D ST CD PpO1 National Grants Training Conference EPA Grants Management - Accountabili and Results Jacksonville, Florida S November 16 - 18, 2004 ------- Table of Contents Breakout Sessions I Breakout Session 2: Breakout Sessions 3 Breakout Sessions 4 (IGMS) Information Breakout Session 5: Breakout Session 6: Breakout Session 8: TOPIC TAB NUMBER Tuesday Plenary Session 1 Wednesday Plenary Session 2 Thursday Plenary Session 3 Environmental Results Training 4 Revised Grants Competition Policy - Implementing the New Competition Requirements 5 & 19 (Repeat): Cost Review Guidance 6 Pre-Award Compliance Review 7 & 7 (Repeat): Interagency Agreements (lAGs) 8 & 9 (Repeat): Integrated Grants Management System Toolbox for Project Officers 9 The Brownfields Program I 0 The Budget Process I I OSDBU Program Requirements and Procurement under Grants 12 Breakout Sessions 10 & 15 (Repeat): Post Award Monitonng 13 Breakout Session II: Erroneous Payments - Finance 14 Breakout Session 12: IGMS Information Toolbox for Grants Specialists IS Breakout Session 13: Tribal Issues 16 Breakout Session 14: Finance Issues - New Changes and Payments (Las Vegas and Cincinnati) 17 Breakout Session 16: Project Officer Feedback on Grants Management 18 Breakout Session 17: State Grants and Performance Partnership Grants (PPGs) 19 Breakout Session 18: Discussion and Q&A’s on Revised Grants Competition Policy 20 Breakout Session 20: Grant Specialist Feedback on Grants Management 91 ------- Table of Contents ------- 1 ------- 2 ------- EPA Grants Management Plan: Progress, Accomplishments, and Challenges 2004 EPA Grants Management Training Conference November 17, 2004 ------- Each Fiscal Year EPA Awards an Average of $4 Billion in Grants Non-Proffts 21.8% Educational Institutions 11.6% Avg # of Awards Other 5.0% \ Total: 7,772 State Governments 35.3% Local Governments I re, I I.JfO Educational Institutions 4.2% Tribes . .1 Local Governments 9.3% Non-Profits ¶• 6.6% Other 0.6% Total: $4,165,853.9 State Governments 77.0% Avg $ Awarded (in thousands) 2.4% \- Tribes 14.8% 2 ------- Since 1995, EPA’s Grants Management Practices Have Been Criticized by Congress, GAO and the Inspector General for: a Inadequate Grant Competition Adequacy of Pre-award Review a Insufficient Oversight of Recipients (especially nonprofit recipients) • Inability to Link Grant Programs to Specific Environment Results • Failure to Align Grants With Agency Strategic Goals a Lack of Accountability 3 ------- To Address These Challenges, in April 2003, EPA Issued its First-ever Long Term Grants Management Plan E There are Five Goals : 1. Enhance the Skills of Personnel Involved in Grants Management 2. Promote Competition in the Award of Grants 3. Leverage Tech no logy to Improve Program Performance 4. Strengthen EPA Oversight of Grants 5. Support Identifying and Realizing Environmental Outcomes 4 ------- Goal 1: Enhance the Involved Skills of Personnel in Grants Management Key Accomplishments : Issued Long Term Training Plan Revamped and Enhanced Project Officer Training Challenges : Progress : Percentage of Certified Project Officers 100% 95% 90% 85% 80% Actual Target 2004 • Mandatory Manager Training • Online Training for Recipients -4 75% Baseline 2002 5 ------- Goal 2: Promote Grants Progress : Percentage of New Grants Competed Over $75K Competition in the Award of Key Accomplishments : • Established Grants Competition Advocate Position • Issued new EPA Order on Grant Competition in September 2002 • Expanded Public Awareness of EPA Funding Opportunities by Posting Synopses on FedGrants.Gov Challenges : • Expanding the Level of Effective Corn petition 4; Baseline 2002 Actual Target 2004 6 ------- ( oal 3: Leverage Technology to Improve Performance Progress: Key Accomplishments : Percentage of Grant Transactions Successfully Deployed IGMS in all Ten Regions 100% • Improved the Agency’s oversight 90% capabilities through creation of 80% Grantee Compliance Database 700/ • Developed an interface to Federal E- 0 Grants portal, e.g. STAR Grants 60% 50% 40% Challenges 30°! • Increasing Electronic Grant 0 0 Applications through Grants.govApply 20/ • Deployment of IGMS in Headquarters 10% 0’ Processed Electronically Baseline Actual Target 2002 2004 7 ------- Goal 4: Strengthen EPA Oversight of Grants Key Accomplishments : • Issued New Policy on Compliance, Review and Monitoring in December 2002 • Established Comprehensive System of Internal Grants Management Reviews • Required Grants Management Performance Standards for Project Officers and Managers Issued Roles and Responsibilities Policy Challenges : • Pre-Award Review • Statistical Approach for Selecting Recipients for Reviews • Expanding Internal Reviews to Include lAGs Restructuring the EPA Grants Management Workforce Progress : Baseline Projected Target Actual 2002 2004 8 ------- Goal 5: Support Identifying Environmental Outcomes Progress : Percentage of Workplans with Actual Target and Realizing Key Accomplishments : • Issued Interim Policy on Environmental Results • Developed Comprehensive EPA Order on Environmental Results Challenges : • Identifying Environment Outcomes from Grants • Linking Outcomes to the Agency Strategic Goals • Reporting to Congress on Environmental Outcomes Environmental Outcomes 70% 60% 50% 40% 30% 20% 10 AOl U /0 Baseline 2003 2004 9 ------- The Ultimate Challenges: E. • To Eliminate the Agency’s Grants Management Weakness • To Become a Best Practices Agency for Grants Management 10 ------- EPA’s Suspension d Debarment Prog ,) National Grants Training Conference ------- C What Is SuspenT ion and Debarment? • Keeps an individual, organization, or government entity from receiving future federal grants or contracts • Has a government-wide effect • Suspension and debarment is a consumer protection organization for the federal government. ------- Suspension and Debarment Are Powerful Tools • For protection, not punishment • The agency is making a business decision. 1 4 1 ------- Suspension and Debarment Are Powerful Tools contracts without Due Process. • The Suspension and Debarment Program C . Individuals or organizations cannot be denied access to 41 Federal grants and provides Due Process. ------- C Suspension and debarment Are Powerful Tools • The main issue in Suspension and Debarment cases is present responsibility. ------- What isi Dufferjje Between Suspension and Debarment? Suspensions are temporary, pending the outcome of an investigation, legal actions, or debarment proceedings. • Suspensions are imposed while we are trying to determine whether misconduct has occurred. ------- • Debarment is imposed after all of the facts are known. C What Is the Differe e Between Suspension and Debarment? • Debarment is for a set number of years. ------- Who Can Be Susjended or Debarred? Individuals, corporations, and non-profit organizations • Misconduct by an individual can be attributed to an organization, and vice versa. ------- __What Conducts 1 Warrant Suspension or Debarment? . False Statements • Environmental Misconduct • Willful Failure to Perform • History of Poor Performance • Willful Violation of a Statutory or Regulatory Requirement . Fraud ------- C What Will Happen lfj)Refer a Case to Suspension and Debarment? • Likely to be resolved by a Compliance Agreement - Organizations are highly motivated to avoid Debarment. • Compliance Agreements will address all problems, including concerns raised by the Program Office and Grants Specialist. • A simple letter from the Suspension and Debarment Division will motivate many grantees to come into compliance. ------- C What Will Happen If jI Refer a Case to Suspension and Debarment? Cases that do not settle go through our formal process. - This includes an informal meeting with the Debarring Official and a Fact-Finding Hearing, if facts are in dispute. • You may be asked to provide documentation or participate in an informal meeting or Fact- Finding Hearing. ------- How Do I Find Out Whe er Someone Is Suspended or Debarred? Everyone who is Suspended or Debarred is listed on the Excluded Parties List System (EPLS). . Find it at: www.epls.gov ------- The Changing Grants Management Climate ------- A new Pre-Award Policy is going into effect on January 1, 2005. It requires Award Officials to refer grantee fraud, waste, and abuse to the Suspension and Debarment Division. It also requires the Director of GAD to refer grantees who are unwilling to develop adequate administrative capabilities to SDD. The_Changing Grants Management Climate ------- GIIIIIIII m y In resolving actions, we about what Agency. • The needs of referring offices will be foremost in our minds! • If you have a doubts about whether grantee should continue receiving Federal funds, consider Suspension and Debarment. Suspension and Debarment are making a business decision is in the best interests of the ------- Sunvna ry • If you are unsure about whether a matter warrants a Suspension or Debarment, call us! • Contact information is in your binder. C ------- • Regions I and 3 Mary Clarke, (202) 564-5388 • Regions 2 and 5 Dan Barros, (202) 564-5383 • Region 4 Angelia Blackwell, (404) 562-9872 • Regions 6 and 7 Kathleen Timr iins, (202) 564-5292 • Regions8andlO Jeanne Pascal, (206) 553-1146 • Region 9 Frank Lane, (415) 947-4548 Contact Information ------- GRANT FRAUD AWARENESS OIG Overview Investigations Types of Cases BRIEFING OUTLINE Assistance Agreement Fraud Roles & Responsibilities ------- OIG OVERVIEW Authority: Inspector General Act of 1978, as amended, allows for the IG to conduct audits and investigations into fraud, waste, and abuse within the EPA. Overall Goal: To provide audit, evaluation, investigative , and advisory services resulting in improved environmental quality and human health. ------- OIG’s THREE MAJOR FUNCTIONAL AREAS OFFICE OF AUDIT — Responsible for performance audits, compliance audits, financial audits and investigative support audits • OFFICE OF PROGRAM EVALUATIONS — Responsible for systematic evaluations of agency programs and systems for efficiency and performance results • OFFICE OF INVESTIGATIONS — Responsible for administrative, criminal, civil, and special project investigations ------- OIG’s THREE MAJOR FUNCTIONAL AREAS • OFFICE OF AUDIT — Responsible for performance audits, compliance audits, financial audits and investigative support audits • OFFICE OF PROGRAM EVALUATIONS — Responsible for systematic evaluations of agency programs and systems for efficiency and performance results • OFFICE OF INVESTIGATIONS — Responsible for administrative, criminal, civil, and special project investigations ------- / -c., 1 i. GS-1811 INVESTIGATIONS HOMELAND SECURITY ACT Criminal Investigators (Special Agents) Administer and take Oaths Serve Subpoenas Authority to - Carry Firearms - Make Arrests - Execute Warrants Investigate and present cases to the Department of Justice ------- INVESTIGATIONS 15 Offices Nationwide 44 Special Agents (Field) 200+ Investigations Avg. FY 03 recovery ________ Indictments in FY 03: 26 Convictions in FY 03: 16 - $11 + Million per Agent Y - ---- ------- OIG or Criminal Investigation Division (CID) • OIG investigates crimes against the EPA • QD investigates crimes against the environment ------- CASE CATEGORIES INVESTIGATED Contract Fraud Assistance Agreement Fraud 20% Program Integrity Employee Integrity Other (Stolen Property, Identity Theft, etc) Laboratory Fraud Computer Crimes ------- / ; i- - : : :. Most complaints concern AA recipients in these three areas: 1. Office of Water • SRF program concerns 33% 2. Tribal Programs 3. Office of Air of all AA investigations ‘1 ------- / TOP CASE TYPES: 1. False Statements (Applications, Financial / Progress Reports) 2. Embezzlement (State Officials, bookkeepers) 3. Wire Fraud (draw downs) 4. False Claims (at project level I construction / sub contract) 5. Anti-trust ------- ELEMENTS OF FRAUD 1. A Representation 2. About a Material Point 3. Which is False 4. Intentionally 5. Which is believed and Acted Upon 6. To the Victim’s Damage ------- UMBRELLA OF GRANT FRAUD ------- Types of Grant Fraud Generally some ruse or artifice to perpetrate the grant fraud and minimize detection while giving it the appearance of legitimacy ‘Payroll Padding ‘Ghost Employees •Salaries given to relatives of friends who are not working on grant ‘Double/Excessive Billing •False Travel Vouchers ‘Payment of Personal Expenses ‘/I, ------- - ‘ Types of Grant Fraud (cont.) •Plagiarism of Researchl Work • Lobbying Submitting False Data •Collusion between the grantee recipient and the government representative •Not doing any of the funded work and grantee fugitates with the funds •Conflict of interest concerning “arm’s length transactions” •Labor cost mischarging •Providing services to non-eligible recipients ------- / — INVESTIGATIVE LEADS • 33 percent originate from gmnt specialists and project officers • Prqject ( 5i Reüeiis • Pi jecs Reports • Deck Reue2es • On-siteRetiezes • Other Law Enforcement Agencies • Hotline ------- LABOR COST MISCHARGING DOD (. ‘-- Work performed Ii ere . . . . . S TATE/PRIVATE ABC, Inc EPA GRANT $$ .but billed over here I ------- GHOST EMPLOYEES & COSTS NOT INCURRED (EPA GRANTS AND SUBSEQUENT CONTRACTS) $ EPA Equipment never provided Supplies never ordered Samples never tested Labor Costs for Non-existent Company employee Projects never completed ------- INFLATED RATES & UNALLOWABLE EXPENSES (EPA GRANTS AND/OR SUBSEQUENT CONTRACTS) EPA L > Consultant Rates Indirect Rates Officer Bonuses Personal or unallowable expenses billed as legitimate “Actual” Rates much lower and disguised or otherwise hidden from Gov’t. ------- SHELL COMPANIES & LEASING SCAMS Leasing Subcontractors Labs, studies, or equipment “Actually owned by ABC Inc., but purported to be a legitimate lease.” ABC Inc. EPA GRANT ------- SHELL COMPANIES & LEASING SCAMS Lobbying issues-using Related parties and family members non-profit companies to use as pass-through to for - No divestiture ________________ of control No arms-length transaction No financial separation 8(a) or MBE “front ” profit companies ((((1 ------- PRODUCT SUBSTITUTION Inferior or cheaper products not in accordance with contract specifications, but purported to be in compliance. We may rely on the P0 technical expertise who know the industry prices on these matters Example: Water treatment plant equipment — SRFs used for State contracts. (SRFs are $2 Billion of EPA’s Grant budget.) ------- BIDRIGGING Conspiracy between “competitors” to 1. price fix competition 2. market allocation generally to the cost or performance detriment of the Government Union or wage related “sweetheart” deals between Example: Same water treatment plant equipment prices may be fixed among competitors contractor and other representatives which allow them to underbid competition — resulting in uneven playing field Title 15 Sherman Anti-Trust Act ------- OBSTRUCTION OF FEDERAL AUDIT It is a crime for anyone to impede, obstruct, or influence an audit of a federal grant/contract *Federal Auditor (GAO or OIG) or quality assurance inspection (OGD) *U.S. Government programs over $100,000 value *Intent to obstruct, impede or influence the audit Thern LOfT!, 18 U.S.C. 1516 ------- BRIBERY/KICKBACKS 18 U.s.c. 201/9 u.s.c. 927 Generally, “Bribery” is a payment made to encourage an act to occur. “Kickbacks or Gratuities” generally are payments that are made from the profits or windfall gained as a result of the act occurring. If offered a bribe, be non-committal . OIG Investigations Office immediately Report to nearest EPA Grant ------- BRIBERY ILLEGAL PAYMENTS MADE AS: Gifts, travel, entertainment Cash Checks and other financial instruments Hidden Interests Loans Payment of bills and expenses .1 Transfers or transactions at other than fair market value ------- Weaknesses and Vulnerabilities of Grant Fraud Investigations • Payments are not contingent upon progress • Progress reports are often generically written making it difficult for investigators to match work efforts with expenditures • There is no 18 U.s.c. warning on the Grant Application nor on progress reports • The magnitude in number and geographical distribution of grants make physical or close scrutiny and monitoring difficult ------- We akne s s e s and Vulne rab ilitie s (cont.) • Some multi-year award grants maintain their funding even as they are being investigated, thus weakening the criminal case • Expenditures above and beyond allowable salaries are not easily identifiable or attributable with overall success or failure of the grant. ------- Investigative Resources • Audits occasionally initiate investigations • U.S. General Accounting Office (GAO) • EPA OIG or other agency’s OIG • Single Audits mandatory for grantees that receives $500,000 in federal payments in a recipient’s fiscal year • Clearly understand the applicable 0MB Circular related to your specific grant recipient ------- Investigative Reports • Standard Form (SF) 269, Financial Status Report provides info total paid vs. total grand award • SF 270, Request for Payment or SF 271, Outlay Report and Request for Reimbursement are submitted by recipients when requesting payments • SF 272, Federal Cash Transactions Report monitors cash management • Progress Reports are required at least annually and include expenses vs. project progress, accomplishments, and problems ------- Documentary Evidence of Fraud • Recipient’s ledger’s for each grant and bank account to compare • Invoices and vouchers • State labor records • Articles of Incorporation • Research grants for other federal or state agencies • Emails between recipient and institutions performing related work • Publications/presentations / dissertations of persons directly associated with recipient ------- SUMMARY OF DO’S AND DON’TS Do discuss your concerns with 01G. Don’t feel compelled to “prove” case or intent Do seek answers to your questions in the normal course of business Don’t “tip off’ subjects of actual or pending investigation Do cooperate with OIG and expect to be contacted and involved Don’t “stop” your normal course of business unless otherwise directed ------- YOUR ROLE Investigations needs you to be the eyes and ears and help identify and report activity which may be fraudulent. • Your efforts are critical to a successful EPA program. • There is no way that we can be everywhere, every time. • Please report fraud activity to our office. ------- U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OFT [ INSPECTOR GENERAL f ICE OF INVE 5T IGAT IONS I “. 1 “ ii t \ F I f I i V. \ — I ‘ I I I ‘ I • 1 J I GRANT FRAUD Cf JF T111 I ‘ s •\ I I ‘ ‘ \ Ii • I tI- * • I ‘ II 4 • • IL J 1 —. . I •‘. I ‘ : I ‘-VI —i’1 I I Ii !) \I If) ‘.. •,•‘ . t . •, ....t CHASE f14. . I F Atfl At :: r .avj 4 ; f. ( C VL “N’’LN I i F V ! AVf.I F . .; (;()N LIC NTE LST F A C ’ STAt F M I .. JI I I .S N ’ : . K S A( ‘ ‘ It) :çr 4 1/’; 1 I UE r! i . • ;i t !() S ‘S ‘ 4 t fl !37i OR (2f :- 2 J-•4 ‘77 ------- Financial Fraud Directorate Desk Officer: Assistance Agreement Investigations John E. Patrick, Special Agent Office of Inspector General Office of Investigations 1200 Pennsylvania Avenue, N.W. Mail Code 2431 T Washington DC 20460 (202) 566-2389 patrick.j ohn epa.gov ------- Debarments and Suspensions • Provides authority to suspend or debar any “person” from participation in any Federally assisted project if necessary to protect the gov t s interest • This action can be pursued concurrently with criminal and civil cases ------- GRANT FRAUD AWARENESS OIG Overview Investigations Types of Cases BRIEFING OUTLINE Assistance Agreement Fraud Roles & Responsibilities ------- A New Day Electronic Grant Applications *‘ ------- Background Formerly Know As EGrants President’s Management Agenda • Public Law 106/107 • Grants.gov FIND & APPLY ------- Grants.gov Storefront trants4jov - F e Edit View Fevorjte Tools Help -Beck - _) J Search Favtes JModi. J _4 J Addre c http: //www grants. QovI 4 4 AIM Search Pop-Ups Bloeked C IM - Games - Per srw aIs - W tPw Grantor. Applicant. EBiz About U. Resource. P.L. 106-107 PrIvacy FAQ• Site Map LP ( 3FR NJ1 . (3 Learn about Public Law 1 .iQ1! Grants.gov featured on WJFK FM 106 7 Radio Show on October 16 at 9 a m Be on the look-out for a request to participate in the Satisfaction Survey’ Grant Oooortunities posted in the last 7 days. Grant ADolic3t gfl Packages available on Grants .gov toda # Review our new Complete Application Package Training Demo ! ; start . Worksrwaj cwc% er?e... ‘ “ ‘k Get Find Gracil Appi i Fn Started Opportunities Grants F FIND. APPLY. SUCCEED. 5M Customer Support Grants.gov allows organizations to electronically find and apply for competitive grant opportunities from all Federal grant-making agencies. Grants .gov is THE single access point for over 900 grant programs offered by the 26 Federal grant-making agencies. The US DeDartment of Health and Human Services is Droud to be the managing partner for Grants gov. an initiative that will have an unparalleled impact on the grant community Navigation of Grants .gov is simple Use the colored tabs and/or links at the top of the screen to access primary sections of the site or the links to the left and below to access information on specific topics Find Or nt OpportunitIes • Search for Grant Ocoortunifles • Register for Notification of Grant Oooortuniti as • Resources focQr nts • Find information on Governmr ’r enefits A Be l v For Grants • Preciare toAppjy torGr int Through Grants ciov • Access Active Grant ADDII cation • Download Grant A oDuicat,on Packeaes - Internet N 2*j $a 6: 53AM - ‘C i-. r.Icroso t P... - Gramt ..go.. - ------- Benefits to Citizen • One Place to FIND Grant Opportunities • One Method to APPLY for Grants • Simplify the Process • Standard Forms and Formats ------- Grants.gov FIND File Edit View Favorites Tools Help 4-’Back - — - ,) j Search JP.vortes jMede j .. ‘ - - - ,.J . Address http://ww . grants. govfFlnd AIM - I - ¼ Search G Pop-Ups E$ocked 0 AIM - Gamec .Pers c - I Ir ,r — I i d (i elM OpSl(nhl II iufi w 4 c c c Search Grant Opportunities Receive Grant Opportunity Notification Access the most requested ‘formation and features SeinctA Topic — Posted Grant ppçiniUes within ! ti .days Available Grant Application Packages Types of Grants Grant Makino Start Wovkspace 4 Wordi erFa.. p 1t F I N D grant opportunities - ‘C Grantore Applicant. EUlz About U• Rewourcee P.1.. i$-iSi Priuscy FAO. Site Map HELP Get Find Grant App Ftw Started Opportunities Grants ‘,‘ Customer Support Grants gov provides organizations with the ability to search for Federal government-wide grant opportunities The Office of Federal Financial Management recently issued a Dolicy directive C Ddf requiring that all Federal agencies post grant opportunities online as of November 7 To begin your search for grant opportunities, access Search rant C) ortunti s below To register to receive all email notifcations of new grant postings from FedGrants gov, access Receive Grant Ooc’ortunity Notification below Search Grant Oepertunities • Basic Search • Browse by Category • Browse by Agency • Advanced Search Receive Grant Qpeertunitv NotIfic tjqn • Selected Notices based on Fundiri Opoortuni , Number • Selected Agencies arid Categories of Funding Activities • Selected Interest and Eligibility Groups • All Grants Notices 1-JOTES: (“inr ’ p .ie-,, I fi net pr-i rrir-iriri’i InI$\s frir i,ih ,‘ h jrit i va ch r . er ’iriK, c,r ii va Ii riporl tr rnr ’rirrt fh p F. inns nni Internet 6 54AM Gr nts.ijov - itrul tt-ant 00$ Microsoft P Grants o - zj ,,_J ,.L1 ------- Download Application File Eck View F ,.o,*es Tool5 Help ‘ -.-- B6Ck — .) j Seech , jJ Favor es Address JJ https ://epply grents .gov/forms_aplc_ldx hurd AIM - - —. Searcf 4 3 rR NJr 3 . .c3 D\I - JMed%e ±j _* _r4 _J J Co € Pop-Ups ockrd: 0 4 AIM 3Games , Perconaic Gr•ntor Applicant. E8l Aheet U. Ra .ourc.. P.1... IS$ -107 Privacy FAO Site Map Get Find Grant Apply For Started Opportunities Grants Customer Support — ii4flhIe - AI I IJ mr Gr .nte ‘ flnwnln .d *ppHr iinn Pack4vJq, Download Application Package Complete Application Package Submit Application Package Track Application Package Status Access the most requested information an features Select ATop —- -:i Complete Application viIc, c1 F c To download an application package, enter the appropriate CFDA Number andfor Funding Opportunity Number and click the “Download Package” button CFDA Number: Funding Opportunity Number: r — Funding Opportunity Competition ID: Download Packege if you do not remember the Funding Opportunity Number for the grant opportunity for which you want to apply, return to the “Find Grant Opportunities” section to locate the grant opportunity and then return to this screen to enter the number to find the appropriate application package Start Wodcspsce Wor rfe 4crocoft P ‘ r .. ‘ ;i : j - Internec N j 6:55AM Done ------- Apply for Grant Electronically Request lw. In* a1Prdpo kU1 )ñr . R* File Edk View ‘ orIt s Toots Help -. Back - ) _j .. .4Se ch JFa%’ortes JMecila j - ,• 4 - _J j Address htt : //fedgrents .gOV/APPHC8fl IEPA/OGD/GADIEPA-GRAI’JTS- 101 8O4-OQ1/ModlIc tIori1 html AIM . . .Seerch POP-UDS8IOC1 d O A AiM — 3G nes • Percon K - Environmental Protection Agency. Region 10. Office of Ecosystems. Tribal and Public Affairs. Attn: RGI Proposals, 1200 6th Avenue, MS ETPA-086, Seattle, WA 98101 Description The Regional Geographic Initiative funds unique, geographically-based projects that fill critical gaps in the Agency’s ability to protect human health and the environment. Link to Full Announcement eg st for Initial Pro osa ( fiiP) for Regjonal Geographic Initiative_Fundj g ii you have difficulty accessing the full announcement electronically, please contact: Phalen, Dan. Project Officer, Phone 206-553-8578. Email phalen.dan©epa.gov Phae Dan Register to Receive Notification Apply for Grant Eleclronic&ly You may return to Grants Opportunities at: • EPA OGD listed by ( Posted D e ] • EPA Agencywide listed by rPosted D eJ (H i ] ISEARCH synopses ] I o e - ir*ernet Sta t Der Finn Worc% erfo r4crosoft P Request N & % AM L ------- Application Package Forms Fle Ed View Favorites Tools H&p 3 Searth JFmvnrWes JMadie Address j Pttp://applv graflts,gos/opoor ijr-it ie /pecka esfopcEPA-S2S- TEST-cfde66 .513. xfd Al IVI 4$i Pop-Ups uockact 0 .4 AIM Genies .. Personals - . F°°’’1 .! ‘ ?tZI I Cancelj Opportunity Title: Offering Agency: CFDA Number: CFDA Description: Opportunity Number: Competition ID: Opportunity Open Date: Opportunity Close Date: Agency Contact: System to System Databese Environmental Protection Agency 66.513 Greater Resenrch Opportunities Feliowehip Program EPA-SZS-TEST 10/10/2004 12/3112004 o i; rinn;y information Systems Specialist Email: f1nney.dennl* epa.gov ..J I will be submitting applications on my behalf, and not on behalf of a company, state, local or tribal government, academia, or other type of org aniz sti on. Applicat lon Filing Name: Mandatosy Documents Application for Federal Assistance (SF-424) Budget information for Non-Construction Programs (SF-424A) lAssurances for Non-Construction Programs (SF-424B) Project Narrative Attachment Form fEPA Key Contacts Form 57013-54 Move Yorm to Mandatory Completed Documents for Submiesion 5ubmI Ior, Li lt Move Fovrri to 000ufnenS List Optional Documents i Stai War Wa j Mlcr C Gran... I. http-.,.. “S uove rormto Optionet Completed Documents icr Submi ion Unknown Zone 6:57AM - : x ThIs electronic grants application is intended to be used to apply far the specific Federal funding opportunity referenced here. If the Federal funding opportunity listed is not the opportunity for which you want to apply, close this application package by clicking on the “Cancer button at the top of this screen. You will then need in locale the correct Federal funding opportunity, download its application and then apply. ------- PureEdge SF 424 - x File Edit View Favorites Tools He i ______ .3.... Bock • ) J ,_i Search _J Favoy es JMe o ,j ... — J Address http: f/apply. Qrarits .gov/oppOrtuntties/pack sjoppEpA-525-TEST -cfdo66 it 13. vfd ‘ C> Go At M SO a rth Pop-Ups ockad: 0 j AIM - Games , Personals - ).Weattw E ‘OOi lt ZJ G 1 - 1 5 , 2. DATE SUBMITTED pniir 3. DATE RECEIVED BY STATE State Application Identifier Orgenizatlonel UnIt: Legal Name Department: Organizational DUNS. Division Address: * Streeti - - - --- ..- ..---‘ --- — - - Street2: r - City County — * State r Zip Code 6. EMPLOYER IDENTIFICATION NUMBER (EfAJ) B. TYPE OF APPLICATION: .) New j Continuation ,j Revision Start WO,... I Wof .:1MlCr...J Gran.... http . VersIon 9/03 Name and telephone number of person to be contacted on matters involving this application (give area code) Prefix First Name’ Middle Name: r ----——- - Last Name -- Country JUSA ‘ ‘ r’ ” — . ———‘..— -. -——‘ .-.—— _________________________ Suffix V Email’ Phone Number (give area code) Fax Number (give area code) 7. * TYPE OF APPLICANT: ISelect Applicant Type Code Unknown Zone 6:57AM Close Form APPLICATION FOR FEDERAL ASSISTANCE 1. TYPE OF SUBMISSION: Application Preapplication 0 ConstructIon .J ConstructIon , ) Non-Construction . .) Non-Construction 5. APPLICANT INFORMATiON ------- Benefits to EPA Customer Service • Quality of Service • An Application database • Authenticating Users • Standards • Tracking Application to Award to Post Award ------- Five Easy Steps APPLYGrants.gov Find Grant Opportunity Download Application Package • Register with Central Contractor Registry • Register with Credential Provider • Register with Grants.gov £ ------- EPA Grants.gov Application Database - 1GM OGD constructed Grants.gov Electronic Application IGMS Database • Applications Migrate to IGMS Award Module S ------- From the World Wide Web to IGMS [ LJ EPA Web Services Central Data Exchange (CDX) Grants.gov IGMS Award and Post Award EPA Grants.gov IGMS Application Database ------- Goals for FY 2005 & 2006 Execulivi Branch anaçemerit Scoreca a. pcttnm.Qt 0 0 0 Ot c •t- - 0 0 • 0 0 PU ( It 0 oto 00 L.’L’ ‘ 0 0 0 0 Ot otootoo (P 1 ,P. 00000t W ?tLA,O • 0 0 0 0 ‘U) 0tØ oto • OtO IU5Et eo•otc LM C”,’ fQ QQ 0 0 0 0 0 0 0 0 0 0 0 0 0 0000 0000 0000 0000 0000 0000 0000 0000 0000 0000 0000 0000 0000 • Grants.gov Program Management Office Goals • Increased Usage of Grants.govAPPLY • 100% of Competitive Opportunities by 10/06 p ’ 4 ------- 3 ------- 4 ------- 5 ------- 6 ------- Cost Review Presented by Marguerite Pridgen OARM/OGD/Grants Administration Division at the National Grants Conference November 2004 Agenda + basics + examples + resources + questions + adjourn What is a cost review? An analysis to verify that the costs in a grant application budget are: allowable, allocable , necessary , and reasonable . 1-3 ------- Who performs the cost review? When must I perform a cost review? A cost review must be conducted for every project selected for funding. no required EPA form ______ some EPA offices/programs prescribe checklists or formats generally review is done by • budget category and/or ______________ • activity or function What form or format do I use to document the review? Cost rGview chocklist c ch.ck 8aIary ranges verify fringe I benefits veñfy cost of L J I Program u and Grants Management Office 4-6 ------- Which application documents contain budget information? Varies ai Typical documents containing cost/budget information: • application page • budget information form • narrative budget justification • workplan • appendix What may I request from the applicant? A information you to conduct your review A do NOT request • personal information • proprietary information • other information not needed for the budget/cost review A be prepared to explain to applicant why you need the information How do I request budget information from an applicant? A 0MB cleared information collection • program announcement • application kit • other guidance A Directly from applicant after project is selected for funding 7-9 ------- How detailed or extensive must the cost review be? A program office works with GMO to establish guidelines major considerations • extent to which costs are verifiable to supporting documents in application • administrative capability of organization • grant amount relative to size of other grants made under the program • other factors related to organizations financial capability What information do I include in my documentation? A Describe the extent of the review • include protocol/checklist used A Detail the findings • COSTS ACCEPTED • COSTS QUESTIONED • COSTS SET-ASIDE Clearly label revised budgets Focus of program and grants office reviews? Program Office focus. all project costs are identified and verified numbers add up budget espporls workplan budgeted costs not prohibited by ules and .r ts correlate to project benefits _____ neededts meet makes general sense, makes program sense Grants Office focus’ all project costs are dentilied end vented numbers add up, correct categorIzatiOn budget detail matches summary, costs treated same in like arcumstaflces not protribiled by program end admin,strakve ruleslguidance costs correlate tD benefits needed to meet objectives or to administer project makes g.rmral sense Budget srroutd be,. 10-12 ------- What constitutes an allowable cost? lpermitted by statute, regulation, and program guidance I meets criteria for allowability in the applicable jprinciples What constitutes an allocable cost? ‘I correlates to project benefits s/assignable to project I in accordance with relative benefits received I meets the criteria specified in the applicable cost principles KEY TERMS + allowable direct costs + allocable indirect costs - applicable credits = Total Project Cost 13-15 ------- What is an applicable credit? - receipt that offsets or reduces project expenses What is an applicable credit? A Examples: purchase discounts rebates or allowances recoveries insurance refunds adjustments of ovarpaymen ts indemnities on losses BUDGET CATEGO RI ES classiflying costs and income in applicant’s budget 16-18 ------- FYI...budget categories vary depending on the form and instructions an applicant uses... inh. S —W.S CuDnI w ir.w,. Gt M. 35..: -— 5-- , . — — — ad nistr vt — .. . ... - . — - 5 — -S — — 4 — — _ _ programmatic — — _ Let’s discuss budget category classification in the SF-424a. 19-2 1 Budget Categories Budget categories are used to classify each item of cost or income. ‘ 1 — N... , 35 S3 S 5 . Q S -i -ff - I. .__— = ------- Budget Categories The categories used in the standard federal application for non-construction grants are: > Personnel >Fringe Benefits > Travel Equipment >Supplies Contractual Construction > Other > Indirect > Program Income Personnel Costs - costs for labor directly related to the grant program/project namely 1 employee salaries and wages PERSONNEL COSTS EXAMPLE reviewing personnel costs in an applicant’s budget 22-24 ------- $36,667 s OddO Personnel Costs - Is the information sufficient? Executive Director Project Director Graduate Students TOTAL $86,667 Personnei Cost Analysis - Get complete information first! Job Title Annual Tune ’flme lProject Salary Commttrnent Allocation Costs Executive sioo,00dti 1 months ‘ 40% $36,667, Director Project $50,000 l2months 100%I $50,000 Director Computatia . $100,000 x (1 irna e 1 ncmUis) x40% 536.667 $50,000 x (1nontis/12m0fltP )x 100% $50,000 100 /etudnl a 5 students * $l0lhour $5.000(sse neal page) Personnel Cost Analysis - Get complete information first! Job Title EPA State Applicant Project Grant Grant Costs Executive ,0OO $30.767’ $36,667 Director Project $50,000 $0 $0 $50000 Director Five(S) $0, $5000” $0 $5,000f Graduate Students used 10 meet lederal match requirement “compensation br pmject-retated work, no student aid, students hired as temporary employees L Five (5) $25,000 ‘100 hours Graduate Students so 100° , $0 25-27 ------- Personnel Cost Analysis - Check accuracy (computations) Executive Director: $100,000 x (I Imonths/l2months) x 40% $36,667 Project Director $50,000 x (I lmonths/l 2months) x I 00% $50,000 Graduate Students: 100 hrs/studentx S students x $10/hour = $5,000 Personnel Cost Analysis - Check accuracy (category) Contractor vs. Employee • Consider Three Common-law Rules I.Behavioral control 2.Financial control 3.Type of relationship of the parties Consultant vs. Contractor • Consultant employer-employee relationship rpersonnei Cost Analysis - Check consistency 28-30 ------- Personnel Cost Analysis. Check computations Job hUe EPA State Applicant Project Grant Grant Costs $5,000 $900 ’ $30,767 ’ Director Project $50,000 so so: Director Five (5) $0 $5OOcY sot Graduate ‘Students ‘used to meet lederal match requirement ersonnei Cost Analysis Check allowability $36,667 $50,000 s0 Personnel Cost Analysis. Check allocability 3 1-33 ------- Personnel Cost Analysis - Check reasonableness +rn tnumb.rafstsff? Project . Director +CompineationeoniP& ItC ____________ th.rs doMe ImiI wo&.. Graduate Students - ‘ .n onwId.? Executive Director FRINGE BENEFITS COSTS EXAMPLE reviewing benefits costs in [ Iicant’s budget Personnel Cost Analysis - Check necessity 34-36 ------- Fringe Benefits costs for personnel employment other than the employee’s direct income vary by organization Fringe Benefits -j Examples: • FICA • State Unemployment Compensation Insurance • Workman’s Compensation Insurace • Sick leave • Vacation leave • Holiday pay Fringe Benefits - Is the information sufficient? [ E icu ve - Director Project Director Graduate Students I — 44% 26% - 7.65% some benefits are required treated as direct costs when identifiable with a given salary/wage 37-39 ------- Fringe Benefits - Check completeness PE cutive Director Project - Director 44% (Includes healti benefits, annual and sid leave life in irenca: FlCA executive pen on plan) 26% (includes healti benefits, annual and aldi leave, life insirance: FICA:i Graduate 7.65% Students (includesFICA) Fringe Benefits - Check accuracy (computations) Executive Director: $100,000 x 44%= $44,000 Project Director: $50,000 x 26%= $13,000 Graduate Students: $5,000 X 7.65% = $382 Fringe Benefits - Check accuracy (category) varies by organization • some employers include certain benefits as direct costs • some employers treat certain benefits as “indirect Costs” • check with organization 40-42 ------- Fringe Benefits - Check allowability Fringe Benefits - Check allocability Fringe Benefits - Check consistency 43-45 ------- Fringe Benefits - Check necessity Fringe Benefits- Check reasonableness Fringe Benefits - Check reasonableness “How much an employer pays for employee benefits varies widely and depends on the age of the workforce and the structure of the benefits package offered In general, costs increase for older workforces The factors driving the differences in cost by age are the time value of money, employee pay, and rates of health care use, disability, and death Source: Viriat,on of &np oy.e B.n.fit Coets by Age I r n Social Security Bulletin. VoL 63 No. 4 (reles ed September 2001) 1ii J 46-48 ------- TRAVEL COSTS EXAMPLE reviewing travel costs applicant’s budget Travel > employee travel and subsistence which is directly related to the grant Travel Costs Completeness_check _______ [ Trip Information Duration Number & st per staff Total ______________ titles of staff Cost EPA National 1 day 2 RI airfare- $101 $304 Conference on (11116104) (Project perdiem - $51 Water I Director and hotel - nla Infrastructure ” Grad (Boston to DC) student Advocacy and 3 days, 1 RT airfare - $134 $887 media relations 3 nights (Executive perdiem- $153 (Boston to DC) (12/1/04- Director) hotel - $600 L ” 12/3/04 ) _______ • appbcanrs policy requires lowest available airfares unless direct flight is unavailable. appkcanfs policy requires federal ,. government per diem rates “required conference per application instructions “justifications for tnps are on Pages 21-22 of wvrkplan in Examples: > Lodging >Airfare > SubsistencelPer diem >foreign travel, if permitted, requires prior approval by the Office of International Affairs 49-5 1 ------- Travel Costs - Accuracy check (computations) EPA National Conference on Water Infrastructure (Boston to DC): Roundtrip airfare - $101 perdiem - S I hotel - 0 Total = $1 S2istaff 2 staff $304 L Advocacy and media relations (Boston to DC): RTairfare $134 perdiem ($ 51/dayx 3days) 153 hotel ($1 50/night x 4 nights) 600 Total = $152/staff I staff= $887 Travel Costs - Accu racy check (category) A only include travel costs of employees on • travel status, and • official business for the grant project [ :c heck 52-54 ------- Travel Costs - Allowability check Travel Costs - Allocability check R ate-S1 4 4 d m 1 3 1 ot 4€O Travel Costs - Necessity check 55-57 ------- Travel Costs - Reasonableness check R n1at $134 p.td m $15 •1 Equipment • nonexpendable tangible personal property • a useful life of more than one year • acquisition cost equals or exceeds • the capitalization level established by the non-profit organization for financial statement purposes. • $5000 • whichever is smaller EQUIPMENT COSTS EXAMPLE reviewing equipment costs in an applicant’s budget 58-60 ------- Equipment - Types Special purpose • used only for research, equipment medical, scientific, or other technical ac?ivities Examples: microscopes x-ray machines surglcai Instruments spectrometers General purpose • other than special purpose equipment Examples offlc. equipment eomc. furnishings e air conditioners Equipment - Key Terms C p;t i t :.• : ::. expendtt.ir’i foi the Expend iture . I’)f’ SI i ’; .(jU ’ ‘ie”i 01 fo equ ipmcn rr I m) r iaUy F(r0 5. It i iu i? C? :• : u et tiIte . . .. Acqws.tion Cast Cfl ( WWOJCO prLco mcciticaii n. a chrn c P ac eSscne •:•. • • .:::: :: :.. nebJt3Jtu r:i n .1 iN k’ th. rpcsi’ 1c i v -n Wd i .4cqirIU i i •.: • • Equipment - General rules on allowability 61-63 ------- Equipment - Check completeness Description Unit Cost Number of Total Cost Units Multifunction $750 2 $1,500 machine and cable (printer, copy, fax, scanner)* dissecting $500 5 $2,500 scope (20x x4Ox) generai purpose office equipcnentfor Project Director and graduate students; multi-functton machines are required by our environmentally preferable “speoai purpose equipment for graduate students to locate arid reco a macrn-organisms ft m stream b.nthc sem .s (ref worispian. pp. 55-59) Equipment- Check accuracy (computations) Muftifunction machine and cable (printer, copy, fax. scanner) $750 x 2= $1,500 dissecting scope (20x x 40x) $500x5$I.SOO Equipment - Check accuracy (category) N determine if applicant’s threshold for equipment is lower than the federal threshold ($5,000) If yes... items under $5,000/unit should be budgeted under “Equipment” If no..items under $5,000/unit should be budgeted under “Supplies” N determine if this is equipment rental t If yes it is neither Equipment nor Supplies It is Other direct costs’ 64-66 ------- Equipment- Check consistency Equipment - Check allowability ab e Equipment - Check allocability 6 7-69 ------- Equipment - Check necessity Equipment - Check necessity / IF BRAND NAME” PRODUCT IS SPECIFIED... Ask the applicant: Why can only the brand name product be procured’ .Why cant a brand name or equaT’ be sought? ,. Did applicant Investigate wtiether a similar product was available? .Can appI cant describe the salient characterisbcsof the Brand name product’ /1 \/ Equipment - Check reasonableness 70-72 ------- Equipment Costs General Considerations Question: When the project comes to an end, what happens to the equipment? Answer: Program Office tells Grants Office prior to the award how the equipment is to be handled. . Option 1 - grantee keeps equipment . Option 2 - grantee gives equipment to 3rd party .Option 3 - grantee transfers title to EPA N etfl iadI iI1Jt ii , acc citir c ) tule 4 ie , Sup f jnd prqecb h ive cU erthpo & 2 SUPPLIES COSTS EXAMPLE reviewing supplies costs in an applicant’s budget Supplies personal property other than equipment intangible property debt nstruments 73-75 ------- Description Unit Cost Acquatic suction sampler (dimensions 42” Lx2 1/14 ”D)” ” Unit Number Total of Units Cost Supplies - Check completeness Office supplies* $150 person/yr 7 $1,050 $36 sampler 20 $720 ; d::::::t:::::ets or boa, muck (ref workplen pp 55-59) Supplies- Check accuracy (computations) Office supplies (pens. paper. sticky notes staples. are purchased In bulk by the organization and cost Is allocated on a per staff basis; per staff allocation is based on historical records of staff usage: most supplies are made from rec led materials) $1 SO/staff x 7 staff = $1,050 Supplies• Check accuracy (category) • tangible personal property other than equipment, intellectual property, etc. •in this example, supplies are items under $500/unit ZAcquatic suction sampler-dimensions 42” Length x 2 1/14” Diameter (organization competed contract with Telly’s Hydro Company: most testing supplies purchased from this supplier or from small businesses) $36lsampler x 20 samplers $720 76-78 ------- Supplies- Check consistency Supplies - Check allowability Supplies - Check allocability Acquat3 C 3 a. mp r m 4i on 4 1 4 F 79-81 ------- Supplies - Check necessity •determine if unused supplies from any of the organization’s other federally funded projects exceeds $5,000 • If yes..the organization should transfer the supplies to this project, if they are needed for this project, or to another federally sponsored project • If no...the applicant may keep the \ j supplies but must compensate the federal government for its share Supplies - Check necessity Supplies - Check reasonableness 82-84 ------- N .tha1 Supectind prc eth and ether po wns may have her 1 Supplies Costs - P General Considerations Question: When the project comes to an end, what happens to unused supplies? Answer: If total value is under $5,000, grantee can do what it wants. If over $5,000: Option 1 - grantee uses supplies on another federally funded project Option 2 - grantee uses supplies on a non-federal project or activity and compensates the government for its share Option 3 - grantee sells supplies and compensates the government for its share CO NTRACTU COSTS EXAMPLE reviewing contract costs in an applicant’s budget Contractual R mutually binding legal relationship obligating the seller to furnish supplies or services (including construction) and the buyer to pay for them s transfer of grant work to a third party 85-87 ------- Contractual - General Considerations Applicant: + not a straw-party” + substantive role Principal performer of project activities, and/or Primary beneficiary of Federal financial assistance; and/or Overall administrator of the project Contractual - General Considerations EPA: + avoid conflicts of interests + avoid appearance of conflicts of interests +do not exceed authority in conducting pre-award reviews of an applicant’s or grantee’s procurement transactions Contractual - Check completeness Cost Duration $107,500 12 months $84,000 8 months Description Lab testing services Environmental awareness campaign (contractor: Environmental Messages, Inc.) 88-90 ------- Contractual - Check completeness Technical Specifications + request to ensure that the item and/or service specified is the one being proposed for purchase Contractual - Check completeness Other procurement documents Examples: • Requests for Proposals • lnvi tions for Bids • Independent Cost Estimates. etc. ‘ ONLY request under the following conditions Contractual - Check completeness Request other procurement documents if one or more conditions exist: + subs ndard procurement procedures + procurement will exceed simplified acquisition threshold at 4$ USC 403(11) (currently $100,000) and + will be awarded without competition +only one bid/offer was received +‘brand name’ product is specified g + be awarded to other than low bidder + proposed modificiacion to existing contract changc the scope or increases the contract amount by more than the simplified acquisition threshold 9 1-93 ------- Contractual - Check completeness Substandard procurement procedures? 0 Check grantee compliance daubase OCheck Federal Audit Clearinghouses “Single Audit Information Site” ORequest procurement procedures fl Procurement system certification (Superfund projects) flAsk the applicant Contractual - Check completeness No competition or one bid/offer and exceeds $100,000? )j Applicant refers to “sole source” procurement j A specific contractor is named in the application (ask if it was selected via sole source procurement.) Contractual - Check completeness “Brand name” product is specified and exceeds $100,000? Ii Applicant must justify why the brand name must be used O Applicant must adequately justify why only the brand name product can be procured and why “brand name or equal” will not be sought • Dud applicant investigate whether a similar product was available? • Can applicant describe the salient characteristics of the “Brand name product? U Determine if the applicant’s written procedures address when and why a brand name must be used. 0 Proposed contractor - affiliate organization (either non-profit or for profit) or affuIiated with an officer, director, or employee of the applicant. 94-96 ------- Contractual - Check completeness Contract will go to other than low bidder and exceeds $100,000? U Applicant must justify why this will occur. U Applicant must explain how the low bid did not comply in all material respects with the invitation notice. Contractual - Check completeness Contract modification will change scope or increase contract amount by more than $100,000? U Applicant must be advised that modifications may be subject to the same procurement requirements (e.g., competition) as new contracts. Li Ask applicant if a new competition will be held. Li “Modifications are quicker and easier” Not adequate justification - Circumvents competition Contractual - Check completeness Contract Lab testing Environmental Budget services Me age , Inc. 1 ( 12 months ) (0 manths Direct Laboi LAeORATORY TE * L ADE TEC I INCIANS $29Thourx2000 ‘$ 5Qi) tours” $58,000 tv$ ”S500* ) SENIOR ENVIRONMENTAL ‘ X ’: ’: ’, ” SCIENTIST $150ftsourx3O0 s $ 11 rr 0OhrI ” . :3 “$4 , 000 g4.0 A S.rv ic ... •r. :. TESTING method : .:: $45/ les ix . Ies esr t10 tntn ‘$4500 c x $T O0U TOTAL $1 ‘. 97-99 ------- Contractual- Check accuracy (computations) - LABORATORY TECHNICIANS $29/hour x 2000 hours $58,000 .-SENlOR ENVIRONMENTAL SCIENTIST $1 50/hour x 300/hr = $45,000 ...AND SO ON Contractual - Check accuracy (category) Contractor vs. Employee • Consider Three Common-law Rules ‘ I.Behavioral control 2.Financial control 3.Type of relationship of the parties Consultant vs. Contractor • Consultant employer-employee relationship P Contractual- Check consistency 100-102 ------- Contractual - Check allocability war ont a tot 4 áte ttn :::. r: . j a ’ bW Contractual - Check necessity foflmenta Contractual - Check allowábility 103-105 ------- Construction A construction of new buildings, or modernization of, or completion of shell space in existing buildings • including installation of fixed equipment • excluding the Cost of land acquisition and off-site improvements Contractual - Check reasonableness CONST COSTS OVERVIEW 106-1 08 ------- Construction A allowable when the program legislation includes specific authority A usually unallowable cost in non-construction programs Construction Examples of activities/costs: a-Architectural and engineering services a-Bid advertising a-Bid guarantees, performance and payment bonds a-Contingency fund a- Filing fees for recording the Notice of Federal Interest a-Inspection fees a- Insurance (e.g. title insurance, physical destruction insurance, and lability Insurance) a-Legal fees related to obtaining a legal opinion regarding title to site a- Preaward costs (e.g. costs incurred before in award for architects fees and consultants fees necessary to the planning and design of the project) management a- Relocation expenses a-Site survey and soil investigation Reviewing Construction Costs J Perform cost review on each item in budget j Review the cost and profit summary of each subagreement :j Ensure EPA’s interest in construction or facility improvement is adequately protected through contract language : J 109-111 ------- Other Direct Costs direct costs that don’t belong under the specific budget categories for direct costs Examples .- insurance space rental - equipment rental printing - publication computer use training fees - utilities - telephone 4” J _J OTHER DIRECT COSTS reviewing other direct costs in an applicant’s budget 112-114 ------- Other Direct Costs Perform usual checks on Other Direct Cost i tern: complete consistent accurate allowable allocable necessary L reasonable overview •joint or common costs benefiting more than one project or activity • not easily assignable to one project or activity INDIRECT COSTS Indirect Costs 115-117 ------- Indirect Costs EXAMPLES: Utilities, rent and depreciation Accounting and Legal President, VP and corporate staff - Personnel/Human Resources - Fringe Benefits such as: Payroll taxes What is an Indirect Cost Rate? •computed rate U applied to a cost base • used to allocate indirect costs to benefitting direct costs FORMULA: Rate = PooI!Base Common Indirect Cost Rates formulas FRINGE BENEFITS (Fringe benefits/total labor) OVERHEAD (Overhead/Direct labor and applicable fringe benefits) GENERAL AND ADMINISTRATIVE (G&A) (G&A expenses/a base that represents total [ nvit of the organization) • Annual and sick leave • Medical Insurance • Disability Insurance 118-1 20 ------- T;poflndfrect Cost Rates Povislonai rne • tançorsry ledirect cost raw applicabk to a ipuc md period +used for fundfsg. euarwn reunburawuu. and ricororix indirect cons on Fed.ral awards psndmg the us bkshanurnt of a feiar race for that peno Predeternsin.d rate •applirable to a sp.clf Ied current or future period. usually the orgisuzitlons fiscal year +bases øii air .isimate of tias costs to ho Incurred durm the period +usushy not sutr$ect to adjustment + not permitted for F.d.r l contracts FDcsd ratr +lus the eimdar tharacteristics as a predetorenmiad rate + the ddference between thu estinated costs and this icwiL ihowsble cons of the period covered by the rate Is carried forward as en a wunenI to the ret. computation of a sikssoquairt period FineJ ret* +applicableto & apeclf ,ed put period whidi is based c l i the ictus; allowable costs of the psrio4 • AfIsrsJauditedrateisnccsi*4ectwad ustsnwrt. What gives EPA the authority to negotiate Indirect Cost Rates? ‘ 0MB Circulars A-2 I, A-87, A- 122 Federal Acquisition Regulation 42.7 How does an applicant get an Indirect Cost Rate? grantees, not applicants, follow the instructions in the grant term/condition submit the required documents 121-123 ------- How do I get copies of rate agreements? approved EPA agreements are posted to DHHS’s Division of Cost Allocation website: http://rates.psc.gov/fmsL ’new _ Se rch html Indirect Costs Example A grant budget contains information about the indirect cost rate that applies to the project. Indirect costs are at a rate of 24.2%, and have been approved for grants, contracts, and other agreements with the Federal • Government. SAMPLE RATE AGREEMENT NO R T T! A LMLNT 0*11 J . 1. 2G0 ORGANOA11ON ,ILPI0RE 1Mp,.,. AI C. ,l” RI ,. ‘, ..e . . ’. e . .u —.— . . , ‘o 5!C11 1 I R40 tCT COlT M105 RAl! IVPt$; TPX FINOL PROW IPROOlSIONAL) P120 IP4EOWOWRMP4fD P?PRCTIVI PRINIIO T I F F FROM TO RAT!I%I LOCATIONS APPIICARWP 10 FINAL 414102 120112 242 *4 AIPPY$RS 10.1 IN. ,l I .*M4 1 5444I0J 1 41 144 5 1 1141*414 . RAMAO$I#IN IS SW 124-1 26 ------- SAMPLE (PAGE 2) LflNtG TAGS C .s . .s.AA.. I. , . Nn. E,TTS......TS ,‘—A CN..y. F.; Eaa!y,nGA.T.Tj AGEGEMENT DATE Ass. A. SEA S SECTIONS SPECEAL EGIANHES I SAMPLE(PAGE3) SECTTEAN ARSENA l A LERGETSOIIS. Tb. nN hi.. Afl ARNTI SER $I5bT*( T N. E SMWt !y ...ANAA.va.. S.AS.y. R Id ppM . , • iTR NM. RET — *SE SJRRRNS 5I IS *.... ,*s.Nats. .ssflNk&.sNs..MNS.a .NSNN SW.T. (T(OTIp.Ntn fldbyGMRT5atuN. TshISdHdMGINARINt NG5 SflA .bNpba., MA.. .Tps SaNsS MA ITGIS SNIbIG smdwt. p,yfly .;Iyp.. .4 b ..A. ....S.d •sss a TOT 5 TTGSRIEG: MA 1 4 I Tb. GGSSESSST po sdS by AT S •T •MSsS RhAb.., n SA 5. M.bbfl .$y TMSS 4 y.TINyTPNSEA S. A. .Ndhs RpIs. D.MR.A.s sRIRs.hsssS •h. S.yy B. Tat(s) ...Id A. .sb)..T.. ;.s.y.lS.;ssSl S. dA.nb.. yTN..FydyS G.y.yyy..TTI. B ACCOASATEIG CHANGES T IS NAyySIN S5st NSs isyN. pflNTNAbySR sTIa !sIS s ,S A. .E..TAsAN..S.A.,...NGMC.t CA..y.. SGRBN •AGIIGta5TUflIGTtG TG NNANSTSEIyTGAR.SNM ..,.py..,.I.4S..sEaCS.S..y4....UNs..TS.sNGS .GsG SENAT S SOTETNT R.. STNA SA ANTIT ITSTTSANA .d(.GA 5NyGNh Nn.b.Tr.wspn.assMp..4S..;ESRASNITNGRTNSFSST. SAMPLE (PAGE 4) C ElABORATES 41 ..yu TT HA pGGGA ..T.T.AbT GIG ‘tT. NT I S , lbs I T s. p VIsA .T.ASR b..d. ,. . .s S E . 1 1 bNG H I M .4. Gas.. y..TT S) I. .s.p ssIS 4.4 N. AEA...ss. bSE...S...,T.s..dI..,SAbISbThs N..dDA .ad ..SssI G 0EAs ØMss...., ,. ,dE .d TCA.. . ,A122 C .S. ;, ..d .h. .S A. .yyNS.. p oT tS. .4TVyTSy tAG yU..s gT.GENRS s..VMAby 412 CETA.T, sAIGsI, SSASS T 4* sb... Tb. .T5.RSISN.TRty pTyTIdy.ypHy .4 4s. Ayn..at By TAT ONQAHISS COT. OI l BEHALF OF THE FEOGRAL CMI.STS.I T. . E s ESTVRINAITT (G.S CN..T. F. E.T S T. s .s. . .sA DEPARTMENT OF HEALTHANO 55555*55 SEA S ICES A GE NC T SIGNS CARE) IS) OaSIS. L.. FlAME) ORECTON. OFIIS)ON OF COST ALLOCATION (TITLE) (OSTE) TN t (GA GA N RA C SEA) )SIGIASTLMG) RI (TITLE) (DATE) TREATMENT OF FRINGE F*FTTS TREATMENTS? FANSEJENCES AMass. N.Adw. NAN I *s p ly MAGESRI pAd StGM. ITI)T.)sdydD 511155.5 .11 T..NISSN.S,TAEIflN SNTNGNE)GTt, SB.’.5y . (EIGGGpNA IN.GES.S s ..TEsds OEF)NITTODA OF HOLINSIANT Eq.dpmwR). ASH N MEy I A I ..S.A..y.l..TA psopfl N 1sM $ stat) VyVI Thy T.N..M T5t . ANI$ITTI —. E M.A F)CA. SQ l. SO). MONGERS COMFEN’SATIOTI. AMA HEALTH RISAITLANCI 127-1 29 ------- Reviewing Indirect Costs O Verify that the recipient has indicated how indirect charges where calculated l Verify that there is a copy of the indirect cost agreement 0 Verify that indirect costs do not exceed what Is approved by the Negotiated Indirect Cost Agreement D Determine whether the recipient is charging directly to the project costs that are normally treated as indirect costs, such as heat, light, rent, or general and administrative costs PROGRAM INCOME overview Program Income gross revenue earned by a recipient from activities in which costs are earned as result of the award 130-132 ------- Program Income â EXAMPLES: Registration fees collected • Income from the sale of products produced under a grant • Rental fees generated from equipment purchased with assistance funds I Reviewing Program Income P RE-AWARD COSTS AND COST SHARING overview U No profit allowed unless there is a specific statutory authority allowing profit t Explanation of how the income will be used - used to determine disposition instructions : 1 133-1 35 ------- PreAward Costs o costs incurred prior to the effective date of the award o directly pursuant to the negotiation and in anticipation of the award o necessary to comply with the proposed delivery schedule or period of performance o in conformance with the appropriate statute and cost principles Pre-Award Costs •Considered on a case-by-case basis •Applicants Incur pre-award costs at their own risk • For nonprofits. generally allowable with approval (40 CFR 30.28) • For states generally allowable with approval (40 CFR 31 .23 and GPI-00-02) •Some programs like Superfund construction grants have other requirements Cost-Sharing - that portion of the program costs not borne by the federal government 136-1 38 ------- Cost-Sharing - May be required by statute, regulation or program policy - Only allowable costs Generally funds awarded under assistance programs of other Federal agencies cannot be used to meet match Maintenance of Effort * Recipient must agree to contribute and maintain a specified level of financial effort for the grant from its own resources or other non-Federal sources o May be required by statute, regulation, or administrative policy o May be limited to a component of the grant activity o Condition of receiving the federal grant funds o Supplement not supplant REFERENCES AND TOOLS information related to cost review 139-14 1 ------- EPA Policies* (htqrJ/lntranet.epagov/ogdlpollcyll.OGPI.TOPk O.htm) Assistance Administration Manual (AAM) 5700* Cha t 2. lcltrdcaj Rr.4,o of Proposals . Seolon Sb(R)(b) Clopter 13. Oateielitaeor CoOs Clrepeer 21. Procu,,eeaei L edarAaWaoaec. a- Cloptar fl. Coil sed Pun. M.tyils Chapter 25, Piogmm a- Chapter 27. Fleol Propsety Aoqol.l lIoo Some of Ire.. documents ountain outdated provuseons and are in Pu. process of bo*sg res*eed. Contact a HG grants poley ep .oal .t .eUstance is needed EPA Policies* (htWJ ,lmtran et. .pt.govIogd!poUcyF7.O GPI .T0P1C u.htm) Grants Policy Issuancest: a- GPI.OO-OS. Cnnt Reel.. Goldan& a- GPI-O3.02. Grsnts Potcy latuance for Consultant Fees a- GPI-02-02.Gridance Eqt.aprruent Acquired Under Assistance Aleenents a- GPI .94-03. FPA kdirect Cost and Speasi Rate PoIcy for Grants and Coøpeedve Aireemants fr.wvded to States and Locel Govern .rents p GPI-95-Ol. EPA hufirmct Coat and SpatIal Rate Policy fo. Crates and Coopatsisne Agreements snowuled to Nonprafit O.ganludoee and EdUCIIIOu .aI inetitudour? °Soen. of Pr... documents cotter outdated provedoni and are in the proceas of being anteed Contact sHO grants polCy 8peaail ei if asaictance a needed Cost Principles * E 1TY TYPE CITATION T WEB CDRESS Educabonsl 0MB Carcular A-21 ht //wwwwbitehOUSe g Ins ttut ions pv/omb c irojlgrs / State. Local, and TOMB Circular A-57 _________________ Indian Tribal Governments Nonproft Or anizabons 0MB circular A-I 22 trttD/kvww whitehouse o ov/or ltFctroilES/ htlP’/tNWW whttetlOuSeG ov/ornti/ctrcuIarSI Commercial Organizations Hospitats FAR and 48 CFR Part 31 45 CFR Part 74, Appendix E ht ./ Nww amer GOv/tar/ Searth at httu://www,UCC 3 es s.0 0 0uovklUra/Cfr/Cfr-t abIe-seerch htmiPpapel Some organlzaicels rosy be exempt torn aorta of Us. requirements of the cost pnncplee -see sects document for none infonnabon 142-144 ------- General Resources on Cost Review Competitive reviews Cognizant Agency and Other Program/Grants Staff A Guidestar A Associations Examples: N . C . . d .IN .,p *A.. .aUec P4CNA) Aic iIic 04 i...4. 04 Mu.&ic. A.4 Aveflice W.uv A.c vaUce MU ,.. We. Ae.ly.. A...wi. . ______________ Resources on Personnel and Benefits Costs l v Previous appi icatioris (C . . . . i . a,y u .Wraiei bc .i.d .U d . o .s ve . br I. .o dy kAvvdtr,d q.plkitUc’c fro.v U. v eO O . .’) s°Similar organizations (c.mp.. cb.dg.sed lth d.o .s .pp. .U l v .ch . , spp$ca .ses lv . .. od ..r . .pvlz .C .rn) b-Bureau of Labor Scausucs National Compensation Survey (.inw . s d. c . by woek.r ct .r .co.r uc . .sd sic.bbslwnsnt th .v .oiccsdcu sod by .e sploc ic-cc) Bureau of Labor Statistics- Occupational Employment S sicsr .. . .i .m .spky. .cd . s . I.. 754 .cc çsv.cc sod 400 .ds UdccoI c. l. do. .cDs pUs .oel .ccd dics js. mph& Employment Standards Adminisu -ason Wage and Hour Division o..— . sop ‘ 0 _____________ b-National Science Foundation (c h ines and En.nssnni Woridorc.. b -AucoinatiCData Processing, Inc. (pinball ru.opseyd .crprovld.ca to dinaceg .4cm lv na . Amid) lv Guidescsr pc-co. -soopv .0cc .d.,c lvdccwpcci4 c .uU . s vipicolana I p) Resources on Fringe Benefits Costs b-Bureau of Labor Statistics b-hctpiUY bi Qv/i csLeb i/For!w .bsm Employer Health Benefir.n 2004 Annual Survey l v- Kaiser Family Foundation and the Health Research and Educational Trust conduct an annual national survey of employers of all sizes htwj/www,kffora/insursncei7 I 48/index,cfm b-Employee Benefit Research Institute (EBRI) 145-147 ------- Resources on Supplies Costs . Sources of Cost information: • Green supply store catatogn (h // .ea1oWs2/srorama/Lr!Pflc sUrt “• • Specialty supply catalogs ( ançie i’n -ii ly • Supply store catalogs (exan Ie: http;llwww.n ki,cotn ) • Applicants cost analysis • Search engines http:flwww.thoma xn et.COril http://wwwfiobIlSpec.cOm( Source of supplies for applicant: General Services Administration (surplus property) ______________ - &&AacL r ij Jjg T xErivlronm.ntalty preferable purthasnsg rrlghtbe nor, rperreve. but cuneietent wIth EPA fusion and no orrxl ranl larrnx and condibons Resources on Travel Costs A Applicant’s policy (from applicant or applicant’s website) A Grants office site visit or desk review records A Travel reimbursement policies from similar applicants for use L’ Companson (NOTE many travel policies for states agencies and colleges/universities are available on the web) Resources on Equipment Costs - Sources of Cost information: • Green supply store catalog? • Specialty supply catalogs exa? e h Jfwww.rscldY.co nI • Supply store catalogs (example: fg i wwwstIples.ComL ) • Applicants coat a alys s • Search engines hctp:/Iwww.thornasnetCOm http:/Iwww.globslspeC.COm) Source of equipment for applicant General Services Mminixtration (wrplus property) 148-150 ------- Resources on Contractor Costs Resources for personnel. beneiu. travel. supplies. etc. would also be useful In reviewing contractors costs .s In determining whether you are dealing with a 1 contractor ’ cost or personnel” cost, refer to: • Independent Contractors vs. Employres http:Iiwww f,9O,hpnl , Determining it s plicants procurement system is sub s ndard: • FodIru Adt Clearinghouses Single Audit Information Sit.. • An entity search in the databese at http:Ilharvester.census .govlsacidissem/entity.htinl will providr summary report of findings Part III of the summary p information will contain a key to compliance problems, such as procurement. related so any questioned costs Resources on Contractor Costs Wi ruar i ,ee.een iarQ l ew n nuone1 *ttu smsuS$beao — .,-w. ne’. ‘aa ’eveeares wt .4 C Rei.w, up .r ’ , en L :T:: innu1w5I.csL S, I ____________________ ins. 4 151-153 Resources on Construction Costs a Some guidance available from US Army Corps of Engineers • contact your HO grants policy specislist or • go to website http;f/www.usace.army.millpublications / ------- Resources on Indirect Costs Quicldist of Information to be included in lnd,rect Coot Rate Proponak from Non-Profit OrganIzations A coot rate proposal a 2.A reconciliation of the proposal to your audited risanciol wcen saou a 3. Lot of active grants during the period Iz t allow for indirect costs, any A 4.A scheduls of indirect salaries stiowing sanpkiy.e sante. thin, amount. and a bref descr tion of dutim performed a S.A scI dule of freige benefits and payn-oll sa s by type and amount a 6.A schedule of total insurance (other than h&th insurance) charged in the proposal by type (lee. disability. wor+rrn co.op. general leblinty. fidelity etc.) and amount 7 .A schedule of aN subtontracU ocer $25,000 . 8.Organrnoeal budget for the next fiscal y r 9. D rrectatloin schedules Iist assets, their costs, d sreclat ion method, accumulated depredatiolt Also mdcat. witch stew ware purdsued or reimbursed with Government funds a I 0 A sample of thnesheets to be daterminod during the review Resources on Indirect Costs US DEPARTMENT OF HEALTH AND HUMAN SERVICES. PROGRAM SUPPORT CENTER, DIVISON OF COST ALLOCATION, ‘ to search for rate agreements online go to h pi/rates.psc . govlfms/dca]new _ search.htm l TRAINING commonly used sources ‘1 154-1 56 ------- Training Resources EPA Project Officer Training • htts nlluitutepa o iogd/i . 5-kia Tra.rrt kedir htm ei I Non-EPA Grants Management Training • USDA Graduate School • Management Concepts lncorporatcd CONTACTS a short list of contacts Key Contacts - Listing Regeonal or Headquarters Grants Management Office S ht ://www.epa.govIogri/gr nts/regiomIh m Headquarter Grants Policy Specialists (OARM/OGD!GAD/PITB) • INDIRECT COST RATE HELP DESK (Grant Rec ients): Mvla Slrepperd Puley, ln(unnauun m d Trvn.ng Branch Grants A*nnstrauun Dt ,n OfrJ 1M/Office c’ Granu nnd Dcbu,menc st tsppard.m a1I Jeça ,.g cc INPORMATION COLLECTIONS (Grant Related); WIN.mnr Nedtn Pt4.cy, lnfunnauucc and Traann 1 Branch Grna , Aan.rnnrauan Dactasun OAMM/Offic ol Granu and D.Wmeet h.dng ccLa tctffptgcct 157-1 59 ------- QUESTIONS (see CONTACTS list) 160-1 62 ------- 7 ------- Attachment 3 Draft EPA Order on Assistance Awards to Non-Profit Organizations o Developed by an Agency-wide work group, including representatives from Program Offices and the Regions. o Responds to Congressional, GAO and OIG concerns that 1) EPA is awarding grants to non-profit organizations that lack administrative or programmatic capability; and 2) EPA is not taking corrective action against non-profit organizations that fail to comply with the terms and conditions of their grant agreements. o Programmatic Pre-Award Reviews for Non-Competitive Awards. Program Offices must assess programmatic capability of all non-profit applicants before sending a funding package to the Grants Management Office (GMO). o Administrative Pre-Award Reviews for new Non-Competitive Awards> $200,000 Non- profit applicants must complete administrative capability questionnaire which GMOs will review. Applicants found to have the necessary administrative capability will be certified for four years. During that period, no additional questionnaire reviews are necessary unless there is adverse performance information in the Grantee Compliance Database. The Order also provides for a re-certification of administrative capability based upon a review of the Grantee Compliance Database and pnor performance. o Administrative Pre-Award Reviews for other Funding Actions GMOs must review Grantee Compliance Database for capability information. o Competitive Grants All competitive grant solicitations must contain a programmatic capability ranking factor(s). Non-profit applicants selected for funding will be subject to a review for administrative capability similar to that for non-competitive awards o Where GMOs identify administrative capability weaknesses, non-profit awards generally cannot be made until the applicant has taken satisfactory corrective action In limited circumstances, EPA can make the award with special conditions prohibiting the applicant from drawing down on grant funds pending corrective action. o Post-Award Non-Compliance: Award officials must take available remedies under grant regulations when non-profit recipients are in material non-compliance with grant terms and conditions. GMOs and Program Offices must also notify the OIG and the Suspension and Debarment Division if they have concerns over the integrity of a non-profit applicant or recipient o Policy applies to Congressional earmarks, but requires advance consultation with the Office of Congressional and Intergovernmental Relations and the Office of the Chief Financial Officer. Anticipated effective date - January 3, 2005. ------- Appendix A The Environmental Protection Agency (EPA) ofJ el1eral Regulations, Title 40, Part 30, Subpart C to assess the adequacy of administrative management systems. The regulation can be found on EPA’s website at http://www.epa.gov/ogd/grants/regulations.htm . If your organization is being recommended for an EPA grant, and your organizational policies and procedures do not fully cover the areas outlined in this document, revised or new policies may be necessary to comply with Federal financial management standards. Instructions: Check the appropriate box to the right for each item. If your organization has written policies/procedures that meet the requirement, check the box under the “Yes”column and provide a paper or electronic copy of policies/procedures, an A-133 audit report, or other evidence that your administrative systems meet the following standards. If your organization does not have written policies/procedures that meet the requirement described under this column, check (1) the box under the “No”column and explain in the box or in an attachment. Yes (policy/procedure or other supporting document is being submitted with this checklist) No (explain) Financial Position and Cash Management 1. Cash Requirements. The procedures must explain how the organization will minimize the time elapsing between the transfer of funds and disbursement of funds. 2. Budgeted and Actual Expenditures. Procedures must outline requirements for comparing actual to budgeted expenditures. Comparisons are usually performed at the close of each month, detailing cumulative incurred costs to date for each budgeted line item. Significant variances must be reviewed to ensure actual costs do not exceed budgeted amounts for the grant period. 3. Annual Audits. If applicable, procedures must detail requirements for an annual audit, to be performed in accordance with 0MB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. A non-Federal audit is required if, during the fiscal year, an organization expends a total of $500,000 for fiscal years ending after December 31, 2003. Accounting_System_(Accrual or cash basis, manual or automated system) ------- Instructions: Check the appropriate box to the right for each item. If your organization has written policies/procedures that meet the requirement, chec un “Yes”c,t 1umn a 1 d ro i p or electronic copy of policies/procedures, an A-133 dit re rt r o r evi u ç that ur dmin s rative systems meet the following standards. If your orga ation es n t ave wr t to olicié pr cedur s that meet the requirement described under this column, ec th o de the” “c n and e am in the box or in an attachment. Yes (policy/procedure or other supporting document is being submitted with this checklist) No (explain) 1 General. Policies must include a description of the accounting system, including cash receipts, general journal, disbursement journals (if used), general ledger and cost accounting principles A double-entry accounting system capable of identif ring expenditures to the Federal grant must be maintained, together with a chart of accounts. 2. Indirect Costs. Policies must describe any existing or planned indirect cost rates (if applicable). The policy must disclose the type of rate or rate(s) used, as well as the content of pooled expenses and the type of allocation base used to allocate cOsts. If all costs are charged direct, the accounting system must adequately track and consistently apply costs to specific cost objectives. Internal Controls Internal controls are necessary for ensunng the efficiency and effectiveness of operations, for safeguarding assets, and for ensuring the reliability of financial reporting Some areas to be covered include the following. I. Cash Receipts. Procedures must provide for adequate separation of duties for receipt and deposit of funds. The individual who opens the mail and receives checks must not be the same person who makes the bank deposits. Policies must include procedures for logging incoming mail and reconciling with bank deposits. When funds are received via electronic funds transfer (EFT) the grantee must have a process in place to ensure appropriate funding sources arc credited with the funds. 2. Bank Reconciliations. Procedures must provide for monthly bank reconciliations. The person performing the bank reconciliation must be different than the person depositing or writing the checks ------- Instructions: Check the appropriate box to the right for each item. If your organization has written policies/procedures that meet the requirement, ehe hl çun “Yes”cj imn i4e-a p or electronic copy of policies/procedures, an A-133 idit re p rt 4 9 . h r evi L that ur dmin s rative systems meet the following standards. If your organ 1 i ation es np fi ve pr cedur s that meet the requirement described under this column,jl cj (j1 t x ‘ der”the and e p am in the box or in an attachment, Yes (policy/procedure or other supporting document is being submitted with this checklist) No (explain) 3. Cash Disbursements. Procedures must provide for maintaining copies of supporting documentation for all disbursements (including EFTs), for controlling blank checks, and for approving disbursements Policies must outline the number of required signatures on checks, as well as signatory authority designations. Significant disbursements (over $1,000) normally require more than one signature. 4 Credit Cards. Policies must describe internal procedures used to control the use of organizational credit cards Procedures must be established to control access to credit cards and prohibit personal expenditures. Policies must also require approval of expenditures, documentation of amounts charged, and limit the amount and type of expenses that can be incurred. Written policies and procedures must provide guidelines for personnel travel, procurement, property control, and the use of consultants. 5 Personnel. A Personnel Manual must include written procedures for general employment, such as hinng, dismissal, hours of work, employee benefits, and available paid absences. Both the amount and type of paid absence, as well as work requirements for earning paid leave must be detailed. 6. Timekeeping Written procedures for time and attendance must include identification of time worked on specific projects (job cost system), as well as paid time off, employee signatures certif ring to the accuracy of the time sheet, and supervisory signature approving time charges. ------- Instructions: Check the appropriate box to the right for each item. If your organization has written policies/procedures that meet the requirement, chec un “Yes”c,Ilumn a1 d i pjaP or electronic copy of policies/procedures, an A-133 dit re rt r o r evi ‘ c’i that ur dmin s rative systems meet the following standards. If your orga i ation es ye wrt4eiIi oIici s pr cedur s that meet the requirement described under this column, eck th ox de + ‘co mn and e am in the box or in an attachment. Yes (policy/procedure or other supporting document is being submitted with this checklist) No (explain) 7 Travel, Procedures must ensure that travel expenses are both necessary and reasonable. Policies must comply with the Hotel/Motel Fire Safety Act and document management control over travel expenses, dollar limitations for mileage, meals and lodging, approval by supervisor prior to travel, approval of travel vouchers, and documentation required for payment. Airfare must be limited to coach fare, and car rental must be limited to compact or mid-sized automobiles (exceptions must be justified). 8. Procurement. PoiLcies must document review and approval procedures for both small and large dollar purchases. Policies must identify dollar limitations; documentation procedures (such as the use of purchase requisition and purchase order forms); the procedures used to ensure cost reasonableness (i.e., competitive bidding, cost or price analysis, etc.), affirmative steps that will be taken to ensure opportunities are available to small and disadvantaged business enterprises; and a statement of preference for the purchase of recycled products pursuant to EPA’s guidelines (ref: http://www epa.gov/opptintr/epr/index htm). 9. Property Control. Property management procedures must establish the basis for accountability for all equipment. Property records must include a description of cost, purchase date, source of funding, location and condition In addition, the procedures must define the frequency of the physical inventory, which must be done no less frequently than every two years; the requirement that all property owned by the Government must be tagged; and a control system to ensure adequate safeguards to prevent and insure against loss or theft 10. Consultants and Subcontracts. Procedures must document the nature and scope of services that may be outsourced; a requirement to evaluate in-house before obtaining external assistance; the required selection process; and a requirement for ensuring the reasonableness of cost. A grantee must address the use of specialized consultants on EPA awards to ensure they are following the salary cap limitations detailed in 40 CFR 30 27(b) ------- Instructions: Check the appropriate box to the right for each item. If your organization has written policies/procedures that meet the requirement, che or electronic copy of policies/procedures, an A-133 systems meet the following standards. If your orgai meet the requirement described under this column, the box or in an attachment. Yes (policy/procedure or other supporting document is being submitted s’ith this checklist) No (explain) 11. Conflict of Interest. Policy guidelines must be established to avoid and prevent conflict of interest situations; policies must reflect State and local laws, and must cover financial interests, gifts, gratuities, favors, nepotism, and other areas such as political participation and bribery. 12. Drug Free Workplace Policy. The requirements of the Drug Free Workplace Act must be included in established policies. Submit questionnaire with documentation at least 60 days prior to your proposed project start date to [ EPA EMAIL ADDRESSI . If you do not have internet access, fax the questionnaire and documents to (202) xxx-xxxx, or mail to the following address US Environmental Protection Agency (EPA) [ MAILING ADDRESS] Attn: [ NAME OF CONTACTJ Applicant’s Authorized Representative: Name ______________________________________________________________ Title _________________________________________________________________ Signature *1f the signed document is submitted by email, it must be submitted in a computerfilefor,nat. such as Portable Document Format (PDF) developed by Adobe Systems, mc, that allows authors to exchange documents among different computer syste ns. while preserving the documents’ typography and page layout ------- I I’1A DRAFT - 10/12/2004 rM — w — — — — — — — — ——---— — — — — — — — -- — — — — — — Classification No.: Approval Date: EPA Policy on Assessing Applicants for Capability Assistance of Non-Profit Awards 1. PURPOSE . This Order establishes internal controls for determining the administrative and programmatic capability of non-profit organizations applying for EPA assistance agreements. This Order also enhances post-award oversight by requiring EPA award officials to take appropriate remedies against non-profit recipients that matenally fail to comply with the terms and conditions of assistance agreements 2. AUTHORITY . The authority for this Order is 40 CFR Parts 30 and 32. 3. BACKGROUNI) . EPA assistance awards (grants and cooperative agreements) to non-profit organizations are an important mechanism for delivering environmental protection to the public. EPA’s Office of the Inspector General, however, has issued numerous audit reports documenting instances of non- profit recipients that have inadequate administrative systems to manage EPA funds or lack the capability to successfully perform the project scope of work. The Office of Grants and Debarment has identified similar issues in conducting post award monitonng activities. Recognizing that it is preferable to address such issues before, rather than after, an assistance agreement is awarded, this Order prescribes uniform pre-award procedures for evaluating the administrative and programmatic capability of non-profit applicants. II also establishes uniform post-award enforcement procedures for addressing a material failure to comply by non-profit recipients. Taken together, these procedures further Goal 4 of the Agency’s long-term Grants Management Plan, “Strengthening Oversight”, by helping to prevent or rectif ’ financial mismanagement or poor performance by non-profit recipients. 4. REGULATORY FRAMEWORK . These procedures are based on existing regulatory requirements. Specifically, 40 CFR § 30.14 ------- authorizes EPA to impose pre-award conditions on a non-profit applicant that has a history of poor performance, is not financially stable, has a management system that does not meet the standards prescribed in 40 CFR Part 30, has not conformed to the terms and conditions of a previous award, or is not otherwise responsible. Further, 40 CFR § 30.62 provides EPA with remedies to deal with non-profit recipients that mismanage assistance agreements either administratively or programmatically. Finally, under 40 CFR Part 32, EPA may suspend or debar non-profit applicants or recipients that pose a serious business risk to the Government. 5. APPLICABILITY AND EFFECTIVE DATE . a. The requirements in Section 8 (a) of this Order for assessing the programmatic capability of non-profit applicants apply to all funding recommendations/decision memoranda for non- competitive awards submitted to the Grants Management Offices on or after January 3, 2005. b. The requirements in Section 8 (b) and (c) of this Order for assessing the administrative capability of non-profit applicants apply to funding recommendations/decision memoranda for new non-profit assistance agreements, incremental funding actions, and supplemental funding amendments submitted to the Grants Management Offices on or after January 3, 2005. c. The requirements in Section 9 of this Order regarding the evaluation of applicants for competitive awards apply to competitive announcements issued on or after January 3, 2005. d. The requirements in Sections 10, 11 and 14 of this Order for Suspension and Debarment referral and post-award remedies apply to EPA’s management of all non profit assistance agreements in effect on or after January 3, 2005. 6. POLICY . It is EPA policy to make assistance awards to non-profit organizations provided they have the administrative capability to safeguard EPA funds and the programmatic capability to perform the proposed work effectively. Further, it is EPA policy to address, to the maximum extent practicable, deficiencies in the administrative or programmatic capability of non-profit organizations at the pre-award stage. Additionally, it is EPA policy to promptly address a material failure to comply by non-profit recipients, including, where appropriate, refemng them to EPA’s Suspension and Debarment program for possible action under 40 CFR Part 32. 7. DEFINITIONS . a. The term “administrative capability” means the capability of an applicant or recipient to develop and implement administrative systems required by 40 CFR Part 30, including systems related to financial management, property management, procurement standards , financial reporting, record-keeping, and submission of administrative reports/certifications for grant closeout. —2— ------- b. The term “programmatic capability” means the technical capability of an applicant or recipient to successfully carry out a project taking into account such factors as the applicant’s (i) past performance in successfully completing federally and/or non-federally funded projects similar in size, scope, and relevance to the proposed project, (ii) history of meeting reporting requirements on prior or current assistance agreements with federal and/or non-federal organizations and submitting acceptable final technical reports, (iii) organizational experience and plan for timely and successfully achieving the objectives of the project, and (iv) staff expertise/qualifications, staff knowledge, and resources or the ability to obtain them, to successfully achieve the goals of the project. c The term “non-profit organization” means any corporation, trust, association, cooperative, or other organization which (1) is operated primanly for scientific, educational, service, chantable or similar purposes in the public interest; (2) is not organized pnmanly for profit; and (3) uses its net proceeds to maintain, improve, and/or expand its operations. The term does not include colleges and universities as defined under Office of Management and Budget (0MB) Circular A-2 1; State, local, and federally-recognized Indian Tribal governments; hospitals; and organizations considered as similar to commercial concerns under Attachment C to 0MB Circular A-122. d. The pre-award threshold is the dollar amount of the federal share of an assistance agreement above which a pre-award review for administrative capability is required for an individual award under Section.8 (b) of this Order. The pre-award threshold for calendar year 2005 is $200,000. Based upon a review of the effectiveness of this Order by the Office of Grants and Debarment, the Assistant Administrator for Administration and Resources Management, or designee, will determine the pre-award threshold for subsequent years e. The term “Grants Management Offices (GMOs)” refers to the headquarters and regional offices responsible for the business management aspects associated with the review and negotiation of applications and the award of assistance agreements. In the regions, GMOs report organizationally to the Assistant Regional Administrator, in headquarters, the GMOs report to the Director of the Grants Administration Division. 8. EVALUATION OF NON-PROFIT APPLICANTS FOR NON-COMPETITIVE AWARDS . a. Review for Programmatic Capability (1) Before sending a non-profit funding recommendation (or decision memorandum, as appropriate) to the GMO, Program Offices must assess the applicant’s programmatic —3— ------- capability. This involves consideration of the programmatic capability factors contained in Section 7 (b) of this Order. At a minimum, it must include an analysis of information from the application and the Grantee Compliance Database. lithe assessment identifies weaknesses in programmatic capability, the Program Office may not approve the application for funding until it determines that the applicant has taken, or is on schedule to take, satisfactory corrective action. (2) The Program Office must provide an assurance in the funding recommendation that it has conducted the review required by paragraph (1), that it believes the applicant possesses, or will possess, the necessary programmatic capability, and that any problems identified during the review have been appropriately addressed. The Program Office must also include in the funding-recommendation any recommended award conditions necessary to ensure programmatic capability. b. Pre-Award ReviewS Administrative Capabihty Ouestionnaire (1) The following requirements apply to: fully-funded new awards above the pre-award threshold, or incrementally funded new awards where the total federal share exceeds the pre-award threshold. (A) Program Offices must notif ’ their GMO as soon as a decision is made to recommend funding to a non-profit applicant. (B) After receiving notification from the Program Office under paragraph (1)(A), GMOs must require the applicant to fill out the Administrative Capability Form contained in Appendix A to this Order and provide supporting documents; and then conduct a review of this information. If the GMO, based upon a review of the completed Administrative Capability Form and after checking the Grantee Compliance Database, determines that the applicant lacks the necessary administrative capability, the award official must impose pre-award or special award conditions under Section 10 of this Order. If the GMO finds that the applicant has the necessary administrative capability, pre-award or special award conditions are not required. (C) A determination by a GMO that a particular applicant has the necessary administrative capability will generally remain in effect for four years. Dunng that time, other GMOs may rely on that determination without requiring the applicant to complete and submit the Administrative Capability Form unless there is adverse, new information available to the Agency, including information in the Grantee Database, beanng on the applicant’s administrative capability. At the end of the four year period, if the Director, GAD finds, after reviewing the Grantee Compliance Database and based upon the results of post-award monitoring and other relevant information, that the applicant had a satisfactory record of administrative capability, the Director may recertify the applicant for —4— ------- another four years without requiring it to complete and submit the Administrative Capability Form. If the applicant’s record of administrative capability is found to be unsatisfactory, the applicant will be subject to a new review under paragraph (l)(B). c Other Pre-Award Reviews for Administrative Capability (1) The following requirements apply to fully-funded new awards that do not exceed the pre-award threshold; incrementally-funded new awards where the total federal share does not exceed the pre-award threshold; and incremental and supplemental funding amendments. (A) GMOs must review the Grantee Compliance Database for information bearing on the applicant’s administrative capability. If the review indicates that the applicant lacks administrative capability, the award official must impose pre- award or special award conditions under Section 10 of this Order. d. Program Office Notification GMOs must promptly notify the Program Office of findings under paragraphs b and c. that an applicant lacks administrative capability. 9. EVALUATION OF APPLICANTS FOR COMPETITIVE AWARDS . a. Competitive announcements under which non-profit organizations may compete for an award must contain a ranking factor, or ranking factors, for evaluating all applicants on their ability to demonstrate the programmatic capability to successfully carry out the proposed project. The ranking factor(s), which is included in Section V of the announcement, must, at a minimum, evaluate all applicants on the programmatic capability criteria described in Section 7(b). The programmatic capability criteria included under the ranking factor(s) must be given significant weight in the evaluation process. b. Section IV of competitive announcements must require applicants to submit information relating to the programmatic capability criteria to be evaluated under the ranking factor(s) in Section V of the announcement. The announcement must also indicate that in evaluating an applicant for programmatic capability purposes under the relevant ranking factor(s), EPA will consider information provided by the applicant and may consider information from other sources including Agency files. c Competitive announcements which may involve individual non-profit awards in excess of the pre-award threshold must contain a provision in Section VI of the announcement, Award Administration Information, stating that non-profit applicants which qualify for funding under the announcement are subject to a pre-award review for administrative capability under Section 8(b) of this Order. The provision must explain that these applicants may be required to fill out —5— ------- and submit to the GMO, with supporting documents, the Administrative Capability Form contained in Appendix A to this Order. d. EPA’s Grants Competition Advocate is authorized to issue guidance as may be necessary to implement this Section. 10. PRE-A WARD OR SPECIAL AWARD CONDITIONS . a. If a GMO identifies weaknesses under Section 8 (b) or (c) of this Order in the administrative capability of an applicant recommended for award, the award official must notif ’ the applicant in wnting (with a cc: to the EPA project officer) of the weaknesses which require the imposition of pre-award conditions. These conditions must require the applicant to address the weaknesses within a specified time and inform the Agency, in writing, of the corrective actions taken. Conditions may include, where appropriate, requiring an applicant to successfully complete Office of Grants and Debarment/GMO non-profit recipient training courses. b. The GMO must assess whether the applicant’s corrective actions are satisfactory. If so, EPA may make the award. If the corrective actions are found to be deficient or the applicant does not respond within the specified time, the award official must provide written notice to the applicant (with a cc: to the EPA project officer) of the deficiencies and advise that an award will not be made. c Award officials must inform the Director of the Grants Administration Division in writing of decisions to deny awards under paragraph b. If the Director finds that a particular applicant has been denied awards in more than one instance due to an unwillingness to develop adequate administrative capability, the Director will refer the matter to the Director of the Suspension and Debarment Division for consideration under 40 CFR Part 32. d. In exigent circumstances, as an alternative to establishing pre-award conditions described under paragraphs (a) and (b), award officials may make an award with special conditions prohibiting the recipient from drawing down EPA funds until it corrects identified weaknesses under a specified timetable. For Headquarters awards, this approach requires the approval of both the Program Office Senior Resource Official and the Director, Grants Administration Division. For Regional awards, this approach requires the approval of both the approving official and the Regional Senior Resource Official. 11. REMEDIES FOR POST-AWARD NON-COMPLIANCE . EPA award officials must take one or more of the remedies under 40 CFR § 30.62 when a non- profit recipient materially fails to comply with the terms and conditions of an assistance agreement These remedies include: (A) temporarily withholding cash payments; (B) disallowing costs; (C) wholly or partly suspending or terminating the current award; (D) withholding further awards for the project or program; and (E) other remedies that may be legally available. The award official must notify the recipient in writing of the action taken, the reasons —6— ------- for the action, and the steps it must take to come into compliance. 12. DISPUTES . In accordance with the dispute process at 40 CFR § 30.63, the award official must: afford applicants the opportunity to contest disagreements over programmatic capability under Section 8 (a) of this Order or decisions to impose pre-award or special award conditions under Section 10 of this Order; and afford recipients the opportunity to contest adverse actions under Section 11 of this Order If EPA pursues suspension or debarment action, the procedures in 40 CFR Part 32 will apply. 13. DOCUMENTATION . GMOs and Program Offices must maintain in the official project file written documentation of the results of all reviews, evaluations, and determinations under this Order. 14. INTEGRITY CONSIDERATIONS . If a GMO or Program Office has concerns as to a non-profit applicant’s or recipient’s integrity based on fraud, waste, or abuse in applying for assistance or carrying out the project or a willful failure to perform, the award official must notify the Office of the Inspector General and the Director of the Grants Administration Division, and also refer the matter to the Director of the Suspension and Debarment Division for consideration under 40 CFR Part 32. 15. GRANTS ADMINISTRATION DIVISION GUIDANCE . The Director, Grants Administration Division (GAD), is authorized to issue such guidance as may be necessary to coordinate GMO and Program Office reviews under this Order, to provide for the reporting of administrative-capability determinations in the Grantee Compliance Database and to avoid duplication of effort in the performance of administrative capability pre-award reviews, including the establishment of a certification/re-certification system for applicants under Section 8 (b) of this Order. 16. WAIVERS . In response to a written request from an award official or Program Office approving official, the Director, Office of Grants and Debarment, may issue waivers from the requirements of this Order based on reasons of national security or unusual or compelling urgency or where a waiver would be in the public interest 17. CONGRESSIONAL EARMARKS . Congressional earmarks to non-profit recipients are not exempt from the provisions of this Order However, award officials must consult with the Office of the Chief Financial Officer (OCFO) —7— ------- and the Office of Congressional and Intergovernmental Relations (OCIR) on proposed decisions under Section 10 of this Order to impose pre-award or special award conditions involving Congressional earmark projects. Program Office approving officials must also consult with OCFO and OCIIR on proposed determinations that a non-profit applicant for an earmark project lacks programmatic capability. For purposes of this Section, Congressional earmarks include assistance agreements/funding amendments to be awarded in response to an action from Congress or a Congressional Committee, as reflected in appropnation or authorizing legislation or applicable legislative history. 18. REVIEW . The Office of Grants and Debarment will review this Order periodically to ensure its continued effectiveness. 19. ROLES AND RESPONSIBILITIES . a. Program Offices are responsible for assessing and documenting the programmatic capability of applicants for non-competitive awards (Section 8a., Section 13) arid competitive awards (Section 9, Section 13); and for consulting with OCFO and OCR on proposed adverse programmatic capability determinations for Congressional earmarks (Section 17). b. GMOs are responsible for conducting and documenting pre-award reviews for administrative capability (Section 8b.- d, Section 13) c. The Director, GAD, is responsible for: developing implementing guidance, database reporting requirements and a certification/recertification system for pre-award administrative capability reviews (Section 8b., Section 15); and making referrals to the Suspension and Debarment Division (Section lOc.) d. Award officials are responsible for: imposing pre-award conditions or making awards with special conditions (Section lOa ,b., and d.); notif ’ing the Director, GAD, of award denials (Section bc.); handling disputes (Section 12); informing the Director, GAD, the Office of the Inspector General and the Director, Suspension and Debarment Division, of integrity concerns (Section 14); and consulting with OCR and OCFO on proposed pre-awardlspecial award conditions for Congressional earmarks (Section 17). e. The Grants Competition Advocate is responsible for issuing guidance on evaluating the programmatic capability of applicants for competitive awards (Section 9d.). f. The Director, Office of Grants and Debarment, is responsible for issuing determinations on requests for waivers (Section 16). —8— ------- 8 ------- IEPA I _ w _ _ — , — — - r ______ — —- - — Classiuicatioii No.: — U — Approval Date: No-Cost Amendments, Processing Invoices and Closeouts of Interagency Agreements (lAGs) (DRAFT- 11/10/2004) A. PURPOSE The purpose of this Order is to establish policies and procedi iics for issuing no-cost amendments to lntei agency Agi cements, piocessing invoiCes undci Interagency Agreements, and, closing out Interagency Agi cements B. APPLICABILITY AND EFFECTIVE DATE This Order applies to all active lAGs upon issuance C. I3ACKCROUNI) EPA awaids appioximately 5600 million in Interagency Agi cements foi a activities that suppoi-t the Agency’s mission EPA explicitly recognizes the imp r nc4 of strengthening the lntei agency Agreement management piocess to meet the Agei1 ’s N pcrfoi mance goals This policy includes specific i equii ements to ensui e that lA re effectively managed The Office of Inspector General (OIG) and the Superfund 120-Day Review identified a number of weaknesses in how EPA administers lAGs EPA has a large backlog of Fm d i id - unds- Out LAGs for which closeout has been delayed due to the absence of final bilhi g i f rm hon For cxample, in an audit ieport in 2003, the OIG found problems in the lAG invoi e pproval process, particularly a failure to receive Supporting cost documentation to substant a invoice amounts and appiovc invoices for payrneilt D. DEFINITIONS For purposes of this policy, an “Interagency Agreement” is a written agreement between Fedetal, State or Local agencies under which goods or services aic provided on a Funds- Out oi Funds-In basis ------- 2 The teni “Funds-Out” (disbursement) means an JAG in which another agency provides goods and/or services o EPA, and EPA disburses funds to the other a ej1cy’s ccount to pay for that agency’s expenses 1 3 The term “Funds-In” (reimbuisement) means an JAG in which EPA pr v des go 4’ or services to another agency or to a state or local government and is rein rsed r/ ts CX CflSCS Under a Funds-In JAG, EPA uses reimbursable authority provid d1jy the Office olManagcmcnt and Budget (OM 13) to perform lAG activities 4 The terni “no-cost amendment” refers to a revision to an JAG that doe ot in.v , lvc the commitment of funds No-cost amendments include, but arc not liniite t , 1 . Pioject Officer changes, realignment of budget categories, and changes to the scjo X’vork 5 An “invoice” is an itemized list of goods shipped or services rendered ’itl a \ac untOf all costs 6 The term “closeout” means ensuring that all of the requirements of the JAG have been met, all financial transactions arc complete, and the project has ended E. I OLICY Inter agency Agreements must be administered and managed in a consistent, \‘e i efficient manner across EPA This Order establishes requirements and procedures for no-cost amendments, processing invoices, and closeouts EPA personnel involved in the administration and management of lAGs must comply with these requirements and pi ocedur es I. No—Cost Amend luciUs For Funds-Out and Funds-In, it is EPA’s policy that formal no-cost amendments a c requii cd ‘hen changes are needed to the scope olwork, budget categories, budget period_ai d Project period These amendments will require a signature from the other agency The Grants Management Office (GMO) will process the no-cost amendment and submit it to the other agency for acceptance Upon receipt of the signed acceptance, the GMO will send a COPY to the Office of Chief Financial Officer, Cincinnati Finance Center (OCFO/CFC) an 4o1 hfEP Pi-oject Officer It will be the responsibility of the GMO to make sure all amendm4i4s are. signed and received from the other agency A formal no-cost amendment will also be required when there is a change in the roject Officer When notified by the EPA Project Officer, the GMO will process a one-page amendment to notify the other agency of the Project Officer change A signature is not requiied from the other agency Copies of these amendments will be sent to the OCFO/CFC aiid the new EPA Project Officer ------- 2. Proccssiut of Invoices a Funds-Out The OCFO/CFC sends any invoices iequii ing approval to the EPA Project 01 approval, the EPA Project Officer must receive and review the following to trc valid and allowable (I) supporting cost documentation to substantiate invoice amounts are reasonable, and (2) adequate documentation on progi ess of work All supporting documentation must be included with the invoice when sent The lAG number and period of performance for work being billed must also be supporting documentation must be copied for the EPA Project Officer files Generally, the EPA Piojeci Officer must approve aiiy invoices for payment within 20 calendar days If the EPA Project Officer has not received supporting cost documentation oy’ dequatc documentation on progress of work, he/she should disapprove payment The Proj 4 t fficei must notify OCFO/CFC within 20 calendar days of difficulties encountered 0 0 C ‘ill notify the other agency informing them of delay in payment b Funds-in The EPA Pioject Officer must notify the OCFO/CFC on a quarterly basis, at a minimum, on the pr ogress of the wüi k per for mcd OCFO/CFC must then request payment fi omcfl e tli agency 3. Closeouts It is EPA’s policy to close all LAGs within 180 calendar days after- the project PC 4 CX iICS This will allow for EPA and the other agencies to reconcile their accounts arid bill for costs incurred during the project period Within 90 calendar days after an [ AG project period has expired, the GMO nust r f it e remaining balance with the OCFO/CFC or the Financial Data Warehouse The Gf ’3 must include this balance when electronically notifying the EPA Project Officer that the L4G has expired This notification must also give other options for the EJ A Project 0ffice j t choose when giving the GMO the status of the [ AG (Attachment A). if there is no iernaiiiin balance, and all work has been completed, the lAG should be closed within 90 calendar days A closeout letter will be required notifying the other agency of the closeout A copy of this letter must be sent to the OCFO/CFC and the EPA Project Officer (Attachment B) lithe LAG has expired and work memamns to be done, the EPA Project Officei must request a no-cost extension 3 ------- Funds-out lAGs with remaining balances \\ iIf require a decrease amendment The GMO must send an amendment to the other agency foi signature The OCFO/CFC will n bhgate dollars until the signed acceptance is received and processed by the GMO Th M ‘i 4 I Insert on the EPA For iii I6I0-I, the following in Block Number 8 “This deci-case auieiidmeiit is to closeout this lAG and deobligate a r ‘ r ) lug funds. if signed acceptance or written notiiicatioii of aiiy (liScrepancy IS hOt received witliiii 90 calendar days from award date, these funds will be deobligated and (lie JAG will be considered closed out.” A copy of the signed acceptance will be sent to the OCFO/CFC and the EPA p o ect icer No closeout letter will be required Funds-in lAGs with remaining balances will require a closeout letter The GM i us end a closeout letter return receipt notifying the other agency that the project is completed and that the remaining funds can be deobligated (Attachment C) A copy of the closeout letter will be sent to OCFO/CFC and the EPA Project Officer EPA will closeout the JAG within 90 calendar days F. ROLES AND RESPONSIBILITI ES I. Grants Management Offices will: a review, approve, and execute all amendments, b enter all information on lAGs into the Integrated Grants Management System (IGMS), c j)IOvrde OCFO/CFC with copies of the Funds-Out lAGs, d ensure that all amendments requiring signature are signed and received froni the other agency, and e ensure closeout of all LAGs within 180 calendar days after the )ired 2. Project Officers (POs) will a receive arid review detailed cost information submitted by other ag ncIes under Funds-Out JAG. This information must be provided on a project-by-project basis and must break down the information into the categories provided in the lAG/Amendment--EPA Form 1610-I, Item 22, 4 ------- C to the b recoid the cost that EPA incurs in performing work under the Funds-En LAG and forward it to OCFO/CFC in order to assure that EPA bills oth rage cies, in accordance with the terms stated in the lAG, for the work it has e c funds-out lAGs, appiove invoices received from othei agencies ( d funds-in lAGs, provide status of the progress to OCFO/CFC (see Section E(2)(b)), and within 90 calendar days after the lAG has expired, provide GMO foi closeout 3. Program Managers will For lAGs within their areas of iesponsibility, designate Project Officers for lAGs and promptly inform the OMO 4. The OCFO/CFC is the central sct-viciiig finance ofllcc for all paynicir rn d receipts on EPA lAGs. All invoices for- payment and all requests for EPA to 1 b Uier agencies for services rendered must be sent to this office. For Ftiii — Out i\d Funds-lu lAGs, the OCFO/CFC will ) \ _ . . a Funds—Out record obligations in the Integrated Financial Managen (1 ElviS), 2 i roccss all paymcnts, 3 piovide information about the financial status of lAGs, and 4 work with the project office and the GMO to closeout lAGs iccord accounts receivable and render bills to other- agcr _ 2 receive payments and record receipts, 3 provide information about the financial status of lAGs, and 4 woik wuth the Iroject office and the GMO to closeout lAGs b Funds-In 5 ------- C. AUTI-JORITY Office of Administration and Resources Management Functional Statement in of Grants and Dcbarmcnt, Grants Administration Division is responsible for Ii Agi cements H. KEYS TO SUCCESS EPA staff and managers will understand their respective roles in implementing the lAG requirements in this Oidcr FI A staff and managers will be held accountablc i_ ro er implementation olthe policies in this Order The Office of Grants and Debam e t I eview compliance with this Oidcr as part of its comprehensive management reviews I. WAIVERS The Director of EPA’s Office of Grants and Debarment may approve waivers from the i cquii ements of this Oidei based on reasons of national security or unusual or compelling urgency oi ‘her e a warvci would be in the public interest J. SUNSETIRE\’JEW DATE The OGD will review this Oidei two ycais horn the date of approval Addittoi OGD develops and issues new policies ot guidance which may altci, augment oi add to these lAG responsibilities, this Oider will be revised accoidingly K. REFERENCES I Owner Veionrca Squiriell, Grants Policy Specialist, 3903R, (202) quirrehl veronica@epa gov 6 ------- ATTACHMENT A LAG Closeout Notificatio,i to Project Oflicers The c-mail will state According to our iecords and the records of the Office of the Chief Financial Officer, Cincinnati Finance Center (OCFO/CFC), this lAG has expired This office is taking action to initiate closeout of this project The JAG is with the ___________________________ , lAG number ________________ The remaining funds to be deobligatcd are __________ It is requested that you review the JAG and determine if (I) all technical requirements have been satisfactorily completed, (2) the final report andlor other deliverables have been received and accepted, and (3) all charges have been billed and/or payments received Check the appropi ate space below and return so that we caii initiate closeout procedures Ifyou have any questions, please call ____________________________on (j _______________ ( ) JAG rcquii enients have been met and closeout can pioceed (including disposition of property), ( ) Proceed with decrease amendment to deobligate icmaining funds, ( ) Delay closeout and final payment (Justification required), ( ) Reimbursable lAG - Contacted OCFO/CFC to verify that all bills have been paid by the othci agency, closeout can pioceed, ( ) Reimbuisable lAG - OCFO/CFC has given iiotificaiion that the JAG should not be closed out at this time Follow-up will occur with OCFO/CFC within 30 ealcndai days for closeout status The GMO will be notified when to proceed with closeout Please return this notification to the Grants Management Office within 30 days from receipt of this e—n ail Remarks ------- ATTACI-1fr1EN r B Closeout LeUer for IACs ‘itli $0 Balance Reference No Dca After reviewing our iecoids and the records of the Office of the Chief Financial Officer, Cincinnati Finance Centci, we aie closing out the above referenccd interagency agreement This ojcct was satisfactoi ily completed and the remaining balance is $0 00 Your records should be kept foi thicc ycars (ten years if Supci fund appropiiation) from the date of this letter lfany litigation, claim or audit is started before the expiration of the thice year (ten year) l)Ci 10(1, your i ecoi ds should be kept until these actions arc completed and any issucs icsolvcd We ai c pleased to have pai ticipated with you in this project Sincerely, cc EPA P0 Jeff Marsala, CFC For funds in lAGs, cc EPA P0, Connie Ely, CFC, and Jessie Price, 2732A ------- ATTACHMENT C Closeout Letter for Reimbursement (Funds—lit) lAGs EPA Reference No Other Agency Reference No Dear After reviewing our records and the records of the Office of the Chief Financial Officer, Cincinnati Finance Center, we are closing out the above referenced interagency agreement This project was satisfactorily completed and the remaining funds to be deobligated by your agency are S 11 your records do not agi cc with ours, contact our Cincinnati Finance Center within 90 days to clairfy the balance If c do not hear fiom you within 90 days, Ihrs project will be closed out The mailing addicss is U.S. Environmental Protection Agency Accounting Operations Office, MS-002 Cincinnati, Ohio 45268-7002 Telephone Number: (513) 487-2076 Our records will be pr-cscrvcd for three years from the date of this letter We ar-c pleased to have participated with you iii this project Sincerely, cc EPA Project Officer Jessie Price, 2732A Molly Williams, CFC ------- Interagency Agreement File Review Protocol November 4, 2004 Purpose: To comply and adhere to Interagency Agreement (JAG) policies and procedures through review of documentation maintained by the Grants Management Officer (GMO) and the EPA Project Officer (P0) files. Methodology for Selecting Sample: • New lAGs funded in the last two years prior to the year the review is conducted • Closed TAGs should be selected that have closed within 12 months of the selection date. • Once a list is developed, you should randomly select the TAG files to be reviewed using a table of random numbers or other approved random selection technique. • It is recommended that the sample be selected from the IGMS Electronic lAG File (EGF Award Data) that is accessible through the Grants Information Tools • For the regions, both the GMO and the EPA Project Officer files should be reviewed and assessed using the evaluation criteria defined below For headquarters, the GMO and the EPA Project Officer files are reviewed separately during their respective reviews. Tips on Determining the Appropriate Sample Size: The following tips are provided to help you in determining the sample size. • Based on our experience with comprehensive grants management reviews, you should include at least 10 TAGs for review. Generally five active and inactive, and five closed. • File reviews should take 30-60 minutes to review each file. ------- Interagency Agreement File Review Protocol Reviewer: Date: lAG Information: lAG Number ReimbursemcntlDisburscrnent (Circle One) Fedcral/StateIForcign/lntragovcrnmental (Circle One) Agency Name Project Period Budget Period Project Officer Program Office Region Statutory Authority Type of lAG (Circle One) A Active B Closed Evaluation Criteria and Rating: For each area of the TAG management process, please rate (circle the number) the quality and quantity of the documentation in the file as follows 1= no documentation 2= partial documentation 3= documentation meets requirements and materials clearly explain the basis for decisions Indicate the basis for your rating next to the score, including explanation for NA, not applicable APPLICATION REVIEW PRIOR TO AWARD 1. Administrative Review(*) GMO File P0 File (Circle one or both if found in both files) 1 No documentation or checklist to indicate that an administrative review was performed 2 Documentation is included, but does not include all of the information listed in number 3 below 3 File includes an administrative review checklist that, at a minimum, includes the following items scope of work, commitment notice, budget, terms and conditions, foreign travel approval, and decision memorandum (*) An Administrative Review is an evaluation performed by the Grants Management Office of the application for compliance with legal, regulatory and interagency agreement requirements. 2 ------- 2. Decision Memorandum GMO File P0 File I No decision memorandum included 2 Decision memorandum included, but does not address all of the information in the Interagency Agreement Funding Package Guidance 3. Decision memorandum included and addresses all of the adequate information in the Interagency Agreement Funding Package Guidance (see GPI-02-01) 3. Statutory Authority (from decision memorandum) GMO File P0 File I No explanation or discussion of the statutory authority 2 Statutory authonty is present, but no explanation provided to explain why this particular authority was chosen 3 Decision memorandum clearly explains the mission of the project related to the statutory authority. (see GPI-02-01). If Economy Act is cited, documentation as to how the lAG will enhance government economy and efficiency. 4. Equipment/Property over $1000 GMO File P0 File 1 Budget indicates equipment/property over $1000 but no documentation of equipment 2 Documentation addresses some of the items referenced in number 3 below, but not all 3 Documentation includes the following (1) list of expendable property over $1000, and (2) documentation as to which agency retains the title after the project has ended NA Not applicable Sa. Documentation of Invoice (Disbursement Only)(*) GMO File P0 File 1. No documentation that the invoice was approved 2 Documentation included of approval of invoice, but no supporting documentation 3. Documentation included for approval of invoice including supporting documentation for worklservices performed 5b. Documentation of Expenditures (Reimbursement Only)(*) GMO File P0 File 1. No documentation of expended funds 2 Documentation included for all expended funds, but no supporting documentation 3. Documentation included for all expended funds including supporting documentation for worklservices performed (*) See history of draw down attached 3 ------- 6. Timely Approval of Invoice (Disbursement Only) GMO File P0 File I invoice approved 2 I calendar days or more after receipt 3 Approval of invoice within 20 calendar days of receipt NA = Not applicable CLOSED OR COMPLETED lAGS 7. Closeout Documentation GMO File P0 File 1 No closeout documentation included 2. Some closeout documentation included, but does not reference all of the information defined in the Policies to Close Disbursement/Reimbursement interagency Agreements 3. Includes all closeout documentation as defined in the Policies to Close Disbursement/Reimbursement Interagency Agreements (see GPI-99-02 & 03) NA = Not applicable (Active JAG) SCORtNG OF FILE REVIEW A. Total Score _______(sum the number of is, 2s and 3s for each of the 7 questions) B Number of NAs (Not applicable) C Maximum Score Possible (eliminate questions scored NA) ________(exampie 7 questions minus 1 NAs, times 3 (maximum score for each question) equals 18 as the maximum possible score for this example) D Total Score as a Percent of Maximum _______(A/C as percent) 4 ------- 9 ------- 10 ------- 4 EPA’s Brownfields Grants Prog ra m 2004 National Grants Management Training Conference November 16, 2004 ------- Purpose of the Session • Provide brief overview of the new Brownfields Grant Guidelines FY 2005 (Subtitle A C) • Review the application process, award process and grant requirements • Provide an opportunity for Q & A ------- Brownfields Definition — bfl - ‘I. real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant.” ------- Small Business Liability Relief and Brownfields Revitalization Act • Brownfields legislation signed in January 2002 • Expands funding for brownfields “Subtitle A” competitive grants • Authorized Section 128(a) State/Tribal “Subtitle C” non-competitive grants ------- Subtitle A Grants • Subtitle A grants include: • Assessment - environmental evaluation and site assessment • Cleanup -direct cleanup funds • Revolving Loan Fund -funding to capitalize loans for cleanup • Job Training - environmental training for residents • Training, Research, and Technical Assistance • Various brownfuelds-related topics (HQ cooperative agreements) ------- Subtitle C — Section 128(a) State and Tribal Response Program Grants • Authorized $50 million for state and tribal response programs • Non-competitive awards for continuing environmental programs • Grants not subject to administrative cost prohibition • In FY04 — All 50 states, 40 tribes, DC, U.S.V.I., Guam and the Northern Marianas Islands received funding ------- Subtitle C (con’t) • Primary purpose — “establish and enhance” response program • State or tribe defines “response program” — may include, e.g., RCRA, UST, or other “response” type programs • Broad range of eligible activities • Limited site-specific work is okay (e.g., assessment and cleanup) • Must be at brownfields sites • Recipients must establish and maintain a “public record” and continue to demonstrate “four elements” (or take steps to demonstrate the “four elements”) to receive funds • EPA considers current balance of unliquidated funds to decide following fiscal year’s funding. ------- FY 2004 Subtitle A Grants • EPA received over 800 proposals last year • Selected over 275: • 155 assessment grants • 92 cleanup grants • 18 revolving loan fund • l6job training ------- Proposal Review Process (Subtitle A) • Re9ioflal Offices review threshold eligibility criteria of proposals from their region (pass/fail) • Regions handle disputes • Regions provide advisory score on “ability to manage grants” (ranking) • Proposals submitted randomly to 10 National Panels • National Panels convene to discuss proposals (already scored) • OSWER Senior Management approves recommended proposals (highest ranking along with “special considerations”) • Announcement of selected proposals (Date TBD by EPA Administrator) • Cooperative Agreements negotiated and awarded in EPA Regions ------- Grant Proposal Due Dates (Subtitle A) • Nov 12— Assessment, Cleanup, and Revolving Loan Fund Grants • Nov 16 — Research, Training and Technical Assistance Grants • January 14, 2005 — Job Training Grants ------- Assessment Grants • Up to $200 K hazardous substance, pollutant, or contaminant • Up to $200K petroleum-only contamination • Site specific “waiver” • Nocost share • Administrative cost prohibition ------- Cleanup Grants • Up to $200K per site • May apply for up to 5 sites — 5 proposals • Non-profits may apply • Cost share 20% • Ownership Issue — must own property by September 30, 2005 • Administrative cost prohibition ------- Revolv I n g Loa n F u n d G ra nts • Up to $1M per eligible entity • Coalitions of eligible entities may apply • Used to capitalize a loan fund for cleanup activities • Up to 4Q% from loan amount may be used to give cleanup subgrants • Costshareof2O% • Administrative cost prohibition • Non-competitive supplemental funding ------- Job Training Grants - W -. _ . — .ra aP’- • $200,000 per grant • Administrative cost prohibition • Nonprofits and educational institutions eligible • These grants have enabled 2,178 participants to complete training of which 1,301 obtained employment. ------- Consultation and Delegation • HQ is approval official • Region is award official • HQ and Regions must consult with Enforcement on Assessment, Revolving Loan Fund and Cleanup grants • Enforcement also plays role in Section 128 Grants ------- Making a Difference • Leveraging Brownfields Investments • For every dollar the federal, state and local ciovernments put into revitalizing Brownfields, almost $2.50 in private investment was attracted. • Brownfields grantees have leveraged $6.6 billion in cleanup and redevelopment dollars. • New Jobs • Brownfields grantees have leveraged a total of over 29,600 cleanup and redevelopment jobs. ------- Regional Brownfields Coordinators • Region 1 — Carol Tucker — 617-918-1221 • Region 2 — Larry D’Andrea - 212-637-4314 • Region 3 — Tom Stolle — 215-814- 3129 • Region 4 — Wanda Jennings — 404-562-8682 • Region 5 — Deborah Orr -312-886-7576 • Region 6 — Stan Hitt -214-665-6736 • Region 7 — Susan Klein — 913-551-7786 • Region 8 — Kathie Atenclo — 303-312-6803 • Region 9- Jim Hanson — 415-972-3188 • Region 10 — Tim Brincefield -206-553-2100 ------- Please visit our Website... — if - www.epa . gov/brownfields • Copy of the guidelines • Frequently Asked Questions ------- 11 ------- Basic Budget Essential Reference Guide FY 2004 Edition The EPA Basic Budget and Budget Execution Course Richard Blackman Budget Office Office of the Chief Financial Officer (OCFO) ------- Table of Contents Acronyms .3 Appropriation Codes & Treasury Symbols .4 Authorizing Legislation . 6 Summary of Appropriations Actions.. 7 NPM List with Codes 8 RPIO List with codes 8 Allowance Holder List with Codes 9 Budget Contacts 11 2004 Goals and Objectives 14 2004 Activities List 15 Program Proj cct List - By NPMJGoaI 18 2004 Program Projects -Alphabetical by Title . . . 27 2004 Program Projects - Numerical by Code 30 Codes 33 List of Key 1FMS Tables. . 33 2004 Object Class Codes.. 33 Reprogramming Justification! Purpose Rules 34 Superfund Allowances 34 Cash-out, Special Account Funds . 34 Key Data Warehouse Inquiries 34 Report Options ... . .. 34 Stakeholders Database, APBD Commitment Database 36 Web Addresses 38 Reimbursable Guidance Tips 39 Data Warehouse Tips .. .. . 46 Funds Control Manual Table of Contents 46 2 ------- Acronyms AH- Allowance Holders ALLT- Allowance Inquiry Table APPR- Appropnation B&F- Buildings and Facilities BAS- Budget Automated System BFY- Budget Fiscal Year BOC- Budget Object Class CERCLA- Comprehensive Environmental Response, Compensation and Liability Act CJ- Congressional Justification CR- Continuing Resolution CWA- Clean Water Act CWSRF- Clean Water State Revolving Fund DWSRF- Dnnking Water State Revolving Fund EPM- Environmental Programs and Management FTE- Full Time Equivalent FY- Fiscal Year GPRA- Government Performance and Results Act JAG- Interagency Agreement IFMS- Integrated Financial Management Systems IG- Inspector General IPAs- Intergovernmental Personnel Assignments LUST- Leaking Underground Storage Tanks Funds NOA - New Obligational Authority NPM- National Program Managers OAR- Office of Air and Radiation OB - Office of Budget OCFO- Office of the Chief Financial Officer 0MB- Office of Management and Budget OPAA- Office of Planning Analysis and Accountability ORD- Office of Research and Development OSWER- Office of Solid Waste and Emergency Response OW- Office of Water PC&B- Personal Compensation and Benefits PPGs- Performance Partnership Grants PRC- Program Results Code RC- Responsibility Centers RPIO- Responsible Program Implementation Office RQ- Requisition Documents S&T- Science and Technology SLC- Senior Leadership Council STAG- State and Tribal Assistance Grant WCF- Working Capitol Fund 3 ------- FY2004 Approp Code FY 2004 FUND Codes Title Bud Treasury Bud Treasury Year Symbol Year Symbol Environmental Programs and Management EPM Reimbursable (Multi-Year) EPM Reimbursable - Ocean Dumping (Multi- Year) EPM Reimbursable - IPA and Non-Federal (Multi-Year EPM Recycling Proceeds (Multi-Year) AC&C No-Year do DOE Approp Transfer Agency for Intern. Development Approp Transfer Agency for Intern. Development Approp Transfer - Homeland Security Supplemental CIO EPM Science and Technology (S&T) S&T Reimb. (Multi-Year) S&T Reimb S&T - IPA and Non Federal (Multi-Year) S&T Reimbursable Homeland Security R&D No Yr do Superfund - S&T; for Execution DOT Approp Transfer! S&T Homeland Security Supplemental C/O S&T Buildings & Facilities Buildings & Facilities dO LUST LUST CIO State and Tribal Assistance Grants (STAG) STAG Categorical Grants STAG Categorical Grants Carryover STAG Clean Water SRF STAG Clean Water SRF Carryover STAG Drinking Water SRF STAG Drinking Water SRF Carryover STAG Special Programs STAG Special Program Carryover D3104 683/40108 03/04 683/40108 03 68X0103 03 68X0103 03 68X0103 03 68X0103 03 68X0103 03 68X0103 03 68X0103 03 68X0103 04/05 684/50108 04/05 684150108 04/05 684150108 04/05 684/50108 04/05 684/50108 04/05 684/50107 04(05 684/50107 04(05 684/50107 04/05 684/501 07 04/05 684/50107 WI1SRF (FY95 and Prior) GTI FY95 03 68X0103 GM1 FY94 03 68X0103 BR BR2 B 03/04 683/40108 BR3 03/04 683/401 08 BR4 B2 B3 B4 B5 04/05 03/04 04 04 03/04 684/50108 663/40108 68X0108 68X01 08 683/40108 04 68X0108 B9 C CR CR1 CR3 CRR C2 C3 C4 C9 D DC F FC 04 03/04 03/04 03/04 03/04 03/04 04 03/04 03 03 03 03 03 03 68X0108 683/40107 683/40107 683/40107 683/401 07 683/40107 68X01 07 683/40107 68X0107 68X01 07 68X0110 68X0110 68-20X81 53 68-20X8153 El El C E2 E2C E3 E3C E4 E4C 4 ------- GH1 FY93 03 68X0103 GBI FY92 03 68X0103 GZA FY91 03 68X0103 GXA FY90 03 68X0103 GVA FY89 03 68X0103 GWR FY77-88 03 68X0103 GHS Contr Auth FY73-77 03 68X0103 G7A PL 84-660-FY67.72 03 68X0103 G7D CG Pub. Works Employ 03 68X0103 H Oil Spill 03 68X8221 HC Oil Spill Approp Dollars C/O 03 68X8221 HR Oil Spill Reimb. 03 68X8221 N Inspector General 03/04 683/40112 N2 Superfund - lG; for Execution 03/04 683/40112 NR inspector General Reimb. (Multi-Year) 03/04 683/40112 P FIFRA 03 68X4310 T Superfund 03 68-20X8145 TC Superfund Appropriated Funds C/O 03 68-20X8145 TR Superfund Reimb. - Au Other 03 68-20X8145 TR1 SF Reimb. - SSC 03 68-20X8145 TR2 SF Reimb - Special Accounts Non Fed 03 68-20X8145 TR2A SF Special Acct Fed Unearned Mv 03 68-20X8145 TR2B SF Past Costs and interest from Treasury 03 68-20X8145 TR3 Superlund - IPA 03 68-20X8145 T2 Superfund -10 for Treasury Transfer 03/04 683/48145 T3 Suporfund - S&T for Treasury Transfer 03/04 683/48145 T4 Natl Drug Contrl Policy Approp Transfer 03 68-20X8145 T5 Sfund Approp Transfer for McEiroy Site 03 68-2DX8145 T9 Homeland Security Supplemental CIO 03 68-20X8145 Superfund Working Capital Fund (Service Agrmts) Tolerance Fund 04/05 684/50112 04105 684/50112 04/05 684/50112 WR Y 04/05 684/58145 04/05 684/58145 03 68X4565 03 68X4311 Miscellaneous Accounts. ZA Operations, Research & Facilities 03 68X0100 ZB Energy R&D 03 68X0109 ZC Misc. Contributed Funds 03 68X8741 ZD GSA Bldg. Deleg. Program 03 68-47X4542 ZE Appalachian Reg Commission 03 68-46X0200 ZF Agency for lnternaVl Devel. 03 68-72X1010 ZG Exxon Valdez Settlement Fund 03 68X5297 5 ------- Authorizing Legislation Clean Air Act: EPA authorized to set limits on how much of a pollutant can me in the air. Set by EPA but states must have their own implementation plan that gets approved by the EPA Federal Water Pollution Control Act (CWA): EPA authorized to set waste water standards for industry and other pollution control programs. It accomplishes this by using both regulatory and non-regulatory tool. It was created due to growing public awareness on pollution problems. Safe Drinking Water Act: Authonzes EPA to set drinking water standards and ensure enforcement. Only regulates drinking water systems that serve more than 25 people. Resource Conservation and recovery Act (RCRA):gave EPA the authority to control hazardous waste from the “cradle-to-grave.” This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a framework for the management of non-hazardous wastes. Also gives communities the right to know what is being emitted in their states and areas, and you can look this up online. CERCLA: Established trust fund money from a law that placed a tax on chemical and petroleum industries. Authorizes EPA to ensure cleanups. The fund created $1.6 billion in the first five years. Pollution Prevention Act Authorized EPA to establish a source reduction plan. Includes recycling, source reduction, and sustainable agriculture. Saves money, reduces liability, and improves efficiency, worker safety, and competitiveness. Oil Pollution Act. Authorizes EPA to ensure responsible parties pay to clean up their own releases. Created because of public concern after the Exxon Valdez oil spill. Toxic Substances Control Act(TSCA): Authorizes EPA to secure information on all new and existing chemical substances and to control those substances that have been determined to cause unreasonable nsk to public health to the environment. Tracks 75,000 industrial chemicals currently produced or imported into the United States. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA):regulates the sale and use of pesticides in the United States. Like private industry, Federal facilities are subject to labeling requirements, worker training and protection standards, safe management, storage and disposal of pesticides, and proper record keeping. Part of EPA’s mission is to ensure that Federal facilities comply with these requirements. The EPA gets funding for FLFRA from registrants for pesticides. When someone wants to register their pesticide they have to pay a permitting fee and that is how FIFRA is funded. 6 ------- Summary of Appropriations Environmental Programs & Management (EPM) - B- Broad range of pollution control efforts for all programs except Superfund, LUST, 010, OIL. Also funds personnel, travel, and management. Science & Technology (S&T)- C- Primarily research & research related activities. Inspector General (IG) -N - Funding for EPA Audit & Investigative functions. Hazardous Substance Response Trust Fund (Superfund) -T- Carries out legislative mandates of CERCLA & related emergency response to hazardous waste spills, long term planning & cleanup of sites, take enforcement actions to require responsible parties to clean up & recover costs. Leaking Underground Storage Tanks Trust Fund (LUST) - F- Cames out legislated mandates of the Superfund Amendments & Reauthonzation Act (SARA); corrective action for releases from leaking underground storage tanks, implements through cooperative agreements with states. Buildings & Facilities (B&F) -D- Repairs, improvements, new construction for EPA buildings. Oil Spill Liability Trust Fund (OIL) - H- Preventing & responding to oil spills in waterways. State and Tribal Assistance Grants (STAG) - E - gives money to states and tribes to aid in solving environmental problems that is divided into four types; Categorical grants: El Clean Water State Revolving Fund: E2 Drinking Water State Revolving Fund:E3 Wastewater & Water Treatment Facilities Earmarks: E4. 7 ------- NPM List with Codes Office of the Administrator (OA) — M Office of International Affairs (OIA) — L Office of Administration & Resources Management (OARM) — G Office of the Chief Financial Officer (OFCO) — J Office of Environmental Information (OEI) — H Office of Prevention, Pesticides & Toxic Substances (OPPTS) — C Office of Research & Development (ORD) — F Office of Air & Radiation (OAR) — A Office of Water (OW) — B Office of Inspector General (OIG) — P Office of General Council (OGC) — N Office of Solid Waste & Emergency Response (OSWER) — D Office of Enforcement & Compliance Assurance (OECA) — E RPIO List with Codes Office of the Administrator (OA) — 11 Office of International Affairs (OIA) — 13 Office of Administration & Resources Management (OARM) — 16 Office of the Chief Financial Officer (OFCO) — 17 Office of Environmental Information (OE1) — 18 Office of Prevention, Pesticides & Toxic Substances (OPPTS) — 20 Office of Research & Development (ORD) — 26 Office of Air & Radiation (OAR) —27 Office of Water (OW) — 30 Office of Inspector General (OIG) — 35 Office of General Council (OGC) — 39 Office of Solid Waste & Emergency Response (OSWER) — 75 Office of Enforcement & Compliance Assurance (OECA) — 77 Region 1 — Boston, 01 Region 2 — New York, 02 Region 3 — Philadelphia, 03 Region 4 — Atlanta, 04 Region 5 — Chicago, 05 Region 6 — Dallas, 06 Region 7 — Kansas City, 07 Region 8 — Denver, 08 Region 9 — San Francisco, 09 Region 10 — Seattle, 10 8 ------- Allowance Holder List with Codes Office of the Administrator (OA) — 11 Office of International Affairs (OIA) — 13 Office of Administration & Resources Management (OARM) — 16 Transit Subsidy — Ti AAOARM-16 Office of Administrator — 51 Administrator Cincinnati — 52 Administrator RTP — 54 Office of Grants & Debarment —74 Office of Acquisition Management — 76 Human Resources & Organizational Services — 85 Office of the Chief Financial Officer (OFCO) — 17 Office of Planning, Accountability, & Analysis — Cl Office of Budget - 42 (42 will change in FY05 per reorganization) Office of Enterprise Technology & Innovation - 42 Office of Financial Management - 42 Office of Financial Services - 42 Office of Environmental Information (OEI) — 18 Office of Technologoy Operations & Planning (WCF) - Hi Office of Prevention, Pesticides & Toxic Substances (OPPTS) — 20 Office of Coordination of Science & Policy — C2 Office of Pesticide Programs —32 Toxic Substances — 69 Office of Research & Development (ORD) — 26 Office of Air & Radiation (OAR) —27 Radiation Programs — 33 Office of Air Quality Planning & Standards — 53 Mobil Sources — 56 Atmosphere & Indoor Air — 58 9 ------- Office of Water (OW) —30 Gulf of Mexico — 37 Groundwater & Dnnking Water —40 Wetland, Oceans, & Watersheds — 87 American Indian Environmental Office — Wi Wastewater Enforcement & Compliance — 23 Science & Technology — 28 Office of Inspector General (OIG) — 35 Office of General Council (OGC) — 39 Office of Solid Waste & Emergency Response (OSWER) — 75 Outreach/Special Project Staff— Dl Technology Innovation Office — D2 Chemical Emergency Preparedness — D3 Innovation, Partnerships & Communication — D5 Office of Solid Waste — 31 Underground Storage Program — 88 Office of Enforcement & Compliance Assurance (OECA) — 77 Office of Compliance — El Office of Regulatory Enforcement — E2 Office of Site Remedial Enforcement — E4 Federal Facilities Enforcement — E5 Office of Planning, Policy Analysis & Communications — E7 Office of Environmental Justice — E8 Federal Activities — 36 Office of Criminal Enforcement, Forensics, & Training — 50 10 ------- FY 2004 BUDGET CONTACTS TELEPHONE FAX RPIO CONTACT NUMBER NUMBER REGIONS Region 1 Phil Cincotta 9-1-617-918-1922 9-1-617-918- 1929 or Irene Karstunen 9-1-617-918-1925 9-1-617-918- 1928 Bill Dowd 9-1-617-918-1923 Patti Grimes 9-1-617-918-1924 Judy Doucette 9-1-617-918-1921 Region 2 Esther Seabrook 9-1-212-637-3460 9-1-212-637- 3509 Donna Vizian 9-1-212-637-3456 Carlos Kercado 9-1-212-637-3595 Barbara Pastalove 9-1-212-637-3577 Lauren Sanfilippo 9-1-212-637-3469 Olga Maisonet 9-1-212-637-3572 Eddie Hemandez 9-1-212-637-3444 Marcia Mai 9-1-212-637-3461 Region 3 Rose Young 9-1-215-814-5194 9-1-215-814- 5233 Fred Warren 9-1-215-814-5154 Linda Banc 9-1-215-814-5 177 Region 4 Patty Bettencourt 9-1-404-562-8211 9-1-404-562- 8210 Amanda Baugh 9-1-404-562-8 199 Lmda Pyle 9-1-404-562-8 193 Thaddeus Allen 9-1-404 562 8191 Ronald Peterson 9-1-404 562 8220 Sandra Thomas 9-1- 404 562 8196 Region 5 Betty White 9-1-312-886-7955 9-1-312-886- 3631 Steven Sloan 9-1-312-886-1958 Andrea Brown Candiff 9-1-312-886-2190 11 ------- Region 6 Sheila Mulkey 9-1-214-665-7424 9-1-214-665- 7284 Robbye Bond 9-1-214-665-7400 John Spelman 9-1-214-665-7425 Paul Whitley 9-1-214-665-7454 Jean Gibbs 9-1-214-665-8300 Region 7 Linda Long 9-1-913-551-7355 Danielle Dunbar 9-1-913-551-7554 9-1-913-551- 7535 or Chester Stovall 9-1-913-551-7549 551- 7579 GayRanes 9-1-913-551-7442 Region 8 Debbie Janik 9-1-303-312-6887 9-1-303-312- 6684 Edna Walton 9-1-303-312-6130 Beth Greenwald 9-1-303-312-6770 Bev Kahn 9-1-303-312-6374 Betty Tipton (WCF) 9-1-303-312-6154 Region 9 Tim Dallas 9-1-415-972-3680 9-1-415-947- 3556 Dennis Shiraki 9-1-415-972-3681 Ada Ellis 9-1-415-972-3684 Jean Koutz 9-1-415-972-3682 Bill Dixon 9-1-415-972-3679 Nida Navarra 9-1-415-972-3683 Region 10 Konna Layne-Jones 9-1-206-553-6915 9-1-206-553-4957 Julie MacLean 9-1-206-553-6982 Deborah Johnson 9-1-206-553-6980 FMD-CJNN Connie Ely 9-1-51 3-487-2&75 9-1-513-487-2063 Molly Williams 9-1-513-487-2076 HEADQUARTERS OA (11) Diane Bazzle 9-1-202-564-0444 9-1-202-564-2744 Frank Rusincovitch 9-1-202-564-0418 Tamika Ward 9-1-202-564-0422 Carol Vogel 9-1-202-564-0426 12 ------- OIA (13) Dona Harris 9-1-202-564-6633 9-1-202-565-2407 or Carolyn Hicks 9-1-202-564-7727 565-2408 Came Pope 9-1-202-564-6626 OARM (16) Steven Blankenship 9-1-202-564-6905 9-1-202-564-0233 Liz Franklin 9-1-202-564-1862 OCFO (17) Larry Burnham 9-1-202-564-3396 9-1-202-564-1433 Krista Mainess 9-1-202-564-5903 9-1-202-501-1606 Marcia Washington 9-1-202-564-1602 OEI (18) Jan Drummond 9-1-202-566-0973 9-1-202-566-1722 Lavone Martinez 9-1-202-566-0975 OPPTS (20) Carol Tems 9-1-202-564-0533 9-1-202-564-0540 Bruce Berkley 9-1-202-564-7802 Shereta Butler 9-1-202-564-0538 ORD (26) Dana Bruce 9-1-202-564-3344 Jackie Baldwin 9-1-202-564-67 16 OAR (27) Kelly Spencer 9-1-202-564-1722 9-1-202-564-1327 Rene’ Posey 9-1-202-564-1224 Monica Middleton 9-1-202-564-0568 OW (30) Marilyn McKenzie 9-1-202-564-0320 9-1-202-564-0348 Terry Woods 9-1-202-564-0326 OIG (35) Ed Maddox 9-1-202-566-2648 9-1-202-566-2706 Mark Anderson 9-1-202-566-2654 OGC (39) Wanda Alston 9-1-202-564-1743 9-1-202-564-1 173 OSWER (75) Loma Washington 9-1-202-566-1897 9-1-202-566-1908 Larry Wilbon 9-1-202-566-1903 OECA (77) Barbara Murphy 9-1-202-564-1081 9-1-202-501-0017 John M. Warren 9-1-202-564-2452 Laura Milton 9-1-202-564-60 17 13 ------- 2004 Goals and Objectives Goal 1. Clean Air- Protect and improve the air so it is healthy to breathe and free of levels of pollutants that harm human health or the environment. Objective I I: Maintain and Improve Outdoor Air Quality Objective 1.2: Indoor Air Objective 13: Atmosphenc Change Objective 1.4: Radiation Objective 1.5: Reduce Greenhouse Gas Intensity Objective 1.6: Enhance Science and Research Goal 2: Clean and Safe Water Objective 2.1: Protect Human Health Objective 2.2: Protect Water Quality Objective 2.3: Science/Research Goal 3 Preserve and Restore the Land Objective 3.1 Prevention of, Preparedness for, and Response to Accidental and Intentional Releases Objective 3.2 Waste Reduction, Recycling, and Safe Waste Management Objective 3.3 Cleanup and Reuse of Contaminated Land Objective 3.4: Science/Research Goal 4: Healthy Communities and Ecosystems Objective 4.1: Chemical, Organism and Pesticide Risks Objective 4.2: Community Health Objective 4.3: Ecosystems Objective 4.4: (none - eliminated) Objective 4.5: Science/Research Goal 5: Compliance and Environmental Stewardship Objective 5.1: Improve Compliance Objective 5.2: Improve Environmental Performance through Pollution Prevention, Innovation, and Analysis Objective 5.3: Build Tribal Capacity Objective 5,4. Science/Research 14 ------- EPA ACTIVITIES for Budget Restructuring to implement the 2003 Strategic Plan with PRC Codes EPA Activities - Environmental PRC Codes A Research and Development : Research and development for the purpose of establishing the information needed to make environmental program decisions. B Regulation/Policy Development : Development or revision of regulatory policies, standards, rules and regulations, guidance documents to implement laws, outreach documents, and related training. C Environmental Program Implementation : Activities directly camed out by EPA that are related environmental program implementation (e.g. regulatory, non-regulatory, or voluntary programs). D Financial Assistance to Non-Governmental Organizations* : Exchange or transactions between EPA and non-governmental entities to accomplish a Federal goal or objective. Includes assistance agreement funding to non-profit organizations, institutes of higher learning, etc. E Financial Transfer to Governmental Organizations* : Financial exchanges or transactions between EPA and other governmental entities to accomplish a Federal goal or objective. Includes interagency agreements with other Federal agencies and assistance agreements to local, state, multi-state, and Tribal governments. *In developing this list of EPA Activities for the new 2003 Strategic Architecture, EPA has aligned our systems with OMB=s Federal Business Reference Model (BRM). The BRM compnses genenc, government-wide activities, including Financial Assistance to Non-Governmental Organizations and Financial Transfer to Governmental. All funding for assistance agreements and interagency agreements will be placed in either the Financial Assistance to Non-Governmental Organizations activity or the Financial Transfer to Governmental Organization activity. Several inquires have raised the question whether information already gathered (e.g. in the Budget Accounting Code) can be used to report on these activities rather than collecting this data through the Activities. The 15 ------- Integrated Financial Management System (IFMS), which is the official Agency budgeting and accounting system, does not contain data regarding interagency or assistance agreement recipients. Interagency and assistance agreement recipient data is maintained in the Agency’s Integrated Grants Management System (IGMS). IGMS provides reports on award expenditures by recipient type (e.g. statelTnballlocal government vs. non- governmental organizations). Each NPM can use IGMS to report on the Financial Assistance to Non-Governmental Organizations and Financial Transfer to Governmental activities. EPA Activities - Support L Administrative Management : Day-to-day management and maintenance of the internal infrastructure such as for facilities, equipment, secunty, and fleets, purchasing, tracking, and overall management of goods and services provided by the Agency such as acquisition of goods and services, inventory controls, logistics management, and services. Interagency and assistance agreement management by grant specialists. M Planning and Resource Management : Determining strategic direction, identifying and establishing programs and processes, and allocating resources among programs. Strategic planning for capital, workforce, or resources, budget formulation and execution (funds control), performance reporting, and enterprise architecture reporting N Controls and Oversight : Activities (beyond ARegulated Activity Management@) that ensure Federal programs and operations and its external partners comply with applicable laws and regulations and prevent waste, fraud, and abuse. Auditing and review activities are related to program evaluation and corrective actions. P Financial Management : Involves activities related to collection and payment functions, general accounting, payroll and travel processing, asset management, and reporting of finances (e.g, financial statements). Does not include Superfund cost recovery functions in the program or finance offices. Q Human Resources Management : Recruitment and management of human resources such as workforce planning, organizational analysis, human resource policy development, classification of positions, recruitment, advancement, awards, training, secunty clearances, performance management, and employee and labor relations. 16 ------- R Information Lifecycle Management : Managmg non-technicallnon- programmatic information such as establishing and managing the policies, guidelines, and standards regarding centralized automated information systems, coordination of information collection processes, information storage, and information dissemination. Development and maintenance of automated systems, support to LAN systems, records management, libraries, dockets and equipment such as winng, etc. S Executive Leadership : Management of operations at the Administrator and Deputy Administrator. The activities of Assistant Administrators, Deputy Assistant Administrators, Regional Administrators, and Deputy Regional Administrators may also be included in this category, if deemed appropriate by the office. This category also captures the non-programmatic activities of CongressionaL/legislative liaisons and Public Affairs offices. T Legal Services : This activity captures the activities of the Office of General Counsel, Offices of Regional Counsel, Administrative Law Judges, and Environmental Appeals Boards. This category does not include the activities of the Office of Enforcement and Compliance Assistance. - Note: The last two digits of the Activity code in the new PRC string are available for OCFO-approved RPIO Activity codes. If an RPIO desires to separately account for Ahow@ they spend their resources for another purpose than the above EPA Activities, they must first obtain an RPIO Activity code from the OCFO. If the RPIO requires others to report on this RPIO Activity, the requesting RPIO must obtain agreement from the other RPIOs before the OCFO will approve the use of a multiple-RHO Activity code. 17 ------- PROGRAM RESULTS CODE (PRCs) - by NPM Goal . Objective . NPM . Program-Project April 5, 2004 NPM : Office of Air and Radiation Goal 1 : Clean Air and Global Climate Change Objective 1.01 : Healthier Outdoor Air 1.01.A.04: Categorical Grant: State and Local Air Quality Management 1.01.A.17: Categorical Grant: Tribal Air Quality Management I .01.A.45: Clean Air Allowance Trading Programs 1.01 .A.58: Federal Stationary Source Regulations I .01.A.59: Federal Support for Air Quality Management I.01.A.60: Federal Support for Air Toxics Programs I.01.A.61: Federal Vehicle and Fuels Standards and Certification 1.01.A.71: Homeland Secunty: Critical Infrastructure Protection 1.01.A.G8: Infrastructure Assistance. Clean School Bus Initiative Objective 1.02 : Healthier Indoor Air 1.02.A.05: Categorical Grant: Radon 1.02.A.74: Indoor Air: Asthma Program 1.02.A.75: Indoor Air: Environment Tobacco Smoke Program 1.02.A.76: Indoor Air: Radon Program I.02.A.77: Indoor Air Schools and Workplace Programs Objective 1.03 : Protect the Ozone Layer I.03.A.C4: Stratospheric Ozone: Domestic Programs 1.03.A.C5: Stratospheric Ozone: Multilateral Fund Objective 1.04 : Radiation 1.04.A.72: Homeland Security: Preparedness, Response and Recovery I .04.A.97: Radiation: Protection I .04.A.98: Radiation: Response Preparedness Objective 1.05 : Reduce Greenhouse Gas Intensity 1.05.A.46: Climate Protection Program Objective 1.06 : Enhance Science and Research l.06.A.45: Clean Air Allowance Trading Programs I .06.A.46: Climate Protection Program 1.06.A.59: Federal Support for Air Quality Management 1.06.A.60: Federal Support for Air Toxics Programs 1.06.A.97: Radiation Protection 18 ------- Goal 4 : Healthy Communities and Ecosystems Objective 4.02 : Communities 4.02.A.68: Geographic Program. Other Goal Z : Enabling Support Program Objective ZZ : Enabling Support Program Z.ZZ.A.73: Homeland Security: Protection of EPA Personnel and Infrastructure NPM : Office of Water Goal 2 Clean and Safe Water Objective 2.01 : Protect Human Health 2.01.B.02: Categorical Grant: Water Quality Cooperative Agreements 2.01.B.03: Categorical Grant: Public Water System Supervision (PWSS) 2.01.B.08: Categorical Grant: Underground Injection Control (UIC) 2.01.B.23: Categorical Grant Beaches Protection 2.01.B.25: Categoncal Grant: Homeland Secunty 2.01.B.42: Beach I Fish Programs 2.01.B.53: Dnnking Water Programs 2.01.B.71: Homeland Security: Critical Infrastructure Protection 2.O1.B.81: Infrastructure Assistance: Drinking Water SRF 2.O1.B.83: Infrastructure Assistance. Puerto Rico Objective 2.02 : Protect Water Quality 2.02.B.01: Categoncal Grant: Nonpoint Source (Section 319) 2.02.B.02: Categorical Grant: Water Quality Cooperative Agreements 2.02.B.06: Categorical Grant: Pollution Control (Section 106) 2.02.B.28: Categorical Grant: Wastewater Operator Training [ Starts in FY20051 2.02.B.68: Geographic Program: Other 2.02.B.78: Infrastructure Assistance: Alaska Native Villages 2.02.B.80 Infrastructure Assistance: Clean Water SRF 2.02.B.88: Marine Pollution 2.02.B.D4: Surface Water Protection Objective 2.03 : Enhance Science and Research 2.03.B.89: National Estuary Program / Coastal Watersheds 2.03.B.D4: Surface Water Protection Goat 4 : Healthy Communities and Ecosystems Objective 4.02 : Communities 4.02.B.82: Infrastructure Assistance: Mexico Border 19 ------- Objective 4.03 : Ecosystems 4.03.B.07: Categoncal Grant: Wetlands Program Development 4.03.B.26: Categorical Grant Targeted Watersheds 4.03.B.63: Geographic Program: Chesapeake Bay 4.03.B.64: Geographic Program: Great Lakes 4.03.B.65: Geographic Program: Gulf of Mexico 4.03.B.66: Geographic Program: Lake Champlain 4.03.B.67: Geographic Program: Long Island Sound 4.03.B.68: Geographic Program: Other 4.03.B.69: Great Lakes Legacy Act 4.03.B.89: National Estuary Program / Coastal Watersheds 4.03.B.E2: Wetlands Goal 5 : Compliance and Environmental Stewardship Objective 5.03 : Build Tnbal Capacity 5.03.B.15: Categoncal Grant: Tnbal General Assistance Program 5.03.B.D9: Tribal - Capacity Building NPM : Office of Prevention, Pesticides, and Toxic Substances Goal 2 : Clean and Safe Water Objective 2.01 : Protect Human Health 2.01.C.09: Categoncal Grant: Pesticides Program Implementation 2.01.C.92: Pesticides: Field Programs Goal 4 : Healthy Communities and Ecosystems Objective 4.01 : Chemical, Organism, and Pesticide Risks 4.O1.C.09: Categorical Grant: Pesticides Program Implementation 4.01 .C. 10: Categorical Grant: Lead 4.01.C.72: Homeland Secunty: Preparedness, Response, and Recovery 4.01.C.92: Pesticides: Field Programs 4.01.C.93: Pesticides: Registration of New Pesticides 4.01.C.94: Pesticides: Review / Reregistration of Existing Pesticides 4.01.C.D5: Toxic Substances: Chemical Risk Management 4.01.C.D6: Toxic Substances: Chemical Risk Review and Reduction 4.01.C.07: Toxic Substances: Lead Risk Reduction Program Objective 4.05 : Enhance Science and Research 4.05.C.54: Endocrine Disruptors 4.05.C.C2: Science Policy and Biotechnology 20 ------- Goal 5 : Compliance and Environmental Stewardship Objective 5.2 : Improve Environmental Performance through Pollution Prevention and Innovation 5.02.C. 13: Categoncal Grant: Pollution Prevention 5.02.C.95: Pollution Prevention Program NPM : Office of Solid Waste and Emergency Response Goal 3 : Land Preservation and Restoration Objective 3.01 : Preserve Land 3.01.D.1 1: Categoncal Grant: Hazardous Waste Financial Assistance 3.01 .D.16: Categoncal Grant Underground Storage Tanks 3.01 .D.86: LUST / UST 3.01.D.A1: RCRA Waste Management 3.01 .D.A2: RCRA Waste Minimization and Recycling Objective 3.02 : Restore Land 3.02.D.11: Categoncal Grant Hazardous Waste Financial Assistance 3.02.D.41: Base Realignment and Closure (BRAC) 3.02.D.72: Homeland Secunty Preparedness, Response, and Recovery 3.02.D.86: LUST / UST 3.02.D.87: LUST Cooperative Agreements 3.02.D.91: Oil Spill Prevention, Preparedness, and Response 3.02.D.99: RCRA Corrective Action 3.02.D.C6: Superfund Emergency Response and Removal 3.02.D.C8: Superfund: EPA Emergency Preparedness 3.02.D.C9: Superfund: Federal Facilities 3.02.D.D2: Superfund: Remedial 3.02.D.D3: Superfund: Support to Other Federal Agencies Objective 3.03 : Enhance Science and Research 3.03.D.D2: Superfund Remedial Goal 4 : Healthy Communities and Ecosystems Objective 4.01 : Chemical, Organism, and Pesticide Risks 4.01.D.C3: State and Local Prevention and Preparedness Objective 4.02 : Communities 4.02.D.24: Categorical Grant. Brownfields 4.02.D.43: Brownfields 4.02.D.79: Infrastructure Assistance: Brownfields Projects 21 ------- Goal 5 : Compliance and Environmental Stewardship Objective 5.02 : Improve Environmental Performance through Pollution Prevention and Innovation 5.02.D.A2: RCRA Waste Minimization and Recycling Goal Z : Enabling Support Program Objective ZZ : Enabling Support Program Z.ZZ.D.73: Homeland Security Protection of EPA Personnel and Infrastructure NPM : Office of Enforcement and Compliance Assurance Goal 3 : Land Preservation and Restoration Objective 3.01 : Preserve Land 3.01.E.48: Compliance Assistance and Centers Objective 3.02 : Restore Land 3.02.E.44: Civil Enforcement 3.02.E.48: Compliance Assistance and Centers 3.02.E.C7: Superfluid: Enforcement 3.02.E.D1: Superftind Federal Facilities lAGs Goal 4 : Healthy Communities and Ecosystems Objective 4.02 : Communities 4.02.E.43: Brownflelds 4.02.E.57: Environmental Justice Goal 5 : Compliance and Environmental Stewardship Objective 5.01 : Improve Compliance 5.01 .E. 12: Categorical Grant: Pesticides Enforcement 5.01.E.14: Categoncal Grant: Toxic Substances Compliance 5.01.E.19: Categorical Grant: Sector Program 5.01.E.44: Civil Enforcement 5.01 .E.48: Compliance Assistance and Centers 5.01.E.49: Compliance Incentives 5.01.E.50: Compliance Monitoring 5.01.E.52: Cnminal Enforcement 5.01.E.55: Enforcement Training 5.01.E.71: Homeland Secunty: Critical Infrastructure Protection 5.01.E.85: International Capacity Building 22 ------- Objective 5.02 : Improve Environmental Performance through Pollution Prevention and Innovation 5.02.E.90: NEPA Implementation Objective 5.04 : Enhance Science and Research 5.04.E.62: Forensics Support Goal Z : Enabling Support Program Obiective ZZ : Enabling Support Program Z.ZZ.E.E8: Congressional, Intergovernmental, External Relations Z.ZZ.E.F8: IT I Data Management NPM : Office of Research and Development Goal 1 : Clean Air and Global Climate Change Objective 1.06 : Enhance Science and Research 1.06.F.A5: Research: Air Toxics I .06.F.B4: Research: Particulate Matter I.06.F.B9: Research: Tropospheric Ozone Goal 2 : Clean and Safe Water Objective 2.03 : Enhance Science and Research 2.03 .F.A7: Research: Dnnking Water 2.03.F.C1: Research Water Quality Goal 3 : Land Preservation and Restoration Object jve 3.03 : Enhance Science and Research 3.03.F.B3: Land Preservation and Restoration 3.03.F.B7: Research: SITE Program Goal 4 : Healthy Communities and Ecosystems Objective 4.05 : Enhance Science and Research 4.05.F.72: Homeland Secunty: Preparedness, Response, and Recovery 4.05.F.84: Human Health Risk Assessments (formerly IRIS) 4.05.F.A6: Research: Computational Toxicology 4.05.F.A8: Research Endocrine Disruptor 4.05.F.B 1: Research Global Change 4.05.F.B2: Research Human Health and Ecosystems 4.05.F.B5: Research: Pesticides and Toxics 4.05.F.B8: Research: STAR Fellowships 23 ------- Goal 5 : Compliance and Environmental Stewardship Objective 5.04 : Enhance Science and Research 5.04.F.A9: Research: Environmental Technology Venfication (ETV) 5.04.F.B6: Research: Pollution Prevention NPM : Office of International Affairs Goal 1 : Clean Air and Global Climate Change Objective 1.01 : Healthier Outdoor Air I.01.L.85: International Capacity Building 1.O1.L.E6: Children and other Sensitive Populations Objective 1.05 : Reduce Greenhouse Gas Intensity 1.05.L.46: Climate Protection Program Goal 2 : Clean and Safe Water Objective 2.01 : Protect Human Health 2.O1.L.85: International Capacity Building 2.O1.L.E6: Children and other Sensitive Populations Objective 2.02 : Protect Water Quality 2.02.L.85: International Capacity Building Goal 4 : Healthy Communities and Ecosystems Objective 4.01 : Chemical, Organism, and Pesticide Risks 4.O1.L.47: Commission for Environmental Cooperation 4.O1.L.85: International Capacity Building 4.O1.L.96: POPs Implementation Objective 4.02 : Communities 4.02.L.47: Commission for Environmental Cooperation 4.02.L.56: Environment and Trade 4.02.L.E1: US - Mexico Border NPM : Office of Environmental Information Goal 4 : Healthy Communities and Ecosystems Objective 4.01 : Chemical, Organism, and Pesticide Risks 4.01.H.D8: TRI / Right to Know Objective 4.02 : Communities 4.02.11.43: Brownfields 24 ------- Goal 5 : Compliance and Environmental Stewardship Objective 5.02 : Improve Environmental Performance through Pollution Prevention and Innovation 5.02.H.21: Categorical Grant. Environmental Information Goal Z : Enabling Support Program Objective Z.ZZ : Enabling Support Program Z.ZZ.H.70: Homeland Security Communication and Information Z.ZZ.H.F1: Exchange Network Z.ZZ.H.F6: information Security Z.ZZ.H.F8: IT / Data Management NPM : Office of the Administrator Goal 4 : Healthy Communities and Ecosystems Objective 4.02 : Communities 4.02.M.43: Brownfields 4.02.M.A4: Regulatory Innovation 4.02.M.E6: Children and other Sensitive Populations 4.03.M.G3: Regional Geographic Initiatives Objective 4.03 : Ecosystems 4.03.M.G3: Regional Geographic Initiatives Goal 5 : Compliance and Environmental Stewardship Objective 5.02 : Improve Environmental Performance through Pollution Prevention and innovation 5.02.M.A3: Regulatory / Economic - Management and Analysis 5.02.M.A4: Regulatory Innovation 5.02.M.E9: Environmental Education 5.02.M.G9: Small Business Ombudsman Goal Z : Enabling Support Program Objective Z.ZZ : Enabling Support Program Z.ZZ.M.70: Homeland Security: Communication and Information Z.ZZ.M.E3: Administrative Law Z.ZZ.M.E7: Civil Rights / Title VT Compliance Z.ZZ.M.E8: Congressional, Intergovernmental, External Relations Z.ZZ.M.G4: Regional Science and Technology Z.ZZ.M.C5: Science Advisory Board Z.ZZ.M.G6: Small Minonty Business Assistance 25 ------- NPM : Office of the Chief Financial Officer Goal 3 : Preserve and Restore the Land Objective 3.02 : Restore Land 3.02.J.C7: Superfund: Enforcement Goal Z : Enabling Support Program Objective Z.ZZ : Enabling Support Program Z.ZZ.J.E5: Central Planning, Budgeting, and Finance NPM : Office of Administration and Resource Management Goal Z : Enabling Support Program Objective Z.ZZ : Enabling Support Program Z.ZZ.G.73: Homeland Security Protection of EPA Personnel and Infrastructure Z.ZZ.G.F2: Facilities Infrastructure and Operations Z.ZZ.G.F3: Acquisition Management Z.ZZ.G.F5: Human Resources Management Z.ZZ.G.G7: Financial Assistance Grants / JAG Management NPM : Office of General Counsel Goal Z : Enabling Support Program Objective Z.ZZ : Enabling Support Program Z.ZZ.N.E4: Alternative Dispute Resolution Z.ZZ.N.F9: Legal Advice Environmental Program Z.ZZ.N.G1: Legal Advice Support Program NPM : Office of Inspector General Goal Z : Enabling Support Program Objective Z.ZZ : Enabling Support Program Z.ZZ.P.G2: Audits, Evaluations, and Investigations 26 ------- 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Program/Projects - Alphabetical Definition Program/Project defines “what” the Agency does based upon specific statutory authonty (programs) or “what” significant tasks or problems the Agency is addressing (projects) These budgetary units help a program manager plan, budget, and acc EnvIronmental (direct charged) Programs PRC Code ProgramlProject Title NPMs Base Realignment and Closure (BRAC) OSWER 41 Beach / Fish Programs OW 42 Brownfields rDSWER, OECA, OGC, OARM,OCFO, OEI, OA 43 Categoncal Grant Beaches Prolection OW 23 Categoncal Grant Brownfields OSWER 24 Categoncal Grant Environmental Information OEI 21 Categoncal Grant Hazardous Waste Financial Assistance OSWER 11 Categoncal Grant Homeland Secunty OW 25 Categoncal Grant Lead OPPTS 10 Categoncal Grant Nonpoint Source (Sec 319) OW 01 Categoncal Grant Pesticides Enforcement OECA 12 Categoncal Grant Pesticides Program Implementation OPPTS 09 Categoncal Grant Pollution Control (Sec 106) OW 06 Categorical Grant PolIuUon Preven on OPPTS 13 Categoncal Grant Public Water System Supervision (PWSS) OW 03 Categorical Grant Radon OAR 05 Categorical Grant Sector Program OECA 19 Categorical Grant State and Local Air Quality Management OAR 04 Categorical Grant Targeted Watersheds OW 26 Categorical Grant Toxics Substances Compliance OECA 14 Categoncal Grant Tnbal Air Quality Management OAR 17 Categoncal Grant Tnbal General Assistance Program OW 15 Categorical Grant Underground Injection Control (UIC) OW 08 Categoncal Grant Underground Storage Tanks OSWER 16 Categoncal Grant Water Quality Cooperative Agreements OW 02 Categorical Grant Wetlands Program Development OW 07 Children and other Sensitive Populations OA E6 Civil Enforcement OECA 44 Clean Air Allowance Trading Programs OAR 45 Climate Protection Program OAR 46 Commission for Environmental Cooperation OIA 47 Compliance Assistance and Centers OECA 48 Compliance Incentives OECA 49 Compliance Monitonng OECA 50 Congressionally Mandated Projects all 51 Cnminal Enforcement OECA 52 Drinking Water Programs OW 53 Endocrine Disruptors OPPTS 54 Enforcement Training OECA 55 Environment and Trade OIA 56 Environmental Education OA E9 Environmental Justice OECA 57 27 ------- 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 63 64 85 66 87 88 89 90 91 92 93 Federal Stationary Source Regulations OAR 58 Federal Support for Air Quality Management OAR 59 Federal Support for Air Toxics Programs OAR 60 Federal Vehicle and Fuels Standards and Certification OAR 61 Forensics Support OECA 62 Geographic Program Chesapeake Bay OW 63 Geographic Program Great Lakes OW 64 Geographic Program Gulf of Mexico OW 65 Geographic Program Lake Champlain OW 66 Geographic Program Long Island Sound OW 67 Geographic Program Other OW 68 Great Lakes Legacy Act OW 69 Homeland Secunty Communication and Information OEI, OA 70 Homeland Secunty Cntical Infrastructure Protection OW,OECA,OPPTS,OA R 71 Homeland Secunty Preparedness, Response, and Recovery OSWER,OAR,OPPTS, ORD 72 Homeland Secunty Protection of EPA Personnel and Infrastructure OAR,OSWER, OARM 73 Human Health Risk Assessments (formerly IRIS) ORD 84 Indoor Air Asthma Program OAR 74 Indoor Air Environment Tobacco Smoke Program OAR 75 Indoor Air Radon Program OAR 76 Indoor Air Schools and Workplace Programs OAR 77 Infrastructure Assistance Alaska Nalive Villages OW 78 Infrastructure Assistance Brownfields Projects OSWER 79 Infrastructure Assistance Clean Water SRF OW 80 Infrastructure Assistance Dnnking Water SRF OW 81 Infrastructure Assistance Mexico Border OW 82 Infrastructure Assistance Puerto Rico OW 83 International Capacity Building OIA I OECA 85 LUST / UST OSWER 86 LUST Cooperative Agreements OSWER 87 Manne Pollution OW 88 National Estuary Program I Coastal Watersheds OW 89 NEPA Implementation OECA 90 Oil Spill Prevention, Preparedness, and Response OSWER 91 Pesticides Field Programs OPPTS 92 Pesticides Registration of New Pesticides OPPTS 93 Pesticides Review/ Reregistration of Existing Pesticides OPPTS 94 Pollution Prevention Program OPPTS 95 POPs Implementation OIA 96 Radiation Protection OAR 97 Radiation Response Preparedness OAR 98 RCRA Corrective Action OSWER 99 RCRA Waste Management OSWER Al RCRA Waste Minimization & Recycling OSWER A2 Regional Geographic Initiatives OA G3 Regulatory! Economic - Management and Analysis OA A3 Regulatory Innovation OA A4 Research Air Toxics ORD A5 Research Computational Toxicology ORD A6 Research Dnnking Water ORD A7 Research Endocnne Disrupter ORD A8 28 ------- 94 95 96 97 Y8 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Research Environmental Technology Venfication (ETV) ORD A9 Research Global Change ORD Bi Research Human Health and Ecosystems ORD B2 Research Land Preservation and Restoration ORD B3 Research Particulate Matter ORD B4 Research Pesticides and Toxics ORD B5 Research Pollution Prevention ORD B6 Research SITE Program ORD B7 Research Fellowships ORD B8 Research Troposphere Ozone ORD B9 Research Water Quality ORD Cl Science Policy and Biotechnology OPPTS C2 State and Local Prevention and Preparedness OSWER C3 Slratosphenc Ozone Domestic Prograrris OAR C4 Stratospheric Ozone Multilateral Fund OAR C5 Superfund Emergency Response and Removal OSWER C6 Superfund Enforcement OECA / OCFO CT Superlund EPA Emergency Preparedness OSWER C8 Superfund Federal Facilities OSWER C9 Superfund Federal Facilities lAGs OECA Dl Superlund Remedial OSWER D2 Superfund Support to Other Federal Agencies OSWER D3 Surface Water Protection OW D4 Toxic Substances Chemical Risk Management OPPTS D5 Toxic Substances Chemical Risk Review and Reduction OPPTS D6 Toxic Substances Lead Risk Reduction Program OPPTS D7 TRI I Right to Know OEI D8 Tribal - Capacity Building OW D9 US?Mexico Border OIA El Wetlands OW E2 Support (in-directly charged) Programs Acquisition Management OARM F3 Administrative Law OA E3 Alternative Dispute Resolution OGC E4 Audits, Evaluations, and Investigations OIG G2 Central Planning, Budgeting, and Finance OCFO E5 Civil Rights I Title VI Compliance OA E7 Congressional, Intergovernmental, External Relations OA I OECA E8 Exchange Network OEI Fl Facilities Infrastructure and Operations OARM F2 Financial Assistance Grants / lAG Management OARM G7 Human Resources Management OARM F5 Information Secunty OEI F6 IT / Data Management OEI / OECA F8 Legal Advice Environmental Program OGC F9 Legal Advice Support Program OGC Gi Regional Science and Technology OA G4 Science Advisory Board OA G5 Small Business Ombudsman, Small Minonty Business OA G6 Assistance 29 ------- 10 25 15 18 16 13 26 23 12 9 7 11 14 20 22 24 21 17 6 4 5 8 19 2 3 28 29 30 31 32 33 34 35 36 37 38 39 40 42 43 44 45 46 47 45 Program/Projects by Code Environmental (direct charged) Programs PRC Code Program/Project Title NPMs Categorical Grant Nonpoint Source (Sec 319) OW 1 Categorical Grant Water Quality Cooperative Agreements OW 2 Categorical Grant Public Water System Supervision (PWSS) OW 3 Categorical Grant State and Local Air Quality Management OAR 4 Categoncal Grant Radon OAR 5 Categorical Grant Pot ution Control (Sec 106) OW 6 Categoncal Grant Wetlands Program Development OW 7 Categoncal Grant Underground Injection Control (UIC) OW 8 Categorical Grant Pesticides Program Implementation OPPTS 9 Categoncal Grant Lead OPPTS 10 Categoncal Grant Hazardous Waste Financial Assistance OSWER 11 Categoncal Grant Pesticides Enforcement OECA 12 Categorical Grant Pollution Prevention OPPTS 13 Categoncal Grant Toxics Substances Compliance OECA 14 Categoncal Grant Tnbal General Assistance Program OW 15 Categorical Grant Underground Storage Tanks OSWER 16 Categorical Grant Tribal Air Quality Management OAR 17 Categorical Grant Sector Program OECA 19 Categorical Grant Environmental Information OEI 21 Categoncal Grant Beaches Protection OW 23 Categorical Grant Brownfields OSWER 24 Categorical Grant Homeland Secunty OW 25 Categoncal Grant Targeted Watersheds OW 26 Base Realignment and Closure (BRAC) OSWER 41 Beach / Fish Programs OW 42 Brownfields OSWER, OECA, OGC, OARM,OCFO, OEi, OA 43 Civil Enforcement OECA 44 Clean Air Allowance Trading Programs OAR 45 Climate Protection Program OAR 46 Commission for Environmental Cooperation OIA 47 Compliance Assistance and Centers OECA 48 Compliance Incentives OECA 49 Compliance Monitonng OECA 50 Congressionally Mandated Projects all 51 Cnminal Enforcement OECA 52 Drinking Water Programs OW 53 Endocnne Disruptors OPPTS 54 Enforcement Training OECA 55 Environment and Trade O IA 56 Environmental Justice OECA 57 Federal Stationary Source Regulations OAR 58 Federal Support for Air Quality Management OAR 59 Federal Support for Air Toxics Programs OAR 60 Federal Vehicle and Fuels Standards and Certification OAR 61 Forensics Support OECA 62 Geographic Program Chesapeake Bay OW 63 30 ------- 49 50 51 52 53 54 55 56 57 58 60 61 62 63 64 65 66 67 68 69 59 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 88 89 90 91 92 93 94 95 96 97 98 99 100 101 Geographic Program Great Lakes OW 64 Geographic Program. Gulf of Mexico OW 65 Geographic Program Lake Champlain OW 66 Geographic Program Long Island Sound OW 67 Geographic Program Other OW 68 Great Lakes Legacy Act OW 69 Homeland Secunty Communication and Information OEI, OA 70 Homeland Secunty Cntical Infrastructure Protection OW,OECA,OPPTSOAR 71 Homeland Secunty Preparedness, Response, and Recovery OSWER,OAR,OPPTS,ORD 72 Homeland Secunty Protection of EPA Personnel and Infrastructure OAR,OSWER, OARM 73 Indoor Air Asthma Program OAR 74 Indoor Air Environment Tobacco Smoke Program OAR 75 Indoor Air Radon Program OAR 76 Indoor Air Schools and Workplace Programs OAR 77 Infrastructure Assistance Alaska Native Villages OW 78 Infrastructure Assistance Brownfields Projects OSWER 79 Infrastructure Assistance Clean Water SRF OW 80 Infrastructure Assistance Dnnking Water SRF OW 81 Infrastructure Assistance Mexico Border OW 82 Infrastructure Assistance Puerto Rico OW 83 Human Health Risk Assessments (Iorrneily IRIS) ORD 84 International Capacity Building OIA / OECA 85 LUST / UST OSWER 86 LUST Cooperative Agreements OSWER 87 Manne Pollution OW 88 National Estuary Program I Coastal Walersheds OW 89 NEPA Implementation OECA 90 Oil Spill Prevention, Preparedness, and Response OSWER 91 Pesticides Field Programs OPPTS 92 Pesticides Registration of New Pesticides OPPTS 93 Pesticides Review I Reregistration of Existing Pesticides OPPTS 94 Pollution Prevention Program OPPTS 95 POPs Implementation OIA 96 Radiation Protection OAR 97 Radiation Response Preparedness OAR 98 RCRA Corrective Action OSWER 99 RCRA Waste Management OSWER Al RCRA Waste Minimization & Recycling OSWER A2 Regulatory / Economic - Management and Analysis OA A3 Regulatory Innovation OA A4 Research Air Toxics ORD A5 Research Computational Toxicology ORD A6 Research Dnnking Water ORD A7 Research Endocnne Disruptor ORD AS Research Environmental Technology Venfication (ETV) ORD A9 Research Global Change ORD BI Research Human Health and Ecosystems ORD B2 Research Land Preservation and Restoration ORD B3 Research Particulate Matter ORD B4 Research Pesticides and Toxics ORD B5 Research Pollution Prevention ORD B6 Research SITE Program ORD B7 31 ------- 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 ESP2 ESP3 ESP5 27 ESP6 ESP7 41 ESP8 ESP9 ESP1 ESPI1 ESP12 ESP13 ESP14 ESP15 ESP4 87 ESP16 ESP17 ESP18 ESP1O 141 Research Fellowships ORD B8 Research Troposphere Ozone ORD BY Research Water Quality CR0 Cl Science Policy and Biotechnology OPPTS C2 State and Local Prevention and Preparedness OSWER C3 Stratospheric Ozone Domestic Programs OAR C4 Stratosphenc Ozone Multilateral Fund OAR C5 Superfund Emergency Response and Removal OSWER C6 Superfurid Enforcement OECA I OCFO C7 Superfund EPA Emergency Preparedness OSWER C8 Superfund Federal Facilities OSWER C9 Superfund Federal Facilities lAGs OECA Dl Superfund Remedial OSWER 02 Superfund Support to Other Federal Agencies OSWER 03 Surface Water Protection OW D4 Toxic Substances Chemical Risk Management OPPTS Toxic Substances Chemical Risk Review and Reduction OPPTS D6 Toxic Substances Lead Risk Reduction Program OPPTS 07 TRI I Right to Know OEI 08 Tribal - Capacity Building OW 09 US?Mexico Border OIA El Wetlands OW E2 Administrative Law OA E3 Alternative Dispute Resolution OGC E4 Central Planning, Budgeting, and Finance OCFO E5 Children and other Sensitive Populations CA E6 Civil Rights / Title VI Compliance CA E7 Congressional, intergovernmental, External Relations CA / OECA E8 Environmental Education CA E9 Exchange Network OEI Fl Facilities Infrastructure and Operations OARM F2 Acquisition Management OARM F3 Human Resources Management OARM F5 Information Security OEI F6 IT I Data Management CEI I OECA F8 Legal Advice Environmental Program OGC Legal Advice Support Program OGC Gi Audits, Evaluations, and Investigations 0 16 G2 Regional Geographic Initiatives CA G3 Regional Science and Technology OA G4 Science Advisory Board CA G5 Small Business Ombudsman, Small Minority Business CA G6 Assistance Financial Assistance Grants / lAG Management Total Number of Program/Projects OARM G7 32 ------- CODES 2004 PRC Code: 1 23 4 5 6 7 89 Goal Objective NPM ProgramfProject Agency Act. RPIO Act ORGN Code: 1 2 3 4 5 6 7 Allowance Holder Resp. Center Add-on/Superfund Allowance designator project/earmark/local code Treasury Symbol: 1 2 3/3 4567 Agency Code FY Specific Appr. 33 ------- Stakeholder Database Add-on F? New1 Line Appx Short Title Titla/Dec Code Cent B CH 2u03 C c T Lc.w ark1 Er v iu r .i re earch rrhj j nj Rc e rch C ntar t cte t1e rvr nr 0 f c fe L ‘ . / ZQ 2003 C 11 EPM San Bernardino Va w for rc earth and de ion (co?t Municipal Water D istr ict, CA evaluation arid envi c.nmer tc e a rnrt i at ion proi ct c r t!:o Ci ty oor 3rThnated h i h ; r at table arid dang rc prc er ed by quihcation fNote: Last year in S&T X \ 20c3 r 6 EP l n r ELI • rd t r re h’ . i . L l . C i.. \ ‘ rIdhiE C -. i r dvn Mr’e ri r Z 2003 C 2 EPM Meckferrburg County for continua orrie pan ion of tIre (Charlotte). NC Charbtte Surlace Water Improvement & Mgmt orogram C 4 3 Hh. .r/aV 1 nti Ir i Mnt. V/a ‘1 i. rrr rl:c . iFt ri’ ri n I — L r i. t; -.ritaJ\ _ e It ft. nJ ti ’ r QAI 2003 N 269 STAO Bake vi le. North Carolina for v er infrastructure improvemen t .. Fr .: ?0 II 141 SlAG Ururnr c 8 k-’J :: .,t rn rrr . QA5 2003 r 44 S T Univ of Vermont Proctor to continue mercury depo it ror Maple Rc earch Center monrtoring eFlectc * !J i i 2u 1 1.’ I ii kyiq I c’r iniLJ Ft ri:rr rr u if pulur rI’ n u . .1 j QAB 2003 C 10 EPM Water Resources n titute. to e tab lich a S n a Ana River Stakeholder Exercise i cr*wi 1 - I 1 jJJ ,ji i’J !,) i1jht _________________________ File Edit View Create Actions Help Welcome E Stakeholder Exercise - 1-by Add-on Code X notes ,j Help J New Earmark _J 2-by NPM _J 3-byPRC _J 4-by Region ._i 5-by RPIO .J 6-by State _J 9-Export Data by RPI ‘_iAPBD Views _J byAPPR _J ExportDatabyPl ‘ ‘ —I Total Dollars _] byAPPR __J by Region .J byRPlO/AHIAP _I by State —/ >Export _.J Detail Data •__J Reference Data , I I 34 ------- Web Addresses Strategic Plan 2003 http://www.epa.gov/ocfo/plan/2003sp.pdl Annual Plan http:/Iintranet.epa. gov/ocfo/budgeti2003/2003ap.htm Annual Report http://intranet.epa.gov/ocfo/perform/apr/1 999apr.htm Funds Control Manual http://intranet.epa.gov/ocfo/policies/directJ2520/index.htm Congressional Justification http://intranet.epa.gov/ocfo/budgetl2004/2004cj . htm Thomas http://thomas.loc.gov / Summary of the Budget http://www.epa.gov/ocfo/budgetl2 004/2004bib.pdf Program/Project Book http://intranet.epa.gov/ocfo/budget/architecture.htm President Budget http://www.whitehouse.gov/news/usbudgetlbudget-fy2004/app _ down.html Superfund Special Accounts hp://intranet.epa.gov/findvallv/policies/superfund/spec-acct.htin Data Warehouse http://intranet.epa.gov/fdw Description of Object Classes http://ntranet.epa.gov/ocfo/policieS/direCtJ259 OfY O2.Pdf OCFO Web page http://intranet.epa.gov/ocfo / 35 ------- REIMBURSABLE GUIDANCE INFORMATION 1. Responsibility The Cincinnati Financial Management Center(CFMC) is responsible for the oversight of financial requirements for Reimbursable Interagency Agreements (RW JAG’s). RW JAG’s are used when EPA receives money from a federal, state or local agency, or a foreign country for services rendered. 2. lAG Identification Number An JAG identification number is assigned to each agreement that is processed through a grants office. The JAG number is located in block 1 on the EPA Form 16 10-1 (Exhibit 1). The following provides a description of the fields that are used to assign the identification number. lAG NO.: RW89937529-01-0 RW: = Reimbursable Agreement. 89: = Agency Number. Each federal agency is assigned a two digit agency identifier by the Dept. of Treasury. This number identifies the agency for which EPA is performing work. The number “89” in the example refers to Dept.of Energy. 93 = JAG processed by Headquarters Grants Office 94 = JAG processed by Region 1-5 Grants Office 95 lAG processed by Region 6-10 Grants Office 7529= Number sequentially assigned by the grants office. 01 = Order of task related to JAG = This number identifies the agreement as the original action if the number equal zero or an amendment for numbers 1-9 or alpha A-Z. 36 ------- 3. Initiating the Interagency Agreement Initiation of a RW JAG should begin with the requesting agency contacting EPA to perform work The requesting agency should provide EPA a written agreement and a funding document. The funding document will vary from agency to agency. For example, the Department of Defense (DOD) normally provides a Military Interdepartmental Purchase Request (MIPR) or a Project Order, the Department of Energy provides an Interagency Agreement (IA), and the Fish and Wildlife Service provides a Purchase Order (P0). These funding documents, which normally provides an identification number, are helpful when billing the agency for work performed. Also, if the funding document does not provide the type of funding; ex: 1 year, 2 year, no year, it is important to obtain this information. This is helpful to determine how long EPA has to use the funding. 4. Processing the Interagency Agreement After the initiation/negotiation of the interagency agreement, the completed package is forwarded to the appropriate grants office for final processing and acceptance. When the review is completed, executed copies of the agreement are distributed to the appropriate offices, i.e., program office, budget office, and CFMC. 5. Reimbursable Account Code Component During the grants specialist review of the package, CFMC is contacted to obtain a unique reimbursable account code component. The account code is assigned based on the information provided on the interagency agreement in Block 26 on the EPA Form 1610-1. This account code is critical to the interagency agreement and is the tracking mechanism for obligations and expenditure incurred to perform the work of the requesting agency. This code is entered on the final copy of the agreement. The account code component fields are as follows: Account Code Components: Site Name DCN FY Approp . Budget Org. Prg. El. Object Site Project Cost Org. Obligation 6. Issuing Authority Reimbursable authority must be issued for each JAG. Once the JAG is fully executed, the program office enters a reprogramming request in the Integrated Financial Management System (IFMS) by budget object class The budget division reviews and approves the reprogramming request in IFMS, if the request in accordance with the JAG. The reimbursable authonty is then reflected in the appropriate operating plan. 37 ------- 7. Spending Authority When the authority is received in the program office’s operating plan, funding documents to perform work for the requesting agency can be executed. These funding documents may be a labor distribution time sheet, travel order, procurement request for a contract or a grant order. It is imperative that the reimbursable account code component assigned to the TAG be used on all funding documents. Reimbursable funding may only be used to perform work in accordance with the budget categories on the TAG. 8. Billing the Requesting Agency CFMC reviews all reimbursable lAG’s obligations/expenditures recorded against the reimbursable account code to determine the amount to bill the requesting agency. A bill is issued when an amount is reflected as expended in IFMS. 9. Agency Locations Codes Agency location codes (ALC) assigned by Dept. of Treasury is essential information when billing the other agency. This number is used when a bill is submitted using the Intergovermental Payment and Collection( [ PAC) system. It is important to obtain this code if it is not provided on the information received from the requesting agency. (EPA’s ALC is 68010727). 10. CFMC’s Address and Contacts Mailing Address EPA Cincinnati Financial Management Center Cincinnati, OH 45268 Contacts: Connie Ely 513-487-2075 Valane Anderson 513-487-2082 Natalie Koch 513-487-2062 Molly Williams 513-487-2076 38 ------- REIMBURSABLE AUTHORITY GUIDANCE (MORE) EPA’S INTERAGENCY AGREEMENT AUTHORITIES ECONOMY ACT The Economy Act should be cited for the authority under which an JAG is to be awarded only if all the following statements are true-- The JAG involves one agency “providing goods or services” to another agency. That is, the servicing agency does not need the goods and services and would not have bought the goods or done the work but for the request of another agency. The amount of the JAG equals the total estimated cost of the goods and services including all direct and indirect costs. Indirect costs may be included only if the servicing agency has an indirect cost rate. At this time, EPA expects to have an indirect cost rate applicable to Oil Spills Response reimbursement lAGs starting in FY 2002. An indirect rate applicable to lAGs initiated in other programs will be implemented after an evaluation of the Oil Spills implementation is performed. For disbursement lAGs, see Comptroller Policy Announcement No. 9 1-04, Interagency Agreements - - Certification of Indirect Cost Rates, for proper JAG language providing greater assurance of cost allocability. None of the funds will be used for a grant or cooperative agreement. The servicing agency will be able to perform the service or obligate the funds within the penod of fund availability. If the servicing agency will be using a contractor to carry out the work, it is necessary that the funds be obligated by the servicing agency within their penod of availability. The decision official has determined that the requested services cannot be provided as conveniently or cheaply by contracting with a commercial enterpnse. If EPA is obtaining goods or services through another agency’s contract, one of the cnteria below must be met— The acquisition will appropnately be made under an existing contract of the servicing agency, entered into before placement of the order, to meet the requirements of the servicing agency; or The servicing agency has capabilities or expertise to enter into a contract for such supplies or services which is not available within EPA; or The servicing agency is specifically authonzed by law or regulation to purchase such supplies or services on behalf of other agencies. 39 ------- COOPERATION AUTHORITIES One or more of EPA’s cooperation authorities listed below, depending on the statute involved, should be cited for authority when the project is a joint effort of the involved agencies and EPA’s proposed activity is authonzed by an EPA statute. Some agencies may not be familiar with alternatives to the Economy Act and may be uncomfortable relying on EPA’s cooperation authorities for an interagency transaction. EPA’s Office of General Counsel believes, and a Comptroller General opinion supports the fact, that EPA’s cooperation authonties are sufficient authonty for both agencies to enter into a funds transfer agreement. 0CC should be contacted if another agency raises the issue. This is especially important if the project conflicts with any of the statutory restnctions of the Economy Act explained above. Cooperation authonties should be cited as the basis for lAGs if the following statements are generally true-- The project is directly related to the needs and substantive interests of both agencies. The statement of work, project descnption, or decision memorandum should explain all agencies’ substantive interest in the work. Both or several agencies are committing resources to the project, whether in the form of salaries, equipment, travel, contract services, or grant funds. The work is consistent with the language of one or more of EPA ’s cooperation authorities. If some or all of the funds will be used for grants or cooperative agreements, provided both the following conditions exist. 1. The relationship between the recipient and the involved agencies is one of assistance. The funding package must include a statement that the pnnciple purpose of the work is to support or stimulate the recipient to accomplish a public purpose and not for the direct use and benefit of the Federal government. 2. All agencies must have adequate authonty to award the grant or cooperative agreement. The decision memorandum should include the assurance that this is the case. 3. EPA cooperation and other agency authorities we are aware of at this time include-- Clean Water Act, Section 1 04(b)(2), Clean Water Act, Section 117. Clean Water Act, Section 50 1(b) (funds out only) Clean Water Act, Section 518(c). Clean Air Act, Section 1 03(b)(2). Clean Air Act, Section 102(b). Solid Waste Disposal Act, Section 8001. Solid Waste Disposal Act, Section 6003. Toxic Substance Control Act, Section 10. Toxic Substance Control Act, Section 26 (funds out only) 40 ------- Federal Insecticide, Fungicide, and Rodenticide Act, Section 17(d). Federal Insecticide, Fungicide, and Rodenticide Act, Section 20. Federal Insecticide, Fungicide, and Rodenticide Act, Section 22. Comprehensive Environmental Response, Compensation and Liability Act, Section 105(a)(4) and Section 115 read together with Executive Order 12580. Marine Protection, Research, and Sanctuaries Act, Section 203. The Safe Dnnking Water Act, Section 1412(b)(12)(A) (Arsenic). The Safe Drinking Water Act, Section 1450(b), (funds out for services). The Safe Drinking Water, Section 1442. The National Environmental Education Act, Section 4(b)(3) and 4(b)(1 1). National Community Service Trust Act, Section 121(b). OTHER AUTHORITIES Many other agencies also have alternative JAG authorities. This does not generally present a problem and EPA can accept the other agency/s citation as authonty for the agreement (e.g, Section 5112(e) of the Information Technology Management Reform Act of 1996, with respect to lAGs for computer services with GSA) In such situations, you should contact OGC or GAD as soon as you are aware of such circumstances (You should also contact OGC if the other agency has cited the Economy Act and any restrictions of that Act identified above pose a problem). INTERNATIONAL AUTHORITiES Authority for international lAGs with other federal agencies is usually either the Economy Act or EPA’s cooperation authorities, supplemented by Section l02(2)(F) of the National Environmental Policy Act In the case of funds-in Interagency agreements with the Agency for International Development, the authority may be Section 632(a) or 632(b)of the Foreign Assistance Act (22 U.S C 2392). There are significant differences between the two--contact OGC. Funds-in agreements with the Department of State are often authonzed by Section 8 of the DOS Basic Authorities Act (22 U.S.C. 2675). Authonty for funds-in agreements with most foreign governments or authorized international organizations (not technically lAGs, but using the L4..G form) is Section 607 of the Foreign Assistance Act (22 U.S.C. 2357). In the case of Taiwan, however, agreements usually cite the Taiwan Relations Act (22 U.S.C. 3308). For assistance in determining the appropriate authority for international agreements, contact OGC. Additional information on Interagency Agreement Funding Package Guidance and Funds Availability can be obtained at: http://intranet.epa.gov/ogd/policyl7.O-GPI-GPI-02-O1 .htm http://intranet.epa.govlogd/regulations. . . .policy.htm 41 ------- MEMORANDUM SUBJECT: Availability of JAG Funds FROM: Scott McMoran Is!, Chief Grants Information and Analysis Branch TO Steve Pressman, Chief Office of General Counsel Grants Branch In our opinion, current guidance in the Compendium of Procedures is fuzzy. We, with assistance from the Cincinnati Financial Management Office, have drafted the following set of pnnciples based on our understanding of the relevant statutory provisions and appropriations law guidance. Funds transferred for expenses such as salaries and benefit&, and travel which cite the Economy Act for authority. Appropriations law is clear--the funds expire when the parent appropriation expires. (31 USC 1535 (d)) . This would be true even if the JAG was for a project which was not completed during the availability -period (Compendium of Procedures, Chapter 1, paragraph 7.g.). Funds transferred for expenses such as salaries, benefits, arid travel and which cite CERCLA or the cooperation provisions of EPA’s program statutes for authority are obligated when the TAG is fully executed (signed by both agencies) The funds are available to the receiving agency for obligation and expenditure until they are expended or the project ends (Compendium of Procedures, Chapter 2, paragraph llI.c.l ). Funds transferred for use under a contract and which cite the Economy Act for authority are obligated when the JAG is fully executed. However, the receiving agency must obligate the funds to the contract before the period of availability of the source appropriation ends. Then, the funds are available for expenditure until the project is completed - or the contract ends, whichever is first (Compendium of Procedures, Chapter 2, paragraph ffl.c. 1.). ••Funds transferred for use under a contract or grant and which cite as authority CERCLA or the cooperation provisions of EPA ’s statutes are obligated when the JAG is fully executed. The funds are available until the project is completed, or the contract/grant ends (Compendium of Procedures, Chapter 2, paragraph ffl.c.l.). If we can agree on these principles, or a reasonable facsimile, we can add the appropriate information to each TAG so that the program offices and other agencies will be aware of how we will treat the funds. If you concur, please sign the block below. Please call Scott McMoran on 260-4392 if you have questions. Concur: Is! 4/26/94 Steve Pressman, OGC 42 ------- Data Warehouse Tips - If you know the document number of a commitment, obligation, or travel document use the query box in the middle *Here you can use all or a portion of the document number *you can limit your search to open or closed documents - If you know a portion of the document number you can use the % as a wildcard example 0342F100% * This is helpful if you are looking for a series of documents with similar document numbers - If you want to place the query results into a spreadsheet (Excel or Lotus 123) *If you are using Internet Explorer *Go to the Edit Menu and click “Select All” *using your mouse right click on the highlighted area and click copy *Open an Excel or Lotus Spreadsheet *Go to the Edit Menu in the spreadsheet application and click “Paste” *your Query Results will be displayed in the spreadsheet. * If you are using Netscape Navigator *Go to the File Menu and click “Save As” *Name the document and place an html extension at the end of the name *Example “Commitments.html” *Be sure to save the document where you can find it *Open an Excel or Lotus Spreadsheet *Go to the File Menu and click “open” *Choose where the document is example “My Documents” or “Desktop”, choose the document *your Query results will appear in the spreadsheet. 43 ------- FUNDS CONTROL MANUAL ADMINISTRATIVE CONTROL OF APPROPRIATED FUNDS TABLE OF CONTENTS 10/1 103 CHANGE CONTROL LOG INTRODUCTION PAGE CHAPTER 1: THE FEDERAL BUDGET PROCESS. LAWS. & GUIDANCE OVERVIEW OF THE FEDERAL BUDGET PROCESS AT EPA FIGURE 1 A National Program Manager (NPM) Budgets I-I B 0MB Submission 1-1 C 1 OMBPassback 1-1 2 Presidents Budget 1-2 D 1 House and Senate Mark-Up 1-2 2 Conference Action 1-2 3 Enacted Appropriation 1-2 a Continuing Resolution/ Agency Shutdown 1-3 b Supplemental Appropriations 1-3 E 0MB Apportionments 1-3 F 1 EPA Allotments 1-4 2. Advices of Allowance 1-4 FEDERAL LAWS AND GUIDANCE 1-5 A Principles of Federal Appropriations Laws 1-5 1 Appropriations as to Purpose 1-5 2 Appropriations as to Time 1-6 a The Unexpired Phase 1-7 b The Expired Phase 1-7 c The Cancelled Phase 1-7 3 Appropriations as to Amount 1-8 B Budget and Accounting Procedures Act (1921) 1-8 C EconomyAct (1958) 1-8 D Congressional Budget Impoundment and Control Act (1974) 1-8 E Federal Managers Financial Integrity Act (FMFIA) (1982) 1-9 F Chief Financial Officers Act (CFO) (1990) 1-9 C “M Acct Legislation 1-10 H Government Performance and Results Act (GPRA) (1993) 1-10 43 ------- FUNDS CONTROL MANUAL ADMINISTRATIVE CONTROL OF APPROPRIATED FUNDS TABLE OF CONTENTS 10/1/03 0MB Circular A-Il (Part 4 )/Instructions on Budget Execution (formerly 0MB Circular A-34)) 1-10 J 0MB Circular A-li (Part 2)/Preparation & Submission of Budget Estimates 1-11 Ill EPA LEGISLATION 1-12 A Authorizing Legislation - 1-12 1 CleanAirAct(CAA)1970 - 1-il 2 Federal Water Pollution Control Act (FWPCA) of 1948 1-12 Clean Water Act (CWA) 1972 1-12 Water Quality Act of 1987 (WQA) 1-12 Beaches Environmental Assessment & Coastal Health Act of 2000 1-12 3 Safe Drinking Water Act (SDWA) 1974 1-12 4 Solid Waste Disposal Act 1-12 Resource Conservation and Recovery Act (RCRA) 1976 1-12 Hazardous and Solid Waste Amendments (HSWA) of 1984 1-12 5 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”) 1980 1-13 Superfund Amendments and Reauthorization Act of 1986 (SARA) 1-13 Emergency Planning and Community Right-To-Know Act (EPCRA) 1-13 Small Business Liability Relief and Brownfields Revitalization 1-13 6 Pollution Prevention Act (PPA) of 1990 1-14 7. National Environmental Policy Act (NEPA) (1969) 1-14 8, Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) 1972 1-15 9 Food Quality Protection Act (FQPA) of 1996 1-15 10 Toxic Substances Control Act (TSCA) of 1976 1-15 11 Radon Abatement Act (RAA) of 1988 1-15 12 Oil Pollution Act (OPA) of 1993 1-15 13 Inspector General Act of 1978 1-16 14 Marine Protection, Research, and Sanctuaries Act (MPRSA) 1-16 B Appropriations Legislation 1-16 1 Annual Appropriations 1-17 2 Multi-Year Appropriations 1-17 a Environmental Program & Management (EPM) 1-17 b Science & Technology (S&T) 1-17 c Office of Inspector General (OIG) 1-18 44 ------- FUNDS CONTROL MANUAL ADMINISTRATIVE CONTROL OF APPROPRIATED FUNDS TABLE OF CONTENTS 10/1/03 3. No-Year Appropriations 1-18 a Hazardous Substance Response Trust Fund (Superfund) 1-18 b Leaking Underground Storage Tanks Trust Fund (LUST) 1-18 c Buildings and Facilities (B&F) 1-19 d Oil Spill Liability Trust Fund 1-19 e State and Tribal Assistance Grants (STAG) 1-19 CHAPTER 2: ROLES AND RESPONSIBILITIES FOR FUNDS CONTROL PARTICIPANTS. 2-1 A Assistant Administrators (A.As) 2-1 National Program Managers (NPMs) 2-1 Responsible Planning and Implementation Officers (RPIOs) 2-1 B. Regional Administrators (RAs) 2-1 C Senior Resource Officials (SROs) & Assistant Regional Administrators (ARAs) 2-2 D Senior Budget Officers (SBOs) 2-3 E. Regional Budget Officers 2-3 F Allowance Holders (AHs) 2-4 G Funds Control Officers (FCOs) 2-4 H Approving Official 2-5 I Originator 2-6 J Obligating Officials 2-6 K. Chief Financial Officer (OCFO) 2-6 1 Office of Planning, Analysis, and Accountability (OPA.A) 2-7 2. Office of Enterprise Technology and Innovation (OETI) 2-7 3. Office of Budget (OB) 2-7 4 Office of Financial Management (OEM) 2-8 5 Office of Financial Services (OFS) 2-8 L Financial Management Officers (FMOs) - 2-8 M Accounts Payable Certifying Officers & Disbursing Officers 2-8 N Office of General Counsel (OGC) 2-9 CHAPTER 3: BUDGET EXECUTION PROCESS ACCOUNT CODE STRUCTURE AT EPA 3-1 A 6-Field IFMS Account Code 3-1 1 Budget Fiscal Year Field (BFY) 3-1 45 ------- FUNDS CONTROL MANUAL ADMINISTRATIVE CONTROL OF APPROPRIATED FUNDS TABLE OF CONTENTS 10/1/03 2 Fund (Appropriation) Field (APPR) 3-1 3. Organization Field (ORG) 3-2 IFMS Account Code Expansion/Utilization FIGURE 2 4 Program Field - Program Results Code Field (PRC) 3-4 5 Site/Project Field 3-5 6 Cost Organization Field 3-6 B Appropriation Number (Treasury Account Symbol) 3-6 C Object Classes 3-6 1 0MB Object Classification Codes 3-6 2 EPA Budget Object Classes 3-7 3 EPA Accounting Sub-Object Classes 3-7 OPERATING PLAN CONTROL AND MANAGEMENT 3-8 A Advice of Allowances 3-8 1 Nature of Allowances 3-8 2 Advice of Allowance Issuance 3-8 3 Adhering to Advices of Allowance 3-9 B Reprogramming 3-9 I Purpose and Definition 3-9 2 General Reprogramming Restrictions 3-10 3. Reprogramming Limitations (Ceilings and Floors) in IFMS 3-11 a Ceilings 3-1 1 b Floors 3-13 4 Reprogramming Process 3-13 C Carryover of Unobligated Balances 3-14 D Reimbursable Allowances 3-14 III. COMMITTING AND OBLIGATING APPROPRIATED FUNDS 3-17 A Reviewing and Approving Funding Documents 3-17 B Recording Commitments 3-18 1. Funds Availability Check 3-18 2 Entering Documents into IFMS 3-18 3 Unfunded Procurement Requests for Planning Purposes 3-19 C Monitoring Funds After Commitment 3-20 1 IFMS Tables 3-20 2 Financial Data Warehouse (FDW) Reports 3-20 3 Orbit Reports 3-21 46 ------- FUNDS CONTROL MANUAL ADMINISTRATIVE CONTROL OF APPROPRIATED FUNDS TABLE OF CONTENTS 10f1103 D Recording Obligations 3-21 E Authorizing Payments 3-22 F Reconciliation 3-23 G. Resolving Issues with Commitments and Obligations 3-23 H. Prevalidation of Funds 3-24 I Overruns/Recoveries 3-24 J. Ratification of Unauthorized Procurements 3-26 K. Recertification of Funds 3-27 L. Centrally Managed Allowances (“Reserves”) 3-29 IV MANAGEMENT REPORTING AND END-OF-YEAR CLOSEOUT 3-31 A Unliquidated Obligations 3-31 B End of Year Close-Out 3-33 CHAPTER 4: SPECIAL SUBJECT ITEMS A Violations Creation, Reporting, & Penalties 4-1 1. Antideficiency Act Violations 4-1 2 EPA Administrative Control of Funds Violations 4-2 B U S Government Purchase Card Program 4-3 C Ordering GSA Office Supplies 4-5 D. Payroll Management and Tracking/PeoplePluS 4-6 E Operating Under a Continuing Resolution 4-7 F Split Funding with Multiple Appropriations 4-7 G Layoffs Between Appropriations 4-9 H Working Capital Funds Services 4-9 I “Administrative” vs “Programmatic 4-11 1 Philosophy 4-11 2 Special-Use Facilities 4-14 3. Examples of Administrative and Programmatic Costs 4-17 J Direct Implementation of State Grants 4-21 K Fees and Fee Programs 4-21 L. Additional Grants information 4-21 EXHIBITS 2520-2-1 Funds Control Relationships in EPA 2520-2-2 FCO Designation Letter and Form 47 ------- FUNDS CONTROL MANUAL ADMINISTRATIVE CONTROL OF APPROPRIATED FUNDS TABLE OF CONTENTS 10/1/03 2520-2-3 Servicing Finance Office (SF0) List 2520-3-1 Treasury SymbollAppropriation Code List 2520-3-2 Object Class Relationships 2520-3-3 IFMS Budget Table Hierarchy 2520-3-4 How to Write a Reprogramming Justification APPEND IC ES 2520-A Glossary of Common Budget Terms and Definitions 2520-B Checklist of Good Fund Control Practices 2520-C Suggested FCO Job Qualifications & Training 48 ------- 12 ------- t a • : ; 34 t : i) .JLAJ ------- Improper Payments Information Act of 2002 National Grants Management Training Conference Jacksonville, FL November 2004 ------- What We Will Talk About •Defining IPIA • Expectations •What We’ve Done •What We’re Doing • Next Steps 11/1/2004 Draft 2 ------- Improper Payments? •Also known as Erroneous Pay •Passed in 2002 — P.L 107-300 — 0MB Memorandum — M-03-13 • Designed to reduce payments that shouldn’t be made • Look at risk points in payment cycle 11/1/2004 Draft 3 ------- What Are the Requirements? • Identify Susceptible Programs •The program is susceptible... —$10 million in improper payments and -r 2.5% of the program dollars • Each Agency defines “the program” —EPA: program/projects • Identify and commit to reducing improper payments 11/1/2004 Draft 4 ------- Also, IPIA Requires... • Recovery Audit Contractors — Outside contractor looking for duplicate payments •Travel Cards - Susceptible to improper payments •Purchase Cards — Susceptible to improper payments 11/1/2004 Draft 5 ------- Improper Payments are Important • President’s Management Agenda Item •OMB is tracking • Focus on Grants • But, few improper payments in EPA • New Twist — Traôk the payments through the entire payment cycle 11/1/2004 Draft 6 ------- What We’ve Done So Far • First Year — Performed Risk Analysis — Developed Corrective Action Plan — Submitted to 0MB May 2004 • Susceptible Programs — Clean Water State Revolving Fund — Drinking Water State Revolving Fund — Superfund Remedial Program 11/1/2004 Draft 7 ------- Commitments so Far • Reduce the amount of improper payments — From $12.4 million to $11.2 million in FY 2004 — By 10% to $10 million in FY 2005 — By 10% to $9 million in FY 2006 11/1/2004 Draft 8 ------- It’s a New Year • New Risk Analysis - Identify at risk programs - Sample transactions — Follow payments through payment cycle •State Revolving Funds — Reviewing again — Office of Water 11/1/2004 Draft 9 ------- Our New Plan... • In process of writing measurement plan TNeed 0MB approval — Including a review of full payment I cycle •Sample occurs 2nd Quarter •Corrective Action Plan in 3rd Quarter 11/1/2004 Draft 10 ------- The Agency is Involved •Grants Office plays a big role — Looking at all grantees — Evaluating for susceptible areas •Water Office also plays a big role T Reviewing states — Reviewing payments 11/1/2004 Draft 11 ------- What’s Next • FY 2004: Report results in PAR • FY 2005: Second Go-round: — 1st Quarter: 0MB concurs on measurement plan — 2’ ’ Quarter: Sampling occurs — 3rd Quarter: Corrective Action Plan • FY 2006: Demonstrate reduction in improper payments 11/1/2004 Draft 12 ------- Useful Information •OMB Website —0MB Memoranda, M-03-07 &M-03- .13 http : Ilwww . wh itehouse.qov/om b/mem oranda/2003.html • OCFO Improper Payments Team — Bill Howard — 202-564-4933 — Joe Nemargut — 919-541-3777 — Charles Young — 202-564-4914 11/1/2004 Draft 13 ------- Questions and Discussion 11/1/2004 Draft 14 ------- EPA OSDBU Non-Procurement MBEIWBE Program QuickFacts! Who We Are and Our Mission: OSDBU is the Office of Small and Disadvantaged Business Utilization. Our mission is to support the protection of the environment and human health by fostenng opportunities for partnerships, contracts, subagreements, and grants for small and socioeconomically disadvantaged concerns. Who We Are Not: We are not an affirmative action program. Our program is firmly focused on education and outreach, resulting in the mclusion of small and soctoeconomically disadvantaged businesses in both direct and indirect procurement opportunities at EPA. What is the Non-Procurement MBEWBE Program?: A goaling program for the participation of MBEs/WBEs in procurements funded through EPA assistance agreements. Why Does the Program Exist?: The program was mandated by congress in response to the large number of procurement opportunities available through assistance agreements vs. Contracts. At EPA, assistance agreement dollars are approximately four times as much as contract dollars. The statutory authonty for the program is as follows: Public Law 101-549, Nov 15, 1990 (clean air act): To the extent practicable, not less than 10% made available to DBEs. Public Law 102-389, Oct 6, 1992 (clean water act): To the fullest extent possible, at least 8% made available to socially and economically disadvantaged concerns, including HBCUs and women. Purpose of the Non-Procurement MBEWBE Program: The purpose of the Non-Procurement MBE/WBE program is to ensure that small, minority, and women-owned business entities are given the opportunity to participate in procurement awards under EPA financial assistance agreements. ------- How We Achieve Our Purpose: Recipients of EPA financial assistance agreements are required to seek, and encouraged to utilize small, minority, and women-owned businesses for their procurement needs under the financial assistance agreement. This is done through the inclusion of terms and conditions in the financial assistance agreement referred to as the “SLx Affirmative Steps” and through the negotiation of “Fair Share Objectives/Goals”. The Six Affirmative Steps: Positive efforts shall be made by recipients to utilize small businesses, minority-owned firms, and women’s business enterprises, whenever possible. Recipients of Federal awards shall take all of the following steps to further this goal. (1) Ensure that small businesses, minonty-owned firms, and women’s business enterpnses are used to the fullest extent practicable. (2) Make information on forthcoming opportunities available and arrange time frames for purchases and contracts to encourage and facilitate participation by small businesses, minority- owned firms, and women’s business enterpnses. (3) Consider in the contract process whether firms competing for larger contracts intend to subcontract with small businesses, minority-owned firms, and women’s business enterpnses. (4) Encourage contracting with consortiums of small businesses, minority-owned firms and women’s business enterpnses when a contract is too large for one of these firms to handle individually. (5) Use the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Department of Commerce’s Minonty Business Development Agency in the solicitation and utilization of small businesses, minority-owned firms and women’s business enterprises. (6) If the prime contractor awards subcontracts, requiring the contractor to take steps in paragraphs (b)(1) through (5) of this section. When the Steps Apply: The Six Affirmative Steps apply and are required to be followed when a financial assistance agreement recipient makes a purchase in any of the following categories: Construction, Equipment, Services and Supplies. The steps apply regardless of the amount of the grant award The steps also apply to sub-recipients. ------- How Fair Share Objectives/Goals Work: The Program requires that fair share objectives for Minonty Owned Businesses (MBE5) and Women Owned Business (WBEs) be negotiated with the States and/or recipients. A fair share represents an amount of funds reasonablely commensurate with the total project funding and the availability of qualified MBE’s and WBE’s, taking into account experience on EPA-funded projects and other comparable projects in the area These objectives operate as goals, not quotas. There are no penalties imposed by EPA if the objectives are not met. Fair share objectives/goals are negotiated by EPA MBE/WBE coordinators, not by project officers. Recipient Reporting...How We Know the Program is Working: Assistance Agreement Recipients are required to report their procurement activities on EPA Form 5700-52(A). This form is required of ALL recipients, even if their procurement activity for the reporting period is zero. It is important for OSDBU and the Agency overall to capture this data in order to monitor if fair share objectives are met, and to measure the effectiveness of our outreach efforts. What You Can Do: • Be aware of why we have the MBE/WBE program and how it works. • Make sure every grant, cooperative agreement, or JAG contains the N4BE/WBE term and condition. • Provide assistance when requested, or direct inquiries to OSDBU or to the regional coordinators for help. • Be alert to any potential problems with compliance/implementation. • Remember us at closeout and during your reviews.. .we are a material term and condition of the grant. ------- REGIONAL MBEIWBE COORDINATORS Region 1 Sharon Molden U.S. EPA John F Kennedy Federal Building One Congress Street Boston, MA 02203 Office: (617)918-1062 FAX: (617)918-1909 Region 3 Ramona McQueen U.S. EPA 1650 Arch Street Philadelphia, PA 19103 Office (215)814-5155 FAX: (215)814-5108 gion 5 Sharon Green U.S. EPA 77 West Jackson Blvd. Chicago, IL 60604-3507 Office: (312)353-5661 FAX: (312)353-9096 Region 7 Chester Stovall U.S. EPA 901 North 5 th Street Kansas City, KS 66101 Office: (913)551-7549 FAX: (913)551-7976 Region 9 Joe Ochab U.S. EPA 75 Hawthorne Street, (P-22) San Francisco, CA 94105 Office: (415)972-3761 FAX: (415)947-3556 Region 2 Otto Salamon U.S. EPA 290 Broadway New York, NY 1007-1866 Office: (212)637-3417 Fax: (212)637-3518 Region 4 Josephine Brown U.S. EPA 61 Forsyth Street, SW Atlanta, GA 30303-8960 Office: (404)562-9672 gion 6 Debra Bradford U.S. EPA 1445 Ross Ave., 12 th Floor, Suite 1200 Dallas, TX 75202-273 3 Office: (214)665-7406 FAX: (214)665-7284 R gion 8 Maurice Velasquez U.S. EPA 999 18th Street, Suite 500 Denver, CO 80202-2405 OfficeS (303)312-6862 FAX: (303)312-6685 Region 10 Marie McPeak U.S.EPA 1200 6 th Avenue (OMIP-145) Seattle, WA 98101 OfficeS (206)553-2894 FAX: (206)553-4957 ------- 0MB CONTROL NO 2030-0020 APPROVED 12/30102 APPROVAL EXPIRES 12/31/05 U.S. ENVIRONMENTAL PROTECTION AGENCY MBEIWBE UTILIZATION UNDER FEDERAL GRANTS, COOPERATIVE AGREEMENTS, AND INTERAGENCY AGREEMENTS PART 1. (Reports are required even if no procurements are made during the reporting period.) 1A FEDERAL FISCAL YEAR 200 lB. REPORTING QUARTER (Check appropnate box) 0 1” (Oct-Dec) 0 2 ’ (Jan-Mar) 0 3 rd (Apr.Jun) 0 4th (Jul-Sep) 0 Annual IC REVISION HIGHLIGHT ITEMS TO BE REVISED AND PROVIDE EXPLANATION IN BLOCK No 6 Year Quarter 2.A FEDERAL FINANCIAL ASSISTANCE AGENCY 3A REPORTING RECIPIENT (Name and Address) (EPA Office Address - ATTN DBE Coordinator) 2B REPORTING CONTACT 2C PHONE 3B REPORTING CONTACT (Recipient) 3C PHONE (EPA DBE Coordinator) 4A FINANCIAL ASSISTANCE AGREEMENT ID NUMBER 4B FEDERAL FINANCIAL ASSISTANCE PROGRAM (SRF Stale Recipients. Refer to Instructions for Completion of 4A, 5A, and SC) 5A TOTAL ASSISTANCE AGREEMENT 5B Check and skip to Block 5C TOTAL PROCUREMENT AMOUNT THIS REPORTING AMOUNT No 7 if no procurements PERIOD (ONLY include the amount not in any pnor reporting and accomplishments penod and procurements made by SRF Loan Recipients and Sub- EPA Share $_______________________ were made this reporting penod o Recipients) $______________________________ Recipient Share $______________________ (Exclude procurement amounts reported by Pnme Contractors) 5D ACTUAL MBEIWBE PROCUREMENT ACCOMPLISHED THIS 5E ACTUAL MBEIWBE PROCUREMENT ACCOMPLISHED THIS REPORTING PERIOD BY RECIPIENT (SRF State Recipients. Report REPORTING PERIOD BY LOAN RECIPIENTS, SUB-RECIPIENTS, State Procurement Activities 1-lere) AND PRIME CONTRACTORS $MBE $WBE $MBE $WBE Construction Construction Equipment Equipment Services Services Supplies Supplies TOTAL TOTAL 6 COMMENTS 7 NAME OF AUTHORIZED REPRESENTATIVE TITLE 8 SIGNATURE OF AUTHORIZED REPRESENTATIVE DATE EPA FORM 5700-52A - (5196) available electronically at http I/www cpa go /osdbu/5700 52a pdf NOTE THIS REPORT IS DUE 30 DAYS AFTER THE END OF EACH FEDERAL FISCAL QUARTER OR ANNUAL SUBMiSSION DATES ARE January 30, April 30, July 30, and October 30’ ‘SUBMISSION DATE FOR ANNUAL REPORTS ------- MBE!WBE PROCUREMENTS MADE DURING REPORTING PERIOD EPA Financial Assistance Agreement Number: ________________ 1 Procurement Made By 2 Business Enterprise 3 $ Value of 4 Date of Award 5 Type of Product or ServucesA 6. NamelAddress/Phone Number of MBEIWBE ‘ Recipient Other Minority Women Procurement MMIDDIYY (Enter Code) Co ntractor or Vendor AType of product or service codes 1 Construction 2 Supplies 3 = Services 4 = Equipment A Business SeMces B = Prof ess onaJ Services C Repair Services D Personal Services ------- EPA FORM 5700-52A -(5196) (Approval Expires 9/30102) INSTRUCTIONS MBE/WBE UTILIZATION UNDER FEDERAL ASSISTANCE AGREEMENTS AND INTERAGENCY AGREEMENTS EPA FORM 570 0-52A A. General Instructions: MBEIWBE utilization is based on Executive Orders 11625, 12138, 12432, PL 102-389 and EPA Regulations Part 30 and 31 EPA Form 5700-52A must be completed by recipients of Federal grants, cooperative agreements, or other Federal financial assistance which involve procurement of supplies, equipment, construction or services to accomplish Federal assistance programs Recipients are required to report to EPA within one month following the end of each Federal fiscal year quarter or annually as in the agreement B. Definitions. Procurement is the acquisition through order. purchase, lease or barter of supplies, equipment, construction or services needed to accomplish Federal assistance programs A contract is a wntten agreement between an EPA recipient and another party (other than another public agency) and any lower tier agreement for equipment, services, supplies, or construction necessary to complete the projecl Includes personal and professional services, agreements with consultants, and purchase orders A minonty business enterpnse (MBE) is a business concern that is (1) at (east 51 percent owned by one or Inclusion of MBEsIWBEs on solicitation lists 2 Assure MBEsIWBEs are solicited once they are identified 3 Where feasible, divide total requirements into smaller tasks to permit maximum MBEIWBE participation 4 Where feasible, establish delivery schedules which will encourage MBEJWBE participation 5 Encourage use of the services of the U S Department of Commerce s Minority Business Development Agency (MBDA) and the U S Small Business Administration to identify MBEsIWBEs more minority Individuals, or, in the case of a publicly owned business, at least 51 percent of the stock is owned by one or more minority individuals, and (2) whose daily business operations are managed and directed by one or more of the minority owners U S citizenship is required Recipients shall presume that minonty individuals include Black Amencans, Hispanic Americans, Native Americans, Asian Pacific Amencans, or other groups whose members are found to be disadvantaged by the Small Business Act or by the Secretary of Commerce under section 5 of Executive order 11625 The reporting contact at EPA can provide additional information A woman business enterprise (WBE) Is a business concern that is. (1) at least 51 percent owned by one or more women, or, in the case of a publicly owned business, at least 51 percent of the stock is owned by one or more women and (2) whose daily business operations are managed and directed by one or more of the women owners Business firms which are 51 percent owned by minonties or women, but are in fact managed and operated by non- minonty individuals do not qualify for meeting MBE/WBE procurement goals The following affirmative steps for utilizing MBEs and WBEs are required to be documented 6 Require that each party to a subgrant, subagreement, or contract award take the affirmative steps outlined here C Instructions for Part I la Complete Federal fiscal year lb Check applicable reporting box quarterly or annually (Federal fiscal year runs from October 1 through September 30) lc Indicate if this is a change to previous year or quarter (Highlight Items to be revised and provide explanation In Block No 6-Comments) ------- 2a-c “Will be provided by EPA” by the loan recipients, sub-recipients, and prime contractors 3a-c Identify the agency, state authonty, university or other organization which is the recipient of the Federal financial assistance and the person to contact concerning this report 4a Assistance Agreements or Interagency Agreement number assigned .by EPA A separate form must be used for each Assistance Agreement or Interagency Agreement ‘For SRF recipients In box 4a list numbers for ALL open Assistance Agreements SRF recipients will report activity for all Agreements on one form 4b Refer back to Assistance Agreement document for this information 5a Total amount of Assistance Agreement wtiich includes Federal funds plus recipient matching funds and funds from other sources ‘For SRF recipients only SRF recipients will not enter an amount in 5a Please leave 5a blank 5b Self-explanatory 5c Total contracts/procurements awarded this quarter For example Actual dollars for procurement from the procunng. office, actual contracts let from the contracts office, actual goods, services, supplies, etc. from other sources Including the central purchasing! procurement centers) °For SRF recipients only In 5c please enter the total procurement amount for the quarter under all of your SRF Assistance Agreements The ligure reported in this section is not directly tied to an Individual Assistance Agreement identification number Sd Dollar amount of all MBEIWBE procurement amounts awarded under this reporting period by the recipient (These amounts include the Federal. State and local shares in the procurement awards). (SRF state recipient report state procurements In this section) 5e Dollar amount of all MBEPINBE procurement amounts awarded under this reporting penod 6 Additional comments or explanations Please refer to specific item number(s) if appropnate 7 Name and title of official administrator or designated reporting official 8 Signature and month, day year report submitted D Instructions for Part II’ For each MBEIWBE procurement made under this assistance agreement dunrig the reporting penod, provide the following information 1 Check whether this is a first tier procurement made directly by Federal financial assistance recipient or other second tier procurement made by recipient’s subgrantee or pnme contractor Include all qualifying second tier purchases executed this quarter regardless of when the first tier procurement occurred . 2 Check MBE 0rWBE 3 Dollar value of procurement 4 Date of award, shown as month, day. year Date of award is defined as the date the contract or procurement was awarded, not the date the contractor received payment under the awarded contract or procurement, unless payment occurred on the date of award 5 Using codes at the bottom of the form, identify type of product or service acquired through this procurement (eg, enter 1 if construction, 2 if supplies, etc) 6 Name, address, and telephone number of MBEM/BE fim, TM, dote. req ,e,1,d to annçly * 4th p .ootoJon , ,n ,dnd.d by .1,011. te regundan , i40 CFR P ,01 30 and 31i 0MB Cbn,0 . te *4dod by SPA to an,,,. .on00 arM aOeoB ,e aulItOnc. n , ,an 9 ar a nnt. Acaa.ia mactote Sole ate arqnhd to obiob , tondto . *4,10 nO idedge 011,5.1014 to pm01ded Thep, r p0tt0t9 and tncordrg blo Om tot 05a mlecBon 00 bd*m.Oon a eetecet.d to enarage i hoc. par ,anpnnoa a.ncc.ly Sudan ‘Oe ’n , 0 Oar to Wt . *411,1. ar Wan 1, ,e ,c., 0,51,0100 by par ’re* to ganateto tantotob ,, .11,0,, 1, dIed,,,,. te pm ,lde bdaanatIo,, toe. to .. Fede. ,i agency Thin bndudei One Ikr ,. needed to roniew innbn00lan , dncelop a , 5the bland tend 05101 Iadn*logy 1101 oynia,tre the oposee of deIedb.g. n da0ng 01 cteB)fflo i,00 .tneSan. p00 1010n g tend ,rotot*4oing It5o.rn0tio, and dlad,elng .00 i,o.000.g tohon00,0 e400 the euding ooy. to mngdy aith Coy fanotootey 0,5115151 . 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This policy rescinds and replaces: EPA Order 5700.4 “Interim Grantee Compliance Assistance Initiative,” EPA Order 5700.3 (and GPI-99-5) “EPA Policy for Post-Award Management of Grants and Cooperative Agreements by Headquarters and Regional Offices,” and the Grants Administration Division (GAD) Grant Policy Issuances GPI-98-6, “Post- Award Management of Assistance Agreements,” and GPI-98-2 “National Strategy to Avert a Future Grant Closeout Backlog.” The purpose of Post-Award monitoring is to provide for the effective oversight of recipient performance and management Expected results of this policy include: 1) continued improvement in post-award efforts; 2) identifiable and documented post-award activities, and, 3) coordinated program and Grants Management Offices (GMOs) post-award efforts. BACKGROUND Between 1998 and 2000, the Agency promulgated GAD policy GPI-98-2, GPI-98-6, and EPA Orders 5700.3 and 5700.4, which comprise the basis of EPA’s Post-Award monitonng activities. These policies require GMOs to develop annual closeout strategies and for all GMOs and Program Offices to develop annual monitoring plans, describing what, how and when post-award activities are performed. Since issuing these policies, the Agency continues its efforts to monitor grantee compliance with the administrative and programmatic requirements of the Agency’s financial assistance programs. Over the last four years, the Agency has made significant progress in post-award management and is committed to strengthening these efforts. EFFECTIVE This Policy will be effective January 8, 2003. The first annual Post-Award DATE Monitoring Plan will be due no later than January 8, 2003. DEFINITIONS For purposes of this policy, the following definitions are used: Grants Management Office (GMO): The Headquarters and Regional Units principally responsible for all business management aspects associated with the review and negotiation of applications and the award and administration of funded projects through audit resolution and final close out. Official Grant File (Grant File) The official file developed and maintained by the GMO to serve as a composite collection of documents and/or items that provide programmatic, administrative and fiscal information on the purpose, performance and history of a specific award to a specific grantee. Official Project File (Project File): The official file developed and ------- maintained by the Program Office to serve as a collection of documents andlor items that provide programmatic and/or fiscal informatLon on the purpose, performance and history of a specific award to a specific recipient. Off-site Evaluation (Desk Review): An advanced monitoring technique where the GMO or Program reviews recipient administrative, programmatic and/or technical procedures, progress and capacity Typically, these evaluations are conducted by telephone, away from the recipient’s location, utilizing a suggested protocol On-site Evaluation An advanced monitoring technique where GMO or Program representatives visit a recipient’s site. For GMOs, these evaluations follow a suggested protocol and include the review of recipient administrative procedures and capabilities. For Programs, these evaluations may follow a suggested protocol and include the review of recipient programmatic and technical progress and capabilities. Program Office (Program): Either the Headquarters Program Office or Regional Program Office pnncipally responsible for managing the technical/programmatic aspects of a specific program. For purposes of this policy, Regional Program Offices may b constituted at a Division level. POLICY This policy comprises five areas: “Grants Management Office Requirements,” “Program Requirements,” “Consolidated Options,” “GAD Commitments,” and “Agency-wide Requirements.” The policy provides two options for the required annual calendar-year Post Award Monitoring Plans: 1) individual plans for the GMOs and Program Offices; and, 2) a consolidated plan that meets the requirements for regional GMOs and regional Program Offices. Grants Management Office Requirements Plans On, or before, January 8 of each year, each GMO will submit an annual, calendar year Post-Award Monitonng Plan to the Director, GAD. This plan must be signed by the Senior Resource Official (or equivalent). A copy of the plan must also be provided electronically, either through electronic mail or an attached diskette Electronically submitted plans must be sent to GAD directly from the SRO. At a minimum, every Plan must provide for the following: Baseline Monitonng Baseline Monitonng is the minimum, basic monitonng that should take place on every award issued by the GMO on an ongoing basis throughout the lifetime of the award. For the purposes of this Policy, Baseline -2- ------- Monitoring will include ensurmg, to the best of the GMO’s ability, that administrative award terms and conditions are satisfied, A-133 audits are filed (as applicable) and Financial Status Reports filed and progress reports and any Quality Assurance matenals are received by the Program Office/Project Officer. During this process, the Grant Specialist (or other designated, and qualified, personnel) will make contact with the Project Officer and the recipient, annually during the life of the agreement. At this time, the Grant Specialist should also review the financial status of the award by comparing funds available to project progress andlor time remaining on the project. If follow-up is needed, the Grant Specialist will do so. All baseline monitonng must be documented in the Official Grant File. Advanced Monitonng Advanced Monitoring is the process by which a recipient’s compliance with applicable administrative and financial statutes, regulations, conditions and policies is evaluated. This can take place through the use of on-site evaluations or off-site evaluations (Desk Reviews). GMOs are responsible for conducting Advanced Monitoring on minimum of 10% of their active grantees (as of the previous October 1). Active grantees include only those whose projects are open but not expired. Counting towards a GMO’s 10% requirement will be done on a recipient basis. However, in instances where a recipient requires a second evaluation within the Plan year, separate reports must be filed for each evaluation to count. Reports should be completed within 60 calendar days of the completion of the evaluation. Activities should not be counted until a report is filed. All advanced monitonng activities completed by the GMO must include a final report which utilizes the format in Attachment One GMOs are responsLble for conducting a minimum number of desk reviews equal to one for each Grant Specialist dunng the Plan year. For example, if a GMO has 10 Grant Specialists, 10 desk reviews are required of that GMO during the Plan year. As part of the 10% requirement, GMOs are also responsible for conducting on-site evaluations during the plan year. All on-site evaluations will include transaction testing for unallowable costs (e.g., lobbying, litigation or entertainment expenses). Attachment Three describes the process of planning and conducting a Desk Review. Attachment Four is a suggested protocol to use in conducting a Desk Review GMOs may modify the protocol to meet their individual needs. Attachment Five describes the process of planning and conducting an on- site evaluation Attachment Six is a suggested protocol to use in conducting on-site evaluations. GMOs may modify the protocol to meet their individual needs. -3- ------- All Advanced Monitonng Activities must be documented in the Official Grant File. Copies of completed protocols must be included in the Official File. Reports and correspondence, as generated, must also be included in the Official File. Critena for selecting recipients for review should be spelled out in the Plan and documented in the Official Grant File for each review. Suggested criteria may mclude, but are not limited to. Referrals, Audit Findings, Agency Priority, Recipient Expenence, Project(s) Cost, Risk, Recipient Location, Statutory or other Requirements, Earmarks, and Funding by Multiple Programs. Attachment Seven is a sample scorecard which may be adapted for local use or guidance. Use of this scorecard is optional. GMOs must ensure appropriate follow-up actions are taken in response to the results of advanced monitoring activities. Where desk reviews identif ’ significant problems, GMOs will be expected to take necessary corrective action (see 40 CFR § 30.60 and §31.43) or target the matter for an on-site review. Pre-Award and Technical/Management Assistance Activities (Assistance Activities ) Assistance Activities are those actions which are performed for the express purpose of aiding recipients and potential recipients to ensure their administrative and financial abilities and techniques are sufficient. They will generally take the form of Management Assistance Forums or Administrative Technical Assistance. Management Assistance Forums are where the GMO brings together a group of recipients or applicants to address sound technical practices. Administrative Technical Assistance is where a GMO works one-on-one with a recipient to address its administrative capabilities and bnng them in line with regulatory and statutory requirements and expectations Assistance Activities do not include activities related to baseline or advanced monitoring activities GMOs should ensure that pre-application assistance is made available on an equal basis to all potential applicants, and in a manner consistent with Module ifi of the Project Officer Training Manual. Assistance activities with up to 1% of the active recipients can be counted toward the 10% Advanced Monitoring Goal. GMOs must ensure, to the extent practical, that all Assistance Activities are documented in Official Grant File. For Management Assistance Activities not attributable to a specific project, a central file must be maintained by the GMO Minimum documentation should include, the date of the activity, the recipient contact and the type of activity involved. Closeouts The closeout of completed assistance agreements must be addressed in the Plan and include: Acknowledgment that the Agency is committed to closeout assistance agreements in a timely fashion (within 180 days of the end of the award). -4- ------- A summary of closeout activity in the previous year; and, A discussion of how closeouts will be addressed during the Plan year and how previously identified impediments will be addressed. Reporting Each GMO must submit to GAD, quarterly reports indicating the number of monitoring and management assistance activities taking place dunng the quarters ending in December, March, June and September Reports are due no later than the 8t1 day of the month following the end of the quarter. While GMOs do not have to submit with their reports a list of the recipients that received advanced, a central list must be maintained by the GMO for possible validation and review purposes The required format for reporting monitonng and assistance activities to GAD is m Attachment Eight. In its Plan, each GMO must identify its reporting contact and note any changes of that contact when the quarterly report is submitted. Grantee Compliance Database The Grantee Compliance Database is a tool available in Lotus Notes. The Database, maintained in GAD, stores historical and prospective data on all Advanced Monitoring Activities, including on-site and off-site evaluations. Database entries must be opened prior to the activity described. Each GMO will designate one individual in its Plan as responsible for ensunng the input of such information into the Database. GAD will provide necessary direction for using this Database. The use of the database to record advanced monitoring activities is required. All applicable fields within the database must be completed to constitute a valid record. Agency Program Office Requirements Plans On, or before, January 8 of each year, each Headquarters and Regional - Program Office will submit an annual, calendar year Post-Award Monitoring Plan to the Director, GAD. This plan should be signed by the Senior Resource Official (or equivalent). A copy of the plan should also be provided electronically, either through electronic mail or an attached diskette. Electronically submitted plans must be sent to GAD directly from the SRO Every Plan must provide for the following: -5- ------- Baseline Monitoring Baseline Monitoring is the minimum, basic monitoring that should take place on every award issued by the Program Office on an ongoing basis throughout the lifetime of the award. For the purposes of this Policy, Baseline Monitoring will include ensuring, to the best of the Program’s ability, that programmatic award terms and conditions are satisfied including but not limited to, receipt and acceptance of progress reports, and Quality Assurance requirements. Dunng this process, the Project Officer (or other designated, and qualified, personnel) will make contact with the Grant Specialist and the recipient, annually dunng the life of the agreement. At this time, the Project Officer should also review the financial status of the award by companng funds available to project progress and/or time remaining on the project. If follow-up is needed, the Project Officer will do so. All baseline monitoring must be documented in the Official Project File. Advanced Monitoring Advanced Monitoring is the process by which a recipient’s compliance with applicable programmatic and financial statutes, regulations, conditions and policies is validated. This can take place through the use of on-site evaluations or off-site evaluations (desk reviews). Program Offices are responsible for conducting on-site or off-site evaluations on a minimum of 10% of their active grantees (as of the previous October 1). Only Advanced Monitoring Activities will count towards a Program Office’s 10% requirement. Counting towards the 10% requirement for Program Offices will be done on an award/program basis provided separate reports are filed for each evaluation conducted. Reports should be completed within 60 calendar days of the completion of the evaluation Activities should not be counted until a report is filed. All advanced monitoring activities completed by the Program Office must include a final report which utilizes the format in Attachment Two. The Director, GAD, may approve the use of a Program’s standard national report format provided the format contains the information included in Attachment Two, and the Program provides a crosswalk between the Program’s format and GAD’s format. Requests to use an alternative format must be made in wnting to the Director, GAD, no later than 60 days from the effective date of this Order. As part of the 10% requirement, Program Offices must conduct on-site evaluations during the Plan year. Attachment Three descnbes the process of planning and conducting a Desk Review. Attachment Nine is a suggested protocol to use in conducting a Desk Review or on-site evaluation. Program Offices may modify the protocol to meet their individual needs. When doing so, five core areas must be addressed; these areas areS 1) Ensunng equipment purchased under the award is properly managed and accounted for, 2) Compare the recipient’s workplanlapplication to actual progress under the award 3) Examine the award’s finances to ensure funds are available to complete the project, 4) Ensure all programmatic terms and conditions are -6- ------- met, and 5) Ensure all programmatic statutory and regulatory requirements are met All Advanced Monitoring Activities must be documented in the Official Project File. Copies of completed protocols or reports must be included in the Official File. Reports and correspondence, if generated, must also be included in the Official File. Critena for selecting recipients for review should be spelled out in the Plan and documented in the Official Project File for each review. Suggested cntena may include, but are not limited to: Referrals, Audit Findings, Agency Pnonty, Recipient Expenence, Project(s) Cost, Risk, Recipient Location, Statutory or other Requirements, Earmarks, and Funding by Multiple Programs. Attachment Seven is a sample scorecard which may be adapted for local use or guidance Use of this scorecard is optional. Program Offices must ensure appropriate follow-up actions are taken in response to the results of advanced monitoring activities. Where desk reviews identify significant problems, Programs will be expected to take necessary corrective action (see 40 CFR § 30.60 and §31.43) or target the matter for an on-site review. Programmatic Assistance Activities Programmatic Assistance Activities are those actions which are performed for the express purpose of aiding recipients and potential recipients to ensure their technical and programmatic abilities and techniques are sufficient. They will generally take the form of Programmatic Assistance Forums or Technical Assistance. Programmatic Assistance Forums are where the Program brings together a group of recipients or applicants to address sound technical practices. Technical Assistance is where a Program works one-on-one with a recipient to address its technical capabilities and bring them in line with regulatory and statutory requirements and expectations. Programmatic Assistance Activities do not include activities related to baseline or advanced monitonng activities Programs should ensure that pre-application assistance is made available on an equal basis to all potential applicants, and in a manner consistent with Module III of the Project Officer Training Manual Programmatic Assistance activities with up to 1% of the active recipients can be counted toward the 10% Advanced Monitoring Goal. Program Offices should ensure, to the extent practical, that all Programmatic Assistance Activities are documented in Official Project File. For Programmatic Assistance Activities not attnbutable to a specific project, a central file must be maintained by the Program Office. Minimum documentation should include, the date of the activity, the recipient contact and the type of activity involved. Closeouts Program Offices must, at a minimum, acknowledge that final technical reports are due to the Agency within 90 days of the end of the project and that within 60 days of their receipt, the PU will provide to the GMO the -7- ------- status of the final technical report. Reporting Each Program Office must submit to GAD quarterly reports indicatmg the number of monitoring and programmatic assistance activities taking place dunng the quarters ending in December, March, June and September. Reports are due no later than the 8 th day of the month following the end of the quarter. While Programs do not have to submit with their reports a list of the recipients that received advanced, a central list must be maintained by the Program for possible validation and review purposes. The required format for reporting monitoring and assistance activities to GAD is in Attachment Eight. In its Plan, each Program Office must identif ’ its reporting contact and note any changes of that contact when the quarterly report is submitted. Grantee Compliance Database The Grantee Compliance Database is a tool available in Lotus Notes. The Database, maintained in GAD, stores historical and prospective data on all Advanced Monitonng Activities, including on-site and off-site evaluations. Database entries must be opened prior to the activity described Each Program will designate one individual in its Plan as responsible for ensunng the input of such information mto the Database. GAD will provide necessary direction for using this Database. The use of the database to record advanced monitoring activities is required. All applicable fields within the database must be completed to constitute a valid record. Consolidated Options for Regions Regional GMOs and Program Offices may decide to submit a Consolidated Annual Plan in lieu of individual Plans. On, or before, January 8 of each year, each Region electing the Consolidated Option must submit an annual, calendar year Post-Award Monitoring Plan to the Director, GAD. This plan must be signed by the Senior Resource Official (or equivalent). A copy of the plan should also be provided electronically, either through electronic mail or an attached diskette. Electronically submitted plans must be submitted to GAD directly from the SRO. Consolidated Plans must include a listing of each GMO and Program covered by the Plan and an acknowledgment that appropriate personnel in each Office have reviewed and participated in the preparation of the Plan. -8- ------- Consolidated Plans should provide for the same coverage as provided for in GMO and Program Office Requirements. This includes addressing Baseline Monitonng, Advanced Monitonng, Closeouts, Grantee Compliance Database, and Reporting. For Regions selecting the Consolidated Option, there is a single 10% minimum requirement for Advanced Monitonng Activities Regions must ensure that not all Activities are performed by a single office in a Plan year. Assistance activities with up to 1% of the active recipients can be counted toward the 10% Advanced Monitonng goal. In Regions selecting the Consolidated Plan, the GMO must coordinate, and submit to GAD, Quarterly reports using the Reporting Format found in Attachment Eight This format requires evaluations o be reported by GMO and Program. This format may be adjusted to accurately reflect the type and number of programs within a Region. Grants Administration Division Commitments GAD is committed to the following actions: GAD will provide written comments on all GMO and Program Office Post-Award Monitonng Plans (Plan) within 60 calendar days of their receipt. GAD will provide an annual fact sheet to the GMOs and Program Offices to assist in the preparation of annual Plans. The Fact Sheet may include additional guidance, submission and contact information, baseline numbers and the anticipated number of reviews. The baseline will include the number of active recipients for each GMO and Program Office as of October 1 and will be the baseline against which all monitonng requirements will be measured dunng the Plan year (January 1 through December 31). GAD will maintain an electronic library of all GMO and Program Post- Award Monitonng Plans. GAD will review this policy within two years of its effective date. Pnor to this review, GAD will convene a workgroup to review the utility and effectiveness of the Compliance Database. Agency-wide Requirements Each Regional GMO and Headquarters Program Office must submit to the Director, GAD, a Grants Management Self Assessment (GMSA) signed by the Senior Resource Official, Assistant Regional Administrator for Management, or equivalent Each Office must complete a GMSA at least once every three years. GAD provided direction on the preparation and -9- ------- conduct of the GMSAs in GPI-04-O 1 , “Grants Management Self- Assessments and the Comprehensive Approach to Grants Management Reviews”, signed by the Director, GAD, on October 14, 2003. This document is available through the OGD intranet at http://intranet.epa.gov/ogd/po licy/7.0-GPI-TOPiCS.htm. WAIVER PROVISION The Director, Grants Administration Division, may grant exceptions to this policy on a case-by-case basis. However, in the interest of uniformity, exceptions shall be permitted only in unusual circumstances. Requests for exceptions must be made in writing by the Senior Resource Official (or equivalent). The Director, GAD, will issue a final determination, in writmg, within 45 calendar days of receipt. ------- ATTACHMENT ONE Required Format for Writing an Administrative On-site/Desk Review Report 1. Introduction Background and Methodology Give a brief descnption of the recipient; a Give Federal grant dollar total and number of EPA grants with project periods, current dollars expended and current dollar value of the assistance agreement; Discuss previous recommendations if any exist. Give a brief description of the objective of the review; Descnbe the source of the requirements used in the review; Discuss the time period of transaction testmg. ExampleS XXX completed an On-site review of XXX’s financial management system. )(XX is a nonprofit organization with its headquartenng located in Washington, D.C. and field offices located in other countries. The primary purpose of the organization is to work with the people of the Western European Newly Independent States and the Pacific Basin in programs that assist human development. XXX had assets of$13,054,093 and revenue of $138,476,669 as of and for the ?ear ended September 30, 2002. Federal grants totaled $133,402,311. CII has one EPA grant. The grant, No. X-xxxxx, was awarded in the amount of $2,480,049 for the penod of March 1, 1999 through February 29, 2004. Currently the recipient has expended $1,254,000 of the grant funds. The purpose of the award, entitled “Environ. Ed., Training and Tech. Assist In Newly Independent States (MIS)”, is to improve environmental management in the MS through a series of capacity-building programs and environmental education The objectives of the review were to assess the effectiveness of the grantee’s internal controls and determine if the grantee’s financial management system meets the requirements outlined in the Code of Federal Regulations (CFR), 0MB Cost Principles and the Terms and Conditions of the EPA Assistance Agreement. The review include an evaluation of the grantee’s financial reports submitted to the EPA and testing of selected transactions for calendar 2002 Reviewers interviewed the staff to obtain an understanding of the operating procedures and internal controls surrounding funds receipt, funds disbursement and financial reporting. They traced the financial data on the most recent Federal Cash Transaction Reports (SF 272), filed with the EPA, to the general ledger and also determined if they were timely filed. They determined whether progress reports were timely filed. They reviewed the grantee’s last two audit reports to determine if any issues may affect the quality of financial information submitted to the EPA. They selected the most recent payment requests from the EPA and verified that funding requests were supported by disbursements and that funds were disbursed in a timely fashion. They selected a sample of recent disbursement transactions for the EPA grants, traced them to source documents, and tested them for proper authorization and for allowability The review was conducted during the period March 10 th through 14 th, 2003 at the XXX offices in Washington, D C. ------- 2. Results of Review (successes and findings) Identify any areas where the recipient is significantly meeting or exceeding expectations. Give a description of the requirement and why the recipient is non-compliant; Recommend a corrective action ExampleS Codes of Conduct/Ethics: Federal regulations require recipients to establish codes of conduct to eliminate any potential conflict of interest and to establish disciplinary actions for those violating the standards. XXX currently does not have any codes of conduct regarding procurement. XXX has agreed to develop and incorporate written codes of conduct. Enacting andenforcing ethical standards protects your organization and ensures federal dollars are employed properly The minimum requirements are outlined in 40 CFR 30.42. Contracts and Consultants: Officials at XXX said they conduct a cost or pnce analysis for every procurement action. We did not find any documented evidence of a cost or pnce analysis being performed for contracted services. Federal regulations require that a documented cost or price analysis be included in the contract files in conjunction with every procurement action. Some services at XXX require highly specialized consultants and professionals. These contracts are awarded noncompetitively and in such instances a sole source justification, and some form of cost or price analysis and a waiver of bidding must accompany the procurement package. In addition, there is a statutory limitation (implemented at 40 CFR 30.27(b) and 31.36(j)) on the amount of EPA grant funds that can be used to compensate individual consultants. XXX has agreed to document a contemporaneous cost or pnce analysis and if needed to include a sole sourcejustification for every procurement action using federal flmds. XXX has agreed to ensure that compensation paid to individual consultants complies with the applicable regulations. XXX currently is developing a noncompetitive justification form which will be required from the XXIX Program Managers when they require a sole source procurement action. We strongly encourage XXX to finalize this draft document. 3. Resolution Plan and Timing Tell the recijilent when the corrective action plan is due and clearly state what should be addressed in the plan. Example: We ask that you identify the actions you will be taking to address the recommendations and suggestions and the associated time frame(s) of each action. Please provide us wLth your action plan within 30 days of this letter 4. EPA Contact Tell the recipient to whom they should send the corrective action plan and where to send it, including phone number. Example: The Review Team appreciated the overview of the grant activities ongoing at ------- XXX. Thank you for the warm hospitality that was extended to us by you and your staff. We look forward to a continued and successful assistance relationship with XXX. Should you have any questions, feel free to contact XXX at (202) 564- xxxx 5. Appendix Example: Review Dates: February 13, 2002 Organization: XXX Persons Contacted XXX, Contracts Administrator XXX, Controller Sources (EPA): X-xxxxxxx-01-0 6/1/00 - 09/30/03 Venfication of Innovative Cement Tech $85,000 $10,000 expended to date of review X- xxxxxxx-01-0 10/02/00 -10/01/02 Environmentally Preferable Product Venfication $50,000 $10,000 expended to date of review ------- ATTAChMENT TWO REQUTRED FORMAT FOR WRITING A PROGRAMMATIC REVIEW REPORT FOR ON-SITE AND OFF-SITE EVALUATIVE REVIEWS 1. Introduction, Background and Methodology Give a brief description of the recipient and the project; Descnbe the grant work-plan commitments; Discuss previous recommendations if any exist; Tell how the review was conducted (eg., on-site versus off-site or protocol used versus covering core areas) 2. Results of Review with Recommendations (success and findings) Address all of the core areas that apply to the agreement as defined in EPA Order 5700.6. 1) Ensuring equipment purchased under the award is properly managed and accounted for, 2) Compare the recipient’s workplanlapplication to actual progress under the award 3) Examine the award’s finances to ensure funds are available to complete the project, 4) Ensure all programmatic terms and conditions are met, 5) Ensure all programmatic statutory and regulatory requirements are met. Program Suggestions and Recommendations should be defined as either major or minor; All recommendations should have corresponding routes to/for resolution specified in the report; When major recommendations are made, EPA should explicitly require the recipient to develop and submit a program enhancement plan to address the major recommendation; Recipient Recommendations and Suggestion; Recommendations for the Grants Office if any; Identify any areas where the recipient is significantly meeting or exceeding programmatic expectations 3. Resolution Plan and Timing Tell the recipient when the corrective action plan is due, and clearly state what should be addressed. ------- 4. EPA Contact Tell the recipient to whom they should send the corrective action plan and where to send it, including phone number. 5. Appendix (optional) If not addressed in section, include identif ’ing and summary information for the project such as Review Dates February 13, 2002 Organization: XXX Persons Contacted: XXX, Contracts Administrator XXX, Controller Sources (EPA) X-xxxxxxx-01-0 6/1/00 - 09/30/03 Verification of Innovative Cement Tech $85,000 $10,000 expended to date of review ------- 14 ------- Improper Payments Information Act of 2002 National Grants Management Training Conference Jacksonville, FL November 2004 ------- What We Will Talk About •Defining IPIA • Expectations •What We’ve Done •What We’re Doing •Next Steps 11/1/2004 Draft 2 ------- Improper Payments? •Also known as Erroneous Pay •Passed in 2002 — P.L 107-300 — 0MB Memorandum — M-03-13 • Designed to reduce payments that shouldn’t be made • Look at risk points in payment cycle 11/1/2004 Draft 3 ------- What Are the Requirements? • Identify Susceptible Programs •The program is susceptible... — $10 million in improper payments and — 2.5% of the program dollars • Each Agency defines “the program” — EPA: program/projects • Identify and commit to reducing improper payments 11/1/2004 Draft 4 ------- Also, IPIA Requires... • Recovery Audit Contractors — Outside contractor looking for duplicate payments •Travel Cards — Susceptible to improper payments •Purchase Cards — Susceptible to improper payments 11/1/2004 Draft 5 ------- Improper Payments are Important • President’s Management Agenda Item •OMB is tracking • Focus on Grants • But, few improper payments in EPA • New Twist — Track the payments through the entire payment cycle 11/1/2004 Draft 6 ------- What We’ve Done So Far • First Year — Performed Risk Analysis — Developed Corrective Action Plan — Submitted to 0MB May 2004 • Susceptible Programs — Clean Water State Revolving Fund — Drinking Water State Revolving Fund — Superfund Remedial Program 11/1/2004 Draft 7 ------- Commitments so Far • Reduce the amount of improper payments — From $12.4 million to $11.2 million in FY 2004 — By 10% to $10 million in FY 2005 - By 10% to $9 million in FY 2006 11/1/2004 Draft 8 ------- It’s a New Year • New Risk Analysis - Identify at risk programs — Sample transactions — Follow payments through payment cycle •State Revolving Funds — Reviewing again — Office of Water 11/1/2004 Draft 9 ------- Our New Plan... O In process of writing measurement plan — Need 0MB approval — Including a review of full payment cycle •Sample occurs 2nd Quarter • Corrective Action Plan in 3rd Quarter 11/1/2004 Draft 10 ------- The Agency is Involved •Grants Office plays a big role — Looking at all grantees — Evaluating for susceptible areas •Water Office also plays a big role T Reviewing states — Reviewing payments 11/1/2004 Draft 11 ------- What’s Next • FY 2004: Report results in PAR • FY 2005: Second Go-round: — 1st Quarter: 0MB concurs on measurement plan — 2 1( Quarter: Sampling occurs — 3rd Quarter: Corrective Action Plan • FY 2006: Demonstrate reduction in improper payments 11/1/2004 Draft 12 ------- Useful Information •OMBWebsite —0MB Memoranda, M-03-07 &M-03- 13 http://www.whitehouse.qov/omb/mem oranda/2003.html •OCFO Improper Payments Team — Bill Howard — 202-564-4933 — Joe Nemargut — 919-541-3777 — Charles Young 202-564-4914 11/1/2004 Draft 13 ------- Questions and Discussion 11/1/2004 Draft 14 ------- 15 ------- 16 ------- 17 ------- 18 ------- 19 ------- 20 ------- 21 ------- |