United States       Office of
         Environmental Protection    The Inspector
         Agency         General
         Inspector General
&EPA    6500 - Functions and
                 Activities of the
                 Office of the
                 Inspector General

                 1985 Edition

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CHECKLIST OF EPA TRANSMITTALS
functions and Activities of the Office of the Inspector General
When kept current, this checklist permits the user to see at a glance which transmittals have been filed.
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EPA Form 1315-4 (Rev. 7-73)
PREVIOUS EDITIONS ARE OBSOLETE.

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/R5

                               EPA MANUAL

                  .  FUNCTIONS AND ACTIVITIES OF THE
                      OFFICE OF INSPECTOR GENERAL
                          CONTENTS OF CHAPTERS

CHAPTER                                                            CHAPTER
TITLES                                                             NUMBERS

ESTABLISHMENT, AUTHORITY, AND ORGANIZATION	1
REPORTING TO THE ADMINISTRATOR AND CONGRESS	2
REPORTING VIOLATIONS AND OTHER PROHIBITED ACTIVITIES
  TO THE OFFICE OF INSPECTOR GENERAL	3
AUDIT ACTIVITIES	4
INVESTIGATIVE ACTIVITIES	5
MANAGEMENT AND TECHNICAL ASSESSMENT ACTIVITIES	....6

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FUNCTIONS AND ACTIVITIES OF THE                   •                         6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


         CHAPTER 1—ESTABLISHMENT, AUTHORITY, AND ORGANIZATION

                           Table of Contents
PARAGRAPH                                                          PARAGRAPH
TITLES    .                                                         NUMBERS

Origin and Establ ishment	1
Independent Status of Inspector General	2
St atu to ry Fun ct i on s	3
Specific Duties	4
Del egated Out i es	5
Other Requirements of the Act	6
Specific Authorities	7
Organization and Staff	8
Relationship to Agency Operations	9
External  Relationships	10

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 FUNCTIONS AND ACTIVITIES OF THE                                            6500
 OFFICE  OF INSPECTOR GENERAL                                                1/22/85


          CHAPTER  1—ESTABLISHMENT. AUTHORITY, AND ORGANIZATION


 1.  ORIGIN AND  ESTABLISHMENT.  The  Inspector General Act of 1978, P.L.
 No. 95-452,  as  amended, 5 U.S.C. app. (1982), which took effect on
 October  12,  1978,  provided for the  statutory establishment of Offices of
 Inspector General  in most departments and major agencies of the executive
 branch,  including  EPA.

    a.   The  Office of  Inspector General  (OIG) was established by the
 Administrator of the Environmental  Protection Agency on January 7, 1980.

    b.   The  primary purpose of the  Inspector General Act was to establish
 and consolidate audit  and investigative operations into an independent
 organization headed by an Inspector General (IG).

 2.  INDEPENDENT STATUS OF INSPECTOR GENERAL.  The independent status of the
 Inspector General  is provided for in the Inspector General Act and is
 further  clarified  in the Congressional committee reports and hearings in
 support  of the  act.

 The Inspector General  reports directly to the Administrator or the Deputy
 Administrator;  shall not report or  be subject to the supervision of any other
 official of  EPA; and is free from any undue influence or constraints in per-
 forming .his or  her functions.  The  independent status of the Inspector
 General  is described below.

    a.   The  Inspector General is appointed by the President without regard
 to political affiliation, is subject to confirmation by the Senate, and can
 only be  removed from office by the President.  The President, however, must
 communicate the reasons for any such removal to both Houses of Congress.

    b.   The  Inspector General cannot be prevented or prohibited from
 initiating, carrying out, or completing any audit or investigation; issuing
 any audit', investigation, or related report; or issuing any subpoena during
 an audit or investigation.

    c.   The  Inspector General is free to report matters to the Congress
 without  the imposition of any restrictions by Agency management which might
 influence or alter the subject matters being reported.

    d.   The  Inspector General may enter into any contracts for services and
may select,  appoint, and employ any required officers and employees within
 the resources available for such activities.
                                  1-1

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 FUNCTIONS AND ACTIVITIES OF  THE                                            65UO
 OFFICE OF INSPECTOR GENERAL                                                1/22/85


 3.   STATUTORY FUNCTIONS.  The  functions  of  the  OIG  are  provided  in  section 2
 of  the Inspector General Act:

     a.  Conduct  and supervise  audits  and investigations  relating to programs
 and operations of the Agency;

     b.  Provide  leadership and coordination  and  recommend policies  to promote
 economy,  efficiency,  and effectiveness and  to prevent and detect fraud and
 abuse in  Agency  programs and operations;  and

     c.  Keep  the Administrator of  EPA and the Congress  fully and currently
 informed  about problems  and  deficiencies related  to the  operation of EPA
 programs  and  the necessity for and the progress of  corrective action.

 4.   SPECIFIC  DUTIES.   The principal statutory duties and responsibilities of
 the OIG  are set  forth in section 4(a) of the Inspector General Act:

     a.  Conduct,  supervise,  and coordinate  audits and investigations and .-.
 provide  related  policy direction in these areas.

     b.  Review existing  and proposed  legislation  and regulations and make
 recommendations  to  the Congress in  the semiannual reports concerning their
 impact on  the economy and efficiency  of  program administration or the
 prevention and detection  of fraud  and program abuse.

     c. Recommend policies for and  conduct, supervise, or coordinate other
 activities of the Agency to promote economy and efficiency in program
 administration and  prevent and detect fraud and abuse.

     d.  Recommend policies for and  conduct, supervise, or coordinate
 relationships  between  the Agency and  governmental entities with respect to
 (1)  all matters  relating  to the promotion of economy and efficiency in
 program administration or the  prevention and detection of fraud and abuse;
or  (2) the identification and  prosecution of participants in such fraud and
 abuse.

     e.  Keep  the Administrator and the Congress fully and currently informed,
by means of reports and otherwise concerning fraud and other serious problems
and  deficiencies, recommend necessary action to correct  such problems and
deficiencies,   and report  on the progress in implementing corrective actions.

5.   DELEGATED  DUTIES.  In addition to the above statutory duties, the
Administrator  has delegated to the  Inspector General the authority to:

     a.  Implement and maintain protective security measures for the
Administrator  as required.
                                  1-2

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 FUNCTIONS AND ACTIVITIES OF  THE                                            6500
 OFFICE OF INSPECTOR GENERAL                                                1/22/85


     b.  Develop  and direct the Agency's  personnel  security program under the
 requirements of  Executive Order  10450,  "Security Requirements for Government
 Employment."

     c.  Carry out  the Agency's administrative enforcement of post employment
 restrictions of  the Ethics in Government Act of 1978, P.L. No. 95-521 as
 amended,  and 18  U.S.C. 207 (a),  (b),  (c) as implemented by 5 CFR Part 737.

 The  responsibilities noted above neither diminish  nor include program
 operating responsibilities of other Agency primary organization heads.
 Pursuant  to  section 9(a)(2)  of the  Inspector General Act, program operating
 responsibilities may not be  transferred  to the Inspector General.

 6.   OTHER REQUIREMENTS OF THE ACT.  In carrying out the statutory duties and
 responsibilities,  section 4  of the  Inspector General Act requires the
 Inspector General  to:

     a.  Comply with the governmental  audit standards published by the
 Comptroller  General  of the United States.

     b.  Establish  guidelines for determining when  it is appropriate to use
 non-Federal  auditors and  ensure that  any work performed by such auditors
 complies  with the  governmental audit  standards.

     c.  Give particular attention to  the activities of the Comptroller
 General with a view toward avoiding duplication and ensuring effective
 coordination  and cooperation;

     d.  Report expeditiously to the Attorney General whenever there are
 reasonable grounds  to  believe Federal  criminal  laws have been violated.

 7.   SPECIFIC  AUTHORITIES.  To carry out the statutory duties and
 responsibilities described in paragraph 1-4, section 6(a) of the Inspector
 General Act  authorizes  the Inspector  General to:

     a.  Have  access  to  all records, reports, audits, reviews, documents,
 papers, recommendations, or other material  available to the Agency.

     b.  Conduct  any  investigation and issue any reports which the Inspector
General deems necessary or desirable.

     c.  Request necessary information  or assistance from any Federal, State,
or local governmental  agency or unit.

    d.  Require,  by  subpoena, the production of all information, documents,
reports, answers, records, accounts, papers, and  other necessary data and
documentary evidence.   (However,  procedures other than subpoenas are to be
used to obtain documents and information from Federal  agencies.)


                                  1-3

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


    e.  Have direct and prompt access to the Administrator when  necessary
for any purpose pertaining to the performance of functions and respons-
ibilities under the Inspector General Act.

    f.  Select, appoint, and employ officers and employees necessary for
carrying out the OIG's functions and duties.

    g.  Obtain the services of experts and consultants.

    h.  Enter into contracts and other arrangements for  audits,  studies,
analyses, and other services with public agencies and private persons,
and make such payments as may be necessary to carry out  the Inspector
General Act.

8.  ORGANIZATION AND STAFF.  The functions and responsibilities  of the various
organizations which constitute the OIG are found in the  EPA Organizations  and
Functions Manual.  The OIG is headed by an Inspector General, who reports  to
the Administrator of EPA.  The Inspector General is assisted by  a Deputy
Inspector General, who acts as the Inspector General during the  absence or
temporary incapacity of the Inspector General when designated.

The OIG has a Headquarters office in Washington, D.C., and various field
offices.  There are three operational offices in Headquarters, each of which
is headed by an Assistant Inspector General  (AIG): the Office of Audit, the
Office of Investigations, and the Office of Management and Technical
Assessment.

The Office of Inspector General has six division offices: Internal Audits
(Headquarters), Eastern (New York), Mid-Atlantic (Washington, D.C., and
Philadelphia), Southern (Atlanta), Northern (Chicago), and Western (San
Francisco).  In each divisional office there is an audit staff and an
investigative staff headed respectively by Divisional Inspectors General
for Audit and Investigation.  Each Divisional Inspector  General  for Audit
(DIGA) reports to the Assistant Inspector General for Audit, while each
Divisional- Inspector General for Investigations (DIGI) reports to the
Assistant Inspector General for Investigations.  All OIG personnel located
in divisional offices are considered members of the EPA OIG Headquarters
staff.

9.  RELATIONSHIP TO AGENCY OPERATIONS.  The functions of the Office of
Inspector General do not replace established lines of operating authority and
responsibility, nor do they eliminate the need for functional supervision  and
line inspections necessary for operating units to discharge their assigned
responsibilities.  The relationships below are particularly worthy of mention.
                                  1-4

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE-OF INSPECTOR GENERAL                                                1/22/85


    a.  Audits and Investigations.  All areas of the Agency's operations and
programs, including operations of grantees, contractors, or subcontractors
participating or doing business with the Agency, are subject to review by the
OIG.  The proper fulfillment of this role entails the maintenance of continu-
ing relationships with all EPA organizations.  Such relationships may involve:

        (1)  Considering, planning, and conducting audits suggested
by EPA officials.

        (2)  Considering and conducting investigations from referrals,
including hotline complaints. .

        (3)  Obtaining the cooperation of EPA officials and employees
during audits and investigations.

        (4)  Briefing EPA officials on the results of audits and
investigations.

    b.  Audit Followup System.  The primary purpose of this system is to ensure
that audit findings and recommendations are effectively resolved.  The primary
responsibility for implementing the audit followup system is vested with EPA's
Assistant Administrator for Administration and Resources Management, the desig-
nated Agency followup official.  The audit followup system provides for an
Audits Resolution Board and Audit Review Group.  OIG officials serves as non-
voting members of these bodies and provide advice, technical assistance, and
various services to these and other EPA organizations to ensure effective
resolution of audit findings and recommendations.  [Also refer to EPA Manual
2750, "Management of EPA Audit Reports and Followup Action" (1984 edition).]

    c.  Personnel Security Program.  The OIG initiates and arranges for
investigations of employees assigned to sensitive positions.  The OIG evaluates
the results of these investigations to determine whether employees applicants
meet the requirements of Executive Order 10450, "Security Requirements for
Government Employment."

     d.  Proposed Legislation and Policy Issuance.  Section 4(a)(2) of the
Inspector General Act requires the OIG to review existing and proposed
legislation and regulations and submit recommendations to the Congress based
on these reviews.  To assist management in ensuring that legislation and
regulations contain necessary controls to promote economy, efficiency and
effectiveness and prevent and detect waste, fraud, and abuse in Agency pro-
grams and operations or other governmental operations, the OIG reviews draft
legislation, regulations, and policy issuances which (1) originate within
EPA, (2) have national  cross-agency concerns, or (3) originate in other
agencies and may involve or concern EPA.  This effort involves working with
originating offices to resolve OIG concerns.
                                  1-5

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 FUNCTIONS AND ACTIVITIES OF THE                                           6bOO
 OFFICE OF INSPECTOR GENERAL                                               1/22/85


     e.  The Office of General  Counsel.   By  a Memorandum of  Understanding,
 the Inspector General Division within  the Office of  General  Counsel
 provides legal  services to  the Office  of Inspector General  in  conjunction
 with audits,  investigations and GIG  operations.  These services  include
 interpreting  regulations and policies.

 10.  EXTERNAL RELATIONSHIPS.  Pursuant  to section 4(a)(4) of the Inspector
 General  Act,  the Inspector  General is  responsible for recommending policies
 for, conducting, supervising,  and  coordinating  relationships between the EPA
 and other Federal  agencies,  Congress,  State and local government agencies,
 and nongovernmental  agencies with  respect to (1) all"matters relating to the
 promotion of  economy and efficiency  in  the  administration of program and
 operations administered or  financed  by  the  Agency, or the prevention and
 detection of  fraud and  abuse in such programs and operations;  and (2) the
 identification  and prosecution  of  participants  in fraud or  abuse in EPA
 programs and  operations.  As appropriate, the OIG participates with other
 Federal  departments  and agencies on  various work-related committees, task
 forces,  and councils.   Major organizations  include the Department of Justice,
 the Office of Management and Budget, the President's Council on  Integrity
 and Efficiency,  the  General  Accounting  Office, and the Congress.  Some of
 the OIG's significant relationships  are described below.

     a.   Congress.   The  OIG  reports directly to Congress on  significant
 audit, investigative, and other related  matters as required by section 5
 of  the Inspector General  Act (see  chapter 2).

     b.   EPA Program  Participants.  Persons  and entities receiving financial
 or  other assistance  from  EPA are subject to OIG audit and investigative
 reviews,  when appropriate.

     c.   General  Accounting Office  (GAP).  Section 4(c) of the  Inspector
 General  Act requires the  Inspector General  to give particular  regard to the
 activities of the  Comptroller General of the United States to avoid dupli-
 cation and ensure  effective  coordination and cooperation.

     d.   Department of Justice.  Section  4(d) of the Inspector General Act
 requires  the  Inspector  General to report expeditiously to the Attorney
 General  whenever the  Inspector General   has  reasonable grounds to believe
 there has been a violation of Federal criminal  law.   In addition, the OIG
 provides  assistance to  United States Attorneys such as preparing or review-
 ing  financial  data and  material pertinent to grand jury presentations or
 court cases involving EPA programs.

    e.   Federal Bureau of Investigation.  By a Memorandum of Understanding,
the Federal Bureau of Investigation (FBI) provides investigative resources
to the OIG, such as forensic analysis of evidence,  and exchanges information
with the OIG in mutual  support of investigative matters.   (See chapter 5,
paragraph 4.)


                                  1-6

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 FUNCTIONS AND ACTIVITIES  OF  THE                                            6500
 OFFICE  OF INSPECTOR  GENERAL                                                1/22/85


     f.   Office of  Personnel  Management.  The OIG, which is responsible for
 the personnel  security  program in  EPA, arranges for investigations by the
 Office  of Personnel  Management (0PM)  and evaluates investigative data
 received from 0PM.   The Office of  Inspector General participates in 0PM
 sponsored training and  development programs.

     g.   President's  Council  on Integrity and Efficiency.  This Council was
 established  by Executive  Order 12301, dated March 26, 1981.  The general
 objectives of the  Council  are to coordinate and implement the Federal
 Government's  policies with respect to promoting integrity and efficiency in
 Federal  programs through  task forces  and committee projects that address
 governmentwide problems and  issues.

 The Council  is chaired  by  the Deputy  Director of OMB.  Membership includes
 the Inspectors General, the  Deputy Attorney General, the Executive Assistant
 Director of  Investigations of the FBI, the Director of the Office of Personnel
 Management, and other key  agency designees.

     h.   Department of the  Treasury.   The OIG is responsible for referring to
 the United States Secret  Service, Department of the Treasury, matters that
 involve  the alleged  forgery of United States checks or irregularities with
 regard to imprest funds.   (Concurrent referral  is also made to the Federal
 Bureau of Investigations.)   The OIG also uses the Treasury Department's
 Law Enforcement Training Center for both initial training of investigators
 and  white collar crime training for e^erienced investigators.

     i.   Office of Management- and Budget.  As an organizational arm of the
President, the Office of Management and Budget (OMB) has a significant role
 in  improving the management of the Federal  Government's operations.  The OIG
works closely  with OMB by  assisting in the implementation of special
Presidential/OMB initiatives dealing with the curtailment of fraud, waste,
and  mismanagement.

    j.  Merit  Systems Protection Board.  When applicable, the OIG may be
requested to investigate "whistleblower" reprisal  allegations which are
referred to the Administrator by the Special Counsel  of the Merit Systems
Protection Board.  The OIG is also responsible for referring alleged
violations of the Hatch Act and other prohibited personnel  practices to
the Merit Systems Protection Board.
                                  1-7

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85
      CHAPTER 2--REPORTING TO THE ADMINISTRATOR AND CONGRESS
                           Table of Contents
PARAGRAPH                                                          PARAGRAPH
TITLES                                                             NUMBERS

Purpose and Responsibility	1
Semi annual Reports	2
Immediate Reporting of Flagrant Problems and Abuses	3

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/72/85


        CHAPTER 2—REPORTING TO THE ADMINISTRATOR AND CONGRESS
 I.  PURPOSE AND RESPONSIBILITY.  One of the principal objectives of the
 Inspector General Act is to keep the head of the agency and the Congress
 fully and currently informed about problems and deficiencies relating to
 programs and operations and the necessity for and progress of corrective
 action.  To accomplish this objective, the act provides that the Inspector
 General report to the Administrator and the Congress significant and flagrant
 problems, abuses, or deficiencies in the Agency's programs and operations.
 The act requires that the Inspector General carry out this reporting semi-
 annual ly and as frequently as considered necessary.

 ?..  SEMIANNUAL REPORTS.  Section 5(a) of the Inspector General Act requires
 the Inspector General to prepare semiannual reports to the Administrator and
 the Congress which summarize the activities of the OIG during six-month
 periods ending March 31 and September 30 of each year.  Section 5(b) calls
 for the Inspector General to furnish the semiannual report to the
 Administrator not later than April 30 and October 31 of each year.  The
 Inspector General Act prohibits the Administrator from making changes in the
 reports.  Further, it requires the Administrator to transmit the semiannual
 reports to the appropriate committees or subcommittees of the Congress within
 30 days after their receipt.

    a..  Required Content.  According to the Act, each semiannual report must
 include, but does not have to be limited to:

        (1)  A description of significant problems, abuses, and deficiencies
 disclosed by audits and investigations during the reporting period.

        (2)  A description of the recommendations for corrective action with
 respect to the significant problems, abuses, or deficiencies mentioned above.

        (3)  An identification of each significant recommendation in previous
 semiannual reports on which corrective action has not been completed.

        (4)  A summary of matters referred to prosecutive authorities and the
 prosecutions and convictions which have resulted.

        (5)  A list of all audit reports completed by the OIG during the
 reporting period.

        (6)  A summary of instances reported to the head of the Agency under
 section 6(b)(2) of the Inspector General Act where information or assistance
was unreasonably refused or not provided to the OIG.

        (7)  A summary of reviews of existing and proposed legislation and
 regulations.
                                  2-1

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85
    b.  Report from the Administrator.  In transmitting the Inspector
General's semiannual report, section 5(b) authorizes the Administrator to
provide the Congress with a separate report containing any comments on the
semiannual report which he or she deems appropriate.  The Administrator is
prohibited from changing the semiannual report.

    c.  Availability of Reports.  Section 5(c) of the Inspector General Act
requires the Administrator to make copies of the Inspector General's semi-
annual report available to the public upon request and at a reasonable cost.

3.  IMMEDIATE REPORTING OF FLAGRANT PROBLEMS AND ABUSES.  Section 5(d) of
the Inspector General Act requires the Inspector General to report to the
Administrator whenever he or she becomes aware of particularly serious or
flagrant problems, abuses, or deficiencies in the Agency's programs and
operations.

The Administrator, in turn, is required by section 5(d) to transmit any
such report of the Inspector General to the appropriate committees and
subcommittees of Congress within seven calendar days, together with a
separate report containing any comments the Administrator deems appropriate.
                                  2-2

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/27/85


              CHAPTER 3—REPORTING VIOLATIONS AND OTHER
                    PROHIBITED ACTIVITIES TO THE  OTG

                           Table of Contents
PARAGRAPH                                                          PARAGRAPH
TITLES                                                             NUMBERS

Authority to Review or Investigate	1
Responsibilities of Agency Management and Employees	2
Cooperation During Audits and Investigations	3
Unreasonable Refusal or Nonprovision of
  Information or Assistance	4
Issuance of Subpoenas	5
Protection of Employee Complainants	6
Hotline Activities	7

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FUNCTIONS AND ACTIVITIES OF THE                                            65QQ
OFFICE OF INSPECTOR GENERAL                                                1/22/85


               CHAPTER 3—REPORTING VIOLATIONS AND OTHER
                    PROHIBITED ACTIVITIES TO THE 016
1.  AUTHORITY TO REVIEW OR INVESTIGATE.  As described in this paragraph,
certain laws provide the Inspector General with authority to review and
investigate various alleged violations and other prohibited activities
affecting the Agency, including complaints involving such activities.   How-
ever, while the Inspector General is authorized to review all complaints
involving the Agency, other processes exist in the Agency for receiving and
acting on certain complaints (see paragraph 7 of this chapter).

    a.  Inspector General Act.  Section 7(a) of the Inspector General  Act
provides for the Inspector General's receipt and investigation of complaints
or information from employees of the Agency concerning the possible existence
of activities constituting a violation of law, rules, or regulations;
mismanagement; gross waste of funds; abuse of authority; or a substantial and
specific danger to the public health and safety.

In addition to the specific authority of section 7(a) of the Inspector General
Act to receive and act on complaints or information from employees of  the
Agency, the OIG may receive and act on complaints and related information from
any other sources.  Such authority stems, in part, from sections 6(a)(l)  and
(?.) of the Inspector General Act, which address the Inspector General's access
to all material  available to the Agency and authority to conduct any investi-
gations which the Inspector General considers necessary.

    b.  Civil  Service Reform Act.  In accordance with section 202(a) of the
Civil Service Reform Act of 1978, 5 U.S.C. 1206, the OIG may be  requested by
the Administrator to investigate complaints, allegations, or information
concerning matters similar to those in paragraph 3-la, which are reported by
employees, former employees, or applicants for employment to the Office of
the Special Counsel, Merit Systems Protection Board, and referred by the
Special Counsel  to the Administrator.  (Such complaints, allegations,  or
information will be processed, investigated, and reported by the OIG in
accordance with the rules and regulations of the Office of the Special
Counsel contained in 5 CFR parts 1250-1261.)

    c.  Ethics in Government Act Regulations.  The implementing  regulations
for titles II  and IV of the Ethics in Government Act of 1978 (5  CFR part 738)
provide for the "designated agency ethics official" (i.e., Deputy General
Counsel) to ensure that appropriate matters are referred to the  OIG [5 CFR
738.203 (b)(12)].  Thus, the OIG may investigate actual or potential
violations of  the Agency ethics standards.
                                  3-1

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 FUNCTIONS  AND  ACTIVITIES  OF  THE                                            6500
 OFFICE  OF  INSPECTOR  GENERAL                                                1/22/85


     d.   Standards of Conduct Regulations.  The Agency's standards-of-conduct
 regulations  (40  CFR  part  3)  provide that employees should furnish, the
 appropriate  Deputy Ethics Official, the Designated Agency Ethics Official or
 the  Inspector  General with information concerning violations of the standards
 of conduct.  The OIG may  investigate violations of the Agency's standards of
 conduct  based  on information of such alleged violations.

 2.   RESPONSIBILITIES OF AGENCY MANAGEMENT AND EMPLOYEES.  The Office of
 Inspector  General can fulfill its responsibilities only with the cooperation,
 full  disclosure, and reporting of information concerning instances of fraud,
 waste, or  mismanagement.  All officials and employees of the Agency are
 responsible  for  complying with laws and regulations and for maintaining high
 standards  of conduct in the  administration of programs and operations of the
 Agency.  Each  employee is responsible for promptly reporting indications of
 wrongdoing or  irregularity to the Office of Inspector General and for
 cooperating  and  providing assistance during any audit or investigation.

     a.   Heads  of Primary Organizations.  Assistant Administrators and other
 heads of organizations who report to the Administrator are responsible for
 ensuring that  (1) any instances of, and information on, any known or
 suspected  violations of law, rules, or regulations, or mismanagement, gross
 waste of funds,  abuse of authority are promptly reported to the OIG;
 (2)  appropriate  instructions are issued to employees to facilitate the
 reporting  of the matters described above; (3) employees are periodically
 counseled  on the need to report such matters promptly; and (4) appropriate
 corrective actions are taken on such reported violations by the appropriate
 supervisor when  work by the OIG to review the situation is not necessary.

     b.  Employees.   All employees of the Agency, within the limits of their
 authority  and  duties, are responsible for (1) fostering the enforcement of
 laws, executive  orders, regulations, and other applicable directives;
 (2) maintaining  high  standards of ethical conduct; and (3) promoting
 efficiency and effectiveness in the administration of the Agency's programs
 and  activities.

 These responsibilities require that all employees promptly report instances
of and information on any known or suspected violation of law, rules, or
 regulations; mismanagement;  gross waste of funds; abuse of authority; or
 substantial  and  specific danger to the public health and safety.  Employees
 should report  such instances to their supervisors, or if necessary directly
to the Office of Inspector General (see paragraph 6 of this chapter).

As stated  in section 7c of the Inspector General Act, action shall not be
taken or threatened  against any employee as a reprisal for making complaints
or disclosing  information to the OIG unless the complaint was made or the
 information disclosed with the knowledge that it was false or with willful
disregard  for  its truth or falsity.
                                  3-2

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 FUNCTIONS AND ACTIVITIES OF THE                                           6500
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 3.  COOPERATION DURING AUDITS AND INVESTIGATIONS.   The  OIG  can  accomplish the
 objectives of the Inspector General  Act  only  with  the cooperation of all EPA
 employees.  The IG Act authorizes the Inspector  General  to  have access to all
 records,  reports, audits,  reviews,  documents,  papers, recommendations, or
 other material  available to the Agency.   To this end, it is necessary that EPA
 manager's  and supervisors ensure that all  EPA  employees  cooperate with the OIG
 during audits and investigations.  Employees  should be  instructed to:

     a.  Disclose and provide information  pertaining to  the matters under
 review.

     b. Make available applicable files,  records,  reports, agreements,
 contracts, correspondence,  or other  required  information.

     c. Advise  OIG of matters which  they  believe warrant review during the
 audit or  investigation.

 Section 701  of  the Civil  Service Reform Act of 1978, 5  U.S.C. 7114, provides
 the  employee union an opportunity to  be  represented at  any examination of an
 employee  in  the union's  bargaining unit  by a  representative of  the Agency in
 the  connection  with an investigation.  The Office of Inspector  General is
 independent  and is not a  representative of the Agency.   Therefore, an employee
 interviewed  by  a member of  Office of Inspector General  does not  have the right
 to have a  union representative present

 4.   UNREASONABLE REFUSAL OR NONPROVISION  OF INFORMATION  OR ASSISTANCE.
 Section 6(b)(2) of the Inspector General  Act provides that whenever informa-
 tion  or assistance requested  is,  in  the judgment of the  Inspector General,
 unreasonably refused  or not provided, the Inspector General is  to report the
 circumstances to the  Administrator without delay.

 Section 5(a)(5) of the Inspector General  Act requires the Inspector General
 to include in the  semiannual  report  to Congress  a summary of each report made
 to the Administrator  in connection with section  6(b)(2)  of the  act.

 The  Inspector General  will  consider  a request for information or assistance
 as unreasonably refused or  not  provided when both of the following condition
 conditions are  present:  (1)  the OIG's audit, survey, evaluation, or inves-
 tigation cannot be satisfactorily completed unless  the  request  is fulfilled;
 and  (2) the  official  refusing  to  honor the request  can  reasonably and legally
 fulfill it.

 5.   ISSUANCE OF SUBPOENAS.   Section  6(a)(4) of the  Inspector General Act
 authorizes the  Inspector General  to  require by subpoena  the production of all
 information, documents, reports,  answers, records,  accounts, papers, and other
 data  and documentary  evidence  necessary in the performance of the functions
 assigned by  the  Inspector General Act.  The subpoena, is  enforceable by order
of any appropriate United States  District Court.   However, procedures other
than  subpoenas  are to  be used  by the  Inspector General  to obtain documents
and information  from other  Federal agencies.

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FUNCTIONS AND ACTIVITIES OF THE                                            6600    (
OFFICE OF INSPECTOR GENERAL                                                1/22/85


If information cannot be obtained voluntarily,  a  subpoena  may  be  issued  to
prime contractors, grantees, subcontractors,  and  subgrantees.   These  may
include State, local, and Indian tribal  governments.

6.  PROTECTION OF EMPLOYEE COMPLAINANTS.

    a.  In accordance with Section 7b of the  Inspector General  Act, the
identify of an employee, other than a supervisor  or manager acting  in his or
her official  capacity, who comes forth with a complaint or information by
contacting the OIG shall be kept confidential.   Exceptions can be made to
this general  rule where (1) the employee consents to  the release  of his  or
her name, or (2) the Inspector General personally determines such disclosure
is unavoidable during the course of the investigation.  The provisions of
confidentiality under Section 7b is limited to  EPA employees who  directly
contact the OIG.  Confidentiality will not be provided pursuant to  Section
7b to an employee who provides information to another employee who  in turn
passes information to the OIG.  The employee  who  passes the information  to
the OIG will  receive confidentiality unless the employee is a supervisor or
manager acting in his or her official capacity.  The provision of confiden-
tiality under Section 7b does not extend to an  employee who is contacted by
OIG staff unless that employee during the course of an interview  or other
communication in connection with an audit or  investigation, makes a new
complaint or provides new information to the  OIG which has not been  solicited
by OIG staff.  Similar requirements for protecting the identities of  sources
of information are found in the Civil Service Reform Act of 1978, the Privacy
Act of 1974,  and the Freedom of Information Act.

    b.  Section 7(c) of the Inspector General Act provides that employees
are prohibited from threatening, taking, recommending, or approving  any
personnel action as reprisal against other employee(s) for making disclosures
to the OIG.  However, employees who make complaints or disclosures  known to
them to be false or with willful disregard for the truth or falsify  are not
so protected.

Employee's who wrongfully take reprisal actions against complainants  or
employees who report a complaint or disclose  information known to such
employees to be false or who do so in willful disregard for its truth or
falsity, may be subject to punitive action in accordance with appendix C of
the EPA Manual of Conduct and Discipline.

7.  HOTLINE ACTIVITIES.  A telephone hotline, maintained in the OIG,  is
available to all EPA employees and the public for reporting Agency  activities
involving fraud, waste, or mismanagement.  The use of the hotline for
reporting complaints should not be looked upon as a requirement;  rather, the
hotline is an alternative to reporting matters directly to one's supervisor
or in person or writing to the OIG (see paragraph 8, chapter 6).
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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


    a.  Operation of the Hotline.  The hotline number is (202) 382-4977.
Field staff can call the hotline number through the Federal  Telecommunications
System by dialing 8-382-4977.  The toll-free number is (800) 424-4000.   Hotline
calls are answered by OIG personnel between 8 a.m. and 4:30  p.m.  (Washington,
D.C.  time), Monday through Friday.  A telephone answering machine records  all
calls received after working hours or on nonworkdays.

    b.  Processing of Hotline Calls.  After initial receipt  and preliminary
screening, the complaint or allegation is referred to the appropriate office
within OIG or EPA for appropriate action.

Complaints or allegations dealing with possible criminal matters  or complaints
or allegations involving serious noncompliance with applicable EPA regulations,
policies, or requirements are generally referred to the Assistant IG for
Investigation or the Assistant IG for Audit.  Other less serious  complaints or
matters requiring technical review may be referred to the appropriate EPA
program office.

A complaint or allegation may be administratively closed if  it is
nonsubstantive or lacks sufficient information to enable appropriate
followup.

    c.  Reporting on Results and Final Disposition.  The program  office
responsible for taking action on the hotline complaint or allegation is
required to inform the Office of Inspector General of the results by
transmitting a copy of the final report or a memorandum summarizing the
action taken.

    d.  OIG Liaison with Other Hotlines.  The General Accounting  Office (GAO)
and Office of Management and Budget (OMB) have established hotline numbers
which are available to the public, as well as Government employees, for
reporting fraud, waste, and related irregularities.  In addition, other
agencies have established hotlines similar to EPA's.  Complaints  received
through these hotlines which relate to EPA programs are referred  to the OIG.
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 FUNCTIONS AND ACTIVITIES OF  THE                                            6500
 OFFICE OF INSPECTOR GENERAL                                               .1/22/85


                       CHAPTER  4—AUDIT ACTIVITIES

                           Table of  Contents
 PARAGRAPH                                                          PARAGRAPH
 TITLES                                                             NUMBERS

 Audit Objectives	1
 Types of Audits	2
 Compliance with Comptroller General's Standards	3 .
 Scope and Frequency	4 ..
 Annual  Audit Plan	5
 Audit Planning Policy and Criteria	6
 Request fo r Audi t	7
 Advance Notification of Audits	8
 Entrance Conference	9
 Exit Conference	10
 Audit Scope	11
 Distribution of Audit Reports Within
  the Agency	12
 Distribution of Audit Reports Outside
  the Agency	13
 Requests by the Public for Audit Reports	.14
 Audit Reports Which May Contain Confidential
  Information or Affect Criminal or Civil
  Prosecution or Litigation	.15
 Inquiries Concerning Audit Work Which Is
  Planned or in Progress	16
 Retention and Disposition of Audit Reports	....17
 Audit Guides	18
 Action  on Audit Reports	19
 Audit Followup System	20
 OMB Circular A-50	21
 Audits  by Independent Public Accountants
  and State and Local Auditors	22
 Attachment P,  OMB Circular A-102	23
 Objectives of Reporting	24
 Focus of Reporting	25
 Supporting Evidence	26
 Contents of Audit Reports	27
 Nature of Audit Findings and Recommendations	28
Questioned and Set-Aside Costs	29
 Sustained Costs and Cash Recoveries/Savings	30

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


                       CHAPTER 4—AUDIT ACTIVITIES


1.  AUDIT OBJECTIVES.  The primary purpose of the OIG's audit program is to
identify, evaluate, and report on the Agency's activities and programs so that
any needed corrective action can be taken and future problems can be prevented.

The principal focus of the audit program is the controls which management has
established or should establish to ensure that operations are carried out in
the most effective manner.

An objective of the OIG's audit program is to make appropriate recommenda-
tions for achieving greater economy, improving efficiency, and obtaining
optimum results in the Agency's operations.  Since the DIG is independent of
EPA program management, it is not empowered to direct changes in the Agency's
policies, procedures, and operations.  This power and authority are vested
with EPA's Administrator, Deputy Administrator, Assistant Administrators,
Associate Administrators, General Counsel, Regional  Administrators and
office directors.  The OIG, however, is responsible for determining that
audit report findings and recommendations are acted upon.  This includes
reviewing the adequacy of the action taken by the Agency to correct reported
problems and deficiencies.  In addition, as appropriate, the OIG will report
unresolved audit findings and recommendations to the Administrator and the
Congress (see chapter 2).

The OIG conducts expanded-scope audits as defined by the Comptroller
General.  Such audits are made up of three elements or types of reviews:

    a.  Financial and Compliance Reviews.  These reviews determine whether
books and records are complete and accurate and whether laws or regulations
have been followed.

    b.  Economy and Efficiency Reviews.  These reviews determine whether
resources (funds, property, and personnel) are adequately controlled and
used in an effective, efficient, and economical manner.

    c.  Program Results Reviews.  These reviews determine whether the desired
results or benefits established by the Congress are being achieved.

OIG audits may include any or all of the three elements depending upon the
planned objectives.

2.  TYPES OF AUDITS.  The audit workload is generally divided into two
main categories, internal and external audits.
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 FUNCTIONS  AND  ACTIVITIES  OF  THE                                            6500
 OFFICE  OF  INSPECTOR  GENERAL                                                1/22/85


     a.   Internal  Audits.   Internal audits  (also known as program audits,
 performance  audits,  or management  reviews) are made of selected EPA
 administrative and program operations to evaluate the effectiveness, economy,
 and  efficiency of those operations.  Audits are directed toward determining
 whether management controls, practices, and procedures at the levels reviewed
 are  adequate and  effective.

 Internal audits are  also  made of selected  EPA programs and activities to evalu-
 ate  their  effectiveness and  to determine whether the anticipated objectives are
 being achieved.

     b.   External  Audits.  External audits  are independent reviews of the
 records and  performance of organizations or entities (program participants)
 receiving  financial  assistance or  benefits from the Agency, such as grant
 recipients,  contractors,  and subcontractors.  The OIG performs external audits
 or arranges  for their performance  by Independent Public Accountants or State or
 Federal  audit  agencies.

 External audits are  also  arranged  by program participants and performed by
 auditors who are  responsible to the participants for conducting audits in
 conformance  with  Attachment P to OMB Circular A-102, "Uniform Administrative
 Requirements for  Grants-in-Aid to  State and Local Governments."  (See paragrapn
 4-23.)

 External audits are  a means of ascertaining the degree of compliance with
 statutes,  regulations, and terms and conditions of the agreements under which
 the  Federal  funds are made available.  Determinations are also made regarding
 the  appropriateness  of the disposition of  funds granted or administered.

 3.   COMPLIANCE UITH  COMPTROLLER GENERAL'S  STANDARDS.  Section 4(b)(l) of the
 Inspector  General  Act requires the Inspector General to comply with the
 standards  established by  the Comptroller General of the United States for
 audits  of  Federal  establishments, organizations, programs, activities, and
 functions.   In addition,  section4(b)(3) of the act requires the Inspector
 General  to take appropriate steps  to ensure that any work performed by non-
 Federal  auditors  complies with the Comptroller General's standards.

 The  Comptroller General's audit standards cover all major aspects of Federal
 audits,  such as the  qualifications and independence of auditors, the scope
 and  conduct of audits, and the reporting of audit results.  The standards
 incorporate  by reference  the standards prescribed by the American Institute
of Certified Public  Accountants and also apply to aduits of a broader scope.

The OIG conducts quality  control  checks at all supervisory levels to ensure
the OIG's and non-Federal  auditors' work complies with the Comptroller
General's audit standards.
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 FUNCTIONS AND ACTIVITIES OF  THE                                            6bOO
 OFFICE  OF INSPECTOR  GENERAL                                                1/22/85


 4.   SCOPE AND FREQUENCY.  All offices  and organizational units of the Agency
 and  all  programs  and operations  are  subject to audit at any time.  Determi-
 nation  of the priority,  nature,  scope, and frequency of audit is the
 responsibility of the Inspector  General.  OMB Circular A-73, "Audit of Federal
 Operations and Programs,"  requires each agency to (1) establish procedures for
 periodic  review of its  individual programs and operations to determine the
 coverage,  frequency,  and priority of audits required; and (2) prepare an audit
 plan  at  least annually,  based on certain criteria prescribed in the circular.
 (See  paragraph 4-5.)

 5.   ANNUAL AUDIT  PLAN.   The  annual audit plan, prepared, by the OIG's Office of
 Audit and  approved by the  Inspector General, represents the OIG's formal plan
 for managing  its  audit  resources and workload during the fiscal year.  The plan
 is based on information  and  suggestions obtained from all  levels of the OIG and
 Agency management  and recognizes the concerns of the Congress, the Office of
 Management and Budget, other Federal agencies, and the general public.  The
 plan  is flexible  and  can be  revised when changes in audit priorities are
 warranted.  The annual audit plan is updated quarterly.

 The annual  audit  plan is distributed to assistant administrators, regional
 administrators, and other EPA officials.  On a request basis, the plan is also
 available  to  other officials who have a need for it.  Copies of the plan are
 also furnished to GAO and OMB.

 6.  AUDIT  PLANNING POLICY AND CRITERIA.  The OIG's policy is to emphasize the
 audit of  (1)  EPA offices which expend significant resources; (2) EPA programs,
 functions, or  activities according to the prescribed priority factors listed
 below; and  (3) external operations where known or potential  problem areas can
 most adversely affect EPA's  accomplishment .of its mission.  In addition to
 specifying the minimum contents of Federal  agency audit plans, OMB Circular
 A-73 prescribes nine  criteria by which priorities should be assigned to
 potential  audit subjects.  OIG's policy regarding priority assignment
 recognizes the OMB criteria  and includes two other factors:   the Inspector
 General  Act's  mandate to prevent and detect fraud and program abuse, and the
 special  concerns of the President and the Administrator of EPA.

 The criteria for planning audits are:

    a.  Susceptibility to fraud, embezzlement,  program manipulation, or other
kinds of irregularities;

    b.  Mandatory requirements of legislation  or other Congressional or GAO
recommendations;

    c.  Emphasis by the President and the Administrator;
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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                l/22/«5


    d.  Management needs as developed in consultation with Assistant
Administrators, Associate Administrators, Regional  Administrators,  General
Counsel, and office directors;

    e.  Newness, changed conditions, or sensitivity of the oryanization,
program, activity, or function;

    f.  Dollar magnitude, duration, or resources involved;

    g.  Prior audit experience, including the adequacy of the financial
management systems and controls;

    h.  Extent of Federal participation in terms of either resources or
regulatory authority;

    i.  Availability of audit resources;

    j.  Timeliness, reliability, and coverage under OMB Circular A-102,
Attachment P, of audit reports by others (e.g., State and non-Federal
auditors); and

    k.  Results of other reviews, such as inspections, project monitoring
reports, and program evaluations.

7.  REQUEST FOR AUDIT.  Although the OIG's Office of Audit will contact regional
and assistant administrators before developing the annual audit plan to obtain
suggestions for planning audits, EPA Headquarters and field officials may
request audit services whenever the need arises.

Requests by Headquarters officials for internal audits of specific operations
should be directed to the Assistant Inspector General for Audit.  Requests for
external audits of grants and contracts should be addressed to the appropriate
Divisional Inspectors General.

Agency officials, however, may direct to the personal attention of the Inspector
General any matter that warrants audit attention because the matter is extremely
sensitive, requires urgent attention, or involves nationwide problems.

8.  ADVANCE NOTIFICATION OF AUDITS.  Generally, the OIG will give advance
notification of audits to appropriate organizational officials.  However, audits
may sometimes be made without prior notification when time or other conditions
make such notification impractical.
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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


9.  ENTRANCE CONFERENCE.  The-entrance conference is a meeting held at the start
of an audit involving a member or members of the audit team and the official(s)
responsible for the organization or operation to be audited.  At this conference,
the lead auditor explains the purpose, scope, and objectives of the audit, as
well as the authority for conducting the audit.  Other areas covered include  the
timetable for completing the audit, access to required records and information,
space accommodations, and introduction of audit team members.  Cooperation with
the audit team and identification of potential  areas warranting audit review
will be sought at this time.

10.  EXIT CONFERENCE.  The exit conference is the official  meeting to close out
the audit.It involves members of the audit team and persons responsible for
administering the audited entity.  Also, in the case of external audits, the
exit conference may include Agency program representatives who have responsi-
bility over the external entity.  The exit conference involves a discussion of
the findings, conclusions, and recommendations of the audit (which are usually
made known to the auditee prior to the exit conference).  It also includes the
corrective actions proposed or taken by the auditee, points of disagreement,
and the auditee's reasons for disagreeing.

11.  AUDIT SCOPE.  The Agency activity or function audited is usually identified
in the title of each audit report.  The scope stated in the report will  show  the
functions of the audit entity reviewed and appraised.  However, in keeping with
normal audit procedures, only a test of records and transactions in a particular
function.will be examined.  Therefore, audit conclusions expressed are based  on
the sample examined unless the sampling plan used provides a basis for project-
ing the results of the audit to the total group of records and transactions
from which the sample was selected.

12.  DISTRIBUTION OF AUDIT REPORTS WITHIN THE AGENCY.  The Office of Inspector
General will transmit audit reports to Agency officials in accordance with
agreed-upon distribution schedules.  The report will be addressed and submitted
to the Agency officials (action officials) who have the responsibility for
taking action on the reported matters.  Copies of the reports will be furnished
to other officials having an interest in the matters covered in the report.
The action official(s) or the Assistant Inspector General  for Audit may furnish
copies of the audit reports to other Agency officials who  need the reports in
the course of their work.

    a.  Draft Audit Report.  Draft audit reports should not be released outside
of the Agency other than to the auditee.  EPA personnel receiving reports for
review and consideration shall exercise due caution to avoid improper dis-
closure inside or outside EPA of information in the audit  reports.  Requests
for draft audit reports should be made to the Inspector General.
                                      4-5

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 FUNCTIONS AND ACTIVITIES  OF  THE                                            6bOO
 OFFICE OF INSPECTOR  GENERAL                                                1/22/85


     b.  Final  Audit  Reports.   Copies of  issued audit  reports are provided only
 to  action addressees and  others  by  previous agreement.  The action official
 should make all,  or  relevant  (and non-confidential) portions of the information
 contained in the  final  report  available  to the auditee.   It is the responsi-
 bility of those regular recipients  to  advise the Assistant Inspector General
 for Audit or applicable Divisional  Inspector General  for  Audit of any chanyes
 in  the agreed-upon distribution  of  the final audit  reports.

 13.  DISTRIBUTION OF AUDIT REPORTS  OUTSIDE THE AGENCY.  The Agency's policy is
 one of full  and responsible  disclosure of its identifiable records and informa-
 tion consistent with the  public  interest concerning national security, personal
 privacy,  and business confidentiality, as recognized  by the Freedom of
 Information  Act,  5 U.S.C. 552.   A requested record  shall  not be withheld from
 copying or inspection unless  it  comes within one of the nine exemptions in 5
 U.S.C. 552.

 14.   REQUESTS  BY  THE PUBLIC  FOR  AUDIT REPORTS.  Audit reports shall be released
 by  the Office  of  Inspector General  to the public upon request after the auditee
 has received the  issued audit  report.  Requests for audit reports should be
 directed  to  the Freedom of Information Officer (A-101), Environmental  Protection
 Agency, Washington,  D.C.  20460,  who will refer them to the Office of Inspector
 General.

 Audit  reports  and related audit  information may be  requested by members of the
 public, State  and local governments, other Federal  agencies, members of Congress
 or  their  staffs,  Congressional committees or subcommittees, and other bodies of
 Congress  including the  General Accounting Office.   Requests for records which
 are  submitted  by  either House of Congress or by a Congressional  committee or
 subcommittee are not  subject to  the Freedom of Information Act.   All other
 requests  for information will generally be treated  as requests under the Freedom
 of  Information  Act.

 15.  AUDIT REPORTS WHICH MAY CONTAIN CONFIDENTIAL INFORMATION OR AFFECT CRIMINAL
 OR  CIVIL PROSECUTION  OR LITIGATION.Portions of an audit report which constitute
 confidential business information or findings indicating  a possible need for
 criminal or  civil action or information which may affect  litigation will not be
 releasable under the  Freedom of  Information Act.  In the  latter case,  the OIG
 will delete  those portions of the report the disclosure of which might create
 obstacles to a  successful  criminal or civil  prosecution by jeopardizing a fair
 trial or alerting certain parties to cover up their unlawful  acts.

 16.  INQUIRIES CONCERNING AUDIT UORK UHICH IS PLANNED OR IN PROGRESS.  Inquiries
 concerning audit work which is planned or in progress shall be referred to the
 Assistant Inspector General  for Audit or to the appropriate Divisional Inspector
 General for  Audit.  The Divisional  Inspectors General  for Audit  are authorized
to respond to such inquiries, but will  generally limit their responses to an
 appropriate  statement regarding the status of the audit (i.e., audit is planned,
audit is in progress, or report will be issued in due course).


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 FUNCTIONS AND ACTIVITIES OF  THE                                            6500
 OFFICE OF INSPECTOR GENERAL                                                 1/32/85


 17.   RETENTION AND DISPOSITION OF  AUDIT  REPORTS.   Disposition of  Inspector
 General  audit reports  distributed  within  the  Agency  is the  responsibility of
 the  receiving office.   The reports should not  be  returned to the  Office of
 Inspector General  but  should be  disposed  of under  the authorized  disposition
 schedules of the receiving office.   In determining the retention  period, the
 offices  should consider that the Office of Inspector General maintains or
 has  access to the  record copy of such reports.

 18.   AUDIT GUIDES.   The OIG's audit  work  is performed by following audit
 guides which spell  out  the objectives, scope,  and procedures to be followed
 in conducting audits.   Audit guides  for external audits are used  repeatedly
 and  are  only updated as required.   Each  internal audit is usually unique and
 requires  the development of  an original audit  guide.  The OIG also develops
 the  audit guides used  by non-Federal auditors  in conducting audits of
 certain  Agency program  grantees.

 19.   ACTION  ON AUDIT REPORTS.  EPA action officials are required  to take
 responsive and timely action  on  all  audit findings and recommendations for
 which  they have appropriate  responsibility pursuant to OMB Circular A-50,
 "Audit Followup and  Resolution," and section 305 of the Supplemental
 Appropriations and  Rescission Act, 1980,  P.L.  No. 96-304, 94 Stat. 857, 928.
 Such officials are  further responsible for taking the necessary action to
 correct  the  reported adverse  conditions and to ensure that the reported
 adverse  conditions  do not  recur.

 20.  AUDIT FOLLOUUP  SYSTEM.   The audit tracking and control system tracks the
 status of  open  audit reports.- The responsibility for resolving open audit
 reports  is vested with  EPA's  Assistant Administrator for Administration and
 Resources  Management.   Assistant Administrators, General  Counsel, Regional
 Administrators  or individuals designated  by them are the Agency's Action
 Officials  under the  Agency's  audit followup system.  Action Officials are
 responsible  for ensuring that timely adequate  responses and determinations
 are transmitted  on findings  and  recommendations contained in audit reports,
 and that both monetary  and non-monetary actions are implemented.  The audit
 followup system  is fully described in EPA Manual 2750, "Management of EPA
Audit Reports  and Followup Actions"  (1984 edition).  The audit followup
 system is designed to:

    a.   Identify promptly  for top EPA management any major problems
disclosed by audits;

    b.  Ensure  that  the  implementation of audit recommendations is
initiated.in a timely fashion; and

    c.  Ensure appropriate followup on the implementation of audit
recommendations.
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FUNCTIONS AND ACTIVITIES OF THE                                            6bOO
OFFICE OF INSPECTOR GENERAL                                                1/22/85


21.  OMB CIRCULAR A-50.  OMB Circular A-50,  "Audit  of  Federal  Operations  and
Programs," prescribes policies to  be followed  by  agencies  in  the  resolution
of audit findings.  The circular provides  that:

    a.  Each agency must establish policies  for  prompt and proper resolution
of audit recommendations.

    b.  Agency followup systems must provide for  a  complete record of actions
taken on audit findings and associated disallowed,  suspended, or  questioned
costs.  In establishing such systems, each agency is required to:

        (1)  Designate officials responsible for  audit followup.

        (2)  Maintain accurate records of  all  audit reports or significant
findings until final resolution.  Records  are  to  be maintained to ensure
appropriate accounting and collection controls over amounts determined due
the Government.  This latter responsibility  has  been assigned to  the
Assistant Administrator for Administration and Resources Management.

        (3)  Make written determinations promptly on all audit findings and
initiate action to ensure that these determinations are carried out.  Such
determinations are to be made within six months  after issuance of the
report.  Final resolution is to proceed as rapidly  as possible.

        (4)  Ensure that resolution actions  are  consistent with laws and
regulations, including written justification and  legal basis for  decisions
not to seek recovery of amounts due as a result  of  audit reports.

        (5) Provide semiannual reports to  the Agency head on the  status of
all audit reports over six months old, the number of reports or findings
resolved during the period, collections or offsets  made, and demands for
payment made.  This responsibility has been  assigned to the Assistant
Administrator for Administration and Resources Management.

        (6)  Evaluate whether the audit followup  system is adequate and
results in timely and proper resolution of audit  findings and recommendations.
Evaluations are to be made periodically.

    c.  When audit recommendations requiring corrective action involve more
than one program, agency, or level of Government, the agency making the audit
must coordinate its corrective action with the other affected organizations.
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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


22.  AUDITS BY INDEPENDENT PUBLIC ACCOUNTANTS AND STATE AND LOCAL

    a.  Non-Federal Audits Extend OIG Resources.  The Inspector General  Act
requires the OIG to establish guidelines for determining when it is
appropriate to use non-Federal auditors.  These auditors must follow
federally prescribed guidelines.

Non-Federal  audits are used as an extension of the OIG resources and usually
are performed by State or local government auditors or by Independent Public
Accountants (IPAs).

The OIG contracts with non-Federal auditors to perform external audits of EPA
grantees and contractors.  The OIG is responsible for arranging and conducting
audits upon notification of project completion.  The audit work of non-Federal
auditors is monitored by the OIG for quality and completeness.

    b.  Qualifications of Independent Public Accountants.  To perform audit
services for EPA, an IPA must be a Certified Public Accountant (or a public
accountant licensed or registered on or before December 31, 1970, by a
regulatory authority of a State or other political subdivision of the United
States).

    c.  Monitoring of non-Federal Audits by the OIG.  Non-Federal audit work
and reports involving EPA program participants are subject to review by the
OIG.  The Inspector General Act requires the Inspector General to take
appropriate steps to ensure that any work performed by non-Federal auditors
complies with the standards established by the Comptroller General of the
United States for audits of Federal establishments, organizations, programs,
activities,  and functions.  If the OIG's review of Independent Public
Accountant audit work indicates deficiencies and actions to correct such
deficiencies are not taken by the IPA, administrative sanctions may be
necessary in conjunction with the cognizant contracting offices.  Sanctions
include reporting an IPA to the appropriate State regulatory authority or
the American Institute of Certified Public Accountants or initiating possible
debarment or suspension from participation in EPA programs.

The OIG also has responsibilities with respect to non-Federal auditors in
connection with OIG's role as designated cognizant audit agency under
Attachment P, OMB Circular A-102.  Cognizant agency responsibilities are
fully described in paragraph 4-23.

    d.  Resolution of Non-Federal Audit Findings.  Upon accepting each non-
Federal audit report, the OIG will transmit the report to the EPA action
official.  The transmittal memorandum will identify those audit findings
which are to be controlled and resolved pursuant to the EPA audit followup
system.  (See EPA Manual 2750, "Management of Audit Reports and Followup
Actions," and paragraph 4-20 of this chapter.)
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 FUNCTIONS AND ACTIVITIES  OF  THE                                            65UO
 OFFICE OF INSPECTOR GENERAL                                                l/?2/85


 23.   ATTACHMENT P,  OMB  CIRCULAR  A-102.   Attachment P to OMB Circular A-102,
 "Uniform Administrative Requirements  for Grants-in-Aid to State and Local
 Governments," establishes audit  requirements  for  State, local, and Indian
 tribal  governments  that receive  Federal  assistance.  The circular provides for
 independent  audits  of financial  operations, including compliance with certain
 provisions of Federal law and  regulations.  These requirements were established
 to ensure that audits are made on  an  organizationwide basis rather than on a
 grant-by-grant basis.

 Under  Attachment P,  the audit  entity  could be an  agency or department of a
 State  or local  government; it  need not be the entire unit of government.  The
 circular requires State,  local,  and Indian tribal governments to arrange for
 independent  audits  at least  every two years and to prescribe the scope of
 audits,  provided that they comply with the requirements of Attachment P.

 The  provisions of Attachment P do not limit the authority of EPA or any other
 agency  to  make audits of  recipient organizations.  However, if independent
 audits  arranged for  by  program recipients meet prescribed requirements,
 Federal  agencies shall  rely on them,  and  any additional audit work is to build
 upon the work  already done.

     a.   Audit  Standards and Guidelines.  Attachment P requires that audits
 be made  in accordance with the Comptroller General's Standards for Audit of
 Governmental  Organizations, Programs, Activities, and Functions ("Yellow
 Book"  1981);  the Comptroller General's Guidelines for Financial and
 Compliance Audits of Federally Assisted Programs  ("Red Book" 1980);  any
 compliance supplements  approved  by OMB;  and generally accepted auditing
 standards  established by  the American Institute of Certified Public
 Accountants.

    b.   Scope of  Audits and Related Testing of Charges.  According to
 Attachment P,  audits must, at  a  minimum, include an examination of the systems
 of internal control, systems established to ensure compliance with laws and
 regulations affecting the  expenditure of Federal funds, financial  transactions
 and accounts,  and financial statements and reports of recipient organizations.
 Attachment P  requires these examinations to be based on a testing of a
 representative  number of  charges to Federal  awards.  The examinations are to
 determine whether:

         (1) There is effective control over and proper accounting for
 revenues, expenditures,  assets,  and liabilities.

         (2) The  financial   statements are presented fairly in accordance
with  generally  accepted acccounting principles.

         (3) The Federal  financial reports contain accurate and reliable
financial data  and are presented in accordance with the terms of
applicable agreements and  Attachment H to OMB Circular A-102.


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 FUNCTIONS AND ACTIVITIES  OF  THE                                            6500
 OFFICE OF INSPECTOR  GENERAL                                                1/22/85


         (4)  Federal  funds  are  expended  in accordance with the terms of
 applicable agreements  and  those  provisions of Federal law or regulations
 that  could have  a  material effect on  the financial statements or on the
 awards tested.

    c.  Period of  Audits.  Attachment P provides that audits should be made
 annually, but not  less frequently than  every two years.  Audits are to cover
 the period since the previous  audit.

    d.  Detection  of Irregularities.  Attachment P requires auditors to notify
 the cognizant agency and  recipient management officials above the level of
 involvement  whenever they  become aware  of irregularities in the recipient
 organization.  Irregularities  include such matters as conflicts of interest,
 falsification of records or  reports, and misappropriation of funds or other
 assets.

    e.   Contents of  Audit  Reports.  Attachment P requires the following
 to be  included in  audit reports.

         (1)  Financial  statements, including footnotes, of the recipient
 organization.

         (2)  Comments on the  recipient's financial statements, including,
 but not  limited  to,  a  statement that the audit was performed in accordance
 with applicable  audit  standards (paragraph 4-3) and an expression of an
 opinion  as to the  fairness of the financial  statements.

         (3)  Comments on the  recipient's noncompliance with the systems
 of internal  control  and the  terms of agreements and those provisions of
 Federal  law  or regulations that could have a material effect on the
 financial  statements and reports.  The  report is also required to
 include  an expression of positive assurance concerning compliance with
 requirements  for tested items and negative assurance for untested items.

         (4)  Comments on the  accuracy and completeness of financial reports
 and claims for advances or reimbursement to  Federal agencies.

         (5)  Comments on corrective action taken or planned by the recipient.

    f.   Retention  and Availability of Audit  Workpapers and Reports.
Attachment P  requires that the audit workpapers and reports be retained for a
minimum of three years  from the date of the  audit report unless the  auditor
is notified  in writing  by the cognizant agency of the need to extend the
 retention period.  The  audit  workpapers are  to be made available upon request
to the cognizant agency or its designees and the General Accounting  Office or
its designees.
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FUNCTIONS AND ACTIVITIES OF THE                                            6600
OFFICE Of INSPECTOR GENERAL                                                1/29./85
    g.  Cognizant Agency Responsibilities.  Attachment P assigns audit
responsibility for major recipient organizations to Federal  agencies known
as cognizant agencies for State departments and agencies that are major
recipients of Federal aid.  Similar lists are being developed for local and
Indian tribal governments.  Each cognizant agency is required to:

        (1) Obtain or make quality assessment reviews of the work of
non-Federal audit organizations and provide the results to other
interested audit agencies. (If a non-Federal audit organization is
responsible for audits of recipients that have different cognizant
audit agencies, a single quality assessment review will be arranged.)

        (2) Assure that all  audit reports of recipients that affect
Federally assisted programs  are received, reviewed, and distributed to
appropriate Federal audit officials.  These officials will be responsible
for distributing audit reports to their program officials.

        (3) Notify Federal awarding agencies and the recipient
organizations if the auditors do not take action to correct significant
inadequacies disclosed in a  review of an audit.  Major inadequacies or
repetitive substandard performance of independent auditors shall be
referred to appropriate professional bodies.

        (4) Ensure that satisfactory audit coverage is provided in a
timely manner and in accordance with the provisions of Attachment P.

        (5) Provide technical advice and act as a liaison 'between Federal
agencies, independent auditors, and recipient organizations.

        (6) Maintain a followup system on audit findings and investigative
matters to ensure that audit findings are resolved.

        (7) Inform other affected audit agencies of irregularities
uncovered.  The audit agencies, in turn, shall inform all appropriate
officials in their agencies.  State or local government law enforcement
and prosecuting authorities  shall also be informed of irregularities
within their jurisdiction.

    h.  Recipient Responsibilities.  Attachment P provides that recipients are
to require subrecipients that are State, local, or Indian tribal governments
to adopt the requirements in Attachment P.  The recipient is required to ensure
that subrecipient audit reports are received as required and shall submit the
reports to the cognizant agency.  The cognizant agency will be responsible for
such reports.
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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


?4.  OBJECTIVES OF REPORTING.  -The Inspector General  Act requires that the
Inspector General provide a means for keeping the Administrator and the
Congress fully and currently informed about problems  and deficiencies relating
to the administration of EPA programs and operations  and the necessity for and
progress of corrective action.

It is primarily through written audit reports that the OIG communicates its
observations, findings, conclusions, and recommendations relative to problems
and deficiencies in program administration.  The OIG  strives to produce clear,
fair, and accurate audit reports which place primary  emphasis on matters
needing attention.  It is the objective of the OIG to present matters in an
objective, unbiased, and convincing manner to prompt  management to take
corrective action where needed.

25.  FOCUS OF REPORTING.  The OIG reports significant matters to EPA manage-
ment in its audit reports.  Although "significant" as applied to audit
reporting is a relative term, the following examples  typify matters that the
OIG may address in its internal and external audit reports.

    a.  A substantial  loss to the Federal Government  has occurred or may occur.

    b.  A serious violation of a law or regulation has occurred.

    c.  An unreasonable or impractical policy or practice is seriously
undermining the success of a program or activity.

    d.  Substantial duplication of effort by employees or between
organizational units is adversely affecting overall efficiency.

    e.  Substantial procurement of unneeded or excess quantities of property,
materials, or supplies is taking place.

    f.  Program objectives are not being accomplished.

26.  SUPPORTING EVIDENCE.  All factual data, findings, conclusions, and
recommendations in OIG audit reports are supported by objective evidence to
sufficiently demonstrate or provide the basis for any matter reported and to
ensure its correctness and reasonableness.  Except as necessary to make a
convincing presentation, detailed supporting data are not normally included
in OIG audit reports.   Such data, however, are maintained on file by the OIG
as part of the audit workpapers and are used to provide support for the
matters reported.
                                  4-13

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 FUNCTIONS AND ACTIVITIES OF  THE                                            65UO
 OFFICE OF INSPECTOR GENERAL                                                1/22/85


 27.   CONTENTS OF  AUDIT REPORTS.

     a.  Basic Contents.   Information  that  is common to both  internal and
 external  audit reports includes:

         (1)  Introductory material, consisting of a brief outline of the
 purpose,  objectives,  scope,  and period covered by the audit;

         (2)  A summary of the significant results of the audit;

         (3)  Background material designed to give the reader  an understanding
 of the nature and  size of the  area audited and any special problems or
 circumstances which have a bearing on the  audit results; and

         (4)  Findings  and recommendations of the audit, consisting of a
 written explanation of problems, weaknesses, deficiencies, and other adverse
 conditions;  their  causes and effects; and  the corrective actions that are
 necessary.

     b.  Financial  Statements and Opinions.  Each audit report which contains
 financial  statements  will express the auditor's opinion on whether the
 information  contained  in  the statements is presented fairly.  If the auditor
 cannot express  an  opinion, the reasons therefore will be stated in the audit
 report.   The audit  report will also contain appropriate explanatory informa-
 tion  about the  contents  of the financial statements as may be necessary for
 full  and  informative  disclosure about the  financial operations of the
 organization,  program, function, or activity audited.  Violations of legal
 or other  regulatory requirements, including instances of noncompliance,
 will  be explained  in  the  audit report.

    c.  Opinions on Internal Controls.  External  audit reports covering
 grantees  in  which  EPA  has a  continuing interest,  as well as  internal audit
 reports covering EPA fiscal   activities, will  express an opinion regarding
 the adequacy of selected elements of the system of internal control.

    d.  Unresolved  Prior Audit Findings.  Some audit reports will  list prior
 audit findings that have not been resolved.  When appropriate, such prior
 audit findings will be updated and presented as findings of the current
 audit, along with  applicable recommendations.

    e.  Views and Comments on Audit Reports.   As  prescribed in EPA Manual
 2750, the views and comments of responsible auditee officials on the findings,
 conclusions, and recommendations of the audit will  be considered and
 appropriately expressed in the final  audit report.

    f.  General Comments.  When necessary,  the audit report will  include
 informative general comments which do not involve audit findings (e.g.,
potential  budget overruns, financial  trends).  Such comments will  normally
cover matters which are necessary to  place the report in a proper perspective.


                                  4-14

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 FUNCTIONS AND ACTIVITIES OF THE                                            6500
 OFFICE OF INSPECTOR GENERAL                                                1/22/85


 28.  NATURE OF AUDIT FINDINGS AND RECOMMENDATIONS.

     a.  Audit Findings.  Errors, weaknesses,  deficiencies,  problems, and
 the need for improvements are reported by the OIG  in  the  form of  audit
 findings.  Audit findings include:

         (1) Statement of condition  (what  is);

         (2) Criteria (what should be);

         (3) Effect (results of difference between what  is and what
             should be);  and

         (4) Cause (why it happened).

     b.   Audit Recommendations.   The OIG will  include  recommendations in its
 audit  reports whenever the audit indicates that actions are needed to bring
 about  improvements or to correct deficiencies.  Recommendations will still
 be made  even  though the necessary actions have been promised or initiated.
 Audit  recommendations are made  directly to the official who has authority to
 the take  recommended action.   Recommendations calling for major policy or
 regulatory  changes will  be made to the appropriate Assistant Administrator
 or the General  Counsel.

 29.  QUESTIONED  AND SET  ASIDE COSTS.   Findings in audit reports may involve
 ineligible  or questionable costs.Such costs will be identified  in the
 caption of  the findings  as  either questioned or set-aside costs.

     a.  Questioned Costs.   Claimed or proposed costs that the auditor has
 concluded should  not  be  reimbursed by the Government or incurred  as part of
 project-eligible  costs  because  they are not allowable under the provisions of
 applicable  laws,  regulations, policies, cost principles, or terms of the
 grant or contract.

     b. Set-Aside  Costs.   A proposed or claimed amount which the auditor has
 not  questioned but  which  the auditor cannot accept without additional
 information or evaluations  and  approvals  by responsible Agency program
 officials.

 30.  SUSTAINED COSTS  AND  CASH RECOVERIES/SAVINGS.   Set-aside or questioned
 costs which EPA management  agrees are ineligible or unallowable and is
 committed to  recover or offset  against future payments are considered
 "sustained."

    a.  Costs to  be Recovered.   The Agency is committed to recover the
 sustained amount  through  billing  and collecting from the grantee or contractor
or through offsets  against payments under existing and future grants or
contracts.


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FUNCTIONS AND ACTIVITIES OF THE                                            6bOO
OFFICE OF INSPECTOR GENERAL                                                1/22/85
    b.  Cost Efficiencies.   Cost efficiencies represent  estimated  amounts
which will  be avoided as a  result of management's commitment  to  implement
auditors'  recommendations.   They include:

        0   Deobligations and/or reprogramming of funds as  a result
           of OIG reviews of Ayency programs;

        0   Costs proposed in contract or grant agreements  which  will
           not be incurred  as a result of  management's concurrence with
           pre-award recommendations; and

        0   Estimated costs  associated with the Agency's, contractor,
           or grantee operations paid for  with Federal funds  which will
           not be incurred  as a result of  management's commitment  to
           take or require  recommended improvements.
                                  4-16

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FUNCTIONS AND ACTIVITIES OF THE                                            6bOO
OFFICE OF INSPECTOR GENERAL                                                1/22/85
                  CHAPTER 5—INVESTIGATIVE ACTIVITIES
                           Table of Contents
PARAGRAPH                                                          PARAGRAPH
TITLES                                                             NUMBERS

Organizational Role	1
Major Categories of Investigations	2
Liaison With the Department of Justice	3
Liaison With the Federal Bureau of Investigation
  and Use of FBI Information	4
Referrals to the Office of Inspector General  by
  Headquarters Personnel	,...5
Referrals to the Office of Inspector General  by
  Field Personnel	6
Ref err a 1 s o f B r i be ry	7
Investigation Without Referrals or Requests	8
Processing of Complaints Against Employees	9
Distribution of Investigative Reports	10
Restriction on Distribution and Use of
  Investigative Reports	11
Action on Investigative Reports	12

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


                  CHAPTER 5—INVESTIGATIVE ACTIVITIES


1.  ORGANIZATIONAL ROLE.  The investigative efforts of the OIG are directed
toward promoting the integrity of Agency programs and personnel.   The  Office
of Investigations is responsible for detecting and investigating  indications
or allegations of irregularities, or violations of Agency regulations  or
Federal criminal statutes.

2.  MAJOR CATEGORIES OF INVESTIGATIONS.

     a.  Criminal Matters.  Generally,  the OIG investigates all  criminal
matters involving waste, fraud, and abuse by EPA employees, contractors or
grantees.  Pursuant to the Inspector General Act and a memorandum of under-
standing, the OIG refers all  matters relating to bribery or attempted
bribery, significant allegations of fraud which culpably involve  an EPA
employee and organized crime  to the Federal Bureau of Investigation.
Pursuant to a separate memorandum of understanding, the OIG refers all
violations of EPA's environmental statutes to the EPA Office of Enforcement
and Compliance Monitoring which investigates such matters.

    b.  Violations of the Standards of  Conduct.  The OIG generally
investigates allegations against employees for unethical or other conduct
prejudicial to the Government (40 CFR Part 3).

3.  LIAISON WITH THE DEPARTMENT OF JUSTICE.  Section (4)(d) of the Inspector
General Act and 28 U.S.C. 535(b) require the Inspector General to report
expeditiously to the Attorney General whenever the Inspector General has
reasonable grounds to believe there has been a violation of Federal criminal
law.

4.  LIAISON WITH THE FEDERAL  BUREAU OF  INVESTIGATION AND USE OF FBI
INFORMATION.  By memorandum of understanding, the FBI provides investigative
resources to the OIG, such as forensic  analysis of physical evidence,  and
exchanges information with the OIG in mutual support of investigative  matters.

Reports and other communications received from the FBI, or the contents of
these documents, may be disseminated only to persons who need the information
in their official capacity.  Advance permission must be obtained  from  the
Assistant Inspector General for Investigation before an FBI report or  other
document is copied, reproduced, paraphrased, quoted, or extracted from.   No
FBI document may be used as a part of,  exhibit to, or reference in any report,
file, or other record which may have a  distribution broader than  that  outlined
in this paragraph.  FBI documents shall not be made available to  the
individuals investigated or their representatives.
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 FUNCTIONS AND ACTIVITIES  OF  THE                                            6500
 OFFICE OF INSPECTOR GENERAL                                                 1/22/85


 5.   REFERRALS TO OFFICE OF  INSPECTOR  GENERAL BY HEADQUARTERS PERSONNEL.

     a.  Referral  to Immediate  Supervisor.  All Headquarters staff should
 report promptly to  their  supervisor  (or other supervisory official within the
 chain  of command up to the appropriate Assistant Administrator) all informa-
 tion or allegations indicating a  possible  irregularity or violation of law or
 regulation.   Subordinate  officials shall in no case delay or withhold
 transmittal  of such information.  Promptly upon receipt of such information,
 Assistant Administrators, division directors, and office supervisors shall
 transmit it  along with any documents  or evidence directly to the Assistant
 Inspector General for Investigations.

    b.   Referral  to Office of  Investigations.

         (1)  Promptly upon receipt of  such  information, the Assistant
 Administrators  or General Counsel shall transmit the referral  directly to the
 Assistant  Inspector General  for Investigations.

         (2)  Employees at  Headquarters may  report matters they believe should
 be  investigated  directly  to  the Office of  Inspector General if they believe
 such a  matter  should not  be  reported  to their supervisor or through the chain
 of  command to  the appropriate Assistant Administrator or General Counsel.

         (3)  Employees seeking confidentiality should report matters they
 believe should  be investigated directly to the Office of Inspector General,
 as  reporting through the  chain of command precludes an employee's opportunity
 for confidentiality,  (see chapter 3, paragraph 26).

 6.  REFERRALS  TO OFFICE OF INSPECTOR  GENERAL BY FIELD PERSONNEL.  All  field
 staff should report promptly to the appropriate Regional Administrator,
 division director, or office supervisor all information or allegations
 indicating a possible irregularity or violation of law or regulation.
 Subordinate officials shall   in no case delay or withhold transmittal  of such
 information.  Promptly upon  receipt of such information, Regional  Admini-
 strators, division directors and office supervisors shall  transmit it  along
 with any documents or evidence directly to the Divisional  Inspector General
 for Investigations serving their region.

 Field employees are free to  report to the Headquarters Office  of Investigations
or the  appropriate Divisional Inspector General  for Investigations any matter
they believe should be investigated.   This shall  be done if the employees
 believe they should not report the matter directly to their superiors  or if
they wish confidentiality  as provided for in  the Inspector General  Act.
                                   5-2

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 FUNCTIONS AND ACTIVITIES OF THE                                           6500
 OFFICE OF INSPECTOR GENERAL                                               1/22/85


 7.  REFERRALS OF BRIBERY.  All  Assistant  Administrators and Regional
 Administrators will  report to  the OIG  directly  and  promptly by telephone any
 allegations relating to  bribery or attempted  bribery of an Agency employee
 or the solicitation and/or acceptance  of  a  bribe  by an Agency employee.

 8.  INVESTIGATION WITHOUT REFERRALS OR REQUESTS.   In carrying out the Inspector
 General's responsibilities for  detecting  and  investigating irregularities and
 abuses and for providing a positive mechanism to  help maintain the integrity of
 Agency activities,  the Assistant and Divisional Inspectors General for
 Investigations are  authorized to initiate investiyations of cases falling with-
 in their  areas of assigned responsibility without  receipt of referrals from
 other  sources or authorities.   The Assistant  or Divisional Inspectors General
 for Investigations  generally shall  advise the appropriate Assistant
 Administrator or other official  of a pending  investigation unless such notice
 would  interfere with that investigation.

 9.  PROCESSING OF COMPLAINTS AGAINST EMPLOYEES.   One of the Agency's most
 important assets is  its  personnel.Accordingly,  complaints against members
 of the staff  must be processed  promptly.  Protection must be provided against
 employee  violations  of EPA standards of conduct,  regulations, or Federal
 criminal  statutes and, at the same  time,  against  unfounded accusations.
 While  wrongdoing should  be uncovered and  corrective action taken with respect
 to the employee who  has  been found  deficient  in the discharge of his or her
 public trust,  the maligned employee  should  be exonerated.  Consequently, to
 help ensure the integrity of EPA operations and confidence of citizens in the
 government, any allegations of  violations by  Agency officials, employees, and
 temporary employees  of the EPA  standards of conduct (40 CFR Part 3) or of the
 provisions of  Federal criminal  statutes will  be reported promptly to the OIG.
 Allegations of  standard of conduct  violations which are civil  rights issues
 will be referred  to  the  Office of  Cvil  Rights.

    a.  Referrals of Complaints  of Discrimination in Agency Employment.
 Al1egations of  discrimination in  EPA employment involving race, age, religion,
 color,  sex, national origin or physical or mental  handicaps are investigated
 by  the  EPA Office of Civil  Rights.

    b.  Complaints Involving Other Federal Agencies.  Complaints against
employees of the  Agency which fall within the cognizance of other Federal
 agencies  will be  referred  directly and expeditiously to the appropriate
agencies  by the Office of  Investigations.

    c.  Inquiry by the Office of  Investigations.  Complaints against employees
of the Agency not referred to other cognizant agencies will  be scheduled for
timely investigation by the Office of  Investigations.   Complaints over which
the Federal Bureau of Investigation has declined to exercise jurisdiction will
also be investigated by the Office of  Investigations.
                                  5-3

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FUNCTIONS AND ACTIVITIES OF THE                                            6bOO
OFFICE OF INSPECTOR GENERAL                                               V22/85
10.  DISTRIBUTION OF INVESTIGATIVE REPORTS.   Distribution  of reports  of
investigation is governed by the contents.   Reports of investigation  are
distributed by the Assistant Inspector General  for Investigations to  the action
officials.  All  requests for investigative  information except from Congress or
other Federal agencies will generally be treated as requests under the Freedom
of Information Act and may only be released  with concurrence of the Assistant
Inspector General for Investigations.

11. RESTRICTION ON DISTRIBUTION AND USE OF  INVESTIGATIVE REPORTS.

    a.  Marking of Investigative Reports.  Investigative reports issued  by the
OIG and all correspondence relating to these reports, except responses to
requests for reports under the Freedom of Information Act, will be marked "FOR
OFFICIAL USE ONLY."

    b.  Review of Investigative Reports.  Within the Agency, investigative
reports may be reviewed only by persons who  need the information in their
official capacity.  Officials receiving reports for review and consideration
shall exercise every precaution to avoid embarrassment to  the subject or any
person who furnished information in connection  with an investigation.

    c.  Distribution to the General Accounting  Office.  The GAO, upon request,
will  be furnished copies of investigative reports under the following
conditions:

        (1)  That release of the report is  not  prohibited  by law or other
special circumstances.

        (2)  That the copies of investigative reports will not be
transmitted to the GAO until Agency officials have had a reasonable
opportunity to receive and examine the reports.

        (3)  That no further release of the reports will be made by GAO
without prior clearance by the Inspector General.

    d.  Distribution to Law Enforcement Agencies Outside EPA.  Investigative
reports or information contained in the reports will be made available to
other Federal offices of investigation and  local law enforcement agencies
with the concurrence of the Assistant Inspector General for Investigations
and in conformity with procedures of the Privacy Act, where applicable.

    e.  Safeguarding and Disposition of Investigative Reports.  While Agency
officials have investigative reports in their possession,  they will be
responsible for ensuring that the  reports and their contents are adequately
safeguarded or maintained in a safe area.  When Agency officials have
determined that they have no further need for the investigative reports, the
reports should be returned to the  Office of Investigations.
                                  5-4

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


12. ACTION ON INVESTIGATIVE REPORTS.  Action officials to whom reports of
investigation are sent are responsible for reviewing, adjudicating, and
initiating appropriate administrative action within 120 days of the date the
OIG sends the report to them.  Investigations involving EPA employees must have
action initiated within 30 days.  Administrative action is initiated when the
first documented action is taken by the action official leading to disposition
of the case.  Statements of intent are not considered actions initiated.
Action officials are responsible for advising the OIG, in writing, of the
action initiated.  When action officials consider that final disposition of an
investigative case has been effected, they will  advise the Assistant Inspector
General for Investigations of the full and complete administrative action
taken.  Assistance is available from the Office of General Counsel and the
Personnel Management Division concerning appropriate administrative actions.
                                    5-5

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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


       CHAPTER 6—MANAGEMENT AND TECHNICAL ASSESSMENT ACTIVITIES


                           Table of Contents
PARAGRAPH                                                          PARAGRAPH
TITLES                                                             NUMBERS

General	1
Organ i zat ion	2
Semiannual  Reports to Congress	3
Personnel Security Program	4
Employee Awareness Program	5
Review of Legislation and Regulations	6
Suspensions and Oebarments	7
Hotline	8
Management Control Efforts	9  .
Fraud Prevention Activities	10
Freedom of Information Act Requests	11
Administrative Functions	12
Committee on Integrity and Management Improvement	13

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FUNCTIONS AND ACTIVITIES OF THE                                            6bOO
OFFICE OF INSPECTOR GENERAL                                                1/22/85


       CHAPTER 6—MANAGEMENT AND TECHNICAL ASSESSMENT ACTIVITIES
1.  GENERAL.  The Assistant Inspector General  for Management and Technical
Assessment is responsible for initiating and carrying out OIG efforts
concerning the prevention and detection of fraud, waste,  and mismanagement  in
Agency programs and operations;  evaluating management controls;  reviewing and
analyzing Agency issuances; initiating employee awareness programs,  including
the operation of the Hotline;  coordinating personnel  security investigations;
preparing the IG's semiannual  reports to Congress and "IG Highlights;"
responding to Freedom of Information Act requests;  coordinating  debarment and
suspension activities; and carrying out OIG administrative functions.

2.  ORGANIZATION.  The Office of Management and Technical Assessment is located
in the OIG's Washington, D.C., Headquarters and comprises tne Management and
Administrative Services Division and the Technical  Assessment and Fraud
Prevention Division.

3.  SEMIANNUAL REPORTS TO CONGRESS.  The Administrative and Management  Services
Division is the focal point for production of the semiannual reports to Congress
as required by section 5 of the Inspector General Act of 1978.  The  Management
and Administrative Services Division plans the production schedule for  report
preparation and coordinates the development, collection,  analysis, editing, and
review of information for inclusion in the semiannual reports.

4.  PERSONNEL SECURITY PROGRAM.   The Assistant Inspector General for Management
and Technical Assessment monitors the personnel security investigations
conducted by the Office of Personnel Management and other agencies;  evaluates
investigative data received; and determines the security, suitability,  and
integrity of EPA employees and prospective employees in accordance with the
requirements of Executive Order 10450, "Security Requirements for Government
Employment."

5.  EMPLOYEE AND PUBLIC AWARENESS PROGRAM.  One of the most powerful ways of
achieving the objectives of the OIG is an active program to inform EPA  employees
and program participants about the OIG and to make these individuals aware of
their responsibility to prevent, detect, and report fraud, waste, and mismanage-
ment.  This employee and public awareness program is carried out through fraud
information bulletins, hotline posters, "IG Highlights"  (a digest of semiannual
reports to Congress), published articles to EPA management and employees,
brochures on the OIG operations, public service announcements, and mailings to
EPA program participants.

6.  REVIEW OF LEGISLATION AND REGULATIONS.  As required by section 4(a)(2) of
the Inspector General Act, reviews are made of existing or proposed legislation
and regulations relating to programs and operations.  In addition to providing
comments within the Agency, the OIG can make recommendations to  Congress on the
impact of such legislation and regulations on the economy and efficiency in the
administration of EPA programs and operations or the prevention  and detection
of fraud and abuse.

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 FUNCTIONS AND ACTIVITIES OF THE                                            6500
 OFFICE OF INSPECTOR GENERAL                                                1/22/85


 7.  SUSPENSIONS AND DE8ARHENTS.  It  is  necessary  that  grants  and  contracts
 awarded by the Agency be made only to those  who are  honest  and  responsible
 and who comply with applicable rules  and  reyulations.   EPA  regulations  (40
 CFR Part 32 and 48 CFR subpart 1509.5)  authorize  the Agency to  deny  any
 individual, organization, or unit  of  government the  opportunity to parti-
 cipate in EPA-assisted programs or operations  because  of misconduct  or  poor
 performance.  The Technical  Assessment  and Fraud  Prevention Division
 coordinates implementation of these EPA regulations; maintains  liaison  with
 affected Agency components;  and arranges  for audit,  engineering,  and
 investigative support for Agency debarment and suspension actions.

 8.  HOTLINE.  The 016 maintains a  24-hour, toll-free hotline  for  the  receipt,
 screening,  and disposition of complaints  concerning  the possible  existence
 of any activity constituting a violation  of  law,  rules, or  regulations;
 mismanagement;  gross  waste of funds; abuse of  authority; or a substantial
 and specific danger to the public  health  and safety.   The hotline toll-free
 number is (800) 424-4000.  EPA employees  should dial 8-382-4977.  (See
 chapter 3,  paragraph  7.)

 9.  MANAGEMENT CONTROL EFFORTS.  Experience  has shown  that  mismanagement,
 waste,  and  abuse can  often occur where  there is a lack of proper manage-
 ment controls  or where those controls are not  followed or enforced.   The
 Technical Assessment  and  Fraud Prevention Division provides assistance
 and advice  to  Agency  officials in  their efforts to implement management
 controls  in  EPA's  programs  and operations.   OMB Circular A-123  requires
 that agencies  review  and  improve internal controls to  eliminate fraud,
 waste,  and  mismanagement  in  the  Federal Government by outlining internal
 control  standards  and a system of  Agency  responsibilites and  requirements
 to address  the  numerous instances  of fraud,  waste, and abuse of Government
 resources.   Congress  expressed  support  for this effort by passing the
 Federal Managers'  Financial  Integrity Act of 1982, 31 U.S.C.  3512.   The act
 requires  that  internal  accounting  and administrative control  standards be
 prescribed  by the  Comptroller  General;  annual  evaluations of  internal
 accounting  and  administrative  controls  be conducted  by each executive
 agency; and  an  annual  statement  by the  head  of each  agency  be submitted to
 the  President and  the  Congress.  The annual  statement  is to address the
 agency's  compliance with  internal  control  standards  and requirements
 prescribed by the  Comptroller  General.

 The  role of  the  OIG is to provide  technical  support  and advice to the
 Agency and to conduct  independent  evaluations of the Agency's implementation
of the act.
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FUNCTIONS AND ACTIVITIES OF THE                                            6500
OFFICE OF INSPECTOR GENERAL                                                1/22/85


10. FRAUD PREVENTION ACTIVITIES.  As the focal point for EPA's fraud
prevention, the Technical Assessment and Fraud Prevention Division is
responsible for.developing and recommending (1) long-range strategies and
goals to minimize the opportunities for the occurrence of fraud and waste in
Agency programs and operations and (2) innovative techniques and systems for
the detection of fraud.  This effort includes:

     a.  Reviewing and analyzing Agency programs, activities, and functions
to identify those areas vulnerable or sensitive to fraud and abuse.

     b.  Developing, coordinating, and conducting training courses,
information, or presentations for OIG staff and appropriate EPA personnel
in fraud detection and prevention techniques or activities and management
control systems.

     c.  Operating as principal liaison with EPA and other government
agencies on fraud control matters, including the President's Council on
Integrity and Efficiency.

11. FREEDOM OF INFORMATION ACT REQUESTS.  The Management and Administrative
Services Division receives, coordinates, and responds to requests for informa-
tion under the Freedom of Information Act.  Requests are coordinated with the
appropriate Assistant Inspector General to determine if the request can be
honored in full or if there is any legal basis for denying all or part of the
request.  The OIG maintains a policy of full disclosure unless the material
requested falls into one of nine exemptions which may limit its release.

12. ADMINISTRATIVE FUNCTIONS.  The Management and Administrative Services
Division is responsible for the administrative functions for the operation
of the Office of Inspector General.  These functions include processing
personnel matters, developing and presenting the budget and related material,
coordinating and issuing operational policies and procedures, managing space
and equipment, and coordinating and carrying out Agency administrative
regulations.

13. COMMITTEE ON INTEGRITY AND MANAGEMENT IMPROVEMENT.  The Committee on
Integrity and Management Improvement is part of the Agency's effort to
eliminate fraud, waste, and mismanagement in EPA programs and operations.
The Committee serves as the Administrator's main policy advisor on matters
relating to fraud prevention and detection.  The Committee, which is chaired
by the Inspector General, consists of representatives from each of the
Assistant Administrators, General Counsel and staff offices in EPA.  As
chairperson of the Committee, the Inspector General serves primarily in an
advisory and coordinating capacity.  Committee members participate in conduct-
ing studies or projects aimed at improving policies or procedures to prevent
or detect fraud, waste, and mismanagement.  The Technical Assessment and Fraud
Prevention Division provides technical assistance and support to the Committee
and its projects.  See EPA Order 1130.1 on the Committee on Integrity and
Management Improvement.


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