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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Financial Management
EPA's Fiscal Years 2015
and 2014 Hazardous Waste
Electronic Manifest System
Fund Financial Statements
Report No. 17-F-0228	May 30, 2017
Industry Systems
Industry Systems
Public
Web Submissions
e-Manifest
Services
States
Web Application

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Report Contributors:	Paul Curtis
Wanda Arlington
Robert L. Smith
Mairim Lopez
Abbreviations
CFR	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
FMFIA Federal Managers' Financial Integrity Act of 1982
OIG	Office of Inspector General
OMB	Office of Management and Budget
Cover photo: From Hazardous Waste e-Manifest System Advisory Board Background
White Paper, January 2017.
Are you aware of fraud, waste or abuse in an
EPA program?
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1200 Pennsylvania Avenue, NW (2431T)
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
Follow us on Twitter @EPAoig
Send us your Project Suggestions

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At a Glance
Why We Did This Review
We performed this audit pursuant
to the Hazardous Waste Electronic
Manifest Establishment Act. The
act requires the U.S.
Environmental Protection Agency
(EPA) to prepare, and the Office of
Inspector General (OIG) to audit,
the Hazardous Waste Electronic
Manifest System Fund financial
statements each year. Our primary
objectives were to determine
whether:
•	The financial statements were
fairly stated in all material
respects.
•	The EPA's internal controls
over financial reporting were in
place.
•	EPA management complied
with applicable laws and
regulations.
The e-Manifest system is being
designed to create a means to
track off-site shipments of
hazardous waste from a
generator's site to the site of the
receipt, and disposition of the
hazardous waste.
This report addresses the
following EPA goal or
cross-agency strategy:
•	Embracing EPA as a high-
performing organization.
EPA's Fiscal Years 2015 and 2014
Hazardous Waste Electronic Manifest
System Fund Financial Statements
Financial Statements Receive an Unmodified Opinion
We rendered an unmodified opinion on the
EPA's fiscal years 2015 and 2014 Hazardous
Waste Electronic Manifest System Fund financial
statements, meaning that the statements were
fairly presented and free of material misstatement.
We found the fund's
financial statements to
be fairly presented and
free of material
misstatements.
We did not identify any matters that we consider to be material weaknesses
or significant deficiencies in the fund.
Noncompliance With Applicable Laws and Regulations
We found that the EPA did not comply with the e-Manifest Act in that, in fiscal
year 2015, the EPA used e-Manifest appropriated funds totaling $22,294 to
cover contract costs unrelated to the e-Manifest project.
Recommendations and Agency Corrective Actions Taken
We recommended that the agency establish controls to ensure that proper
allocations for contract payments are made in the future, and improve
contract oversight. The EPA agreed with our finding and recommendations,
and promptly implemented and completed all corrective actions.
The corrective actions taken by the agency address the intent of our
recommendations and corrected the identified deficiencies.
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
OFFICE OF
INSPECTOR GENERAL
May 30, 2017
MEMORANDUM
SUBJECT: EPA's Fiscal Years 2015 and 2014 Hazardous Waste Electronic Manifest System Fund
Financial Statements
Report No. 17-F-0228
Office of the Chief Financial Officer
Barry Breen, Acting Assistant Administrator
Office of Land and Emergency Management
Donna Vizian, Acting Assistant Administrator
Office of Administration and Resources Management
This is our report on the audit of the U.S. Environmental Protection Agency's (EPA's) Hazardous Waste
Electronic Manifest System Fund financial statements for fiscal years 2015 and 2014, conducted by the
Office of Inspector General (OIG). The project number for this audit was OA-FY16-0122. This report
contains a finding that describes problems the OIG identified and corrective actions the OIG
recommended. 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
Because you took sufficient corrective actions to address the report recommendations, you are not
required to provide a written response to this final report. We consider all recommendations resolved.
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: Paul C. Curtis, Director
Financial Statement Audits

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's Fiscal Years 2015 and 2014
Hazardous Waste Electronic Manifest System
Fund Financial Statements
17-F-0228
Table of C
Inspector General's Report on EPA's Fiscal Years 2015
and 2014 Hazardous Waste Electronic Manifest System
Fund Financial Statements
Report on the Financial Statements		1
Management's Discussion and Analysis		2
Evaluation of Internal Controls		3
Tests of Compliance With Laws and Regulations		4
Prior Audit Coverage		5
Agency Comments and OIG Evaluation		5
Attachments
1	Compliance With Laws and Regulations 		6
EPA Did Not Comply With the e-Manifest Act		7
2	Status of Recommendations and Potential Monetary Benefits		10
Appendices
A For the Fiscal Year Ended September 30, 2015,
and the Period from Inception to September 30, 2014
Hazardous Waste Electronic Manifest System (e-Manifest)
Fund Financial Statements
B Agency Response to Draft Report
C Distribution

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Inspector General's Report on EPA's Fiscal Years
2015 and 2014 Hazardous Waste Electronic
Manifest System Fund Financial Statements
The Administrator
U.S. Environmental Protection Agency
Report on the Financial Statements
We have audited the accompanying financial statements of the U.S. Environmental
Protection Agency's (EPA's) Hazardous Waste Electronic Manifest System Fund
(known as the e-Manifest fund), which comprise the balance sheet for the fiscal
year ended September 30, 2015, and for the period from inception (October 5,
2012) to September 30, 2014, and the related statements of net cost and changes in
net position; the statement of budgetary resources for the years then ended; and the
related notes to the financial statements.
Management's Responsibilities for the Financial Statements
Management is responsible for the preparation and fair presentation of these
financial statements in accordance with accounting principles generally accepted
in the United States of America; this includes the design, implementation and
maintenance of internal controls relevant to the preparation and fair presentation
of financial statements that are free from material misstatement, whether due to
fraud or error.
Auditor's Responsibility
Our responsibility is to express an opinion on these financial statements based
upon our audit. We conducted our audit in accordance with generally accepted
government auditing standards; the standards applicable to financial statements
contained in Government Auditing Standards, issued by the Comptroller General
of the United States; and Office of Management and Budget (OMB) Bulletin
15-02, Audit Requirements for Federal Financial Statements. These standards
require that we plan and perform the audit to obtain reasonable assurance about
whether the financial statements are free of material misstatements.
An audit involves performing procedures to obtain audit evidence about the
amounts and disclosures in the financial statements. The procedures selected
depend on the auditor's judgment, including the assessment of the risks of
material misstatement of the financial statements, whether due to fraud or error. In
making those risk assessments, the audit considers internal control relevant to the
entity's preparation and fair presentation of the financial statements in order to
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design audit procedures that are appropriate in the circumstances. An audit also
includes evaluating the appropriateness of accounting policies used and the
reasonableness of significant accounting estimates made by management, as well
as evaluating the overall presentation of the financial statements.
We believe that the audit evidence we have obtained is sufficient and appropriate
to provide a basis for our audit opinion.
Opinion
In our opinion, the Hazardous Waste Electronic Manifest System Fund financial
statements, including the accompanying notes, present fairly, in all material
respects, the assets, liabilities, net position, net cost, changes in net position and
budgetary resources of the EPA as of September 30, 2015, and for the period from
inception (October 5, 2012) to September 30, 2014, in conformity with
accounting principles generally accepted in the United States of America.
Specific Audit Requirements of the Hazardous Waste Electronic
Manifest Establishment Act
The Hazardous Waste Electronic Manifest Establishment Act (e-Manifest Act)
requires the Office of Inspector General (OIG) to include an analysis of (1) the
fees collected and disbursed, (2) the reasonableness of the fee structure in place,
(3) the level of use of the system by users, and (4) the success to date of the
system in operating on a self-sustaining basis and improving the efficiency of
tracking waste shipments and transmitting waste shipment data. As the fund has
not yet established a fee structure and started use of the system, no such analyses
were performed.
Management's Discussion and Analysis
Our audit was conducted for the purpose of forming an opinion on the financial
statements as a whole. The Management's Discussion and Analysis are presented
for purposes of additional analysis and are not a required part of the basic
financial statements. Such information is the responsibility of management.
We obtained information from the fund's management about its methods for
preparing the Management's Discussion and Analysis, and reviewed this
information for consistency with the financial statements.
We did not identify any material inconsistencies between the information
presented in the fund's financial statements and the information presented in the
Management's Discussion and Analysis.
Our audit was not designed to express an opinion and, accordingly, we do not
express an opinion on the fund's Management's Discussion and Analysis.
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Evaluation of Internal Controls
As defined by OMB, internal control, as it relates to the financial statements, is a
process, effected by the agency's management and other personnel, that is
designed to provide reasonable assurance that the following objectives are met:
•	Reliability of financial reporting—Transactions are properly recorded,
processed and summarized to permit the preparation of the financial
statements in accordance with generally accepted accounting principles,
and assets are safeguarded against loss from unauthorized acquisition, use
or disposition.
•	Compliance with laws, regulations, contracts and grant agreements—
Transactions are executed in accordance with provisions of applicable
laws, including those governing the use of budget authority, regulations,
contracts and grant agreements, noncompliance with which could have a
material effect on the financial statements.
Opinion on Internal Controls. In planning and performing our audit, we
considered the fund's internal controls over financial reporting by obtaining an
understanding of the agency's internal controls, determining whether internal
controls had been placed in operations, assessing control risk, and performing
tests of controls. We did this as a basis for designing our audit procedures for the
purpose of expressing an opinion on the financial statements and to comply with
OMB audit guidance, not to express an opinion on internal control. Accordingly,
we do not express an opinion on internal control over financial reporting, nor on
management's assertion on internal controls included in Management's
Discussion and Analysis. We limited our internal control testing to those controls
necessary to achieve the objectives described in OMB Bulletin No. 15-02,
Audit Requirements for Federal Financial Statements. We did not test all internal
controls relevant to operating objectives as broadly defined by the Federal
Managers' Financial Integrity Act of 1982 (FMFIA), such as those controls
relevant to ensuring efficient operations.
Material Weaknesses and Significant Deficiencies. Our consideration of the
internal controls over financial reporting would not necessarily disclose all
matters in the internal control over financial reporting that might be significant
deficiencies. Under standards issued by the American Institute of Certified Public
Accountants, a significant deficiency is a deficiency, or combination of
deficiencies, that is less severe than a material weakness, yet important enough to
merit attention by those charged with governance. A material weakness is a
deficiency, or combination of deficiencies, such that there is a reasonable
possibility that a material misstatement of the entity's financial statements will
not be prevented, or detected and corrected in a timely manner. Because of
inherent limitations in internal controls, misstatements, losses or noncompliance
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may nevertheless occur and not be detected. We did not note any matters that we
consider to be material weaknesses or significant deficiencies in the fund.
Comparison of EPA's FMFIA Report With Our Evaluation of Internal
Controls
OMB Bulletin No. 15-02, Audit Requirements for Federal Financial Statements,
requires the OIG to compare material weaknesses disclosed during the audit with
those material weaknesses reported in the agency's FMFIA report that relate to
the financial statements, and identify material weaknesses disclosed by the audit
that were not reported in the agency's FMFIA report. For financial statement
audit and financial reporting purposes, OMB defines material weaknesses in
internal control as a deficiency or combination of deficiencies in internal control,
such that there is a reasonable possibility that a material misstatement of the
entity's financial statements will not be prevented, or detected and corrected, on a
timely basis. The agency did not report any material weaknesses impacting the
fund as of September 30, 2015.
Tests of Compliance With Laws and Regulations
EPA management is responsible for complying with laws and regulations
applicable to the agency and the fund. As part of obtaining reasonable assurance
about whether the fund's financial statements are free of material misstatement,
we performed tests of its compliance with certain provisions of laws and
regulations, noncompliance with which could have a direct and material effect on
the determination of financial statement amounts, and certain other laws and
regulations specified in OMB Bulletin No. 15-02, Audit Requirements for Federal
Financial Statements. The OMB guidance requires that we evaluate compliance
with federal financial management system requirements, including the
requirements referred to in the Federal Financial Management Improvement Act
of 1996. We limited our tests of compliance to these provisions and did not test
compliance with all laws and regulations applicable to the EPA's Hazardous
Waste Electronic Manifest System Fund.
Opinion on Compliance With Laws and Regulations
Providing an opinion on compliance with certain provisions of laws and
regulations was not an objective of our audit and, accordingly, we do not express
such an opinion.
We did not identify any noncompliance that would result in a material
misstatement to the audited financial statements. We did notice one
noncompliance with the e-Manifest Act. In fiscal year 2015, the EPA used
e-Manifest appropriated funds totaling $22,294 to cover contract costs unrelated
to the e-Manifest proj ect. According to the e-Manifest Act, the EPA shall take all
necessary measures to ensure that amounts in the e-Manifest fund are used only to
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carry out the goals of establishing, operating, maintaining, upgrading, managing,
supporting and overseeing the e-Manifest system. The EPA did not have adequate
oversight to prevent the inappropriate use of the e-Manifest funds. As a result, the
EPA is not in compliance with the e-Manifest Act. Further details on this
noncompliance are in Attachment 1.
During our previous financial statements audit, we did not report any material
weaknesses, significant matters or recommendations impacting the fund.
The agency agreed with our finding and recommendations. In response to our
recommendations, the agency promptly implemented and completed all corrective
actions. The agency's full written response is in Appendix B.
Prior Audit Coverage
Agency Comments and OIG Evaluation
Paul C. Curtis
Certified Public Accountant
Director, Financial Statement Audits
Office of Inspector General
U.S. Environmental Protection Agency
May 25, 2017
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Attachment 1
Compliance With Laws and Regulations
Table of Contents
1 EPA Did Not Comply With the e-Manifest Act	 7
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1 - EPA Did Not Comply With the e-Manifest Act
In fiscal year 2015, the EPA used e-Manifest appropriated funds totaling $22,294 to cover
contract costs unrelated to the e-Manifest project. According to the Hazardous Waste Electronic
Manifest Establishment Act (e-Manifest Act), at Section 2, Subsection (d)(2)(C), the EPA shall
take all necessary measures to ensure that amounts in the e-Manifest fund are used only to carry
out the goals of establishing, operating, maintaining, upgrading, managing, supporting and
overseeing the e-Manifest system. The EPA did not have adequate oversight to prevent the
inappropriate use of the e-Manifest funds. As a result, the EPA was not in compliance with the
e-Manifest Act.
The Federal Acquisition Regulation, at 48 CFR Section 1.602-l(b), requires contracting officers
to ensure that all requirements of law, executive orders, regulations and all other applicable
procedures have been met. The Federal Acquisition Regulation, at 48 CFR Section 1.602-2(a),
also requires that contracting officers ensure sufficient funds are available for obligation. The
EPA's Comptroller Policy Announcement No. 00-10, "Implementation of 5 CFR, Part 1315 —
Prompt Payment," Section II.B.(4), further requires the project officers to distribute invoice
amounts by account number to assure that costs are charged to the proper appropriation or
funding source.
Various EPA offices have responsibilities in ensuring that the agency complies with the
e-Manifest Act:
•	The Office of Administration and Resources Management is responsible for the EPA's
acquisition activities, including administering contracts. This office's contracting officers
manage the contracts and are responsible for ensuring that there are sufficient funds
available for obligation.
•	The Office of Land and Emergency Management oversees the e-Manifest project, and
assigns related contracts to project officers. This office's project officers certify the
contract invoices for payment, and are responsible for ensuring that costs are allocated to
the proper appropriation.
•	The Office of the Chief Financial Officer provides financial services for the agency and
makes payments to EPA contractors. This office relies on EPA project officers' invoice
allocations to disburse contract payments.
We found that the EPA used e-Manifest appropriated funds totaling $22,294 to cover contract
costs unrelated to the e-Manifest project. In 2012, the EPA awarded a service contract to a
contractor for multiple work assignments funded by different appropriations. In 2014, the EPA
added a work assignment with the purpose of providing support for the e-Manifest rulemaking.
During 2015, the EPA received various invoices for work related to the e-Manifest project, as
well as other work assignments, performed under this contract. The invoices listed all costs by
work assignment, and an Office of Land and Emergency Management project officer distributed
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the invoice amounts by appropriation. The invoiced amounts were paid by the Office of the
Chief Financial Officer from the e-Manifest funds.
During the final months of the performance period for the contract in 2015, certain work
assignments did not have sufficient obligations available to cover the invoiced amounts. The
obligated funds for these work assignments were under other appropriations not related to the
e-Manifest project. However, to certify the invoices for payment, the project officer allocated the
invoiced amounts from these work assignments to the e-Manifest appropriation, because the
e-Manifest appropriation had obligated funds available. The project officer was not aware of the
restrictions over the e-Manifest appropriations. In addition, the Office of Administration and
Resources Management's contracting officer did not ensure that the EPA met the requirements
of the e-Manifest Act, and that there were sufficient funds available for obligation for the various
other work assignments. Therefore, the EPA did not have adequate oversight to prevent the
inappropriate use of the e-Manifest funds.
As discussed above, the EPA expended e-Manifest funds on non-e-Manifest purposes, thus
violating the requirements of the e-Manifest Act. In addition, by not having adequate oversight to
prevent the inappropriate use of funds, the EPA was at risk of exceeding the amount of funds that
were available in another appropriation. We determined that, as of the end of fiscal year 2015,
the money taken from the e-Manifest funds and used for other work assignments was not
returned to the e-Manifest appropriation.
Agency Actions Taken
In response to our position paper issued during the audit, the Office of Land and Emergency
Management, in coordination with the Office of the Chief Financial Officer and the Office of
Administration and Resources Management, promptly took corrective actions and refunded the
e-Manifest fund for all the amounts paid for costs unrelated to the e-Manifest project.
Recommendations
We recommend that the Assistant Administrator for Land and Emergency Management:
1.	Establish controls to make sure the allocations for contract payments are made from the
appropriate funds and the e-Manifest funds are used only for the e-Manifest project.
We recommend that the Assistant Administrator for Administration and Resources Management:
2.	Improve contract oversight to:
•	Verify there are sufficient funds available for the various work assignments so
that costs are paid using the proper appropriations.
•	Be aware of fund restrictions, specifically for the e-Manifest fund.
•	Communicate these matters to the responsible project officer.
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Agency Comments and OIG Evaluation
The agency agreed with our finding and recommendations, and promptly implemented and
completed all planned corrective actions.
The Office of Land and Emergency Management promptly implemented the following corrective
actions:
•	Included reminders, in its monthly financial reports, that e-Manifest appropriated funds
may only be used for e-Manifest-related work without any exceptions; and verbally
reiterates this directive at monthly budget meetings.
•	Issued additional guidance to all Project Officers and Contracting Officer Representatives
at the Office of Resource Conservation and Recovery affirming that e-Manifest funds
may only be used for e-Manifest work.
•	Added "proper invoice processing" as a performance standard to the performance
agreements of all Project Officers and Contracting Officer Representatives at the Office
of Resource Conservation and Recovery.
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Attachment 2
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
Establish controls to make sure the allocations for contract
payments are made from the appropriate funds and the
e-Manifest funds are used only for the e-Manifest project.
Improve contract oversight to:
•	Verify there are sufficient funds available for the various
work assignments so that costs are paid using the proper
appropriations.
•	Be aware of fund restrictions, specifically for the
e-Manifest fund.
•	Communicate these matters to the responsible project
officer.
Assistant Administrator for 12/31 /16
Land and Emergency
Management
Assistant Administrator for 9/30/16
Administration and
Resources Management
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
For the Fiscal Year Ended September 30, 2015, and
the Period from Inception to September 30, 2014
Hazardous Waste Electronic Manifest System (e-Manifest) Fund
Financial Statements
(#)
* protE-0,
Produced by the U.S. Environmental Protection Agency
Office of the Chief Financial Officer
Office of the Controller
EPA's FY 2015 Annual e-Manifest Financial Statements
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TABLE OF CONTENTS
Page
Management's Discussion and Analysis
Introduction	 1
Current EPA RCRA Manifest Program	1
E-Manifest System Planning Activities	1-2
Acquisition Strategy Change	2-3
e-Manifest System Development	3-4
Principal Financial Statements
Financial Statements
Balance Sheet	5
Statement of Net Cost	6
Statement of Changes in Net Position	7
Statement of Budgetary Resources	8
Notes to Financial Statements
Note 1. Summary of Significant Accounting Policy	9-12
Note 2. Fund Balance with Treasury	12
Note 3. Other Assets	12
Note 4. Other Liabilities	12
Note 5. Payroll and Benefits Payable, non-Federal	13
Note 6. Income and Expenses from Other Appropriations	13
Note 7. Reconciliation of Net Cost of Operations to Budget
(Formerly the Statement of Financing)	14
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EPA's FY 2015 Annual e-Manifest Financial Statements

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Management's Discussion and Analysis
Introduction
The Hazardous Waste Electronic Manifest System fund (e-Manifest) was established as a result
of the Hazardous Waste Manifest Establishment Act (Public Law 112-195, October 5, 2012).
The e-Manifest Act requires the United States Environmental Protection Agency ('EPA' or 'the
Agency') to establish and own a hazardous waste electronic manifest program information
technology ('IT') system that will enable electronic manifesting as a means to augment or
replace the use of paper manifests for tracking hazardous waste shipments. The e-Manifest Act
requires that the e-Manifest system:
•	Meets the needs of the user community;
•	Attracts sufficient user participation and service revenues to ensure the viability of the
system (the e-Manifest Act authorizes EPA to collect reasonable user fees); and
•	Decreases the administrative burden on the user community.
Current EPA RCRA Manifest Program
The EPA Office of Land and Emergency Management (OLEM) provides policy, guidance and
direction for the Agency's emergency response and waste programs. The Office of Resource
Conservation and Recovery (ORCR) within OLEM works to protect human health and the
environment by ensuring responsible national management of hazardous and nonhazardous
waste. Working with delegated state waste programs, ORCR implements the 1976 Resource
Conservation and Recovery Act (RCRA), and ensures that the resource conservation, recovery
and waste management goals of RCRA are met. All states with the exception of Iowa and Alaska
have been delegated RCRA authority, meaning that states implement many, if not all, aspects of
RCRA policy.
The manifest program, as implemented by EPA and the states, ensures that hazardous waste
shipments are consistently tracked, and that hazardous wastes in fact arrive at permitted waste
management facilities. The manifest program is based on both RCRA and Department of
Transportation (DOT) hazardous materials law (The Hazardous Materials Transportation Act
(HMTA)). These laws together require uniformity in the content and use of the hazardous waste
manifest form.
e-Manifest System Planning Activities
Discussion of the e-Manifest system itself has taken place over many years; beginning back in
the 1990's when the concept of an electronic manifest system was first taking shape. Further
activities continued over the years to envision the e-Manifest system through various stakeholder
discussions and pilots. For more information on EPA's efforts prior to the passage of the e-
Manifest Act in 2012, Please Visit at http://www.epa.gov/osw/hazard/transportation/manifest/e-
man-pastmeetings.html.
1
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In early calendar year (CY) 2013, EPA conducted various stakeholder requirements meetings to
reengage with the user community. The purpose of these meetings was to build on past e-
Manifest work to determine high level system functional requirements. Following this, a system
alternatives analysis was conducted to look at various system implementation approaches, all
assuming (among other things) a full electronic mobile workflow. The alternatives analysis
recommended that EPA leverage cloud hosting for initial system development and system
launch, and for long-term operations and maintenance (O&M), consider re-negotiating the cloud
contract model or potentially migrate to an on premise hosting model to keep costs down.
Also as a part of the planning work, a system Concept of Operations (CONOPS) was completed
that, at a high level, outlines both what the current manifest process entails for highway and rail
transporters as well as what the future system may look like. The CONOPS document provides a
process and conceptual model for how data will flow from stakeholder to stakeholder and
through the system during the manifest workflow.
The technical architecture for e-Manifest was completed in FY 2015. This architecture includes
the specific components and data flows, as currently defined, to illustrate a technical solution for
the e-Manifest system. In doing so, it defines the specific boundaries of the e-Manifest system
and how the different parts of the system work together to provide the required services based on
current requirements. For example, areas such as system Cross-Media Electronic Reporting
Regulation (CROMERR) integration, paper manifest processing and manifest data quality
assurance (QA) were analyzed as a part of this effort.
As a part of this technical architecture planning work, EPA conducted targeted meetings with
states and industry separately in order to further flesh out current processes as well as
expectations for the above areas. The meetings were more detailed than previous discussions,
and provided critical information to inform system requirements.
The technical architecture work completed in FY 2015 serves as baseline for the current manifest
program and provides very strong foundation for future system buildout. It meets user needs and
provides flexibility for future iterations of the system.
Acquisition Strategy Change
The EPA's system development work is focused on ensuring user needs are met from day one of
national system deployment. To accomplish this, the agency is conducting user-centered design
and development, and is utilizing agile software development methodologies. This approach
embodies continuous improvement through pilots and testing, using iterative processes, and
continued regular engagement with users and stakeholders throughout the process to provide on-
going opportunities for input.
EPA's FY 2015 Annual e-Manifest Financial Statements
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Instead of locking in on one source, the new e-Manifest Program services contract (multi-vendor
indefinite delivery/indefinite quantity (IDIQ)) will utilize a variety of vehicles for the following
segments of the system:
•	Project management including integration services.
•	Paper manifest processing.
•	User help desk and User training.
Quality assurance for manifest data amongst industry, states, and the EPA.
Services to calculate, collect, and support reporting of user fees for paper and electronic
manifest processing.
Support for stakeholder communication, including outreach and meeting support.
Research has shown that using this type of lean start-up methodology, with agile techniques,
lowers the cost of system development by addressing uncertainties promptly, and by ensuring
that the work being completed brings real value to users.
The agency is actively engaged with the U.S. General Services Administration's "18F"
government IT development support group. In September 2015, the EPA completed an initial
system demonstration. The EPA worked with several industry users to complete this initial
system functionality, and is compiling their technical feedback/testing results on how to improve
or better meet their needs.
The agency will continue to work closely with users, adding more functionality in an incremental
manner, evolving to a minimum viable product (MVP), and providing continuous improvement
for the lifetime of the system. By taking this iterative approach the EPA will refine remaining
uncertainties from our architecture planning work in the most cost effective manner.
e-Manifest System Development
As a follow-on to the completed technical and conceptual architecture, e-Manifest embarked on a
pilot to create initial system functionality with the GSA's 18F consulting shop. The 18F support
group provided the IT expertise to create the foundation of e-Manifest and also provided agile
project management support. Specifically, 18F:
•	introduced user-centered design/development, which engages industry/state users in the
early phases of development,
•	created the development platform and hosting environment for e-Manifest
•	leveraged open source technologies (Trello, GitHub, biweekly online meetings
showcasing recent system updates) to allow users and other stakeholders to follow and
participate in system development
EPA's FY 2015 Annual e-Manifest Financial Statements
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Although not as straightforward as standard government IT development projects, this course
correction from traditional lifecycle system development ("waterfall") methodology to agile will
ultimately deliver a better system in a quicker, more value-added method going forward.
e-Manifest began its agile development in FY 2015 and developed a solid plan moving forward.
The agency is committed to keeping Congress informed of our progress in an open fashion:
Conducting biweekly sprint delivery demonstration meetings.
•	Publicly conducting our business on the open source site "Github."
Provided e-Manifest is fully-funded; we will follow this path of milestones to system launch in
spring 2018.
•	September 2015- initial system functionality completed.
•	Spring of 2016 - minimal viable product development.
•	Spring through fall of 2016 - early full scale development.
•	Fall of 2016 through winter of 2018 - rolling iterative releases/testing of system.
•	Calendar year 2018 - national deployment (collecting user fees).
EPA's FY 2015 Annual e-Manifest Financial Statements
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Principal Financial Statements
Financial Statements
Environmental Protection Agency
e-Manifest
Balance Sheet
As of September 30, 2015 and 2014
(Dollars in Thousands)
FY 2015	FY 2014
ASSETS
Intragovernmental:
Fund Balance with Treasury (Note 2)	$ 3,411	$ 1,867
Other (Note 3)		7_		\J_
Total Intragovernmental		3,418		1,884
Total Assets	$ 	3,418	$ 	1,884
LIABILITIES
Intragovernmental:
Accounts Payable and Accrued Liabilities	$ 4	$ 2
Other (Note 4)		12_ 	U
Total Intragovernmental	16	13
Accounts Payable & Accrued Liabilities	109	159
Payroll & Benefits Payable (Note 5)		122 	125
Total Liabilities	$ 247	$ 297
NET POSITION
Unexpended Appropriations $ 3,240 $ 1,656
Cumulative Results of Operations		(69) 	(69)
Total Net Position		3,171 	1,587
Total Liabilities and Net Position	$ 	3,418 $ 	1,884
The accompanying footnotes are an integral part of these financial statements
EPA's FY 2015 Annual e-Manifest Financial Statements
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Environmental Protection Agency
e-Manifest
Statement of Net Cost
For the Periods Ending September 30, 2015 and 2014
(Dollars in Thousands)
COSTS
Gross Costs
Expenses from Other Appropriations (Note 6)
Less:
Earned Revenue
For the Fiscal
Year Ended
September 30,
2015
2,157
From Inception
(October 5,2012)
to September 30,
2014	
2,116
1,786
NET COST OF OPERATIONS
2,157
3,902
The accompanying footnotes are an integral part of these financial statements
EPA's FY 2015 Annual e-Manifest Financial Statements
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Environmental Protection Agency
e-Manifest
Statement of Changes in Net Position
For the Periods Ending September 30, 2015 and 2014
(Dollars in Thousands)

For the Fiscal Year
Ended September
30,2015
From Inception
(October 5,2012) to
September 30,2014
Cumulative Results of Operations:
Net Position - Inception !
S (69) 3

Budgetary Financing Sources:
Appropriations Used
Income from Other Appropriations (Note 6)
2,090
2,018
1,786
Total Budgetary Financing Sources
2,090
3,804
Other Financing Sources (Non-Exchange)
Imputed Financing Sources
66
29
Total Other Financing Sources
Net Cost of Operations
66
(2,157)
29
(3,902)
Net Change
-
(69)
Cumulative Results of Operations !
S (69) 3
> (69)
Unexpended Appropriations:
Net Position - Beginning of Period !
S 1,656 3

Budgetary Financing Sources:
Appropriations Received
Appropriations Used
3,674
(2,090)
3,674
(2,018)
Total Budgetary Financing Sources
1,584
1,656
Total Unexpended Appropriations
3,240
1,656
TOTAL NET POSITION :
S 3,171 3
> 1,587
The accompanying footnotes are an integral part of these financial statements
EPA's FY 2015 Annual e-Manifest Financial Statements
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Environmental Protection Agency
e-Manifest
Statement of Budgetary Resources
For the Periods Ending September 30, 2015 and 2014
(Dollars in Thousands)


For the Fiscal Year
Ended September
30,2015
From Inception
(October 5,2012) to
September 30,2014
BUDGETARY RESOURCES
Unobligated balance, brought forward, October 1: '
Recoveries of prior year unpaid obligations
S
1,013 $
17
-
Unobligated balance from prior year budget authority, net
Appropriations (discretionary and mandatory)

1,030
3,674
3,674
Total Budgetary Resources !
s
4,704 $
3,674
STATUS OF BUDGETARY RESOURCES
Obligations Incurred !
Unobligated Balance, end of year:
Apportioned
Unapportioned
s
1,484 $
3,220
2,661
1,013
Total Unobligated balance, end of period

3,220
1,013
Total Status of Budgetary Resources !
s
4,704 $
3,674
CHANGE IN OBLIGATED BALANCE
Unpaid Obligations:
Unpaid obligations, brought forward, October 1 (gross) !
Obligations incurred, net
Outlays (gross)
Recoveries of prior year unpaid obligations
s
854 $
1,484
(2,130)
(17)
2,661
(1,807)
Unpaid obligations, end of year (gross)

191
854
Memorandum entries:
Obligated balance, start of year 1
&
854 $

Obligated balance, end of year (net) !
s
191 $
854
BUDGET AUTHORITY AND OUTLAYS, NET:



Budget authority, net !
s
3,674 $
3,674
Agency outlays, net !
s
2,130 $
1,807
The accompanying footnotes are an integral part of these financial statements
EPA's FY 2015 Annual e-Manifest Financial Statements
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Environmental Protection Agency
e-Manifest
Notes to Financial Statements
For the Periods Ending September 30, 2015 and 2014
(Dollars in Thousands)
Note 1. Summary of Significant Accounting Policies
A.	Reporting Entity
The U.S. Environmental Protection Agency (EPA or Agency) was created in 1970 by executive
reorganization from various components of other Federal agencies in order to better marshal and
coordinate Federal pollution control efforts. The Agency is generally organized around the
media and substances it regulates — air, water, land, hazardous waste, pesticides and toxic
substances.
The Hazardous Waste Electronic Manifest System Fund (e-Manifest) was authorized by the
establishment of the Hazardous Waste Electronic Manifest System Act. The act mandates that
the Agency, within three years, establish a hazardous waste electronic manifest system that can
be accessed by any user. The act authorized the administrator to impose on users' fees to pay
costs incurred in developing, operating, maintaining, and upgrading the system, including any
costs incurred in collecting and processing data from a paper manifest submitted to the system
after the date on which the system enters operations. For fiscal year 2015, the e-Manifest Fund
was accounted for under Treasury symbol number 6815/174330.
In fiscal year 2013 (October 5, 2012, date of inception), after the enactment of the e-Manifest
Act but prior to the Agency receiving appropriated funding, costs were incurred for the
development of the e-Manifest system. These costs have been captured in the line items
'Expenses from Other Appropriations' on the Statement of Net Cost, and as 'Income from Other
Appropriations' on the Statement of Changes in Net Position, and total $1,786 million for fiscal
year 2013.
B.	Basis of Presentation
These financial statements have been prepared to report the financial position and results of
operations of the EPA for the e-Manifest Fund in accordance with the Chief Financial Officers
Act of 1990 and the Government Management Reform Act of 1994. The reports have been
prepared from the books and records of the EPA in accordance with Office of Management and
Budget (OMB) Circular A-136 Financial Reporting Requirements, and the EPA's accounting
policies which are summarized in this note. These statements are therefore different from the
financial reports also prepared by the EPA pursuant to OMB directives that are used to monitor
EPA's FY 2015 Annual e-Manifest Financial Statements
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and control the EPA's use of budgetary resources. The balances in these reports have been
updated from the EPA consolidated financial statements to reflect the use of FY 2015 cost
factors for calculating imputed costs for Federal civilian benefits programs. These updates
impact the Balance Sheet, Statement of Net Cost, and Statement of Changes in Net Position.
C.	Budgets and Budgetary Accounting
Funding of the e-Manifest Fund will be provided by fees collected from users to offset costs
incurred by the EPA in carrying out these programs. For inception (October 5, 2012) through
fiscal year 2014, funding for the e-Manifest fund was from appropriated funds. EPA did not
collect fees from inception (October 5, 2012) of the fund through FY 2015.
D.	Basis of Accounting
Generally Accepted Accounting Principles (GAAP) for Federal entities is the standard
prescribed by the Federal Accounting Standards Advisory Board (FASAB), which issues
standards for the federal government. The financial statements are prepared in accordance with
GAAP for federal entities.
Transactions are recorded on an accrual accounting basis and a budgetary basis. Under the
accrual method, revenues are recognized when earned and expenses are recognized when a
liability is incurred, without regard to receipt or payment of cash. Budgetary accounting
facilitates compliance with legal constraints and controls over the use of Federal funds.
E.	Revenues and Other Financing Sources
For FY 2015, EPA did not collect any user fees for the e-Manifest fund, as the system is still in
development.
F.	Funds with the Treasury
The e-Manifest Fund did not have any receipts for fiscal year 2015.
(7. Investments in U. S. Government Securities
Investments in U. S. Government securities are maintained by Treasury (Bureau of Fiscal
Services) and are reported at amortized cost net of unamortized discounts. Discounts are
amortized over the term of the investments and reported as interest income. E-Manifest will hold
the investments to maturity, unless needed to finance operations of the fund. No provision is
made for unrealized gains or losses on these securities because, in the majority of cases, they are
held to maturity. Only fees collected will be invested in U.S. Government securities. As of
September 30, 2015 the e-Manifest fund had not collected any fees.
EPA's FY 2015 Annual e-Manifest Financial Statements
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H.	General Property, Plant and Equipment
The e-Manifest fund complies with the provisions of SFFAS No. 6 and 10. E-manifest did not
have any property as of September 30, 2015.
I.	Liabilities
Liabilities represent the amount of monies or other resources that are more likely than not to be
paid by the Agency as the result of an Agency transaction or event that has already occurred and
can be reasonably estimated. However, no liability can be paid by the Agency without an
appropriation or other collections. Liabilities for which an appropriation has not been enacted
are classified as unfunded liabilities, and there is no certainty that the appropriations will be
enacted.
J. Accrued Unfunded Annual Leave
Annual, sick and other leave is expensed as taken during the fiscal year. Sick leave earned but
not taken is not accrued as a liability. Annual leave earned but not taken as of the end of the
fiscal year is accrued as an unfunded liability. Accrued unfunded annual leave is included in the
Balance Sheet as a component of "Payroll and Benefits Payable."
K. Retirement Plan
There are two primary retirement systems for Federal employees. Employees hired prior to
January 1, 1987, may participate in the Civil Service Retirement System (CSRS). On January 1,
1984, the Federal Employees Retirement System (FERS) went into effect, pursuant to Public
Law 99-335. Most employees hired after December 31, 1983, are automatically covered by
FERS and Social Security. Employees hired prior to January 1, 1984, elected to either join FERS
and Social Security or remain in CSRS. A primary feature of FERS is that it offers a savings
plan to which the Agency automatically contributes one percent of pay and matches any
employee contributions up to an additional four percent of pay. The Agency also contributes the
employer's matching share for Social Security.
With the issuance of SFFAS No. 5, "Accounting for Liabilities of the Federal Government,"
accounting and reporting standards were established for liabilities relating to the federal
employee benefit programs (Retirement, Health Benefits, and Life Insurance). SFFAS No. 5
requires that the employing agencies recognize the cost of pensions and other retirement benefits
during their employees' active years of service. SFFAS No. 5 requires that the Office of
Personnel Management (OPM), as administrator of the CSRS and FERS, the Federal Employees
Health Benefits Program, and the Federal Employees Group Life Insurance Program, provide
federal agencies with the actuarial cost factors to compute the liability for each program.
EPA's FY 2015 Annual e-Manifest Financial Statements
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L. Use of Estimates
The preparation of financial statements requires management to make certain estimates and
assumptions that affect the reported amounts of assets and liabilities and the reported amounts of
revenue and expenses during the reporting period. Actual results could differ from those
estimates.
Note 2. Fund Balance with Treasury
FY 2015 FY 2014
Entity Assets	$ 3,411 $ 1,867
Note 3. Other Assets
FY 2015	FY 2014
Other Intragovernmental Assets
Advance to Working Capital Fund	$ 	7_ $ 	T7_
Total $ 7 $	17
Note 4. Other Liabilities
For FY 2015, the Payroll and Benefits Payable, non-Federal, are presented on a separate line of
the Balance Sheet and in a separate footnote (see Note 5).
FY 2015 FY 2014
Other Intragovernmental Liabilities
Covered by Budgetary Resources
Employer Contribution- Payroll	$ 	12_ $ 	11
Total	$	12 $	11
EPA's FY 2015 Annual e-Manifest Financial Statements
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Note 5. Payroll and Benefits Payable, non-Federal

FY 2015
FY 2014
Covered by Budgetary Resources


Accrued Payroll Payable to Employees
$ 35
$ 35
Withholdings Payable
17
19
Thrift Savings Plan Benefits payable
1
2
Total
53
56
Not Covered by Budgetary Resources


Unfunded Annual Leave Liability
69
69
Total
$ 122
$ 125
Note 6. Income and Expenses from Other Appropriations
The Statement of Net Cost reports program costs that include the full costs of the program
outputs and consist of the direct costs and all other costs that can be directly traced, assigned on a
cause and effect basis, or reasonably allocated to program outputs.
The e-Manifest Fund was authorized in 2013 by the Hazardous Waste Electronic Manifest
System Act. The Agency began incurring costs in FY 2013 upon the issuance of the act, but
funding for e-Manifest specific appropriation was not received until FY 2014. The costs incurred
prior to the appropriation have been captured in the tables below:
FY 2014 Expenses from Other Appropriations
Payroll Costs	$ 931
Contracts	855
Total	$ 1,786
Income from Other Appropriations	$ 1,786
Expenses from Other Appropriations	(1.786)
Net Effect	$
EPA's FY 2015 Annual e-Manifest Financial Statements
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Note 7. Reconciliation of Net Cost of Operations to Budget (formerly the Statement of
Financing)
RESOURCES USED TO FINANCE ACTIVITIES:
Budgetary Resources Obligated
Obligations Incurred
Less: Spending Authority from Offsetting Collections and Recoveries
Obligations, Net of Offsetting Collections
Other Resources
Imputed Financing Sources
Income from Other Appropriations
Net Other Resources Used to Finance Activities
Total Resources Used to Finance Activities
For the Fiscal
Year Ended
September 30,
2015
1,484
(17)
1,467
66
66
1,533
From Inception
(October 5,
2012) to
September 30,
2014
2,661
2,661
29
1,786
1,815
4,476
RESOURCES USED TO FINANCE ITEMS
NOT PART OF THE NET COST OF OPERATIONS:
Change in Budgetary Resources Obligated
Total Resources Used to Finance Items Not Part of the Net Cost of
Operations
Total Resources Used to Finance the Net Cost of Operations
624
624
2,157
(643)
(643)
3,833
For the Fiscal
Year Ended
September 30,
2015
COMPONENTS OF THE NET COST OF OPERATIONS THAT Wil l,
NOT REQUIRE OR GENERATE RESOURCES IN THE CURRENT
PERIOD:
Components Requiring or Generating Resources in Future Periods:
Increase in Annual Leave Liability
Total Components of Net Cost of Operations that Require or Generate
Resources in Future Periods
Total Components of Net Cost of Operations That Will Not Require or
Generate Resources in the Current Period
Net Cost of Operations
From Inception
(October 5,
2012) to
September 30,
2014
2,157
	69_
69
	69_
3,902
EPA's FY 2015 Annual e-Manifest Financial Statements
14
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Appendix B
Agency Response to Draft Report

yv i14• ¦ a •;1: r\!v> wTizui.u. prc ••• ton agency
WASHINGTON, D C 20480
tfssfizei?
SUBJECT: Response to LM^je oflnspcctor General Draft Report No. OA-J VI6-0122 ""EPA *«r Fiscal
h'ear.s 2015 and 2014 Hazardous U ,i,ste Electronic Manifest System Fund I maitciai
Statements.."" Dated February 27, 2017 —
Thank you for the opportunity to respond to the issues and recommendations in the subject draft
audit report. The following is a summary of the agency's overall position, along with its position
on each of the report recommendations. For those report recommendations which the agency
agrees, we have provided either high-level intended corrective actions and estimated completion
dates, to the extent we can, or reasons why we are unable to provide a corrective action or
estimated completion date at this time. For those report recommendations which the agency does
not agree, we have explained our position and proposed alternatives to recommendations. Also,
attached are our technical comments.
AGENCY'S OVERALL POSITION:
Overall, the agency concurs with the findings and recommendations of this report.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS:
Agreements
TO:
FROM: IV. -,j A. Bloom, Acting Chief Fmanei
OFee of Lite Chief financial Officer
Nigel Simon, Acting Principal Deputy
Ofike of Land and Kmergenc) Manage
Arthur A. Etkms, Jr.. inspector Genera'
Office of the inspector General
Donna Vi?.:au, Acting Assistant A&ttir
Office of Administration and Resource


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No.
Recommendation
Agency Explanation/Response
Completion Date
Establish controls to make
sure the allocations for
contract payments are made
from the appropriate funds
and the e-Manifest funds are
used only for the e-Manifest
project.
Office of Resource
Conservation and Recovery and
Resources Management Staff, in
the monthly financial reports it
issues to the office, will remind
recipients that M3 money may
only be used for e-Manifest
related work without any
exceptions. RMS will also
restate this directly to the ORCR
Project Officers and Contracting
Officer's during monthly budget
meetings and contract spending
reviews.
ORCR's office director will
issue a memorandum to the
ORCR POs and Contracting
Officer's Representatives
highlighting the importance of
M3 money remaining separate
from all other funding streams.
The memorandum will clearly
state that M3 money is only to
be used on e-Manifest related
work assignments and there are
no exceptions.
The performance standards for
all ORCR POs and CORs will
be amended to include proper
management of M3 money,
which includes: invoicing,
obligating and de-obligating,
and committing and de-
committing M3 funds.	
10/06/2016
11/09/2016
12/31/2016
Improve contract oversight
to:
• Verify there are
sufficient funds
available for the
various work
assignments so that
costs are paid using
The CO sent out an email to the
COR highlighting the
importance of ensuring invoice
payments are accomplished
using the appropriate funds
applicable to the work ordered
and completed. The email also
advised that dedicated funds can
only be used to pay for work
09/14/2016
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the proper
performance associated with


appropriations.
those funds, and that


• Be aware of fund
specifically, M3 funds can only


restrictions,
be used on e-Manifest related


specifically for the
work assignments with no


e-Manifest fund.
exceptions.


• Communicate these



matters to the
The CO and COR worked
09/30/2016

responsible project
together to complete the


officer.
corrective action under the cited
contract: 1) Environmental
Programs and Management
funds were obligated to the
contract for reimbursement of e-
Manifest monies; 2) the invoices
which were inappropriately paid
with e-Manifest funds were
reprocessed for payment with
the appropriate (EPM) funds;
and, 3) reviewed invoices and
ordered work to ensure that the
e-Manifest funds were only used
to pay for costs incurred on the
work assignment related to the
e-Manifest work.

CONTACT INFORMATION
If you have any questions regarding this response, please contact Benita Deane, Management
Integrity and Accountability Branch, Office of the Controller, at 202-564-2079.
Attachment
cc: Howard Osborne
Jeanne Conklin
Meshell Jones-Peeler
Paul Curtis
Wanda Arrington
Mairim Lopez
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Attachment
Technical Comments
Office of Land and Emergency Management Technical Comments:
The Office of Land and Emergency Management considers Recommendation #1 resolved. Also,
it is our opinion that wherever the Report states that OLEM was not in compliance with
applicable laws and regulations, the Report should be revised to state that our office responded
promptly to take corrective actions.
OLEM took the lead in coordinating corrective actions between the Office of the Chief Financial
Officer and Office of Acquisition and Resource Management to repay the funds during the
discovered misuse of M3 funds. In addition, OLEM issued guidance and updated staff
performance standards to ensure the allocations for contract payments are from the appropriate
funds and the e-Manifest funds are only for the e-Manifest project. Specifically, OLEM's prompt
response and corrective actions should be noted in the following sections:
•	At a Glance both with respect to "Noncompliance with Applicable Laws and
Regulation" and "Recommendations and Planned Agency Corrective Actions;"
•	Draft Report Page 5, end of carryover paragraph;
•	Draft Report Page 7 - conclusion of 1st paragraph;
•	Draft Report Page 8 - conclusion of 2nd full paragraph; and
•	Draft Report Page 8 - Agency Action Taken.
•	In addition, the "Agency Action Taken" section should include language detailing
OLEM's issuance of additional guidance to all Office of Resource Conservation and
Recovery management and Project Officers and Contracting Officer's Representatives
affirming that M3 funds may only be used for e-Manifest work. It should also include
OLEM's addition of proper invoice processing as a performance standard to the
performance agreements of all the aforementioned parties. Lastly, it should include
OLEM's reminders, in monthly financial reports it issues, that M3 money may only be
used for e-Manifest related work without any exceptions and its verbal reiteration of this
directive at monthly budget meetings.
OARM Technical Comments:
Although the contracting office is ultimately responsible for all contract administration activities,
specific activities have been delegated to the COR. Accordingly, while both the contracting
officer and COR monitor the funding obligations on the contract, invoice payment is a delegated
activity to the COR, and the COR is responsible for performing the necessary tracking to ensure
sufficient funds are available for invoice payment. In the context of this process, the CO will
continue to work with the COR to ensure adequate tracking mechanisms are in place. Also,
although it is the delegated duty of the COR to review and pay invoices, the CO will continue to
perform random reviews of the Agency's Financial Compass Data Warehouse to ensure the use
of appropriate funds to pay invoices.
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Appendix C
Distribution
The Administrator
Chief of Staff
Chief Financial Officer
Assistant Administrator for Land and Emergency Management
Assistant Administrator for Administration and Resources Management
General Counsel
Agency Audit Foilow-Up Coordinator
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Controller, Office of the Controller, Office of the Chief Financial Officer
Deputy Controller, Office of the Controller, Office of the Chief Financial Officer
Director, Financial Services Division, Office of the Chief Financial Officer
Director, Accounting and Cost Analysis Division, Office of the Chief Financial Officer
Chief, General Ledger Analysis and Reporting Branch, Accounting and Cost Analysis Division,
Office of the Chief Financial Officer
Principal Deputy Assistant Administrator, Office of Land and Emergency Management
Director, Office of Resource Conservation and Recovery, Office of Land and Emergency
Management
Deputy Director, Office of Resource Conservation and Recovery, Office of Land and Emergency
Management
Associate Director, Program Implementation and Information Division, Office of Resource
Conservation and Recovery, Office of Land and Emergency Management
Branch Chief, Permits Branch, Office of Resource Conservation and Recovery, Office of Land
and Emergency Management
Branch Chief, Information Collection and Analysis Branch, Office of Resource Conservation
and Recovery, Office of Land and Emergency Management
Associate Branch Chief, Information Collection and Analysis Branch, Office of Resource
Conservation and Recovery, Office of Land and Emergency Management
Chair, Fee Rule Workgroup, Permits Branch, Office of Resource Conservation and Recovery,
Office of Land and Emergency Management
Deputy Assistant Administrator, Office of Administration and Resources Management
Director, Office of Acquisition Management, Office of Administration and Resources
Management
Director, Office of Resource, Operations and Management, Office of Administration and
Resources Management
Deputy Director, Office of Resource, Operations and Management, Office of Administration and
Resources Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of Acquisition Management, Office of Administration and
Resources Management
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