U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Audit Report
Follow-up on Audit of
Undistributed Site Costs Finds
Corrective Actions Not Complete
Report No. 08-P-0236
August 25, 2008
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Report Contributors: Paul Curtis
Meg Bastin
Arthur Budelier
Wendy Swan
Abbreviations
CFO Chief Financial Officer
EPA U.S. Environmental Protection Agency
MATS Management Audit Tracking System
OARM Office of Administration and Resources Management
OCFO Office of the Chief Financial Officer
OIG Office of Inspector General
OMB Office of Management and Budget
OSWER Office of Solid Waste and Emergency Response
RMDS Resources Management Directive System
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
08-P-0236
August 25, 2008
Catalyst for Improving the Environment
Why We Did This Review
We sought to determine
(1) the status of corrective
actions taken in response to an
Office of Inspector General
report, EPA Could Improve Its
Redistribution of Superfund
Payments to Specific Sites,
issued in July 2006; and
(2) whether the Action
Official sufficiently
documented and certified the
corrective actions.
Background
I Audit follow-up is essential to
good management and
improving the efficiency and
effectiveness of U.S.
Environmental Protection
Agency (EPA) programs and
operations. EPA has audit
follow-up procedures and
designated officials who
I manage this process. EPA
Manual 2750 requires EPA to
form a corrective action plan
and complete the actions by
the agreed upon milestone
dates. In our prior report, we
noted that EPA did not timely
redistribute Superfund
payments from a general site
identifier to specific sites.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2008/
20080825-08-P-0236.pdf
Follow-up on Audit of Undistributed Site Costs
Finds Corrective Actions Not Complete
What We Found
EPA initiated some corrective actions in response to our prior report on
undistributed site costs, but did not complete them. Also, EPA did not maintain
accurate information in the Management Audit Tracking System.
Management control weaknesses contributed to a breakdown in the audit follow-
up process. EPA did not document formal work assignments for audit follow-up
and maintain accountability. EPA did not consistently monitor audit follow-up
activities, communicate follow-up status among program offices and obtain
follow-up agreements, and document work completion. The policies and
procedures in EPA Manual 2750 are the design framework for EPA's internal
controls over the audit follow-up process. Since EPA did not complete the
corrective actions, its financial management and environmental protection efforts
could be impacted. Superfund costs not redistributed appropriately from a general
site identifier to specific sites may not be considered in settlement negotiations
and oversight billings. Consequently, these funds may not be recovered from
responsible parties and be available for future site clean-up activities.
Because EPA did not complete the corrective actions, we could not fully address
our second audit follow-up objective, which was to determine whether the Action
Official sufficiently documented the corrective actions and certified them, as
required by EPA Manual 2750.
What We Recommend
We recommend that EPA make formal work assignments, document the
assignments, and hold assignees accountable. EPA also needs to monitor audit
follow-up activity, communicate among program offices, document work
progress, and elevate future disagreements for resolution. Further, we recommend
that EPA resolve an interagency agreement redistribution problem and redistribute
interagency agreement costs of $4.9 million, including $1.8 million in additional
costs recorded after May 12, 2006, and redistribute $2.8 million cooperative
agreement costs to the correct general and site specific identifiers. In response to
the draft report, EPA agreed with all our recommendations and its proposed
corrective actions should address our recommendations.
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I
5
V-.X'
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
August 25, 2008
Follow-up on Audit of Undistributed Site Costs
Finds Corrective Actions Not Complete
Report No. 08-P-0236
Paul Curtis
Director, Financial Statement Audits
Lyons Gray
Chief Financial Officer
Susan Parker Bodine
Assistant Administrator for Solid Waste and Emergency Response
Luis A. Luna
Assistant Administrator for Administration and Resources Management
This is our report on the follow-up audit to our July 2006 report, EPA Could Improve Its
Redistribution of SuperfundPayments to Specific Sites, conducted by the Office of Inspector
General (OIG) of the U.S. Environmental Protection Agency (EPA). This report contains
findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. This report represents the opinion of the OIG and does not necessarily represent
the final EPA position. Final determinations on matters in this report will be made by EPA
managers in accordance with established audit resolution procedures.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $107,088.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective actions plan for agreed upon
actions, including milestone dates. Please e-mail an electronic version of your response that
complies with Section 508 of the Rehabilitation Act to Meg Bastin at bastin.margaret@epa.gov.
We have no objections to the further release of this report to the public. This report will be
available at http://www.epa.gov/oig.
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If you or your staff have any questions, please contact me at (202) 566-2523 or
curtis.paul@epa.gov, or Meg Bastin at (513) 487-2366 or bastin.margaret@epa.gov.
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Follow-up on Audit of Undistributed Site Costs 08-P-0236
Finds Corrective Actions Not Complete
Table of Contents
Purpose 1
Background 1
Audit Follow-up 1
Summary of July 2006 Audit Report 2
Responsible Offices 3
Noteworthy Achievements 3
Scope and Methodology 3
Results of Follow-up Audit 4
Corrective Actions Not Completed 4
Incorrect Information in MATS 6
Costs Redistributed to Incorrect Site Identifier 6
Conclusion 6
Recommendations 7
Agency Response and OIG Evaluation 7
Status of Recommendations and Potential Monetary Benefits 9
Appendices
A Audit Management Responsibilities 10
B Status of Corrective Actions 11
C Details on Scope and Methodology 13
D EPA Response to Draft Report 14
E Distribution 24
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08-P-0236
Purpose
The purpose of this review was to evaluate the status of corrective actions taken by the U.S.
Environmental Protection Agency (EPA) in response to the Office of Inspector General (OIG)
report, EPA Could Improve Its Redistribution of SuperfundPayments to Specific Sites, issued
July 31, 2006. Our objectives were to determine whether:
The Agency took adequate corrective action.
The Action Official sufficiently documented the corrective actions and certified them
as required by EPA Manual 2750.
Background
Audit Follow-up
The Inspector General Act of 1978 established OIGs in Federal agencies to conduct
independent audits and investigations of agency programs and operations, and make
recommendations to improve their efficiency and effectiveness. Amendments to the Act
in 1988 directed agencies to report to Congress semiannually on the status of follow-up
on OIG audit report recommendations.
Office of Management and Budget (OMB) Circular A-50 specifies certain timeframes for
audit resolution and requires agencies to develop systems to ensure prompt
implementation of audit recommendations. According to OMB Circular A-50, audit
follow-up is essential to good management and is a shared responsibility of agency
managers and audit organizations.
EPA's policy and procedures on the audit follow-up process are in EPA Manual 2750,
most recently revised in 1998. EPA Manual 2750 implements OMB Circular A-50 and
the Inspector General Act Amendments of 1988. The Manual specifies a chain of
responsibility for the audit management process, starting with the Chief Financial Officer
(CFO) as the Agency's designated Audit Follow-up Official. According to EPA Manual
2750, the Agency's Audit Follow-up Official has "personal responsibility" for Agency-
wide audit resolution. The Action Official certifies that corrective actions are complete.
Appendix A provides more details on audit management responsibilities.
OIG reports usually contain recommendations for Agency Action Officials to take
corrective actions to address the findings and conclusions of the report. When the
Agency and the OIG agree on the corrective actions, this decision is documented in the
Management Decision letter. EPA Manual 2750 requires actions to be completed within
365 days of the management decision, or otherwise explain reasons for delay.
The Office of the Chief Financial Officer (OCFO), with the CFO as the Agency Audit
Follow-up Official, maintains and operates the Management Audit Tracking System
(MATS) to track audit follow-up, report, and resolution dates, and corrective actions
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08-P-0236
Agency-wide. However, OCFO only requires limited information to be entered into
MATS, including milestone dates, financial information (if applicable), and explanations
for missed deadlines. Further details on the status and actions taken to implement
corrective actions must be documented by the Action Official's office. This information
is essential for the Agency to assess and certify that agreed-to actions are completed.
According to EPA Manual 2750, official files are required to include seven major
elements:
Names of Action Official and other parties responsible for implementing,
tracking, following up, and reporting on corrective actions
Draft reports
Responses to draft reports
Final reports
Approved Management Decisions
OIG Management Decision acceptance memoranda
All pertinent documentation and certification information
Together, MATS and official files document an audit's history, as well as the actions
taken by the Agency to address recommendations and correct deficiencies.
Managers are responsible for good internal control, according to Standards for Internal
Control in the Federal Government., issued November 1999 by the U.S. Government
Accountability Office. Management should design internal controls to ensure that
ongoing monitoring occurs. Monitoring of internal controls should include policies and
procedures to ensure that management promptly resolves findings of audits and other
reviews. Managers are to (1) promptly evaluate findings from audits and other reviews,
including those showing deficiencies and recommendations reported by auditors;
(2) determine proper actions in response to findings and recommendations from audits
and reviews; and (3) complete, within established time frames, all corrective actions or
otherwise resolve the matters brought to management's attention.
Summary of July 2006 Audit Report
In our July 2006 report, we noted that EPA did not make timely redistribution of
payments on Superfund cooperative agreements, interagency agreements, and small
purchases from the general site identifier "WQ" to the specific Superfund sites or other
general site identifiers. As of May 12, 2006, $13 million was recorded in "WQ" for those
funding vehicles. Superfund costs not redistributed appropriately to specific sites may
not be considered in settlement negotiations and oversight billings. Consequently, these
funds may not be recovered from responsible parties and be available for future site
clean-up activities.
EPA accounts for response costs at a site-specific level to enable cost recovery. EPA
obligates costs not readily identifiable to a site to the general site identifier "WQ," and
upon payment redistributes the costs to specific sites. Additional general identifiers are
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08-P-0236
"ZZ" for preliminary site assessment costs on sites that have not been assigned an
identifier number and "00" for indirect costs not related to a specific site that will be
allocated to the Superfund indirect cost rate.
We found various reasons why EPA did not timely redistribute the "WQ" costs. EPA did
not establish "WQ" procedures, consistently monitor the "WQ" accounts, and provide
"WQ" training. EPA also did not require cooperative agreement recipients to provide the
site-specific cost detail needed, include a review of undistributed "WQ" costs in the
cooperative agreement closeout process, and hold project officers accountable for their
"WQ" responsibilities.
We recommended that EPA (1) develop written "WQ" procedures, including timeliness
standards and monitoring procedures; (2) provide training; (3) redistribute the remaining
historical "WQ" costs; (4) change cooperative agreement conditions to require recipients
to provide cost details within 24 hours of drawing down funds; (5) amend the closeout
process for cooperative agreements to include "WQ" procedures; and (6) promote
accountability for "WQ" redistributions among project officers and finance office
personnel. Appendix B provides EPA's corrective action plan, agreed-upon milestone
dates, and status of corrective actions.
Responsible Offices
Three EPA offices have primary responsibility for the areas covered in the subject report
and the related audit follow-up. OCFO is responsible for EPA's financial management
and Superfund cost recovery system. The Office of Solid Waste and Emergency
Response (OSWER) manages the Superfund program. The Office of Administration and
Resources Management (OARM) is responsible for administration of grants and
cooperative agreements.
Noteworthy Achievements
EPA personnel at EPA finance centers in Las Vegas, Nevada, and Research Triangle Park, North
Carolina, implemented procedures that significantly decreased the undistributed "WQ" costs for
cooperative agreements and small purchases. See Table 1 later in this report for the
undistributed "WQ" costs by funding vehicles and the resulting decreases and increases.
Scope and Methodology
We conducted this audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives. We conducted our audit from January 16, 2008,
through February 25, 2008. Appendix C contains a more extensive discussion on our scope and
methodology.
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08-P-0236
Results of Follow-up Audit
EPA initiated some corrective actions to develop written procedures, provide training, and
redistribute the historical "WQ" costs, but did not complete them and did not maintain accurate
information in MATS. Also, EPA distributed some costs to an incorrect site identifier. The
policies and procedures in EPA Manual 2750 are the design framework for EPA's internal
controls over the audit follow-up process. However, management control weaknesses
contributed to a breakdown in the audit follow-up process:
EPA did not document formal work assignments for audit follow-up and maintain
accountability.
EPA did not consistently monitor audit follow-up activities, communicate follow-up status
among program offices and obtain follow-up agreements, and document work completion.
Personnel within OCFO and OSWER did not resolve a disagreement affecting
interagency agreement redistributions and delayed the corrective action.
Because EPA did not complete the corrective actions, its financial management and
environmental protection efforts were impacted. Superfund costs not redistributed appropriately
to specific sites may not be considered in settlement negotiations and oversight billings.
Consequently, these funds may not be recovered from responsible parties and be available for
future site clean-up activities.
Because EPA did not complete the corrective actions, we could not fully address our second
audit follow-up objective, which was to determine whether the Action Official sufficiently
documented the corrective actions and certified them, as required by EPA Manual 2750.
Corrective Actions Not Completed
EPA did not complete the eight actions it planned to take in response to our 2006 report.
As of March 31, 2008, EPA was 16 months past the milestone dates of October/
November 2006 and 20 months past the management decision date of July 31, 2006,
without completing the actions. Appendix B provides the status of corrective actions.
While EPA significantly decreased the undistributed historical "WQ" costs for
cooperative agreements and small purchases, "WQ" costs increased for interagency
agreements. "WQ" costs for interagency agreements increased from May 12, 2006,l to
December 31, 2007, by a net $1,081,507, to $4,866,735. The total includes a remaining
amount of $2,993,960 that we reported on previously and additional costs charged to
"WQ" of $1,872,775 since May 12, 2006. Table 1 illustrates the undistributed "WQ"
costs by funding vehicle at May 12, 2006, and December 31, 2007, and the amount of
increase or decrease.
1 We reported the May 12, 2006, undistributed "WQ" costs in the prior audit report based on EPA's updated data
reports. We did not audit this data.
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08-P-0236
Table 1: Undistributed "WQ" Costs
Funding Vehicle
Cooperative Agreements
Interagency Agreements
Small Purchases
Totals
Undistributed "WQ"
May 12, 2006
(Unaudited)
$7,417,231
3,785,228
1,737,599
$12,940,058
December 31,
2007
$337,502
4,866,735
707,723
$5,911,960
(Decrease) / Increase
in "WQ"
May 12, 2006 to
December 31, 2007
$(7,079,729)
1,081,507
(1,029,876)
$(7,028,098)
Source: OIG analysis of EPA data obtained from the Financial Data Warehouse
A disagreement between OSWER and OCFO over the sufficiency of data submitted
delayed the redistribution of the majority of interagency agreement "WQ" costs. By not
resolving the dispute or elevating the issue to higher levels, corrective actions to decrease
the balance of interagency agreement "WQ" costs were not completed.
Although EPA made significant progress on the corrective action to redistribute the
historical "WQ" costs, the other corrective actions are incomplete. These actions are
necessary to support timely "WQ" cost redistributions in the future. The incomplete
actions include preparing written procedures, evaluating the need for training, revising
cooperative agreement conditions and the closeout process, and promoting accountability
among project officers and finance office personnel.
Management control weaknesses in audit follow-up contributed to the delay in the
corrective actions. EPA did not comply with several internal control procedures designed
for the audit follow-up process. EPA did not:
Document formal work assignments for audit follow-up and maintain
accountability. The MATS files had no record of individual assignments for
audit follow-up.
Monitor audit follow-up activities consistently, communicate follow-up status
among program offices, and obtain follow-up agreements on corrective actions
needed and the assignment of responsibility for the actions.
Document the completion of work for corrective actions. The MATS files
contained some e-mails regarding the redistribution of "WQ" costs, efforts on
preparing written procedures, and training. However, the files did not have
documentation to readily indicate the status of the corrective actions.
Elevate an issue affecting the "WQ" redistributions for interagency
agreements to a higher level of authority for resolution. OCFO and OSWER
personnel were unable to resolve an issue about the allocation of Superfund
costs to the proper sites and redistribute $3.3 million "WQ" costs.
Correspondence shows the issue has existed since 2002.
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08-P-0236
Ensure corrective actions were implemented. For example, OCFO did not
monitor the Cincinnati Finance Center's redistribution efforts and ensure that
the historical "WQ" costs were redistributed.
When OIG inquired about the status of audit follow-up, EPA initiated an effort on
January 31, 2008, to ascertain the current status. EPA provided an updated status on
March 7, 2008, which proposed a new milestone completion date of September 30, 2008,
for all the corrective actions.
Incorrect Information in MATS
The status of a corrective action recorded in OCFO's MATS tracking system was not
accurate. OCFO labeled the corrective action to redistribute the historical "WQ" costs as
complete. However, the action was only partially complete. EPA had redistributed the
historical "WQ" costs for cooperative agreements and small purchases, but not for
interagency agreements. OCFO marked the action "complete" based solely on
information about the cooperative agreement redistributions. OCFO did not have
information at the time on the status of small purchases and interagency agreement
redistributions. Therefore, OCFO did not comply with its control procedures for the
Action Official to ensure that corrective actions are documented, tracked, and
implemented, and for the Audit Follow-up Coordinator to ensure that responses to OIG
reports are complete and timely. Accurate information is necessary for MATS to serve as
a useful management tool.
Cosfs Redistributed to Incorrect Site Identifier
EPA redistributed some historical costs to an incorrect site identifier. Region 5 finance
personnel redistributed $5.4 million of cooperative agreement "WQ" costs on May 8,
2006, based on an assistance adjustment notice. The redistribution helped reduce the
undistributed "WQ" costs reported as of May 12, 2006, in the audit report. Region 5
recorded the costs to the "ZZ" site identifier used for preliminary site assessment, which
precluded cost recovery. However, the site cost detail subsequently received on
October 4, 2006, revealed $1.3 million site-specific costs and $1.5 million indirect costs.
Region 5 should have redistributed the $2.8 million costs in October 2006 to specific site
identifiers and the "00" identifier for indirect costs to make the costs available for
potential cost recovery. EPA Comptroller Policy Announcement 93-02 requires that all
financial transactions recorded in the accounting system be supported by adequate source
documentation. EPA did not comply with this control procedure when it recorded the
redistribution without adequate support.
Conclusion
EPA did not complete the corrective actions it planned to take in response to our 2006 report.
Management control weaknesses in the audit follow-up process delayed EPA's actions to
implement OIG recommendations and improve its programs. EPA needs to improve its audit
follow-up process and complete the corrective actions for our 2006 report. Because EPA did not
complete the corrective actions, its financial management and environmental protection efforts
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08-P-0236
were impacted, and funds may not be recovered from responsible parties and be available for
future site clean-up activities.
Recommendations
We recommend that the Chief Financial Officer, the Assistant Administrator for Solid Waste and
Emergency Response, and the Assistant Administrator for Administration and Resources
Management take the following actions to complete the corrective actions for our July 2006 audit
recommendations:
1. Make formal work assignments for corrective actions, document the assignments in
the MATS files, and hold the individual assignees accountable.
2. Monitor audit follow-up activity, communicate the audit follow-up status among
program offices, and document work progress and completion in the MATS files.
3. Resolve the issue that delayed the redistribution of interagency agreement costs.
4. Elevate future disagreements among Action Officials regarding corrective actions to
the Agency Audit Follow-up Official (the Chief Financial Officer) for resolution.
5. Redistribute the interagency agreement "WQ" costs of $4,866,735, including
$2,993,960 historical costs and $1,872,775 additional costs recorded from May 12,
2006, to December 31, 2007.
Further, we recommend that the Chief Financial Officer:
6. Correct the May 8, 2006, entry to properly redistribute $2.8 million cooperative
agreement costs to the correct general and site specific identifiers.
Agency Response and OIG Evaluation
EPA agreed with all our audit recommendations and its proposed corrective actions should
address our recommendations.
EPA submitted with its response to the draft report a revised corrective action plan and milestone
dates for our July 2006 report, EPA Could Improve Its Redistribution of Superfund Payments to
Specific Sites. EPA significantly adjusted the action plan by making changes to the corrective
actions and revising the milestone dates from October/November 2006 to July 31, 2008, through
November 30, 2008.2 We believe the revised action plan addresses the recommendations.
Therefore, in accordance with EPA Manual 2750, we approve EPA's request to change the
corrective action plan.
2 On August 13, 2008 EPA again revised the corrective action plan to update the July 31, 2008, milestone dates to
August 29, 2008.
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08-P-0236
EPA's complete response to the draft report, including its revised action plan for our July 2006
report, is in Appendix D.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (in $OOOs)
Rec. Page
No. No.
Subject
Status1
Action Official
Planned
Completion
Date2
Claimed Agreed To
Amount Amount
Make formal work assignments for corrective
actions, document the assignments in the MATS
files, and hold the individual assignees
accountable.
Monitor audit follow-up activity, communicate the
audit follow-up status among program offices, and
document work progress and completion in the
MATS files.
7 Resolve the issue that delayed the redistribution of 0
interagency agreement costs.
Elevate future disagreements among Action
Officials regarding corrective actions to the Agency
Audit Follow-up Official (the Chief Financial Officer)
for resolution.
Redistribute the interagency agreement "WQ" costs
of $4,866,735, including $2,993,960 historical costs
and $1,872,775 additional costs recorded from
May 12, 2006, to December 31, 2007.
Correct the May 8, 2006, entry to properly
redistribute $2.8 million cooperative agreement
costs to the correct general and site specific
identifiers.
Chief Financial Officer, 08/29/08
Assistant Administrator for
Solid Waste and Emergency
Response, and
Assistant Administrator for
Administration and
Resources Management
Chief Financial Officer, 08/29/08
Assistant Administrator for
Solid Waste and Emergency
Response, and
Assistant Administrator for
Administration and
Resources Management
Chief Financial Officer, 09/30/08
Assistant Administrator for
Solid Waste and Emergency
Response, and
Assistant Administrator for
Administration and
Resources Management
Chief Financial Officer, 08/4/08
Assistant Administrator for
Solid Waste and Emergency
Response, and
Assistant Administrator for
Administration and
Resources Management
Chief Financial Officer, 11/30/08
Assistant Administrator for
Solid Waste and Emergency
Response, and
Assistant Administrator for
Administration and
Resources Management
Chief Financial Officer 08/31/08
$1,873
$1,873
$2,800
$2,800
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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08-P-0236
Appendix A
Audit Management Responsibilities
Title
Duties
Agency Audit
Follow-up Official
Ensures Agency-wide audit resolution and that systems for audit
follow-up are in place
Ensures corrective actions are actually implemented
Designates an Agency Audit Follow-up Coordinator
Agency Audit
Follow-up Coordinator
Maintains and conducts quality assurance and analysis of the
Agency audit tracking system and data
Prepares reports to Congress
Action Officials
Implements the audited program (commonly the regional official
or Assistant Administrator to whom the report is addressed)
Ensures that corrective actions are documented, tracked, and
implemented
Certifies that corrective actions are complete (or designates a
certifying official to do so)
Audit Management
Officials
Is designated in each regional and national program office
Develops and maintains office-specific procedures for audit
follow-up and resolution
Designates office-specific Audit Follow-up Coordinators
Ensures managers and staff within their office understand the
audit management process and take timely and appropriate
corrective actions
Audit Follow-up
Coordinators
Serves as a contact point for OIG
Provides guidance and ensures that responses to OIG reports
are complete and timely
Maintains official files containing the record of management
decisions and certifications of completed corrective actions
Provides status reports to the Agency Audit Follow-up
Coordinator on corrective actions and audit resolution, and tracks
reasons for delay
Source: EPA Manual 2750
10
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Appendix B
Status of Corrective Actions'
Corrective Action
Agreed
Upon
Milestone
Date
Status
1-1. For all funding vehicles, OCFO will draft
appropriate "WQ" accounting policies to
enhance Comptroller Policy
Announcement 96-01.
October
2006
Not complete. The policies are not
yet written into the Resources
Management Directive System
(RMDS). OCFO projects it will
complete the corrective action by
September 30, 2008.
1-2. OCFO will incorporate "WQ" redistribution
procedures into Chapter 4 "Direct Site
Charging" in RMDS 2550D, Financial
Management of the Superfund Program,
which is in the process of being updated by
OCFO/Office of Financial Management.
October
2006
Not complete. The policies are not
yet written into the RMDS. OCFO
projects it will complete the corrective
action by September 30, 2008.
1-3. OCFO/Office of Financial Services will
develop standard operating procedures for
simplified acquisitions similar to Superfund
contracts for the processing of payments.
October
2006
Not complete. Research Triangle
Park Finance Center established
procedures for simplified acquisitions,
but EPA has not completed the written
procedures for them.
2-1. OSWER and OARM, in cooperation with
OCFO/Office of Financial Management,
will evaluate the need for training on "WQ"
redistribution procedures for each type of
funding vehicle. OCFO/Office of Financial
Management has provided OARM with
project officer training materials for
interagency agreements to include in its
on-line officer train ing course.
November
2006
Partially complete. Research
Triangle Park Finance Center provided
some "WQ" training for project officers
and contract officers at the annual
Superfund Project Officer Contracting
Officer Conference. OCFO needs to
provide project officer training
materials, and OSWER and OARM will
provide training in future classes.
3-1. OCFO, OARM, and OSWER have
prioritized this issue in order for the
balances to come in line with current "WQ"
payments only and is working with States
and other Agencies to ensure compliance.
OCFO will work with the regions to
redistribute the historical costs remaining in
the "WQ" site identifier.
Ongoing
Partially complete. EPA has
redistributed grants/cooperative
agreements and small purchases, but
not interagency agreements.
Appendix B reflects the audited Status of Corrective Actions as of February 25, 2008, the last day of audit field
work. Subsequently, on March 7, 2008, EPA submitted an updated corrective action plan with a proposed milestone
completion date of September 30, 2008, for all corrective actions. Appendix D has EPA's revised corrective action
plan and milestone dates that it submitted on July 16, 2008. On August 13, 2008, EPA again revised the corrective
action plan to update the July 31, 2008, milestone dates to August 29, 2008.
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Corrective Action
Agreed
Upon
Milestone
Date
Status
4-1. OCFO and OSWER are currently working
together to agree on the time frame to
provide site specific cost details within one
business day of the payment draw down.
This will include providing the award
officials with appropriate programmatic
terms and conditions to be included in
future grants. OCFO has updated the
cooperative agreement "WQ" site
distribution policy which is being included in
a draft of RMDS 2550D, Chapter 9, on
cooperative agreements and has updated
the chapter to address the OIG's
recommendation.
October
2006
Not complete. Las Vegas Finance
Center established requirements for its
grant/cooperative agreement recipients
to provide site specific cost details in
one business day. However, EPA has
not completed written procedures and
has not updated terms and conditions
of assistance agreements.
5-1. OCFO, OARM, and OSWER will
coordinate changes in closeout procedures
to ensure and verify that "WQ" costs are
redistributed. OCFO and OSWER are in
the process of amending the latest draft of
RMDS 2550D, Chapter 9, to include
language that would require all "WQ"
payments to be redistributed at the time of
grants closeout.
October
2006
Not complete. The policies are not
yet written into the RMDS. OCFO
projects it will complete the corrective
action by September 30, 2008.
6-1. OCFO, OARM, and OSWER will issue
guidance that assigns specific
responsibilities to ensure that "WQ" costs
are redistributed in a timely manner.
OCFO, OARM, and OSWER will promote
such accountability through the update and
revision of relevant policies and the
evaluation of training needs on an ongoing
basis. OCFO/Office of Financial Services
will continue to monitor "WQ" payment
balances for all funding vehicles on at least
a quarterly basis to ensure that appropriate
project officers and grantees are held
accountable.
November
2006
and
Ongoing
Not complete. The policies are not
yet written into the RMDS. OCFO
projects it will complete the corrective
action by September 30, 2008.
Source: OIG analysis of EPA data
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08-P-0236
Appendix C
Details on Scope and Methodology
We reviewed the status of EPA's corrective actions taken in response to the OIG Report
No. 2006-P-00027, EPA Could Improve Its Redistribution of Superfund Payments to Specific
Sites, issued July 31, 2006. To determine the status of corrective actions, we interviewed
Agency personnel in OCFO, OSWER, and OARM; reviewed audit follow-up information in the
MATS database and MATS files; and obtained data reports of undistributed "WQ" costs for
cooperative agreements, interagency agreements, and small purchases.
We tested a sample of redistributed "WQ" payments recorded from March 30, 2006, to
December 31, 2007, to determine whether EPA charged the appropriate site identifiers and had
proper supporting documentation for the redistributions. We used the monetary unit method of
statistical sampling to select from all Servicing Finance Office locations a sample of cooperative
agreements, interagency agreements, and small purchases.
We assessed the internal controls relevant to our objectives. We gained an understanding of the
internal controls by reviewing OMB and EPA audit follow-up guidance and interviewing
personnel at Headquarters, regional offices, program offices, and finance centers. We did not
review the internal controls over EPA's Financial Data Warehouse from which we obtained data
reports, but relied on the OIG's review performed during the audit of EPA's Fiscal Year 2007
financial statements.
Since EPA did not complete the corrective actions, we could not fully address our second audit
follow-up objective to determine whether the Action Official sufficiently documented the
corrective actions and certified them, as required by EPA Manual 2750.
We also reviewed two prior OIG evaluation reports on audit follow-up (see Table 2). These
reports covered EPA's audit follow-up processes in the Office of Water, Office of Enforcement
and Compliance Assurance, and Office of Air and Radiation.
Table 2: Prior Audit Coverage
Report Title
EPA's Office of Air and Radiation Needs to Improve
Compliance with Audit Follow-up Process
EPA Can Improve Its Oversight of Audit Follow-up
Report No.
08-P-0080
2007-P-00025
Date
February 12, 2008
May 24, 2007
Source: OIG evaluation reports
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08-P-0236
Appendix D
EPA Response to Draft Report
July 16, 2008
MEMORANDUM
SUBJECT:
FROM:
TO:
Draft Audit Report: Follow-up on Audit of Undistributed Site Costs Finds
Corrective Actions Not Complete, Assignment No. 2008-0040
Lorna M. McAllister, Director
Office of Financial Management
Milton Brown, Director
Office of Financial Services
Krista Mainess, Director
Office of Program Management
James E. Woolford, Director
Office of Superfund Remediation and Technology Innovation
Howard Corcoran, Director
Office of Grants and Debarment
Melissa Heist, Assistant Inspector General for Audit
Office of Inspector General
This is in response to the May 14, 2008 memorandum on the draft audit report "Follow-
up on Audit of Undistributed Site Costs Finds Corrective Actions Not Complete, No 2008-0040. "
We concur with all audit recommendations except for recommendation number 4. Attached are
our consolidated corrective action plans with milestones including the corrective actions and
milestones for the original 2006 report, "EPA Could Improve Its Redistribution of Superfund
Payments to Specific Sites, No. 2006-P-00027".
With regard to recommendation No. 4, the disagreement cited by the OIG remained at a
level below the Action Officials and was resolved by lower level management between the two
offices. Therefore, we do not believe there is a need to elevate this disagreement to the Agency
Audit Follow-up Official.
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08-P-0236
If you or your staff have any questions or need additional information concerning this
response, contact lantha Y. Gilmore at 202-564-7654.
Attachment
cc: Lyons Gray
Maryann B. Froehlich
Melissa Heist
Joshua Baylson
Susan Dax
Raffael Stein
James Wood
Paul Curtis
Bill Samuel
15
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08-P-0236
August 4, 2008
MEMORANDUM
-th-
SUBJECT: Amendment: July 16 Response to Draft Audit Report: Follow-Up Audit of
Undistributed Site Costs Funds Corrective Actions Not Complete, Assignment No.
2008-0040.
FROM: Lorna M. McAllister, Director /s/
Office of Financial Management
Howard Corcoran, Director
Office of Grants and Debarment
TO: Melissa Heist, Assistant Inspector General for Audit
Office of Inspector General
As you know, your office conducted an exit conference to provide feedback on the July
16th written response to the Draft Audit Report: Follow-Up Audit Undistributed Site Costs
Funds Corrective Actions Not Complete, Assignment No. 2008-0040. Based on this feedback,
the original response to Recommendation #4 which states: Elevate future disagreements among
Action Officials regarding corrective actions to the Agency Audit Follow-up Officials (the Chief
Financial Office) for resolution] will be revised to state the following:
"The Agency agrees to elevate future staff disagreements between offices
to upper level management for resolution."
If you have any questions, please have your staff contact lantha Y. Gilmore on 202-564-
7654.
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08-P-0236
ATTACHMENT
Name of Report:
Background Information
Audit Report: Follow-up on Audit of Undistributed Site Costs Finds Corrective
Actions Not Complete.
Report Number
and Date:
2008.0040 M M 200g
J
Title of Finding
Followup on Audit of Undistributed Site Costs Finds Corrective Actions Not Complete
p in jjpyj'7'T^ , ^ , ! p gnu " M; ^ gjuii u: ^ h|||' i(. ( 111 , s 11 \ I if o i I?
Recommendation:
Make formal work assignments for corrective actions, document the
assignments in the MATS files, and hold the individual assignees
accountable.
Office Director:
Krista Mainess (OPM)
Lora Culver (OMIS)
Howard Corcoran (OGD)
POC Manager:
Barbara Freggens (OPM)
Johnsie Webster (OMIS)
Bernie Davis-Ray (OARM)
a. Summary of
Corrective Action:
OARM/OGD, OCFO/OPM and OSWER/OMIS - Each Audit Follow-up
Coordinator (Coordinator at each Program Office's Immediate Office
level) will update MATS with a revised corrective action plan. The
revised action plan will identify each Office's responsible Action Officer
and will include updated plan actions, and new milestone dates.
b. Target Completion Date: July 3 1,20082 c. Actual Date Completed
Recommendation:
Monitor audit followup activity, communicate the audit followup status
among program offices, and document work progress and completion in
the MATS files.
Office Director:
Krista Mainess (OPM)
Lora Culver (OMIS)
Howard Corcoran (OGD)
_
Jjr
Mana§er
Barbara Freggens (OPM)
Johnsie Webster (OMIS)
Bernie Davis-Ray (OARM)
a. Summary of
Corrective Action:
OARM/OGD, OCFO/OPM and OSWER/OMIS - Each Audit Follow-up
Coordinator will request a monthly progress report from each responsible
project officer and will hold quarterly meetings to assure successful
completion of the audit recommendations and will ensure that MATS is
updated quarterly.
b. Target Completion | July 31, 20082
c. Actual Date Completed:
Recommendation:
Resolve the issue that delayed the redistribution of interagency
agreement costs.
Office Director:
James E. Woolford (OSRTI)
v '
POC
Manager:
Barbara McDonough (OSRTI)
& v '
a. Summary of
Corrective Action:
OSRTI will complete development of internal procedures for performing
site redistribution for its Project Officers. The procedures will include
processes to ensure that its Project Officers know and communicate
appropriate information to the appropriate Finance Center to enable the
redistribution of WQ costs in a timely manner.
b. Target Completion Date: September 30, 2008 c. Actual Date Completed:
-------
08-P-0236
TV^rj-if^^fiif^^
5
Recommendation:
Office Director:
a. Summary of
Corrective
Action:
Redistribute the interagency agreement "WQ" costs of $4,866,735,
including $2,993,960 historical costs and $1,872,775 additional costs
recorded from May 12, 2006, to December 31, 2007.
Milton Brown (OFS) A, , . ,,. . . /rkT7C,x
T c iir if- j T>/^A,f Melvm Vismck (OFS)
James E. Woolford POC Manager: , v , ..^n,
fOSRTD Barbara McDonough (OSRTI)
OSRTI will provide data for its outstanding interagency agreement WQ
disbursements through Budget Fiscal Year 2007 or documentation of
reasons for outstanding unredistributed disbursements to OCFO/CFC no
later than September 8, 2008.
OCFO/CFC will enter redistributions from information received from
OSRTI and other appropriate offices into IFMS by November 30, 2008.
b. Target Completion Date: November 30, 2008
J^Mincws i'fellit 5^& iI.C5 als
6
Recommendation:
Office Director:
a. Summary of
Corrective
Action:
c. Actual Date Completed:
^K
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08-P-0236
ATTACHMENT
(Note: Original response is in GREEN. Agency's updated response is in RED)
Background Information
Name of Report: Audit Report: EPA Could Improve Its Redistribution of Superfund Payments to
Specific Sites
Report Number 2006.p.00027 M 3l 20Q6
and Date: J
Title of Finding
EPA Could Improve Its Redistribution of Superfund Payments to Specific Sites
i ^"ksd'rrnriTiri-i ? fiT; i *;-.
Recommendation:
Office Director:
a. Summary of
Corrective Action:
As agreed, develop written procedures for implementing EPA's
Superfund site specific accounting policies related to the general site
identifier WQ, including a timeliness standard for redistributions for
each funding vehicle, an explanation of project officers'
responsibilities, monitoring procedures, and WQ cost reviews at the
time of closeout. Develop a standard format for project officers of
interagency agreements to transmit cost redistribution information to
the Cincinnati Finance Center.
Lorna McAllister (OFM) POC lantha Gilmore (OFM)
Milton Brown (OFS) Manager: Mel Visnick (OFS)
For all funding vehicles, OCFO/OFM will or has begun drafting
appropriate WQ accounting policies to enhance the Comptroller Policy
Announcement 96-01. WQ redistribution procedures will be
incorporated into Chapter 4 "Direct Site Charging" of the RMDS
2550D, also known as "Financial Management of the Superfund
Program," which is in the process of being updated by OCFO/OFM.
Change: For all funding vehicles, OCFO/OFM is drafting an update to
appropriate WQ accounting policies to include WQ redistribution
procedures. Under OCFO's new numbering scheme for all for
Superfund policies, Chapter 4 is now Chapter 2 of RMDS 2550D,
"Direct Site Charging" also known as "Financial Management of the
Superfund Program."
New Target Date: July 31, 20082
OCFO/OFS is also developing standard operating procedures for
simplified acquisitions similar to Superfund contracts for the processing
of payments.
OCFO/OFS will provide this information for inclusion into the draft
policy referenced above.
New Target Date: July 31, 20082
b. Target Completion Date: October 2006 c. Actual Date Completed:
19
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08-P-0236
Recommendation:
Evaluate the need for training on WQ redistribution procedures for each
type of funding vehicle and provide the appropriate level of training to
the responsible personnel.
Office Director:
James E. Woolford
(OSRTI)
Howard Corcoran (OGD)
Lorna McAllister (OFM)
POC
Managers:
Barbara McDonough
(OSRTI)
Jeanne Conklin (OGD)
lantha Gilmore (OFM)
a. Summary of
Corrective Action:
OSWER/OSRTI and OARM/OGD, in cooperation with OCFO/OFM,
will evaluate the need for training on WQ redistribution procedures for
each type of funding vehicle.
OCFO/OFM has provided OARM/OGD with project officer training
materials for lAGs to include in its on-line officer training course.
Change: OSWER/OSRTI and OARM/OGD will evaluate training
needs for their staffs. OCFO/OFM will assist OSWER and OARM on
an as requested basis.
New Target Date: August 27, 2008
b. Target Completion Date: November 2006 c. Actual Date Completed:
STs'iShTZ
Recommendation:
Continue working with the regions to redistribute the historical costs
remaining in the WQ site identifier.
Office Director:
Milton Brown (OFS)
Howard Corcoran (OGD)
James E. Woolford
(OSRTI)
POC
Manager:
Melvin Visnick (OFS)
Jeanne Conklin (OGD)
Barbara McDonough
(OSRTI)
a. Summary of
Corrective Action:
EPA has prioritized this issue in order for the balances to come in line
with current WQ payments only and is working with States and other
Agencies to ensure compliance. For instance, Region III has a small
backlog that they plan to eliminate. Region V is working to eliminate
the backlog before the Cooperative Agreement processing migrates to
OFS/LV this winter and has already redistributed $9.6 million. Region
V is also committed to redistributing the balance of $7.3 million by
December 2006, having obtained the cooperation of its recipients to
provide the necessary site-specific cost detail. OCFO/OFS has
aggressively worked to redistribute simplified acquisition backlog and
has provided the regions with reports for their use in eliminating their
own backlog. The Las Vegas Finance Center, in coordination with the
regions and grant recipients, has already redistributed to the correct
sites all outstanding cooperative agreement WQ balances for the
regions it services.
Change: With the consolidation of all Agency grant payment services
to the Las Vegas Finance Center, LVFC received additional grants that
20
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08-P-0236
lacked site specific cost detail. LVFC completed their research and
eliminated the backlog of grants on 9/6/07.
OCFO/OFS has assisted the Regions in distributing WQ costs. The
Cincinnati Finance Center continues to work with OSRTI and the
Regional Offices to obtain the data required to complete redistribution.
Any current balance in WQ for contracts and small purchases under
RTF's control represents ongoing payments (not part of the backlog)
and are quickly redistributed.
New Target Date: November 30, 2008
b. Target Completion Date: June 30, 2006 c. Actual Date Completed:
J ^-mmj:Wi i,;{i:B7[T?r3>r,, § , 5; :;;>, ^i^i, j j, y , .r ,,__. -K, .j,-,.,
4
Recommendation:
Office Director:
a. Summary of
Corrective Action:
Continue working to change the cooperative agreement conditions to
require the recipient to provide site-specific cost details within 24 hours
of drawing down funds, and enforce those conditions.
Lorna McAllister (OFM) lantha Gilmore (OFM)
James E. Woolford POC Barbara McDonough
(OSRTI) Manager: (OSRTI)
Howard Corcoran (OGD) Jeanne Conklin (OGD)
OCFO/OFM and OSWER/OSRTI are currently working together to
agree on the time frame to provide site specific cost details within one
business day of the payment draw down. This will include providing
the award officials with appropriate programmatic terms and conditions
to be included in future grants.
OCFO/OFM has updated the Cooperative Agreement WQ site
distribution policy which is being included in a draft of Chapter 9,
RMDS on Cooperative Agreements and has updated the chapter to
address the OIG's recommendation.
Change: OCFO, OARM and OSWER are currently working together
to provide the award officials with the appropriate National
programmatic term and condition to be included in future grants.
OARM/OGD and OSWER/OSRTI will provide this information to
OCFO/OFM for incorporation into the draft policy referenced in
Recommendation No. 1 .
New Target Date: July 31, 20082
OCFO/OFM will provide updates to the Cooperative Agreement WQ
site distribution policy which is being included in the draft policy
update referenced in Recommendation No. 1 .
New Target Date: July 31, 20082
b. Target Completion Date: October 2006 c. Actual Date Completed:
21
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08-P-0236
ii i r f^:
Recommendation:
Amend the closeout process for cooperative agreements to include
procedures to verify that WQ costs are redistributed.
Office Director:
Milton Brown (OF S)
Howard Corcoran
(OGD)
James E. Woolford
(OSRTI)
Lorna McAllister
(OFM)
POC
Manager:
Mel Visnick (OFS)
Jeanne Conklin (OGD)
Barbara McDonough
(OSRTI)
lantha Gilmore (OFM)
a. Summary of
Corrective Action:
OCFO/OFS, OARM/OGD, and OSWER/OSRTI will coordinate
changes in closeout procedures to ensure and verify that WQ costs are
redistributed.
OCFO/OFM and OSWER/OSRTI are in the process of amending the
latest draft of 2550D Chapter 9 to include language that would require
all WQ payments to be redistributed at the time of Grants closeout.
Change: OSWER/OSRTI will provide updates to the OCFO/OFM draft
policy update referenced in Recommendation No. 1 to include a
requirement that all WQ payments to be redistributed at the time of
Grants closeout. At present RMDS 2550D Chapter 9 (now Chapter 4
under the new numbering scheme) does not address WQ and is not
being updated at this time.
New Target Date: July 31, 20082
b. Target Completion Date: October 2006 c. Actual Date Completed:
Recommendation:
Promote accountability for WQ redistributions among project officers
and finance office personnel.
Office Director:
Lorna McAllister (OFM)
Howard Corcoran (OGD)
James E. Woolford
(OSRTI)
Milton Brown (OFS)
POC
Manager:
lantha Gilmore (OFM)
Jeanne Conklin (OGD)
Barbara McDonough
(OSRTI)
Melvin Visnick (OFS)
a. Summary of
Corrective Action:
OCFO/OFM, OARM/OGD, and OSWER/OSRTI will issue guidance
that assigns specific responsibilities to ensure that WQ costs are
redistributed in a timely manner. As discussed above, OCFO/OFM,
OARM/OGD, and OSWER/OSRTI will promote such accountability
through the update and revision of relevant policies and the evaluation
of training needs on an ongoing basis.
OCFO/OFS will continue to monitor WQ payment balances for all
funding vehicles on at least a quarterly basis to ensure that appropriate
project officers and grantees are held accountable.
22
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08-P-0236
Change: OCFO/OFM draft policy referenced in Recommendation 1
will clarify roles and responsibilities to identify who is responsible for
redistributing WQ costs and strengthen the timeframes by which the
redistribution is to occur.
New Target Date: July 31, 20082
b. Target Completion Date: November 2006 c. Actual Date Completed:
23
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08-P-0236
Appendix E
Distribution
Office of the Administrator
Chief Financial Officer
Assistant Administrator for Solid Waste and Emergency Response
Assistant Administrator for Administration and Resources Management
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
Office of General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Financial Management
Director, Office of Site Remediation and Technology Innovation
Director, Office of Grants and Debarment
Audit Follow-up Coordinator, Office of the Chief Financial Officer
Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response
Audit Follow-up Coordinator, Office of Administration and Resources Management
Deputy Inspector General
24
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