17
A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR 27 1997
OFFICE OF
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
Review of ORD's Extramural Management Specialist Position
Audit Report No. E1BBF6-23-0001-7100141
Elissa R.
Deputy Assistant Inspector General
for External Audits
Robert J. Huggett
Assistant Administrator
Office of Research and Development
A copy of the subject final report is attached. This report contains findings that describe the
results of our audit of the effectiveness of the EMS position within ORD. We hope that the
results of our review will be useful to your office as you continue to work to assure extramural
resources are well managed.
This report represents the opinion of the Office of Inspector General. Final determinations on
matters in this report will be made by EPA managers in accordance with established EPA audit
-esolution procedures. Accordingly, the findings described in this audit report do not necessarily
represent the final EPA position. We have no objection to the release of this report to the public.
Your response to our draft report is included as appendix 1. Based on the Office of Research and
Development's response and discussions with staff, we made appropriate changes to this final
report.
ACTION REQUIRED
In accordance with EPA Order 2750, we have designated you as the Action Official for this
report. The Action Official is required to provide this office with a written response to the audit
report within 90 days of the final report date. The response should address all recommendations.
For corrective actions planned but not completed by the response date, reference to the specific
milestone dates will assist us in deciding whether to close out this report.
Recyclad/RecyclaM* • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Poslconsumer)
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Should you or your staff have any questions regarding this report, please contact Leah Nikaidoh,
Audit Manager, Northern Audit Division, at (513) 366-4365.
Attachment
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Review of ORD's Extramural
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EXECUTIVE SUMMARY
PURPOSE
RESULTS IN BRIEF
Historically the Office of Research and Development (ORD) has
experienced weaknesses in extramural management. As a result, in
1990, under the Federal Mangers' Financial Integrity Act
(FMFIA), the Agency declared ORD's management of extramural
resources a Presidential-level material weakness. In response,
ORD established the Extramural Management Specialist (EMS)
position to help correct some of its contracting deficiencies. We
examined the EMS position to determine its effectiveness in
correcting ORD's extramural weaknesses. The objectives of the
audit were to determine:
The functions EMSs perform.
The benefits ORD gained from the position, and the
method ORD uses to measure the benefits.
The mission EMSs should serve with regard to
procurement issues.
The EMS position helped to improve ORD's extramural
management. The position contributed to ORD removing
extramural management as a FMFIA weakness. EMSs' on-site
accessibility enabled them to advise and train ORD management
and technical staff on proper extramural management procedures.
Although the creation of the position was beneficial, we found
areas needing improvement. ORD had not clearly defined the
EMS role and, as a result, this sometimes led to the performance of
unallowable or unintended duties. Further, the Office of
Acquisition Management (OAM) and the Grants Administration
Division (GAD) did not fully understand the benefits of working
with EMSs. ORD also had support staff who performed EMS-
related duties. In some cases, the support staff helped do the work
of EMSs who were less knowledgeable in the assistance agreement
area. Also, the EMS role is evolving, given decreasing and
shifting ORD budget projections. Since ORD created the EMS
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position, it has not performed any extramural workload analyses to
determine the best use of its EMS resources.
RECOMMENDATIONS
We recommend that the Assistant Administrator for Research and
Development require his staff to:
1. Develop a standardized EMS position description, with
assistance from OAM and GAD, which includes a "core"
set of duties and responsibilities to ensure consistent
implementation nationwide.
2. Revise Chapter 4 of the ORD Policies and Procedures
Manual to clarify that EMSs are not permitted to perform
PO duties either officially or informally, unless a waiver is
granted. ORD needs to delineate under what circumstances
a waiver is appropriate.
3. Communicate the EMS role to OAM and GAD
management and staff, and take steps to improve the
communication between them.
4. Identify those support staff performing extramural duties,
and develop, clarify, and communicate policies regarding
the appropriate role of support staff in extramural matters,
including whether support staff can be POs.
5. Coordinate with GAD on the feasibility of establishing
rotational assignments for EMSs needing more assistance
agreement experience.
6. Conduct extramural workload analyses by location to
determine the best use of ORD's EMS resources.
7. Initiate discussions with the Director, GAD to consider
revising its IAG Compendium and its Assistance
Administration Manual, and provide input to GAD on what
information needs revision.
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ORD COMMENTS AND
OIG EVALUATION The Assistant Administrator for ORD provided a written response
to our draft report on March 26, 1997. The Assistant
Administrator agreed with all recommendations in this report.
ORD is developing a corrective action plan, including milestone
dates, to address our recommendations and will submit this within
the 90-day comment period. We will evaluate ORD's corrective
action plan when received. Appendix 1 contains a copy of ORD's
written response to our draft report.
in
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IV
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Table of Contents
EXECUTIVE SUMMARY 1
CHAPTERS
1 INTRODUCTION 1
Purpose 1
Background 1
Scope and Methodology 3
Prior Audit Coverage 5
2 EMS POSITION HELPED TO IMPROVE ORD'S EXTRAMURAL
MANAGEMENT 6
Advising ORD Management and Staff 7
Reviewing Extramural Procurement Packages 8
Performing Management Studies 9
Developing Professional Relationships 9
Coordinating Staff Development 11
3 IMPLEMENTATION OF EMS ROLE NEEDS CLARIFICATION 12
EMSs Performed PO Duties 12
Position Descriptions Needed Revision 14
OAM and GAD Unclear About EMS Role 14
Conclusion 15
Recommendations 16
ORD Comments and OIG Evaluation 16
4 SUPPORT STAFF PERFORMED EMS DUTIES
AND SERVED AS PROJECT OFFICERS 17
Expertise of Support Staff Used to Address Workload 17
Support Staff Assisted EMSs Who Were
Less Knowledgeable in Assistance Area 18
Support Staff Also Served as POs 20
Conclusion 20
Recommendations 21
ORD Comments and OIG Evaluation 21
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5 EMS RESOURCE PLANNING IS NEEDED 22
ORD's Implementation of Corrective Actions 22
ORD's Extramural Budget Shifts and Declines 22
EMSs Performed "Other" Duties 24
Conclusion 25
Recommendation 25
6 EMSs CALL FOR IMPROVEMENTS 26
EMS Position Can Be Improved 26
EMSs Suggest Improvements to Guidance Documents 26
Conclusion 27
Recommendation 27
EXHIBIT
1 PRIOR AUDITS OF EXTRAMURAL MANAGEMENT 28
APPENDICES
1 ORD'S RESPONSE TO THE DRAFT REPORT 30
2 ABBREVIATIONS 34
3 DISTRIBUTION 35
VI
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CHAPTER 1
Introduction
PURPOSE
BACKGROUND
In 1995, we conducted a survey of the timeliness of the pre-award
procurement process at the Cincinnati Contracts Management
Division. We learned, among other things, that the Office of
Research and Development (ORD) established a position—the
Extramural Management Specialist (EMS)—in 1993 to help ORD
correct some of its contracting deficiencies. According to Office
of Acquisition Management (OAM) officials, the EMS position
resulted in mixed outcomes—some benefits and some impediments.
As a result, we reviewed various aspects of the EMS position and
its implementation by ORD. In March 1996, we decided to
examine the EMS position to determine its effectiveness in
correcting ORD's extramural weakness.
The objectives of this audit were to determine:
• What functions EMSs performed.
• What benefits ORD gained from the position, and how
ORD measured these benefits.
• What "mission" EMSs should serve with regard to
procurement issues.
ORD provides EPA with an integrated research and development
program. In addition to conducting research and development
projects, ORD partners with the academic scientific community
through extramural assistance agreements. ORD was officially
reorganized as of October 1, 1995. ORD consists of three
Headquarters offices, three national Labs and two national Centers.
The Labs and Centers are the: (1) National Exposure Research
Laboratory (NERL); (2) National Risk Management Research
Laboratory (NRMRL); (3) National Health and Environmental
Effects Research Laboratory (NHEERL); (4) National Center for
Environmental Assessment (NCEA); and (5) National Center for
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Environmental Research and Quality Assurance (NCERQA).
Various divisions and offices comprise each Lab/Center.
During the 1980s and early 1990s, the Office of Inspector General
(OIG) identified Agency weaknesses with extramural management,
particularly in the contracts area. In 1990, the Agency declared
ORD's management of extramural resources as a Presidential-level
material weakness under the Federal Managers' Financial Integrity
Act (FMFIA). To address this weakness, ORD, among other
things, created a network of acquisition specialists in 1993 to
advise top management on appropriate procurement practices.
In 1993, the Agency provided funding to ORD for seven full-time
equivalent positions to be used solely for acquisition management.
ORD was required to match that amount and, therefore, dedicated a
total of 14 positions for acquisition management. ORD created the
EMS position as one step, among several, to help correct the
FMFIA weakness identified in 1990. The fourteen EMSs are
located throughout the country, with at least one at each of the
Labs/Centers' geographical sites. ORD filled most EMS positions
in 1994. EMSs report to Lab/Center Deputy Directors, unless
located at a remote division, in which case the EMSs report to
Division Directors.
EMSs provide on-site expertise and guidance on extramural
management and coordinate all extramural management activities
for their respective offices, laboratories, or divisions. EMSs: (1)
advise ORD management and staff on all extramural management
issues, policies, and procedures; (2) perform management studies;
(3) develop high-level professional relationships; and (4)
coordinate staff development.
Under ORD policy, EMSs are not permitted to manage individual
extramural instruments, such as a project officer (PO) does. EMSs
must have procurement expertise commensurate with a contracting
officer or contract specialist. EMSs must also be knowledgeable
about other extramural instruments, such as assistance agreements
and interagency agreements.
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SCOPE AND
METHODOLOGY
We focused our review on the EMS position rather than on any
specific EMSs or locations. Our review was based on the newly
reorganized ORD structure, although most EMSs were hired prior
to that event.
Using a structured questionnaire, we interviewed each of ORD's
14 EMSs. We interviewed nine of the EMSs face-to-face, and the
other five via telephone. Within ORD, we also interviewed.
Twenty-five support staff who performed administrative or
extramural review and coordination functions.
Each of ORD's five Lab/Center Deputy Directors.
Three Division Directors.
Office of Resources Management and Administration
(ORMA) staff, including its Associate Director, Policy
Review and Evaluation Staff Chief, and Resources
Planning and Execution Staff Chief.
Project officers.
ORD's Deputy Assistant Administrator (AA) to discuss
concerns regarding the implementation of the position.
We also interviewed the following within the Office of
Administration and Resources Management:
• OAM's Director.
• Special Assistant to the OAM Director.
• Contract Management Division (CMD) Directors from
Cincinnati and Research Triangle Park (RTP).
• Three CMD Branch Managers.
• Several contracting officers and contract specialists.
• Both Award Officials in the Grants Administration
Division (GAD), and several GAD grants specialists.
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We participated in four of ORD's monthly Extramural
Management Network teleconferences.1
We reviewed files for 21 judgmentally selected procurements to
determine EMS input. We reviewed 6 contracts, 8 cooperative
agreements, 3 grants, and 4 interagency agreements. We also read
sections of ORD's management review reports that pertained to
extramural management. These reports included reviews of
extramural management at Narragansett, Rl; Gulf Breeze, FL; Ada,
OK; and Athens, GA2. We also reviewed position descriptions
and performance agreements for EMSs and other ORD employees
who performed EMS-related functions.
To assess the effectiveness of EMSs' teaching of the Project
Officer (PO) Assistance Course, we reviewed the 34 course
evaluations that ORD provided to us. Participants, who took the
course in 1996, gave scores for overall course quality and the
effectiveness of the instructor, among other things. According to
ORD officials, over 500 staff took the PO course.
We reviewed ORD's Policies and Procedures Manual and ORD's
fiscal 1995 and 1996 FMFIA reports. We visited ORD offices in
Washington, D.C.; Cincinnati, OH; RTP, NC; Athens, GA; and
Las Vegas, NV. We also visited OAM offices in Washington,
D.C., Cincinnati, and RTP. We visited GAD's Headquarters in
Washington D.C.
We performed our audit in accordance with the 1994 Government
Auditing Standards issued by the Comptroller General. We
conducted fieldwork from April 1996 to December 1996. This
'ORD's Extramural Management Network consists of ORMA officials, all 14 EMSs, and some support
staff who perform extramural coordination activities. ORD established the Network to resolve extramural
management issues and promote good management practices. Network members participate in monthly
teleconferences to convey information, solicit input, and assess issues.
2The Athens report was a draft report.
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PRIOR AUDIT
COVERAGE
Review of ORD's Extramural
Management Specialist Position
report also includes preliminary information we gathered during a
survey prior to the audit.
Various OIG audits from 1983 through 1994 identified ORD
extramural management problems. Audits in the 1990s focused on
specific ORD laboratories in Duluth, MN; Athens, GA;
Narragansett, RI; Corvallis, OR; and Gulf Breeze, FL. The
General Accounting Office also issued several audit reports and
testified before Congress during the 1980s and 1990s on EPA-wide
extramural management problems. See exhibit 1 for a list of prior
OIG and GAO audit reports and testimony.
In the OIG's November 1996 Semiannual Report to Congress, we
stated that EPA made positive changes in its contract management
practices, and that EPA should improve assistance agreement
management practices.
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CHAPTER 2
EMS Position Helped to Improve ORD's
Extramural Management
EMSs, via the functions they performed and their on-site
availability, helped ORD remove its six-year FMFIA material
weakness pertaining to extramural resource management. ORD
did five other things—in addition to creation of the EMS positions—
which also contributed to the removal of the FMFIA weakness.
ORD:
1. Appointed an SES-level Acquisition Executive to oversee
the resolution of the weakness.
2. Developed and conducted comprehensive extramural
training courses.
3. Developed and implemented new policies and procedures.
4. Conducted comprehensive management reviews.
5. Converted contractor positions to in-house positions.
ORD's Policies and Procedures Manual (Manual), Chapter 4,
outlined the functions EMSs should perform, and stated EMSs
should provide on-site expertise and guidance on extramural
management and coordinate such activities. According to the
Manual, EMSs (sometimes referred to as Acquisition Specialists or
Acquisition Managers) coordinate all extramural management
activities for their respective offices, laboratories, or divisions.
Among EMS duties are:
1. Advising ORD management and staff on all extramural
management issues, policies, and procedures (including
reviewing Lab/Center, or office extramural packages that
require higher level approval within ORD).
2. Performing management studies.
3. Developing high-level professional relationships.
4. Coordinating staff development.
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According to the Manual, EMSs are not permitted to manage
individual extramural instruments, such as a project officer does.
EMSs must have procurement expertise commensurate with a
contracting officer or contract specialist. Also, EMSs must be
knowledgeable about other extramural instruments, such as
assistance agreements and interagency agreements. ORD's Senior
Resource Official (SRO)3 can waive these requirements. For
instance, according to the Manual, the SRO might place greater
weight on assistance experience for locations that primarily use
assistance agreements. EMSs hired with waivers should take
appropriate training within one year.
ADVISING ORD
MANAGEMENT
AND STAFF
EMSs advised top-level managers, as well as technical staff, at
their locations on extramural matters. All EMSs reported to the
appropriate level—the Deputy Lab/Center Director, or Division
Director. In general, they strove to identify potential concerns
early and notify management of such concerns. Because EMSs
were on-site, they also had direct access to POs. EMSs counseled
POs on proper procurement practices.
EMSs significantly contributed to ORD management and staffs
understanding of extramural management. Lab/Center Deputy
Directors generally said they valued EMSs' expertise and their
accessibility. POs also generally said EMSs added value. Some
POs, varied, however, on how much input they solicited from
EMSs. Some said they did not seek EMS input because of prior
PO experience; other POs went to another source of information.4
Some POs noted that although they did not frequently seek EMS
assistance, the POs valued the EMSs' availability.
3ORD's Deputy AA for Management.
4Some POs sought the advice of support staff who had expertise on assistance and IAG packages. Please
refer to chapter 4 for a discussion of this issue.
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REVIEWING
EXTRAMURAL
PROCUREMENT
PACKAGES
According to ORD statistics, since fiscal 1994~the year EMSs
were hired—ORMA's approval of procurement packages increased
significantly. These packages were first reviewed by an EMS
before submission to ORMA.
Fiscal
Year
1994
1995
1996
Packages Reviewed
by ORMA
532
220
136
Approved
391
198
124
Percent
Approved
73
90
91
ORMA, as shown above, reviewed far fewer packages in fiscal
1995 and 1996 than in fiscal 1994. This occurred primarily
because ORD increased its thresholds for package approvals at the
Lab/Center Director level. The Federal budget impasse in early
fiscal 1996 also resulted in fewer packages needing ORMA's
review. ORMA typically reviews only those packages that require
ORD AA approval or SRO concurrence.
OAM's opinion on ORD package quality was mixed. Some
officials stated that the packages were better due to the EMSs.
Several contracting officers and contract specialists, however, said
they still had to spend substantial time with POs to improve
procurement packages. According to some OAM officials, lower
level ORD packages (which do not require ORMA review) often
need substantial improvements after ORD initially submits them to
OAM's contracts management divisions. A GAD Award Official
said ORD's package quality was generally good. We did not
perform work in this area and, therefore, cannot make a
determination regarding these statements.
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PERFORMING
MANAGEMENT
STUDIES
DEVELOPING
PROFESSIONAL
RELATIONSHIPS
EMSs worked on ORD Management Review teams, with ORMA
officials, and helped conduct reviews at ten locations since 1994.
The review teams were effective in identifying weaknesses and
areas of concern within the Labs/Centers. The reviews were
comprehensive, and identified significant concerns. For instance,
at Gulf Breeze, an EMS was functioning as a PO on two contracts.
This was against ORD policy. The EMS's PO duties have since
been properly transferred to other staff. Eleven of 14 EMSs (78
percent) stated they believed ORD Management Reviews were a
key element in educating staff and ensuring that correct extramural
instruments are used. Only the EMS position, ORD policies, and
OIG reports were cited more often by EMSs as having contributed
to the use of correct instruments.
EMSs also are responsible for identifying various extramural
management areas requiring improvement, or that might have the
potential for waste, fraud, or abuse.
EMSs participated in ORD's Extramural Management Network.
Network members included various ORMA staff members, as
well as the EMSs. ORMA's Policy Review and Evaluation Staff
Chief chaired the Network. The Network met monthly through
teleconferences. ORD established this Network to assist ORMA
with extramural management matters, such as policy and procedure
development and communication of guidance.
EMSs shared their ideas and experiences to address issues and
implement improvements during the Network's monthly
teleconferences- EMS participation in these teleconferences helped
ORMA officials determine if policies were being implemented
consistently in the field. The Network Chair often asked EMSs to
assist ORMA in developing extramural policies or researching
extramural issues. EMSs noted generally that the teleconferences
were useful in conveying information. In January 1997,
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Extramural Management Network officials met for a 3-day
conference to discuss the future role of the EMS position, as well
as other emerging issues.
EMSs contacted 0AM staff regarding both general interpretations
and clarifications of regulations and guidance, as well as individual
procurement package issues. EMSs' knowledge of their
organizations' needs combined with extramural expertise and on-
site locations provided EMSs with unique insight into extramural
needs. EMSs drew on their extramural backgrounds to help them
understand how general regulations and guidance pertained to
specific extramural package issues. EMSs acted as "interpreters"
between OAM and ORD staff.
Despite some concerns, OAM officials generally stated EMSs
added value or had the potential to add value because: (1) EMSs
were on-site, which enhanced communication with POs; (2) EMSs
helped POs learn PO functions; (3) ORD submitted higher quality
packages than some other EPA offices that did not have a similar
position5; and (4) EMSs were central points of contact to resolve
contract issues.
Some OAM officials noted, however, that the value added
depended on whether EMSs assumed proactive and collaborative
roles. These officials recognized the potential value EMSs can add
because some EMSs understand both program and extramural
needs. However, OAM officials stressed that EMSs must remain
objective and work with, rather than against, OAM. OAM officials
also voiced other concerns: (1) EMSs sometimes do not seem
aware of regulation and policy changes and need to be in an
information dissemination loop; (2) EMSs seem more oriented
toward procedures for level-of-effort contracts than for fixed price
contracts, which OAM is encouraging the use of; and, (3)
contracting officers and contract specialists still need to spend a lot
of time with POs on packages.
5Two OAM staff members thought it was very likely EMSs had a positive effect on package quality, but
did not directly attribute it to diem.
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A GAD Award Official said the EMS position has the potential to
add value because it can provide GAD with central points of
contact. The Award Official added, however, that EMSs could
generally use more assistance training and experience.6
COORDINATING
STAFF DEVELOPMENT EMSs improved ORD's understanding of extramural management
by providing various training courses to ORD staff. EMSs taught:
(1) an ORD PO course for assistance management, (2) work
assignment manager training, (3) an Interagency Agreement
supplemental course, (4) invoice processing training, (5) a one-day
seminar on assistance management, and (6) cost administration
management training. According to the PO Assistance Course
evaluations we reviewed, participants gave average scores of 4.4,
4.4, and 4.3, for "overall quality", "effectiveness of instructor", and
"relevance to job responsibilities", respectively. The scores were
out of a possible score of "5."
The NERL-Cincinnati EMS and the NRMRL-Cincinnati EMS
coordinated and assisted with, respectively, monthly meetings
between ORD and OAM personnel from January 1995 to May
1996. The NERL-Cincinnati EMS held another acquisition forum
in January 1997. The forums provided an excellent opportunity for
information exchange and improvement of working relations.
^ost GAD grants specialists we talked to did not know about the EMS position and had not talked with an
EMS.
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CHAPTER 3
Implementation of EMS Role Needs Clarification
EMSs PERFORMED
PO DUTIES
The EMS role was not well-defined. As a result, EMSs performed
duties that were not permitted under ORD policy. Also, staff
within OAM and GAD did not fully understand the benefits of
working with EMSs. These conditions occurred because: (1)
ORD's policy is not sufficiently clear, (2) ORD communication
with OAM and GAD regarding the EMS role needs improvement,
and (3) some EMS position descriptions (PDs) need revision.
Some EMSs performed PO duties, which was not allowed under
ORD policy. ORD's Manual, Chapter 4, states, ". . because of
their role as consultants and advisors to ORD line managers, EMSs
are prohibited from serving as Project Officers or Work
Assignment Managers." According to ORD's Deputy AA, EMSs
should neither formally be POs, nor informally perform PO duties.
Although ORD's policy states that an EMS cannot formally hold
the title of PO, it should be clarified that EMSs should also not
perform PO duties informally.
Several EMSs stated that they met with contractors, usually with
POs present, to resolve issues pertaining to specific procurements.
One EMS, along with the PO—and with approval from the
contracting officer—met with an 8(a) contractor prior to award of a
janitorial services contract, valued just over $1 million. The EMS
said he discussed technical issues including required experience
levels of the boiler maintenance person and the cost of the work
uniforms. He said he did not get very involved in the negotiation
of pricing because the contractor was "on target with their rates."
According to the EMS, he thought his involvement was within his
official job classification of "Acquisition Manager". The EMS
stated that he gets approval from contracting officers before
meeting with contractors. The EMS's PD included the function of
negotiating with and debriefing contractors. The EMS also stated
that he prepared the procurement package for the PO.
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In another case, an EMS exceeded his authority on behalf of his
Division. The EMS, rather than the Division Director or PO, sent a
memo to the Contracts Management Division in RTF (CMD-RTP)
canceling a proposed contract. The EMS also did not advise his
Division Director to notify top-level ORD management and GAD
officials about a potential organizational conflict of interest (OC1)
on a cooperative agreement (CA).
The ORD Division originally planned to award a contract, rather
than a CA. CMD-RTP identified an OCI with a potential offerer
during the contract pre-award process. According to the EMS,
funding available for the project decreased around the same time.
This significantly reduced the project's scope. The Division then
decided to fund a project, which was for a public purpose, through
a CA. Although the scope of the CA was more general than the
contract, the potential for the same OCI remained. GAD
subsequently approved a sole-source justification from the
recipient to use that subcontractor on the CA. Under 40 Code of
Federal Regulations, Part 33, CA recipients must exclude
contractors that present OCIs. During our review, ORD staff
determined that the EMS should have notified ORD management
regarding the potential for an OCI under the CA.
Three EMSs were formally POs. One EMS continued to serve as a
PO. However, the EMS recused himself from participation in any
EMS duties that would affect the contract for which he served as
PO. The EMS took this action to avoid any conflict of interest
situation which could have occurred. This EMS is also the
Program Operations Staff (POS) Director for the National Health
and Environmental Effects Research Laboratory's division in
Corvallis. As a result, he performed two roles in addition to his
EMS role. The second EMS was a PO for two contracts, and an
alternate PO for two other contracts. His PO duties were properly
transferred to other staff, as a result of a May 1995 ORD
Management Review. The third EMS obtained a waiver memo
from the Deputy AA, allowing him to function as a PO.
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POSITION
DESCRIPTIONS
NEEDED REVISION
OAM AND GAD
UNCLEAR ABOUT
EMS ROLE
In 7 of 14 cases (50 percent), EMSs' PDs needed updating. Also,
6 of the 14 PDs (43 percent) contained duties typically performed
by POs. For example, one EMS's PD stated that he "personally, or
through project officers, guides contractors on technical, legal,
policy and administrative aspects of the projects for which they
provide support"; and (b) provides "performance feedback to
contractor/recipient senior management. . ." The EMS agreed
these are PO functions. He stated that he performs those functions
only in a general capacity.
In other cases, EMSs had either assumed new roles which were not
addressed in their PDs, or the EMSs no longer performed certain
functions, which had yet to be deleted from the PDs. ORD's
Deputy AA, and ORMA's Associate Director, stated that EMSs
should have accurate PDs. According to the Deputy AA, the PDs
for all EMSs should contain a consistent core of duties. He stated
that ORD should review each EMS PD and revise the PDs
accordingly to ensure EMSs understand the functions they should
be performing. The official position classification on 7 (50
percent) of the 14 EMSs' PDs was either Acquisition Manager or
Acquisition Program Manager.7
Both GAD and OAM officials—including grants specialists and
contracting officers—stated that they did not fully understand the
role of the EMS. For example, five of six GAD Grant Specialists
that we interviewed dealt primarily with someone other than the
EMS to resolve assistance package issues. Usually, they interacted
with a division or laboratory level "assistance coordinator". One
GAD Branch Chief stated she did not know whether these
assistance coordinators performed the same functions as EMSs.
7According to the PDs, 3 (21 percent) of the 14 were classified as EMSs, 2 (14 percent) were Acquisition
Analysts, 1 (7 percent) was a Management Analyst, and 1 (7 percent) was a Supervisory Program Analyst.
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Another GAD Branch Chief stated he was confused about whether
to contact the PO or the EMS to resolve issues and when.
Some GAD staff were not aware of who the EMSs were. A GAD
Branch Chief gave us a list of the people his staff typically dealt
with to resolve assistance issues. Only one EMS appeared on the
list; instead, most were administrative or clerical employees within
ORD. As a result, GAD staff might not have been working with
the most knowledgeable ORD official.
0AM officials also expressed concerns about the EMS role,
including concerns that some EMSs: (1) performed both
acquisition and project officer functions, often without authority or
a warrant, (2) performed more functions than intended when the
position was established; and (3) have lost their objectivity for
implementing correct procedures in favor of carrying out their
program offices' needs. ORD officials stated that they were aware
of OAM's concerns.
CONCLUSION
Core EMS responsibilities should be identified. EMSs need to
have a clear understanding of what their role is, and have accurate
and up-to-date PDs. Half of the EMSs had "manager" in their
official job classification. This could cause EMSs to believe they
should have an active role in managing procurements. EMSs
should neither be POs, nor perform PO duties, but instead be
independent reviewers and advisors to ORD management and staff.
EMSs are not authorized to legally bind the Federal government
concerning procurement decisions. Also, new POs need to have
the opportunities to perform the duties they should be learning.
OAM and GAD should also be made aware of the role EMSs play
and the value they can add to the procurement process.
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RECOMMENDATIONS
We recommend that the Assistant Administrator for ORD instruct
his staff to:
3-1 Develop a standardized EMS position description, with
assistance from OAM and GAD, which includes a "core"
set of duties and responsibilities to ensure consistent
implementation nationwide.
3-2 Revise Chapter 4 of the ORD Policies and Procedures
Manual to clarify that EMSs are not permitted to perform
PO duties either officially or informally, unless a waiver is
granted. ORD needs to delineate under what circumstances
a waiver is appropriate.
3-3 Communicate the EMS role to OAM and GAD
management and staff, and take steps to improve the
communication between them.
ORD COMMENTS AND
OIG EVALUATION ORD agreed with the findings and recommendations. They will
submit a corrective action plan with milestone dates in their
response to the final report. We will review ORD's submission
when received.
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CHAPTER 4
Support Staff Performed EMS Duties
And Served As Project Officers
EXPERTISE OF
SUPPORT STAFF
USED TO ADDRESS
WORKLOAD
Some ORD support staff, although not EMSs, performed EMS
duties. In some cases, the Labs/Centers established these positions
to make efficient use of resident expertise and address existing
workloads. In other cases, the positions were created to address a
lack of EMS knowledge about assistance agreements. The
distinction between the roles of the EMS and these support staff is
not clear. As a result, support staff—who may not have the training
or experience of the EMS— could provide incorrect advice. Also,
EMSs may not gain needed experience if support staff performs
those tasks.
ORD did not envision these extramural support positions when it
reprogrammed staff years in 1993 to create the EMS positions.
ORD's extramural policies are silent on these positions, and the
role these individuals should play in the procurement process.
We identified 16 ORD support staff who performed duties such as:
(I) helping technical staff prepare Statements of Work, (2) helping
technical staff develop Independent Government Cost Estimates,
(3) writing extramural training manuals, (4) teaching extramural
training courses, and (5) reviewing extramural packages prior to
management approval. We identified at least one support staff in
each Lab/Center, except NCERQA, who performed at least one of
the duties cited above. Most had titles like "Extramural Specialist"
or "Extramural Assistant". ORD officials were unaware of the
number of support staff acting in this capacity.
In some cases, Labs/Centers used support staff—some of whom had
substantial knowledge of extramural policy and procedures—to
manage extramural instruments. For example, the National Center
for Environmental Assessment (NCEA) recently created a team
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concept for managing extramural instruments. As part of this
concept, the NCEA Deputy Director assigned four people—two in
Washington, one in Cincinnati, and one in RTF—the role of, what
he called, "junior EMS." Three of the four have contract
backgrounds; one has assistance agreement experience.
At NERL-RTP, four "Acquisition Specialists" reviewed extramural
packages before the packages were reviewed by the EMS. These
support staff were used to ease the large workload the EMS would
otherwise have to handle alone. In addition to his local workload,
NERL-RTP's EMS also performed special review tasks for
ORMA.
SUPPORT STAFF
ASSISTED EMSs WHO
WERE LESS
KNOWLEDGEABLE
IN ASSISTANCE AREA
The Labs also used the support staff to help EMSs who were less
knowledgeable in the assistance agreement area. At NHEERL-
RTP, about 32 percent of its fiscal 1996 extramural budget was for
assistance agreements. Three NHEERL-RTP support staff helped
the EMS review extramural packages and perform other EMS-
related tasks. These staff told us that their positions were created
around July 1996. NHEERL's Deputy Director told us in August
1996 that the EMS needed more direct experience in the assistance
agreement area.
At NHEERL-Corvallis, the EMS«also the POS Director-relied
significantly on an Extramural Projects Coordinator to review
assistance agreement packages and coordinate with POs. The EMS
relied on the Coordinator for two key reasons: (1) the Coordinator
had more assistance agreement experience, and (2) the EMS had
limited time to accomplish EMS tasks since he was also the POS
Director for the Division. The EMS informed us that the
Extramural Projects Coordinator position was created in 1988 to
perform extramural review and coordination duties.
At NERL-LV, an Extramural Assistant reviews all assistance
agreement packages, before review by the EMS. The EMS was
hired in 1994 from the Department of Defense; he had a
contracting background. The Extramural Assistant, on the other
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hand, had EPA experience processing assistance agreements, and
NERL-LV valued that expertise. The Extramural Assistant has
been detailed to GAD for the past five years, for a two-month
period, to process assistance agreements at fiscal year end.
According to ORD's Management Review Team Leader, an ORD
review team found in 1995 that the EMS was not as knowledgeable
as he should be in the assistance agreement field. The EMS stated
that he attended three EPA assistance agreement training courses
within six months after being hired and now teaches, on occasion,
the ORD assistance course for POs.
Chapter 4 of the ORD Policies and Procedures Manual requires
that EMSs have experience commensurate with that of a contract
specialist or contracting officer. The Manual also states that EMSs
must be knowledgeable of Federal and EPA directives governing
other extramural management activities. ORD's Deputy AA stated
that he wanted one person per location to be the expert in all
extramural areas. He also stated that contracting experience was
the most important factor in hiring EMSs. He said that: (1)
contracting is where the Agency had most of its problems in the
past, and (2) assistance agreements are not as complex and skills
for managing them could be learned easier.
The ORD term "Extramural Management Specialist" infers a
knowledge of all extramural instruments, including assistance
agreements and lAGs. The official position classification on 9 of
the 14 EMSs' Position Descriptions (64 percent), however, was
either Acquisition Manager, Acquisition Program Manager, or
Acquisition Analyst, which implies a strong contracting
("acquisition") background.8 Twelve of the 14 EMSs (85 percent)
did not have experience processing assistance agreements or lAGs
within EPA before becoming EMSs.
ORD has taken steps to ensure EMSs have taken the appropriate
assistance agreement training. However, we could not determine,
8According to the PDs, 3 (21 percent) of the 14 were classified as EMSs, 1 (7 percent) was a Management
Analyst, and 1 (7 percent) was a Supervisory Program Analyst.
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in some cases, whether the EMSs had gained adequate knowledge
of the area because some support staff continue to perform
substantial reviews of assistance agreement packages prior to the
EMSs' reviews.
SUPPORT STAFF
ALSO SERVED AS POs
CONCLUSION
Twelve of the 16 support staff (75 percent) were also POs. The
ORD Policies and Procedures Manual, Chapter 4, does not allow
EMSs to be POs In addition, according to ORD's Deputy AA,
EMSs should not informally perform PO functions. We question
whether support staff performing EMS-related duties should be
allowed to be POs for the same reason that EMSs are not. One
NCEA support staff stated that if she were an EMS, she could not
be a PO due to the ORD restriction. She stated that she liked being
able to perform both her PO and EMS roles. The NCEA Deputy
Director stated that he contemplated pursuing EMS certification
for this one support person but needed her to carry out PO duties
and, therefore, did not pursue that certification. If a Lab/Center
has a limited number of POs available to manage projects, it might
be necessary to permit the performance of both roles. However, if
a Lab/Center is using support staff positions to bypass the formal
EMS/PO restriction, that is not appropriate.
The range of time spent among support staff on EMS and PO
duties varied. The Extramural Projects Coordinator at Corvallis
stated she spent about 85 percent of her time performing
extramural coordination duties and 15 percent on PO duties.
Others spent less time on EMS duties and more time on PO duties.
An NCEA support staff person stated he was a PO for seven
cooperative agreements and interagency agreements, and a pre-
award PO for one contract.
ORD should identify all support staff performing EMS-related
duties, and determine what roles these staff play and should play in
extramural management. If ORD determines that having these
staff perform such duties is necessary, ORD should: (1)
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communicate this role to OAM and GAD, and (2) consider
revising its Manual to address the role of such staff and whether
they are permitted to be POs.
Management should neither establish nor maintain extramural
support staff positions to make up for EMSs who are less
knowledgeable of assistance agreements. ORD management
expects EMSs to be experts on all extramural topics. Although
management may have created support staff positions as a
temporary fix to aid EMSs, that practice should not be promoted as
a long-term solution. Instead, ORD should identify ways to
improve EMSs' knowledge in the assistance agreement area.
RECOMMENDATIONS
ORD COMMENTS AND
OIG EVALUATION
We recommend that the Assistant Administrator for ORD instruct
his staff to:
4-1 Identify those support staff performing extramural duties,
and develop, clarify, and communicate policies regarding
the appropriate role of support staff in extramural matters,
including whether support staff can be POs.
4-2 Coordinate with GAD on the feasibility of establishing
rotational assignments for EMSs needing more assistance
agreement experience.
ORD agreed with the findings and recommendations. ORD will
submit a corrective action plan with milestone dates when they
respond to the final report. We will review ORD's submission
when received.
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CHAPTER 5
EMS Resource Planning is Needed
ORD'S
IMPLEMENTATION
OF CORRECTIVE
ACTIONS
ORD'S EXTRAMURAL
BUDGET SHIFTS
AND DECLINES
Since ORD created the EMS position, ORD has not performed any
extramural workload analyses to determine the best use of its EMS
resources. The role of the EMS will continue to evolve due to the
implementation of corrective actions and shifts and declines in
ORD's extramural budget. Also, most EMSs performed "other"
duties because the EMSs did not have a full-time EMS workload.
Because ORD officials have not conducted any EMS workload
analysis, ORD is not sure how such resources should be spent for
maximum effectiveness.
In its fiscal 1996 FMFIA Assurance Letter, dated October 31,
1996, ORD~with concurrence from OAM and OIG~removed
extramural management as a material weakness. In 1990, EPA
declared ORD's management of extramural resources as a
Presidential-level FMFIA weakness. To correct the weakness,
among other things, ORD established on-site EMSs at the
laboratories in 1994. EMSs have played a major part in enabling
ORD to remove that FMFIA weakness. EMSs have, among other
things, trained project officers and management in proper
procurement practices, and have reviewed and helped rewrite
extramural management policies.
According to the Chief of ORD's Resources Planning and
Execution Staff (RPES)-who is also ORD's Senior Budget
Officer—ORD's extramural budget: (1) has declined and will
decline, overall, in the near future; and, (2) has shifted from an
emphasis on using contracts to assistance agreements, primarily
grants. A significant Agency initiative has been to expand the
competitively awarded grants and fellowships program. The Chief
stated that ORD's AA wants to "get scientists back to the bench"
conducting research, instead of being POs and managing contracts.
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Because of budgetary shifts and declines, the Chief stated that the
workload for EMSs on a dollar level has decreased at the Labs,
while it is increasing at NCERQA, since it manages all EPA
grants. As a result of the Agency's initiative, proposed funding for
the grants and fellowship program reached $115 million in the
1997 President's Budget Request. This represents a significant
increase in NCERQA's total extramural budget (from about $33
million in fiscal 1994 to about $121 million in fiscal 1997-a 266
percent increase).
The following table shows ORD's extramural budget obligations,
in millions of dollars, by procurement instrument from fiscal 1991
to fiscal 1995.9
Instrument
Contracts
Cooperative
Agreements
Grants
Interagency
Agreements
(lAGs)
TOTAL
1991
$190.5
838
29.4
20.3
$324.0
1992
$192.8
107.9
38.7
27.3
$366.7
1993
$176.4
110.5
34.2
40.7
$361.8
1994
$171.6
108.8
39.8
66.0
$386.2
1995
$152.0
92.9
63.4
56.0
$364.3
Funding for grants rose nearly 60 percent (about $23.6 million)
from 1994 to 1995. According to the Chief of RPES, funding for
ORD's grants and fellowships program doubled in fiscal 1996 and
again in fiscal 1997. Funding for contracts, on the other hand,
decreased about 11 percent (nearly $20 million). Funding for
cooperative agreements and lAGs also both decreased from 1994
to 1995 about 15 percent.
9ORD did not have complete data beyond 1995.
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The RPES Chief stated that it is prudent for ORD to maintain a
certain level of resources for EMS positions. However, he was not
sure whether they would need one EMS at each location. He said
that, given the shifts in the budget, ORD should review the
workloads, by location, to determine how best to allocate
resources.
Based on data provided by EMSs, the three major labs (NERL,
NRMRL, and NHEERL) experienced reductions in overall
funding, and significant funding decreases for cooperative
agreements and lAGs over the last three fiscal years. Therefore,
the extramural workloads may have decreased substantially and
should be evaluated.
EMSs PERFORMED
"OTHER" DUTIES
ORD has a network of 14 EMSs, along with a group of support
staff, who perform extramural-related activities. Nine of the 14
EMSs (64 percent) stated they also performed "other" duties not
directly related to extramural management, generally accounting
for 10 to 30 percent of their time. One EMS stated he spends
between 60 to 70 percent of his time performing other roles. ORD
managers assigned EMSs other functions and roles because some
did not have a full-time extramural-related workload. The ORD
Policies and Procedures Manual is silent on the role EMSs should
play in "other" work areas. According to ORD's Deputy AA,
Lab/Center managers should have the flexibility to assign duties to
their EMSs, but ORMA should be consulted. He also said that
now might be a good time for ORD to review EMSs' workloads
and the other duties they are performing. Although the
performance of other tasks may be necessary, lower grade staff
might more efficiently perform some of the administrative duties.
EMSs stated they performed such duties as: (1) serving as FMFIA
internal control coordinators, (2) managing property, (3)
conducting quality assurance reviews, (4) providing ethics training,
(5) maintaining Financial Disclosure reports and recusal
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statements, and (6) creating and operating Internet web sites10. In
1993, ORE) reprogrammed 14 staff years for the EMS position to:
...create a network of acquisition specialists or managers
in Headquarters and the laboratories to advise program
managers on appropriate acquisition practices and to
identify and resolve emerging problems in ORD
acquisition practices.
ORD's PRES Chief stated that the EMS role should evolve into
other things, with input from the Labs/Centers and ORD
Management Council.11 He believed that EMSs should always be
involved in training the staff. One lead EMS—a GS-14 who also
performs higher-level duties for ORMA—also stated that the EMS
role is changing, but he suggested that the EMS role in the future
should provide less emphasis on training the staff and more on
oversight.
'CONCLUSION
RECOMMENDATION
Because of changes in the role of EMSs and in the types of
extramural instruments used by ORD, now is a good time for ORD
management to review extramural workloads and functions and
determine the best use of its resources.
We recommend that the Assistant Administrator for ORD instruct
his staff to:
5-1 Conduct extramural workload analyses by location to
determine the best use of ORD's EMS resources.
10Part of operating the Internet sites is extramural-related. Requests For Proposals and other procurement
information were put on the Internet to increase competition.
11 The ORD Management Council consists of the Senior Resource Official, the ORMA Director, and the
five Lab/Center Deputy Directors for Management.
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CHAPTER 6
EMSs Call For Improvements
Most EMSs believed they had adequate management support to do
their job effectively. Although EMSs felt "empowered", they still
believed their position could be improved and made suggestions
for doing that.
EMS POSITION CAN
BE IMPROVED Ten of the 14 EMSs (71 percent) stated their EMS position could
be improved. Of those 10:
• Nine EMSs (90 percent) said the position could be
improved by: (1) better means of communication between
ORD and OAM, and (2) less duplication of effort between
EMSs and other ORD reviewers.
• Eight EMSs (80 percent) stated that better means of
communication between ORD and GAD would enhance the
EMS position.
• Five EMSs (50 percent) cited "other" improvements
needed, including better communication between ORMA
and EMSs, and an increased role for EMSs in the
budgeting/planning cycle.
EMSs SUGGEST
IMPROVEMENTS TO EMSs called for improvements in Agency guidance documents for
GUIDANCE assistance agreements and lAGs, particularly in post-award areas:
DOCUMENTS
• Nine of 14 EMSs (64 percent) said either great or some
improvement was needed in the management of LAGs
within their organization.
• Eight of 14 EMSs (57 percent) said some improvement was
needed in the management of cooperative agreements.
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CONCLUSION
RECOMMENDATION
EMSs recommended that GAD's IAG Compendium and its
Assistance Administration Manual be revised and updated
to help them do their job. EMSs believed both documents
were unclear, giving the Compendium an average "clarity"
score of 2.2, and the Assistance Manual an average score of
2.4, on a scale of 1 (not all clear) to 5 (extremely clear).
Improvements can, and should, be made which will aid EMSs in
carrying out their duties more efficiently and effectively.
We recommend that the Assistant Administrator for ORD instruct
his staff to:
6-1 Initiate discussions with the Director, GAD to consider
revising its IAG Compendium and its Assistance
Administration Manual, and provide input to GAD on what
information needs revision.
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Exhibit 1
Page 1 of 2
PRIOR AUDITS OF EXTRAMURAL MANAGEMENT
QIGALJDITS
Year
1994
1994
1993
1993
1992
1992
1986
1983
Report Title
Management of Cooperative
Agreements: ORD, Environmental
Research Laboratory, Gulf Breeze, FL
Management of Assistance and
Interagency Agreements: ORD,
Environmental Research Laboratory,
Corvallis, OR
Management of Extramural Resources:
ORD, Environmental Research
Laboratory, Narragansett, RI
Management of Extramural Resources:
ORD, Environmental Research
Laboratory, Athens, GA
Contracting Activities at
Environmental Research Laboratory,
Dulura, MN
EPA's Management of Computer
Sciences Corporation Contract
Activities
Contract Management Practices at
Environmental Monitoring Systems
Laboratory - Las Vegas
Review of the Office of Research and
Development's Extramural Activities
Report No.
4100237
4100214
3100236
3100156
2100443
2100295
6000773
30828
Date Issued
03/31/94
03/21/94
06/16/93
03/31/93
07/7/92
03/31/92
03/26/86
03/31/83
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GAP AUDITS AND TESTIMONY
Exhibit 1
Page 2 of 2
Year
1991
1989
1989
1987
1985
1982
Report Title
Government Contractors: Are
Service Contractors Performing
Inherently Governmental
Functions?
GAO Testimony — "Sound
Contract Management Needed at
the Environmental Protection
Agency"
GAO Testimony — "The
Environmental Protection
Agency's Use of Consultants"
Status of EPA' s Contract
Management Improvement
Program
The Environmental Protection
Agency Should Better Manage
Its Use of Contractors
EPA's Use of Management
Support Services
Report No.
GAO/GGD-92-11
GAO/T-RCED-89-8
GAO/T-GGD-89-5
GAO/RCED-87-68FS
GAO/RCED-85-12
GAO/RCED-82-36
Date Issued
11/18/91
02/23/89
02/03/89
Jan. 1987
01/04/85
03/09/82
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Appendix 1
Page 1 of 4
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
March 26, 1997
OFFICE OF
RESEARCH AND DEVELOPMENT
MEMORANDUM
SUBJECT:
FROM
TO:
Response to OIG Draft Report of Audit No. E1BBF6-23-0001
Review of ORD's Extramural Management Specialist positions
Robert J. Huggett, Ph.D.
Assistant Administrator
for Research and Develo
Elisjsa R. Karpf
Deputy Assistant Inspector General
for Acquisition and Assistance Audits (2421)
Purpose
This memorandum responds to the Office of Inspector General's Draft Report
of Audit No. E1BBF6-23-0001, Review of ORD's Extramural Management
Specialist (EMS) Positions, dated February 21,1997.
Discussion
We reviewed the draft report and concur with the findings and
recommendations. We do, however, have an attached set of comments which, we
believe, will improve the overall quality of the report.
We greatly appreciate die assistance of the Auditor-in-Charge in working
closely with us on position papers and for his presentation at the ORD EMS
Training Conference held at Las Vegas, NV, in January 1997. We believe the OIG's
attention to the issues identified in the report will help us improve ORD's
extramural management.
Ricyclcd/RKyctabl*
PrtnW •» Soy/Cvtoli Mi on ftftr r«t
> it to>M 75* racydtd tar
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Review of ORD's Extramural
Management Specialist Position
Appendix 1
Page 2 of 4
Should you have any questions, or require additional information, please
contact Arnie EHoora on 260-9496.
Attachment
Henry L. Longest, II (8101)
Debbie Dietrich (8102)
PeterDurant(8102)
ORD Management Deputies
ORD EMS Network
JimMorant(8102)
Colleen Lentini (8102)
Arnie Bloom (8102)
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Appendix 1
Page 3 of 4
Attachment
ORD Comments on Draft Report of Audit No. E1BBF6-23-0001
Review of ORD's Extramural Management Specialist Positions
Introduction
We appreciate the opportunity to review the subject draft report on ORD's
Extramural Management Specialist (EMS) Positions. We have several comments
and concerns regarding the issues presented in the draft report. Our comments are
organized by chapter with page numbers referenced to the draft report. We concur
with the stated recommendations and appreciate the OlG's attention to considering
our thoughts to clarify and enhance the report's content and message.
Chapter 3
p. 13 - EMSs Performed PO Duties - EMSs are not to become POs, but
EMSs are to assist and advise the POs. At the PO's request, EMSs should
provide support to the PO by attending and participating in meetings. It
must be clear that the EMS participation is as an advisor to the PO. The CO
has the final call on the issues.
p. 15 - Position Descriptions Needed Revision - We concur with
Recommendation 3-1 to develop a standardized EMS position description
that entails core duties and responsibilities for the EMS. We hope to develop
mis standardized position description with the input and concurrence of the
ORD Management Council.
p. 15 - OAM and GAD Unclear About EMS Role - We concur that EMSs
should help OAM staff understand the EMS role. EMSs should emphasize to
OAM mat OAM's first point of contact should be the PO. The EMS only
serves as an advisor to the PO.
Chanter 4
p. 20 - Support Staff Assisted EMSs Who Were Less Knowledgeable in
Assistance Area - ORD never intended that EMSs would replace all other
support for POs. EMSs are to augment controls, not become the sole source
of information. Support staff serve as POs and are not EMSs.
The EMS is the principal source of advice on extramural issues for laboratory
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Review of ORD's Extramural
Management Specialist Position
Appendix 1
Page 4 of 4
management. ORD will ensure that any EMS in need of additional training
in the assistance area or any other area will be trained.
p. 22 * Support Staff Also Served as POs - "Support staff performing
EMS-related duties should not be allowed to be POs for the same reason that
EMSs are not." We agree the EMSs cannot be POs. However, POs and
support staff who show leadership in mentoring and advising co-workers on
how to do a good job should be encouraged, not restricted because they are
experienced and competent. As stated earlier, the EMS is the principal
source of advice in extramural issues for laboratory management.
Deputy Directors cannot arbitrarily assign current staff to be an EMS. ORD
experience requirements, careful training, recruiting from the outside, or an
approved deviation to the qualification requirements are necessary before the
Senior Resource Official appoints the EMS.
p. 23 - Recommendation 4-1 - We agree with Recommendation 4-1 that we
should identify and be aware of others besides EMSs who serve to advise or
help POs. As we conduct our analysis of this issue, we also will consider the
need to develop, clarify and communicate policies regarding the appropriate
role of support staff in extramural matters, including whether support staff
can be POs.
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Appendix 2
Page 1 of 1
ABBREVIATIONS
AA Assistant Administrator
CA Cooperative Agreement
CMD Contracts Management Division
EMS Extramural Management Specialist
EPA Environmental Protection Agency
FMFIA Federal Managers' Financial Integrity Act
GAD Grants Administration Division
IAG Interagency Agreement
NCEA National Center for Environmental Assessment
NCERQA National Center for Environmental Research and Quality Assurance
NERL National Exposure Research Laboratory
NHEERL National Health and Environmental Effects Research Laboratory
NRMRL National Risk Management Research Laboratory
OAM Office of Acquisition Management
OARM Office of Administration and Resources Management
OCI Organizational Conflict of Interest
OIG Office of Inspector General
ORD Office of Research and Development
ORMA Office of Resources Management and Administration
PD Position Description
PO Project Officer
POS Program Operations Staff
PRES Policy Review and Evaluation Staff
RPES Resources Planning and Execution Staff
RTP Research Triangle Park
SRO Senior Resource Official
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Review of ORD's Extramural
Management Specialist Position
Appendix 3
Page 1 of 2
DISTRIBUTION
Acting Inspector General (2410)
Assistant Administrator for Research and Development (8101)
Deputy Assistant Administrator for Management, ORD (8101)
Director, Office of Resources Management and Administration, ORD (8102)
Associate Director, Office of Resources Management and Administration, ORD (8102)
Chief, Policy Review and Evaluation Staff, Office of Resources Management and
Administration, ORD (8102)
Director, Office of Acquisition Management (3201)
Special Assistant, Office of Acquisition Management (380IF)
Director, Grants Administration Division (3903F)
Audit Liaison, Grants Administration Division (3903F)
Audit Liaison, Office of Acquisition Management (3201)
Audit Liaison, Office of Administration and Resources Management (3102)
Audit Liaison, Office of Research and Development (8102)
Director, Program & Policy Coordination Office (3102)
Agency Follow-up Official (3101)
Attention: Acting Chief Financial Officer
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Review of ORD's Extramural
Management Specialist Position
APPENDIX 3
Page 2 of 2
Agency Follow-up Coordinator (3304)
Attention: Director, Resources Management Division
Audit Follow-up Coordinator (8102)
Attention: Office of Resources Management and Administration
Headquarters Library (3404)
GAO Issue Area Planner
Electronically Distributed
Extramural Management Specialists
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