United States
Environmental Protection
Municipal Construction
Washington DC 20460
February 1984
Guidelines for Overviewing
Construction Grant Activities
Conducted under the
Interagency Agreement with
the Corps of Engineers

           United States
           Environmental Protection
           Municipal Construction
           Washington DC 20460
February 1984
Guidelines for Overviewing
Construction Grant Activities
Conducted under the
Interagency Agreement with
the Corps of Engineers


1. Purpose 1
2. Background 1
3. Introduction 2
4. Reporting 3
a. Level 1 3
b. Level2 4
c. Level 3 5
d. Level 4 6
5. Overviewing 7
a. EPA Headquarters 8
b. Corps Headquarters 9
c. EPA Regional Office 10
d. Corps Division Office 12
e. Corps District Office 13
I Interagency Agreement Participating Offices
II Chart: “An Organization of Construction Grant
Overviewing and Reporting”

1. PURPOSE : The purpose of this document is to provide general
operating guidance to EPA Regional Offices (RO) as well as to
the Corps of Engineers (Corps) Division and District Offices
in discharging their management responsibilities in
overviewing activities conducted under the Interagency
Agreement (rAG) on projects funded under EPA’s construction
grants program. By giving proper and continual attention to
the indicators of progress (reporting) and by exercising
prudent management (overview measures), a more effective
construction program can be realized and the early detection
of evidence of waste, fraud and mismanagement of Federal grant
funds can be achieved.
2. BACKGROUND : With the elimination of Step 1 and Step 2 grants
from the construction grants program and the completion of
planning and design work on many projects, the focus of the
program is shifting to construction per Se. In a recent, in
depth study of Regional Office functions and activities ,(the
“Baseline” !“study), considerable attention was given to the
need for strengthening Step 3 overview activities. A
myriad of methods and procedures are used by the Regional
Offices, the Corps (under the lAG with EPA) and by the States
(under their delegation agreements) to monitor grantee
management of construction projects. The guidelines presented
here are designed to satisfy the need for an integrated and
consistent overview structure for assessing the effectiveness
of the various activities performed on construction grants
projects under the lAG with the Corps.
1 ”Construction Grants Program Baseline Functions, Municipal
Construction Division, July 1, 1983.

EPA has prepared an official guidance document a”for the
general overview of State and Corps performance under a
delegated program which supplements the regulations found
in Subpart J of 40 CFR Part 35. One of the four evaluation
methods described in that guidance is the Program Management
Review to “... assess the adequacy of EPA, State and Corps
program management towards achieving priority objectives.”
Herein is provided a methodology for conducting program
management reviews of Step 3 activities on a continuing basis.
3. INTRODUCTION : This guidance document contains three main
sections: Reporting, Overviewing, and Appendices. The
Overviewing section is preceded by a section on Reporting
because the overview process, to a large extent, depends
on the information in the various reports generated by
activities of the Corps under the lAG. The Appendices contain
(a) a brief description of the roles and responsibilities of
the participant organizations in the lAG program; and (b) a
chart illustrating the various EPA, Corps and State
organizations involved in the overviewing and reporting
activities of the construction grants program and their
associated levels.
The Corps/State/Regional Office roles will vary according to
the status of the delegation of grant management functions in
individual States. The recommendations contained herein
should be considered as guidance and modified as necessary in
keeping with individual Regional experiences and operating
requirements as well as the specific responsibilities and
procedures outlined in State Delegation Agreements and
EPA/Corps Regional Interagency Agreements. It is expected
that these Agreements, as appropriate, will be revised or
supplemented to reflect this guidance.
Construction Grants Delegation and Overview Guidance, Office of
Water Program Operations, December 22, 1983.

In general, the Regions with the larger Corps operations
should adhere more closely to these guidelines than Regions
overviewing smaller Corps operations.
4. REPORTING - The process of reporting on various Corps
activities must be orderly. As the chart in Appendix II
indicates, this order may have four levels.
a. Level 1 represents the reports prepared by the
Corps inspector. These reports are a distillation of the
inspector’s observations of activities performed
by the grantee, the grantee’s A/E, resident
engineer/inspector and the construction contractor, along
with his/her findings and perceptions. The Corps
inspector also reports on other activities in which
he/she participates.
The following is a listing of typical Level 1 reports:
(1) Interim/final inspection and on—site presence
(2) Preconstructjon conference and project management
conference (PMC) minutes.
(3) Information contributed to construction management
evaluation (CNE) reports.
(4) Reports on the progress and numbers of:
o B&C reviews
o Administrative completions
o Physical completions
o Outlay projections
o Project management assignments
° Grant closeouts

Special requests/assignments
— Technical assistance/reports
- Engineering field studies
- Technical investigations — including feasibility
— Independent cost estimates
- Dispute/” credit” determinations
— Technical supervision
- Start-up monitoring
— 205(g) evaluation assistance
- Disaster assistance (related to construction
grant projects)
— Advisor to a State
The above reports are submitted to Level 2 for review and
further action, including transmittal of information to other
participants in the overview process.
b. Level 2 comprises the first line of supervision of the
field staff and, therefore, the first level of management
in the overview process. Typically, Level 2 is the Corps
District Office where inspection and related activities
have been assigned.
The following types of reports should be prepared by the
Corps District Office for overviewing authorities:
(1) A report summarizing activities and assignments
carried out during the report period -— including,
for example, project, grantee, grant, date
performed, inspector’s name, contract(s) (where
appropriate), etc.

(2) A list of inspection and activity review reports
which were submitted by District inspectors to each
(3) Monthly status of financial/administrative areas,
e.g., FTEs (part-time/full—time), expenditures by
object class, overhead; lAG staffing plans (at
beginning of fiscal year). Excessive shortfalls or
overages should be called to the attention of and
explained to higher authority. This notification
may be an oral or written commentary.
(4) Program accomplishments, problems, issues,
recouunendations, and significant findings
from inspections, PMCs, and CMEs.
The above types of reports are forwarded to the Corps Division
Office (Level 3).
c. Level 3 represents the Corps Division Office which
has an lAG program reporting responsibility to EPA
Regional Office(s) and to Corps Headquarters. The
following are sample types of reports:
(1) Quantitative management reports detailing: status
of work plan activities -- number and kinds of
activities, frequency and location; grants and
personnel involved; financial/administrative
summary: FTEs; expenditures; annual staffing and
training p1ans.
system for reporting these items has been implemented.

(2) Qualitative management reports describing overall
results in summary form including: accomplishments!
deficiencies, information of interest to others,
e.g., ROs, and problems and issues.
(3) Overview efforts
(Where Step 3 activities are delegated to the State, the
State Headquarters and other offices would also receive
copies of the above information.)
d. Level 4 consists of the EPA Regional Offices and the
Corps’ Headquarters. Since reports prepared at Level 4
must satisfy the national program management requirements
of EPA (relate to the Corps National work plan), the
Level 4 reporting process needs to be of manageable
(1) From the Corps, a quarterly statement of performance
under the lAG consisting of:
o Status of work plan: actuals vs. targets
(Division, District, totals)
o Financial/administrative summary: - FTEs;
obligations, expenditures (Region, Division,
District, totals)
o Annotations to explain shortfalls or excesses — By
Division, District, National summary
0 Overall results — National summary

o Accomplishments/deficiencies - National summary
o Programmatic problems/issues - Requiring EPA/HQ
(2) From each Regional Office, a monthly description of the
Region’s management of Corps resources showing:
o Status of work plan: completed assignments (State
and Regional totals)
o Financial/administrative summary - FTEs -
O Overall results in the Region ’
o Accomplishments/deficiencies — Region-wide or by
State (as appropriate)V
o Programmatic/issues - Requiring Headquarters
attent ion ’
5. OVERVIEWING - Basically, the process of overviewing, to be
efficient, depends, in part, upon the availability of data and
reports which adequately describe the activities under review.
Such information, in the hands of staff who desire to assure
that resources are being applied appropriately and that the
objectives of the program are in fact, being met, and
who understand their overview role in the management chain,
can help sustain the overall effectiveness of the lAG program.
system for reporting these items has been implemented.
NOTE: Particular emphasis needs to be given to these items
in quarterly reports.

In the sections which follow, the use of reports and
various review procedures are addressed. The overview
process is presented in the reverse order of the reporting
process — i.e. from the top down.
a. EPA Headquarters
In carrying out its national program responsibilities, EPA
Headquarters’ overview of the Regional Offices and Corps
Headquarters consists of the following actions:
(1) Analyze management reports submitted monthly by
Regional Offices and quarterly by Corps HQ to:
determine if annual work plan and resource targets
are generally on course; assure that priority needs
are given priority attention; assess the overall
effectiveness of operations under the lAG; summarize
information for higher authorities; resolve issues
directly with ROs or Corps EQ —- making periodic
adjustments of work plan and resource targets; issue
general guidance or directives; provide assistance
to the ROs; and contact higher authorities to
resolve exceptional issues.
(2) Initiate overview activities, to include: visiting
EPA Regional Offices to assess management
practices, discuss issues/problems/successes, and
exchange views with RO personnel; observing
operational practices 1 by visiting (with RO
Note: (a) Such visits will be discussed with Corps Headquarters
in advance and may be done with Corps Headquarters staff.
(b) Reviews at the Division, District and grantee level
will be coordinated with the Regional Office and a Regional
representative will be invited to attend. Similarly,
reviews at the District level will be cleared through
Division Offices. Cc) Where grantee level reviews are
involved, the State will also be invited to attend.

staff on a limited, selective basis ) Corps
Division and District Offices and grantees;
and, on a sample basis and in conjunction with the
overall RO effort, participating in CMEs and
observing PMCs and preconstruction conferences.
(3) Develop annual work plan instructions and related
guidance and evaluate Regional submissions to
assure priority activities are emphasized and
Regionally proposed activities are fully coordinated
with Divisions and States. Approve annual work
plans and resource targets.
(4) Provide fiscal reports necessary to meet Agency
legislative, budget and accounting requirements.
b. Corps Headquarters
As the organization charged with assuring that
assignments under the lAG program are effectively carried
out by its personnel nationwide, the Corps’ overview
responsibilities are:
(1) Maintain continual contact with Division Offices to
assure that Corps lAG managers are operating an
effective program and to provide advice and
assistance which may be needed to overcome Corps
operating problems and resolve management issues in
these offices.
(2) Analyze and evaluate reports submitted monthly by
Division and District Offices to assure that
assignments are being implemented in a professional
and timely manner and lAG funds are properly
accounted for.

(3) Issue guidance and directives, as needed, to assure
quality efforts are being maintained throughout the
Corps organization.
(4) Selectively visit Corps field offices at all levels
to: assess management and operational practices ——
including providing full and competent staffing and
assuring the prudent use of lAG funds; discuss
operational and procedural issues/problems!
successes; and exchange views.
(5) Assist EPA Headquarters in the development of annual
work plan instructions and related guidance; and
coordinate and evaluate the preparation of Division
submissions to assure that instructions are
consistently followed and close coordination with
EPA Regional Offices is achieved.
(6) Provide EPA Headquarters with monthly and quarterly
program and resource utilization reports necessary
for the effective administration of the lAG program.
c. EPA Regional Office
EPA Regional Office lAG overview responsibilities cover
the activities assigned to the Corps’ Division and
District Offices under the annual work plan. In
particular, the Regional Office should:
(1) Monitor and respond to work plan accomplishment
data, received monthly, on the kinds and numbers
of activities, FTEs, expenditures, etc., primarily
to assure that progress in meeting annual commit-
ments is being made.

(2) Conduct informal meetings (generally monthly) with
counterpart(s) in the Division(s) to review overall
progress, discuss means of strengthening
communications among all participants in the program
and follow through as appropriate. (Where
geographical distances warrant, telephone calls may
(3) Conduct formal meetings (quarterly) with staff of
Division(s) and, as needed, Districts and,
as appropriate, States to review performance
(e.g., number of outputs, quality of work, fund and
staff utilization), resolve shortcomings, and
discuss future work schedules (including planned
outputs, staffing, and correction of inadequacies).
(4) Conduct or overview the conduct of construction
management evaluations (CMEs) —— a cooperative
effort among EPA, Corps and States. (Details are
found in the CME handbook.) .”
(5) Annually, review representative samples of project
reports to assess their quality and the adequacy of
follow—up activities on deficiencies noted therein.
(State/EPA project officers, who regularly receive a
copy of field reports, should also be requested to
inform the Regional Corps coordinator of critical
inadequacies if observed.) In addition, case study
reviews of crucial activities may be undertaken.
(These would be defined in the annual Corps work
plan and/or the State monitoring plans.)
‘Construction Management Evaluation and Project Management
Conference Manual, Municipal Construction Division,
December 1983.

(6) Conduct review inspections of activities
undertaken in each District. Such reviews should
include visits to a limited number of projects to
verify the completeness and quality of project
inspections and reports, as well as to the District
Office itself to examine its operations in managing
lAG assignments. These reviews should be
coordinated with Corps Division staff to avoid
duplication of effort.
(7) With associated Divisions, assess the need for
training and assist in providing or coordinating
training courses.
d. Corps Division Office
A Corps Division’s overview responsibilities will vary
somewhat with both the activities delegated to its
associate States and the assignments negotiated in the
annual work plan. However, certain minimum activities
are expected. Each Division Office should:
(1) Conduct quality assurance reviews of activities
negotiated in the annual work plan.
(2) Conduct, regularly, reviews of each District’s
overall lAG management effort to be certain that
(a) District supervisors are assuring that
assignments and follow-up actions on deficiencies
are being carried out in a timely and effective
manner, (b) proper staffing is maintained (number,
qualifications, skill mix, full—time vs. part—time
and vacancies promptly filled), (c) supervision of
lAG staff is consistent with effective management

practices, (d) a positive working relationship with
the States is maintained, (e) required financial
reports are produced in a timely fashion, and
reviewed (and approved) properly by both
administrative and program officials at the
Districts, and (f) program data and reports are
properly prepared and timely submitted.
(3) Assess the need for training and assist in providing
or coordinating the planning or conduct of training
(4) Review representative samples of project reports
(inspections, B/C reviews, etc.) from each Corps
District to assess the completeness and quality of
the inspector’s findings, as well as the adequacy of
follow-up activities on deficiencies noted.
(5) Where large amounts of resources are concentrated
in one particular activity, conducts case study
reviews to assure that measures which can enhance
the effectiveness of that activity are continuously
e. Corps District Office
The Corps District Office is, in most instances, the
first line of supervision over the conduct of field
assignments. Overview efforts at this level are
especially critical to the success of the lAG program.
Such activities should include:
(1) Regularly reviewing segments of the annual work plan
assigned to the District to assure that annual
targets can be met and quarterly targets are being

(2) Performing detailed reviews of the conduct of
individual staff assignments and the preparation
of related reports.
(3) Assuring that: the interface of Corps activities
with States and grantees is properly and
continuously maintained; findings and
recommendations to States and grantees are
followed—up; grants management aspects of an
inspection and those elements of guidance presented
in the “Operating Procedures for Monitoring
Construction Activities t ’ are duly considered by
inspectors; and that feedback is provided to staff
inspectors so that growth and improvement can
be continually fostered.
(4) Developing needed standard operating procedures;
evaluating performance; recognizing the need for
and assisting in providing for individual training

Interagency Agreement Participating Offices

CORPS - INSPECTOR - Acts as EPA’s agent where the inspection
functions have not been delegated to the State or are shared (in
some instances) with the Corps; role is similar to that of the
EPA or State inspector vis-a—vis grantee, except the inspector
reports to the Corps District Office and is not responsible for
protecting State interests, per Se. His/her authority has
essentially the same limits as those of an EPA inspector. The
thrust of an interim inspection report is an evaluation of the
quality of the grantee’s management of the project. (See
“Operating Procedures for Monitoring Construction Activities” for
The inspector may also serve in an “on-site” capacity on a large
project, about $50 million or more, or a cluster of projects to
provide continuous coverage of the progress of work. In an on—site
role, the inspector has the same duties and responsibilities as
when conducting interim inspections.
The inspector conducts final inspections, project management
conferences (PMCs) and participates in preconstruction conferences.
He/she may also participate in construction management evaluations
(CMEs) as a member of a CME team, be involved in special
assignments which draw upon his/her construction expertise or serve
as a technical advisor to a State’s construction grant operations.
CORPS - DISTRICT OFFICE — Provides supervision to the field
inspectors; manages field level activities conducted for EPA;
evaluates inspection and other reports submitted by the inspectors
and forwards the results to the EPA Regional Office and State. The
District Office is the basic link between the day—to-day field
operations of the Corps and the management structure of the lAG, in
seeing that the work plan objectives are being addressed and

CORPS — DIVISION OFFICE - Supervises the activities of associated
District Offices and coordinates their activities with EPA Regional
Offices. The Division Office is the link between the District
Office and Corps Headquarters and EPA Regional Offices. It is
responsible for the development and implementation, with EPA
Regional Offices, of the annual work plan (and budget) and for
seeing that national priorities/objectives/resource targets are
accomplished by the District Offices. Also responsible for seeing
that the work plan reports of Corps activities are submitted in a
timely manner.
EPA - REGIONAL OFFICE (RO ) - Under the lAG, the RO monitors the
performance of, and provides programmatic and technical assistance
to, the Corps; reports to EPA Headquarters on program progress,
resourse use problems and accomplishments. The RO, with its
Divisions, is responsible for developing the annual work plan, for
assessing Corps performance against work plan objectives and for
integrating the operations of the Corps into the overall conduct of
the construction grants program within its geographical boundaries.
CORPS HEADQUARTERS - Directs the implementation of the lAG program
through its Division and District Offices and, in accordance with
the provisions of the lAG, assures that the program is effectively
managed at all Corps levels of operation. Coordinates the
development of the annual work plan among its field offices and
assists EPA Headquarters in resolving work plan issues and in
making final determinations; issues policy and guidance necessary
to assure effective Corps field operations; assures that lAG funds
are properly expended and that staffs necessary to execute lAG -
assignments are available; counsels, consults with and assists EPA
Headquarters on instituting program improvements; conducts studies
on the program’s overall effectiveness or on areas of special
interest and provides EPA Headquarters with appropriate progress
reports — — including formal quarterly and annual briefings.

EPA — HEADQUARTERS - Directs the conduct of the national program,
assuring that the ten Regional programs are operated as an
integrated whole; approves annual work plans; establishes program
priorities; distributes resources among the ROs and allocates funds
to District Offices; provides data and justifications to support
needed lAG appropriations in EPA budget cycle; provides policy
direction and supplemental guidance as required; prepares and
issues regulations to implement the authorizing statutes; overviews
lAG operations and evaluates RO performance, particularly assuring
that approved work plan commitments and OWOGAS targets are met;
prepares summary reports on the status of lAG activities; and
responds to requests for lAG information from 0MB, Congress, GAO,
national organizations and the public at—large.

An Organization of Construction Grant
Overviewing and Reporting

An Organization of
Construction Grant Overviewing and Reporting
Level 3
Level2 4’ I
Level 1
[ NE
J I ’
Direction of Overviewing
——-— ‘- Direction of Reporting