J**"%
OFFICE OF INSPECTOR GENERAL
REPORT OF AUDIT
REGION 1'S OVERVIEW OF
SMALL GRANTEES
September 30,1996
E1FMF6-01-0020 6100314
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Inspector General Division
Conducting the Audit: Eastern Audit Division
Boston, Massachusetts
Region Covered: Region 1
Offices Involved: Office of the Regional
Administrator
Office of Ecosystem
Protection
Office of Administration
& Resource Management
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE INSPECTOR GENERAL
EASTERN AUDIT DIVISION
JOHN F. KENNEDY FEDERAL BUILDING
BOSTON, MASSACHUSETTS 02203-0001
SEP 30 1SSS
NEW YORK OFFICE:
290 BROADWAY
NEW YORK, NY 10007-1866
I:
n
MEMORANDUM
SUBJECT:
FROM:
Audit Report of Region 1's Overview of Small Grantees
Assignment No. E1FMF6-01 -0020-6100314
Paul D.
Divisional Inspector General
Eastern Audit Division
TO:
John DeVillars
Regional Administrator
EPA - New England
Attached is our report entitled "Region 1 's Overview of Small Grantees". Our overall
objective was to determine if Region 1's monitoring and oversight assured that small
grantees carried out their work plan objectives within their approved budget. The report
contains important findings and recommendations regarding the subject area.
Action Required
In accordance with EPA Order 2750. you, as the action official are required to provide
this office a written response to the audit report within 90 days of the final audit report
date. For corrective actions planned buttiot completed by your response date, reference
to specific milestone dates will assist this office in deciding whether to close this report.
We have no objections to the further release of this report to the public.
Should you have any questions about this report please contact me or Wilfredo Vazquez-
Pol, Principal Team Leader at 565-3160.
Attachment
Racy clad/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recyded Paper (40% Postccnsumer)
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EXECUTIVE SUMMARY
PURPOSE
BACKGROUND
Environmental Justice
Environmental Education
Small grantees represent a significant proportion of Region
1's grant workload. Additionally many small grantees are
new to or have limited experience in executing grant
agreements. This inexperience can create more work for
Regional program and grant staff. However, the Region's
limited resources often are directed at grantees with larger
awards. In general, our review was to determine if small
grantees were receiving the attention they needed to
successfully carry-out their projects so that the public
benefits from these programs.
The objectives of our audit were to determine if Region 1's
monitoring and oversight assured that small grantees carried
out their work plan objectives within the Grantee's approved
budget. Additionally, we paid specific attention to whether
the Environmental Education Small Grants (EESG) and
Environmental Justice Small Grants (EJSG) programs
accomplished their respective programs' intended purposes.
For our review, we defined a small grant as an award of
$100,000 or less. As of September 30, 1995, Region 1 had
283 grants meeting this definition. These grants
represented 48 percent of the number of grants awarded but
only 1 percent of total grant funding.
In 1994, President Clinton issued Executive Order 12898
establishingienvironmental justice as a national priority. The
EJSG program was established to provide financial
assistance and stimulate a public purpose by supporting
projects to any affected community group (e.g., community-
based/grassroots organizations, churches, schools,
colleges, other non-profits, Tribal governments, etc.).
The Environmental Education Grants Program provided
financial support for projects which design, demonstrate, or
disseminate environmental education practices, methods, or
techniques.
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RESULTS IN
BRIEF
Monitoring grantee performance needs to be
considered as high a priority as awarding grant funds.
Monitoring is not only a way to identify poor grantee
performance, but it is also a way to identify positive grantee
contributions so that others can use or learn from successful
programs.
Regional Management needs to assure that monitoring
systems are in place and that adequate resources are
allocated to this activity. In particular, new programs and/or
grantees need more overview and assistance by the Region
to assure successful project completion. We found that
grantees for the newer programs such as Environmental
Justice (EJ) or the Urban Environmental Initiative (UEI) were
not always successful in carrying out their grant objectives.
As a result, the public was short-changed of environmental
benefits. Additional EPA oversight could keep grantees on
track to assure effective use of grant funds. Also, grantees
with successful programs desired more EPA recognition
because the grantees believed others could use their
programs. Widespread application of programs is one of the
criteria for selection of Environmental Education (EE) and EJ
grants.
The Region also needs to review its grant procedures to
assure that small grantees are not overly burdened with
excessive paperwork which is not applicable to them.
The following sections highlight our findings. Details can be
found in Chapters 2 through 5.
PRINCIPAL
FINDINGS
Our Principal findings are summarized below. Chapter 2
describes the problems we found with the Environmental
Justice program. Chapter 3 describes the problems we
found with the Roxbury Community College grants. Chapter
4 discusses the issue of needing to close-out grants more
timely. Chapter 5 addresses the issue of adequate
resources for the Environmental Justice and Environmental
Education programs.
n
EXECUTIVE SUMMARY
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REGION 1 NEEDS TO
REVIEW DIRECTION
OF EJSG PROGRAM
A. Need to Pro-
actively Monitor
EJSG Program
Four of the five EJ small grantees we visited did not provide
the environmental assistance to local communities as
intended. The success of the EJSG program suffered from
inadequate monitoring due in part to the insufficient resource
allocation. Additionally, the grant application and agreement
process was designed for grantees of larger awards. Small
grant recipients found the paper work requirements
burdensome and in some areas not applicable to the grants
they received. Further, based upon the results of our
review, Region 1's monitoring was not sufficient to assure
that the grantees followed their work plans and budgets.
Also, the Region did not utilize the grantee's final reports to
evaluate overall strengths and weaknesses of the program.
Because of her many responsibilities, the EJ Coordinator
(EJC) said she limited her monitoring to 20% of the grants,
as recommended by Headquarters OEJ. The Assistant
Regional Administrator stated that EJ was a very important
program to which the Region was committed. This recently
developed program is at a point where Region 1 needs to
identify the most effective types of grantees and activities
which will best serve the targeted communities. Region 1
should discuss with Headquarters OEJ how to streamline
the grant process to make it more accessible to community
groups with limited grant experience.
Insufficient monitoring of the EJ small grants program
resulted in the following program weaknesses
1. Grantee Performance
(a) Grantees were not following their workplans.
(b) Grantes financial records were inadequate.
(c) Grantees were unfamilair with federal grant
regulations.
2. Regional Performance
(a) Grants were not closed out timely resulting in
unliquidated balances.
(b) Final reports were not used to identify
successful/unsuccesful projects.
in
EXECUTIVE SUMMARY
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B. Selection
Procedures for
EJSG Needs to be
Re-Evaluated and
Strengthened
NEED TO DEVELOP
SPECIFIC STRATEGIES
TO ASSURE THAT
RCC MEETS GRANT
GOALS
Adequate resources were not allocated to this program
activity nor was the EJC trained as a Project Officer. The
grantees had limited if any contact with the EJC and
unilaterally changed the work plans. As a result, some of
the affected communities did not benefit from such planned
activities to create strategies to address hazardous waste
sites or polluted air.
Region 1 should re-examine the EJ small grants application
process to assure that: 1) funding is directed towards
community-based/grassroots organizations; 2) duplication
of effort is avoided; and 3) project activities are consistent
with the amount budgeted. One-half of the 1994 EJ small
grants were awarded to non-profit environmental entities
rather than the affected community-based/grassroots
agencies. Our review showed that non-profit, environmental
groups could not fully complete their work plan tasks
because they were unfamiliar with the communities they
were serving. These grantees planned to prepare reports
on toxic sites within the greater Boston area using data from
the EPA and the State of Massachusetts. Three of five
grantees visited advised that their applications promised
more than the grantee could accomplish with the funds
received.
Roxbury Community College (RCC) was making limited
progress toward its grant goal of providing lead abatement
and other related training which could lead to jobs in the
community. This was due in part to Regional staff
approving a work plan which did not include tasks specific
enough to assure successful grant completion. Additionally,
Region 1 had not assured that RCC understood its financial
responsibilities. Regional staff acknowledged that they were
under time constraints to award the grants. Therefore, the
work plans and other grant documents were sufficient just to
award the grants. Additionally, the Region desired to allow
maximum flexibility for this new project RCC staff stated
that they concentrated their first year's efforts on
establishing the Center rather than training. As a result, so
few students had signed up that classes could not be held.
IV
EXECUTIVE SUMMARY
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I
NEED TO CLOSE-OUT
GRANTS MORE
TIMELY
?"Grants shou^fbe^
ctosed^out ''mthm:six%
months after)
Region 1 had not closed out 79 grants with an outstanding
balance of $3,637,766. These grants were
between 6 months to as
many as 33 months past
their project completion
date, and continued to
remain open. The Grants
Administration Unit Manager
provided several reasons for
grants not being close-out
timely and advised that
close-out procedures were
being reviewed for
streamlining possibilities. By
not deobligating the funds,
the Agency is unnecessarily tying-up funds that otherwise
could be utilized.
:^£tepter40r
Grants Administratioh
•ssmt
REGIONAL
MANAGEMENT DID
NOT ALLOCATE
ADEQUATE
RESOURCES TO
MONITORING
OF EE AND EJ
GRANTS
When Project Officers for the EJ and Environmental
Education (EE) grants programs were on extended leave,
their grant monitoring responsibilities were not adequately
covered. As a result, the Project Officers could not keep
up with their monitoring duties and did not follow-up on
indicators of potential problems. Additionally, the EEC
placed too much reliance upon the conclusions of an
assistant who was not an EPA employee.
EXECUTIVE SUMMARY
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RECOMMENDATIONS
REGION 1
COMMENTS
During our review, the issues regarding EJ, RCC, and timely
close-out of grants were discussed with Regional officials.
The Region has indicated a general acceptance of our
recommendations and has begun to implement some of the
following recommendations.
Region 1 should review the progress of its EJSG program by
evaluating the EJ/PO's workload and monitoring system.
Specifically, we recommended that the EJ/PO
responsibilities be shared with other program staff; amend
the EJC's position description to reflect PO responsibilities;
provide grant training to EJ small grantees; review EJSG
final reports on a timely basis to recognize and promote
successful results; work with Headquarters OEJ to
streamline the application process; ensure the grant work
plan is consistent with grant budget; require grantees to
submit grant amendments to reflect significant changes in
grant work plans, budgets, organizational structure, etc.; and
verify the non-profit status of applicants.
For Roxbury Community College, we recommended review
and revision of work plans; request progress reports, define
how project success will be determined; and take
appropriate action to assure that RCC understands and
carries out its financial responsibilities.
In general, we recommended that grants administration and
project officers work closer together and follow guidance for
timely close-out of grants.
We also recommend that Regional Management develop a
plan to assyre that critical functions of personnel who are on
extended leave be covered.
In general, Region 1 agreed with our recommendations but
in some instances did not agree with the basis for the audit
recommendations. Their response has been summarized at
the end of each finding as appropriate. The Region's
complete response is included as Appendix B. An exit
conference was held on September 30, 1996.
VI
EXECUTIVE SUMMARY
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TABLE OF CONTENTS
Page
Executive Summary . I
CHAPTERS
1. Introduction
Purpose 1
Background 1
Scope and Methodology 3
Prior Audit Coverage 6
2. Region 1 Needs to Review Direction of
Environmental Justice Small Grants Program
A. Need to Pro-Actively Monitor Environmental
Justice Small Grants 7
Regional Response and OIG Evaluation 17
B. Selection Procedures for Environmental Justice Grants Need to
Be Re-evaluated and Strengthened 21
Regional Response and OIG Evaluation 27
3. Need to Develop Specific Strategies to Assure that
Roxbury Community College Meets Grant Goals 28
Regional Response and OIG Evaluation 36
4. Need to Close-Out Grants More Timely 37
Regional Response and OlG/Evaluation 40
5. Regional Management did not Allocate Adequate resources to
Monitoring of Environmental Education and Environmental
Justice Grants 41
Regional Response and OIG Evaluation 43
APPENDICES
Appendix A - Schedule of Outstanding Grants and Balances 45
Appendix B - Regional Comments 48
Appendix C - Distribution 55
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INTRODUCTION
PURPOSE
BACKGROUND
The mission of EPA is to assume Federal responsibility for
assisting in the protection and enhancement of the
environment. One of the major activities that EPA carries
out in pursuit of this mission is to award grants and
cooperative agreements to States and local governments,
Indian tribes, non-profit organizations, and educational
institutions. These awards can be used to run State
programs with Federal mandates and for research projects.
Based on our survey results of Region I's administration of
small grants, we focused our review on the Environmental
Justice {EJ} Grant Program as well as other selected small
grants. Additionally, we reviewed Environmental Education
Grants as part of a national review of the Environmental
Education Grant Program.
The objectives of our audit were to determine if EPA Region
I's monitoring and oversight assured that small grantees
carried out work plan objectives within the EPA approved
budget.
The EPA Region I had 588 current non-construction grants
totaling $1,036,768,615 that were opened as of September
30, 1995. The 588 grants
included 1) 283 grants with a
dollar value equal to or less than
$100,000, 2) 186 grants with a
dollar value between $100,000
and $500,000, 3) 38 grants with a
dollar between $500,000 and
$1,000,000 and 4) 81 grants with
The 283 grants of SI 00,000 or
less represent 48% of the total
number of grants awarded, but
only 1% of total grant funding.
a dollar value greater than $1,000,000.
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Environmental Justice
In 1994, President Clinton issued Executive Order 12898
establishing environmental justice as a national priority. The
Order, entitled "Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income
Populations," focused federal attention on the environment
and human health conditions of minority population's and
low-income populations with the goal of achieving
environmental protection for all communities.
EPA's Office of Environmental Justice (OEJ) served as the
point of contact for environmental justice outreach and
educational activities, provided technical and financial
assistance, and
disseminated
environmental
justice
information. In
addition, to
integrating
environmental
justice goals into EPA's various programs; OEJ established
a small grants program to aid affected community-
based/grassroots organizations, other non-profit
organizations and Tribal governments. Headquarters
funded EJ $500,000 in fiscal year 1994 and $3,000,000 in
fiscal year 1995. The regions could add discretionary funds
to EJ, if available.
REGION 1
YEAR
1994
1995
ENVIRONMENTAL JUSTICE GRANTS
NO. GRANTS AMOUNT
3 $50,000
21 $319,236
Environmental
Education
The Environmental Education Grants Program provides
financial support for projects which design, demonstrate, or
disseminate
environmental
education
practices,
methods, or
techniques. This
program is
authorized under
Section 6 of the National Education Act of 1990. EPA
headquarters awards approximately $1 million in grant funds
per year and each of EPA's ten regional offices award
approximately $150,000 to $180,000 per year.
j REGION
1 YEAR
1 1994
I 1995
1 ENVIRONMENTAL
NO. GRANTS
24
27
EDUCATION GRANTS
AMOUNT
$162,318
$196,609
>:
>
:;:
— J?
CHAPTER 1
INTRODUCTION
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SCOPE AND
METHODOLOGY
We performed our audit in accordance with Government
Auditing Standards issued by the Comptroller General.
Survey work was conducted between October 1995 and
March 1996. Our audit field work was conducted March 27,
1996 and June 28, 1996. Our audit covered the period
September 1, 1991 to October 1, 1995.
We reviewed Region I's administration and oversight of
small grants which we defined as those valued at $100,000
or less. We reviewed grants in the following program areas:
GRANT PROGRAMS REVIEWED
•• <• •.
PROGRAM
Pesticides
Environmental Justice
Environmental Education
Lead
Drinking Water
Solid Waste
TOTAL
NO. GRANTS
1
9
11
2
1
1
25
As a result of our survey work, we focused our review on EJ
small grants. Our review of Environmental Education grants
was conducted in conjunction with a nationwide review of
this program by OIG H.Q.'s Special Review Unit.
Internal Controls
Management is responsible for establishing effective
management controls. Management controls include the
plan of organization, methods and procedures adopted by
management to ensure that its goals are met. These
controls include the systems for measuring, reporting and
monitoring program performance. In order to assess
management controls over the small grants administration
we evaluated the adequacy of record keeping by the project
officers and grant management specialists. Specifically, we
reviewed files for evidence of grantee applications, grant
specialist's review of applications, executed grant
CHAPTER I
INTRODUCTION
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FMFIA
agreement, evidence of application rating, submission of
final reports, Financial Status Reports and grant fund
requests submissions, and general correspondence.
+ Evaluated the status of grant funds by comparing
grant fund balances as recorded on EPA's GIGS and
MARS databases to the grant file documents.
4 Evaluated how EPA determines whether the grantee
successfully completed the grant's intended goals
and complied with grant agreement and workplan.
+ Through on-site visits with selected grantees we
evaluated the effectiveness of EPA's grant
administration, grantees' familiarity with grant
requirements, grantees accomplishments and
adequacy of grantees accounting of grant and
matching funds.
* Reviewed the amount and adequacy of guidance for
small grants provided by EPA Headquarters Office of
Environmental Justice.
4 Evaluated grant specialist and project officer
compliance with suggested guidance for grant
administration as provided in the Grants
Administration Manual.
t Evaluated whether Regional Management adequately
staffed and allocated resources for the grant
management and project officer areas of small grant
administration.
We found tHat controls over the adequacy of record keeping
and grant fund status were adequate. However, controls
over monitoring grant accompiishments, compliance with
grant administration guidance and management's allocation
of resources were weak. Examples of these weaknesses
are provided in the audit report's findings. We have
provided recommendations to strengthen and improve
management controls over small grant administration.
In planning our audit, we reviewed Region 1's 1995
Assurance Letter to the Administrator issued October 26,
1995. The report did not note any weaknesses in grants'
management.
CHAPTER 1
INTRODUCTION
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To accomplish our audit objectives we:
4 Selected a judgmental sample of small grants having
values of 5100,000 or less from a listing of grants
showing activity in Fiscal Years 1993, 1994, and
1995.
* Focused our review on grants awarded under the
Environmental Justice and Environmental Education
Programs.
4 Reviewed the applicable Jaws, regulations, directives
and other guidance relating to the grants reviewed.
* Reviewed grants management files and project officer
files which included:
- Grant applications, budgets and work plans
- Grant agreements
- Final reports and financial status reports
* Interviewed responsible EPA Region I, Headquarters
and grantee officials.
To evaluate the effectiveness of the awarded grants, we
compared grantees' work plans to the final reports.
Additionally, we selected 20 grantees to review grant
accomplishments and evaluate the adequacy of controls
over grant funds. Site-visits were conducted with eight
grantees and telephone calls were made to two grantees.
Financial audits of the grantees' operations were not
conducted. .:"
CHAPTER I
INTRODUCTION
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PRIOR AUDIT
COVERAGE
There have been no prior audits of Region I's small grants
by the EPA Office of Inspector General.
CHAPTER 1
INTRODUCTION
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CHAPTER 2
REGION 1 NEEDS TO REVIEW DIRECTION OF
ENVIRONMENTAL JUSTICE SMALL GRANTS
PROGRAM
INTRODUCTION
A. NEED TO PRO-
ACT1VELY MONITOR
EJ SMALL GRANTS
The Environmental Justice Small Grants (EJSG) is a new
program which requires greater Regional attention than
previously provided to grantees to assure that these grants
assist minority and low-income communities with
environmental issues. Four of the five grantees we visited
had not successfully completed their work plans. The
remaining grantee had significantly amended the scope of
the work without seeking or obtaining Regional approval.
Most of the grantees indicated that their past contact with
Region 1 was limited but would welcome more involvement
by the Region. Enough time has passed for the Region to
evaluate what is and is not working for the EJSG program.
The following sections A and B provide findings of significant
weaknesses which the Region should address in its overall
review of the EJSG program.
Inadequate monitoring of the EJSC's program resulted in
the following program weaknesses
1. Grantee Performance
(a) Grantees were not following their workplans.
(b) Grantees financial records were inadequate.
(c) Grantees were unfamilairwith federal grant
regulations.
2. Regional Performance
(a) Grants were not closed out timely resulting in
unliquidated balances.
(b) Final reports were not used to identify
successful/unsuccesfui projects.
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1. Grantee Performance
Adequate staff resources were not allocated to this program.
In addition to coordinating program activities, the EJ
coordinator (EJC) was solely responsible for the
administration of 29 EJ small grants and 6 pollution
prevention grants for the New England region. These grants
were valued in excess of $750,000. Even though the EJC
was the designated project officer (PO), this responsibility
was not included in the EJC's position description nor had
the EJC received formal PO training.
The EPA Grants Administration Manual provides guidance
on monitoring grant activity and closeout. In addition,
Headquarters Office of Environmental Justice issued
transmittal #96-2, which suggested that EJCs monitor at
least 20% of small grants.
The EJC believed she was following Headquarters guidance
of monitoring 20% of the small grants. However, based
upon our review the amount of monitoring conducted was
not sufficient to identify problems experienced by the
grantees. We found grantees who were not following their
work plans, and in some cases the FY' 94 work plans had
stifl not been completed as of FY' 96. Most grantees stated
that they had very little contact with EPA and would have
liked more. In addition, information which could be valuabfe
in determining how best to implement EJ in the region or
selecting future projects was not maximized. In our opinion,
grantee performance would have been more successful had
Region 1 provided technical assistance.
Grantee performance indicated that the current level of
monitoring by the EJC was not adequate to assure grantee
compliance with all aspects of the grant agreement. In order
to determine"how effective the grantees performed, we
judgementally selected five grantees. We evaluated their
performance by reviewing the grant applications, work plans,
budgets, and final reports. We also visited each of the
selected grantees and discussed grant accomplishments,
controls over grant funds and EPA's administration of the
grants. Sections (a), (b), and (c) highlight weaknesses
found in grantee administration.
CHAPTER 2
REGION I NEEDS TO REVIEW DIRECTION
OF EJ SMALL GRANTS PROGRAM
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(a) Grantees Did Not
Follow Work Plans
and EPA Was Not
Advised of Changes
Grantees are required to adhere to their work plans.
The grantees had not advised
EPA of all changes made to the
work plans and were unaware
that they should do so. EPA is
responsible for ensuring that
public funds are adequately
protected and used for their
intended purposes. Effective
monitoring of these grants would
have identified these grantee
changes in work plan scope. The following are examples of
how the scope of work plans were changed:
Grantees must submit a
formal amendment before
changing objectives or the
scope of the project. . •_•:•
40 CFR §30.700
Roger Williams Park Zoo Planned -
Citizens Agenda
Development Fund
Actual -
Planned -
Actual -
Planned -
The significant goals of the work plan were to
conduct water quality testing and analysis, and
to develop a program to increase children's
awareness of their environmental needs and to
clean up 18 parks.
These activities were reduced and replaced
with landscape architecture, animal handling,
theater development, and video development.
Also, in-place of visiting water treatment plants,
the students visited the Bronx Zoo, New
England Aquarium and had an overnight camp
at the zoo. The grantee allowed the teen
participants to develop and implement the
program.
Publish a report listing the toxic waste sites in
the major urban areas of the state. Hold a
press event detailing toxic problems in Boston.
Compiled an internal report which consisted of
photocopies of EPA and Massachusetts
Department of Environmental Protection (DEP)
data-bases of toxic sites and hazardous waste
users in the cities of Boston, Springfield and
Worcester. No press release was held.
Outreach and education to 100 community
groups in urban communities of color about
toxic waste problems and assist them in
CHAPTER 2
REGION 1 NEEDS TO REVIEW DIRECTION
OF EJ SMALL GRANTS PROGRAM
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campaigns to encourage responsible parties to
clean-up their dump-sites in a timely and
effective manner. Speak to 20-30 groups
about grantees program and help 5-10 groups
develop local campaigns.
Actual - Outreached to 100 groups. Did presentations
to 10 groups. Worked with 3 groups by
starting to develop organizing strategies. No
toxic site clean-up strategies were completed.
Roxbury Neighborhood Planned
Council fRNC)
The project envisioned would bring into one
volume abstracts of ali environmental research
concerning air quality. The report would be
duplicated and distributed to local libraries,
community health centers, community service
centers, selected city and state agencies, and
a number of neighborhood organizations.
Actual - The grantee did not execute a contract
specifying the scope of work needed to
develop the desired guide. As a result, the
grantee was not satisfied with the guide. This
guide was provided to EPA's EJC on August
15,1995, This report contained generic
information on federal, state and local laws
covering air pollution, an overview of air
pollutants, abstracts of articles on air pollution
and a glossary of terms. A great deal of the
information contained in the guide was found in
pamphlets available at the EPA Office's
reception area. The grantee was not satisfied
with this report and had an unpaid
^ undergraduate student revise the guide. On
July 3, 1996, the group submitted a revised
report dated June 1996. The project period
was amended twice with the last project period
ending date February 1996.
10
CHAPTER2
REGION 1 NEEDS TO REVIEW DIRECTION
OF EJ SMALL GRANTS PROGRAM
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Committee for Boston
Public Housing
(b) Grantees Financial
Controls Over Grant
Funds Are Not Adequate
Planned - The grant generally called for outreach to the
23,000 people living in public housing,
identifying through surveys the most important
environmental issues to tenants across the
developments, and conducting city-wide
workshop.
Actual - As a result of this outreach a core group of 36
tenants expressed an interest in getting
information and working to address hazards in
their communities. The survey consisted of
door-knocking and passing out flyers to 1300
households at six developments. Instead of a
citywide workshop addressing specific
concerns having wide implications, the
committee selected two developments for
concentrated site-based campaigns based on
interest shown by tenants.
The committee also conducted needs
assessments, a health fair and started a youth
environmental summer camp. These activities
were not part of the grant's work plan.
Through discussions with grantees and limited reviews of
available financial documents, we found that most of the
grantees in our sample
did not have adequate
financial records. We
attribute these financial 11 Grantees should maintain aj^accur.d^eM
Control weaknesses to I ™rrent
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$7,800 would be raised to bring the total project cost to
$12,800. The grantee advised that between $3,000 -
$4,000 was raised, not the $7,800 required. However, the
grantee's Fina! Status Report (FSR) showed total project
costs of $12,800. The grantee Project Manager advised that
he completed the FSR based on the original budgeted
figures rather than actual. The Project Manager offered to
submit a revised FSR based on actual figures. We also
found that the grantee was charging the grant for a
consultant fee which was for grant application preparation.
We advised the grantee that this cost was not eligible.
Roxbury Neighborhood Council, Inc. - The project manager
advised that the treasurer of the Coalition Against the
Asphalt Plant (CAAP) rather than the RNC treasurer
maintained a checkbook from which all payments were
made to the researcher. The grant also provided that the
grantee was to provide $ 1,596 for in-kind services,
however, these services were not documented.
Roger Williams Park Zoo - The grantee received additional
funding from various sources for the project. However,
actual time charged to the grant could not be documented.
Instead, the grantee charged EPA for salary based on the
budget. The grantee also charged EPA for food for the
overnight camp, an activity not included in the original work
plan.
The Committee for Boston Public Housing - The accountant
was unavailable during our visit; therefore, the grantee was
unable to give any details on costs.
9 Grantees Were
Unfamiliar with Federal
Grant Regulations
Three of the7 grantees (Roxbury Neighborhood Council,
Mass Toxics Campaign, and Roger Williams Park Zoo) were
not aware of federal regulations governing their grants,
specifically, 40 CFR § 30 and 31. Some of these grantees
had not received federal funds in the past. They advised the
only instructions they had received were a listing of grant
instructions, which were the same for grants valued up to
$100,000. One of the grantees was surprised at the amount
of paperwork required for these small grants of less than
$10,000. Two grantees were receptive to the idea of new
grant recipients attending some type of training at the time of
12
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grant approval. This training would cover grantees'
responsibilities and what constitutes adequate record
keeping. This type of training in conjunction with proactive
monitoring will provide new grantees with the skills and
feedback necessary to ensure that public funds are
adequately protected and used for their intended purposes.
2. Regional Administration
In addition to increasing its oversight of grantee activities,
the Region needs to assure that completed grants are
closed out on a timely basis and the project results are
evaluated for use by EPA. Sections (a) and (b) provide
details.
(a) Region 1 Needs to
Close Out 1994 Grants
and Eliminate
Unliquidated Balances
The 1994 EJ grants had not been closed out in a timely
manner and grantees were awaiting their final payments.
The EJC advised that workload and unfamiliarity with the
close-out procedures
were the reasons why
the grants had not
been closed-out. In
addition, the Grants
Specialist (GS) is
responsible for
initiating grant
closeout reminder
letters 90 days before
the end of the project
period to the POs and
the grantees. The
GS stated that she
did not have the time
to send out reminder
letters.
EPA should close cut projects promptly.
Delay unnecessarily ties up obligated but:
unexpended funds. Also, closeout
becomes more difficult as time passes ' ....
because persons responsible for various
aspects of at project resign, retire, or
transfer; memories of events are less
dear; the interests of die Protect: Officer
and Project Manager shift to other
matters; and documents are lost or
destroyed.
- Chapter 40-
Grants Administration Manual
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The status of the 1994 grants as of March 20, 1996 was as
follows:
GRANTEE
Citizen's Agenda
EQ991 535010
Boston Public Housing
EQ991 536010
Dudley Street Initiative
EQ991 534010
Mass Toxics Campaign
EQ991 532010
Tellus Institute
EQ991 537010
Wobanaki, Inc.
EQ991 538010
Roxbury Neighborhood
EQ991533010
Envsronmentors (2)
EQ991531010
BALANCE
$1,000
1,500
1,100
1,600
-0-
1,500
1,200
5,000
FINAL REPORT
RECEIVED
01/10/96
08/95
10/31/94
no rec'd
09/14/95
03/11/96
08/15/95(1}
N/A
PROJECT/BUDGET
END DATE
07/31/95
05/30/95
07/31/95
06/01/95
08/30/95
09/01/95
02/28/96
01/15/95
(1) The grantee's project manager advised us that the
report submitted to Region 1 on 8/15/95 was not the final
report. The 8/15/95 report was submitted to Headquarters
as the final report. A revised report dated June 1996, was
submitted to the Region on July 3, 1996.
(2) The EJ Coordinator advised that the grantee,
Environmeniors never executed their grant because
they could not raise thier matching funds. The EJ
Coordinator was not aware of this until the grantee was
contacted to submit the final report. By not reprogramming
these funds, EPA deprived the next highest rated grantee of
scarce and limited funds. Additionally, it represented a poor
financial management practice by Region 1 by not ensuring
these obligated funds were utilized.
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(b) Timely Review of Final
Reports Will Enhance the
EJ Program
A review of EJ final reports provides the EJC with valuable
information on minority and low-income environmental
concerns. However, the EJC advised that due to workload
requirements and other priorities, she had not been able to
review all the final reports. To-date, 5 of the 7 FY' 94 final
reports were received. Of the 5 final reports received, the
EJC only reviewed 2. The EJC planned to review the
remaining final reports when the grants are closed out.
The final report was the only report that EJ small grantees
were required to submit. As a pilot effort to reduce reporting
burdens, EJ small grantees were exempt from submitting
interim reports. Therefore, the final report was a critical
document for evaluating the program's accomplishments
both regionally and nationally. The review of the final report
should be timely in order for EPA to identify successful
grantees and get these projects recognition at the national
level. Likewise, grantees whose performance was
inadequate or projects which were not successful should be
identified and not recommended for future funding.
The Region as well as EJ HQ can learn how to better serve
minority and low-income communities based upon the final
reports. EPA HQ staff advised us that they conduct only an
administrative review, not a substantive review of the final
report. EJSG is a delegated program to the regions.
Therefore, it is important for the region to recognize
successful projects with widespread applications which they
can share with the Agency and promote nationally.
As an example, the Committee for Boston Public Housing
through its 1994 EJ grant established a potential connection
between the environment and health problems affecting
tenants in public housing. This grantee determined that for
one housing development, 60% of the families had at least
one member with asthma. The grantee
was working with some of the major
Boston Hospitals to scientifically
document the possible link. This type of
information should be brought to HQs
attention. The EPA Administrator is
responsible for coordinating EJ efforts among the various
government agencies. The Departments of Health and
Human Services along with Housing and Urban
i EPA needs to recognize grant
i results.
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CONCLUSION
Development may have resources available to assist the
grantee in such a study. Additionally, recognizing a
successful grantee will be a boost for EPA's EJ program
both nationally and regionally. Without timely review at the
regional level this type of information may not be recognized
and promoted.
The EJSG program represents great potential in eiiminating
environmental injustices to low-income and minority
populations. Region 1 has demonstrated its commitment to
this principle by not only administering the national EJSG
program, but also by establishing a regional program called
the Urban Environmental Initiative (UEI). We believe our
recommendations will assist you in developing and
implementing the EJSG program in Region 1.
Region 1 needs to reassess how the EJSG program is
administered. The EJC is new to the position, has not been
fully trained as a PO and has not been provided any
resources. Additionally, the EJC could benefit by utilizing
technical assistance in reviewing grantee performance as is
done with the Ecosystems grants. Assistance can be
obtained from the EJ council, UEI, or any other program
section. For example, the EJSG and UEI programs could
work together by having the four UEI city coordinators act as
POs for grantees located in their jurisdiction. Also, by using
other program staff, EJ concepts will be integrated across all
media.
Region 1 needs to pro-actively monitor its EJSG program.
This monitoring is needed to ensure that grantees adhere to
their work pjans and use grant funds for their intended
purposes. Evaluation of project accomplishments will assist
the region and Headquarters in achieving the program's
goals of addressing the concerns of minority and low-income
communities. Headquarters defines adequate monitory as
consisting of conducting site visits, teleconferences or some
other type of meetings with grantees. The time to reassess
and enhance monitoring of EJSG is now. The EJC's
workload has increased from seven EJ grants in FY' 94 to
twenty-one EJ grants plus six pollution prevention grants in
FY' 95. In addition, FY1 96 grants will soon be awarded,
resulting in additional grants to be monitored.
16
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REGION t NEEDS TO REVIEW DIRECTION
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RECOMMENDATIONS We recommend that you:
REGIONAL
RESPONSE AND
OIG EVALUATION
1. Share the EJ project officer responsibilities with other
program staff.
2. Amend the EJC's position description to reflect PO
responsibilities.
3. Consider presenting a training class to new grantees
which will assure that grantees are aware of federal
requirements in the following areas:
- work plan execution,
- financial accounting and reporting, and
- performance reporting.
4. Assure the EJ PO advises grantees to seek EPA
concurrence on work plan changes.
5. Require closer coordination between the PO and the
GS to assure that grants are closed out timely and
grant funds are liquidated. As required, the GS
should initiate grant closeout reminder letters to the
PO and grantee 90 days before the end of the project
period.
6. Assure that final reports are reviewed timely to
recognize and promote successful results.
Region 1 agleed to share the EJ project officer
responsibilities; rewrite the EJC's position description to
include project officer responsibilities; provide training to
grantees on project management responsibilities; and
require closer coordination between the PO and GS to
assure that grants are closed-out timely. However, the
Region believed it was already showcasing EJ success
stories starting with the very first grant cycle in FY' 94.
While the Region generally agreed with our
recommendations, they did disagree with the basis for some
17
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of the recommendations. These comments follow according
to the report's applicable sections.
Regional Response
A. (1) Grantee
Performance
The Region stated that two of the FY' 94 grantees submitted
their final reports which provided information contrary to the
finding in our report. "Both grantees have conducted
activities that are consistent with their proposed activities."
016 Response
A. (1) Grantee
Performance
At the time of our audit, the EJC provided us
reports which she identified as "final" reports for the
referenced grantees. We reviewed the two grantees' final
reports, which the EJC advised were received after the audit
period. The Committee for Boston Public Housing submitted
a one page letter. This letter provided no additional
information than what was provided in the report given to us
to review. The second final report, submitted by the
Roxbury Neighborhood Council, revealed that the previously
submitted report had been edited but generally presented
the same information and data.
Regional Response
Regarding the OIG's conclusion that grantees were not
following their work plans, the Region commented that:
The goal of the EJSG program is to put the power
back into the hands of the community, which was
actually the case with the grantees referenced in the
Report. One has to recognize that oftentimes what
an applicant has proposed in their application for
funding is not always what a community wants - and
this is the lesson to be learned.
The Region continued by identifying Citizen's Agenda and
Roger Williams Zoo as examples of how grantees changed
their work plans in response to the community. In the case
of Citizen's Agenda, the Region explained that the grantee
was unable to gain the participation of neighborhood groups
because "the grantee did not receive their support." Further,
"In grantee's final report, they blamed their failure to get
community support, .... on the fact that grantee was
unfamiliar to the community and did not win community's
trust.
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In the case of Roger Williams Zoo, the Region believed the
changes to the work plan by the teens were in keeping with
the spirit of the project. The Region also believed we
"mischaracterized" the objectives of the work plan. "For
example, in grantee's proposal no reference was made to
clean up eighteen (18) parks as part of their project.
Grantee's proposal clearly states the following 'inspire the
children to take ownership of the parks by organizing a trash
clean-up in the park following the [YEP] program'. In other
words, the clean-up of 18 parks was not a deliverable of this
project."
OIG Response
We reported these instances of non-compliance with the
approved work plan because work plan revisions were not
uncommon for this program and the EJC was not aware of
these revisions. Significant work plan revisions should be
discussed with the Region not only because the regulations
require it, but also so the Region can assure the grant
programs are meeting their objectives and benefitting the
public. We are concerned that the Region identified
Citizen's Agenda as an example of a community revising a
project. As the Region itself stated, this grantee did not
receive the support of the community it was trying to serve.
In our opinion, not obtaining community support for a project
that is targeted towards helping a community is a serious
problem. Accordingly, in Section B of our finding, we
discussed the problem non-community based groups had in
carrying-out their projects.
We disagree that the work plan for Roger Williams Zoo did
not include a reference to clean-up 18 parks. One of the
work plan objectives was to, "Deliver the teen-led program to
children gathering for free lunches at 18 urban parks." The
work plan described the teen-led program as follows: "The
youths will present the program to urban children who come
to city parks to participate in the federal lunch program.
After the program the younger children will be empowered to
take care of their neighborhood by cleaning up the park."
The grantee advised us that this was done but at a reduced
level as we indicated in our finding.
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Regional Response
A. (2) Regional
Performance
In response to our conclusion that final reports were not
used to identify successful/unsuccessful projects, the
Region stated:
Typically, a successful project can only be determined
upon completion of the project. At the time of your
review (Oct1 95 - March' 96) only three of the nine (9)
FY' 94 Grant Recipients had completed their projects
and consequently submitted their final reports.
The Region also stated that it had showcased the work of
one grantee with an environmental tour. Also, successful EJ
projects were presented during Environmental Justice
Council meetings.
016 Response
A. (2) Regional
Performance
As stated in our Scope and Methodology section, our survey
work was conducted from October 1995 to March 1996 and
our audit field work was conducted from March 27,1996 to
June 28, 1996. An entrance conference was held with the
Region to explain the difference between the survey and
audit phase. During a foflow-up conversation regarding the
Region's response, the EJC agreed that only 7 final reports,
not 9 were due for FY' 94. The EJC also indicated that the
figure of 3 in the response may have been in error. During
the audit the EJC provided us with 6 reports which she
identified as "final" reports.
As already noted in our finding, at the time of our audit, the
EJC had reviewed only two of the reports due to workload
requirements and other priorities. We were concerned that
workload constraints would prevent further review of other
final reports. Also, we believe that Region 1 should also be
sharing information learned from this program on a
nationwide basis.
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B. SELECTION
PROCEDURES FOR EJ
GRANTS NEEDS TO
BE RE-EVALUATED
AND STRENGTHENED
50% of grants awarded to '
environmental groups vs
affected community groups.
The Environmental Justice Small Grants (EJSG) application
and selection process needs to be re-examined to
encourage greater participation by community-
based/grassroots organizations as well as to assure that the
grants meet the program's intended purpose. One-half of
the 1994 EJ small grants were awarded to environmental
entities rather than to affected community-based/grassroots
agencies. While environmental
entities may be more experienced
in preparing grant applications, our
review did not show that they were
more successful in carrying out
their projects. In some cases,
unfamiliarity with the communities
they were serving was the reason why they did not complete
their original work plan. The EJSG program was established
to award funds for designing, demonstrating or
disseminating practices, methods, or techniques which
address environmental justice concerns. EPA did not intend
to award grants simply for the dissemination of EJ
information. Yet, that is what some of the 1994 grantees
did. Region 1 stated that, "The analysis that goes into the
evaluation of the EJSG applications is continually being
perfected." While the Region was taking steps to improve
the application and selection process they did caution that,
"... this is not a science and we will continue to do our best in
applying sound judgment in this regard."
The Federal register dated December 3,1993 provided the
following criteria for eligible activities:
The purpose of the grants program is to provide
financial assistance and stimulate a public purpose by
supporting projects to any affected community group
(for example, community-based/grassroots
organization, school, education agency, college or
university, and non-profit organization) and tribe who
engage or plan to carry out projects to address
environmental justice issues. Projects that focus on
the design, methods, and techniques to evaluate and
solve environmental justice issues of concern to
affected communities will be given priority. Funds
21
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can be used to develop a new activity or to
substantially improve the quality of existing ones.
EPA is interested in funding environmental justice activities
that go beyond providing information to community groups
or citizens. Dissemination of environmental justice
information, by itself, is not an environmental justice project,
although such information may be an essential element.
Environmental justice information provides facts or opinions
about environmental justice issues or problems, but does
not necessarily enhance critical thinking, problem solving, or
effective decision-making skills.
Our review found some of the grantees from the 1994 EJ
small grants program did not meet the intended program's
purpose; were similar in scope, promised more than they
could deliver, and may not meet grantee eligibility
requirements. Examples of these grants were as follows:
Grants Did Not Meet
Program's Purpose
The Roxbury Neighborhood Council, Massachusetts Toxic
Campaign Fund, and Citizens Agenda Development Fund
each planned to issue reports which would educate urban
neighborhoods of color on toxic waste problems and identify
the areas of pollution in the Greater Boston area. These
grantees planned to issue their reports to the media and/or
make them available to the public. The grantees' goals
were dissemination of information. None of these grantees
provided designs, demonstrations, methods or techniques to
evaluate and solve environmental justice issues of concern
to affected communities. For various reasons, none of these
grantees have been successful in issuing the planned
report.
Region 1 awarded fifty percent of the grant funds to
environmental action groups as opposed to community
based/grassroots organizations in the affected areas. Being
known by the affected community
was an important part of the group's
ability to carry out their project. A
community-based group such as the
Dudley Street Initiative accomplished
their work plan according to their final
report. The Committee for Boston
The.purpose of:thei:grant;
program was ^ to provide
financial assistance; to any
affected group:;?•• 'Klj :&•'•
1994 EJ Guidance^
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Environmental groupsr:
unfamiliar with affected
communities, \; ;<. ;..
Public Tenants identified a potential link between the public
housing environment and tenant health.
Some groups were not located in the affected
neighborhoods and had not established contacts with
affected neighborhood leaders. For
example, the Project Manager for the
Citizens Agenda Development Fund
advised that one reason why their
grant's goals were not achieved was due
to the group not being known by the
affected community. Citizens Agenda
Development Fund was located in
downtown Boston and had worked primarily with suburban
and rural communities. Additionally, the grantee's
unfamiliarity with the neighborhood impacted his ability to
utilize the database information. The Project Manager did
not know if the streets, identified as having pollution
problems, were located in the affected neighborhoods.
Similarly, the Massachusetts Toxics Campaign's Project
Manager advised that one reason for reducing the scope of
his project was his unfamiliarity with Boston's impacted
neighborhoods. The Environmentors, a Washington D.C.
based environmental group, never executed their grant
award because they could not raise the matching funds.
These environmental action groups could provide valuable
services to affected community-based groups. However,
funding the affected, local groups and allowing them to seek
the services offered by these action groups would result in
more effective use of grant funds. Based on these results, it
is our opinion that funding the affected community-based
groups would result in more tangible benefits to the affected
citizens.
Region 1 indicated it will seek Headquarters OEJ support to
make appropriate changes in the application process to
assure that community groups are fairly represented.
Duplication Of Efforts By
Funded Grantees
The Massachusetts Toxics Campaign Fund, Citizens
Agenda Development Fund and Tellus each planned to
prepare a report on toxic sites within the greater Boston
area. Each of these grantees planned to extract data from
the EPA and Massachusetts Department of Environmental
23
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REGION I NEEDS TO REVIEW DIRECTION
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Protection (DEP) databases such as the Toxics Release
Inventory (TRI) and the Geographic Information Service
(GIS). These grantees planned to educate communities on
the disproportionate share of toxic waste sites in
communities of color in the area. The Tellus project used
the information to identify common pollution sources and
provided prevention techniques. The Citizens Agenda
Development Fund extracted copies of these databases but
found that they were arranged by street name and since the
grantee was not familiar with the areas or neighborhoods,
the data was not of much use. The Massachusetts Toxic
Campaign's project was to be completed on June 1, 1995.
The project manager advised that about this time, he put
aside the project work in order to complete work on his
dissertation. He resumed working on the grant in April 1996,
ten months after the date the project was to be completed.
Applications Promised
More Than Delivered
Three of the five grantees we visited, Citizens Agenda
Development Fund; Massachusetts Toxics Campaign Fund;
and the Committee for Boston Public Tenants advised that
their grant applications promised more than the grantee
could accomplish with the funds received. Although the
grantees reduced the scope of work, only one notified EPA
of the grant changes. None of the grants were formally
amended to show the reduction in scope of services. The
grantees were funded based on their planned goals and
accomplishments. EPA needs to improve its analysis of
applications at the time of selection by comparing intended
accomplishments to available funding. Applications
promising goals which cannot be accomplished with
available funds should be rejected. This will allow well-
intentioned applicants who might plan a less grand, but
more realistic project an equal chance to receive funding.
The EJ Small Grants Program was intended to provide
funding to minority and low-income communities. Some
community groups may not be experienced in grant
application preparation. As a result, EPA needs to re-
evaluate its selection procedures for this program.
Otherwise, established environmental groups, experienced
in grant application writing will have an advantage over the
affected, local community-based organizations. EPA
funding of diverse community-based organizations will also
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Review of Eligibility
Requirements for Grant
Funds Needs to be
Improved
aid in preventing duplication of efforts by grantees, as
occurred when funding went to environmental action groups.
Additionally, funding the affected community-based groups
will result in projects that focus on solving environmental
justice issues of concern to the community rather than
providing them with information/data that may already be
known to the group or is accessible from the EPA or
Massachusetts DEP.
Region 1 stated it "will take every step to ensure that the
grantees adhere to the grant condition that requires them to
submit for approval, written request identifying any changes
to grant scope or budget." Additionally, Region 1 plans to
institute as part of the grant conditions, three mandatory
meetings of the grantees. The first meeting will occur at the
time the awards are made and will focus on the
responsibilities of both the Region and the grantees during
the project period. The second meeting will occur during the
middle of the budget period to determine grantee progress.
The third and final meeting was described as a "show-case"
meeting which "will allow grantees to share their wonderful
stories and learn from each other in the process."
Another issue of concern raised during our audit dealt with
the
requirements
Any affected community group, tribal .
government ana non-profit organization
may apply lot funding. Only non-profit ;
organizations, community groups,
institutions, ana tribal governments, not
individuals, are eligible to apply tor
funding.
Federal Register
December 3, 1993
over who was
eligible to
apply for EJ
funding.
We did not find
any direct
violations with
regard to this
requirement,
however, two grantees provided examples of a weakness in
identifying eligible grantees. One grant was awarded to
Roxbury Neighborhood Council, a non-profit community-
based group. However, the project direction and funding
was controlled by a coaiition group of which the grantee was
a member. The coalition group represented a larger, diverse
geographic area and was not incorporated or non-profit,
making it ineligible for grant funds.
25
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CONCLUSION
RECOMMENDATIONS
Another grant was awarded to Massachusetts Toxics
Campaign, a non-profit organization which, soon after
receiving funding, lost its source of operating funds from its
national organization. The national organization was
dissolved. The local organization continued to exist but was
comprised of all volunteers. The project manager for this
grant is completing the project by himself and has control
over the grant funds. This situation comes close to funding
an individual.
Region 1's Environmental Justice Coordinator advised that
when applications are evaluated the reviewer takes the
grantee's statement on the application that it is a non-profit
at face value. Due to the new type of grantees being
targeted for EJ funding, EPA needs to strengthen its controls
in this area in order to ensure that only eligible grantees are
provided funding under the EJ Program.
Region 1 will research how others confirm non-profit status
and implement any appropriate changes.
The EJSG program is at a point where the Region should
evaluate what types of grantees and projects work best to
meet community needs. Grantee and project selection are
pivotal in assuring that community needs are met
Community knowledge and organizational skills are
important in carrying out grant work plans. Region 1 should
work with Headquarters OEJ and other regions to develop
the best procedures for grant application/selection.
We recommend that you:
1. Streamline the EJ application process to encourage
the selection of more affected, community-based
grassroots organizations.
2. Ensure that application evaluators analyze stated
goals to available funds in order to ensure grant
projects are feasible.
3. Require grantees to submit formal grant amendments
to reflect any changes to grant's scope or budget.
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REGIONAL
RESPONSE
4. Verify the non-profit status of applicants.
5. Require grantees to advise the Region of any
significant funding/organization changes.
The Region stated: "We feel that non-profit
organizations can provide useful service to the targeted
communities that is consistent with the EJSG Program
protocol. However, we do support community-based
grassroot organizations in taking the initiatives to address
their own environmental justice issues and will continue to
improve the EJSG solicitation process to achieve this end"
OIG RESPONSE
While it is possible that non-profits can provide useful
services, the examples we reported showed that non-profits
without community support can have a difficult time doing
so. In the future, the Region may want to assure that non-
community based groups have community support.
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CHAPTER 3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
ASSURE THAT ROXBURY COMMUNITY COLLEGE
MEETS GRANT GOALS
Roxbury Community College (RCC) was making limited
progress toward its grant goal of providing lead abatement
and other related training which would lead to jobs in the
community. This was due in part to Regional staff approving
a work plan which did not include tasks
specific enough to assure successful grant
completion. Additionally, Region 1 had not
assured that RCC understood its financial
responsibilities as a grantee. Regional
staff acknowledged that they were under
time constraints to award the grants.
Therefore, the work plans and other grant
documents were sufficient just to award the grants.
Additionally, the Region desired to allow maximum flexibility
for this new project. RCC staff stated that they concentrated
their first year efforts on establishing the center rather than
training. As a result, so few students had signed up for
classes that classes could not be held.
Work plan tasks not
specific enough to assure
successful grant
completion.
RCC was awarded $46,000 on September 27,1994 to
establish an environmental education center for lead
abatement training and
other training related to
toxic substances for the
period October 1, 1994
to September 30, 1995.
Another grant for
$73,128 was awarded
on September 28, 1995
for Phase II of the
establishment of an
environmental education
training center for lead
STATUTORY AUTHORITY FOR GRANTS
Funds are granted to assist States and territories ..
in developing and carrying out authorized "/
programs for accrediting training programs for".
persons engaged in lead-based paint activities | ---;
and certifying contractors engaged in lead-based "
paint activities. ' t- ~ * \ - / ,
Toxic Substance Contra!,Act (TSCA);
S*ctkm404(g>';
28
-------
a. Work Plan
Accomplishments
abatement for the period October 1, 1995. to September 30,
1996.
RCC is part of Massachusetts' public higher education
system and is accredited by the New England Association of
Schools and Colleges, Inc.
According to the Fiscal Year 1995 work plan, the
communities surrounded by RCC have been identified by
EPA as having high rates of lead poisoned children. In
order to address this issue, EPA formed a consortium with
surrounding agencies including Federal, State, and City with
the following goals:
+ Develop a trained work force of minority-owned
contractors trained in safe lead paint removal to be
hired under state and city contracts to work in inner
city neighborhoods where the risk of childhood lead
poisoning is high.
+ Establish a lead abatement training center in the
minority community.
* Provide lead
abatement job
opportunities for
minority lead
abatement worker.
* Provide business
development
assistance to minority
lead abatement
contractors.
The grants to RCC were to
assist in carrying out the
above goals of the lead
abatement project.
While the grant goals were
fairly specific, the work plan
tasks were vague on how
these goals would be met.
Fiscal Year 1995 Grant Goals
1. Work with the EPA to accomplish the
objectives of the Environmental Justice
Lead Abatement Training & Employment
Opportunity Pilot Project.
2. Establish an advisory committee in
which the scope of the environmental
educational center can be defined'and
work guided.
3. Provide specific lead abatement training
to low income and minorities..
4. Determine whether the needs of the
community are best served by the
Educational Center being a direct provider
of the training, a contractor, broker, or al!
of the above.
5. Seek funding which will increase the size
and scope of the Environmental
Educational Center for Training.
29
CHAPTER 3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
ASSURE THAT RCC MEET PROGRAM GOALS
-------
For example, Task 1 only provided that "Coordinator works
with Pilot Project participants to refine and carry out
objectives"; Task 2 provided, "Coordinator becomes familiar
with the human and physical plant resources of Roxbury
Community College in order to increase the success of the
Education Center"; Task 7 provided, "Coordinator defines
the scope of future work through the Environmental
Educational Center at Roxbury Community College". The
remaining tasks are similarly vague. EPA's "Managing Your
Financial Assistance Agreement - Project Officer
Responsibilities" handbook states that work plans should
describe the method to accomplish the objectives.
The Manager of Pesticides, Toxics and Radiation Unit
stated:
As for the FY' 95 grant, the lack of specificity can be
attributed to the need to provide maximum flexibility in
meeting the project goais. As a pilot project, there
were various potential methods for achieving the
stated objectives. The EPA project officer and the
RCC project manager met on numerous occasions
while establishing the Advisory Board. Once
established, the Board provided input on how to meet
the goals. The EPA project officer did not develop
any amendments to reflect these adjustments as the
project developed, which would have been advisable.
We believe the undefined tasks on how RCC was to
accomplish its goals contributed to the project's limited
success especially in the area of providing training.
Additionally, Region 1 staff had not adequately advised
RCC that grant activities typically occur during the project
period designated on the signed Grant Agreement. The only
lead abatement training given, occurred prior to the grant
period. Region 1's Manager of Pesticides, Toxics and
Radiation Unit stated that:
This training was intended for the grant period,
however, it was necessary to complete the training in
a specific time period. The EPA project officer
believed that RCC could receive credit and be
reimbursed for the courses when the grant was
signed. RCC acted in good faith and provided the
CHAPTER 3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
30 ASSURE THAT RCC MEET PROGRAM GOALS
-------
training prior to the commencement of the grant
period. It was inappropriate for the project officer to
advise this course of action and not request the
appropriate deviation to insure grants administration
procedures were followed.
While there may have been some confusion on project
periods initially, we believe this response does not
adequately explain the lack of success of this project. Lead
abatement classes as well as classes in Environmental Law
and Indoor Air Quality were offered by RCC during both the
Fiscal Years 1995 and 1996 project periods identified in the
grant agreements.
RCC's Program Manager said establishing the center was
the priority for the first year's operation. We believe start-up
activities did not significantly hamper the project's progress
in providing training. RCC's Project Coordinator had already
been hired prior to the start of the project period and a
facility already existed. Lead abatement training had been
offered prior to the project period as defined in the grant
agreement and then offered again with other environmental
courses during the grant project period.
As of April 1996, so few students had enrolled in any of the
environmental courses offered that RCC was unable to hold
classes. Additionally, RCC advised us that of the 15
students who completed the lead abatement course held
prior to the project period as stated in the grant agreement,
only 3 students were able to get jobs. In our opinion,
adequate planning on how to attract
students had not been done. We
believe cost and practicality of course
offerings were not well considered. The
State Department of Employment and
Training subsidized $800 of this course's
tuition for the students who took the training held prior to the
project period. No one enrolled in this course when it was
offered during the grant project period at the unsubsidized
tuition of $955. The experience of past students in obtaining
work may also have had a bearing on the lack of follow-up
enrollment. We also noted that non-credit courses for a fee
were offered. In our opinion, such courses are probably not
an attraction since these courses would not lead to a degree
Environmental courses canceled
due to lack of enrollment
31
CHAPTERS
NEED TO DEVELOP SPECIFIC STRATEGIES TO
ASSURE THAT RCC MEET PROGRAM GOALS
-------
or a job. Also, students cannot get financial aid for non-
credit courses. RCC's Project Coordinator stated that she
has taken steps to make the course offerings more attractive
to students. For example, internships possibly leading to
employment will be offered. Also, course tuition was being
reduced. For example, the Lead Abatement course was
being offered for $475 for the 1996 summer semester.
However, this reduction in tuition is not a reduction in the
student's cost to be certified. The original course offered at
$955 included a required physical examination and
certification. Now the student must obtain the physical and
certification on their own.
Again, we believe Region 1 and RCC need to better plan how
training will be provided so that the grant project's goals are
met. Region 1 and RCC may also wish to work with other
State or federal agencies as well as private businesses to
address such impediments as cost of courses or employment
opportunities.
Region 1 and RCC were working to address these issues.
On April 16, 1996 Region 1 revised the project scope to
include tasks such as executing a marketing approach
targeted toward minority candidates; investigating payment
options for courses; developing information regarding
prospective employment opportunities for graduates; and
developing and administering follow-up evaluation with
graduates. Additionally, measures of success to assure that
classes are delivered, attended, and evaluated were also
added.
RCC was also responsible, "to determine whether the needs
of the community are best served by the Education Center
being a direet provider of the training, a contractor broker, or
all of the above". While Region 1 did not require the grantee
to provide a formal report, we believe it should be
documented how the community needs were assessed and
the resulting conclusions. RCC staff commented that the
prior lead abatement training was provided by a contractor.
RCC was interested in obtaining state certification to conduct
lead abatement training on its own but needed to purchase
equipment which could be expensive. Since lead abatement
training was a grant goal, this is an issue Region 1 staff may
wish to discuss further with RCC.
CHAFFER3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
•>2 ASSURE THAT RCC MEET PROGRAM GOALS
-------
The Manager of Pesticides, Toxics and Radiation Unit stated
that RCC engaged in a number of outreach activities in the
community to determine how best RCC could serve as an
Environmental Education Center but had not documented
these activities. The current grant has since been amended
to require monthly progress reports documenting activities,
issues, lessons learned as wel! as financial expenditures. In
addition, there will be a requirement for bi-monthly
communication with the EPA project officer.
Performance goals will be documented and opportunities for
mid-course corrections will be identified and documented in a
timely fashion.
Another goal was to seek funding which would increase the
size and scope of the Environmental Center for Training, The
RCC Program Manager stated that EPA was the only source
approached to obtain additional funding; he commented that
RCC had received two other EPA grants. The Manager of
Pesticides, Toxics and Radiation Unit was under the
impression that RCC would canvas other institutions for
additional funding. Again, we believe if a specific task had
been included on how RCC would seek additional funding,
this misunderstanding coufd have been avoided.
The Region has since amended the current grant to require
RCC to develop an overall implementation budget and
funding strategy.
Some of the activities sponsored by the Center during Fiscal
Year 1995 were an Environmental Career session for area
high school students; a public dialogue on Revitalization and
Brownfieldsj and a Massachusetts Residential Environmental
Fair. These activities were not included in the work plan.
RCC established an Advisory Board as required by the work
plan. Meetings were held monthly except for the
summertime.
33
CHAPTERS
NEED TO DEVELOP SPECIFIC STRATEGIES TO
ASSURE THAT RCC MEET PROGRAM GOALS
-------
b. Financial Responsibilities RCC was unfamiliar with federal grant accounting practices.
Additionally, its own internal controls were not adequate to
support personnel cost allocations or control its budget. As a
result, RCC did not submit a timely Financial Status Report
(FSR). The EPA Project Officer said he had provided an
information package explaining grantee responsibilities and
discussed contents with the RCC staff. The RCC staff said
they had not.received the package. Without adequate
internal controls there is no assurance grant funds will be
used for their intended purpose.
The Fiscal Year 1995 grant agreement required: "The
recipient agrees to submit a final FSR no later than 90 days
after the end of the project period." The project period ended
September 30, 1995 making a final FSR due by January 1,
1996. During a meeting on January 22, 1996, the grantee's
Financial Consultant stated that an FSR had not been
submitted because he did not know how to complete the form.
He was not aware that he could refer to 40 CFR § 31,
Uniformed Administrative Requirements for Grants and
Cooperative Agreements to State and Local Governments or
OMB Circular A-110, "Uniform Requirements for Grants and
Other Organizations" for guidance in accounting for grant
funds. The grant award documents which the grantee signed
did show the appropriate governing CFR reference. The EPA
Project Officer said he had explained the FSR requirements
with the grantee's Financial Consultant and mailed three
packages on grants management to the grantee.
Also, during our January 22,1996 meeting, the RCC's
Financial Consultant said that RCC's Project Coordinator's
time was not charged on an actual basis to the grant. The
Project Coordinator and the Financial Consultant estimated
time worked:ion grant activities. RCC's Financial Consultant
said he recognized this as an internal control weakness and
was taking corrective action.
A December 2, 1995 joint report issued by the
Commonwealth of Massachusetts offices of the Auditor and
Comptroller reported that RCC needed improvements in
internal control practices and its budget process. Budget
overruns were not uncommon; 13 of RCC's 30 departments
over expended their budgets. RCC was preparing an Internal
Control Manual to address the weaknesses reported.
CHAPTER 3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
34 ASSURE THAT RCC MEET PROGRAM GOALS
-------
Based upon the State's review and the grantee's statements
regarding their unfamiliarity with grant and accounting
regulations, we believe EPA needs to direct more attention to
RCC to assure that past and any future grant funds are
properly accounted for.
In response to our concern, the Region revised the work plan
to require a training session on grantee fiscal responsibilities,
monthly financial reports, and a clear process for tracking
hours on an actual basis for the project.
CONCLUSION
In summary, the Manager of Pesticides, Toxics and Radiation
Unit stated:
EPA and RCC have reevaluated the objectives of this
project and have agreed on changes in the scope of
work, the priorities for continued development of the
center and specific tasks and milestones. These will all
be properly documented.
The Manager continued:
We believe all of your concerns (and ours) are being
addressed in the FY '96 grant. This project is an
important step for the development of a sustainable
educational infrastructure for the surrounding
community. RCC's success will serve to strengthen
environmental stewardship in the community and
increase the pool of environmental professionals from
multi-cultural backgrounds.
Based upon the results of our review, Region 1 staff needed
to be more involved overseeing the progress of this project as
well as assuring that RCC understood its responsibilities as a
federal grantee. Since our review, the Regional staff has
amended the FY '96 grant to include many of our
recommendations. However, the Regional staff also should
not lose sight of the fact that these grants were awarded as
part of an effort to reduce the risk of lead poisoning in children
by developing job opportunities for the community in lead
paint removal. These grants were funded under TSCA with
35
CHAPTER 3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
ASSURE THAT RCC MEET PROGRAM GOALS
-------
the objectives of "accrediting training programs for persons
engaged in lead-based paint activities and certifying
contractors engaged in lead-based paint activities." Simply
setting up an education center, offering a variety of courses,
or hosting various outreach activities, etc. is drifting away from
the original intent of this project to provide lead abatement
training which would provide the community with economic
opportunities and health protection.
RECOMMENDATIONS Region 1 has accepted our recommendations as follows:
1. Review current work plans and revise accordingly to assure
that goals and timetables are reasonable and that the
methods to accomplish the goals are well defined.
2. Include as part of the grant special conditions the
submission of progress reports. Such reports should tie into
the work plan goals such as number and description of
classes provided, students attended, student success in
obtaining employment.
3. Include as part of the work plan a way to determine the
success of the project.
4. Meet with RCC staff to determine why past EPA efforts to
inform the grantee of its financial responsibilities were not
successful.
5. Require RCC to maintain payroll records on an actual
basis.
We also recommend that you:
6. Assure that the project staff obtains and follows the Internal
Control Manual RCC was working on as reported by the State
Auditor and Comptroller.
REGIONAL
RESPONSE AND
OIG EVALUATION
The Region did not provide written comments in response
to this finding in our draft report.
36
CHAPTER 3
NEED TO DEVELOP SPECIFIC STRATEGIES TO
ASSURE THAT RCC MEET PROGRAM GOALS
-------
This page intentionally left blank
-------
CHAPTER 4
NEED TO CLOSE-OUT GRANTS MORE TIMELY
Grant close-out should be
completed within six months after
the end of the agreement
- Chapter 40
Grants Administration Manual
Region 1 has not closed-out 79 grants with an outstanding
balance of $3,637,766. These grants are between six months
to as many as thirty-three months past the project ending
date, and continue to remain open. The Grants
Administration Unit's Manager
provided several reasons for
grants not being closed-out
timely and advised that close-
out procedures were being
reviewed for streamlining
possibilities. By not
deobiigating the funds, the
agency is unnecessarily tying-up
unexpended funds that otherwise could be utilized.
While conducting our audit of small grantees, we found
several grants having project periods that ended on
September 30, 1995 or earlier, with balances remaining in the
accounts.
In order to
determine
the extent
of this
problem,
we
expanded
our review to include all grants. We utilized a Grants
Information & Control System's (GIGS) printout dated March
18, 1996. This report provided the grant number, project and
budget ending dates, project officers' names and the grant
specialists' initials. We compared this report to a
Management and Accounting Reporting System's (MARS)
report dated March 20, 1996 showing total obligations,
amounts paid and balances available. We listed all grants
ENDING DATES
01/01/95-09/30/95
01/01/94-12/31/94
01/01/93-12/31/93
NO. OF GRANTS
62
15
2
AGING OF
GRANTS
6 months +
18 months +
30 months +
37
-------
and the amounts remaining in the balances for those grants
having a project period ending September 30, 1995 or earlier.
Our analysis of grants with project periods ending September
30, 1995 or earlier found 79 grants with corresponding
balances totaling $3,637,766.
The specific grant numbers with project/budget ending dates
and balances are provided on Appendix A.
An update to the Grants Administration Manual dated August
27, 1992 provided the following suggested guidance for
grants administration specialist on close-out of grants.
The grant specialists prepares a "completion alert" for the
EPA Project Officer 90 days before the end of the project
period. This memo requests information on whether the
project/budget period needs to be extended or if the
assistance award can be closed-out. A letter should be
mailed to the recipient 30 days after project completion.
When the project completion date is 90 days old, the grants
administration specialist will review these projects to
determine whether another follow-up letter is needed. At 120
days after the project completion date, the grants specialist
should check with the project officer and issue the grantee a
follow-up letter setting a specific date for the grantee to
respond. Close-out should be completed within six months
after the end of the agreement.
The Grants Administration Manager advised that the Close-
Out Procedures were being reviewed for streamlining
possibilities, especially for small grants with balances under
$5000. Grants Administration has been working with the
Region I Finance Office since December 1995 to develop
"Fast Track tMose-out procedures for old and small grants to
identify and deobligate unliquidated obligations on inactive
grants. Additionally, the Grants Administration Manager
advised there is a Grants' Close-out Team working to close-
out these type of grants.
Further, the Grants Administration Manager provided several
reasons as to why these grants were not closed-out in a
timely manner. Some reasons provided were:
+ Of the 79 grants listed, 55 were for State Continuing
Programs. Close-out of these programs is a low
38
CHAPTER 4
NEED TO CLOSE-OUT GRANTS TIMELY
-------
priority for a number of reasons. It is the policy of this
Region to reissue these funds to the states for
additional activities. Most states request and receive
an extension for submittal of their Financial Status
Reports (FSRs), so accurate balances of unexpended
funds can be identified for carryover purposes.
Another reason that can delay timely close-out is the
lack of an approved final indirect cost rate.
4 Work effort in fiscal year 1996 was significantly
impacted by the Continuing Resolution which resulted
in many rounds of funding intervals, furloughs and the
dedication of resources for the Project Officer training
required by headquarters.
4 A higher priority for processing awards over closing out
grants.
4 The Policy and Procedures'Specialist was on detail to
another office division.
The Grants Administration Manager agreed with a number of
our observations regarding the need to close-out grants more
timely. His own review identified additional grants from prior
years that need to be closed-out. Further, he advised that the
following actions have been or will be taken to close-out
grants more timely:
4 Reallocate workload to ensure equitable distribution
f Streamline guidance as much as possible to facilitate
the close-out process.
4 Provide training to Project Officers on Close-out.
4 Prioritize the close-out of completed grants but highest
priority will remain with the processing of awards.
4 Use additional resources from outside the Grants
Management Unit to expedite close-outs. Close-out of
grants was an area identified by the Office of
Administration and Resource Management staff as
needing additional support.
39
CHAPTER4
NEED TO CLOSE-OUT GRANTS TIMELY
-------
CONCLUSION
Revise the close-out policy to expedite the close-out
process.
Identify and deobligate funds on the noted grants.
Close-out all completed grants.
The Grant Administration Unit's Manager provided some
positive actions to address the Region's need to close-out
and deobligate closed-out grants. Region I Management
needs to explore all options to assure that adequate
procedures/ policies are established and followed that will
result in the timely close-out of small grants.
RECOMMENDATIONS We recommend that you:
1.
REGIONAL
RESPONSE
OIG RESPONSE
Ensure that grants administration specialists follow
guidance for timely cfose-out of grants.
2. Ensure that the listed grants are given priority for
immediate close-out.
The Region agreed in general with the recommendations to
correct deficiencies in the grants administration process and
had already taken corrective action in some cases.
We concur.
40
CHAPTER 4
NEED TO CLOSE-OUT GRAiNTS TIMELY
-------
CHAPTER 5
REGIONAL MANAGEMENT DID NOT ALLOCATE
ADEQUATE RESOURCES TO MONITORING OF
ENVIRONMENTAL EDUCATION AND
ENVIRONMENTAL JUSTICE GRANTS
Regional Management allowed Environmental Education and
Environmental Justice grant program activities to remain
unstaffed when Project Officers were on extended leave. As
a result, no monitoring was conducted or the monitoring which
was conducted was insufficient to assure that grantees
complied with the terms of their grant agreements. Prudent
management practices would not allow important positions to
remain vacant for extended periods of time without coverage
of their most important functions.
In contrast to the EJSG program, the EESG program had an
established monitoring system in place. However, this system
could not compensate for a lack of EPA staff to overview
grant activity. The EJSG program needed to develop an
active monitoring practices. However, the lack of EPA
personnel available to conduct any type of monitoring when
the EJC was on extended leave just further exacerbated this
problem.
The Environmental Education Coordinator (EEC) worked on a
part-time basis. She had a job-share partner but this
individual was not involved in grants management and
recently resigned. A paid individual from the American
Association of Retired Persons (AARP) assisted the EEC with
grant monitoring. He was not an EPA employee and worked
13 hours a week for the Region. He assisted the EEC by
processing environmental education grants, responding to
requests for information from the public, writing reports related
to grantees' progress, communicating between Region 1 and
Headquarters Environmental Education Division.
41
-------
The EEC estimated that she was on various periods of
extended leave amounting to 8 months within a 14 month
period {this estimation included 5 weeks of a government
wide shutdown). She also said she had three supervisors
during this time. When the EEC was on leave for 6 weeks
recently, her job-share partner was also on leave. The
person who filled-in for the EEC's job-share partner was
unfamiliar with the EEC's grant responsibilities. This person
was given the priority to work on the "Earth Artist" project.
As a result of the lack of coverage of the EEC's grant
activities, the EEC sometimes missed indicators of grant
performance requiring follow-up action because she relied too
much on the AARP's conclusions. In one case, a grantee
presented only 2 rather than the 10 workshops agreed to in
the work plan and still received the entire grant amount.
According to the EEC, the grantee should have been required
to explain how the entire funds were expended and a
determination made whether or not to withhold funds. This
was not done; she said that this one got by.
All the monitoring reports we reviewed were conducted by the
AARP; we did not see any reports by the EEC. Our
conversation with the EEC on her acceptance of one report
indicated that the EEC should increase her review of the
AARP's work. The EEC agreed with our assessment of a
final report which did not adequately explain how the grantee
carried out its work plan. The EEC described the style of the
report as "cutesy" and the contents as "lame". However, the
AARP had reviewed the report and determined it to be "OK".
Relying upon the AARP's assessment, the EEC authorized
the final payment. In another case, the AARP conducted a
mid-year review by phone and noted that the grantee would
be late in completing the project by one month. No follow-up
actions were recommended. We conducted a similar phone
review one week later and found that the grantee was
experiencing financial difficulties and that the new project
manger was unfamiliar with grant progress. In our opinion,
such information would indicate a need for some type of
follow-up action by the Region.
42
CHAPTER 5
REGIONAL MANAGEMENT DID NOT ALLOCATE
ADEQUATE RESOURCES TO MONITORING
EE AND EJ GRANTS
-------
The EJC stated that she was on maternity leave from
September 1994 to December 1994. During that time, no one
filled-in for her other than an intern who worked
on processing the grant proposals. As already
reported in Chapter Two, a more active
monitoring system needs to be developed for
the EJSG program. However, any
monitoring system developed will not be useful
if there is no one to implement it. The EJC will
again be on maternity leave in the near future. Regional
management needs to plan now to assure that improvements
it is currently making to monitor EJ small grantees will not be
lost.
CONCLUSION
The function of grant monitoring is very important because it
assures that EPA funds are providing expected benefits to
designated recipients. We believe it is a function which
should receive as high a priority as awarding grant funds.
Regional management needs to develop a plan to assure
such a critical function continues to be carried-out when staff
is on extended leave. Regional management should also
assure that this function is properly carried out and
supervised by EPA staff.
RECOMMENDATIONS We recommend that you:
1. Develop a plan to assure that critical functions of
personnel who are on extended leaves of absence are
covered.
REGIONAL
RESPONSE
The Assistant Regional Administrator stated:
Both the Senior Policy Advisor who has supervisory
responsibilities for the EEC and I, who have
responsibility for the EJC, agree with your conclusion
that grant monitoring should receive as high a priority
as awarding grant funds.
43
CHAPTERS
REGIONAL MANAGEMENT DID NOT ALLOCATE
ADEQUATE RESOURCES TO MONITORING
EE AND EJ GRANTS
-------
OIG RESPONSE
The Region stated that both the EEC and EJC received
Project Officer training in May of 1996 and understand their
responsibilities. The Region plans to add 30 hours/week of
administrative assistance to the EJC and an additional half-
time position to support the EEC. Additionally, most of the
FY' 95 PO responsibilities for the EJ grants have been
assigned to other appropriate Project Officers. This will be
done for FY1 96 grants as well. Grantees will also be trained
to assure that they understand their responsibilities as well.
We concur with the Region's action.
44
CHAPTERS
REGIONAL EE GRANT APPLICATION REVIEW
WAS INCONSISTENT WITH AGENCY WIDE POLICY
-------
APPENDIX A
SCHEDULE OF OUTSTANDING GRANTS AND BALANCES
GRANT NO.
A001 25395
D00145095
E00148795
F00147095
100109095
J 1001 94401
L001 60095
NE991 36201
NI001 79301
VCOO 173506
EQ99153101
X1 001 96701
A001 25595
CP001 84501
CP001 90001
D00145295
D00145695
EQ991 53201
EQ991 53401
EQ991 53501
EQ991 53601
FOO 147295
G001 48295
100199195
L001 60295
NE991 39301
PB991 54001
VC001 72905
X001 340010
X001 77801
STATE
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
DC
KY
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
BALANCE
AVAILABLE
$1,004,712.00
$250,204.00
$11,646.00
$216,152.00
$86,732.00
$1,515.00
$54,597.00
$1,718.00
$65,000.00
$50,382.00
$5,000.00
$23,631.00
$265,820.00
$50,000.00
$6,983.00
$73,907.00
$37,885.00
$8,000.00
$1,100.00
$1,000.00
$t:,500.00
$2,159.00
$3,110.00
$28,000.00
$2,432.00
$5,017.00
$9,200.00
$15,051.00
$8,333.00
$824.00
PROJECT/BUDGET
END DATE
30 September 1995
30 March 1995
30 September 1 995
30 September 1995
30 September 1995
30 September 1993
30 September 1995
31 December 1994
31 August 1994
30 September 1995
15 January 1995
31 March 1995
30 September 1995
30 September 1995
31 October 1994
30 September 1995
30 September 1995
1 June 1995
31 July 1995
31 July 1995
30 May 1995
30 September 1995
30 September 1995
30 September 1995
30 September 1995
30 June 1995
30 September 1995
30 September 1995
31 May 1995
30 September 1994
45
-------
APPENDIX A
CD001 76501
CD001 97801
D00145195
E001461950
GOO 148 195
100123095
1001449950
KOO 195401
L00160195
NE99147201
NW001 52801
V00173105
T001 998010
A001 25695
D001 45395
E001463950
F00147395
G00148395
J100195501
K1 001 62304
NE991 36701
NE991 38301
NE991493010
A001 25795
DOO 145495
EOO 140894
E001 47794
E001 47795
FOO 147495
G001 48494
G001 48495
100144095
1001697940
K001 96101
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
ME
MN
NH
NH
NH
NH
NH
NH
NH
NH
NH
LNH
Rl
Rl
Rl
Rl
Rl
Rl
Ri
Rl
Rl
Rl
Rl
$5,000.00
$68,252.00
$1,425.00
$11,714.00
$12,707.00
$240,806.00
$11,008.00
$1,489.00
$65,041.00
$1,794.00
$12,718.00
$10,585.00
$769.00
$34,276.00
$9,383.00
$15,405.00
$194,492.00
$16,102.00
$1,211.00
$2,687.00
$20.00
$176.00
$30.00
$77,132.00
$45,563.00
$3,788.00
$4,605.00
$6,716.00
$259,990.00
$6,000.00
$26,546.00
$76,401.00
$4,000.00
$734.00
30 September 1995
30 June 1995
30 September 1 995
30 September 1995
30 September 1995
30 September 1995
30 September 1995
31 January 1995
30 September 1995
30 May 1995
31 August 1995
30 June 1995
3 July 1995
30 September 1995
30 September 1995
30 September 1995
30 September 1995
30 September 1995
31 December 1993
30 June 1994
30 June 1995
31 December 1994
31 December 1994
30 September 1995
30 September 1995
30 September 1994
30 September 1994
30 September 1995
30 September 1995
30 September 1994
30 September 1995
30 September 1995
30 June 1995
31 December 1994
46
-------
APPENDIX A
LOO 160495
NE99137601
NE99137701
NE99147601
CL001 69001
D001 45595
EQ991 53801
EOO 140994
E00140995
E00148694
E00148695
F00147595
G001 48595
100150095
NP991 39801
TOTAL
Rl
Rl
R!
Rl
VT
VI
VT
VT
VT
VT
VT
VT
VT
VT
VT
$2,928.00
$126.00
$5,000.00
$1,000.00
$1,872.00
$33,570.00
$1,500.00
$4,404.00
$599.00
$17,637.00
$8,776.00
$5,796.00
$12,065.00
$22,317.00
$1.00
$3,637,766.00
30 September 1995
30 June 1994
30 June 1994
15 May 1995
31 March 1995
30 September 1995
1 September 1995
30 September 1994
30 September 1 995
30 September 1994
30 September 1995
30 September 1995
30 September 1995
30 September 1995
1 September 1995
47
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APPENDIX B
Page 1 of 7
REGIONAL COiMMENTS
U.S. ENVIRONMENTAL PROTECTION AGENCY
•REGION I
J.F.K. FEDERAL BUILDING, BOSTON, MA 02203-2211
MEMORANDUM
DATSt September 12, 1996
SDBJ: Draft Audit Report of Region I's Overview of Small Grantees
(ProgramRepcr- No. E1FMF6-01-0020)
FROM:
sista
nal Administrator
TO: Paul D. McKechnie, Divisional Inspector General
Eastern Audit Division
I a si writing i
Region I's Ova
I ragard the f
a matter of sa
action, as wel
ir.er.crandum cu~
.with your reca
in which we do
the basis of -
Chapter 2
r. response to the draft audit report entitled,
rview of Small Grantees, dated August 1, 1996.
inclines ar.d conclusions of the draft audit as
riousness, and one requiring immediate remedial
1 as long tarm refora. The balance of this
lines the actions taken or underway to comply
siendations. It also discusses the instances
not agree with the premises that appear to be
ha audit recomjnendat\ons.
We agree with vhe recommendations outlined in this chapter and
the Executive Summary Regarding the Environmental Justice Small
Grants (EJSG) and in some cases have already engaged in their
implementation:
A - Need to Proactively Monitor Environmental Justice Small
Grants
(1) Share the EJ project officer responsibilities - The Project
Officer responsibilities for the FY'95 EJ grants are being shared
by the four U'ZI City coordinators and other trained P.O.s with
compatible inrarests. Once awarded, the FY'96 EJSG and EJP2
Project Officer responsibilities will be similarly shared.
(2) PO responsibilities need to be included in EJC's PD - The
EJC's position description was rewritten to include Project
Officer responsibilities.
(3), (4) Grantsa project management responsibilities - Grantees'
grant management responsibilities will be covered in a series of
three (3) mandatory meetings, the first of which is scheduled to
take place in October, 1996. Topics to be covered include book-
keeping issues such as grantees' scope of work being consistent
with allocated budget and amending work-plans to reflect changes
in the scope of work, budget, organizational structure and/or
staffing.
48
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APPENDIX B
Page 2 of 7
-2-
(5) Agreed.
(6} Promote successful EJ Projects - One of the biggest benefits of the
Environmental Justice Small Grants (HJSG) program is shcw-casir.g the success
stories of our grant recipients. It is a benefit not only to the recipients
but to EPA-New England as well, for a lot of the programmatic issues
associated with environmental justice resulted from the great things that
are currently happening in communities that received EJSG funding.
For instance, the Urban Environmental Initiative (USD program in the
region resulted from the success story of one of our recipients. We feel
that EPA-N*ew England has been engaged in showcasing EJ success stories
starting with our very first grant cycle in FY'94.
B - Selection Procedures
(1) Streamline the application process - In an effort to continually improve
the EJSG program, it is customary for HQ to seek feedback from the regions
or. ways to make the application process more user-friendly. During the
FY'97 cycle, the recommendations made in your IG Report will be taken into
consideration and HQ will work with all the regions in this regard.
Additionally, some rsgior.s are already engaged in conducting chair own
grant.-wricing workshops. KQ is viewing this effort as a regional initiative
being fueled with regional resources. However, they will act as a clearing
house to facilitate the flow of information among the regions. We will
monitor the success of this effort to see if it is one we couic adopt in
this region.
(2) We agree.
(3) We agree. It will be part of our mandatory'training and
monitoring.
(4)'Verify non-profit status o£ grantees - This current FY'96 funding cycle,
and for future funding cycles, non-profit status of applicants are being
verified with their submittal of a.^eopy of the letter from the IRS providing
information such as the Employer Identification Number (EIN) as well as tax
status.
(5). We agree. It will be included in our mandatory training fcr grantees
and our own monitoring program.
%
Policy Disagreements
(I) Refer to Executive Summary Heading "Region I needs to review the
direction of the SJSG Program." Page {iii)
A. "Need to actively Monitor EJSG Program."
49
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APPENDIX B
Page 3 of7
1. Grantee Performance '
(a) "Grantees were not following their work plans." Page 9 of the
Report compared four {4} Grantees' planned activities with their actual
activities.
Response: Two of the FY'94 grantees referenced in A(I) above
{Committee for Boston Public Housing and Roxbury Neighborhood Council) have
submitted their final reports which provided information contrary to the
findings in IG Report. Boch grantees have conducted activities that are
consistent with their proposed activities. A copy of the final report for
"Committee for Boston Public Housing" and other supporting documents, as
well as a copy of the final report for Rcxbury Neighborhood Council can be
furnished upon request.
2. Regional Performance
(b) "Final Reports were not used to identify successful/
unsuccessful projects."
Response: Typically, a successful project can only be
determined upon completion of the project. At the time of your review
(Oct'95-March'96) only three of the nine (9) FY'S4 Grant Recipients had
completed their projects and consequently submitted their final reports.
Wobanaki Inc, located in Swanton, VT submitted their final report March 11,
1996; Tellus Institute located in Boston, MA submitted their final report
September 14, 1995 and Dudley Street Neighborhood Initiative (DSNI) located
in Roxbury, MA submitted their final report October 31, 1994.
We did showcase cr,e of these three grantees. On April 21, 19S4, an
environmental tour was conducted of the DSNI neighborhood {the target
audience of the SJ project) . This tour/event provided the impetus for
future EPA partnering with DSNI. We have also sponsored another
environmental tour with an FY1 95:^grant recipient in October, 1995, We have
also used other vehicles such as the Environmental Justice Council meetings
to showcase other successful EJ projects and will continue to engage in
other activities to accomplish this task.
Refer to Executive Summary Heading "Region I needs to review direction of
EJSG Program." Page (iii) «
A. "Need to pro-actively monitor EJSG Program.*
1. Grantee Performance
(a) "Grantees were not following their work plans." Page 9 of the Report
compared four (4) Grantees' planned activities with their actual activities.
50
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APPENDIX B
Page 4 of 7
-4-
/»
Response: We agree with your recommendation that grantees seek EPA
concurrence OR work plan changes. We plan to emphasize at our training
meeting that list requirements be followed, however, in defense of past
practices. The goal of the EJSG program is to put the power back into the
hands of the community, which was actually the case with the grantees
referenced in the Report. One has to recognize that oftentimes what an
applicant has proposed in their application for funding is not always what a
community wants - and this is the lesson to be learned.
In these examples, grantees approached the target audience with one proposal
but the target audience had their own agenda and priorities. Take for
example, "Citizen's Agenda." In their proposal, this grantee planned to
publish a report listing the toxic waste sites in major urban areas in the
state and envisioned the participation of neighborhood groups in this
effort. However, the grantee did not receive their support. In grantee's
final report, they blamed their failure to gee community support (did not
speak tc 20-30 groups as planned)on the fact that grantee was unfamiliar to
the community and did not win community's trust. As a result, grantee made
presentations to only ten groups. Grantee developed city-by-city packets of
data tc inform local groups about the hazards that related to air quality,
vacant lots and auto shops in their neighborhoods.
In the case of "Eegsr Williams Zoo, the grantee's project was entitled
"Youth and the Environment" (YEP). Grantee's primary objectives were to (1)
"Provide interns [tssns] with a wide range of environmental experiences
through time spent with the zoo staff and through visits to other
institutions"; (2) "Support the interns in creating an interactive,
exciting education program on environmental health by collaborating with
Keep Providence Beautiful, a grassroots organization that deals with quality
of life issues in Providence, Rhode Island." The grantee, in keeping with
the spirit of this project, YEP, felt comfortable in empowering the youth to
tailor the project activities to fit their needs and expectations. Kence,
when the youth opted to make certain substitutions (refer to IG report on
Page 9}, Grantee accommodated teens feeling assured that the objectives
of the project were still being met.
Worthy of mention at this time is the fact that Roger Williams Zoo project
objectives as statad above, were not identified in the Report. In fact, the
objectives that were cited in IG Report and some of the conclusions derived
thereof were mischaracterized. For example, in grantee's proposal no
reference was made to clean up eighteen (18) parks as part of their project.
Grantee's proposal clearly states the following "inspire the children to
take ownership of the parks by organizing a trash clean-up in the park
following the [YE?] program". In other words, the clean-up of 18 parks was
not a deliverable of this project.
51
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APPENDIX B
Page 5 of7
-5-
Ir. sum, despite the fact'that the above two grantees failed to inform us in
a timely manner that certain changes were being made to the their work plan,
the accual deliverables of their project were still consistent with the
objectives of the EJSG program.
B. "Selection Procedures for EJSG needs to be Ra-Evaluated and
Strengthened."
"... One half of the 1994 EJ Small grants were awarded to non-profit
environmental -entities rather than the affected community-based/grassroots
agencies.•
Responset We feel that non-profit organizations can provide useful service
to the targeted communities that is consistent with the EJSG Program
protocol. However, we do support conununity-based/grassroot organizations in
taking the initiatives to address their own environmental justice issues and
'will continue to improve the SJSG solicitation process to achieve this end.
Chapter 4
We acrae in general wich the recommendations to correct deficienciencies in
the grants administration process that were raised in Chapter 4 of the
report.
During the time thae the draft report was being developed, and since
receiving a copy, we have concentrated on reducing the large number of
grants that needed to be closed out. We concur with your recommendation to
give priority to the immediate close-out of the grants listed in Appendix A.
As of August 18, 1996, we have deobligated funds for 35 of these grants. The
Grants Management Unit has been instructed by Project Officers not to
deobligate funds from 24 continuing grants on your list. Based on this
decision not to close out continuing grants, funds for 80% of the available
grants on your list have been deobligated.
We acree with your recommendation cc ensure that grants administration
specialists follow guidance for,.timely closeout of grants. The Grants
Management Office, in partnership with the Region I Finance Office, has
developed and is using a fast track procedure to streamline administrative
closeout for grar.cs of 5,000 or less. This process will make it easer for
the specialists to process small grant closeouts and at the same time give
them the needs resources to deal with the more complex larger grants.
t
In addition to these new procedures, Project Officer training was completed
in May 1996. This training included sections on closeout procedures. We
believe that this training will result in better grants that are more
conducive to timely closeout in the future.
52
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APPENDIX B
Page 6 of 7
-6-
Chapter S
3oth the Senior Policy Advisor who has supervisory responsibilities for the
ESC and I, who have responsibility for the EJC, agree with your conclusion
that grant monitoring should receive as high a priority as awarding grant
funds.
Both the EEC and EJC received Project Officer training in May, 1996, and
understand these monitoring responsibilities. They have been consulted
about the kind of supervision/assistance that they need and requested
additional clerical/administrative support. Thus, instead of assigning a
Supervisory Project Officer over the EJ and EE POs, we are adding 30
hours/week of administrative assistance to the EJC and additional half time
position to support the EEC.
When the EJC is on maternity leave beginning in December, another EPA
permanent employee will be detailed to assume the critical functions of the
position.
As discussed befcre, most of the FY'95 PO responsibilities for EJ grants
have been assigned to other appropriate Project Officers in the
organization. The same will be cone for the FY'96 grants thus reducing the
workload on the ZJC. The first training session required for the FY'96
grant recipients will be held in October, further insuring that the grantees
understand their responsibilities.
Chapter 6
We feel that the recommendations in Chapter 6 of this report are not
necessary, since "he Region's review process was consistent with Agency-wide
policy.
We use standard screening and evaluation forms created by the Environmental
Education Division at EPA Headquarters, which is taken strictly from the
solicitation notice published in the Federal Register each year. In
previous years, cur review process consisted of at least three reviews per
application {two internal EPA stajff reviews and one external environmental
educator review), all of which were combined by the Environmental Education
Coordinator (EEC) into a single, weighted score. Despite the use of
numerical ranking sheets, scores wera often inconsistent from one evaluator
to the next. For example, two evaluators may have ranked the project high
and one low. This created problems in determining which projects were most
outstanding.
In order to avoid such discrepancies, the Regional Administrator urged the
EEC to develop a more streamlined approach to reviewing the large numbers of
education grant applications. It was agreed that a few pairs of reviewers
(EPA employees with environmental
53
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APPENDIX B
Page 7 of7
-7-
aducation experience) would come to consensus on each application. This
provided for much more consistency among the review of all applications.
The use of external reviewers at this point in the process is precluded due
to Federal Advisory Committee Act requirements that prohibit non--federal
employees from making recommendations as to which grants to fund.
Therefore, external review was incorporated into the process afcer the
initial consensus-method review was conducted. The EEC found at least one
external environmental educator in each New England state to review project
descriptions, budgec information, and internal evaluation, sheets for each
pre-application that ranked above the median (which included about 2/3 or
all proposals). External evaluators' comments were generally consistent
with those of internal employees, and the EEC considered their comments in
her recommendations to the Regional Administrator for which grants to fund.
54
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APPENDIX C
REPORT DISTRIBUTION
Office of Inspector General
Inspector General (2441)
Assistant Inspector General for Audit (2421)
Deputy Assistant Inspector General for
Acquisition and Assistance Audits (2421)
Deputy Assistant Inspector General for
Internal and Performance Audits (2421)
Divisional Inspector Generals
Executive Assistant to the Inspector General (2441)
Regional Office
Regional Administrator
Senior Advisor for Management/Assistant
Regional Administrator
Senior Advisor for Policy
Director, Office of Ecosystems Protection
Director, Office of Administration and Resource Management
Audit Coordinator
EPA Headquarters Office
Comptroller (3301)
Agency Follow-up Official (3304)
Associate Administrator for Regional Operations
and State/Local Relations (1501)
Director, Grants Administration Division (3903F)
Director, Office of Environmental Justice (3103)
Office Of Congressional Liaison fl 302)
Office of Public Affairs (1701)
Headquarters Library (3304)
55
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