UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WSG 19
Date Signed: January 24, 1980
MEMORANDUM
SUBJECT: Use of Grant Funds for Data Management Activities
FROM: Victor J. Kimm (signed by Victor J. Kimm)
Deputy Assistant Administrator for Drinking Water (WH-550)
TO: Region I-X Water Supply Branch Chiefs
I. Background
In anticipation of the passage of the Safe Drinking Water Act (SDWA), the Office of
Drinking Water (ODW) initiated a study to plan for the information systems necessary for the
successful implementation of the Act. One of the results of that study was a recommendation that
EPA develop a State-oriented data management system.
As a result of the feasibility study, ODW initiated the development of the Model State
Information Systems (MSIS). MSIS had one primary purpose, i.e., to provide common data
management functions, consistent with the program. This was accomplished by providing
capabilities for maintaining public water supply inventory information, perform a consistent and
cost effective determination of compliance of water supplies against applicable Regulations,
maintaining information on enforcement actions an variances and exemptions, and submitting the
information required in the annual report.
MSIS operates on large scale computers manufactured by Henle, IBM and UNIVAC. The
IBM version operates at the EPA's Washington Computer Center (WCC), and is available both to
EPA Regions and to States choosing to use WCC as their State designated computer center.
II. OMB Circular A-90
The Office of Management and Budget (OMB) Circular A-90 outlines government
policies with regard to the installation of computers and the use of computer programs within the
States. The basic policy is that the Federal government cannot require a State to install or use
specific computers or computer programs.
NOTE: MSIS has been superseded by FRDS 2.0.
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On the other hand, OMB Circular A-90 also prohibits the use of Federal grant funds by
States for developing computer programs when such computer programs already exist and have
been offered to the States by the Federal government. The purpose of such a provisions, of
course, is to prevent public monies from being expended when such a capability is already
available to a State government.
An opinion was sought from the Office of General Counsel (OGC) on whether MSIS fell
within the provisions of OMB Circular A-90. It is the opinion of OGC that MSIS does indeed fall
within OBM circular a-90. For your convenience, I am attaching a copy of their response.
III. Guidance
To carry out the OGC opinion, it is very important that all proposed grant requests for
data management funds be carefully reviewed for conformance with OMB Circular A-90. Failure
to perform a thorough review could result in States having to return such monies upon audit.
Generally, data management funds can be used for activities which include:
1. Computer resources - This usually encompasses direct charges for use of a State's
designated computer center. Such charges usually include computer time, data
storages, computer supplies (e.g., computer paper, disk packs, computer tapes),
etc.
2. Data preparation - charges in this category usually results from activities required
to prepare information onto a computer readable media. This may be
accomplished by keypunching, key entry, etc.
3. Personnel - Charges for personnel (e.g., computer systems analyst, computer
programmers) can only be used for the development of reports from stem or for
development and implementation of capabilities not in MSIS. New capabilities
might supplement or extend capabilities not in MSIS.
4. Computer Equipment - These typically might include data terminals which
communicate with State's designated computer centers.
5. Miscellaneous - Charges in this category might include data communications
modems, data communication charges from a public utility, etc.
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During the grant negotiations with our individual Starts, close attention must be paid to
this area. During the headquarters Regional evaluation the request for data management funds
from your States will be carefully reviewed. Those expenditures which are at variance with OMB
circular A-90 will be indicated.
Headquarters Computer systems Staff and Drinking Water Branch personnel are available
to work with you in reviewing a State's proposed expenditure. I recommend that you take
advantage of this opportunity prior to approving such expenditures by calling Tom Martin at
(426-9805) or Jim Manwaring at (472-4152).
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