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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Financial Management
EPA Complied With Improper
Payment Legislation, but
Testing Can Be Improved
Report No. 17-P-0212	May 10, 2017
Testing improvements

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Report Contributors:
Doug LaTessa
Patrick Mclntyre
Michael Petscavage
Mary Anne Strasser
Abbreviations
AFR
Agency Financial Report
CBOR
Compass Business Objects Reporting
CPS
Commodity Payments Statistics
CWSRF
Clean Water State Revolving Fund
DWSRF
Drinking Water State Revolving Fund
EPA
U.S. Environmental Protection Agency
FY
Fiscal Year
IPERA
Improper Payments Elimination and Recovery Act of 2010
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
OMB
Office of Management and Budget
RTP-FC
Research Triangle Park Finance Center, Financial Services Branch
SPITS
Small Purchase Information Tracking System
U.S.C.
United States Code
Cover image: Graphic illustrating how improved testing for improper payments can result in
better use of funds for environmental and supporting programs. (EPA OIG image)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
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Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
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May 10, 2017
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At a Glance
(wi
^4 PrO^
Why We Did This Review
The Improper Payments
Elimination and Recovery Act
of 2010 (IPERA), as modified
by the Improper Payments
Elimination and Recovery
Improvement Act of 2012,
requires that each fiscal year
the Inspector General of each
agency determine whether the
agency is in compliance with
the law. In addition, Office of
Management and Budget
Memorandum M-15-02 states
that the Office of Inspector
General (OIG) may evaluate
the accuracy and completeness
of agency reporting and the
agency's performance in
reducing and recapturing
improper payments. Our audit
focused on the U.S.
Environmental Protection
Agency's (EPA's) compliance
with these requirements.
This report addresses the
following EPA goal or
cross-agency strategy:
• Embracing EPA as a high-
performing organization.
EPA Complied With Improper Payment
Legislation, but Testing Can Be Improved
What We Found
The EPA complied with improper payments legislation
when reporting improper payments in fiscal year 2016.
However, we noted issues of concern.
Improved testing for
improper payments
will result in better
use of funds for
environmental and
supporting programs.
EPA Region 2 tested only 46 percent of the selected
Hurricane Sandy grant expenditures for improper
payments, instead of the 100 percent required. The
Disaster Relief Appropriations Act of 2013 designated Hurricane Sandy disaster
relief funding as susceptible to significant improper payments, requiring the EPA
to develop a statistical sampling plan for testing Hurricane Sandy expenditures.
Region 2 staff misunderstood the requirement to test all dollars associated with
the four federal payments to the New York State Department of Environmental
Conservation. Incomplete testing impacted the certainty that there were no
improper payments in the sampled items for Hurricane Sandy grants payments.
Additionally, insufficient internal controls for commercial payments resulted in
inaccurate information being reported. The EPA understated total dollar outlays
for contract payments by $33,877. Further, the EPA could not confirm the
accuracy of the monthly and year-end total "Amount Paid" values, nor the
improper payment error rate for commodity payments. During the course of our
audit, the EPA took sufficient action to address this issue.
Recommendations and Planned Agency Corrective Actions
We recommend that the Chief Financial Officer revise its annual review guidance
to include language to require testing of all dollars associated with statistically
selected samples. The agency concurred with the recommendation and provided
an estimated completion date of August 2017 to revise its annual review
guidance. The recommendation is considered resolved with the corrective action
pending.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oia.
Listing of OIG reports.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
May 10, 2017
MEMORANDUM
SUBJECT: EPA Complied With Improper Payment Legislation, but Testing Can Be Improved
Report No. 17-P-021?
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY17-0054.
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.
Action Required
You are not required to provide a written response to this final report because you provided agreed-to
corrective actions and planned completion dates for the report's recommendation. Should you choose to
provide a final response, we will post your response on the OIG's public website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as
amended. The final response should not contain data that you do not want to be released to the public;
if your response contains such data, you should identify the data for redaction or removal along with
corresponding justification.
FROM
Arthur A. Elkins Jr.
TO
David Bloom, Acting Chief Financial Officer
We will post this report to our website at www.epa.gov/oig.

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EPA Complied With Improper Payment
Legislation, but Testing Can Be Improved
17-P-0212
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Office		2
Scope and Methodology		2
Prior Audit Coverage		3
2	EPA Complied With IPERA		4
IPERA and OMB Provide Requirements for Compliance		4
EPA Was in Compliance With IPERA		4
3	Testing for Hurricane Sandy Improper Payments Needs Improvement		6
Legislation and EPA Policy Provide Guidance on Sampling		6
Region 2 Staff Did Not Test All Hurricane Sandy Grant Expenditures		6
Actions Taken		7
Recommendation		7
Agency Comments and OIG Evaluation		7
4	Improvement Is Needed in Process of Collecting and Reporting
Improper Payments for Contract and Commodity Payments		8
Internal Controls Needed to Achieve Reporting Reliability		8
Internal Controls Were Not Sufficient to Detect Reporting Errors		8
Actions Taken		10
Status of Recommendations and Potential Monetary Benefits		11
Appendices
A Agency Response to Draft Report	 12
B Distribution	 14

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Chapter 1
Introduction
Purpose
The purpose of the audit was to report on the U.S. Environmental Protection
Agency's (EPA's) compliance with the Improper Payments Elimination and
Recovery Act of 2010 (IPERA), and to evaluate the accuracy and completeness
of agency reporting and performance in reducing and recapturing improper
payments.
Background
Office of Management and Budget (OMB) Memorandum M-15-021 states that
Inspectors General may evaluate (1) the accuracy and completeness of agency
reporting, and (2) agency performance in reducing and recapturing improper
payments. Also, Inspectors General are annually required to determine whether
agencies are in compliance with the six requirements identified in IPERA.
IPERA requires agencies to conduct risk assessments of their programs or activities
to determine whether they are susceptible to significant improper payments.
IPERA defines significant improper payments as gross annual improper payments
exceeding the statutory threshold of both 1.5 percent of program outlays and
$10 million of all program or activity payments during the fiscal year reported, or
$100 million. IPERA defines the term "payment" as any transfer or commitment
for future transfer of federal funds such as cash, securities, loans, loan guarantees,
and insurance subsidies to any non-federal person or entity, that is made by a
federal agency, a federal contractor, a federal grantee, or a governmental or other
organization administering a federal program or activity. For improper payment
reporting, the EPA collects and reports improper payments by type of activity
(i.e., payment stream).
For fiscal year (FY) 2016 reporting, the majority of the EPA's activities were
determined to be at a low risk of significant improper payments. According to the
EPA, three of the agency's risk-susceptible activities—the Clean Water State
Revolving Fund (CWSRF), Drinking Water State Revolving Fund (DWSRF), and
Hurricane Sandy—remain below statutory thresholds. OMB deemed the State
Revolving Funds to be risk-susceptible, and the Disaster Relief Appropriations Act
of 2013 (Public Law 113-2) designated Hurricane Sandy funding as susceptible to
significant improper payments. In addition, grant payment activities have been
newly identified as risk-susceptible based on the results of transaction testing
1 OMB Memorandum M-15-02, dated October 20, 2014, modified OMB Circular No. A-123, Appendix C,
Requirements for Effective Estimation and Remediation of Improper Payments.
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performance in FY 2016. Therefore, the EPA stated that robust statistical sampling
will be initiated for grant payments in FY 2017 and beyond to identify accurate
improper payment rates and estimates.
Responsible Office
The Office of the Chief Financial Officer (OCFO) formulates and manages the
EPA's annual budget and performance plan, coordinates the EPA's strategic
planning efforts, develops the EPA's annual Performance and Accountability
Report, and implements the Government Performance and Results Act. OCFO
also provides financial services for the EPA and makes payments to the EPA
grant recipients, contractors and other vendors. The office provides policy, reports
and oversight essential for the financial operations of the EPA.
Scope and Methodology
We conducted this performance audit from November 2016 to April 2017 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 objective. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objectives.
The purpose of the audit was to report on the EPA's compliance with IPERA and
evaluate the accuracy and completeness of agency reporting and performance in
reducing and recapturing improper payments. To determine whether the EPA
complied with IPERA, we reviewed the EPA's FY 2016 Agency Financial Report
(AFR) and accompanying materials. We interviewed agency staff at the EPA
headquarters for OCFO, the Office of Administration and Resources
Management's Office of Grants and Debarment, and the Office of Water. We also
interviewed OCFO staff from the Las Vegas, Research Triangle Park and
Cincinnati Finance Centers.
We gained an understanding of the processes, procedures and controls used for
improper payment and recovery reporting across the EPA—including State
Revolving Funds, grants, commodities, contracts, payroll and Hurricane Sandy—
and selected judgmental samples from each activity. We traced improper
payments in our sample back to source documentation to test the accuracy of
improper payment reporting in the EPA's FY 2016 AFR. For the State Revolving
Funds, we reviewed the transaction testing worksheets to verify that they were
completed in accordance with EPA policies. We reviewed all of the qualitative
and quantitative risk assessments that the EPA prepared. We took steps to confirm
the accuracy of both the Office of Grants and Debarment's and Las Vegas
Finance Center's improper payment schedules to the EPA system-generated
support data for the grants payment stream. For EPA activities that are currently
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considered to be susceptible to significant improper payments, we reviewed a
sample of negative draws, Program Evaluation Reports, and transaction testing
reports and worksheets, to identify improper payments that were not reported.
We also used data systems, including the Grantee Compliance and Recipient
Activity Database, Contract Payment System (CPS), Small Purchase Information
Tracking System (SPITS), and Compass Data Warehouse. We verified the
information in the systems to source documentation, and concluded that the
information provided a reasonable basis for our findings and conclusions.
Prior Audit Coverage
During this audit, we followed up on agency corrective actions from EPA Office
of Inspector General (OIG) Report No. 16-P-0167. EPA Complied With Improper
Payment Legislation, but Stronger Internal Controls Are Needed, issued May 10,
2016. That report made seven recommendations. We verified that all corrective
actions have been completed.
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Chapter 2
EPA Complied With IPERA
The EPA complied with IPERA for FY 2016 reporting. IPERA established six
requirements that must be met for agencies to be considered in compliance. We
found that the EPA complied with all six conditions.
IPERA and OMB Provide Requirements for Compliance
IPERA and Part II, Section A(3), of OMB Memorandum M-15-02 established the
following six mandatory steps for agency compliance:
•	Publish an AFR or Performance and Accountability Report for the most
recent fiscal year and post that report and any accompanying materials
required by OMB on the agency website.
•	Conduct a program-specific risk assessment for each program or activity
that conforms with 31 U.S.C. Section 3321 (if required).
•	Publish improper payment estimates for all programs and activities
identified as susceptible to significant improper payments under its risk
assessment (if required).
•	Publish programmatic corrective action plans in the AFR or Performance
and Accountability Report (if required).
•	Publish, and meet, annual reduction targets for each program assessed to be
at risk and estimated for improper payments (if required and applicable).
•	Report a gross improper payment rate of less than 10 percent for each
program and activity for which an improper payment estimate was obtained
and published in the AFR or Performance and Accountability Report.
EPA Was in Compliance With IPERA
The EPA met the six requirements of IPERA, as shown in Table 1. Therefore, the
EPA's FY 2016 improper payment reporting was in compliance with IPERA.
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Table 1: EPA met the six requirements of IPERA
Requirement
Complied?
Description
Published an AFR for the most
recent fiscal year and posted it
on the agency website.
Yes
The EPA published an AFR on the agency website on November 15,
2016.
Conducted a program-specific
risk assessment (if required).
Yes
The EPA performed program-specific risk assessments for seven
payment streams (listed below) based on OMB Memorandum M-15-02,
which requires executive agencies to conduct risk assessments of their
programs or activities to determine if they are susceptible to significant
improper payments.
•	CWSRF
•	DWSRF
•	Grants
•	Contracts
•	Commodities
•	Payroll
•	Hurricane Sandy
Published improper payment
estimates for all programs and
activities identified as
susceptible to significant
improper payments
(if required).
Yes
The CWSRF and DWSRF programs are considered to be risk-
susceptible programs. The EPA reported improper payment estimates
for both of these programs in Table 1 in the Improper Payments
Compliance section of the AFR.
Also, pursuant to the Disaster Relief Appropriations Act of 2013, all
payments made under the act are automatically deemed susceptible to
significant improper payments. As a result, the EPA designed and
implemented a statistical sampling plan for testing Hurricane Sandy
expenditures. The EPA reported improper payment estimates for the
Hurricane Sandy payment stream in Table 1 in the Improper Payments
Compliance section of the AFR.
Published programmatic
corrective action plans in
(if required).
Not
Required
The EPA did not meet the statutory threshold of $10 million and
1.5 percent of program outlays, or $100,000,000, and therefore the
corrective action plan is not required. Improper payments reported for
risk-susceptible programs were:
•	CWSRF - $80,000
•	DWSRF-$170,000
•	Hurricane Sandy - $0
Published and met annual
reduction targets for each
program assessed to be at risk
and estimated for improper
payments.
Yes
The EPA published and met the annual reduction targets for FY 2016.
Each year, the EPA establishes a targeted rate that is a reduction from
the prior year's targeted rate. The actual improper payment rate was
less than the targeted rate established as the reduction target for
FY 2016.
Payment
Targeted rate
Actual rate
Stream
(percent)
(percent)
CWSRF
1.45
.01
DWSRF
1.99
.01
Hurricane Sandy
1.5
0
Reported a gross improper
payment rate of less than
10 percent for each program
and activity for which an
improper payment estimate
was obtained and published in
the AFR.
Yes
The EPA reported gross improper payment rates of less than 10% for
each payment stream.
•	CWSRF: .01%
•	DWSRF: .01%
•	Hurricane Sandy: 0%
Source: OIG analysis of EPA data.
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Chapter 3
Testing for Hurricane Sandy Improper Payments
Needs Improvement
Testing for Hurricane Sandy improper payments needed improvement. EPA
Region 2 staff did not test all grant expenditures corresponding to the selected
Hurricane Sandy payments for improper payments. Region 2 staff tested only
46 percent of the expenditures corresponding to the four selected federal payments
for the state of New York. The Disaster Relief Appropriations Act of 2013
designated Hurricane Sandy disaster relief funding as susceptible to significant
improper payments, requiring the EPA to develop a statistical sampling plan for
testing Hurricane Sandy expenditures. The EPA applied a stratified random
sampling methodology in selecting payments to review. However, EPA Region 2
staff misunderstood that they were required to test all dollars associated with the
four federal payments selected. Not testing 100 percent of the grant dollars
associated with the four selected federal payments impacted the certainty that there
were no improper payments in selected Hurricane Sandy grants.
Legislation and EPA Policy Provide Guidance on Sampling
The Disaster Relief Appropriations Act of 2013 designated Hurricane Sandy disaster
relief funding as susceptible to significant improper payments. Per OMB M-13-07
requirements, the EPA developed a statistical sampling plan for testing Hurricane
Sandy expenditures. The EPA applied a stratified random sampling methodology in
selecting payments for review, as the EPA recognized that Hurricane Sandy
expenditures are comprised of several categories, including, for example, grants and
contracts. The sampling plan stated that the EPA would conduct estimates of these
categories to identify potential weaknesses and vulnerabilities. As a result, the EPA
applied a stratified random sampling methodology in selecting payments for review,
which would increase the precision of the estimate of the percentage of erroneous
payments. Within each category, the EPA's sampling methodology stated that a
simple random sample of payments would be selected for review. The impact of this
stratification was to maximize the total number of dollars being selected for review.
Region 2 Staff Did Not Test All Hurricane Sandy Grant Expenditures
EPA Region 2 staff did not test all (100 percent) selected Hurricane Sandy grant
dollars for improper payments. EPA Region 2 tested only 10 of the 65 invoices, or
$118,141 of $255,524 (46 percent) of the expenditures corresponding to the four
selected federal payments for the state of New York. The EPA's OCFO
statistician confirmed that the expectation in the sampling plan was that
100 percent of the underlying dollars in each selected payment would be tested.
Region 2 staff did not understand that all dollars associated with the four selected
Hurricane Sandy payments should have been tested. Instead, staff thought that
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they needed to test at least a portion of each of those four federal payments.
Therefore, Region 2 did not test all of the underlying dollars associated with those
federal payments.
After reviewing the 10 invoices, staff informed us that it was clear that all
evidence of documentation of costs was in order. Based on this, Region 2 staff
stated that the documentation proved the validity of the recipient's internal control
system and, as a result, there was no need to test the remaining invoices.
However, the lack of 100-percent testing of the grant dollars impacted the
certainty that there were no improper payments in the four payments for the
Hurricane Sandy grants strata.
Actions Taken
On January 31, 2017, an EPA Region 2 grant specialist informed the OIG that all
transaction testing had been completed and that no additional improper payments
were identified. Thus, Region 2 indicated that as of January 31, 2017, all
Hurricane Sandy dollars had been tested.
Recommendation
We recommend that the Chief Financial Officer:
1. Revise the annual guidance on improper payments reporting to include
language requiring that 100 percent of all dollars associated with
statistically selected samples are tested for improper payments.
Agency Comments and OIG Evaluation
The EPA agreed with the recommendation and will revise its annual guidance to
include language requiring that 100 percent of all dollars associated with
statistically selected samples are tested for improper payments. The EPA provided
an estimated completion date of July 31, 2017, for the corrective action. The
recommendation is considered resolved pending completion of the corrective
action.
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Chapter 4
Improvement Is Needed in Process of
Collecting and Reporting Improper Payments for
Contract and Commodity Payments
Insufficient internal controls lead to inaccurate information being collected and
reported to stakeholders. Although the reported improper payments dollar amount
and error rate was accurate for contract payments, the EPA understated total
dollar outlays for contract payments by $33,877. For commodities payments, the
EPA could not confirm the accuracy of the monthly and year-end total "Amount
Paid" values, nor the improper payment error rate. Internal control should provide
reasonable assurance that reporting for internal and external use is reliable. The
deficiencies noted occurred because the Standard Operating Procedure did not
include sufficient detail for when software upgrades required the reporting
process to change mid-year.
Internal Controls Needed to Achieve Reporting Reliability
Section OV1. 01 of the U.S. Government Accountability Office's Standards
for Internal Control in the Federal Government (GAO-14-704G), issued
September 2014, defines internal control as:
A process effected by an entity's oversight body, management, and
other personnel that provides reasonable assurance that the
objectives of an entity will be achieved. These objectives and
related risks can be broadly classified into one or more of the
following three categories:
•	Operations - Effectiveness and efficiency of operations
•	Reporting - Reliability of reporting for internal and
external use
•	Compliance - Compliance with applicable laws and
regulations
Internal Controls Were Not Sufficient to Detect Reporting Errors
Although we noted no exception in the reported improper payments dollar amount
and error rate, the OCFO Research Triangle Park Finance Center's (RTP-FC's)
quantitative risk assessment for the contract payments understated total dollar
outlays by $33,877. In addition, for 11 of 12 months, RTP-FC's staff could not
confirm the accuracy of the reported commodity payments values for the
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"Amounts Paid," nor the aggregate yearly total "Amounts Paid" value of
$214,790,300.
Internal controls were not sufficient to identify and correct the reporting errors
caused by human errors that were made during the process. During RTP-FC's
data collection and reporting process for improper contract payments, RTP-FC
did not use the correct improper payment reporting data for the total dollar outlay.
During the data collection and reporting process for commodities improper
payments, RTP-FC encountered the following issues:
•	EPA's Compass Financial System was upgraded in February 2016. After
the upgrade, RTP-FC staff discovered reporting errors in the Commodity
Payments Statistics (CPS) reports from the Small Purchase Information
Tracking System (SPITS). Therefore, Compass Business Objects
Reporting (CBOR) reports were used in subsequent months.
•	RTP-FC staff stated that a year-end CPS report was not generated from
SPITS due to a system reporting error discovered after the February 2016
update to Compass. RTP-FC staff stated they could not rely on the data
being reported from SPITS. Thus, no reconciliation was performed to
account for subsequent monthly adjustments.
•	RTP-FC staff did not generate either a year-end CPS or a CBOR report to
reconcile monthly adjustments posted to the Compass Financial System
for the "Amounts Paid" values reported in the monthly SPITS and CBOR
reports. After the Compass Financial System update in February 2016,
staff recognized errors in some of the data reported in the SPITS reports.
Due to these reporting errors and not performing a year-end reconciliation,
staff could not confirm the accuracy of the "Amounts Paid" values.
•	RTP-FC staff could not confirm the accuracy of the year-end "Amounts
Paid" values for 11 of 12 months, the aggregate year-end total "Amount
Paid" value, or the 0.10 percent error rate. This occurred because RTP-FC
did not account for adjustments to the "Amounts Paid" values that were
made to the prior monthly SPITS and CBOR reports.
The RTP-FC's Standard Operating Procedure - Improper Payments Reporting,
December 6, 2016,2 does not specifically identify the data from either the CPS,
SPITS or CBOR reports that should be used to populate the commodity and
contract payments quantitative risk assessments. The Standard Operating
Procedure also does not include a requirement to track monthly adjustments in
CBOR reports, and reconcile the accumulative monthly reports with the year-end
report.
2 Section G, "Improper Payment Reporting Requirements"; and Appendix C: Improper Payments QA Checklist.
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As a result of the reporting errors for contract payments, and the unreliability of
the commodities payments computed error rate of 0.10 percent, stakeholders—
such as the public, Congress and other federal agencies—may not be able to rely
on the accuracy of the information the EPA collected and reported.
Actions Taken
On February 2, 2017, RTP-FC amended the current Standard Operating Procedure
to include the following:
•	Clarify, with specificity, which documents are to be generated from each
data system.
•	Clarify, with specificity, which data field values from the generated
reports are to be used to populate the quantitative risk assessment.
•	Document the process to reconcile the monthly CBOR reports to the
year-end values for the "Total Invoices Paid" and "Amounts Paid" values.
We are not making any recommendations regarding this issue because the agency
took sufficient corrective actions to address this issue during the course of our
audit.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Potential
Planned	Monetary
Rec. Page	Completion	Benefits
No. No.	Subject	Status1 Action Official	Date	(In $000s)
1 7 Revise the annual guidance on improper payments reporting to R Chief Financial Officer 7/31/17
include language requiring that 100 percent of all dollars
associated with statistically selected samples are tested for
improper payments.
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Draft Report
(Received April 26, 2017)
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Audit Report No. OA-FY17-0054,
"EPA Complied With Improper Payment Legislation, but Testing Can Be
Improved," dated April 11, 2017
FROM: David A. Bloom, Acting Chief Financial Officer
Office of the Chief Financial Officer
TO:	Michael Petscavage, Director of Contracts and Assistance Agreement Audits
Office of Inspector General
Thank you for the opportunity to respond to the recommendation in the subject draft audit report.
The following is a summary of the agency's overall position on the report recommendation.
AGENCY'S OVERALL POSITION
The agency concurs with the recommendation in the draft audit report.
AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATION
Agreements
No.
Recommendation
High-Level Intended Corrective
Action(s)
Estimated
Completion
1
The Chief Financial Officer revise the
annual guidance on improper payments
reporting to include language requiring
that 100 percent of all dollars
associated with statistically selected
samples are tested for improper
payments.
Office of the Chief Financial Officer
will revise the annual guidance to
include language requiring that 100
percent of all dollars associated with
statistically selected samples are tested
for improper payments.
7/31/2017
CONTACT INFORMATION
If you have any questions regarding this response, please contact the OCFO's Audit Follow-Up
Coordinator, Benita Deane, at 202-564-2079.
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cc: Jeanne Conklin
Meshell Jones-Peeler
Sherri' Anthony
Bob Trent
Andrew LeBlanc
Mary Anne Strasser
Doug LaTessa
Patrick Mclntyre
Benita Deane
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Appendix B
Distribution
The Administrator
Chief of Staff
Chief Financial Officer
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Chief Financial Officer
Controller, Office of the Controller, Office of the Chief Financial Officer
Deputy Controller, Office of the Controller, Office of the Chief Financial Officer
Director, Policy, Training & Accountability Division, Office of the Chief Financial Officer
Chief, Management Integrity & Accountability Branch, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
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