&EPA United States Environmental Protecsion Agency Office of Solid Waste and Emergency Response DIRECTIVE NUMBER: 9275.2-01 TITLE: Remedial Financial Management Instructions APPROVAL DATE: September 21, L984 EFFECTIVE DATE: September 21, 1984 ORIGINATING OFFICE: OEWOPM m FINAL D DRAFT STATUS: REFERENCE (other documents): OSWER OSWER OSWER fE DIRECTIVE DIRECTIVE L ------- 0.3/19/87 United States Environmental Protection Agency Washington, D.C. 20460 EPA OSWER Directive Initiation Request 2, Originator Information Name of Contact Person MiH Coda Office ENGELBERT OERR/OPM 1. Directive Number 9275.2-01 Telephone Number 382-1441 3. Title REMEDIAL FINANCIAL MANAGEMENT INSTRUCTIONS 4. Summary of Directive (Include brief statement of purpose) , Developed in order to ensure a smooth transition in implementing the April 16, 1984, Superfund delegations. (See directives class 9260.2, CERCLA Delegations of Authority.) Provides a planning structure for Regional Administrators to identify and assign Regional financial responsibility for remedial activities. (9/84, 28 pp) 5. Keywords SUPERFUND, CERCLA, REMEDIAL PROGRAM, FINANCIAL MANAGEMENT, DELEGATIONS 6a. Does this Directive Supercede Previous Directives)?! 1 yes 3J No What directive (number, title) b. Does it Supplement Previous Directives^)? yes X No What directive (number, title) 7. Draft Level A • Signed by AA/DAA B - Signed by Office Director C - For Review & Ce This Request Meets OSWER Directives System Format 8. Signature of Lead Office Directives Coordinator C 9. Name and Title of Approving Official 1 L. THOMAS xnment In Development )ate )ate 09/21/84 OSWER OSWER OSWER DIRECTIVE DIRECTIVE ------- OSWER Directive 9275.2-1 SUPERFUND REMEDIAL PROGRAM FINANCIAL MANAGEMENT AUTHORITY, RESPONSIBILITIES AND PROCEDURES U.S. Environmental Protection Agency Office of Emergency and Remedial Response September 4, 1984 ------- OSWER Directive 9275.2-1 SUPERFUND REMEDIAL PROGRAM FINANCIAL MANAGEMENT AUTHORITY, RESPONSIBILITIES AND PROCEDURES Under the Superfund delegations approved April 16, 1984, the Regional Offices have additional authority and responsibilities for significant portions of the remedial program. This includes both programmatic and administra- "tive authority and responsibilities, described in detail in the various Superfund remedial program guidance pack- ages, and specific financial management authority, respon- sibilities and procedures described in this document. Regional financial management authority consists of three distinct, but interrelated, parts: approval, com- mitment and obligation (award). Authority to approve re- medial activities is contained in the Superfund delega- tions package. In general, Regional approval authority under the remedial program will include all direct re- sponse activities except Records of Decision (ROD). Funding authority will be contained in the Regions' allowances, which will provide funding for the following remedial program mechanisms: Remedial planning activities under REM/FIT and REM-II Cooperative Agreements (CA) Designated Interagency Agreements (IAG) U.S. Army Corps of Engineers lAGs for tech- nical assistance (RI/FS and design) U.S. Army Corps of Engineers lAGs for reme- dial design and implementation U.S. Federal Emergency Management Agency (FEMA) lAGs for permanent relocation (allo- cation transfer) Other Federal agencies as appropriate (site-specific only). -1- ------- OSWER Directive 9275.2-1 In accordance with Federal acquisition regulations, all contract obligations will be made by the Procurement and Contracts Management Division (PCMD) in Headquarters. The remedial program's Cooperative Agreement obligation authority is delegated in the Superfund delegations pack- age (delegations 14-4-A and 14-4-C); IAG award authority has been delegated elsewhere (delegation 1-11). FEMA allocation transfer lAGs must be processed through the Office of the Comptroller, Budget Division and FMD Head- quarters Financial Reports and Analysis Branch, as described in Section VI. Please note that although delegations of remedial program authority have been in effect since April 16, 1984, Regional funding authority will not be effective until the issuance of remedial program allowances begin- ning October 1, 1984. For the purposes of clarification, a glossary of acronyms used in this document is attached for reference. I. DELEGATIONS OF AUTHORITY The following highlights the delegations of financial management authority and responsibility in the remedial program, subject to the general restrictions noted below: RAs will approve and initiate remedial planning activities (14-4-A) RAs will determine necessity of and select ini- tial remedial measures (14-4-B) AASWER will determine the necessity of and select remedial action activities (14-5) RAs may enter into Superfund State Contracts (which are not procurement contracts) and award Cooperative Agreements with States to implement and perform remedial actions and planning activities (14-4-C) RAs may award lAGs (1-11) RAs may redelegate activity approval authority, e.g., RI/FS, to Regional Program Divisions RAs may redelegate award authority for CAs and lAGs to Regional Management Divisions; may also redelegate to Management Divisions authority for funds certification (commitment). -2- ------- CSWER Directive 9275.2-1 The following limitations apply to the Regional ap- proval of remedial activities: Regions must comply with directives issued by AASWER Authority subject to approved funding levels RA authority for selecting initial remedial mea- sures (IRM) may not be redelegated Regions subject to requirements of Administra- tor's Strategic Planning and Management System. II. REGIONAL OFFICE ALLOWANCES Starting October 1, 1984, each Regional Office will be issued an allowance by the Office of the Comptroller to be used to fund remedial activities. The Regions will re- quest annual remedial funding in the Superfund Comprehen- sive Accomplishments Plan (SCAP), which will be broken out by quarter. The approved SCAP will determine the amount of the annual allowance, and the quarterly allocations of that allowance. The allowance will be issued as follows: October 1 for first and second quarters March 1 for third quarter June 1 for fourth quarter. End of fiscal year adjustments may be necessary to accom- modate unforeseen events. In addition, Headquarters will maintain a contingency reserve to fund unanticipated actions. Regions must manage and control their allowances in accordance with Agency directives, e.g., Accounting Manual. Headquarters will provide assistance and over- sight as required. III. FINANCIAL MANAGEMENT RESPONSIBILITIES The following EPA organizational units have financial management responsibilities for the Superfund remedial program. These responsibilities are detailed in Exhi- bit 1. Since Regions may be organized differently and internally may assign responsibilities as best meets their needs, these descriptions are intended to serve as guide- lines to assist Regions to carry out their functions. -3- ------- OSWER Directive 9275.2-1 (1) Regions Regions will in general be responsible for ap- proving, funding, obligating and implementing the pri- mary remedial response activities. The Regional Ad- ministrator has authority to approve and fund remedial activities (except the selection of remedial actions), to obligate Cooperative Agreements, award lAGs and to enter into non-procurement Superfund State Contracts. This authority may be redelegated, in whole or in part, to Regional Division Directors. The Management Division, e.g., Administrative Services Division, Of- fice of Policy and Management, etc., will be respon- sible for the management and control of the Region's allowance and financial processes, and the Cooperative Agreement and IAG award processes. The Program Divi- sion, e.g., Waste Management Division, Office of Emer- gency and Remedial Response, etc., will initiate and direct all remedial response activities in the Region. (2) Headquarters The Office of Solid Waste and Emergency Response, as the national program manager, is generally respon- sible for maintaining program consistency, providing necessary guidance and directives and reporting on program activities and accomplishments. The Assistant Administrator for Solid Waste and Emergency Response (AASWER) is delegated the primary authority for these Headquarters functions, but may redelegate selected authority to OERR managers. AASWER will determine the necessity of and will select the appropriate remedial action (except for IRMs). The indirect-response (non-site-specific) portions of the remedial program will be funded and coordinated in OERR Headquarters. OERR will develop program specific guidance for CAs and lAGs. The Office of Administra- tion and Resources Management (OARM), through the Pro-, curement and Contracts Management Division (PCMD), will carry out its contract award and management re- sponsibilities. The Financial Management Division (FMD) of OARM will provide accounting policies and procedures, billing and collections functions, support to cost recovery, allocation transfer by SF-1151 and other financial functions. The Grants Administration Division (GAD) of OARM will provide national guidance on the processing and award of Cooperative Agreements and lAGs. The Budget Division of the Office of the Comptroller issues allowances and processes change requests for fund reallocations and transfers, and notifies FMD to effect the SF-1151 allocation transfers. -4- ------- OSWER Directive 9,275.2-1 (3) Servicing Finance Offices The field organizations that play a role in fin- ancial management of the remedial program are FMD's Servicing Finance Offices (SFO). The SFOs provide accounting services and entry into the Financial Man- agement System (FMS) for contracts (SFO-Research Tri- angle Park) and reimbursable lAGs (SFO-Cincinnati) awarded by GAD, PCMD or Regional offices; services for Superfund Cooperative Agreements will be provided by Regional Offices. FMD-Headquarters, Financial Reports and Analysis Branch, will process all SF-1151s for allocation transfer lAGs. IV. SUPERFUND ACCOUNT NUMBERS The ten-digit Superfund account number structure is essentially the same as that used throughout the Agency, with the addition of identifiers to track costs by site/ spill and activity. The Superfund account number identi- fies the year in which money was authorized; the appropri- ation, program element, allowance holder, responsibility center and activity to which the spending action will be charged; and, for site-specific actions, the site/spill identifier and site-specific activity code for which funds will be used. Site-specific charging requires the follow- ing structure for the last three fields of the account number: 8th field--site-specific activity code; 9th and 10th fields--site/spill identifier. The account number is assigned to the Procurement Request (PR) or Commitment Notice (CN) at the time a remedial activity is funded. The Regional Management Division must set up the account number in FMS. When assigning Superfund account numbers, the Manage- ment Division needs to determine if the incident is at a new or existing site/spill. This process is complicated by the fact that: The removal, remedial and enforcement programs will all be requesting account numbers They may be funding work at the same sites/spills The same site/spill may have several different names (aliases). If the account number is for an existing site/spill, the appropriate assigned identifier should be used. If it is for a new site/spill, the next sequential identifier -5- ------- OSWER Directive 9275.2-1 should be issued and recorded. For new account numbers, the Regional Management Division will set up the account number in FMS. At the same time, each Regional Management Division will provide the Financial Management Division- Headquarters, Financial Reports and Analysis Branch, with the new sites added to the identifier list to assist in their accounting control process and for special reporting requirements. For the balance of FY 1984, the OERR Funds Control Center (OERR/FCC) will assign site/spill identifiers. V. DOCUMENT CONTROL NUMBER The Document Control Number (DCN) is a unique six- digit number assigned by the Region that identifies each individual financial transaction. The DCN is assigned to the PR or CN at the time a remedial activity is funded. One DCN should be used for each commitment at a site. The DCN is entered on the PR or CN prepared and signed in the Region. The corresponding obligating document, e.g., Cooperative Agreement, must have the same DCN and account- ing data as the CN. Allocation transfer IAGs, requiring no CNs, do not require DCNs, only the appropriation number (68/20X8145) and the IAG number. VI. FINANCIAL DOCUMENT PROCESSING There are two basic types of financial documents needed to undertake a remedial activity. FEMA allocation transfer IAGs are processed using different documents, as described at the end of this section. Since each Region may establish its own responsibilities and redelegations under Superfund, the following description is intended to guide, not mandate, the Region's internal processing of documents. The first type of document is used to commit funds for a remedial activity. There are two types of commitment documents: the Procurement Request (EPA Form 1900-8) and the Commitment Notice (EPA Form 2550-9). The PR is used to commit funds for contracts; the CN to commit funds for Cooperative Agreements (CAs) and reimbursable Interagency Agreements (IAGs); CNs are not used for allocation trans- fer IAGs. The Program Division will prepare the PR or CN and obtain all necessary program approvals and signatures, and will send the document to the Management Division for addition of accounting information (account number, appro- priation and DCN). The RA as Allowance Holder, or designee, will certify the availability of funds and set aside the required funds on the allowance's Document Con- trol Register (DCR). For allocation transfer IAGs, no formal commitment of funds takes place; however, based on -6- ------- OSWER Directive 9275.2-1 a memo stating the site and amount requested, the Manage- ment Division shduld set aside sufficient funds in the OCR to assure proper fund control. The approved PR or CN is entered as a commitment into FMS, directly by the Region for Cooperative Agreements and by the SFO/RTP for con- tracts or SFO/ Cincinnati for reimbursable lAGs. Disposi- tion of the documents after commitment shall be as follows! PRs for REM portion of REM/FIT and REM-II -- re- tain copy of PR in Regional contract file, send original PR with Work Assignment to PCMD in Head- quarters, with an information copy to the REM/FIT Project Officer in HSCD CNs for Cooperative Agreements and lAGs — send with remainder of funding package (CA applica- tion, Assistance Funding Order and Special Condi- tions for Cooperative Agreements; transmittal memo and EPA Form 1610-1 for reimbursable lAGs) to Regional Grants office. For allocation trans- fer lAGs, the funding memo should be sent to the Regional Grants Office. See Exhibit 2 for an outline of this process. The second type of document is the obligating docu- ment. There are three documents of this type that are used in the remedial program. They are: REM/FIT and REM-II contract modifications, which are obligated by PCMD in Headquarters Cooperative Agreement, which is obligated by the Regional Administrator IAG, which is signed by the Regional Administra- tor, but not obligated until signed by the other Federal agency. Note that Superfund State Contracts, which outline' state and EPA responsibilities and provide required state assur- ances under CERCLA, are not obligating documents. They are negotiated and signed in the Regions. Obligating documents must be processed in accordance with guidance issued by PCMD, GAD and FMD. Regions will make obligations/awards as noted above. For CAs, Regions are responsible for entering obligations into their Docu- ment Control Register and into FMS. For reimbursable lAGs, original executed obligating documents must be sent to SFO-Cincinnati for entry into FMS. Allocation transfer -7- ------- OSWER Directive 9275.2-1 IAGs with PEMA must be coordinated with the Office of the Comptroller. For contracts awarded by PCMD, they will be responsible for making distribution to the Region and to SFO-RTP. See Exhibit 3 for an outline of these processes, Deobligations of funds are handled similarly to obli- gations of funds. The same commitment and obligation doc- uments and procedures are used, except that the dollar amount indicated is a reduction rather than an addition. The availability of funds after deobligation has taken place depends on when the funds had initially been obli- gated. Current fiscal year funds are available for reuse within the allowance as soon as the deobligation is effec- tive. Prior fiscal year funds that are deobligated' revert back to the Trust Fund. In order to reuse the funds, 1) The allowance holder must request a carryover of the funds to their allowance 2) OERR will evaluate the request based on the approved SCAP and national priorities, and will recommend distribution of funds 3) The Office of the comptroller must approve the request 4) The request must be approved and a reapportion- ment obtained from the Office of Management and Budget. For FEMA allocation transfer IAGs, funds are trans- ferred to FEMA via SF-1151, Non-expenditure Transfer Au- thorization. This transfer is accomplished after review and approval by the Office of Comptroller, Budget Divi- sion, which will process a change request and notify FMD-Headquarters, Financial Reports and Analysis Branch, to effect the requested transfer. Regions must obtain from FEMA a quarterly outlay plan with eacn signed IAG, and must forward one signed copy of the IAG, a signed change request and outlay plan to both: Office of the Comptroller, Budget Division, at- tention: Liz Milstead Office of the Comptroller, FMD, Financial Reports and Analysis Branch, attention: Ivery Jacobs VII. CONTRACTOR INVOICES REM/FIT and REM II contractors will provide copies of their monthly invoice or voucher for payment to the Re- gions for review. Regional Site Project Officers (RSPO) -8- ------- OSWER Directive 9275.2-1 have 5 days to review the invoice. If the invoice accur- ately reflects contractor activities, no further action is required. If the RSPO identifies a problem, it should be reported to the appropriate Headquarters Project Officer for resolution. At the end of the five day review period, the project Officer will resolve any problems, certify that the voucher is consistent with the services provided, and forward the certification to the SFO/RTP. Additional guidelines and procedures on processing contractor in- voices are included in the "REM/FIT Users Guide" and a memorandum to the Regions dated February 13, 1984 (redis- tributed April 23, 1984). VIII. REPORTING REQUIREMENTS The OERR Funds Control Center (OERR/FCC) is responsi- ble for preparing periodic and ad hoc financial status reports on the remedial program. For these reports to be both timely and comprehensive, FCC needs to get from the Regions information on extramural obligations. This in- formation will be obtained by running an FMS report on the fifth working day of each month for the Regions' obliga- tions. Since not all obligations may be in FMS at that time, a Region must submit a supplemental report including those extramural obligations that have not been entered into FMS. To be included in the previous month's status report, this Regional report must be received by FCC no later than the sixth working day of the month and must contain, for each obligation or commitment in FMS: Document Control Number Account Number Site/spill name Amount of open commitment Amount of obligation Date of obligation Specific activity funded. Reports should be sent to: Becky Kennedy OERR Funds Control Center WH-548D At the end of the fiscal year, reports will be re- quired on a more frequent basis to provide senior manage- ment with a more timely record of Superfund expenditures for potential reallocation of funds. FCC will not verify the Regional information, but will compile various reports using the data in FMS supplemented by that submitted by the Regions. Additional guidance on reporting requirements will follow. -9- ------- OSWER Directive 2-1 Exhibit 1 Financial Management Responsibilities (Remedial Program) REGION Regional Administrator Authority to initiate remedial planning activities and select IRMs Authority to award Authority to enter (non-procurement) May redelegate selected authorities Approves Action Memos (optional) Cooperative Agreements and lAGs into Superfund State contracts to Division Directors I >—• o Management Division Assigns account numbers and DCNs to all commitment and Regional obligation documents Issues site/spill identifiers for Region effective October 1, 1984 Processes all commitment documents for contracts and lAGs; sends copy of PR or CN to SFO/RTP or SFO/Cincinnati for entry into FMS Enters Cooperative Agreement commitments, obligations and drawdowns into FMS Processes Cooperative Agreements and designated lAGs, including assigning CA and IAG identification numbers; may award agreements if authority redelegated Maintains files of all financial documents Prepares required financial reports Sets up account numbers (new obligational authority only) in FMS Controls allowance, maintains DCR and- reconciles transactions Provides fiscal oversight of Cooperative Agreements and prepares appropriate responses to IG audits ------- OSWEK Directive 9275.2-1 Exhibit 1 (cont'd) Financial Management Responsibilities (Remedial Program) Program Division Initiates remedial actions; prepares PRs/CNs and work statements Reviews invoices and reports problems to HQ PO Initiates and approves TDDs under FIT contract Prepares Action Memos and forwards to RA (optional) Drafts SCAPs Works with states to develop Superfund State Contracts and Cooperative Agreements HEADQUARTERS AASWER Formally issues remedial guidance and directives Selects appropriate remedial actions Approves SCAPs May redelegate selected authorities to OERR OERR/FCC Prepares various Superfund financial reports Prepares Superfund-specific guidance and directives Implements and oversees compliance with Agency financial management policies and procedures Processes and commits funds for FIT and REM and REM-II management and award fee ------- OSWER Directive 9275.2-1 Exhibit 1 (cont'd) Financial Management Responsibilities (Remedial Program) OERR/HSCD Provides guidance and coordination for REM/FIT and REM II contracts Coordinates REM/FIT and REM II award fee process Initiates FIT funding and rebid; coordinates and manages REM/FIT and REM II performance evaluation; shifts PIT resources as necessary; certifies REM/FIT and REM II vouchers Coordinates RAP approvals and amendments Drafts remedial guidance and directives and coordinates Agency review Develops program specific guidance for CAs and lAGs ro PCMD Awards, administers and modifies REM/FIT and REM-II contracts Awards all contract modifications to incorporate REM work assignments Maintains official contract files FMD Promulgates Agency-wide accounting policies and procedures Maintains and implements the official agency-wide accounting systems Assists in assembling financial cost recovery documents and FMS print-outs; bills and monitors cost recoveries, penalties and fines for Superfund consent/settlement agreements and administrative orders Bills and monitors payments for state cost shares under Superfund State Contracts Sets up carryover account numbers in FMS Transfers funds for FEMA lAGs by SF-1151 GAD Transfers official CA and IAG files to Regions Issues guidance for the processing and award of CAs and lAGs ------- OSWEK Directive 9275.2-1 Exhibit 1 (cont'd) Financial Management Responsibilities (Remedial Program) Budget Division Issues allowances Processes change requests tor budget reallocations and transfer lAGs Reviews transfer requests and notifies FMD to process SF-1151 OJ SFQ'S SFO/RTP Enters commitments for contracts into FMS Enters obligations and payment information into FMS for REM/FIT and REM-II contracts Processes invoices for REM/FIT and REM-II contracts Maintains official contract financial files SFO/Las Vegas Transfers official files and responsibilities for CAs to Regions SFO/Cincinnati Processes invoices for lAGs; enters commitments, obligations and payments for reimbursable lAGs into FMS Maintains official IAG (reimbursable) financial files ------- OSWER Directive 9275.2-1 Exhibit 2 Financial Document Processing - Remedial Commitment Documents 1. Regional Program Division prepares commitment document (PR or CN) or funding memo (allocation transfer lAGs). 2. Commitment document and remainder of funding package undergo Regional legal and administrative review. 3. RA approves all remedial planning and implementation activities; for remedial action activities, a copy of the signed Record of Decision must be included in the funding package to document compliance with delegations. 4. Regional Management Division adds accounting informa- tion (account number, appropriation and DCN) and cer- tifies availability of funds; enters commitment in OCR and either directly into FMS for Cooperative Agree- ments or sends document to SFO/RTP for contracts or SFO/Cincinnati for reimbursable lAGs for entry of com- mitment into FMS. For allocation transfer lAGs, only appropriation number and IAG number are required; sufficient funds should be set aside in the OCR. 5. Distribution of commitment document/funding package depends on type of funding mechanism: REM/FIT or REM-II contracts -- send to PCMD- Headquarters, with copy to OERR/HSCD Project Officer Cooperative Agreement or IAG -- send to Regional Grants office. -14- ------- OSWER Directive 9275.2-1 Exhibit 3 Financial Document Processing - Remedial Obligating Documents 1. Award Official depends on type of funding mechanism: a. REM/FIT and REM-II contract amendments -- PCMD- Headquarters b. Cooperative Agreements -- RA c. lAGs — RA. 2. For item "a" above, distribution after signature is: HSCD/RAB — for contract management purposes PCMD -- for filing in official file SFO-RTP — for entry into FMS and filing in of- ficial file Regional Management Division — for entry into OCR and filing in Regional financial file. 3. For item "b" above, distribution after signature is: Regional Management Division -- for entry into OCR and FMS and filing in official file. 4. For item "c" above, distribution after signature is to the recipient Federal agency. After signature by the Federal agency, distribution is: Regional Management Division -- for entry into OCR and filing in official file SFO/Cincinnati -- for entry into FMS and filing in official file. FEMA allocation transfer lAGs with change requests and quarterly outlay plans must be forwarded to the Office of the Comptroller: Budget Division, for processing of change requests Financial Management Division, Financial Reports and Analysis Branch, to transfer funds by SF-1151 to FEMA. -15- ------- OSWER Directive 9275.2-1 ATTACHMENT Acronyms Used in Remedial Financial Management procedures AASWER - Assistant Administrator for Solid Waste and Emergency Response ADCR - Automated Document Control Register AFO - Assistance Funding Order CERCLA - Comprehensive Environmental Response, Compen- sation, and Liability Act of 1980 (Superfund) CA - Cooperative Agreement CN - Commitment Notice DCN - Document Control Number DCR - Document Control Register FEMA - U.S. Federal Emergency Management Agency FMD - Financial Management Division (Headquarters) FMS - Financial Management System GAD - Grants Administration Division (Headquarters) HSCD - Hazardous Site Control Division (Headquarters) HSCD/RAB - Remedial Action Branch of HSCD HSCD/SRCB - State and Regional Coordination Branch of HSCD IAG - Interagency Agreement OARM - Office of Administration and Resources Man- agement (Headquarters) OERR - Office of Emergency and Remedial Response (Headquarters) OERR/FCC - Funds Control Center of the Office of Emer- gency and Remedial Response (Headquarters) -16- ------- OSWER Directive 9275.2-1 PCMD - Procurement and Contracts Management Division PR - Procurement Request RA - Regional Administrator REM/FIT - Remedial/Field Investigation Team Contract REM II - Remedial Contract RI/FS - Remedial Investigation/Feasibility Study RTP - Research Triangle Park SCAP - Superfund Comprehensive Accomplishments Plan SFO - Servicing Finance Office TDD - Technical Directive Document -17- ------- OSWER Directive 9275.2-1 COMMENTS MATRIX REMEDIAL FINANCIAL MANAGEMENT PROCEDURES COMMENTOR C. Morgan Kinghorn Comptroller SUBJECT Title of Document Financial Management Authority, Responsibi- lit ies ... (p. 1) Financial Management Authority, Responsibil ities... (p. 2) Financial Management Responsibilities... (p. 4 sec. 2) COMMENT Retitle document to "Fund Control" or "Resources Control Instructions." Add sentence as follows: "Designated Interagency Agreements site specific for U.S. COE, Coast Guard, HHS should be a master agreement and task orders issued by each Region so requirements are consistent ..." Modify present language to read: "FMD Headquarters Financial and Reports Analysis Branch and Office of the Comptroller..." Modify existing language to read "...support to cost recovery and allocation transfer by SF-1151 and other financial functions." Modify existing language to: ..."Office of the Comptroller issues allowances, processes change requests for fund reallocations, and notifies FMD to effect the SF-1151 transfer . " RESPONSE Comment noted. Title not changed to be consistent with removal procedures. Comment noted. This issue is currently being investigated. Comment accepted and new language has been included in the text. Comment accepted. New sentence reflects suggested change. Comment accepted. Text has been changed to reflect this new language. -1- ------- OSWER Directive 9275.2-1 COMMENTOR . Morgan Kinghorn rontinued) SUBJECT Financial Management Responsibilities ... (p. 5 sec. 3) Document Control NO (p. 6) Financial Document Processing (p. 8) Financial Management Responsibilities (Exhibit 1) Financial Management Hesp. FMD (Exhibit II Financial Management Resp. FMD (Exhibit 1) 'COMMENT Add: "FMD-Headquarters, Financial Reports and Analysis Branch will process all IAG's transfer allocations by SF-1151." Add:..."only appropriation number 68/20X8145 and the IAG number." Insert the following language: "This transfer is processed after review and approval by the OC Budget Division, which will process a change request and notify the Office of the Comptroller ... to effect the requested transfer." Add: "Audits Agreements as Cooperative necessary." Insert as 2nd bullet: "Main- tains and implements the offi- cial Agency-wide accounting systems." RESPONSE Comment accepted. Recommended language will be added. Comment accepted and changes made to clarify this point. Comment accepted. Sug- gested wording will be substituted. Comment not accepted, Inspector General audits Cooperative Agreements. Comment accepted. Additional comment included. Add to 2nd bullet: "...bills Comment accepted. and monitors cost recoveries, Additional respon- penalties and fines for Super- sibilities included. fund, consent/settlement agreements & Admin. Orders." -2; ------- OSWER Directive 9275.2-1 COMMENTOR C. Morgan Kinghorn (continued) Harvey Pippen, Jr Director, Grants Admin. Division Financial Resp. FMD SUBJECT Management (Exhibit 1) Financial Management Resp. Budget Division (Exhibit 1) Financial Document Processing, Remedial Commitment Documents (Exhibit 2) Financial Document Pro- cessing Remedial Obligating Documents (Exhibit 3) Financial Management Responsibility (p. 4 sec. 2) Financial Document Processing (p. 8) Financial Document Processing (p. 8) COMMENT Add bullet: "Transfer by SF-1151 funds for FEMA lAG's (both remedial and removal)." Add bullet: requests and process SF-1151" "Reviews notifies transfer FMD to RESPONSE Comment accepted. Since this is a document pertaining to remedial activities only, the parenthesis will be omitted. , Comment accepted and item added. Comment accepted and language modified. Comment accepted and suggested changes incorporated into text Revise existing language to read: "For transfer lAGs, appropriation number and IAG number only is required". Modify existing language as follows: "...Comp- troller - Budget Division for processing of change request and review and approval of the transfer, and to FMD Head- quarters, Financial Reports and Analysis Branch to transfer funds by SF-1151 to FEMA." GAD responsibility for issuing Comment accepted and IAG guidance and tracking section has been lAGs should be clearly noted, clarified. Term "transfer lAGs" should - be clarified; use the term "allocation transfer" where appropriate. Clearly state that Regional offices must secure separate IAG number for each transaction. Comment accepted and changes will be made to clarify this point Comment noted. Regional Offices must secure separate IAG number for each IAG. -3- ------- OSWER Directive 9275.2-1 COMMENTOR . L. Molino, Chief rocurement Branch A ruce Engelbert, hief, Program anagement Branch im Fields, Deputy irector HSCD SUBJECT Contractor Invoices, (p. 9) Financial Document Processing (p. 7) Reporting Requirements (p. 9) Financial Management Authority, Responsi- bilities. ..(p. 1) Financial Management Authority, Responsi- bilities. ..(p. 1) Financial Management Authority Hesponsi- bi1it ies...(p. 1) COMMENT Procedures in REM/FIT manual no longer appropriate. Replace "amendments" with "modifications." This section should be the same as Reporting Require- ments in the Removal Procedures. No discussions of the differences involved in deobligating funds in the current fiscal year accom- panied with funding previous fiscal years. A procedural change would result in delays/loss of cer tain planned FY '84 4th quar- ter obligations; interim Procedure Needs Modification, Modify 1st sentence by adding:..."delegations approv- ed April 16, 1984, ...program- matic and administrative authority and responsibilit- ies ... remedial program guid- ance packages and specific financial management authority, responsibilities and procedures"..." RESPONSE Comment accepted. Revised procedures will be included. Comment accepted and change made. Comment accepted and change made. Comment accepted. Section on deob- ligation for current and previous fiscal years added. Comment accepted. Due to your comments and the timing of the procedure, Interim Procedures have been deleted. Comment accepted. Appropriate changes made. ------- OSWER Directive 9275.2-1 COMMENTOR Tim Fields, (continued) HSCD SUBJECT Regional Office Allowances (p. 3) Financial Management Responsibilities (Head- quarters, p. 4) Super fund Acc't. Numbers (p. 5) Financial Document Processing (p. 8) Contractor Invoices (p. 9) Reporting Requirements (p. 9) COMMENT RESPONSE Program Division, (Exhibit 1, p. 11) Delete references to "Remedial Comment accepted. Accomp. Plan (RAP); replace Replaced with Super- with SCAP described in fund Comprehensive "Superfund Implementation Accomp. Plan (SCAP) Directives." GAD no longer provides guid- ance function - OERR does this. Modify the sentence to read: "The Headquarters Management Division". Modify reference as follows "FEMA Allocation Transfer". See suggested language attached. Reporting requirements in this procedure below current practice. Revise to read: "Reviews invoices and reports problems to the HQ PO." Comment noted. Role of OERR process has been clarified. Comment not accepted. Regional Management Division establishes acc't numbers. Clarification made. Comment accepted. Terminology corrected. Comment accepted. Revised procedures have been included. Comment noted. OPPM currently investigating options which will improve quality and timeliness of data from the regions. Comment accepted. Change has been made to revise invoice procedures. -5- ------- OSWER Directive 9275.2-1 COMMENTOR Tim Fields, (continued) HSCD SUBJECT OERR/HSCD (Exhibit 1, p. 12) PCMD (Exhibit 1, p. 12) Financial Document Processing (Exhibit 2, No. 5) Financial Document Processing (Exhibit 2, No. 5) Financial Document Processing (Exhibit 3, No. 2 ) Attachment (p. 16) Attachment (p. 16) COMMENT Clarify sentence to read: "Provides guidance and coor- dination for REM/F1T and REM II contracts". RESPONSE Comment accepted. REM II has been added to all references in REM/FIT contracts. What is the difference between Comment accepted. "awards, administers and modi- Language changed to fies REM/FIT and REM II con- read: "REM/FIT and tracts" and awards all con- REM II contracts to tract amendments". incorporate all work assignments". Add: "send to PCMD-Headquar- Comment accepted. ters, with copy to OERR Changes made. and HSCD." Add: "send to Grants office, OERR/"HSCD". Regional with copy to Modify sentence as follows: "HSCD/RAB - for contract man- ayement purposes". Refer to this sheet at the beginning of text. Add: "HSCD/SRCB-State and Regional Coordination Branch of HSCD." Comment noted and needs to be clarified. Com- ment is not consistent with OERR report and policy. Comment accepted. As national project offi- cer, HSCD needs to oversee contract management activities. Comment accepted. Reference to the attachment will be made at the beginning of document. Comment accepted. Addition made. -6- ------- OSWLR Directive 9275.2-1 COMMENTOR Region I Region II Region III Diane White Region IV Robert Springer, Director, Planning and Management Branch Region V SUBJECT No comments re.ceived. No comments received. No comments received. No comments received. Financial Management Responsibilities (p. 3) COMMENT RESPONSE Region VI Susan Gordon, Assistant Regional Administrator for Policy & Management Region VII John Hardaway Region VIII Financial Management Procedures (p. 6) No comments received, Certification of Invoices (p. 9) Financial Management Resp. (p. 3) Document is too vague; section on payments is omitted. Instruction on financial man- agement procedures should come from OARM or be jointly issued with them. Additional explanation is needed in the review and certification of invoices, Instructions do not under- score the need to prepare accurate budgets for remedial actions. Financial procedures after Oct. 1, 1984, are covered in general, but not in speci- fics. Details need to be spelled out. Comment noted. Agree that document is vague. Document is intended to familia- rize Region with funding mechanisms. Comment noted. OARM was consulted and concurred when preparing these procedures. Comment accepted. Regional role clarified. Comment noted. That is the purpose of SCAP, Comment noted. As mentioned previously, document is intended to familiarize Regions with funding mechanisms. -7- ------- OSWLR Directive 9275.2-1 COMMENTOR aula iii'sson, nforcement case 'evelopment Officer, .egion IX iora McGee, )irector, Management Division (egion X SUBJECT No comments received. Supecfund Accounting Numbers (p. 5) Document Control (p. 6) COMMENT RESPONSE Develop criteria which iden- tify when enforcement, reme- dial or removal should be set up into the account numbers. Provide regions with mailing addresses to which documenta- tion should be sent and indi- cate whether it has been acted upon. Comment noted. Onqe a site ID is established, the same I.D. number will be used for that site by all programs. Comment noted. Addres- sees of contractors are in Superfund Directory. -8- ------- |