UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                   OFFICE OF THE INSPECTOR GENERAL
                        NORTHERN DIVISION
                     77 WEST JACKSON BOULEVARD
                       CHICAGO. IL 60604-3590

                         June 26, 1995
MEMORANDUM

SUBJECT:  Report No.  E1AMB5-05-0053-5100372
          Region 5's  Budget Execution Process
FROM:     Anthony C.  Carrollo    / (
          Divisional  Inspector^eneral ror Audits
          Northern Division

TO:       Valdus V. Adamkus
          Regional Administrator
          Region 5

     We have completed  our survey of Region 5's budget
execution process.  EPA's  National Performance Review (NPR)
team visualized an EPA  where managers understand the link
between strategic planning,  budget formulation,  and the
operating plan; know  early in the fiscal year what resources
are available to operate their programs; and are involved in
the budget execution  process.   We believe Region 5's budget
formulation and execution  process meets these goals.

     Region 5's Reinvention  Implementation Plan identifies
the budget process and  narrowly defined program elements as a
key barrier to organizational  design flexibility.   As part of
its reorganization, Region 5 is committed to creating cross-
regional teams.  As the report recognizes,  cross-regional
teams do not fit neatly into the current budget program
element structure.  As  part  of its implementation plan,
Region 5 needs to work  with  Headquarters on how resources
should be allocated for cross-regional teams.
PURPOSE AND OBJECTIVES

     Federal spending practices  are  receiving  increased
scrutiny and criticism.  The  Vice  President's  Report of the
NPR of 1993 called for improved  budgeting through linking
spending with program priorities and performance.   Recent
Congressional actions, including the Chief Financial Officers
Act of 1990 and the Government Performance and Results Act of
1993, have also responded  to  the need for more accurate
financial reporting and more  efficient program and financial
management in the Federal  Government.
                                         ury
Printed oa Recycled Paper

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                           Region 5*s  Budget Execution Process
      The objectives of our survey were  to  obtain an
 understanding of how Region 5 managed the  budget execution
 process and to determine whether resources were  used in
 accordance with Congressional intent and Agency  requirements.
 BACKGROUND

      More than a year and a half  before  a  fiscal  year begins,
 EPA plans activities and calculates how  much  money it will
 need to carry them out.   The EPA  national  program offices,
 with input from the regions,  formulate the overall budget
 request for accomplishing EPA's environmental program goals.
 (Exhibit 1 contains a flowchart of the budget process,
 focusing on the development and execution  of  the  budget  at
 Region 5.)   After the President and the  Office of Management
 and Budget (OMB)  have reviewed the budget  request,  it goes  to
 Congress,  usually in the December or January  before the
 fiscal year.

      While Congress is reviewing  the budget,  EPA  is
 developing an  operating  plan.  The budget  request indicates
 the aggregate  amount of  resources for the  EPA regional
 offices.   The  operating  plan  allocates resources  to the
 individual  regions.   In  developing the operating  plan,
 Headquarters notifies Region  5 of the number  of workyears it
 may receive in each program for the upcoming  fiscal year, as
 well  as  the total  amount of funding.  Region  5 uses this
 information to develop its  part of the EPA operating plan.

      The  operating plan  divides funds by program  element and
 budget object  class.   Program elements identify funds for
 specific  activities,  such as  indoor air program,  regional
 management, and hazardous substance spill  and site  response.
 The budget  object  class  describes what type of expenses the
 funds  are to be used for, such as personnel,  travel,
 administration, grants,  etc.  In  developing the operating
 plan,  EPA may  make  changes  to the original budget request.
 These  changes  are  approved  by OMB and Congress during the
 budget review  process.

     Congress  passes  an  EPA budget,  usually between October 1
 and January 1  of the  fiscal year.   OMB provides the budgeted
 funds to EPA by quarters.   EPA Headquarters distributes funds
 to Headquarters offices  and the regions according to the
 operating plan.  Headquarters Budget Division provides Region
 5 spending  authority  in  an  advice of allowance letter.  This
advice of allowance,  along with the  operating plan,  is the
basis for Region 5's  budget.
                            REPORT No.  E1AMB5-05-0053-5100372

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                          Region  5'a Budget  Execution  Process
     During  the  fiscal year, Region  5 may  find  that  certain
programs  do  not  have  sufficient  funds to cover  all expected
needs.  Region 5 may  reprogram resources between programs
within  an appropriation.  However, EPA  as  a whole must  obtain
Congressional approval to reprogram  funds  into  or out of any
program in excess of  $500,000.
SCOPE AND METHODOLOGY

     We conducted our survey fieldwork from January through
April 1995 at Region 5 in Chicago.  Our survey covered the
Region 5 budget execution process for fiscal years 1994 and
1995.  We also met with EPA auditors from the Office of
Inspector General's Central Audit Division to review their
workpapers and discuss their findings in an audit of Region
7's budget execution process.  Details of our scope and
methodology are included in exhibit 2.

     We performed our evaluation in accordance with the
Government Auditing Standards, 1994 Revision, issued by the
Comptroller General.  We reviewed internal controls related
to Region 5's budget execution and its compliance with
Federal regulations.  As part of our evaluation, we reviewed
the Region 5 Comptroller Branch's fiscal year 1994 Federal
Managers' Financial Integrity Act (FMFIA) report.

     We issued a draft report to the Regional Administrator,
Region 5, on April 25, 1995.  The Regional Adminstrator's
response, dated June 6, 1995, is incorporated into the report
and included as Appendix 1.
RESULTS OF REVIEW

     Region 5's internal controls over the budget process
were effective.  There was an open process of budget review
and negotiation through which Region 5 arrived at the
allocation of funds and workyears for each division.  Region
5 used the Integrated Financial Management System (IFMS) to
record transactions and track the actual use of funds against
the budget.  The Budget Section in the Planning and
Management Division provided the divisions periodic budget
reports from IFMS to reconcile with their supporting records
and to control their spending.  Region 5 assigned employee
fixed account numbers that reflected the employees'  work
activities, and personnel costs and workyears were charged to
the proper program elements.
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                            REPORT No. E1AMB5-05-0053-5100372

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                           Region 5' *  Budget Execution Proce»
      Budget  Controls  Were Effective

      The internal  controls over Region 5's budget process
 were  effective.  The  Region 5  budget process allowed  for all
 divisions to provide  input and assume accountability  for how
 funds were budgeted and used.   Region 5 tracked spending
 against  the  budget in IFMS.   Controls within IFMS prevent
 Region 5 from spending more than its budget.  The Region 5
 divisions used periodic IFMS reports from the Budget  Section
 to  reconcile budget and spending actions with their own
 records.   Effective internal controls over the budget process
 reduce the likelihood that Region 5 will spend funds  in
 excess of its budget  or for purposes not intended by
 Congress.

      Region  5 divisions made decisions on how workyears and
 funds would  be allocated.   (See flowchart in exhibit  1.)
 Workyears were allocated to the divisions based on the
 results  of national workload model distributions, inter-
 divisional negotiations,  and special regional needs.  The
 National  Program Managers,  working with the Deputy Regional
 Administrators, used  workload  models to distribute workyears
 to  the regions.  Within Region 5,  the division directors
 negotiated the movement of the workyears between divisions.
 For example,  the Office of Superfund gives workyears  to other
 media divisions to provide assistance in conducting Superfund
 work.  The Deputy Regional Administrators resolved any
 disagreements  on workyear  negotiations.

      The  Deputy Council, consisting of the deputy directors
 from  each Region 5 division, was  responsible for developing
 Region 5's operating  plan.   The Deputy Council made decisions
 on  how personnel, travel,  and  other funds would be
 distributed  to the divisions.   Funds were distributed to the
 divisions  based on workyear allocations and historical costs.
 The Region 5  Deputy Council  also  decided on special regional
 "tap"  positions.  These consisted of positions that were not
 included  in  the national workload models,  such as the State
 Coordinators  and the  Regional  Hearing Clerk.  Region  5 taps
 workyears  from the divisions to cover these positions.

      Region  5  inputs  the operating plan into IFMS, which is
 the official mechanism  for recording transactions and
 tracking the actual utilization of funds against the  budget.
 Controls within IFMS prevent any  commitment of funds  that
would create a deficiency  in an appropriation.   The Budget
Section monitored IFMS  on  a  daily basis to ensure that Region
 5 did not  exceed its budget.   For fiscal year 1994,  Region 5
                              4

                            REPORT NO. E1AMB5-05-0053-5100372

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                           Region 5'»  Budget Execution  Process
obligations  and  expenditures  did  not  exceed budgeted
appropriations.

      The  divisions  remained involved  in  budget  execution
throughout the year.   The  Budget  Section provided  the
divisions with monthly status reports from  IPMS.   The
divisions used these  reports  to reconcile with  their records
and  control  their spending.

      Region  5 Was Controlling Funds at the
      Program Element  Level

      Congress approves EPA's  budget at the  program element
level, and EPA directives  require control of funds at the
program element  level.  Resource Management Directive 2520
states that:

      The  amount  of  money allocated to one program
      element determines how much the  Allowance  Holder
      may  commit  or  obligate for that  program.   The Funds
      Certifying  Officer should not certify  funds if
      processing  an  action would exceed the  limit on a
      program element.

      However, Region  5 budget officials  told us that
Headquarters Budget Division  verbally instructed them to
monitor funds at the  appropriation level.   The  fiscal year
1993  advice  of allowance letter also  stated that allowance
holders would be held accountable at  the appropriation level,
rather than  the program element level.

      Based on Headquarters  instructions.  Region 5  implemented
procedures to monitor  funds at the appropriation level.
During most  of fiscal  year  1994,  Region  5 was not verifying
that  funds were available in  the program element before
committing funds for use.  In the last quarter  of fiscal year
1994, Headquarters  Budget Division sent a memo  to allowance
holders informing them that they should monitor at the
program element level.  The Headquarters Budget Division
instructed Region 5 to  move funds as necessary  to cover any
overobligations of  program elements.   Region 5  Budget Section
was unable to balance  all program elements by the end of the
fiscal year because Headquarters closed IFMS to all but
emergency reprogrammings.  As of September  30,   1994,  Region 5
had 22 program elements that were over-committed and
obligated.   (See exhibit 3 for a comparison of budgeted and
actual costs for 1994.)  However,  none of these
overobligations violated the  Congressional reprogramming
limitation of $500,000.


                              5

                            REPORT No. E1AMB5-05-0053-5100372

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                           Region 5's Budget Execution  Process
      For fiscal  year 1995,  Region  5 was monitoring  funds  at
 the program element  level,  as  required by EPA policy.  Region
 5 verified that  funds were  available  in the program element
 before committing funds  for use.

      Region 5  Allocation of Workyears Was Reasonable

      During the  divisional  workyear negotiations, the program
 divisions provided the Office  of Public Affairs  (OPA) and the
 Information Management Branch  (1MB) with additional
 workyears.   Each of  these offices  provided direct support for
 program divisions and, therefore,  charged program specific
 program elements.  We believe  that based on how Region 5  is
 organized,  it  was reasonable for personnel in these offices
 to charge program specific  program elements.

      OPA coordinates public affairs for each division in
 Region 5.   Personnel in  OPA generally charge their  time to
 regional management.   However, OPA personnel who work for a
 specific program charge  their  time to a program element
 associated  with  that program.  For instance, the public
 affairs specialist that  works  with the air program  charges
 their time  to  the  stationary sources enforcement program
 element.  An important part of an  effective enforcement
 program is  communicating to the public EPA's activities.   OPA
 has  a separate Superfund Community Relations Branch, which
 provides community relations at Superfund sites.  These
 personnel charge  their time to Superfund.  Based on how
 Region 5 has organized its  public  affairs activities, it  is
 reasonable  OPA personnel  to charge media specific program
 elements.

      1MB provides  information  management support to Region 5
 divisions.   In the FY 1994  Program Element Descriptions,
 information management services are included under an
 administrative management program  element.   However, Region 5
 charged some information management personnel to program
 specific account numbers.   During  fiscal year 1995,  Region 5
 divisions requested  additional information management support
 than  was provided for in  the administrative management
program element.   The divisions provided 12.4 environmental
program workyears to  1MB  to cover  the additional information
management  services.   Region 5 analyzed what activities 1MB
employees were performing and  assigned program specific
account  numbers to personnel based on this  analysis.  We
believe Region 5's allocation  of program specific account
numbers  to personnel  in  1MB was reasonable  since 1MB was
providing direct support to the program divisions.
Information management support is needed to efficiently carry


                               6

                            REPORT No. E1AMB5-05-0053-5100372

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                           Region  5's Budget  Execution  Proceaa
out  the  activities  described  in  the program elements  1MB
personnel  are  charging.

      Employee  Activities Were Accurately Recorded

      Employee  time  was generally charged to program elements
that  corresponded to  the work the employee performed.  We
tested a statistical  sample of 33 Region 5 employees.   (See
Exhibit  2, Scope and  Methodology, for details of the
sampling.)  We interviewed the employees as to their  work
activities.  We obtained employee fixed account numbers from
the Time and Attendance, Payroll, Personnel System  (TAPPS)1
and from the EPA Payroll System  (EPAYS)2.   For each employee
in our sample,  we compared the program element description
for the  fixed  account number  to  the activities the employee
was performing.  The  program  element description agreed with
the employee activities for 32 of 33 employees.  One  employee
was not  charging to the correct  fixed account number.  The
employee's supervisor was aware  of the problem and was taking
action to  correct the fixed account number.

      Employee  fixed account numbers are included in three
different  information systems:   TAPPS, EPAYS, and the
Electronic Timesheet  System  (ETS).3   The Budget Section
inputs changes in fixed account  numbers into EPAYS.   However,
changes  were not reflected in the other two systems.  Of
1,373 Region 5  employees listed  in TAPPS, 105  {8 percent)
were  missing fixed  account numbers.   In our sample of 33
employees, we  also  found that:

  •   TAPPS did not  have the correct fixed account number for
      5 (15 percent) employees; and

  •   ETS did not have the correct fixed account number for
      one employee.
     1   TAPPS is a subsystem of EPAYS used for data entry
into EPAYS.

     2   EPAYS is the automated system for computing payroll.
It is used to upload payroll actions to IFMS as summary
transactions for inclusion in the general ledger and budget
tables.

     3  ETS is a system that allows employees  to complete
their payroll distribution timesheets on the computer.
                            REPORT No. E1AMB5-05-0053-5100372

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                           Region 5'B Budget Execution Proceaa
      Ideally,  these systems  should be linked,  and  changes  in
 one system should be automatically reflected in the  other  two
 systems.   However,  the systems  were not  designed to  transfer
 information.   Therefore,  the Budget Section needs  to
 systematically notify the Human Resource Branch, where  TAPPS
 is maintained,  and the Superfund Accounting Section,  where
 ETS is maintained,  of fixed  account number changes.
 Incorrect fixed account numbers in these systems could  cause
 an employee's  payroll to be  charged to the wrong program
 element or appropriation.
 DRAFT REPORT RECOMMENDATION

      We  recommended that  the  Regional  Administrator,  Region
 5,  implement procedures to  ensure  that fixed account  numbers
 are consistent  in all  information  systems.
AGENCY COMMENTS

     The  Regional Administrator, Region  5,  agreed with  the
conclusions  in our  report.  Region  5  agreed with the
recommendation and  was  formulating  a  plan  for  corrective
action.
ACTION REQUIRED

      In accordance  with EPA Order 2750, please provide this
office with a written response to the  report within  90 days.
The response should include a corrective action plan, with
milestone dates,  for implementing the  draft report
recommendation.

      This audit report contains findings that describe
problems the OIG  has identified, and corrective actions the
OIG recommends.   This audit report represents the opinion of
the OIG.  Final determinations on matters in this report will
be made by EPA managers in accordance  with established EPA
audit resolution  procedures.  Accordingly, the findings
described in this audit report do not  necessarily represent
the final EPA position.

     Should you or  your staff have any questions, please
contact Charles Allberry, Audit Manager, at 353-4222.

Exhibits (3)
Appendix (2)


                              8

                            REPORT No. E1AMB5-05-0053-5100372

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                           Region 5*a Budget Execution Proceaa
                                                  EXHIBIT  2
                                                  Page 1 of  2
                     SCOPE AND METHODOLOGY
     To  gain an understanding of the budget process, we
 reviewed laws, directives, policies, and procedures that
 relate to the budget execution process, including:  (1)
 .Resource Management Directives 2510 and 2520,  (2) Fiscal  1994
 Appropriations Act,  (3) advice of allowance letters, and  (4)
 EPA Budget Division Policy Statements.

     To  understand Region 5's budget process, we interviewed
 officials in all divisions throughout Region 5 and in the
 Comptroller Branch, Budget Section.  We discussed how Region
 5 formulated, executed, and monitored the budget.  We
 examined documents and reports that were part of the budget
 execution process.  We also reviewed Region 5's internal
 controls over the commitment and obligation of funds, as  well
 as budget controls in the Integrated Financial Management
 System {IFMS) .  We did not perform any tests of controls
 within IFMS.

     To  determine if Region 5 used resources in accordance
 with Congressional intent and Agency requirements, we
 assessed Region 5's compliance with its budget.  We reviewed
 Region 5's operating plans and reprogrammings of funds for
 compliance with Congressional requirements and EPA
 directives.  We compared budgeted amounts of appropriations,
 program  elements, and workyears to the actual results.

  •  We  matched the National Program Manager-Deputy Regional
     Administrator (NPM-DRA)  Consensus Distribution of
     workyears and the Region 5 operating plan to determine
     if  there were significant differences.

  •  We  compared the Region 5 budgeted funds and the actual
     obligations to determine whether Region 5 exceeded its
     portion of the budget at appropriation and program
     element levels.

  •  We  compared the workyear and expense ceilings provided
     in  the fiscal year 1994 advice of allowance and the
     actual use of resources to determine whether Region  5
     exceeded ceilings.

     To  determine whether Region 5 was charging workyears and
personnel  costs to the proper program elements, we tested a


                             10

                            REPORT No. E1AMB5-05-0053-5100372

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                          Region 5'a Budget Execution Process
                                                    EXHIBIT 2
                                                  Page 2 of 2

statistical sample of Region 5 employees.   Our sample size
was 33 from a universe of 1,373 employees in all divisions.
The sample was based on an anticipated error rate of 3
percent, a desired precision of error rate of 10 percent, and
a desired confidence level of 85 percent.   Prior to testing
the sample, we discussed our sample methodology with Region 5
management.  We verified the accuracy of personnel charges
through tests of personnel records and payroll supporting
documentation.  We interviewed the Region 5 employees in our
sample regarding their activities to determine whether the
fixed account numbers they were assigned properly reflected
their work activities.
                              11

                            REPORT No. E1AMB5-05-0053-5100372

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                                 Region 5'm Budget Execution  Proc<»»
EXHIBIT 3
Page 1 of 1
Comparison of Actual and Budgeted Costs *
Fiscal 1994
Program Element Detcription
1 Air Quality Management Implementation
2 Ambient Air Quality Monitoring
3 Radiation Program Implementation
4 Radon Action Program Implementation
5 Petticidet Enforcement
6 Pesticide* Program Implementation
7 Resource Management - Regions
g Administrative Management - Regions
9 Regional Support Services (Abatement, Control,
A Compliance)
10 Regional Support Services (Program and
Research Operation!)
11 Regional Counsel
12 Drinking Water Implementation (Midwest Hood)
13 Toxic Substances Enforcement
14 Hazardous Waste Management Regional
Strategy Implementation
15 Enforcement Policy ft Operation!
16 Military Base Closures - Nonsite
17 Wetlands Protection
18 Great Lake* Program
19 Water Quality Criteria, Satndards. and
Applications
•
20 Municipal Pollution Control
21 Hazardous Substance Spin A Site Response
22 Hazardous Substance Response - Office of
Air and Radiation
TOTAL
Approved
Annual Plan
$3,524,100
1,049,000.00
50,100.00
230300.00
688,400.00
344.200.00
244.200.00
28.703.00
5,687,206.00
53.000.00
1,073^00.00
138.900.00
1479300.00
3,562,100.00
39,919.00
115400.00
1,002300.00
3,227.300.00
5224WO.OO
279.793JOO
20341.101.00
224,257.00
J44.007.279
Cumulative Amount Over-
commitments Committed/ Percent Over
+ Obligation Obligated Annual Plan
$3437.191
1,0514)19.00
62068.00
234,818.00
709.241.00
352,068.00
244436.00
30,046.00
5.788312.00
57309.00
1.078335.00
148355.00
1481.194.00
3470^75.00
41.029.00
166300.00
1,004469.00
3.2344W8.00
561318.00
281320.00
20377,492.00
233,091.00
S44J47.474
113,091
24119,00
12.168.00
4418.00
20341.00
7368.00
336.00
1343.00
101,106.00
4309.00
4,935.00
9,455.00
1394.00
8,175.00
U 10.00
51400.00
1,769.00
7,688.00
384*18.00
1427.00
36391.00
8334.00
S340.195
0.4
03
243
2.0
3.0
23
0.1
4.7
13
8.1
04
63
0.1
02
23
44.7
0.2
02
7.4
OS
02
3.9
* Table lists only those program elements that were over -committed or obligated
 This represented 22 out of 171 program dements.


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                                  REPORT No. E1AMB5-05-0053-5100372

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                                Region 5's Budget Execution Process
                                                        APPENDIX 1
                                                        Page 1 of 1
                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                REGIONS
                         77 WEST JACKSON BOULEVARD
                           CHICAGO. IL 60604-3590

                               JUN 06  1985


                                                      KavTOTIC ATTENTION OF
                                                             R-19J
MRMORAKPUX

SUBJECTt   Region 5 Response to the Office of  Inspector General
           Draft Report on Region 5's Budget Execution Process

ntOMi      Valdas V. Adamkus
           Regional Administrator

TOs        Anthony C. Carrollo, Divisional Inspector General
              for Audits, Northern Division
Thank  you for the opportunity to respond to the draft report on Region
5's budget execution process.  We found the report to be very
informative.   We agree with the recommendation and are presently
formulating our plan for corrective action.

If you have any questions concerning these comments, please call
Howard Levin,  Chief,  Financial Analysis Section, at (312) 886-7522.
                                              Valdas V. Adamkus
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                                 REPORT No. E1AMB5-05-0053-5100372

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                          Region 5'a BudgetExecution  Process
                                                  APPENDIX  2
                                                  Page  1 of 1

                         DISTRIBUTION

Region 5

  Regional Administrator

  Audit Followup Coordinator  (MFA-10J)

Headquarters

  Agency Followup Official;
    Attention:  Assistant Administrator for Office of
    Administration and Resources Management  (3101)

  Agency Followup Coordinator;
    Attention:  Director, Resource Management Division  {3304)

  Director, Financial Management Center (3303-F)

  Headquarters Library (3401)

Office of Inspector General

  Inspector General

  Deputy Inspector General
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                            REPORT No. E1AMB5-05-0053-5100372

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