title 40 CFR 30.21 require that the Association's financial management system
provide records that identify adequately the source and application of funds for federally-
sponsored activities. For example, the Association could not show where almost
$378,804 of Federal grant funds drawn under EPA grant X783173901 were recorded in
the Association's accounting records. The Executive Director could not explain the
reason why grant draws were not properly recorded in the accounting system. Further, in
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the fiscal year ended June 30, 2003,2 the Association's single auditor reported as a
material weakness that the Association did not have adequate procedures in place to
accurately track and record grant balances.
Unsupported Labor Costs
The Association could not support some of its labor costs. From July through October
2004, the Association recorded labor charges twice in the accounting system. The
duplicate labor transactions were caused by using two different databases to record grant
expenditures in the general ledger.
We also noted that for a 5-month period from January through May 2005, all labor costs
were recorded in the accounting system using a single general journal entry. As stated
above in the section entitled "Unsupported General Journal Entries," the Association did
not have any documentation to support and sufficiently explain the general journal entries
for recorded labor.3 Further, in reviewing the labor charges, the Association could not
provide all the required labor activity reports (timesheets). The provisions of Title 40
CFR 30.21 (b) (7) require the Association's financial management system to have
accounting records that are supported by source documentation. The provisions of Title
40 CFR 30.21 also require the Association to maintain a financial management system
that is accurate, current, and complete, and provide for the effective control over and
accountability for all funds. Because the Association's accounting transactions were
inaccurate and unsupported, the Association's financial management system does not
comply with the provisions of Title 40 CFR 30.21.
While we cannot verify labor charges, the Association did require employees to prepare
labor activity reports which met OMB labor documentation requirements. Therefore, if
the Association is able to locate all of its timesheets, it may be able to reconstruct the
allowable labor costs for each grant.
Unsupported Indirect Cost Rates
The Association could not support the recorded indirect costs. The Association recorded
indirect costs in the general ledger using general journal entries. As discussed above in
the section entitled "Unsupported General Journal Entries," the Association did not have
any documentation to support and sufficiently explain its general journal entries for the
indirect costs. Accordingly, the Association could not demonstrate how the indirect cost
rate was calculated or what costs were included in the indirect rate.
The Association did not prepare,4 submit, or receive approved final indirect cost rates
from EPA for the fiscal years ended June 30,2001, through June 30,2005, as required by
the applicable regulations. The provisions of Title 40 CFR 30.27 require non-profit
2 The single audit report was submitted by the Association to the Federal Audit Clearinghouse on January 19,2005.
3 The journal entries also included fringe benefits such as PICA and Medicare.
4 On January 19,2006, the Association emailed the O1G a worksheet of what appears to be the Association's fiscal
year 2003 provisional indirect rate. No explanation was provided with the spreadsheet.
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organizations to follow the provisions of OMB Circular A-122 for determining allowable
costs. OMB Circular A-122, Attachment A, subparagraph E (2), requires a nonprofit
organization to submit an initial indirect cost proposal to the cognizant Federal agency no
later than 3 months after the effective date of the award. The Circular also includes the
requirement that organizations with previously negotiated indirect cost rates must submit
a new indirect cost proposal to the cognizant agency within 6 months after the close of
each fiscal year.
On behalf of EPA, the U.S. Department of the Interior's National Business Center
(Center) negotiated provisional indirect rates for the years ended June 30, 2005, and June
30, 2006. However, the Center informed the Association that a final rate for 2005 would
not be negotiated until the Association submitted a revised proposal containing actual
costs, based on, and reconciled to, financial statements that meet the requirements of the
Single Audit Act of 1984. To date, the Single Audit for 2005 has not been completed,
and the Association has not submitted a revised final indirect cost rate proposal for 2005
to either EPA or the Center.
Under Reported Program Income
The Association underreported program income under EPA grants CP83107001,
X783164601, and CP83106901. The Association held various summits, forums, and
other conferences, and earned program income from holding these meetings. The
Association recorded $54,256 for program income under the three grants and reduced the
grant costs by $54,256. However, the Association provided reports which show that the
Association earned program income of at least $85,751 for the three grants. Thus, the
Association's general ledger does not accurately identify all of the program income
earned. The Association did not have sufficient controls to ensure all the program
income was properly recorded. By not properly recording the program income, the
Association's financial management system was not accurate, and the incurred costs may
have been overstated for EPA grants CP83107001, X783164601, and CP83106901.
Written Accounting Procedures Did Not Meet Standards
The Association did not have adequate written accounting procedures for identifying
direct and indirect costs, and the basis for allocating such costs to projects, as required by
the regulations. Title 40 CFR 30.2l(b) (6) states that the Association's financial
management system shall provide written procedures for determining that costs are
reasonable, allowable, and allocable in accordance with the Federal cost principles and
the terms of the agreement.
In developing written procedures, the Association needs to address the requirements of
OMB Circular A-122. Specifically, the Association needs to address (1) the allocability
of costs (Attachment A, paragraph A.4), (2) the three allocation methods authorized for
indirect costs (Attachment A, paragraph D), (3) definition of direct and indirect costs
(Attachment A, paragraphs B and C), and (4) the negotiation and approval of indirect cost
rates (Attachment A, paragraph E).
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As discussed above in the section entitled "Unsupported Indirect Costs Rates," the
Association did prepare provisional indirect rates for fiscal years ended June 30,2005,
and June 30, 2006; however, the Association could not explain, and did not have written
accounting procedures to identify, what costs were actually included in the indirect cost
rate calculations. Consequently, the Association could not demonstrate that the proposed
indirect costs were allowable in accordance with OMB Circular A-122.
For example, we noted that during the fiscal year ended June 30, 2005, the recipient
accounted for membership services as an indirect cost in its accounting system. The
provisions of OMB Circular A-122, Attachment A, subparagraph B (4), provides that the
costs of activities performed primarily as a service to members, clients, or the general
public when significant and necessary to the organization's mission, must be treated as
direct costs whether or not allowable and be allocated an equitable share of indirect costs.
Since the Association could not explain to us what costs were included in the indirect
cost rate calculation, we were unable to determine whether the Association correctly
removed the membership services from the indirect cost pool and appropriately classified
the membership services as direct costs. Without written policies and procedures to
distinguish between direct and indirect expenses, the Association could not properly
support either the direct or indirect costs reported for the EPA agreements.
Noncompliance with Cash Management Requirements
For the year ended June 30, 2003, the Association's single auditor reported that the
Association did not comply with the Federal cash management requirements. The single
auditor disclosed that the Association received advances in excess of expenditures
totaling $141,289. The single auditor reported that the reason for the excess advances
was that the Association did not properly record grant draws. In addition, cash receipts
were incorrectly posted to the wrong grant in the accounting records, resulting in the
balances of the grants being misstated.
The provisions of Title 40 CFR 30.22 provide that payment methods shall minimize the
time elapsing between the transfer of funds from the United States Treasury and the
issuance or redemption of checks, warrants, or payment by the recipient. Cash advances
shall be limited to the minimum amounts needed and be timed to be in accordance with
the actual, immediate cash requirements of the recipient organization in carrying out the
purpose of the approved program or project.
10
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U.S.
1200 Pen.*>ivrn;.L*
3".1- Library
Single Audits Not Completed
The Association did not obtain single audits for the fiscal years ended June 30, 2004, and
June 30, 2005, as required by Title 40 CFR 30.26. Title 40 CFR 30.26 provides that
nonprofit organizations are subject to the audit requirements of OMB Circular A-133.
OMB Circular A-133, Subpart B, requires nonfederal entities that expend $300,000
($500,000 for fiscal years ending after December 31,2003) or more in a year in Federal
awards to have a single audit conducted in accordance with applicable requirements of
the Circular. The certified public accountant firm contracted to conduct the Association's
single audit for the fiscal years ended June 30, 2004, discontinued work after finding
accounting irregularities. On July 18,2005, after being notified of the accounting
irregularities, EPA temporarily placed the Association on the "reimbursement" method of
payment, as authorized by Title 40 CFR 30.14 and 30.22(h)(l). EPA took this action
pending completion of corrective action to comply with Title 40 CFR Part 30.
Improper Procurement
Under Grants X783105101 and X7 83173901, the Association awarded two sole source
fixed price contracts to the America's Clean Water Foundation, a related nonprofit
organization.5 These contracts required the Foundation to provide "Circuit Rider"
services to the Association. The first contract, under grant number X783105101, was for
$284,514.6 The second contract, under grant X783173901, was for $368,524.7 Federal
regulations (Title 40 CFR 30.42) provide that no employee, officer, or agent shall
participate in the selection, award, or administration of a contract supported by Federal
funds if a real or apparent conflict of interest would be involved. There was a conflict of
interest since both the Association's Executive Director and Deputy Director were paid
employees of both organizations--the Association and the America's Clean Water
Foundation~and they both signed the contracts. In addition, the Association did not
conduct a cost analysis of the two contracts in violation of Title 40 CFR 30.45. Without
competition and the required cost analysis, there is no assurance that the prices paid were
reasonable.
The Association also entered into shared service agreements for financial and
administrative support services. These agreements were fixed price and identified as
"indirect expenses for ASWIPCA." The value of these service agreements for a 2-year
period ending June 30, 2005, was $152,099. These agreements also violate Title 40 CFR
30.42 and 30.45.
5 The two nonprofit organizations are related through common management, and share office space, the telephone
system, and office equipment.
6 The Association's Schedule of Budgeted & Reported Outlays by Assistance Agreement reported $308,224 for this
contract.
7 The Association's Schedule of Budgeted & Reported Outlays by Assistance Agreement reported $245,682 for this
contract.
11
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We recommend that the Director for the Grants Administration Division:
1. Recover $1,883,590 unless the Association is able to:
• Reconstruct its accounting records and exclude all duplicate recorded costs from
its accounting records.
• Provide explanations and support for all general journal entries.
• Identify and record all grant draws and program income in its accounting system.
• Ensure that all transactions are supported by adequate source documentation
including labor activity reports.
• Prepare and submit fringe and indirect cost rate proposals for fiscal years 2001
through 2005 in accordance with OMB Circular A-122.
• Develop written procedures to determine reasonable, allowable, and allocable
costs in accordance with OMB Circular A-122.
• Submit interim or final financial status reports for all seven grants included in this
report. When submitting these status reports, include a schedule of reported
outlays for each grant similar to those included in this report.
2. Disallow contract costs procured in violation of Title 40 CFR 30.42 and 30.45.
3. Rescind provisional indirect cost rates for fiscal years ended June 30, 2005, and
June 30, 2006.
4. Stop work on all active grants and do not award any new grants until EPA has
assurances that the Association meets minimum financial management requirements.
5. Keep the Association on the reimbursement payment method until the Association
meets minimum financial management requirements, settles current Federal
liabilities, and repays all disallowed costs.
6. Require the Association to comply with single audit requirements for fiscal years
ended June 30, 2004, and June 30,2005.
12
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFfTS(in$OOOs)
See. Page
No. No.
Subject
Status1
Action Official
Planned
Completion
Date
12 Recover $1,883,590 unless Die Association is able U Director, Grants
to (a) reconstruct its accounting records and Administration Division
exclude duplicate recorded costs, (b) provide
explanation and support for all general journal
entries, (c) identify and record all grant draws and
program income in its accounting system, (d)
ensure that all transactions are supported by
adequate documentation including labor activity
reports, (e) prepare and submit fringe and indirect
cost rate proposals for fiscal years 2001 - 2005 in
accordance with OMB Circular A-122, (f) develop
written procedures to determine reasonable,
allowable, and allocate costs in accordance with
OMB Circular A-122, and (g) submit interim and
final financial status reports, including a schedule
of reported outlays for each grant similar to those
included in this report.
12 Disallow contract costs procured in violation of U Director, Grants
40 Cf R 30.42 and 30.45. Administration Division
12 Rescind provisional indirect cost rates for fiscal U Director, Grants
years ended June 30,2005. and June 30.2006. Administration Division
12 Stop work on alt active grants and do not award U Director, Grants
any new grants until EPA das assurances that the Administration Division
Association meets minimum financial management
requirements.
12 Keep the Association on the reimbursement U Director, Granls
payment method until trie Association meets Administration Division
minimum financial management requirements,
settles current Federal liabilities, and repays all
disallowed costs.
12 Require the Association to comply with single audit U Director, Grants
requirements for fiscal years ended June 30,2004, Administration Division
and June 30,2005.
Incurred Agreed To
Amount Amount
$1,884
(a)
(a)
(a) The values for the questioned contract and indirect costs are $661,105 and $89,515, respectively, and are included in recommendation 1 to recover
$1,883,590.
1 0 - recommendation is open with agreed-to corrective actions pending;
C = recommendation is aosed with all agreed-lo actions completed;
U = recommendation is undecided with resolution efforts in progress
13
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Appendix A
Scope and Methodology
We performed our examination in accordance with the Government Auditing Standards, issued
by the Comptroller General of the United States, and the attestation standards established by the
American Institute of Certified Public Accountants. We also followed the guidelines and
procedures established in the Office of Inspector Genera! Project Management Handbook, dated
January 14, 2005.
We conducted this examination to express an opinion on the incurred costs, and determine
whether the recipient complied with all applicable laws and regulations, as well as any special
requirements under the agreement. We conducted our field work from January 9, 2006, through
January 20, 2006.
In conducting our examination, we performed the following procedures:
• We reviewed grant and project files to obtain background information on the Association
and the agreement.
• We interviewed recipient personnel to understand the accounting system and the
applicable internal controls as they relate to the reported outlays.
• We reviewed the most recent single audit reports to identify issues which may impact our
examination.
• We reviewed the recipient's internal controls specifically related to our objectives.
• We performed tests of the internal controls to determine whether they were in place and
operating effectively.
We examined the incurred costs on a test basis to determine whether the costs were adequately
supported and eligible for reimbursement under the terms and conditions of the agreements and
Federal regulations and cost principles.
15
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Appendix B
Recipient Response and OIG Comments
June 29, 2006
Mr. Michael A. Rickey
Director, Assistance Agreement Audits
U.S. Environmental Protection Agency
Office of the Inspector General
77 West Jackson Blvd
Chicago, IL 60604-3507
Re: ASIWPCA Response to Office of Inspector General Draft Attestation Report
Draft Attestation Report on EPA Grants X82919901, X82973401, X783105101,
CP83106901, CP83107001, X783164601, and X783173901
Report No. 2006-00620
Dear Mr. Rickey:
The Association of State and Interstate Water Pollution Control Administrators
(ASIWPCA) appreciates the opportunity to respond to the Office of Inspector General's
(OIG) draft audit report entitled, Association of State and Interstate Water Pollution
Control Administrators Incurred Costs For Seven EPA Assistance Agreements (draft
report) dated April 13, 2006.
Please find our detailed response attached which addresses and clarifies the
information in OIG's draft report. Although we understand that not all of the issues
raised in the draft report will be resolved before becoming final, the ASIWPCA Board
asks that the OIG will reconsider aspects of its opinion based on the response provided.
Specifically, the Association is requesting that incurred costs identified as questioned
costs by OIG in the draft report be deemed unresolved, until such time as GAD has
been given the chance to review the entire record. The Association also requests that
the final report be tempered with an acknowledgement of the limitations of a general
ledger for financial analysis when embezzlement has occurred.
For those areas where OIG has identified weaknesses, ASIWPCA has revised its
procedures and systems to ensure current and future compliance with Federal
regulations. These have also been identified in the attached detailed response.
Again, thank you for the opportunity to reply to these findings.
16
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Sincerely,
Karen Gautreaux
ASIWPCA President and
Deputy Secretary, Louisiana DEQ
cc: ASIWPCA Board of Directors
Linda Eichmiller, ASIWPCA
Luis Luna, EPA
Howard Corcoran, EPA
Richard Kuhlman, EPA
Michael Mason, EPA
Bill Roderick, EPA
Mark Bialek, EPA
Melissa Heist, EPA
Eileen McManon, EPA
John Manibusan, EPA
Ben Grumbles, EPA
James Hanlon, EPA
Enclosure
-••.,,J
17
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ASIWPCA RESPONSE
Draft Attestation Report:
Association of State & Interstate Water Pollution Control Administrators
Incurred Costs for Seven USEPA Assistant Grants
Summary
The Association of State & Interstate Water Pollution Control Administrators
(Association) is hopeful that the Office of Inspector General (OIG) will revise its
recommendation to recover the entire amount of grant monies utilized by the
Association to complete the work on seven grants. OIG has identified several areas
where the Association can improve its processes and procedures. Many improvements
have already been implemented and we will continue to work with the Office of Grants &
Disbarment (GAD) to implement and address any remaining concerns.
We have made great strides in mitigating the damage caused by the bookkeeper who
embezzled Association funds. We are well along in our effort to rebuild all direct
expenses for USEPA grants with backup that provides much greater detail than the
general journal entries. We have removed the duplicate entries caused by the use of
two data systems. We are working to identify and record all grant draws and other
program income. All of our program activity reports (timesheets) back to 2002 have
been consolidated and the data entered into spreadsheets. We are working with GAD to
determine the most cost effective way to deal with the final indirect cost rate proposals.
Once our financial rebuild is completed we will be able to provide final financial status
reports for all seven grants.
The Association recognizes the report raises many legitimate issues and would like to
work with the Agency to put into place and implement a corrective action plan. Since
discovering the embezzlement, the Association has:
> Hired an accounting firm with a strong background in nonprofit organizations and
USEPA grants
> Reorganized fiscal paper files which the bookkeeper intentionally put into
disarray
> Secured provisional indirect cost rates for FY2005 and FY2006
> Started preparations for final indirect cost rate for 05/06
> Continued to rebuild the Association's electronic accounting system
> Rebuilt the Payroll records for FY2002-2006
> Organized all fiscal supporting documentation for the original 4 grants identified
by OIG as subject to review. The scope will be expanded to include all 7 grants
reviewed in this report.
18
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> Updated the Association's personnel and fiscal operation manuals as requested
by USEPA
> Confirmed with USEPA that all prior year Single Audit issues have been
resolved.
> Documented and summarized all program income for each grant
The accounting system and the related software have been "real time" for an entire year
since July 1, 2005. Accruals are made when they occur, receipts are processed as they
are received, and checks are written within the system. Grant expenditures are tracked
against the grant or cooperative agreement and against the remaining grant balance to
ensure propriety and timeliness of incurring the costs and billing the cost to the Federal
government. The books are closed within 10 days of the subsequent month with a
reconciliation prepared for the cash and other major accounts and the subsidiary
ledgers. Checks and balances are maintained between bookkeeping staff and the on-
site out sourced accounting firm that provide oversight.
The Association understands the difficulty that the OIG Inspectors had in reviewing the
financial status of the organization. The general ledger (GL) had numerous errors,
poorly supported general journal entries, and for a short time period contained
redundant transactions. As such, it is clearly within the purview of the Office of Inspector
General to recommend disallowance of all incurred costs in situations where a grantee
does not comply with financial, program management and procurement standards as
outlined in the federal regulations.
The Association is instead requesting that these costs be deemed unresolved, until
such time as GAD has been given the chance to review the entire record. The
Association also requests that the final report and analysis be tempered with an
acknowledgement of the limited utility of the general ledger available at the time of
review.
OIG Comment: Deeming the questioned costs as unresolved would be
inconsistent with the OIG's long-standing reporting practice and the Inspector
General Act of 1978. The OIG's opinion is based on the condition of the records,
observations and results of analysis at the time field work was conducted. This
basis is consistent with the requirements of the Government Auditing Standards,
Questioned costs are defined in the report as costs that are (1) contrary to a
provision of a law, regulation, agreement, or other documents governing the
expenditures of funds, or (2) not supported by adequate documentation. The
action official for this report will resolve the report's finings in accordance with
EPA's Audit Management Process. If the action official decides to provide a
supplementary analysis of the findings and recommendations, the action official
will inform the recipient of the specific information or documentation that will be
needed in support of the findings. Any disputes with the action official's decision
will be resolved in accordance with Title 40 CFR 30.63.
19
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We agree that the general ledger had limited utility at the time of our review.
However, the limited use of the general ledger did not relieve the Association of
its responsibility for maintaining an adequate financial management system as
required by Title 40 CFR 30.21.
1. Unsupported General Journal Entries
The Association recognizes this was a problem with general journal entries which
made it difficult to use the general ledger (GL) and validate the entries with
supporting documentation. However, we are concerned that the scope of this
issue was mischaracterized by stating that the Association "could not provide
support for any of its general journal entries" [emphasis added]. This supporting
documentation was available but because the investigators did not request these
materials, we did not think to offer them at that time. For example, support for
FY2005 general journal entries were all kept in a single binder in the
bookkeeping office and to our knowledge this was not requested by the
investigators during the review process.
The specific example provided in the draft report represents another instance
where supporting documentation was actually available during the review. The
$255,000.00 general journal entry for labor and fringe benefit costs incurred
during a 5-month period had supporting documentation behind it. Our new
accounting firm, Raffa & Associates was responsible for this particular general
journal entry and did maintain the appropriate materials as supporting
documentation. (See Appendix 113) Behind these spreadsheet schedules were all
of the individual timesheets, payroll documents, and fringe benefit vendor files.
Due to the chaos caused by the former bookkeeper and the need to deal with the
embezzlement, the journal entry was believed by Raffa to be the best approach
under the circumstances.
For many general journal entries in the GL the documentation is available.
However, we recognize general journal entries can be a potential vulnerability in
an accounting system. As we rebuild our financial records, the use of general
journal entries will be limited, and proper source documentation will be
scrupulously retained.
OIG Comment: According to notes in our audit work papers, the auditors
(not investigators) made several requests to the Association's Executive
Director, and the accounting firm's personnel for the documentation
needed to support all the general journal entries. The supporting
documentation was not provided, including the $255,000 general journal
entry prepared by the accounting firm. ; \\
The support for the journal entries will be necessary to support the
reconstruction and revised claims to EPA.
13 The appendices are available from the OIG upon request.
20
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Duplicated Recorded Costs
During our in-house review, the Inspector was given a ledger for FY2004 which
continued past June 30 and ran to the first week of November. The Inspector
was also given the FY2005 ledger which started July 1, 2004. The net effect was
that from July 2004 to November 2004 there were two data systems or ledgers
tracking our financial status. Although our accountants did not know at that time
which of the two systems more accurately represented those months, they did
explain to the Inspector our intent to rebuild our financial records using the more
accurate of the two sets of data.
Since that time, we have initiated action to go back and document all direct
expenditures for each grant and put them in spreadsheet schedules, which will
eliminate all issues with duplicate entries per OIG's recommendation.
OIG Comment: The Association will need to revise its Schedules of
Budgeted & Reported Outlays by Assistance Agreement that were
incorrect and overstated due to the duplicate recorded costs. The
Association will also need to revise the outlays reported on the Financial
Status Reports.
Unsupported Grant Draws
The Association recognizes that this was an issue for our grants. Although we
have not yet determined whether this was an artifact of the embezzlement or not,
we do understand the importance of property tracking this information. As part of
the rebuild, Federal cash draws are now and will be appropriately documented in
the future to comply with Title 40 CFR 30.21. This issue is also addressed in the
revised ASIWPCA Accounting Policies Manual.
Unsupported Labor Costs
As was noted in the duplicate transaction section, there were two databases
tracking our income and expenses during the time period of July 2004 to
November 2004. This was fully disclosed to the Inspectors at the time of the
review. A decision had not been made by our accountants as to which database
represented the correct information. The Inspectors were informed that as part of
the rebuild this could be determined and all redundant entries for those months
would be eliminated.
Also noted in general journal entry section above, recorded in the GL is general
journal entry for $255,000.00 representing 5 months of labor and fringe. Backup
support documentation was available at the time and has been provided as apart
of this response. The organization's bookkeeper passed away in March of 2005,
after having been hospitalized off and on for the three months prior. In June of
21
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2005 it was discovered that the labor costs for the prior months had not been
entered into the financial system and the new accounting firm determined that a
general journal entry was appropriate under the circumstances.
We have traditionally been very diligent about tracking our time in labor activity
reports. In the past, both the employee and supervisor were required to sign off
on the paper copies. Almost every single signed paper copy for the last 5 years
has been found to reconstruct our financial records and all data from these labor
activity reports have been entered into spreadsheet schedules which have been
shared with GAD through the reimbursement process. (See Appendix 2)
OI6 Comment: The supporting documentation for the $255,000 journal
entry is not sufficient to fully support the entry. The assumptions and
methodology used to determine the labor allocation and associated costs
are not clear. Further, the hours on the schedules supporting the journal
entry vary somewhat from the hours shown in Appendix 2 of the
Association's response.
5. Unsupported Indirect Cost Rates
As was noted in the section above, in the future, the Association will avoid using
general journal entries for direct or indirect expenses unless absolutely
necessary and will retain all appropriate supporting documentation.
The Association has made a good faith effort to properly document indirect cost
rates in compliance with the USEPA policy. There appeared to be some
inconsistencies between the USEPA policy and the Office of Management and
Budget (OMB) circulars regarding indirect cost documentation. Subsequently,
the USEPA and OMB policies were amended to reconcile these apparent
inconsistencies. Because the Association relied on and complied with the
original USEPA policy, any failure to submit annual indirect cost rate proposals to
USEPA was unintended. Thus, the Association should not be penalized for the
previously-submitted documentation.
The Association acknowledges an understanding of the OMB Circular A-122,
which requires the recipient to submit new indirect cost proposals to the
cognizant agency within six months after the close of each fiscal year. The
Association further understands USEPA cannot accept the reported outlays for
indirect costs until we resubmit final indirect cost rate proposals for all
appropriate prior years. Our efforts to do so are now underway with GAD to get
final rates for FY2005 and FY2006.
OIG Comment: EPA's policy to allow the recipient to retain the indirect
cost rate proposal(s) oh file did not comply with OMB Circular A-122,
Attachment A, subparagraph E (2) and has been rescinded.
Nevertheless, both EPA and OMB policies required the Association to
22
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prepare an indirect cost rate proposal. The Association did not provide
any evidence that it prepared or maintained such documents.
Accordingly, all indirect costs remain unsupported until the Association
submits and receives approved indirect rates for ail years beginning with
the fiscal year ended June 30, 2001.
Under-reported Program Income
The Association agrees that this was an issue with the GL. However, it should be
noted that ASIWPCA's program staff tracked and documented this information in
detail on spreadsheets (by event, participant and payment method). The
methodology was explained to the investigators and those records were available
for review. To the extent the GL differs from those records, we recognize
changes must be made as part of the rebuild.
OIG Comments: The Association may have more program income than is
supported by supplemental records. In reviewing the general ledger we
identified program income from the CAFO roundtables/summits meeting;
however, there were no Regonline14 reports provided for that meeting.
Therefore, the program income may be greater than the amount identified
in the supplemental records. By not properly recording and reconciling the
program income, the Association's financial management system was not
accurate, and the incurred costs may have been overstated for EPA
grants CP83107001, X783164601, and CP83106901.
Inadequate Written Accounting Procedures
The Association agrees there were deficiencies in our written accounting
procedures. Further, where there may not have been written deficiencies, there
were areas of concern relating to implementation.
We request that the OIG review the Association's Accounting Policies Manual,
dated August 2005, prepared for us by Raffa & Associates. If upon further
review, more details must be provided, the Association is very willing as part of a
corrective action plan, to provide more information in those areas. Several layers
of checks and balances have been instituted to ensure implementation.
As part of our provisional indirect cost rate application, the Association now
provides detailed descriptions of any and all assumptions made to develop the
rate. Although in the past our provisional rate calculations included member
services, for all current and future applications these costs will be treated as
direct costs. The Association will further ensure that EPA is provided all relevant
materials to support rate calculations and that appropriate written procedures are
14 Online event registration software and services for meetings, conferences, training classes, and other corporate
functions.
23
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in place to provide explanation to EPA regarding our treatment of direct and
indirect expenses.
OiG Comment: The Association did not provide us with the Accounting
Policies Manual either during our field work or in response to this report.
Accordingly, we cannot comment on the adequacy of the procedures.
8. Noncompliance with Federal Cash Management Requirements
The Association agrees that this was an ongoing problem that comes up in the A-
133 Single Audits Reports. Although no Federal funds have been identified as
having been stolen, the report provides insight into the methodology of the
embezzler to use different funds to back pay other expenses. Procedures with
checks and balances have been put into place to assure this will not be a
problem in the future.
9. Single Audits Not Completed
As was noted above, the FY2003 Single Audit Report was not finalized until June
24, 2004. In an attempt to go forward with the FY2004 Single Audit, Raffa &
Associates discovered the embezzlement and the Association agreed that the
audit should be put on hold until we could place confidence in our financial
records. The Association is aware that under OMB Circular A-133, nonfederal
entities that expend $300,000 ($500,000 for fiscal years ending after December
31, 2003) or more in a year in Federal awards must have a Single Audit
conducted. We are currently rebuilding our records and will work with our
accountants and the Office of Grants to determine the appropriate timing and
solution for this issue.
The OIG draft report indicates that issues identified in the FY2003 Single Audit
have not been addressed and resolved. ASIWPCA has since submitted to the
agency a summary of actions that have been completed to resolve the issues
identified in that audit (See Appendix 3). Those measures are in place and
operational.
10. Improper Procurement
It is agreed that in situations where two organizations are related through
common management, share office space, the telephone system, office
equipment, etc., that greater scrutiny must exist to avoid a conflict of interest for
decisions to spend Federal grant dollars on contractual services inter-
organizationally. The specific issues raised in the OIG draft report focused on the
TMDL Circuit Rider Grants and the Shared Services Agreement with America's
Clean Water Foundation (ACWF) as well as several other smaller contracts.
24
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The Association believes that these issues can be worked out with USEPA
upon further discussion and review of ASIWPCA records. For instance we
believe that information can be provided and presented by ASIWPCA that the
rates from most work were at or below market rates and that the work was
effectively completed. We look forward to discussing this further with USEPA.
25
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Appendix C
Distribution
Office of the Administrator
Director, Grants Administration Division (Action Official)
(responsible for report distribution to recipient)
Director, Office of Grants and Debarment
Audit Followup Coordinator, Office of Grants and Debarment
Assistant Administrator for Water
Assistant Administrator for Air and Radiation
Agency Followup Official (the CFO)
Agency Followup Coordinator
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
General Counsel
Acting Inspector General
d-.-.•-";:'•
NW
26
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