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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
17-P-0355
August 9, 2017
Why We Did This Audit
The U.S. Environmental
Protection Agency (EPA) Office
of Inspector General (OIG)
received a hotline complaint
alleging mismanagement by
EPA Region 10 of its biweekly
pay cap waiver process.
The OIG initiated an audit to
determine whether Region 10's
process meets federal
requirements and complies with
established agency policies
and procedures. The purpose
of this report is to alert the
agency on issues identified
during our work. The issues
identified pertain not only to
Region 10 but also to EPA
headquarters offices involved
in the waiver process. Audit
work is continuing.
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.
Management Alert: Concerns Over Compliance,
Accountability and Consistency Identified With EPA's
Biweekly Pay Cap Waiver Process
What We Found
The OIG identified concerns over
compliance, accountability and consistency
We identified issues with
,, , ^	documentation of biweekly pay
with EPA Region 10s and headquarters Cap waivers at Region 10, as well
biweekly pay cap waiver process.	as matters that pertained to EPA
headquarters offices. This
EPA Region 10 provided waiver requests management alert is for
for some but not most instances where	consideration by the agency as it
employees exceeded the biweekly pay cap updates policies and procedures,
during fiscal years 2015, 2016 and 2017
(through January 7, 2017). In addition, 11 of 15 requests provided by Region 10
lacked adequate information to determine whether there was an emergency with
a threat to life and property, or whether that work was critical to the mission of the
agency. While all requests were approved by the Region 10 Regional
Administrator as required, only one request was approved by the Region 10
Human Resources Officer as required by EPA policy. This occurred because the
region did not have an internal policy or process in place to address review by
the regional Human Resources Officer, the need for sufficient justification, or the
retention of supporting documents. As a result, the potential exists that Region 10
employees could be overpaid or be paid for work that does not meet the intent of
premium pay requirements in 5 U.S.C. § 5547.
We also identified inconsistencies and a lack of accountability over the
processing of Region 10's waivers within the EPA's Office of Administration and
Resources Management (OARM) and Office of the Chief Financial Officer
(OCFO). Based on interviews with officials and personnel, we learned that there
is no clear line of responsibility to maintain documentation for waiver requests or
to track requests and approvals between the region, OARM and OCFO. Neither
OARM nor OCFO could provide a list of waivers for the period requested or
supporting documentation. Both offices denied responsibility for tracking the
waivers and maintaining the supporting documentation.
The agency is updating the biweekly pay cap waiver policies and procedures. We
are alerting the EPA to these matters for consideration as it drafts these updates.
Due to the potential impact of these matters on the agency's overall biweekly
waiver process, the OIG has expanded the scope of this ongoing audit to include
other regional and headquarters offices.
Agency Response
Listing of OIG reports.
We issued a discussion document on June 22, 2017, for the agency's review. The
OIG considered suggestions provided by Region 10 and OARM and modified the
report accordingly.

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