May 30, 2014
*	 U.S. Environmental Protection Agency	14-P-0272
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At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency's (EPA's)
Office of Inspector General
conducted this review to
assess agency controls and
processes for managing a time-
and-materials (T&M) contract.
We selected one contract to
determine whether: (1) the EPA
has procedures that require the
verification of contractor
personnel as having the
qualifications and credentials
specified in the contract;
(2) the implementation of that
verification process is effective;
and (3) the EPA received the
level of services for which the
agency paid.
The contract, EP-W-07-067
("Technical and Outreach
Support Services for Domestic
and Global Climate Initiatives
and Global Climate Change
Programs"), was awarded by
the EPA's Office of
Administration and Resources
This report addresses the
following EPA goal or
cross-cutting strategy:
 Embracing EPA as a high-
performing organization.
For further information, contact
our public affairs office at
(202) 566-2391.
The full report is at:
Weak Management of a Climate Change
Services Contract Creates Risk EPA Did Not
Receive Services for Which it Paid
What We Found
The EPA lacks a process to verify that
contractor personnel had the skill level to
satisfy contract requirements. We reviewed all
93 task orders for contract EP-W-07-067 and
focused on task order 25. The task order 25
review revealed several problems:
The EPA awards millions of
federal dollars to contractors
every year. It must have
robust oversight and
management controls in
place to prevent waste and
unnecessary spending.
	The task order did not list any employees
named in reviewed invoices.
	The EPA repeatedly modified the task order to increase funding from an
initial estimate of $310,917 to over $2,000,000.
	The contracting officer's representative for task order 25 accepted the
contractor's deliverables without documenting a review of the contractor's
personnel qualifications in comparison with the labor categories invoiced.
	The task order was closed without all deliverables being met.
In the contract we reviewed, the official contract file was incomplete, the
determination and findings document did not properly justify the use of a T&M
contract, a government-surveillance plan was not created, and a contracting
officer's representative improperly authorized the disposal of government
property. There was almost no contract management after the contract was
awarded, and the contracting officer had little involvement with contract
administration and delegated most tasks to the contracting officer's
representatives. Given the lack of oversight, contract administration and
documentation, the EPA cannot verify that the contractor provided qualified staff
for the execution of the contract, which created the risk of the agency not
receiving services for which it paid.
Recommendations and Agency Response
We made eight recommendations to the Assistant Administrator for
Administration and Resources Management to improve, implement or address
agency oversight of contractor personnel, subcontractors, activities and invoices
under T&M contracts; best practices for agency personnel when dealing with
T&M contract administration; and questionable charges and improper disposal of
government property for contract EP-W-07-067. The EPA has agreed with some
recommendations and proposed some acceptable corrective actions. However,
information on actions is incomplete and disagreements remain. Therefore, all
recommendations are unresolved. In its final response to this report, the EPA
must provide additional information, as described in this report, to resolve the
report recommendations.