&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-
------- |