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U.S. Environmental Protection Agency	15-N-0171
' ^L\ Office of Inspector General	June 29,2015
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At a Glance
Why We Did This Review
The Government Charge Card
Abuse Prevention Act of 2012
requires the Inspector General
of each executive agency to
conduct periodic assessments
of the agency purchase card or
convenience check programs.
Risk assessments should
identify and analyze risks of
illegal, improper or erroneous
purchases and payments.
These risk assessments are
used to determine the scope,
frequency and number of
periodic audits of purchase
card or convenience check
transactions.
As the Inspector General for
the U.S. Chemical Safety and
Hazard Investigation Board
(CSB), our objective was to
perform a risk assessment of
agency purchase cards usage,
as required by the act.
This report addresses the
following CSB goal:
• Preserve the public trust by
maintaining and improving
organizational excellence.
CSB's Fiscal Year 2014 Purchase Card Program
Assessed as High Risk
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oia.
The full report is at:
www.epa.gov/oig/reports/2015/
20150629-15-N-0171.pdf
What We Found
Our risk assessment determined that CSB's
fiscal year (FY) 2014 purchase card program
was at high risk for illegal, improper or
erroneous purchases and payments. The
program did not meet federal requirements.
CSB's purchase card program had the following
deficiencies:
CSB's $280,000 purchase
card program for FY 2014 was
assessed as high risk for
illegal, improper or erroneous
purchases and payments.
•	CSB did not have a written Charge Card Management Plan until November
2014. CSB was unaware of the requirement to submit its plan to the Office
of Management and Budget by the required January 2014 deadline.
•	CSB's management made assurances it had the appropriate policies and
controls in place for purchase cards in FY 2014, but CSB did not establish
written policies and controls in a management plan until FY 2015.
•	CSB's management plan did not identify all key management officials.
•	CSB's management plan did not contain the required compliance summary
and internal control assurance assessment.
•	CSB did not obtain prior written supervisory approvals for purchases.
Because CSB's purchase card program is at high risk for illegal, improper or
erroneous purchases and payments, we will conduct an audit of CSB's purchase
card program in FY 2016.
In response to our draft report, CSB agreed that it did not timely submit a
Charge Card Management Plan to the Office of Management and Budget by the
required deadline, and did not include the compliance summary in its
management plan. CSB has also agreed that it did not obtain prior written
supervisory approval for some purchases.
However, CSB disagrees that it certified controls without written internal policies
and procedures. CSB maintains that it follows the Bureau of the Fiscal Service's
purchase card procedures and the management plan formalized CSB's
longstanding purchase card procedures. We did not find evidence that CSB staff
were made aware that there were no agency-specific policies and therefore they
were required to follow Bureau of the Fiscal Service guidance. CSB also
disagrees that the management plan did not identify key management officials.
We believe that the CSB Managing Director approves funding for all purchase
card transactions and should be listed as a key management official.

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