&EPA
United States
Environmental Protection
Agency
Administration And
Resources Management
(3304)
EPA 205-R-94-005
December 1994
1994 Integrity Act Report To
The President And Congress
Federal Managers'
Financial Integrity Act (PL. 97-255)
October 1, 1993—September 30, 1994
f
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Cover photo by:
Scott Mullin Photography
Ridgefield, Connecticut
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC 3 0 1994
THEADMMSTRATOR
Hie President
The White House
Washington, D.C. 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. In my judgment,
EPA has achieved the intent of the Federal Managers' Financial Integrity Act. EPA's
Inspector General concurs that the Agency has implemented the Act in a reasonable and
prudent manner this year.
EPA's newly reengineered process under the Integrity Act reflects my strong belief
in managers' personal accountability for effectively planning, budgeting, and managing
their programs to achieve results within the boundaries of law. Consistent with the call
of the Administration's National Performance Review, EPA studied, and then created its
new approach to management integrity, which "works better and costs less." Our
tangible savings to date include an annual reduction of over 50,000 pages of original
documents, recapturing over 60,000 valuable work hours in the process. EPA's approach
boldly links integrity with new management goals of the Government Performance and
Results Act (GPRA), the recently enacted Government Management Reform Act, and the
Chief Financial Officers Act. Together, these statutes establish a sound basis for a new
framework of management accountability, which we are working to develop at EPA, and
which may be a model that could be applied across the Federal government.
In conducting our self-assessment under EPA's new integrity approach this year,
each of my Assistant and Regional Administrators exercised personal judgment in
reviewing their programs and operations, and in identifying, correcting, and reporting
significant management weaknesses. In September, my Senior Leadership Council
(SLC) met with, and thoroughly reviewed new material weaknesses proposed by the
Office of Management and Budget (OMB), and the General Accounting Office, as well
as EPA's Inspector General. The SLC convened again in December to consider the
positions of our principal oversight colleagues, and the results of EPA's Assistant and
Regional Administrators' annual self-assessments. Based on their concerted
deliberations, the SLC then developed its own independent recommendations for my
final decision.
Printed on Recycled Paper
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As a result of the Agency's comprehensive annual assessment and my personal
decisions, I am pleased to report that EPA has corrected four material weaknesses: 1)
Accelerating Remedial Cleanup; 2) Alternative Remedial Contract Strategy (ARCS)
Contracts Management; 3) Pesticides Antimicrobial Program; and 4) Federal Facilities.
OMB is deleting the Superfund area from its High Risk List, based on a determination
that timely cleanup of National Priorities List sites has been impeded by structural
problems that the Administration has proposed to correct through reauthorization
legislation. OMB will continue-to track management of ARCS contracts under EPA's
separate Contract Management High Risk Area.
While I am not identifying any new material weaknesses for your attention, my
senior managers and I are addressing several key program issues raised during our self-
assessment These include EPA's use of science in making policy and regulatory
decisions* and the Agency's development and implementation of sound and useful
environmental program performance measures under GPRA. The Agency is also
working to prioritize, audit, and close out the most vulnerable of the remaining $20.7
billion in grants under EPA's Wastewater Treatment Construction Grants program.
With this early and ongoing management attention, we expect to prevent these areas
from developing into serious management control problems.
Finally, Agency managers are taking strong action to correct EPA's fourteen
carryover material weaknesses, including the two that remain on OMB's High Risk List
1) Agency Contract Management; and 2) Agency Financial System. EPA is on schedule to
correct its three remaining material financial system non-conformances. These areas are
fully described in the enclosures.
I intend to work closer/ with the new Congress and our state partners to develop
effective environmental legislation, implement EPA's national programs, and enhance
our mutual ability to protect human health and the environment
Sincerely,
Carol M. Browner
Enclosures
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
FISCAL YEAR 1994
INTEGRITY ACT REPORT
TO THE
PRESIDENT AND CONGRESS
Federal Managers' Financial Integrity Act
(P.L. 97-255)
October 1, 1993 - September 30, 1994
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1994 INTEGRITY ACT REPORT
TABLE OF CONTENTS
CONTENTS
PAGE
Transmittal Letter to the President
Enclosure A Statistical Summary of Performance
Al
Enclosure B Progress Report on High Risk Areas
Bl-3
Enclosure C Schedule of Corrective Actions for
Material Weaknesses
Ranked Material Weakness Summary
14 Carryover Material Weaknesses
4 Corrected Material Weaknesses
Cl-37
Enclosure D Schedule of Corrective Actions for
Material Non-Conformances
Material Non-conformance Summary
3 Carryover Non-conformances
D 1-7
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Enclosure A - Statistical Summary of Performance
-------
1994 INTEGRITY ACT REPORT
U.S ENVIRONMENTAL PROTECTION AGENCY
STATISTICAL SUMMARY OF PERFORMANCE
SECTION 2. INTERNAL CONTROL
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1992 Report
1993 Report
1994 Report
Total
Number of Material Weaknesses
Number reported
for the first
time in:
34
8
0
0
42
For that year,
number that have
been corrected:
28
0
0
0
28
For that year,
number still
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6
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0
0
14
Of the total number corrected, how many were corrected in 1994? 4
SECTION 4. FINANCIAL MANAGEMENT SYSTEMS
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1992 Report
1993 Report
1994 Report
Total
Number of Material Non-eonformances
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 1994? 0
"Enclosure A - Page 1
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Enclosure B - Progress Report on High Risk Areas
-------
1994 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. The Agency has completed 31 of the 40 recommendtions for
strengthening contracts management and is making substantial progress to complete the
remaining actions. 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
was declared as two material weaknesses, which EPA is reporting corrected in FY 1994.
OMB has removed Superfund from its High Risk List. (See Enclosure C, pages 30 and 32,
for a detailed description of the Agency's corrective action strategy, milestones and results
indicators.)
Enclosure B - Page 1
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1994 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
1995
Explanation for Change in Date: Programming delayed availability
of reports.
Enclosure B - Page 2
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The Agency's corrective action strategy for FY 1995 includes developing enhanced central Agency reports.
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 FY 1995.
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 FY 1989 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
6/93
10/92
2/94
6/94
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
1/95
ACTUAL
COMPLETION
DATE
11/92
5/93
6/93
10/93
5/94
Enclosure B - Page 3
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Enclosure C - Schedule of Corrective Actions
Material Weaknesses
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
RANKED MATERIAL WEAKNESSES SUMMARY
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1. Research & Development Facilities
2. Environmental Data Quality
3. Research & Development Extramural Resources
4. Research & Development Equipment
5. Drinking Water Primacy
6. Contracts Management
7. Accounting System-Related Financial Management Problems
8. Information Resources Planning & Security
9. Accounts Receivable
10. Research & Development Operating Expenses
11. Pesticides Data Integrity
12. Storm Water Permitting
13. Superfund Cost Recovery
14. Integrated Data for Enforcement Analysis (IDEA) System
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1. Accelerating Remedial Qeanup
2. Alternative Remedial Contract Strategy (ARCS) Contracts
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3. Federal Faculties
4. Pesticides Antimicrobial Program
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Enclosure C - Page 1
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ J OMB High Risk Area
[]New
[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;
[ JPRO
[ ] 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
1997
Explanation for Change in Date: Agency Masterplan contingent on
implementation of Laboratory Study.
Enclosure C - Page 2
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1994 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 FY 1994.
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. Develop FY 1995 budget initiatives to
support increased funding for facility repairs,
maintenance and construction.
3. Implement Masterplan.
ORIGINAL
TARGET
DATE
9/92
6/92
6/92
9/94
CURRENT
TARGET
DATE
5/95
4/95
N/A
1/97
ACTUAL
COMPLETION
DATE
4/94
Enclosure C - Page 3
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1994 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 fairing 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
[JCG
[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
1997
Explanation for Change in Date: Deficiencies detected in
inplementing quality assurance programs must be addressed
organizations.
by
Enclosure C - Page 4
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1994 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 FY 1994, ORD initiated 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
N/A
12/93
2. Develop, along with the Office of Human
Resource Management, generic language to
address QA responsibilities for Agency
managers' Performance Standards.
4/94
4/95
3. Distribute schedule for Management Systems
Reviews planned for 1994. Report quarterly on
progress.
1/94
N/A
1/94
4. New EPA Quality Manual, to include EPA
Order on QA and revised QA requirements and
in green border.
4/94
4/95
5. Present updated status and action plan to the
Administrator's Senior Leadership Council.
5/94
N/A
5/94
6. Distribute schedule for Management Systems
Reviews planned for 1995. Report quarterly on
progress.
1/95
1/95
Enclosure C - Page 5
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[X] Material Weakness
[ ] Corrected
[ J 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:
[JPRO
[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
1996
Explanation for Change in Date: Development of ORD-specific
policies and courses extended the initiation of training.
Enclosure C - Page 6
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1994 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 is 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) establish
Extramural Management Specialist positions in all ORD offices and laboratories. 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 POs, DOPOs,
and WAMs with contract 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
9/91
12/91
12/91
CURRENT
TARGET
DATE
9/96
N/A
N/A
ACTUAL
COMPLETION
DATE
10/94
9/94
Enclosure C - Page 7
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[X] Material Weakness
[ ] Corrected
[ J 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:
[JPRO
[]AC&C
[X]SF
[ ] LUST
[]B&F
[JCG
[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
1999
1999
Explanation for Change in Date: Not Applicable
Enclosure C - Page 8
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
During FY 1995, ORD will: 1) reassess its equipment inventory to ensure accuracy; 2) assess the impact
of previous year's funding of equipment inventory; and 3) sustain replacement/upgrade of antiquated
equipment in each laboratory that provides the necessary capability to support critical research programs.
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.
4. Verify that management control weakness has
been corrected.
ORIGINAL
TARGET
DATE
3/94
4/94
6/94
9/94
CURRENT
TARGET
DATE
1/95
4/95
N/A
9/99
ACTUAL
COMPLETION
DATE
8/94
Enclosure C - Page 9
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[X] Material Weakness
[ ] Corrected
[ J 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, Drinking Water Implementation Division
Office of Ground Water and Drinking Water, Office of Water (OW)
APPROPRIATIONS/ACCOUNTS:
[X] PRO
[X] AC&C
[]SF
[ ] LUST
[ JB&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 10
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1994 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.
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 FY '94
contract plan.
8. Validate that states have implemented new
rules included in the priority strategy.
ORIGINAL
TARGET
DATE
3/93
annually
9/93
ongoing
3/93
6/93
8/93
9/97
CURRENT
TARGET
DATE
12/94
annually
N/A
ongoing
N/A
3/95
N/A
9/97
ACTUAL
COMPLETION
DATE
annually
9/93
ongoing
1/93
11/93
Enclosure C - Page 11
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1994 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 FY 1993 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
1996
Explanation for Change in Date: Not Applicable
Enclosure C - Page 12
-------
1994 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'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 poh'cies to emphasize
acquisition management.
8. Adopt aggressive poh'cies 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
3/96
6/93
6/94
6/93
6/93
9/94
9/95
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
3/95
N/A
N/A
6/96
9/95
ACTUAL
COMPLETION
DATE
10/92
2/94
7/94
6/93
6/94
6/94
Enclosure C - Page 13
-------
1994 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 1994 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 14
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
EPA will update and issue policy guidance based on the newly implemented software and complete
enhancements to the IFMS to produce complete and accurate reports. We will also develop project cost
accounting and property systems capability requirements and an interface with Grants Information and
Control System (GICS). During FY 1995 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. Complete final on-site verification reviews.
2. Conduct Strategic and Master Plan Study.
3. Complete Property System Requirement Study.
4. Implement Version 5.1e of IFMS.
- User Manuals and System Documentation
5. Develop Funds Management Requirements.
6. Complete enhancements to produce accurate
reports.
7. Develop Project Cost Accounting Requirements.
8. Implement interface between IFMS and GICS.
9. Eliminate ADCR.
10. Replace FMS functions in CPARS.
11. Install Project Cost Accounting System.
12. Implement Property Accounting System.
ORIGINAL
TARGET
DATE
6/93
3/93
1/94
2/94
9/93
6/94
9/93
9/94
6/94
2/95
9/95
7/96
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
N/A
N/A
12/94
N/A
2/95
9/95
7/96
ACTUAL
COMPLETION
DATE
6/93
7/93
6/94
5/94
9/94
9/94
9/94
9/94
Enclosure C - Page 15
-------
1994 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
1996
Explanation for Change in Date: Corrective actions expanded to
include an indepth Strategic IRM Plan.
Enclosure C - Page 16
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The strategy for improving IRM planning and security is progressing on schedule. Program offices are
effective participants in the process and a central authority was established with Agency-wide
representation to oversee and direct planning -- the Executive Steering Committee (ESC) for IRM.
Instead of piloting the IRM planning process as originally identified, we undertook completion of a formal
and indepth strategic IRM planning process. We established an external advisory group under the
National Advisory Council for Environmental Policy and Technology (NACEPT) and procedures and
guidance will be developed to aid those involved in IRM multi-year planning. The ESC will review
progress and ensure that EPA is taking the proper actions to integrate IRM planning and budgeting.
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. Designate security officers.
2. Establish program offices' planning process.
3. Update information security policies/standards.
4. Secure sensitive system's risk analysis and plans.
5. Implement a security monitoring program.
6. Establish central review capability.
7. Provide mandatory security awareness training.
8. Validate information security milestones.
9. Initiate pilot integrated planning cycle.
10. Revise and finalize IRM planning procedures
and guidance.
11. Initiate Agency-wide IRM Multi-year Plan.
12. Publish Agency-wide Integrated IRM Plan.
13. Validate information planning milestones.
ORIGINAL
TARGET
DATE
4/93
9/93
12/93
12/93
6/93
12/93
6/93
4/94
5/94
2/95
5/95
12/95
12/95
CURRENT
TARGET
DATE
N/A
N/A
12/94
N/A
N/A
N/A
N/A
12/94
N/A
2/95
5/95
12/95
12/95
ACTUAL
COMPLETION
DATE
9/93
9/93
<
6/93
6/93
12/93
6/93
5/94
Enclosure C - Page 17
-------
1994 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.
These shortfalls consist of inaccurate and incomplete automated reports and lack of flexibility for
automatically accounting for installment payments and calculating superfund compound interest. These
shortfalls continue to prevent the Agency from achieving maximum efficiency in 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 Spfll
[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
1995
Explanation for Change in Date: Programming problem delayed
availability of reports.
Enclosure C - Page 18
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
EPA's strategy in FY 1995 includes: 1) updating and issuing policy guidance based on the new software
version; and 2) completing enhancements to the IFMS 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 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
6/93
12/92
2/94
2/94
2/94
6/94
8/94
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
5/95
1/95
N/A
ACTUAL
COMPLETION
DATE
11/92
6/93
5/93
5/94
5/94
5/94
Enclosure C - Page 19
-------
1994 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
[JCG
[X] R&D
[ ] OH 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
1996
Explanation for Change in Date: Corrective actions were delayed
pending EPA Lab Study recommendations. Full correction is
contingent on resources appropriated through the budget process.
Enclosure C - Page 20
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
The Agency's strategy is 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 initiatives will continue and will be further
enhanced by improved quality control procedures.
RESULTS INDICATORS;
Corrective actions resulted in increases in ORD laboratory operating expense funds from $22 million in
FY 1990 to over $50 million in FY 1994. 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
3/94
4/94
6/94
7/94
8/94
CURRENT
TARGET
DATE
3/95
4/95
6/95
7/95
8/95
ACTUAL
COMPLETION
DATE
Enclosure C - Page 21
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ jNew
[X] Material Weakness
[ ] Corrected
[ ] Non-conformance
[X] Carryover
TITLE: Pesticides Data Integrity
DESCRIPTION;
An Agency 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 office
coordination.
RESPONSIBLE MANAGER:
Elaine Stanley, Director, Office of Compliance
Office of Enforcement and Compliance Assurance (OECA)
APPROPRIATIONS/ACCOUNTS;
[X] PRO
[X] AC&C
[JSF
[ ] LUST
[]B&F
[]CG
[]R&D
[ J 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
1994
1995
Explanation for Change in Date: Reorganization of the Office of
Enforcement and Compliance Assurance resulted in a delay of final
decision on GLP lab accreditation program.
Enclosure C - Page 22
-------
1994 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 recommendations on the
Federal Insecticide, Fungicide and Rodenticide Act GLP program. In FY 1995, 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 QPP auditors.
7. Validate effectiveness of corrective actions by
assessing selected laboratory inspections, training
program evaluations, and inspector performance.
ORIGINAL
TARGET
DATE
12/91
2/92
9/92
4/93
4/93
1993
9/92
CURRENT
TARGET
DATE
N/A
N/A
N/A
9/95
N/A
9/95
9/95
ACTUAL
COMPLETION
DATE
12/91
9/93
8/92
9/93
Enclosure C - Page 23
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[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 Management
Office of Water (OW)
APPROPRIATIONS/ACCOUNTS:
[X] 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:
1991
1993
1994
1995
Explanation for Change in Date: OMB final review and approval
of report before submission to Congress.
Enclosure C - Page 24
-------
1994 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. OMB has offered comments and approval is
expected for submission of the final report to Congress in December 1994. In FY 1995, 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 FY 1992 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
1/91
12/91
1/92
10/92
10/92
6/92
3/93
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
N/A
N/A
12/94
ACTUAL
COMPLETION
DATE
1/91
12/91
1/92
9/92
9/92
9/92
Enclosure C - Page 25
-------
1994 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 FY1990-92 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:
Bruce M. Diamond, Director, Office of Site Remediation Enforcement
Office Enforcement and Compliance Assurance (OECA)
APPROPRIATIONS/ACCOUNTS;
[]PRO
[]AC&C
[X]SF
[ ] LUST
[JB&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
1995
1995
1995
Explanation for Change in Date: Not Applicable
Enclosure C - Page 26
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA'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. EPA 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
6/93
9/95
9/95
CURRENT
TARGET
DATE
9/95
9/95
9/95
9/95
ACTUAL
COMPLETION
DATE
Enclosure C - Page 27
-------
\
m
1994 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:
Elaine Stanley, Director, Office of Compliance
Office of Enforcement and Compliance Assurance (OECA)
APPROPRIATIONS/ACCOUNTS;
[X] PRO
[X] AC&C
[X]SF
[ ] LUST
[]B&F
[JCG
[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
1995
Explanation for Change in Date: Review of a draft testing protocol
resulted in more extensive updates than originally planned.
Enclosure C - Page 28
-------
1994 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.
In FY 1995, 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 an increase in the number of EPA Headquarters and Regional users of the
IDEA system, which will result in 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 OECA 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
6/93
6/93
6/93
9/93
12/92
3/93
6/93
9/93
CURRENT
TARGET
DATE
N/A
N/A
12/94
3/95
N/A
N/A
N/A
N/A
ACTUAL
COMPLETION
DATE
6/93
6/93
9/94
12/92
9/93
9/93
9/93
Enclosure C - Page 29
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[X] OMB High Risk Area
[]New
[X] Material Weakness
[X] Corrected
[ J Non-conformance
[ ] 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
1994
Corrected
Explanation for Change in Date: N/A
Enclosure C - Page 30
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY-
The Agency's corrective action strategy was to standardize the remedial planning/remedy selection process
by developing presumptive remedies for selected site types, 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 63 in FY 1991 to 278 by September 1994;
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 at selected
facility types. Other presumptive remedy pilots have demonstrated overall reduction in time to identify
remedial actions. Effectiveness of presumptive remedies were validated through field demonstrations,
monitoring and reporting results. National guidance was modified based on results of pilots.
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 analysis.
10. Finalize soil screening level guidance.
ORIGINAL
TARGET
DATE
12/91
9/92
9/93
9/92
9/93
9/93
3/94
9/94
9/94
9/94
CURRENT
TARGET
DATE
9/92
12/92
9/93
9/93
9/93
9/93
3/94
9/94
9/94
9/94
ACTUAL
COMPLETION
DATE
2/92
7/92
9/92
9/93
9/93
9/93
9/94
Deferred: contingent on
passage of 1994 SRA
6/94
8/94
Enclosure C - Page 31
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•LM U
JSSU
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[X] OMB High Risk Area
[]New
[X] Material Weakness
[X] Corrected
[ J Non-conformance
[ ] 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 $350
million per year 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:
[JPRO
[ ] 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
1992
1994
Corrected
Explanation for Change in Date: N/A
Enclosure C - Page 32
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
EPA created the Superfund Revitalization Office and Regional Management Teams to focus management
attention to ARCS contract issues. EPA's corrective actions were designed to: 1) establish decreasing
national program management cost targets to lower overhead expense ratios; 2) increase Regional
flexibility in selecting ARCS contractors 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 the award fee process to ensure best contractor efforts.
RESULTS INDICATORS:
EPA corrective actions steadily reduced program management costs from 20 percent in 1991 to 11.7
percent by 1994; balanced the ARCS/COE construction management system, with no extant excess
contract capacity; and, instituted IGCEs for work assignments over $25,000. EPA Headquarters
completed Regional reviews to validate corrective actions in FY 1994. Headquarters developed and
distributed a validation template survey that the Regions completed in FY 1994, and which confirmed the
effectiveness of corrective actions.
MAJOR CORRECTIVE ACTION
MILESTONES
r
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. Regions return completed templates.
11. Analyze results of Regional surveys.
12. Discuss survey results with Regions.
13. Take corrective action as needed.
ORIGINAL
TARGET
DATE
4/92
7/92
9/92
7/92
11/92
9/92
9/92
8/93
11/93
2/94
4/94
6/94
9/94
CURRENT
TARGET
DATE
8/92
7/92
9/92
7/92
11/92
12/92
12/92
8/93
11/93
2/94
4/94
6/94
9/94
ACTUAL
COMPLETION
DATE
8/92
4/92
7/92
9/92
11/92
12/92
12/92
8/93
11/93
2/94
4/94
6/94
9/94
Enclosure C - Page 33
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[X] Material Weakness
[X] Corrected
[ ] Non-conformance
[ ] Carryover
TITLE: Federal Facilities
DESCRIPTION:
Internal reviews found vulnerabilities in 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 included additional Agency workyears to perform new work and remedial site
assessments at one thousand sites. EPA's FY 1994 budget reflected only about forty percent of the
projected need,
RESPONSIBLE MANAGER:
Barry Breen, Director, Federal Facilities Enforcement Office
Office of Enforcement and Compliance Assurance (OECA)
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
1993
1994
Corrected
Explanation for Change in Date: N/A
Enclosure C - Page 34
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1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY:
In FY 1994, EPA completed the accelerated cleanup strategy and developed the base closure Model
Accelerated Cleanup (MAC) program to concentrate efforts on bases where the Department of Defense
(DOD) has developed reuse plans.
RESULTS INDICATORS:
EPA's goal was to increase the number of base closures and property transfers resulting from more timely
and effective EPA oversight and enforcement of Federal facility cleanup. In FY 1994 the Agency
obtained 100 workyears and $7 million in funding through an interagency agreement with DOD for
activities related to the President's Fast Track Cleanup Program at selected BRAC bases. The Agency's
potential liability for addressing additional Federal Superfund sites was limited by court action to the
Northeastern United States, resulting in only ten additional Federal facilities considered for listing on the
National Prioirites List. EPA has completed evaluation and listing of these sites.
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
2/94
10/94
8/94
9/94
Enclosure C - Page 35
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[X] Material Weakness
[X] Corrected
[ ] Non-conformance
[ ] 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;
Daniel M. Barolo, Director, Office of Pesticide Programs
Office of Prevention, Pesticides, and Toxic Substances (OPPTS)
APPROPRIATIONS/ACCOUNTS;
[]PRO
[X] AC&C
[]SF
[JLUST
[]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
1994
1994
Explanation for Change in Date: Not Applicable
Enclosure C - Page 36
-------
1994 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 FY 1994, EPA conducted an Alternative
Management Control Review which confirmed that the program addressed remaining weaknesses.
RESULTS INDICATORS:
The key success measure for correcting the antimicrobial program weaknesses is improved test methods
for determining the efficacy of antimicrobial products, resulting in the removal of ineffective sterilants
from the marketplace. Fourteen ineffective sterilant products used on critical medical instruments have
been removed from the market; several others have been referred for enforcement.
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 (IAG).
4. Expand EPA/state cooperative agreements.
5. Extend IAG 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 vah'date
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
9/91
12/91
9/91
6/92
9/92
9/92
9/93
9/91
9/91
9/92
9/91
9/94
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
N/A
ACTUAL
COMPLETION
DATE
9/91
9/91
6/92
6/92
9/92
9/92
6/93
9/92
9/92
9/92
9/91
9/94
Enclosure C - Page 37
-------
Enclosure D - Schedule of Corrective Actions
Material Non-Conformances
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL NON-CONFORMANCES SUMMARY
1. Regional/General Ledger Accounts Receivables
1989
1994
1995
D-2
2. Property Accounting Process
1983
N/A
1996
D-4
3. Accounting System Interfaces
1985
1993
1995
D-6
Enclosure D - Page 1
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[ ] New
[ ] Material Weakness
[ ] Corrected
[X] Non-conformance
[X] Carryover
TITLE: Regional/General Ledger Accounts Receivables
NON-CONFQRMANCE TYPE AND DESCRIPTION; Core Financial System
Internal reviews found several potential unrecorded accounts receivable in the Regions resulting from
program officials not promptly notifying the servicing finance office of the creation and disposition of
receivables. The IFMS accounts receivable module lacks the capabilities to automatically process the
unique Superfund requirements of compound interest and flexible 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
1995
Explanation for Change in Date: Programming problems delayed
availability of reports.
Enclosure D - Page 2
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
The Agency now requires each Servicing Finance Office to reconcile the recorded accounts receivable with
the program office and the Office of Regional Council to assure that all receivables are recorded in IFMS.
Discussions were held with the Department of Justice to identify alternative measures for obtaining
account receivable documents more expeditiousty and we are developing an automated function to handle
installment receivables.
RESULTS INDICATORS;
Key results indicators include updated and accurate IFMS user documentation, enhanced accounts
receivable installment functions within IFMS, and 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
6/93
2/94
2/94
2/94
6/94
6/94
8/94
CURRENT
TARGET
DATE
N/A
N/A
N/A
N/A
5/95
1/95
1/95
N/A
ACTUAL
COMPLETION
DATE
5/93
6/93
5/94
5/94
5/94
Enclosure D - Page 3
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[ ] 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). Internal reviews identified continuing problems
with recording property in the Agency's General Ledger. The Agency formed a Quality Action Team
(QAT) which recommended procuring a property module compatible with IFMS, and developed an
implementation strategy.
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
Target date was deferred
pending development of
fixed assets module
1996
Explanation for Change in Date: Development of correction date was
deferred in FY 1993 pending outcome of development of enhanced
fked assests module for Federal financial system users.
Enclosure D - Page 4
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CORRECTIVE ACTION STRATEGY;
The QAT recommended a module compatible with IFMS and an implementation strategy which was
accepted by EPA management. The strategy contains steps to: 1) examine policies, procedures and EPA
requirements; 2) reconcile data; and 3) develop user manuals and provide training prior to installing the
system.
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. Install Property Accounting System Module.
ORIGINAL
TARGET
DATE
9/93
7/93
1/94
7/96
CURRENT
TARGET
DATE
N/A
N/A
N/A
7/96
ACTUAL
COMPLETION
DATE
3/93
7/93
6/94
Enclosure D - Page 5
-------
1994 INTEGRITY ACT REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
[ ] OMB High Risk Area
[]New
[ ] 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 (GIGS) as requiring an interface with IFMS. The
other systems are not fully developed for an interface to 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
1995
1996
Explanation for Change in Date: Property Accounting System
requirements and implementation plan were not known last year.
Enclosure D - Page 6
-------
1994 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); 4) implementing cost accounting capability; and implementing
Property Accounting System. We plan to terminate the legacy systems at the end of FY 1995. 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, installation of Property
Accounting System, 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. Analyze disposition of historical FMS data.
2. Eliminate ADCR.
3. Finalize project cost accounting
requirements.
4. Implement project cost accounting
requirements.
5. Implement interface between IFMS and
regional GICS.
6. Implement Property Accounting System.
7. Implement replacement for FMS historical
data.
8. Replace FMS function in CPARS.
9. Implement MARS view of historical data.
10. Automate Superfund layoff.
11. Implement accounting number changes.
ORIGINAL
TARGET
DATE
9/93
6/94
9/93
9/95
9/93
10/92
3/95
2/95
7/95
8/95
10/95
CURRENT
TARGET
DATE
N/A
N/A
N/A
9/95
12/94
7/96
9/95
2/95
7/95
8/95
10/95
ACTUAL
COMPLETION
DATE
10/93
9/94
9/94
Enclosure D - Page 7
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For additional copies of this report, please write to:
Environmental Protection Agency
Resource Management Division 3304
Quality and Management Integrity Branch
401 M Street, S.W.
Washington, DC 20460
or call:
Phone: (202) 260-9650
Fax: (202) 260-0400
and request EPA's 1994 Integrity Act Report.
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