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*	U.S. Environmental Protection Agency	17-p-0380
JHLrS Office of Inspector General	September 12,2017
—At a Glance
Why We Did This Audit
We conducted an audit of
U.S. Environmental Protection
Agency (EPA) Contract
No. EP-W-14-020, which
procures services in support of
the EPA's Alternative Dispute
Resolution and Public
Involvement activities. The
purpose of this audit was to
determine whether the EPA
receives services and whether
costs are billed in accordance
with contractual and acquisition
In June 2014, the EPA
awarded Contract No. EP-W-
14-020, which is valued at over
$51 million and has a period of
performance of 60 months. The
objective of this contract is to
implement the agency's
Alternative Dispute Resolution
Policy and Public Involvement
Policy. Mediation, facilitation,
outreach, coaching and training
are among the services
procured under this contract.
This report addresses the
• Operating efficiently and
EPA's Alternative Dispute Resolution and Public
Involvement Contract Needs Better Management
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.aov/oia.
Listing of OIG reports.
What We Found
The terms of Contract No. EP-W-14-020 were not
in compliance with the Federal Acquisition
Regulation (FAR) and the EPA Acquisition
Regulation (EPAAR). In addition, some contract
deliverables did not comply with contract
requirements. Specifically, we identified the
following issues during our audit:
The EPA must provide
better assurance that it
effectively receives
services and correctly
pays for billings under
this $51 million contract.
•	Several contract terms were outdated, contradictory and incomplete.
Several required clauses were also missing.
•	The contract did not permit firm-fixed-price task orders.
•	Monthly progress reports, final reports and invoices were missing some
required contract data.
Also, management of Contract No. EP-W-14-020 needs improvement to comply
with contractual and acquisition requirements. Specifically, we found the following
issues during our audit:
•	Four Task Order Contracting Officer's Representatives did not provide written
technical direction, as required by the contract and EPAAR.
•	In one case, the EPA did not report contractor performance evaluation
information in a timely manner, as required by the FAR.
•	The Contracting Officer did not perform invoice reviews in a timely manner,
as required by the EPA Acquisition Guide.
•	The Contracting Officer did not issue the Contracting Officer's Representative
appointment memorandum in a timely manner, as required by the FAR and
the EPA Acquisition Guide.
These issues occurred due to insufficient oversight.
Recommendations and Planned Agency Corrective Actions
The EPA was proactive in responding to our findings throughout our audit
fieldwork. As described in the "Actions Taken" subsections in Chapters 2 and 3,
the agency completed actions to correct a majority of the issues we identified.
Consequently, this report makes only three recommendations to the Assistant
Administrator for Administration and Resources Management and to the General
Counsel. Our recommendations include actions to improve the contract's terms,
deliverables, management, oversight and internal controls. The EPA agreed with
all three recommendations and provided planned corrective actions and
completion dates that meet the intent of the recommendations. As of the
publication of this report, corrective actions are pending for Recommendation 1
and are completed for Recommendations 2 and 3.