svEPA
United States
Environmental Protection
Agency
Administration And
Resources Management
(3304)
EPA 205-R-93-005
December 1993
1993 Integrity Act
Report To The President
And Congress
Federal Managers' Financial Integrity Act
(RL 97-255)
October 1,1992 - September 30,1993
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC 2 9 1993 THE ADMINISTRATOR
The President
The White House
Washington, DC 20500
Dear Mr. President:
I am pleased to advise you that the Environmental Protection Agency's (EPA) management
control and financial systems, except as noted below, reasonably assure the protection of our
programs and resources from fraud, waste and abuse, thus achieving the intent of the Federal
Managers' Financial Integrity Act. My Inspector General agrees that we have significantly
improved the Agency's implementation of the Integrity Act by the strong, positive management
actions that we have taken in 1993.
My personal assurance to you is based on significant management action and reforms that I
have set in motion since January 1993, as well as my trust and confidence in my new management
team. In my first year as Administrator, I strengthened management accountability at the Agency
by creating Senior Resource Officials to ensure sound integrity and management principles in
achieving program results. I also established my Senior Leadership Council, composed of my top
career and appointed executives, to discuss and act on the tough regulatory, enforcement, program,
and management issues that affect the daily lives of our citizens.
I also have focused on strengthening the management framework within EPA during the last
year. I conducted a far-reaching review of EPA's budget to ensure that the Agency's base resources
are better managed and targeted to new and emerging environmental priorities. That effort will
culminate in the Spring of 1994 with the completion of an Agency-wide Strategic Plan that will tie
together the budget process and the environmental objectives of the Agency. I assessed EPA's
enforcement authorities and implemented a reorganization plan to centralize, clarify, and strengthen
our national enforcement role. I established a high-level workgroup to implement the recently
passed Government Performance and Results Act, including Agency participation in the
Administration's performance measures pilot program and the development of measurable goals to
help set the Nation's environmental agenda. I also initiated an effort to integrate implementation of
the Integrity Act with the Chief Financial Officers Act and the Government Performance and
Results Act. These actions are intended to improve the efficacy of our programs and strengthen the
effectiveness of EPA's management controls in achieving our environmental mission.
Printed on Recycled Paper
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EPA's assessment of 1993 management integrity accomplishments, Presidential weaknesses,
and plans to strengthen the Agency's management control systems reflect my commitment to
accountability and managing for results. My Assistant and Regional Administrators and I
thoroughly reviewed existing material weaknesses proposed for correction by the Agency, and new
areas proposed by the Office of Management and Budget, the General Accounting Office, and
EPA's managers and Inspector General.
As a result of this assessment, I am pleased to report that we have corrected five material
weaknesses in 1993: 1) the Superfund Contract Laboratory Program; 2) Audit Follow-up; 3)
Requests for Audits of EPA Contractors; 4) Chemical Testing; and 5) Pesticides Disposal. While
we are not identifying any new Presidential weaknesses in 1993, we are continuing to focus attention
on key areas of our information resources management program. I have asked EPA's Inspector
General to work with our Chief Financial Officer to strengthen the integrity of EPA's information
systems and to improve the Agency's financial management of Superfund.
We continue to report 18 material weaknesses, including three areas on the Office of
Management and Budget's High Risk list: 1) Superfund remedial cleanup and contract
management; 2) Agency-wide contracts management; and 3) EPA financial systems: accounts
receivable module and system documentation. Finally, we have corrected two of our five material
financial system non-conformances: '!) General Ledger account adjustments; and 2) Treasury
reports reconciliation. These areas are fully described in the Enclosures.
In discussing EPA's management problems, my senior leadership team and I must advise you
that several of our major environmental programs are at risk, not because of weaknesses in our
management controls, but because of resource shortfalls at the national level and unfunded Federal
mandates at the state and local level. In my Agency plan to implement National Performance
Review recommendations, I propose to reinvest savings from streamlining our operations back into
the Agency for critical improvements to our programs. I believe that this action is essential to meet
high public expectations for a reinvented government and to begin addressing resource issues.
With your support, I intend to work closely with Congress and our state partners to develop
long-term funding solutions for EPA's national programs and to enhance our ability to protect
human health and the environment.
Sincerely,
Carol M.
Enclosures
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1993 INTEGRITY ACT REPORT
TABLE OF CONTENTS
CONTENTS PAGE
Transmittal Letter to the President
Enclosure A Statistical Summary of Performance A 1
Enclosure B Progress Report on High Risk Areas B 1-3
Enclosure C Schedule of Corrective Actions for
Material Weaknesses C 1-46
Ranked Material Weakness Summary
18 Carryover Material Weaknesses
5 Corrected Material Weaknesses
Enclosure D Schedule of Corrective Actions for
Material Non-Conformances D 1-11
Material Non-conformance Summary
3 Carryover Non-conformances
2 Corrected Non-conformances
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Enclosure A - Statistical Summary of Performance
-------
1993 INTEGRITY ACT REPORT
U.S ENVIRONMENTAL PROTECTION AGENCY
STATISTICAL SUMMARY OF PERFORMANCE
SECTION 2. INTERNAL CONTROL
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Prior Years
1991 Report
1992 Report
1993 Report
Total
Number of Material Weaknesses
Number reported
for the first
time in:
27
7
8
0
42
For that year,
number that have
been corrected:
22
2
0
0
24
For that year,
number still
pending:
5
5
8
0
18
Of the total number corrected, how manv were corrected in 1993? 5
SECTION 4. FINANCIAL MANAGEMENT SYSTEMS
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Prior Years
1991 Report
1992 Report
1993 Report
Total
Number of Material Non-conformances
Number reported
for the first
time in:
18
0
0
0
18
For that year,
number that have
been corrected:
15
0
0
0
15
For that year,
number still
pending:
3
0
0
0
3
Of the total number corrected, how many were corrected in 1993? 2
Enclosure A Page 1
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Enclosure B • Progress Report on High Risk Areas
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
PROGRESS REPORT ON HIGH RISK AREAS
Title and Status; Financial Systems
EPA's financial system does not provide timely data and does not fully automate
accounting for receivables. (See Enclosure B, page 2, for a detailed description of the
Agency's corrective action strategy^ milestones and results indicators.)
Title and Status: Contracts Management
EPA is implementing a comprehensive plan to address Agency-wide contract
management problems. In 1993, the Agency reorganized and elevated its procurement
and contracts management functions, and established Senior Resource Officials in each
program and Region to strengthen accountability for all resource management
responsibilities. This High Risk Area is also a material weakness. (See Enclosure C, page
12 for a detailed description of the Agency's corrective action strategy, milestones and results
indicators.)
Title and Status; Superfund
This High Risk area has two components: (1) Alternative Remedial Contract
Strategy (ARCS) Contracts Management, and (2) Accelerating Remedial Cleanup. EPA
has significantly improved management of the ARCS contracts and completed major
corrective action workplans to accelerate cleanups of Superfund sites. This High Risk
Area is also declared as two material weaknesses. (See Enclosure C, pages 22 and 28, for
a detailed description of the Agency's corrective action strategy, milestones and results
indicators.)
Enclosure B - Page 1
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[X] OMB High Risk Area
[ ]New
[ ] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Financial Systems
DESCRIPTION:
GAO, OIG, and internal Agency reviews found non-conformances and deficiencies in EPA's Integrated
Financial Management System (IFMS). IFMS is not fully automated to account for receivables and does
not provide timely data.
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1989
1990
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure B - Page 2
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA's strategy in FY94 includes: 1) implementing a new version of the IFMS Core software to provide
new accounts receivable functionalities, system documentation, and user manuals; 2) conducting training
classes on accounting and managing accounts receivable; and 3) issuing and updating policy guidance on
systems enhancements to produce complete and accurate reports. EPA will review the annual Financial
Management Officers' (FMO) certifications for accounting system problems. EPA will request OIG
validation that corrective actions eliminated management control weaknesses as a result of its annual audit
of EPA's financial statement required by the Chief Financial Officers Act. Pending OIG concurrence,
EPA plans to recommend removal of financial systems from OMB's High Risk List in 1994.
RESULTS INDICATORS:
Key results indicators include accurate and timely accounting of receivables and improved IFMS capability
to produce OMB and EPA management reports.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Update policies for recording General Ledger
transactions in IFMS.
2. Install enhancements to Accounts Receivable
Module to handle debt servicing.
3. Complete third round of on-site verification
reviews for Accounts Receivable.
4. Reconcile FY89 General Ledger conversion
adjustments.
5. Implement Version 5.1e of IFMS, user
manuals, and system documentation.
6. Complete enhancements to produce complete
and accurate OMB and Treasury reports,
financial statements, and supplemental accounts
receivable reports.
ORIGINAL
TARGET
DATE
10/92
12/92
06/93
10/92
02/94
06/94
CURRENT
TARGET
DATE
04/93
02/93
N/A
10/93
02/94
06/94
ACTUAL
COMPLETION
DATE
11/92
05/93
06/93
10/93
Enclosure B - Page 3
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Enclosure C • Schedule of Corrective Actions
Material Weaknesses
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
RANKED MATERIAL WEAKNESSES SUMMARY
C&rrfOverM^tenalWf^knesscs
1. Environmental Data Quality
2. Research & Development Extramural Resources
3. Research & Development Facilities
4. Federal Facilities
5. Research & Development Equipment
6. Contracts Management
7. Drinking Water Primacy
8. Accounting System-Related Financial Management Problems
9. Information Resources Planning & Security
10. Accounts Receivable
11. Alternative Remedial Contract Strategy (ARCS) Contracts
Management
12. Pesticides Antimicrobial Program
13. Research & Development Operating Expenses
14. Accelerating Remedial Cleanup
15. Pesticides Data Integrity
16. Storm Water Permitting
17. Superfund Cost Recovery
18. Integrated Data for Enforcement Analysis (IDEA) System
1. Audit Follow-up
2. Requests for Audits of EPA Contractors
3. Lack of Effectiveness in Chemical Testing Program
4. Contract Lab Program
5. Pesticides Disposal
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Page
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C-8
C-10
C-12
C-14
C-16
C-18
C-20
C-22
C-24
C-26
C-28
C-30
C-32
C-34
C-36
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C-38
C-40
C-42
C-44
C-46
Enclosure C - Page 1
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Environmental Data Quality
DESCRIPTION;
EPA organizations that make or use environmental measurements are required to maintain a Quality
Assurance (QA) program to assure that environmental data of the appropriate type and quality are
collected to support Agency decisions. GAO and OIG have criticized the Agency for failing to
systematically assess the integrity of the Agency's environmental data measurement program.
RESPONSIBLE MANAGER:
H. Matthew Bills, Director, Office of Modeling, Monitoring Systems, and Quality Assurance
Office of Research and Development (ORD)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
]B&F
[]CG
[X] R&D
[X] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1994
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure C - Page 2
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
ORD has focused top management attention on the importance of quality assurance to increase
environmental data quality supporting Agency decisions. ORD has provided QA compliance status
reports and distributed policies and regulations to all senior managers. ORD has also developed QA
performance standards, required for all managers responsible for environmental data collection activities.
During FY94, ORD will initiate an on-site review process to provide technical assistance to managers in
developing QA management plans and strengthening their QA programs.
RESULTS INDICATORS:
ORD is aggressively working with Agency offices to achieve full compliance in developing required QA
management plans. Site review results will provide indicators of accuracy in environmental measurements.
MAJOR CORRECTIVE ACTION
MILESTONES
ORIGINAL
TARGET
DATE
CURRENT
TARGET
DATE
ACTUAL
COMPLETION
DATE
1. Conduct Alternative Management Control
Review of the Agency's contract files for QA
documentation.
12/93
12/93
2. Develop, along with the Office of Human
Resource Management, generic language to
address QA responsibilities for Agency
managers' Performance Standards.
04/94
04/94
3. Distribute schedule for Management Systems
Reviews planned for 1994. Report quarterly on
progress.
01/94
01/94
4. New EPA Quality Manual, to include EPA
Order on QA and revised QA requirements and
in green border.
04/94
04/94
5. Present updated status and action plan to the
Administrator's Senior Leadership Council.
05/94
05/94
Enclosure C - Page 3
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ] New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Research & Development Extramural Resources
DESCRIPTION:
Internal ORD assessments and OIG audits and related reviews identified a number of vulnerabilities in
ORD's management of extramural resources, which account for nearly seventy percent of total ORD
funds. The vulnerabilities include a wide range of programmatic, administrative, and financial issues.
These deficiencies in ORD laboratories significantly impair the ORD mission.
RESPONSIBLE MANAGER:
Clarence Mahan, Director, Office of Research Program Management
Office of Research and Development (ORD)
APPROPRIATIONS/ACCOUNTS:
[]PRO
[X] AC&C
[X]SF
[ ] LUST
]B&F
[]CG
[X] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1990
1992
Internal ORD Actions 1994
External Actions 1995
Internal ORD Actions 1994
External Actions 1995
Explanation for Change in Date: Not Applicable
Enclosure C - Page 4
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
ORD's comprehensive strategy to strengthen extramural resource management and ensure compliance
with all ORD, EPA, and Federal policies and requirements was to: 1) assign executive-level oversight;
2) conduct comprehensive staff training; 3) develop and implement new policies and procedures and
evaluate their effectiveness; 4) conduct indepth management reviews and analyses; and 5) integrate
resource requirements into the Agency's budget and planning processes. These types of initiatives and
efforts will continue and will be further enhanced with improved quality control procedures.
RESULTS INDICATORS:
ORD is striving to achieve effective, efficient extramural resource management in full compliance with
EPA and Federal policies and requirements.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Complete training sessions for WAMs, POs,
and DOPOs with management responsibilities.
2. Develop policy guidance on generic issues
and problems.
3. Implement management oversight throughout
ORD and provide proactive approaches in
identifying and correcting problems.
ORIGINAL
TARGET
DATE
09/91
12/91
Ongoing
CURRENT
TARGET
DATE
09/94
09/94
09/94
ACTUAL
COMPLETION
DATE
Enclosure C - Page 5
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Research & Development Facilities
DESCRIPTION:
The majority of ORD's twelve research laboratories and five field stations, which provide scientific
expertise for the Agency's regulatory program, are over thirty years old and in various stages of disrepair.
No valid Agency Masterplan exists to promote systematic upkeep and maintenance of these EPA-owned
assets. The disrepair results in health, safety, and environmental violations and vulnerabilities in EPA's
science program.
RESPONSIBLE MANAGER:
Clarence Mahan, Director, Office of Research Program Management
Office of Research and Development (ORD)
APPROPRIATIONS/ACCOUNTS;
UPRO
[]AC&C
[]SF
[ ] LUST
[X] B&F
[]CG
[X] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1989
1990
1994
1994
Explanation for Change in Date: FY94 target date is contingent on
development of Agency Masterplan.
Enclosure C Page 6
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
ORD created a Buildings and Facilities (B&F) Committee comprised of ORD Laboratory Directors to
focus senior management attention on B&F projects, priorities, and budget strategies to ensure systematic
upkeep and repair of ORD laboratories. Results to date include an automated ORD internal data
collection process to identify annual B&F requirements, an automated methodology to rank B&F projects
by category and improve decision and allocation processes, and Congressional authority to use R&D
allocations to fund B&F projects costing $75,000 or less. EPA also developed and implemented a
Masterplan effort to address B&F needs and strategic research requirements at three ORD laboratories
and has scheduled remaining ORD laboratories for FY94.
RESULTS INDICATORS:
ORD's goal is efficient and fully operational laboratories consistent with a Masterplan strategy for
systematic maintenance and upkeep. ORD is an ardent supporter of Masterplan initiatives and continues
to work with the Agency in this area.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Obtain input for the Masterplan effort from
ORD senior managers to ensure strategic
planning is included.
2. Establish policies for the appropriate
management of B&F procurement costing
$75,000 or less.
3. Provide EPA with documented ORD B&F
requirements to support the Agency's B&F
budget request.
ORIGINAL
TARGET
DATE
09/92
06/92
06/92
CURRENT
TARGET
DATE
07/94
02/94
03/94
ACTUAL
COMPLETION
DATE
Enclosure C - Page 7
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ] New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Federal Facilities
DESCRIPTION;
Internal reviews found vulnerabilities for Agency oversight and enforcement of Federal facility cleanup
under the Comprehensive Environmental Response, Compensation and Liability Act of 1980, further
exacerbated by the unfunded mandates of the Base Realignment and Closures Act (BRAC I, II, and III).
Resource projections include additional Agency workyears to perform new work and remedial site
assessments at one thousand sites. EPA's FY94 budget currently reflects only about forty percent of the
projected need.
RESPONSIBLE MANAGER:
Barry Breen, Acting Director, Office of Federal Facilities Enforcement
Office of Enforcement (OE)
APPROPRIATIONS/ACCOUNTS:
[]PRO
[]AC&C
[X]SF
[ ] LUST
]B&F
[]CG
[ JR&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
1993
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure C - Page 8
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
In FY94, EPA will complete the accelerated cleanup strategy and develop the base closure Model
Accelerated Cleanup (MAC) program to concentrate efforts on bases where DOD has developed reuse
plans.
RESULTS INDICATORS:
EPA's goal is to increase the number of base closures and property transfers resulting from more timely
and effective EPA oversight and enforcement of Federal facility cleanup.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Seek increase in workyears and Administrative
ceiling.
2. Develop strategy for program efficiencies.
3. Develop strategy for streamlining cleanup
process.
4. Conduct validation to ensure corrective action
is successful.
ORIGINAL
TARGET
DATE
12/91
12/91
12/91
12/92
CURRENT
TARGET
DATE
12/93
12/94
12/94
12/94
ACTUAL
COMPLETION
DATE
Enclosure C - Page 9
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Research & Development Equipment
DESCRIPTION:
As a result of internal reviews, ORD discovered that its scientific equipment, the basis for vital
assessments and analyses supporting EPA's mission and regulatory program, is aged and obsolete by
industry standards. There is no Agency strategy for equipment planning or budgeting to strengthen
laboratory scientific capability.
RESPONSIBLE MANAGER:
Clarence Mahan, Director, Office of Research Program Management
Office of Research and Development (ORD)
APPROPRIATIONS/ACCOUNTS:
[ ]PRO
[]AC&C
[X]SF
[ ] LUST
]B&F
[]CG
[X] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report
Current Correction Date:
1988
1990
1994
1999
Explanation for Change in Date: FY94 target date is contingent on
Agency completion of ORD's second Five- Year Plan.
Enclosure C - Page 10
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
ORD created a Capital Equipment Committee to focus senior management attention on scientific and
technical equipment requirements and funding decisions. ORD received unprecedented Congressional
authority to fund scientific equipment with R&D appropriated funds, previously restricted to the former
S&E appropriation. ORD's Five-Year Budget Plan for FY88-93 increased funding for scientific
equipment. ORD's FY94-99 Five-Year Plan requests additional resources.
RESULTS INDICATORS:
EPA increased resources for scientific equipment from $2 million to $13 million annually in its efforts to
improve the quality of ORD's scientific equipment. The long range goal is state-of-the-art scientific
equipment at all ORD laboratories.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Update inventory and perform analysis for
replacement vs. upgrade needs.
2. Submit annual budget initiatives.
3. Develop a replacement/upgrade scientific
equipment plan for 1995-1999 based on current
funding level.
ORIGINAL
TARGET
DATE
03/94
04/94
06/94
CURRENT
TARGET
DATE
03/94
04/94
06/94
ACTUAL
COMPLETION
DATE
Enclosure C - Page 11
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[X] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Contracts Management
DESCRIPTION:
In 1992, OIG reported widespread and systemic problems with EPA contracts management, including:
1) personal services relationships between contractors and EPA staff; 2) contractor performance of
inherently governmental functions; 3) loss of EPA staff expertise which could jeopardize Agency control
over major programs; 4) unqualified contractor staff; 5) inadequate assurance of cost-effective Agency
operations; and 6) weaknesses in EPA property administration. The Agency established the Standing
Committee on Contracts Management (SCCM) to identify and begin to correct widespread problems
identified by OIG and recommend corrective actions to address the problem's root causes. In FY93 the
SCCM was renamed the Resources Management Committee (RMC) comprised of Agency Senior
Resource Officials to focus on all extramural resource management responsibilities.
RESPONSIBLE MANAGER:
Betty L. Bailey, Director, Office of Acquisition Management
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Miscellaneous
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1996
1996
1997
Explanation for Change in Date: Analysis of pilot program to
locate Contracting Officers and Project Officers was extended
months.
co-
five
Enclosure C - Page 12
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The SCCM identified seven key deficiencies in EPA contracts management and recommended
improvements in each of the following areas: 1) the organizational standing of the Agency contracts
management function; 2) management accountability; 3) resources allocation; 4) training; 5) policy
and guidance; 6) human resource development; and 7) control of contractor cost and performance.
RESULTS INDICATORS:
EPA completed fifteen of the forty SCCM recommendations in FY93 and will complete remaining
recommendations through FY97. EPA's goal is effective contracts management practices in
compliance with EPA and Federal policies and regulations.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Develop Milestone Plan.
2. Restructure EPA's central contracts function.
3. Integrate accountability for program results
and contract management at strategic, operational,
and project levels.
4. Allocate resources to ensure efficiency and
integrity of acquisition function.
5. Develop a comprehensive training program.
6. Revamp EPA procurement guidance
documents and policies.
7. Revise human resource policies to emphasize
acquisition management.
8. Adopt aggressive policies and programs to
ensure effective contractor performance and
rigorous control of contractor costs.
9. Develop and implement the Integrated
Contract Management System (ICMS).
ORIGINAL
TARGET
DATE
10/92
11/94
03/96
06/93
06/94
06/93
06/93
09/94
09/95
CURRENT
TARGET
DATE
N/A
12/93
03/97
N/A
06/94
01/94
03/94
02/95
09/96
ACTUAL
COMPLETION
DATE
10/92
06/93
Enclosure C - Page 13
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Drinking Water Primacy
DESCRIPTION:
The Agency requires states to adopt and implement all EPA drinking water regulations to retain primacy.
Expansion in the number and complexity of drinking water regulations has increased workload demands
and threatened states' ability to retain primacy. EPA lacks capacity and expertise to implement programs
withdrawn or returned from the states, as required under current law. Unless strong steps are taken, the
Federal/state partnership in the drinking water program is in serious jeopardy.
RESPONSIBLE MANAGER:
Robert Blanco, Director, Enforcement and Program Implementation Division
Office of Ground Water and Drinking Water, Office of Water (OW)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[]SF
[ ] LUST
]B&F
[]CG
[ ] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1997
1997
1997
Explanation for Change in Date: Not Applicable
Enclosure C - Page 14
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA is working to: 1) increase Public Water Systems Supervision grants to states; 2) allocate resources
to the greatest public health threats first; 3) allow more time for states to build capacity for primacy;
4) provide training and technical assistance to states on the use of alternative financial mechanisms; and
5) promote innovation and flexibility in program implementation. EPA developed a contingency plan,
including use of third parties, to directly implement state programs. EPA also prepared a report on key
issues for the Congress in reauthorizing the Safe Drinking Water Act.
RESULTS INDICATORS:
States' ability to generate resources projected as needed for primacy is the key success measure. To date,
thirteen states have enacted fees or increased resources to support the drinking water program. Resource
proposals for five other states are pending before their legislatures.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Revise state resource needs assessment to
estimate shortfall by year and by regulation.
2. Implement the priorities guidance with each
state through the annual work planning process.
3. Assess state abilities to meet priority one
activities.
4. Identify/work to resolve state capacity needs,
work to resolve.
5. Develop contingency plan for directly
implementing state primacy programs.
6. Identify EPA resource needs to directly
implement state programs.
7. Elevate state capacity efforts in FY94
contract plan.
8. Validate that states have implemented new
rules included in the priority strategy.
ORIGINAL
TARGET
DATE
03/93
annually
09/93
ongoing
03/93
06/93
08/93
09/97
CURRENT
TARGET
DATE
12/93
annually
N/A
ongoing
N/A
03/94
11/93
09/97
ACTUAL
COMPLETION
DATE
annually
09/93
ongoing
01/93
Enclosure C - Page 15
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[X] OMB High Risk Area
[ ] New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE; Accounting System-Related Financial Management Problems
DESCRIPTION:
While EPA's Integrated Financial Management System (IFMS) meets the Joint Financial Management
Improvement Program core accounting system requirements, specific systems-related problems impair
EPA's ability to provide complete, reliable, and timely data for Agency decision-making and control of
assets. These problems include: 1) incomplete user manuals and system documentation; 2) inadequate
automated project cost accounting capability; 3) incomplete interfaces with programmatic and
administrative systems; and 4) inadequate financial management reports. EPA's Financial Systems is also
reported on the Office of Management and Budget's High Risk List and in Enclosure D, Financial
Systems Non-conformances, of EPA's 1993 Integrity Act Report.
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1995
1995
1995
Explanation for Change in Date: Not Applicable
Enclosure C - Page 16
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA is developing project cost accounting and property systems capability requirements and an interface
with Grants Information and Control System (GICS). During FY94, OIG will validate the effectiveness
of corrective actions as part of its annual audit of EPA's financial statement required by the Chief
Financial Officers Act.
RESULTS INDICATORS:
EPA's key success measure is complete, reliable, and timely financial data to support effective Agency
decision-making.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Issue and update final policy to record
transactions in IFMS.
2. Complete final on-site verification reviews.
3. Install debt service enhancement to Accounts
Receivable Module.
4. Conduct Strategic and Master Plan Study.
5. Complete Property System Requirement Study.
6. Implement Version 5.1e of IFMS.
User Manuals and System Documentation
7. Develop Funds Management Requirements.
8. Complete enhancements to produce accurate
reports.
9. Develop Project Cost Accounting Requirements.
10. Implement interface between IFMS and GICS.
11. Eliminate old systems FMS and RMIS.
ORIGINAL
TARGET
DATE
04/94
06/93
12/92
03/93
01/94
02/94
09/93
06/94
09/93
09/94
09/95
CURRENT
TARGET
DATE
04/94
06/93
02/93
07/93
01/94
02/94
06/94
06/94
09/94
10/94
09/95
ACTUAL
COMPLETION
DATE
11/92
06/93
05/93
07/93
Enclosure C Page 17
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Information Resources Planning and Security
DESCRIPTION:
OIG and GAO believe that material management control weaknesses have resulted in duplication,
inefficiency, cost overruns, and delays in developing and implementing EPA systems, ineffective Agency
management of ADP contracts, data quality deficiencies, exposure of sensitive data to unnecessary risk,
and inability to support EPA's cross-media mission. They indicate that lack of top management
commitment and sufficient resources to support Information Resources Management (IRM) impede
comprehensive EPA assessment of environmental risks and solutions.
RESPONSIBLE MANAGER:
Alvin M. Pesachowitz, Director, Office of Information Resources Management
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1995
1995
1995
Explanation for Change in Date: Not Applicable
Enclosure C - Page 18
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA is implementing a three-phased approach for IRM planning that involves carrying out a
comprehensive action plan, developing necessary policies and procedures, and conducting a pilot planning
process. OIRM leadership and National Data Processing Division are strengthening EPA's information
planning and security program by: 1) integrating IRM Planning and Budgeting; 2) improving coordination
of system development; 3) revising EPA's Information Security Policy and Manual; 4) improving security
monitoring; and 5) training Agency staff on computer security awareness.
RESULTS INDICATORS:
Key EPA success measures for IRM planning and security include reduced risk of data security fraud,
increased data quality for better decision-making, and reduced costs from integrated planning and
budgeting and coordinated systems development.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Analysis of access paths into the National
Computer Center.
2. Create risk reduction implementation schedule.
3. Designate security officers.
4. Establish program offices' planning process.
5. Update information security policies/standards.
6. Secure sensitive system's risk analysis and plans.
7. Implement a security monitoring program.
8. Establish central review capability.
9. Formalize above in Agency policy.
10. Provide mandatory security awareness training.
11. Validate information security milestones.
12. Initiate pilot integrated planning cycle.
13. Finalize policies in Agency policy.
14. Initiate Agency-wide IRM Integrated Plan.
ORIGINAL
TARGET
DATE
03/93
05/93
04/93
09/93
12/93
12/93
06/93
12/93
03/94
06/93
04/94
05/94
New
05/95
CURRENT
TARGET
DATE
03/93
03/93
04/93
09/93
N/A
N/A
N/A
12/93
03/94
06/93
04/94
05/94
12/94
03/94
ACTUAL
COMPLETION
DATE
03/93
03/93
09/93
09/93
03/93
Enclosure C - Page 19
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ] New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Accounts Receivable
DESCRIPTION:
EPA internal reviews and OIG audits identified technical shortfalls in EPA's accounts receivable module,
non-current policies and procedures, inaccurate and incomplete reports, and insufficiently trained
personnel. These vulnerabilities continue to prevent the Agency from effectively managing its receivables.
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1994
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure C - Page 20
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA's strategy in FY94 includes: 1) implementing a new version of the Integrated Financial Management
System (IFMS) Core software to provide new accounts receivable functionalities, system documentation
and user manuals; 2) conducting training classes on accounting and managing accounts receivable; and
3) issuing and updating policy guidance on systems enhancements to produce complete and accurate
reports. OIG will validate the effectiveness of completed corrective actions as part of its annual audit of
EPA's financial statement required by the Chief Financial Officers Act.
RESULTS INDICATORS:
Key results indicators include accurate and timely accounting of accounts receivables, worth $464 million
as of September 1993, and improved IFMS capability to produce OMB and EPA management reports.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Update policies for recording transactions in
IFMS.
2. Complete final on-site accounts receivable
(A/R) verification reviews.
3. Install debt service enhancements to A/R
Module.
4. Implement Version 5.1e of IFMS:
User Manuals;
- System Documentation; and
A/R Installment Enhancement.
5. Complete enhancements to produce complete
and accurate reports.
6. Train staff on accounting and managing
receivables.
ORIGINAL
TARGET
DATE
10/92
06/93
12/92
02/94
02/94
02/94
06/94
08/94
CURRENT
TARGET
DATE
04/93
06/93
02/93
02/94
02/94
02/94
06/94
08/94
ACTUAL
COMPLETION
DATE
11/92
06/93
05/93
Enclosure C - Page 21
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[X] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Alternative Remedial Contract Strategy (ARCS) Contract Management
DESCRIPTION:
ARCS contracts support the Superfund cleanup program with a total potential value in excess of $6 billion
over their ten-year term. A 1991 internal Agency review by the Superfund Management Task Force found
weaknesses in: 1) program management and organization; 2) contract capacity and utilization; 3) contract
controls; 4) financial audits and reviews; and 5) the contract award fee process. Ineffective contract
administration and oversight resulted in excessive contractor and program management costs.
RESPONSIBLE MANAGER:
Henry L. Longest, Director, Office of Emergency and Remedial Response
Office of Solid Waste and Emergency Response (OSWER)
APPROPRIATIONS/ACCOUNTS:
[ ]PRO
[]AC&C
[X]SF
[ ] LUST
]B&F
[]CG
[ ] R&D
[ ] Oil Spill
f 1 Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
1992
1993
1994
Explanation for Change in Date: EPA will validate the
effectiveness of corrective actions in FY94.
Enclosure C - Page 22
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA created Regional Management Teams to focus management attention to ARCS contract issues.
EPA has taken steps to: 1) establish decreasing national program management cost targets to lower
overhead expense ratios; 2) increase Regional flexibility in selecting contracts or Army Corps of Engineers
(COE) to balance ARCS usage; 3) monitor actual contract utilization and take timely action to reduce
or redistribute excess contract capacity; 4) initiate independent government cost estimates (IGCE) to
better control costs; and 5) improve award fee process to ensure best contractor efforts. EPA is
supplementing, and will eventually replace, ARCS contracts with Response Action Contracts (RAC).
RESULTS INDICATORS:
EPA reduced program management costs from twenty percent in 1991 to 12.3 percent in 1993; reduced
actual costs from $30.2 million in 1990 to $24.7 million in 1992; increased contract capacity and utilization
rates from $75 million to $141 million; balanced ARCS/Army COE construction management system; and
stabilized government cost estimates. EPA conducted five Regional reviews in FY93 to validate corrective
actions and will complete five more Regional reviews in FY94. The Regions will also self-assess
effectiveness of corrective actions to validate results in FY94.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Assess the apparent excess contract capacity.
2. Ensure balanced Construction Mgt. System.
3. Examine HQ/Regional mgt. responsibilities.
4. Revise the Program Management Concept.
5. Assess the current workload assumption.
6. Facilitate revised policy implementation.
7. Assess and reinforce award fee policy.
8. Establish Regional capacity for IGCEs.
9. Send validation template to Regions.
10. Discuss results with Regions.
11. Take corrective actions as needed.
ORIGINAL
TARGET
DATE
08/92
07/92
09/92
07/92
11/92
09/92
09/92
08/93
11/93
06/94
09/94
CURRENT
TARGET
DATE
08/92
07/92
09/92
07/92
11/92
12/92
12/92
08/93
11/93
06/94
09/94
ACTUAL
COMPLETION
DATE
04/92
04/92
07/92
09/92
11/92
12/92
12/92
08/93
Enclosure C - Page 23
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
] OMB High Risk Area
]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Pesticides Antimicrobial Program
DESCRIPTION:
A 1990 GAO review found weaknesses in the Agency's antimicrobial program, including: 1) the integrity
and quality of EPA databases; 2) validity of test methods; and 3) lack of a plan for enforcement and
follow-up actions regarding efficacy claims. These management problems increase the potential risk of
infection to patients in the health care system from ineffective disinfectant products.
RESPONSIBLE MANAGER;
Douglas D. Campt, Director, Office of Pesticide Programs
Office of Prevention, Pesticides, and Toxic Substances (OPPTS)
APPROPRIATIONS/ACCOUNTS:
[ ]PRO
[X] AC&C
[]SF
[ ] LUST
]B&F
[]CG
[ ] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1990
1992
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure C - Page 24
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA implemented a comprehensive product testing program, researched major antimicrobial test methods,
and allocated sufficient funds to correct identified problems. In FY94, EPA will conduct an internal
review to validate the effectiveness of its corrective action strategy.
RESULTS INDICATORS:
The key success measure for correcting the antimicrobial program weaknesses is improved test methods
for determining the efficacy of antimicrobial products, thus, resulting in the removal of ineffective
sterilants from the marketplace. Fourteen ineffective sterilant products that are used on critical medical
instruments have been removed from the market, and action is pending against several others.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Issue public notice of testing programs/results.
2. Finalize process to handle failing data results.
3. Complete screening testing for sterilant products
under Food & Drug Administration Interagency
Agreement (LAG).
4. Expand EPA/state cooperative agreements.
5. Extend LAG on enforcement testing of sterilants.
6. Refine antimicrobial testing strategy.
7. Initiate tuberculocidal & hospital disinfectant
product testing at EPA Environmental Monitoring
Systems Laboratories.
8. Initiate cooperative agreements to validate test
methods, statistical support, injured cells tests.
9. Develop policies to clarify registration data
review and acceptance of new protocols.
10. Initiate refinements to tracking data bases.
11. Establish antimicrobial complaint system.
12. Validate ongoing corrective actions.
ORIGINAL
TARGET
DATE
09/91
12/91
09/91
06/92
09/92
09/92
09/93
09/91
09/91
09/92
09/91
09/94
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
09/94
ACTUAL
COMPLETION
DATE
09/91
09/91
06/92
06/92
09/92
09/92
06/93
09/92
09/92
09/92
09/91
Enclosure C - Page 25
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Research & Development Operating Expenses
DESCRIPTION:
Internal EPA reviews identified that the lack of sufficient resources for research and development
laboratory operating expenses prevents the Agency from maintaining adequate and up-to-date research
materials and services for vital scientific studies and analytical activities. This significantly impairs
fulfillment of the Agency's research mission.
RESPONSIBLE MANAGER:
Clarence Mahan, Director, Office of Research Program Management
Office of Research and Development (ORD)
APPROPRIATIONS/ACCOUNTS:
[ ]PRO
[]AC&C
[X]SF
[ ] LUST
B&F
[]CG
[X] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1990
1992
1995
1995
Explanation for Change in Date: Not Applicable
Enclosure C - Page 26
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The Agency's strategy was to: 1) obtain Congressional approval for increased flexibility in use of the
Research and Development appropriation; 2) consolidate ORD's budget structure to allow more efficient
allocation of resources; 3) include ORD laboratory funding requirements in Agency budget and planning
processes; and 4) issue new policy initiatives, specialized financial management reviews and evaluations,
and improve monitoring and reporting techniques. These type of efforts and initiatives will continue and
will be further enhanced with improved quality control procedures.
RESULTS INDICATORS:
Corrective actions resulted in increases in ORD laboratory operating expense funds from $22 million in
FY90 to over $35 million in FY93. A key measure of success is obtaining an overall reduction of risk to
the Agency's scientific and research mission through improved funding of EPA's R&D laboratories.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Reassess overall weakness to determine the
propriety of Integrity Act reporting.
2. Submit a proposal to the Agency based on
"1." above.
3. Develop policy directives for financial
management operations.
4. Conduct financial management reviews.
5. Validate effectiveness of corrective action in
reducing the risk to the Agency.
ORIGINAL
TARGET
DATE
03/94
04/94
06/94
07/94
08/94
CURRENT
TARGET
DATE
03/94
04/94
06/94
07/94
08/94
ACTUAL
COMPLETION
DATE
Enclosure C - Page 27
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
y
[X] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Accelerating Remedial Cleanup
DESCRIPTION:
A 1991 internal Agency review by the Superfund 30-Day Task Force identified management control
weaknesses causing a slow rate of cleanup of Superfund sites.
RESPONSIBLE MANAGER:
Henry L. Longest, Director, Office of Emergency and Remedial Response
Office of Solid Waste and Emergency Response (OSWER)
APPROPRIATIONS/ACCOUNTS;
[]PRO
[]AC&C
[X]SF
[ ] LUST
]B&F
[]CG
[ ] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
1992
1993
1994
Explanation for Change in Date: EPA will validate effectiveness of
corrective actions in FY94.
Enclosure C - Page 28
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The Agency's strategy is to standardize the remedial planning/remedy selection process by developing
presumptive remedies, developing and issuing standards for contaminated soils, and developing and
implementing a model management process for accelerating cleanups -- the Superfund Accelerated
Cleanup Model.
RESULTS INDICATORS:
Corrective actions have increased site cleanups from sixty-three in 1991 to over two hundred by September
1993; presumptive remedy pilots have demonstrated up to a one-year acceleration in the Remedial
Investigation/Feasibility Study process, and up to three years in the remedy selection process. Other
presumptive remedy pilots have demonstrated overall reduction in time to identify remedial actions.
Effectiveness of presumptive remedies will be validated through field demonstrations, monitoring and
reporting results, and modification of guidance based on demonstration results.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Segregate Federal Facilities from the
National Priorities List.
2. Expand Superfund's measures of success.
3. Expand flexibility of design/construction
contracts.
4. Standardize the remedial planning process.
5. Set aggressive cleanup targets.
6. Elevate issues causing delays.
7. Draft ground water presumptive remedy.
8. Draft other presumptive remedy guidance.
9. Complete technical assistance.
10. Finalize soil screening level guidance.
ORIGINAL
TARGET
DATE
12/91
09/92
09/93
09/92
09/93
09/93
03/94
09/94
09/94
09/94
CURRENT
TARGET
DATE
09/92
12/92
09/93
09/93
09/93
09/93
03/94
09/94
09/94
09/94
ACTUAL
COMPLETION
DATE
02/92
07/92
09/92
09/93
09/93
09/93
Enclosure C - Page 29
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[X] Material Weakness
[ ] Corrected
[ ] Non-con fonnance
[X] Carryover
TITLE: Pesticides Data Integrity
DESCRIPTION:
An OPPTS internal review and the OIG's special Good Laboratory Practices (GLP) program review
identified the following problems in the laboratory data integrity portion of the pesticides and toxic
substances enforcement program: 1) inspectors lacked training in laboratory fraud detection; 2) too much
advance notice prepared laboratories for upcoming inspections; 3) the GLP program lacked the means
of identifying laboratories based on their contracted scientific studies; and 4) poor internal coordination
between the Office of Pesticides Programs and the Office of Compliance Monitoring.
RESPONSIBLE MANAGER;
Michael M. Stahl, Director, Office of Compliance Monitoring
Office of Prevention, Pesticides, and Toxic Substances (OPPTS)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[]SF
[ ] LUST
[ ]B&F
[JIG
[]CG
[ JR&D
[ ] Oil Spill
[ 1 Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
1992
1993
1994
Explanation for Change in Date: Delayed implementation of
neutral administrative scheme for laboratory selection and
workgroup's results.
Enclosure C - Page 30
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA's strategy to strengthen data integrity of pesticides and toxic substances includes: 1) training
Headquarters, Regional, and National Enforcement Investigations Center GLP inspectors;
2) implementing a laboratory targeting system; and 3) implementing OIG report recommendations on the
Federal Insecticide, Fungicide and Rodenticide Act GLP program. In FY94, EPA will validate the
effectiveness of corrective actions by completing feasibility studies of a laboratory registration program
and automated laboratory selection system.
RESULTS INDICATORS:
Key success measures are reduced risk of data fraud and increased data quality for better decision-making.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Pilot test revised inspection notification
procedures.
2. Implement a revised neutral administrative
scheme for laboratory selection procedures.
3. Initiate an inspector training program.
4. Conduct a feasibility analysis of laboratory
accreditation.
5. Identify pivotal studies for audit process.
6. Improve coordination between OPP/OCM for
GLP program effectiveness through increased
use of OPP auditors.
7. Validate effectiveness of corrective actions by
assessing selected laboratory inspections, training
program evaluations, and inspector performance.
ORIGINAL
TARGET
DATE
12/91
02/92
09/92
04/93
04/93
1993
09/92
CURRENT
TARGET
DATE
N/A
N/A
N/A
01/94
N/A
1993
09/94
ACTUAL
COMPLETION
DATE
12/91
09/93
08/92
09/93
Enclosure C - Page 31
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Storm Water Permitting
DESCRIPTION:
The Clean Water Act (CWA) Amendments of 1987 require EPA to implement a permit program for
storm water drainage. Internal Agency reviews found delays in implementing this National Pollutant
Discharge Elimination System (NPDES) permit program, depriving the public of improved water quality
required by the Act.
RESPONSIBLE MANAGER:
Cynthia C. Dougherty, Director, Permits Division, Office of Wastewater Enforcement and Compliance
Office of Water (OW)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[]SF
[ ] LUST
[ ]B&F
[JIG
[]CG
[ ]R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
1993
1993
1994
Explanation for Change in Date: Additional time allowed for
public review and comment of EPA first draft report to Congress.
Enclosure C - Page 32
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA's strategy for meeting CWA Amendments of 1987 storm water permitting requirements is to:
1) increase Agency resources devoted to storm water program activities; 2) revise and promulgate NPDES
storm water regulations; 3) initiate issuance of permits; and 4) study current and future storm water
permit programs and prepare a report to Congress. In FY94, EPA will track milestones on the Agency's
Semiannual Regulatory Agenda and the quarterly OWEC agenda. These tracking systems will validate
the effectiveness of OW's planned actions, report the status of accomplishments, and verify results.
RESULTS INDICATORS:
Because this material weakness results from the Agency's failure to perform activities required by the
CWA Amendments, completion of those activities constitutes successful correction. A key success
measure is improved water quality as a result of implementing the NPDES storm water permitting
program.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Reorganize to create a storm water unit.
2. Allocate increased FY92 extramural funds.
3. Provide EPA Regions with increased contract
support for storm water permit programs.
4. Complete initial comprehensive outreach
activities.
5. Establish Notice of Intent Processing Center in
operation.
6. Issue 12 EPA storm water general permits.
7. Complete Report to Congress.
ORIGINAL
TARGET
DATE
01/91
12/91
01/92
10/92
10/92
06/92
01/94
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
N/A
01/94
ACTUAL
COMPLETION
DATE
01/91
12/91
01/92
09/92
09/92
09/92
Enclosure C - Page 33
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Superfund Cost Recovery
DESCRIPTION:
EPA is authorized under the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) to recover all response action costs incurred by the government from responsible parties.
OIG and GAO FY90-92 audits and reviews of the Agency's Superfund cost recovery program identified
problems in: 1) cost documentation; 2) data accuracy; and 3) accounting for all past costs of cleanups.
RESPONSIBLE MANAGER:
Sally Seymour, Director, CERCLA Enforcement Division, Office of Waste Programs Enforcement
Office of Solid Waste and Emergency Response (OSWER)
APPROPRIATIONS/ACCOUNTS:
[ ]PRO
[]AC&C
[XJSF
[ ] LUST
[ ]B&F
[JIG
[JCG
[ ] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1995
1995
1995
Explanation for Change in Date: Not Applicable
Enclosure C - Page 34
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
OSWER's strategy to improve the performance of the cost recovery program is to: 1) promulgate a Cost
Recovery Rule which establishes a methodology for calculating full recovery of EPA indirect costs,
requires documentation supporting response actions, clarifies CERCLA statute of limitations for cost
recovery actions, and sets cost recovery legal standards; 2) develop a Cost Recovery Procedures Manual
to provide users with information on preparing cost and work-performed documents to support cost
recovery actions; 3) enhance Cost Recovery Data Tracking by automating Superfund time sheets and
Contract Lab Program documents; and 4) develop guidance and procedures to standardize presentation
of settlement data.
RESULTS INDICATORS:
Success measures include increased accuracy of Superfund cost recovery accounting and documentation
and increases in the levels of funds recovered from responsible parties. OSWER is developing validation
procedures to assess effectiveness of corrective actions.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Promulgate Cost Recovery Rule.
2. Develop Procedures Manual.
3. Enhance Data Tracking.
4. Settlement Documentation.
ORIGINAL
TARGET
DATE
11/93
06/93
09/95
09/95
CURRENT
TARGET
DATE
02/94
03/94
09/95
09/95
ACTUAL
COMPLETION
DATE
Enclosure C - Page 35
-------
()
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Integrated Data for Enforcement Analysis (IDEA) System
DESCRIPTION:
GAO identified continuing weaknesses in the Agency's information system to provide integrated
enforcement data, both in documentation and testing of system software, and training IDEA system end
users.
RESPONSIBLE MANAGER;
Gerald A. Bryan, Director, Office of Compliance Analysis and Program Operations
Office of Enforcement (OE)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[ ] LUST
[]B&F
[]CG
[ JR&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1992
1992
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure C - Page 36
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
The Agency's corrective action strategy is to develop: 1) systems and program documentation; 2) a system
testing approach and methodology; and 3) an intensive on-site training program for end users. EPA will
validate effectiveness of corrective actions by establishing a documentation library and instituting
procedures for updating system documentation, software, maintenance, testing and training.
RESULTS INDICATORS:
A key success measure is increased users of OE's IDEA system to promote more effective multi-media
enforcement.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Develop a project plan for documentation and
review corrective action milestones.
2. Project review and evaluation of status.
3. Submit testing-documentation procedures.
4. Update documentation and implement testing
procedures.
5. Develop IDEA training plan.
6. Develop and test user friendly interface and
user manual.
7. Training provided for OE and HQ media
program office staff and EPA regional office staff.
8. Provide ongoing support and reports to Agency
targeting and screening efforts.
ORIGINAL
TARGET
DATE
06/93
06/93
06/93
09/93
12/92
03/93
06/93
09/93
CURRENT
TARGET
DATE
06/93
06/93
12/94
09/94
12/92
09/93
09/93
09/93
ACTUAL
COMPLETION
DATE
06/93
06/93
12/92
09/93
09/93
09/93
Enclosure C - Page 37
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[X] Material Weakness
[X] Corrected
[ ] Non-conformance
[ ] Carryover
TITLE; Audit Follow-up
DESCRIPTION;
OIG reviews noted problems in the Agency's audit follow-up program: 1) lack of an effective system to track
audits and corrective actions; 2) erroneous data in the tracking system and in reports to Congress; and 3) lack
of a Quality Assurance (QA) Program.
RESPONSIBLE MANAGER;
John J. Sandy, Director, Resource Management Division, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS;
pqpRO
[X] AC&C
[X]SF
[ ] LUST
[]B&F
[]CG
[]R&D
[ ] Oil Spill
[] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1989
1990
1993
1993
Explanation for Change in Date: Not Applicable
Enclosure C Page 38
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
EPA's strategy was to: 1) develop an automated system to track OIG audits; 2) assure data quality in the
automated system through on-site reviews, a quality assurance manual, and awareness bulletins; and 3) improve
management communications with the Inspector General and senior managers through periodic meetings and
issuance of a monthly Significant Audits Report. The effectiveness of the corrective action strategy was
validated through regular measurement of discrepancies in data fields, reconciliation of report data, and
comparison and documentation of field and national system data.
RESULTS INDICATORS:
Sustained reduction of differences in OIG and Management Audit Tracking System (MATS) data from
forty-eight to five percent; sustained reduction in percent of management decisions over 180 days past due by
thirty-two percent; fifteen percent reduction of corrective actions taking over one year to complete; improved
accuracy of data in Semiannual Reports to Congress.
MAJOR CORRECTIVE ACTION
MILESTONES
1 . Develop a QA Program.
2. Conduct on-site QA reviews.
3. Develop an EPA-wide early warning report.
4. Initiate a task force to identify MATS
concerns.
5. Develop additional audit follow-up guidance.
6. Develop and apply administrative procedures.
7. Reinforce accountability.
8. Protect sensitive data in MATS.
9. Launch a Quality Action Team on Audit
Management.
ORIGINAL
TARGET
DATE
05/91
05/91
03/92
12/91
12/90
07/92
02/92
03/93
02/93
CURRENT
TARGET
DATE
04/92
09/92
09/92
02/93
06/93
05/93
06/93
03/93
02/93
ACTUAL
COMPLETION
DATE
04/92
Ongoing
09/92
03/93
09/93
05/93
09/93
01/93
03/93
Enclosure C Page 39
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ } OMB High Risk Area
[ j New
[X] Material Weakness
[X] Corrected
[ ] Non-confonnance
[ ] Carryover
TITLE: Requests for Audits of EPA Contracts
DESCRIPTION:
Our 1991 internal Agency review found that the Office of Inspector General lacks adequate resources to
fulfill the Agency's demand for contract audits.
RESPONSIBLE MANAGER:
Kenneth A. Konz, Assistant Inspector General for Audit
Office of Inspector General (OIG)
APPROPRIATIONS/ACCOUNTS:
[]PRO
[]AC&C
[]SF
[ ] LUST
[]B&F
[X]IG
[]CG
[ ]R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
Ongoing
Ongoing
1993
Explanation for Change in Date: Not Applicable
Enclosure C - Page 40
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The OIG's corrective action strategy to improve audit coverage of the Agency's contractors was: 1) to
assign oversight responsibility for the Agency's top twenty-five contractors to a single OIG field division;
2) to assume audit cognizance for twelve contractors; 3) to expand staff training opportunities; and 4) to
obtain assistance from the Defense Contract Audit Agency (DCAA) in addressing pre-1991 audit backlog.
RESULTS INDICATORS:
OIG reduced the number of open incurred cost audit requests received prior to 1991 to fifty-seven, or just
twelve percent of the total open requests.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Request addition 24 workyears and $2.4 million
for contract audit work in fiscal 1993 budget.
2. Assign responsibility, for overseeing and
coordinating audits.
3. Expand staff training opportunities.
ORIGINAL
TARGET
DATE
09/91
08/93
07/93
CURRENT
TARGET
DATE
N/A
N/A
N/A
ACTUAL
COMPETITION
DATE
09/91
08/93
08/93
Enclosure C - Page 41
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ] New
[X] Material Weakness
[X] Corrected
[ ] Non-confonnance
[ ] Carryover
TITLE: Lack of Effectiveness in Chemical Testing Program
DESCRIPTION:
Two GAO reports defined specific shortcomings of the chemical testing program: 1) lack of test data and
few Toxic Substance Control Act (TSCA) Section 4 test rules; 2) lack of criteria to determine when risks
trigger regulatory or testing actions; 3) no information system to track the status of chemicals being tested;
and 4) need to make test results more readily available to the public.
RESPONSIBLE MANAGER:
Joseph S. Carra, Deputy Director, Office of Pollution Prevention and Toxics
Office of Prevention, Pesticides and Toxic Substances (OPPTS)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[]SF
[ ] LUST
[ ] B&F
NIG
[]CG
[ ] R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report
Current Correction Date:
1990
1992
1993
1993
Explanation for Change in Date: Not Applicable
Enclosure C - Page 42
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
OPPT implemented two fundamental program changes: 1) established a clear agenda of specific testing
needs, not just data gaps, and aggressively pursued testing actions on those needs; and 2) promulgated
regulations for testing by chemical groups to expedite the process.
RESULTS INDICATORS:
Results of bimonthly internal reviews validated that the design, implementation and utilization of a variety
of regulatory and voluntary tools have produced a more effective and expedited process to identify and
communicate testing needs and develop test data.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Publish first Master Testing List (MTL).
2. Develop process for updating the MTL.
3. Release revised MTL.
4. Develop process for producing test rules and
consent orders integrating the chemical testing
program with the existing chemical program.
5. Develop a new master tracking system.
6. Improve coordination and productivity within
the chemical testing program.
7. Enhance Toxic Substance Control Act
Tracking System entries.
8. Complete validation of corrective actions.
ORIGINAL
TARGET
DATE
08/91
08/91
11/92
04/92
08/92
10/92
10/92
09/93
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
ACTUAL
COMPLETION
DATE
12/90
06/92
12/92
04/92
08/92
10/92
10/92
06/93
Enclosure C Page 43
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
] OMB High Risk Area
JNew
[X] Material Weakness
[X] Corrected
[ ] Non-conformance
[ ] Carryover
TITLE; Contract Lab Program
DESCRIPTION:
EPA's Contract Laboratory Program (CLP) provides state-of-the-art chemical analytical services with data
of known and documented quality that is the basis for cleanup and enforcement decisions in the
Superfund program. In March 1991, an Agency-wide Task Force reviewed the CLP and found insufficient
management controls to safeguard data quality and resources from fraud, waste, and misuse. The Task
Force recommended corrective actions to reduce program costs, strengthen program organization and
management, and develop and certify good laboratory practices.
RESPONSIBLE MANAGER:
Henry L. Longest, Director, Office of Emergency and Remedial Response
Office of Solid Waste and Emergency Response (OSWER)
APPROPRIATIONS/ACCOUNTS;
[]PRO
[]AC&C
[X]SF
[ ] LUST
]B&F
[]CG
[ ]R&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1991
1994
1994
1993
Explanation for Change in Date: Not Applicable
Enclosure C - Page 44
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
OSWER completed all corrective actions and improved management controls to reduce program costs,
strengthen organization and management, and certify laboratory procedures and data quality. OSWER
will continue validation efforts in FY94 by issuing data-gathering surveys and data acceptance forms to
the Regions and labs to determine the extent that remedies have corrected weaknesses.
RESULTS INDICATORS:
OIG follow-up reviews determined that management controls are in place to ensure continuing good
laboratory practices for assuring data quality. Use of data acceptance forms safeguards laboratories from
paying for inaccurate data. Use of Contract Compliance Screening software resulted in improved
adherence to contract requirements by labs and more useful and timely analytical data.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Ensure top management support for
workgroup.
2. Evaluate usefulness of unannounced/surprise
audits.
3. Consider usefulness of GOCO's to provide
analytical services.
4. Study potential conflict of interest services
issues in delivery of analytical services contract.
5. Implement non-CLP tracking system for fund-
lead activities.
6. Laboratory self-screening for contract
compliance.
7. Improved audit follow-up procedures to
ensure that detected differences are promptly
corrected.
8. Expand the use of performance evaluation
materials and consider using blind samples.
ORIGINAL
TARGET
DATE
12/92
12/92
10/92
10/92
02/93
12/93
06/93
06/94
CURRENT
TARGET
DATE
08/93
07/93
12/92
12/92
02/93
12/93
09/93
09/93
ACTUAL
COMPLETION
DATE
09/93
09/93
11/92
11/92
02/93
09/93
09/93
09/93
Enclosure C - Page 45
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ]New
[X] Material Weakness
[X] Corrected
[ ] Non-confonnance
[ ] Carryover
TITLE: Pesticides Disposal
DESCRIPTION:
The Disposal Program was declared a material weakness in 1990 as a result of a September 1990
Inspector General (IG) review that identified elements of risk as lack of: 1) accurate knowledge of
dinoseb stocks and storage conditions; 2) satisfactory actions to ensure emergency planners were informed
of stocks in their area; and 3) a strategic plan for future actions on suspended and cancelled pesticides.
RESPONSIBLE MANAGER:
Douglas D. Campt, Director, Office of Pesticide Programs
Office of Prevention, Pesticides and Toxic Substances (OPPTS)
APPROPRIATIONS/ACCOUNTS:
[]PRO
[X] AC&C
[]SF
[ ] LUST
[]B&F
[]CG
[ JR&D
[ ] Oil Spill
[ ] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1990
1992
1993
1993
Explanation for Change in Date: Not Applicable
Enclosure C - Page 46
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA incinerated all dinoseb stocks and emptied all warehouses identified by the IG. EPA incinerated
one hundred percent of ethyl-dibromide (EDB) and fifty percent of T-silvex stocks. The Agency published
proposed regulations for registrants responsible for recall and disposal of future suspended and cancelled
pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act Amendments of 1988.
RESULTS INDICATORS:
A March 1993 IG follow-up review indicated significant progress by the pesticides program to reconcile
Regional and state indemnification and disposal records. EPA disposed of all dinoseb and EDB stocks.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Notified dinoseb holders of responsibilities and
EPCR notification responsibilities.
2. Completed 1990 milestones.
3. Increased inspection efforts to ensure safe
storage stocks.
4. Red Border - procedural regulations for
suspended and canceled pesticides.
5. Regulations sent to OMB.
6. Pesticide Container Report.
7. Completed disposal of 100% of remaining EDB
stocks (06/89), 50% of remaining T/Silvex stocks
(02/92), and 100% of dinoseb stocks (12/92).
8. Container regulations completed Red Border
review.
9. Developed options papers for pesticide
management regulations.
10. Validate corrective actions.
ORIGINAL
TARGET
DATE
N/A
N/A
N/A
09/91
uncertain
06/92
03/92
10/92
11/92
09/93
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10/92
11/92
09/93
ACTUAL
COMPLETION
DATE
03/89
04/90
05/90
09/91
01/92
05/92
12/92
10/92
11/92
09/93
Enclosure C - Page 47
-------
Enclosure D - Schedule of Corrective Actions
Material Non-Conformances
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL NON-CONFORMANCES SUMMARY
i, •.
/ '*'•• J
Correction
. DM!
Correction
Date
Page
1. Regional/General Ledger Accounts Receivables
1989
1994
1994
D-2
2. Property Accounting Process
1983
1993
N/A
D-4
3. Accounting System Interfaces
1985
1993
1995
D-6
^4;V,«V^ <£<**>
Year
Reported
Correction
Date
Current
Correction
Date
1. General Ledger Account Adjustments
1989
1993
1993
D-8
2. Reconciliation of Treasury Reports and IFMS
1989
1993
1993
D-10
Enclosure D - Page 1
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[ ] Material Weakness
[ ] Corrected
[X] Non-conformance
[X] Carryover
TITLE: Regional/General Ledger Accounts Receivables
NON-CONFORMANCE TYPE AND DESCRIPTION: Core Financial System
Internal and OIG reviews found several potential unrecorded accounts receivable in the Regions resulting
from program officials not promptly notify the servicing finance office of the creation and disposition of
receivables. Inadequate system capabilities and user manuals contributed to the problem. Additional
system-related problems with the Integrated Financial Management System (IFMS) accounts receivable
module include erroneous calculation of interest and penalties for Superfund receivables, and inability to
automatically handle installment receivables.
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1989
1990
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure D - Page 2
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA established an interdisciplinary Accounts Receivable Task Force to ensure that each Region had
instituted procedures in compliance with Headquarters guidance. In FY93, the Task Force completed
reviews of all the Regions. OIG staff has agreed to review and test the enhanced IFMS accounts
receivable module as part of its audit of EPA's FY93 financial statement required by the Chief Financial
Officers Act.
RESULTS INDICATORS:
Key results indicators include updated and accurate IFMS user documentation, enhanced accounts
receivable installment functions within IFMS, and ready availability of financial information in reporting
formats that meet user requirements.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Install enhancements to Accounts
Receivable module to handle debt servicing.
2. Third round of on-site verification reviews.
3. Implement Version 5.1e of IFMS:
- User Manuals;
- System Documentation; and
- Accounts Receivable Installment
Enhancements.
4. Complete enhancements to produce
needed reports:
- Standard Form 220.9; and
Supplemental Accounts Receivable
Reports.
5. Provide training on accounting and
managing receivables.
ORIGINAL
TARGET
DATE
12/92
06/93
02/94
06/94
08/94
CURRENT
TARGET
DATE
02/93
06/93
02/94
06/94
08/94
ACTUAL
COMPLETION
DATE
05/93
06/93
Enclosure D - Page 3
-------
1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[ ] Material Weakness
[ ] Corrected
[X] Non-conformance
[X] Carryover
TITLE: Property Accounting Process
NON-CONFORMANCE TYPE AND DESCRIPTION: Core Financial Subsidiary System
Property values are recorded in the Agency's General Ledger accounts and reconciled with data contained
in the Personal Property Accountability System (PPAS). OIG and GAO audits and reviews found
problems with reporting and reconciling data in the Integrated Financial Management System (IFMS) and
PPAS. The Agency must enhance the process for recording property to improve the accuracy of
accounting records.
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1983
1989
1993
While an exact target date
cannot be defined as described
below, EPA targets FY95 to
begin implementation.
Explanation for Change in Date: EPA's efforts are contingent upon
successful development of an enhanced fixed assets module for
Federal Financial Systems users, currently underway.
Enclosure D - Page 4
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA developed interim policies for capitalized property and procedures for manual reconciliation between
IFMS and PPAS. In FY93, EPA established a Quality Action Team (QAT) to assess the Agency's
property accounting process and recommend system improvements. OIG will review effectiveness of
corrective actions as part of its annual audit of EPA's financial statements required by the Chief Financial
Officers Act.
RESULTS INDICATORS:
EPA's key success measures are full accounting for capitalized property and increased accuracy of
property accounting records.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Revise policy and procedures for identifying
and capitalizing property and recommending
opportunities for automated interface between
IFMS and PPAS.
2. Present QAT recommendations to process
owners.
3. Develop implementation strategy for
recommendations accepted by process owners.
4. Identify additional milestones based on QAT
recommendations.
ORIGINAL
TARGET
DATE
09/93
07/93
01/94
To be
determined
CURRENT
TARGET
DATE
N/A
N/A
01/94
To be
determined
ACTUAL
COMPLETION
DATE
09/93
07/93
To be
determined
Enclosure D - Page 5
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[ ] Material Weakness
[ ] Corrected
[X] Non-conformance
[X] Carryover
TITLE: Accounting System Interfaces
NON-CONFORMANCE TYPE AND DESCRIPTION: Core Financial System
Internal reviews identified problems with capability of key Agency administrative systems to electronically
interface with the Integrated Financial Management System (IFMS), as required by OMB Financial
Management System Objectives to avoid duplication of data entry. Currently, EPA has identified only
one system, Grants Information and Control System (GICS) as requiring an interface with IFMS.
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1985
1990
1993
1995
Explanation for Change in Date: Additional opportunities to
eliminate reliance on EPA's legacy systems have delayed
completion.
Enclosure D - Page 6
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA's corrective action strategy to complete the electronic interface between IFMS and EPA's other
administrative systems includes: 1) expanding the Agency's Account Code structure; 2) reprogramming
systems that interface with IFMS; 3) converting historical accounting information to IFMS/Management
and Accounting Reporting System (MARS); and 4) implementing cost accounting capability. OIG will
validate the effectiveness of these corrective actions as part of its annual audit of EPA's financial
statements as required by the Chief Financial Officers Act.
RESULTS INDICATORS:
Results indicators include automated interface between IFMS and GICS and elimination of dependency
on the Financial Management System (FMS), the Automated Document Control Register (ADCR), and
the Resource Management Information System (RMIS).
MAJOR CORRECTIVE ACTION
MILESTONES
1. Decision on account number options.
2. Analyze disposition of historical FMS data.
3. Define modifications for IFMS and regional
GICS.
4. Eliminate ADCR.
5. Finalize project cost accounting
requirements.
6. Implement interface between IFMS and
regional GICS.
7. Move FMS/RMIS payroll reporting functions
into IFMS/MARS.
8. Replace FMS interface with IFMS interface.
9. Eliminate old systems - FMS and RMIS.
10. Implement account number changes.
ORIGINAL
TARGET
DATE
03/93
09/93
01/93
06/94
09/93
09/93
10/93
03/94
09/93
10/95
CURRENT
TARGET
DATE
10/93
10/93
03/94
09/94
09/94
10/94
06/94
10/94
09/95
10/95
ACTUAL
COMPLETION
DATE
Enclosure D - Page 7
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ JNew
[ ] Material Weakness
[X] Corrected
[X] Non-conformance
[ ] Carryover
TITLE: General Ledger Account Adjustments
NON-CONFORMANCE TYPE AND DESCRIPTION: Core Financial System
Internal reviews found instances of improper classification of accounting data which affected the accuracy
of the closing balances for certain accounts during the FY89 conversion from the Financial Management
System (FMS) to the Integrated Financial Management System (IFMS).
RESPONSIBLE MANAGER:
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[XjCG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1989
1990
1993
1993
Explanation for Change in Date: Not Applicable
Enclosure D - Page 8
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA's corrective action strategy included: 1) implementing the Management Accounting and Reporting
System (MARS); 2) completing EPA/Treasury cash reconciliation; 3) adjusting beginning account
balances; and 4) reclassifying transactions. EPA concurred with auditors' proposed adjustments and
entered them into IFMS. OIG will review these entries as part of the annual audit of EPA's financial
statement required under the Chief Financial Officers Act.
RESULTS INDICATORS:
The key success measure is correction of conversion errors that were entered into IFMS resulting in
accurate Agency account balances.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Update policies for recording transactions in
IFMS.
2. Adjust FY89 FMS to IFMS conversion
errors.
3. Adjust beginning account balances.
4. Adjust and reclassify transactions, as
appropriate.
ORIGINAL
TARGET
DATE
03/92
12/89
12/89
02/90
CURRENT
TARGET
DATE
11/92
10/93
10/93
10/93
ACTUAL
COMPLETION
DATE
11/92
10/93
10/93
10/93
Enclosure D - Page 9
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1993 INTEGRITY ACT REPORT
US. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ] New
[ ] Material Weakness
[X] Corrected
[X] Non-conformance
[ ] Carryover
TITLE: Reconciliation of Treasury Reports and Integrated Financial Management System (IFMS)
NON-CONFORMANCE TYPE AND DESCRIPTION; Core Financial System
Internal reviews found that EPA could not produce cash reconciliation reports during the initial
implementation of Integrated Financial Management System (IFMS). As a result, the Agency could not
reconcile its General Ledger with Treasury reports in a timely manner.
ACCOUNTABLE OFFICIAL (AQ):
Kathryn S. Schmoll, Comptroller, Office of the Comptroller
Office of Administration and Resources Management (OARM)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[X]SF
[X] LUST
[X] B&F
[X]IG
[X]CG
[X] R&D
[X] Oil Spill
[X] Other
PACE OF CORRECTIVE ACTION:
Fiscal Year First Identified:
Original Targeted Correction Date:
Correction Date In Last Year's Report:
Current Correction Date:
1989
1989
1993
1993
Explanation for Change in Date: Not Applicable
Enclosure D - Page 10
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1993 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
As a result of correcting the closing accounting balances for FY89 to FY92, EPA successfully reconciled
IFMS and Treasury reports during FY93. EPA concurred with the auditors' proposed adjustments and
entered them into IFMS. OIG will review these entries as part of its annual audit of EPA's financial
statement under the Chief Financial Officers Act.
RESULTS INDICATORS:
The key success measure is agreement between Treasury and Agency IFMS reports.
MAJOR CORRECTIVE ACTION
MILESTONES
1. Perform a comprehensive review of Treasury
records and the Agency's General Ledger for
09/30/92 to ensure reconciliation of balances.
ORIGINAL
TARGET
DATE
12/89
CURRENT
TARGET
DATE
10/93
ACTUAL
COMPLETION
DATE
10/93
Enclosure D - Page 11
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