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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-P-0347
September 2, 2014
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA) Office
of Inspector General (OIG)
conducted an audit evaluating
the Office of Acquisition
Management's (OAM's)
Contract Management
Assessment Program (CMAP).
CMAP is an integral part of
OAM's implementation of the
U.S. Office of Management and
Budget (OMB) Revised
Circular A-123, Management's
Responsibility for Internal
Control. The objectives of our
audit were to answer the
following questions:
1.	Are contracting offices
implementing the CMAP?
2.	Are the assessments
sufficient to identify
weaknesses in internal
controls or systemic
vulnerabilities?
3.	Are follow-up actions
sufficient to ensure that
weaknesses and
vulnerabilities are
corrected?
This report addresses the
following EPA goal or
cross-agency strategy:
• Embracing EPA as a high-
performing organization.
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/2014/
20140902-14-P-0347.pdf
EPA Needs to Improve Contract Management
Assessment Program Implementation to
Mitigate Contracting Vulnerabilities
What We Found
CMAP is an integral part of OAM's implementation of
OMB Revised Circular A-123 requirements. Multiple
factors hinder CMAP implementation, such as
ambiguous guidance, the EPA's organizational
structure, and lack of resources. The contracting
organizations within the EPA are implementing CMAP
to varying degrees. Required submissions were not always submitted timely, and
some annual reports did not contain all of the required elements. Additionally, the
CMAP policy does not incorporate a process to address noncompliance. As a
result, it is questionable whether the CMAP program can be fully and optimally
implemented until the agency makes needed changes.
CMAP will not be fully
and optimally
implemented until the
agency makes needed
changes to improve
implementation.
The EPA follow-up actions in response to peer review findings appear to be
sufficient to ensure that weaknesses and vulnerabilities are corrected. However,
one plan did not provide dates for the completion of planned corrective actions
and OAM does not formally agree to or approve the corrective action plans.
Additionally, quarterly update reports are not always submitted timely. OMB
Revised Circular A-123 states that agency managers are responsible for taking
timely and effective action to correct identified deficiencies. CMAP policy lacks
specificity, which creates confusion and hinders follow-up action implementation.
As a result, corrective actions may take longer than necessary.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Administration and
Resources Management revise the CMAP policy to correct ambiguity and
strengthen accountability, implement organizational changes to provide OAM
with greater authority and oversight over regional contracting organizations, and
evaluate whether the resources allocated to the CMAP are sufficient to ensure
adequate internal controls and effective CMAP implementation. The agency
agreed to take corrective action for all but one of the recommendations. It
disagreed with the recommendation to implement organizational changes.
Noteworthy Achievements
We found that the assessments contracting organizations are required to perform
under the CMAP program are designed to identify weaknesses in internal
controls or systemic vulnerabilities. The CMAP components collectively address
all five Government Accountability Office standards for internal control. If CMAP
is implemented according to its program design, the EPA's internal controls for
contracts management should improve overtime.

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