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^ PRO"^° OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA Needs to Improve
Oversight of Its
Audio Conference Services
Report No. 17-P-0408
September 26, 2017
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Report Contributors:
Michael D. Davis
Gloria Taylor-Upshaw
Alexandra Zapata-Torres
Darryl Mason
Anita Mooney
Abbreviations
EPA
U.S. Environmental Protection Agency
FY
Fiscal Year
GAO
Government Accountability Office
HP AC
Headquarters Personal Audio Conference
OCFO
Office of Chief Financial Officer
OECA
Office of Enforcement and Compliance Assurance
OEI
Office of Environmental Information
OIG
Office of Inspector General
OMB
Office of Management and Budget
VoIPPC
Voice over Internet Protocol Phone Conference
WCF
Working Capital Fund
Cover photos: An EPA-issued desk telephone (left), and an EPA audio conference call
device. (EPA OIG photos)
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* U.S. Environmental Protection Agency 17-p-0408
JHL \ Office of Inspector General September 26, 2017
\
At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), performed this audit to
determine whether EPA
oversight and use of audio
conference line services are an
efficient and economical way to
use taxpayer funds.
The EPA provides multiple
audio conference services.
Reservationless Plus is the
agency's primary audio
conference service. In fiscal
years 2015 and 2016, EPA
offices and regions spent
over $8 million using
Reservationless Plus.
The EPA's Office of
Environmental Information
(OEI) is the administrator of the
agency's audio conference line
services.
This report addresses the
following:
Operating efficiently and
effectively.
EPA Needs to Improve Oversight of Its
Audio Conference Services
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 EPA's internal controls and oversight of its audio
conference services need improvement. Our review
found the following:
The EPA did not establish official policies and
procedures for the efficient use of audio
conference services.
The EPA is unable to
substantiate whether
its audio conference
service usage totaling
$8.4 million was
cost-effective.
The EPA did not effectively monitor service costs and usage, and did not
have documentation readily available to determine whether service cost
estimates were reasonable and accurate.
Two EPA regions and an EPA program office spent over $260,000 to
contract for services already provided by the agency.
This occurred because the EPA was not fully aware of the required controls
needed to mitigate risks, including management roles and responsibilities for
such control activities. In fiscal year 2016, the EPA spent about $1.2 million for
audio conference calls with one to six participants. These costs could have been
avoided by using other less costly conference call services.
Recommendations and Planned Corrective Actions
We recommend that OEI's Assistant Administrator and Chief Information Officer
establish internal controls that include (a) completing an assessment,
(b) implementing policies and procedures that define customer roles and
responsibilities, and (c) providing training on the use of audio conference
services and avenues for potential cost savings. We also recommend that OEI
design and implement internal controls that allow EPA program offices and
regions to monitor audio conference activities. In addition, we recommend that
OEI maintain documentation to support Reservationless Plus usage rate
formulation, approvals and calculations.
We recommend that the EPA's Chief Financial Officer increase customer
awareness about the agency's Working Capital Fund Policy Standard
requirements for mandatory services, and establish controls that require EPA
program offices and regions to comply with the mandatory services requirements.
The agency concurred with all recommendations, but OEI's planned corrective
actions do not meet the intent of Recommendations 1, 2 and 4. These
recommendations are unresolved, and we will work with the agency for
resolution. We consider the planned corrective actions for Recommendation 3
to be acceptable. Recommendation 3 is resolved with corrective actions pending.
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e O
Iwl
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 26, 2017
MEMORANDUM
SUBJECT: EPA Needs to Improve Oversight of Its Audio Conference Services
Report No. 17-P-04C"
FROM:
Arthur A. Elkins Jr.
TO:
Steven Fine, Acting Assistant Administrator and Chief Information Officer
Office of Environmental Information
David Bloom, Acting Chief Financial Officer
Office of the Chief Financial Officer
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY16-0275.
This report contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. 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
The Office of Environmental Information concurred with Recommendations 1, 2 and 4, but the office's
planned corrective actions do not meet the intent of the recommendations. These recommendations are
unresolved. We consider the planned corrective actions for Recommendation 3, addressed to the Chief
Financial Officer, to be acceptable and the recommendation is resolved.
In accordance with EPA Manual 2750, the resolution process begins with the issuance of this report.
Within 30 days, we are requesting that the acting Assistant Administrator for Environmental Information
and Chief Information Officer meet with the OIG's Assistant Inspector General for Audit. If resolution
is still not reached, the Office of Environmental Information is required to complete and submit a
dispute resolution request to the Chief Financial Officer to continue resolution.
If your office provides acceptable corrective action prior to the meeting, 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.
We will post this report to our website at www.epa. gov/oig.
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EPA Needs to Improve Oversight of
Its Audio Conference Services
17-P-0408
Table of Contents
Chapters
1 Introduction 1
Purpose 1
Background 1
Responsible Offices 2
Noteworthy Achievements 3
Scope and Methodology 3
2 EPA Did Not Have Policies and Procedures for Using
Audio Conference Services 5
EPA Is Required to Implement Effective Internal Controls 5
EPA Did Not Implement Control Activities to Mitigate Risks 6
OEI Was Not Fully Aware of the Need for Control Mechanisms 6
EPA Spent Over $1 Million for Audio Conference Service Calls
With Six or Fewer Participants 7
Conclusion 7
Recommendation 8
Agency Comments and OIG Evaluation 8
3 OEI Did Not Implement Controls to Oversee Audio Conference
Service Costs and Usage 10
EPA Is Required to Implement Effective Internal Controls
to Monitor Audio Conference Services 10
OEI Lacks Controls to Monitor Audio Conference Services 11
OEI Relies on EPA Programs and Regions to Monitor the Costs
and Usage of Audio Conference Services 11
EPA Risks Wasting Taxpayer Funds 12
Conclusion 12
Recommendation 13
Agency Comments and OIG Evaluation 13
4 EPA Did Not Follow Its Audio Conference Service
Requirement for Sole-Provider Services 14
EPA Directives Establish the Working Capital Fund as the
Sole Provider of Audio Conference Services 14
Two EPA Regions and an EPA Program Office Procured
Audio Conference Services Outside the Working Capital Fund 15
EPA Increased Its Audio Conference Service Costs 16
Conclusion 16
Recommendation 17
Agency Comments and OIG Evaluation 17
- continued -
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EPA Needs to Improve Oversight of
Its Audio Conference Services
17-P-0408
Chapters
5 OEI Did Not Have Supporting Documentation for
Reservation I ess Plus Service Cost Estimates 18
Federal Standards and EPA Policy Require Management to
Maintain Documentation for Examination 18
EPA Did Not Follow Policy and Maintain Documentation for
Reservationless Plus Service Usage Rate Determinations 18
Conclusion 19
Recommendation 20
Agency Comments and OIG Evaluation 20
Status of Recommendations and Potential Monetary Benefits 21
Appendices
A Agency Response to Draft Report 22
B Distribution 30
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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency (EPA), Office of Inspector General
(OIG), conducted this audit to determine whether the EPA's oversight and use of
audio conference line services are an efficient and economical way to use
taxpayer funds.
Background
The EPA provides multiple audio conference services throughout the agency.
These services are provided through the agency's working capital fund (WCF).
The WCF is a revolving fund authorized by law to finance a cycle of operations in
which the costs for goods or services provided are charged to users. The WCF
operates like a commercial business within the EPA. Customers pay for services
received and generate revenue for the fund. Customers include EPA offices and
other federal agencies. The EPA has used the WCF to finance audio conferencing
services.
Reservationless Plus Conference Service
The Reservationless Plus service is the EPA's primary audio conference service.
Reservationless Plus provides audio conference services to EPA employees 24
hours a day, 7 days a week. The service links multiple meeting participants
through a single telephone conversation. Reservationless Plus also provides basic
and premium operator assistance, as well as international dialing options.
The basic Reservationless Plus service allows employees to host conference calls
for up to 125 participants, and the service is billed to EPA regions and offices
through the WCF based on usage. Reservationless Plus usage is determined by
the number of participants and the length (i.e., minutes) of the conference.
EPA offices and regions spent over $5 million in fiscal year (FY) 2015, and
over $3.4 million in FY 2016, for Reservationless Plus usage and additional
surcharges. The EPA has limited records on the usage of this service.
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Headquarters Personal Audio Conference Service
The Headquarters Personal Audio Conference (HPAC) service offers the ability to
conference up to five participants plus a leader. A total of six people can be on the
conference line, and a call-in number and code are provided to participants. The
HPAC service is an excellent alternative to Reservationless Plus for EPA
headquarters employees. However, HPAC is not available to EPA regions, and
the service has also reached its capacity. Currently, the EPA is not accepting new
account requests for this service. The EPA does not have records to document its
usage of the HPAC service.
Manual Voice over Internet Protocol Phone Conference
As an alternative to the HPAC service, the EPA's Office of
Environmental Information (OEI) provides the Manual
Voice over Internet Protocol Phone Conference (VoIPPC)
through the Enterprise Voice Services initiative, which
migrates old phone services to a Voice over Internet
Protocol. The Enterprise Voice Services initiative unifies
voice services across the EPA as it reduces costs,
standardizes business processes, and provides a more
robust telecommunications platform for employees to use.
The Manual VoIPPC allows employees to manually
conference up to five participants plus a leader at no cost.
A total of six people can be on the conference line while using a desk telephone.
Other Audio Conference Services
Other audio conference services contracted by one EPA program office and two
EPA regions include the following:
1 Source International LLCUsed by the EPA's Office of
Enforcement and Compliance Assurance.
BT Conferencing Video Inc.Used by EPA Region 8.
1 Source International LLCUsed by EPA Region 5.
Responsible Offices
OEI administers and manages the EPA's audio and voice services. As the
administrator of these services, OEI plans, directs and controls service delivery to
WCF customers.
The EPA's Office of the Chief Financial Officer (OCFO) has overall
responsibility for the WCF. The WCF board provides policy, planning and
operations oversight. The board also advises the EPA's Chief Financial Officer
EPA desk telephone.
(EPA 01G photo)
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about the WCF's financial condition. WCF staff provide financial management
oversight of the fund.
Noteworthy Achievements
OEI provides audio conference services to the EPA based on customer
consumption. OEI stated that it has made every effort to reduce costs and provide
exceptional customer service to EPA customers. Audio conference service rates
were reduced from $0,108 per minute/per person/per call in FY 2015 to $0,055
per minute/per person/per call in FY 2017, while overall customer use steadily
increased. OEI stated that the increase in customers contributed to the lowering of
audio conference service rates. OEI also stated that it is conducting a unified
communications study to review all currently available audio and video
conferencing capabilities to eliminate duplication, and to identify the most
efficient path forward to support the EPA's conferencing needs.
Scope and Methodology
We conducted this audit from September 7, 2016, to July 25, 2017, in accordance
with generally accepted government auditing standards issued by the Comptroller
General of the United States. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our audit objective. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objective.
To answer our objective, we reviewed the EPA's audio conference services and
related costs, WCF usage and billings, and EPA oversight activities for FYs 2015
and 2016. We also reviewed the following laws, policies and procedures:
Public Law 97-255, Federal Managers' Financial Integrity Act of1982,
September 8, 1982.
Office of Management and Budget, Circular A-123,Management's
Responsibility for Enterprise Risk Management and Internal Control,
July 15, 2016.
Government Accountability Office, GAO-14-704G, Standards for Internal
Control in the Federal Government, September 2014.
EPA OCFO, Resource Management Directives System No. 2540-14,
Policy Standard, Working Capital Fund, January 8, 2014 ("WCF Policy
Standard").
EPA OCFO, Resource Management Directives System No. 2540-14-P5,
Policy Procedure 5, Working Capital Fund Exit Procedures, January 8,
2014.
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To gain an understanding of audio conference service operations and controls, we
performed the following:
Reviewed EPA background information about audio conference services.
Assessed internal controls related to audio conference service usage.
Reviewed relevant information systems controls.
Interviewed EPA staff responsible for audio conference service billings,
contracts and WCF rates.
Conducted a survey of 90 EPA personnel concerning their use of audio
conference services. The survey randomly included at least two employees
from each EPA program office, and EPA Regions 2, 4, 5, 6 and 8.
Identified any unique or additional audio conference services used by EPA
program offices and regions, and the cost of these services.
Reviewed contract information for audio conference services.
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Chapter 2
EPA Did Not Have Policies and Procedures for
Using Audio Conference Services
The EPA did not establish official policies and procedures to mitigate risks
associated with using audio conference services, such as cost increases and
surcharge services. The Government Accountability Office (GAO) has internal
control policies and standards that require management to implement control
activities through policies and procedures designed to achieve objectives such as
effectiveness and efficiency of operations.
As the administrator of audio conference services, OEI is responsible for
establishing control activities through policies and procedures designed to
mitigate relevant risks associated with using audio conference services. OEI was
not fully aware of the need for controls over audio conference service usage
because OEI did not assess the risks associated with using these services. As a
result, the EPA did not maximize cost-savings opportunities available by
leveraging audio conference service usage, or by using alternative services.
EPA Is Required to Implement Effective Internal Controls
EPA management is responsible for implementing policies and procedures to
mitigate risks. GAO's Standards for Internal Control in the Federal Government,
September 2014, Principle 7, paragraph 7.01, states that "Management should
identify, analyze, and respond to risks related to achieving the defined
objectives." Overview information for the Control Activities section on page 44
states the following:
Control activities are the actions management establishes
through policies and procedures to achieve objectives and
respond to risks in the internal control system, which includes
the entity's information system.
And Principle 12, paragraph 12.03, explains management responsibilities:
Management documents in policies for each unit its
responsibility for an operational process's objectives and
related risks, and control activity design, implementation,
and operating effectiveness.
Principle 12, paragraph 12.03, also states, "Each unit also documents policies in
the appropriate level of detail to allow management to effectively monitor the
control activity." In addition, paragraph 12.04 states, "Management
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communicates to personnel the policies and procedures so that personnel can
implement the control activities for their assigned responsibilities."
EPA Did Not Implement Control Activities to Mitigate Risks
The EPA did not issue official policies and procedures to implement control
activities to address the relevant risks associated with using audio conference
services, such as increased costs. OEI did not create a policy or procedure that
required offices and regions to adhere to opportunities for audio conference
service cost savings by using various audio conference systems, or alternative
services such as the HP AC service and the Manual VoIPPC.
OEI also did not develop training to educate employees on how to efficiently use
audio conference services to reduce costs. In August 2014, staff from the WCF
issued the service evaluation report titled Audio and Web Conferencing. The
evaluation reported the following:
WCF audio conference service users were dissatisfied with the
service costs and considered the service expensive.
EPA employees need to be educated about the ways to reduce
audio conference service costs.
EPA should consider other contracting sources for its
Reservationless Plus audio conference service contract.
We conducted a survey of 90 agency staff to learn about audio conference
services used throughout the EPA. We received 27 responses, which resulted
in a 30-percent response rate to our survey. Of the 27 survey respondents, 11
expressed concerns about high costs, other services being available at a lower
cost, and employees generally not being aware of Reservationless Plus service
costs.
OEI Was Not Fully Aware of the Need for Control Mechanisms
As the administrator of the agency's audio conference services, OEI is responsible
for establishing control activities through policies and procedures designed to
mitigate relevant risks associated with using audio conference services. OEI was
not fully aware of the need for controls over audio conference service usage
because it did not assess the risks associated with this usage. The WCF evaluation
report and OEI's 2014 article addressed the need to reduce costs and educate
agency staff on audio conference services. However, OEI did not implement
controls to mitigate the risks associated with audio conference service usage costs,
such as establishing policies that address roles and responsibilities for customer
program offices and regions, and informing users about ways to reduce costs.
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EPA Spent Over $1 Million for Audio Conference Service Calls With
Six or Fewer Participants
Using 12 months of call data, OEI analyzed
audio conference calls with six or fewer
participants in EPA program offices, and
estimated potential Reservationless Plus
cost savings of about $1.8 million. Although
OEI provided this information on its website,
it does not have a policy or procedure that
encourages staff to use lower-cost audio services.
Figure 1: EPA spent over $1 million
for audio conference service calls
with six or fewer participants
Over $1 million spent
We found that in FY 2016, the EPA spent
about $1.2 million on audio conference calls
with six or fewer participants. Audio conference
users are not aware of the potential areas to
reduce costs and need training on using audio
conference services. Adequate control
mechanisms are needed to help reduce audio
conference service costs and maximize
Reservationless Plus services.
Source: EPA OIG-generated figure.
Conclusion
The EPA did not issue official policies and procedures to implement control
activities to address relevant risks associated with using audio conference
services, such as increased costs. As the administrator of audio conference
services, OEI was not aware of its responsibility to establish adequate
mechanisms over audio conference service usage.
As a result, cost-saving opportunities were not maximized to leverage audio
conference service usage or alternative services. Audio conference users also
are not aware of the potential areas to reduce costs. OEI should establish control
activities to assess the risks associated with using audio conference services,
define customer roles and responsibilities for using audio conference services,
and provide training to audio conference users about the services and avenues for
potential cost savings.
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Recommendation
We recommend that the Assistant Administrator for Environmental Information
and Chief Information Officer:
1. Establish the following internal controls:
a. Complete an assessment of risks associated with using audio
conference services.
b. Implement policies and procedures that define customer roles and
responsibilities for using audio conference services.
c. Provide training on the use of audio conference services and
avenues for potential cost savings.
Agency Comments and OIG Evaluation
The agency agreed with our recommendation. For recommendation la, OEI
stated that it has assessed risks with the Reservationless Plus service and made
significant efforts to control the costs of the service, but EPA offices that use the
service must also consider risks and costs. OEI also stated that sufficient service
information, reports and reviews are available to individual offices to make
informed decision on service consumption levels within their respective resource
constraints. OEI noted that it has been exploring opportunities to further reduce
costs and is promoting Skype as a lower-cost replacement for Reservationless
Plus. OEI plans to promote the transition through an outreach campaign during
FY 2018. OEI provided an estimated completion date of September 30, 2018, for
this part of the recommendation.
We agree with OEI's response to Recommendation la. However, OEI did not
provide its assessment of the risks associated with using audio conference
services.
For Recommendation lb, OEI stated that this part of the recommendation is
complete because OEI considers the policies and procedures and customer roles
and responsibilities to be well-defined already. OEI also stated that the Working
Capital Fund Policy Standard outlines policy for audio conference services. OEI
went on to state that it provides agency staff with information on these services
through various links on the EPA's intranet, periodic training sessions, and
through OEI's eBusiness application.1
1 eBusiness is a web application where users establish accounts, shop for WCF products and services via an online
catalog, obtain products and services, and monitor usage. Activity Managers and Service/Product Managers are able
to provide and charge-back for products and services via automated registration, usage submission and verification,
billing and reporting features.
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Although OEI agreed with the Recommendation lb, its response does not meet
the intent of our recommendation. The Working Capital Fund Policy Standard is
an OCFO policy. Training links on the EPA's intranet provide access instructions
on how to get a Reservationless Plus account, how to use the service, sign-on to
calls, and the costs related to using the audio conference line services. As the
manager of the EPA's audio conference services, OEI has not established its own
policies and procedures that explain OEI's roles as the manager of the mandatory
audio conference services, as well as customer roles associated with monitoring
costs and using the most cost-effective audio service. OEI should establish and
implement policies and procedures that explain these controls.
For Recommendation lc, OEI stated that the EPA's intranet provides training
via several links, guides and artifacts showing the user how to use the various
services and what they cost. OEI also stated that during FY 2018, it plans to
do additional training and outreach to promote the use of Skype for audio
conferencing. OEI provided an estimated completion date of September 30, 2018,
for this part of the recommendation.
Although OEI agreed with Recommendation lc, its response does not meet the
intent of our recommendation. OEI directed us to several agency links that
included the EPA's intranet, EPA Region 5's intranet, and two Office of Research
and Development intranets. We agree that agency links would provide training
on audio conference services. However, OEI should establish agencywide
training to address avenues for potential cost savings, direct agency staff to the
various links provided, and the usage of Skype for audio conferencing planned for
FY 2018.
We consider Recommendation 1 unresolved, and we will work with the agency
for resolution.
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Chapter 3
OEI Did Not Implement Controls to Oversee
Audio Conference Service Costs and Usage
As the administrator of audio conference services, OEI plans, directs and controls
service delivery to WCF customers. OEI did not implement controls that require
audio conference service costs and usage to be effectively monitored. OEI also
was not aware of contractor costs for the HP AC service.
Federal laws and standards require management to establish internal controls to
provide reasonable assurance that resources are safeguarded against fraud, waste
and abuse. OEI stated that it relies on EPA program offices and regions to
monitor audio conference service usage. OEI also believed that there was no cost
for the HP AC service. The EPA is unable to determine whether audio conference
service usage totaling over $8.4 million for FYs 2015 and 2016 was a cost-
effective use of taxpayer funds, and whether the funds were used for authorized
purposes. The EPA is at risk of misusing taxpayer funds for services other than
Reservationless Plus, because the agency has no documentation to support the
monitoring, costs and usage of the HP AC service.
EPA Is Required to Implement Effective Internal Controls to Monitor
Audio Conference Services
The EPA did not implement controls that require audio conference service costs
and usage to be effectively monitored. The Federal Managers' Financial Integrity
Act of 1982 requires federal agencies to establish internal accounting and
administrative controls to provide reasonable assurances that property and other
assets are safeguarded against waste and unauthorized use. OEI controls are
needed to require program offices and regions to monitor audio conference
services. GAO's Standards for Internal Control in the Federal Government,
Principle 16, paragraph 16.04, states that "Ongoing monitoring is built into the
entity's operations, performed continually, and responsive to change." Also,
paragraph 16.05 states the following:
Management performs ongoing monitoring of the design
and operating effectiveness of the internal control system
as part of the normal course of operations. Ongoing
monitoring includes regular management and supervisory
activities, comparisons, reconciliations, and other routine
actions.
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OEI Lacks Controls to Monitor Audio Conference Services
OEI did not implement controls to require program offices and regions to monitor
Reservationless Plus costs and usage. OEI stated that it relies on EPA program
offices and regions to monitor audio conference service usage. EPA program
offices and regions spent $8,464,646 in FYs 2015 and 2016 for Reservationless
Plus audio conference services. This total amount includes $15,752 spent for
weekend audio conference calls. Figure 2 below shows EPA program offices' and
regions' expenditures in FYs 2015 and 2016 for Reservationless Plus audio
conference services.
Figure 2: EPA expenses for Reservationless Plus usage and for weekend calls
Total spent for
Reservationless Plus
audio conference service usage
$3.4
million
/
2015
$5 million
Amount spent
for weekend calls
Source: OIG analysis of FY 2015 and FY 2016 EPA expenses for Reservationless Plus.
OEI also does not know the contract cost for the design and implementation of the
HP AC service, which was implemented to reduce the costs of Reservationless
Plus. OEI said that the HP AC service was acquired through modifications of
existing contracts for audio conferencing and telephone services. OEI could not
identify the actual cost for the HP AC service, and did not have documentation to
support contract modifications for the design and implementation of the service.
OEI believes that the HP AC service is available at no cost to the agency.
However, OEI's contractor provided a spreadsheet to us containing HP AC service
usage data, which shows the service is billed to EPA program offices through the
WCF voice service at a rate per minute. Billings for FYs 2015 and 2016 totaled
$66,191 for usage of the HPAC toll-free service line.
OEI Relies on EPA Programs and Regions to Monitor the Costs and
Usage of Audio Conference Services
OEI stated that managers in all EPA offices and regions should monitor the use
and related costs of audio conference services. We concluded that OEI does not
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believe it is their office's responsibility to verify EPA program offices and regions
are monitoring audio conference activities to prevent unauthorized use and waste.
In accordance with the EPA's WCF Policy Standard, Exhibit 1, most WCF
services are in data processing activity, which is managed by OEI. Data
processing activity includes audio conference and voice services. OEI is the
administrator of the Reservationless Plus audio conference service, and voice
services that include the HP AC service and the Manual VoIPPC system within the
data processing activity.
OEI has not developed mechanisms to effectively capture HP AC service costs
and usage. OEI believes that it did not incur costs for the acquisition of the HP AC
service. However, OEI's contractor stated that OEI did not require them to
separately track and account for design costs and implementation of the HP AC
service.
EPA Risks Wasting Taxpayer Funds
The EPA is unable to assess whether conference call services totaling over
$8.4 million was an economical use of taxpayer funds. Also, without controls to
effectively monitor audio conference service costs and usage by program offices
and regions, the EPA is unable to assess whether funds were used for authorized
purposes. The EPA is at risk of wasting taxpayer funds for the HP AC service
because OEI did not monitor the costs or usage of the service.
Conclusion
As the administrator of audio conference services, OEI did not implement
controls to require EPA program offices and regions to monitor Reservationless
Plus costs and usage. OEI also has not developed controls to effectively capture
HP AC service costs and usage. EPA program offices and regions are unable to
assess whether usage costs totaling over $8.4 million for FYs 2015 and 2016 were
an economical use of taxpayer funds, and whether funds were used for authorized
purposes. The EPA should design and implement controls that require program
offices and regions to (1) effectively monitor audio conference service usage, and
(2) track and account for costs. The EPA also would reduce the risk of abuse and
waste related to audio conference services by designing and implementing control
mechanisms for effective monitoring.
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Recommendation
We recommend that the Assistant Administrator for Environmental Information
and Chief Information Officer:
2. Design and implement internal controls that allow EPA program offices
and regions to monitor audio conference activities to prevent unauthorized
use and waste.
Agency Comments and OIG Evaluation
The agency agreed with Recommendation 2. OEI stated that this recommendation
is complete, and that the necessary controls exist to allow EPA program offices
and regions to monitor audio conference service activities. OEI stated that its
eBusiness application contains all current and historical consumption data for
EPA headquarters and regional offices. OEI also stated that EPA offices using
audio conferencing services currently have the tools to routinely monitor their
billed usage of all WCF services. In addition to using OEI's eBusiness
application, customers also receive a Conference Summary Report with
pertinent conference information.
Although OEI agreed with Recommendation 2, its response does not meet the
intent of our recommendation. As the manager of the EPA's audio conference
services, OEI has not designed and implemented controls, such as a reporting
process or procedures for using the tools that would require EPA program and
regional offices to use OEI tools to routinely monitor the usage of audio
conference services. Although there may be legitimate reasons for Reservationless
Plus calls with six or fewer participants, with no established requirements to use
lower-cost services, the potential for waste and unauthorized use continue to exist.
We consider this recommendation unresolved, and we will work with the agency
for resolution.
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Chapter 4
EPA Did Not Follow Its Audio Conference Service
Requirement for Sole-Provider Services
EPA Regions 5 and 8, and the agency's Office of Enforcement and Compliance
Assurance (OECA), duplicated sole-provider audio conference services by
spending over $260,000 to contract for similar services. However, the EPA's
WCF Policy Standard states that sole-provider services must be ordered through
the WCF. In addition, the EPA's guidance for WCF service agreements lists audio
conference services as a sole-provider service.
WCF staff stated that they do not know how to determine whether WCF
customers are using audio conference services outside the WCF. EPA
organizations misused over $260,000 of taxpayer funds to acquire audio
conference services and did not realize expected cost savings from the WCF
because the agency did not follow its own financial policy standard.
EPA Directives Establish the Working Capital Fund as the
Sole Provider of Audio Conference Services
The EPA's WCF Policy Standard describes WCF service categories and
requirements by service types, such as "Sole Provider," "Preferred Provider" and
"Discretionary." For FYs 2015 and 2016, the EPA's audio conference service was
listed as a sole-provider service. The directive states the following about sole-
provider services:
EPA internal customers must order these services through
the WCF and cannot use an outside provider. No requests for a
WCF departure waiver to procure any of these services from an
alternative service provider will be considered. Examples include
services provided by the Postage, Financial Management, and
Employee Relocation Activities, as well as email, desktop, and
computer security.
According to the WCF Policy Standard, Part II, the EPA can save costs by
consolidating WCF services. The policy mentions the following benefits:
Cost savings achieved through agencywide enterprise solutions.
The WCF provides services on a consolidated basis across the
agency. This is more cost effective than each office buying the
service individually.
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Improved customer awareness of costs and management of
service consumption. Customers are informed of the cost
associated with each service and receive monthly bills
providing utilization, thus enabling them to make informed
decisions on consumption levels necessary for their office
and related costs.
Two EPA Regions and an EPA Program Office Procured
Audio Conference Services Outside the Working Capital Fund
EPA Regions 5 and 8, and the OECA program office, contracted audio conference
services from providers outside the WCF. Staff from the WCF became aware of
the audio conference services for Regions 5 and 8 at a WCF board meeting. At
that meeting, regional representatives explained that the services they acquired
were at a lower cost than the WCF-provided Reservationless Plus audio
conference service. WCF staff asked the EPA's Office of the Chief Financial
Officer, Business Analysis Branch, to evaluate both regions' audio conference
services. However, WCF staff were unable to determine the total costs of these
services because the staff could not obtain data about regional overhead costs.
WCF staff stated they informed board representatives from EPA Regions 5 and 8
that the use of the Reservationless Plus service is mandatory for regions.
We conducted a survey of 90 EPA staff, and from the 27 respondents we learned
about the different audio conference services throughout the agency. Survey
participants from EPA Regions 5 and 8 responded that they requested a waiver to
procure audio conference services outside the WCF. However, the regions
requested the waivers through regional management; not directly through WCF
staff. Region 5 stated that beginning in FY 2011, the region was experiencing
severe budget constraints. Region 5 identified the regional audio conference
service costs obtained through the WCF as an area for potential operating cost
reductions, because the region's market research showed a substantial gap
between the Reservationless Plus service and open-market rates. Region 8 stated
that it was unaware that Reservationless Plus was a mandatory service.
The EPA's WCF Policy Standard states that the agency will not consider requests
for a WCF departure waiver to procure any audio conference services from an
alternative service provider. WCF staff stated in interviews that they are not
aware of any requests to depart from using WCF audio conference services.
The active contract spreadsheet that we obtained from the EPA's Office of
Acquisition Management's intranet website included contract data as of
February 26, 2016. Using the spreadsheet, we identified three audio conference
service contracts for Regions 5 and 8, and OECA. Further, we reviewed the
EPA's financial system and identified $264,984 in audio conference service
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expenses from FY 2015 through FY 2016. Specifically, the financial data and
contracting information we reviewed showed the following:
October 14, 2014, through September 29,2016OECA spent a total of
$59,926 for an audio conference service contract with 1 Source
International LLC. This contract ended July 30, 2016.
October 6, 2014, through August 29, 2016EPA Region 5 spent a total
of $139,094 for an audio conference service contract with 1 Source
International LLC. This contract has funds available until FY 2018 in the
EPA's financial system. However, Region 5 stated it returned to using
WCF services in March 2017.
February 11,2015, through September 29, 2016EPA Region 8
spent a total of $65,964 for an audio conference service contract with
BT Conferencing Video Inc. This contract has funds available through
FY 2017.
WCF staff explained that they rely on WCF board representatives and service
managers to inform customers about requirements for sole-provider services.
WCF staff stated that they could not determine which customers use or do not use
sole-provider services. WCF control mechanisms are needed to increase customer
awareness of WCF requirements found in the EPA's WCF Policy Standard, and
requirements that mandate customers comply with the directive.
EPA Increased Its Audio Conference Service Costs
The EPA was inefficient in its use of taxpayer funds for audio conference
services, because two EPA regions and a program office did not follow the
agency financial policy. When WCF customers procure services outside the fund,
expected cost savings are not achieved through the services provided on a
consolidated basis across the agency. According to the EPA's WCF Policy
Standard, this agencywide enterprise solution is more cost-effective than each
office buying the service individually. When controls that enforce WCF
requirements are not implemented, the EPA is at risk of increased inefficiencies
related to the use of audio conference services.
Conclusion
EPA Regions 5 and 8, and the OECA program office, duplicated audio conference
services by spending over $260,000 in contract services outside the WCF.
Services were duplicated because Region 5 identified the service as an area for
potential operating cost reduction, and Region 8 was unaware that Reservationless
Plus was a mandatory service.
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The EPA was inefficient in its use of taxpayer funds for audio conference
services. EPA program offices and regions that procure WCF mandatory services
outside the fund increase the agency's risk of wasting taxpayer funds and hinder
the EPA's ability to achieve expected cost savings from the WCF. The EPA
should increase customer awareness and establish controls for agency program
offices and regions to comply with policies and procedures for the efficiency of
operations.
Recommendation
We recommend that the Chief Financial Officer:
3. Increase the EPA's internal customer awareness of the Working Capital
Fund Policy Standard's mandatory services requirements, and establish
controls that require EPA program offices and regions to comply with the
requirements.
Agency Comments and OIG Evaluation
The agency agreed with our recommendation and provided corrective actions with
completion dates.
For Recommendation 3, OCFO stated that it will prepare an annual memorandum
to be distributed to the WCF board. The memorandum will outline all sole
provider, preferred provider and discretionary services provided by the WCF. In
addition, OCFO stated that it will prepare a memorandum for distribution to the
Office of Administration and Resources Management's Office of Acquisition
Management. The memorandum will serve as notification for the Office of
Acquisition Management not to award contracts or task orders related to WCF
sole-provider services. These services must be purchased through the WCF, and a
waiver cannot be requested to purchase services from an outside vendor.
OCFO estimated that the completion date for Recommendation 3 is December31,
2017.
We consider the agency's planned corrective actions for this recommendation to
be acceptable. The recommendation is resolved with corrective actions pending.
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Chapter 5
OEI Did Not Have Supporting Documentation for
Reservationless Plus Service Cost Estimates
The EPA did not have supporting documentation for Reservationless Plus audio
conference service cost estimates and billing rate calculations. The EPA's WCF
Policy Standard requires WCF service providers, customers, financial and other
support staff to maintain records at the transaction level to, "Provide clear audit
trails of financial transactions that include all materials created in support of a
financial transaction."
OEI did not maintain records relating to communications that involve the
calculations and approvals of rates. As a result, the EPA cannot effectively
monitor Reservationless Plus service usage rates, and the agency is at an
increased risk of wasting resources and incorrectly billing its WCF customers.
Federal Standards and EPA Policy Require Management to Maintain
Documentation for Examination
GAO's Standards for Internal Control in the Federal Government, Principle
10.03, requires appropriate documentation of transactions and internal control.
Further, the WCF Policy Standard, Part II, Section D, states the following:
The EPA will maintain records at the transaction level that:
1. Provide clear audit trails of financial transactions that
include all materials created in support of a financial
transaction or event.
2. Include disclosure of events or circumstances that
affect a user's interpretation.
In addition, Exhibit 3 in Section Id of the WCF Policy Standard states the
following:
During the planning phase of the WCF Business Cycle, WCF
Activities compute a proposed service rate, using estimated
costs and workload data, for each of the services and products
to be offered during the upcoming fiscal year.
EPA Did Not Follow Policy and Maintain Documentation for
Reservationless Plus Service Usage Rate Determinations
The EPA did not have supporting documentation for the Reservationless Plus
audio conference service cost estimates and billing rate calculations. OEI staff
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responsible for the Reservationless Plus usage rate calculations provided us with a
table of estimated costs and expected Reservationless Plus minutes for FYs 2015
and 2016. However, OEI did not have documentation to support the basis for the
detailed costs listed in the tables, and how the estimates related to the acquisition
and delivery of service.
OEI staff explained that they do not follow a standard procedure for calculating
Reservationless Plus cost estimates, and they provided documentation that only
lists cost estimates and the expected Reservationless Plus usage of minutes. OEI
staff stated that they do not follow a standard procedure for documenting the
WCF's Reservationless Plus usage rate calculation. However, the EPA's WCF
Policy Standard outlines a rate formulation and approval process, and requires the
agency to maintain documentation that provides clear audit trails of financial
transactions that include all materials created in support of a financial transaction
or event.
OEI staff explained that the former Reservationless Plus audio conference service
manager left the EPA; therefore, no one was available to provide details about the
Reservationless Plus cost estimates used in FYs 2015 and 2016 for WCF usage
billing rate calculations. OEI staff stated that communications related to the
calculations and approvals of usage billing rates mainly occur via telephone.
OEI does not have records of such communications.
Further, OEI was unable to document that Reservationless Plus service usage
billing rate determinations are reliable and accurate for recovering full service
costs. The EPA is at an increased risk of wasting resources and incorrectly billing
its WCF customers, because OEI does not have supporting documentation for
Reservationless Plus service costs and estimates.
Conclusion
The EPA should maintain documentation and records of Reservationless Plus
audio conference service cost estimates and WCF billing rate determinations to
effectively monitor costs and establish rates that are accurate and reasonable.
Billing rates are intended to recover the full cost of acquiring and delivering the
service to program offices and regions. Maintaining detailed records of the costs
involved with providing the service is necessary to establish a WCF billing rate
that is not significantly overstated or understated.
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Recommendation
We recommend that the Assistant Administrator for Environmental Information
and Chief Information Officer:
4. Maintain documentation to support Reservationless Plus usage rate
formulation, approvals and calculations.
Agency Comments and OIG Evaluation
The agency agreed with our recommendation. For Recommendation 4, OEI
stated this recommendation is complete, and the process is well-documented.
The service rate is developed as part of the detailed budget formulation process
overseen by the OCFO's WCF staff. OEI also stated that sufficient documentation
exists to support the rate formulation and approvals. In addition, OEI provided the
FY 2016 WCF Financial Statements and Independent Auditor's Report, and
stated that it further shows that WCF processes are acceptable.
Although OEI agreed with Recommendation 4, its response does not meet the
intent of our recommendation. While OEI stated it has completed this
recommendation, OEI did not provide approval documentation to support the
process. OEI should follow the EPA's WCF Policy Standard and maintain
approval documentation so that there is an audit trail of its decisions, approvals
and formulation process.
We consider this recommendation unresolved, and we will work with the agency
for resolution.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Potential
Monetary
Rec.
Page
Planned
Benefits
No.
No.
Subject
Status1
Action Official
Completion Date
(in $000s)
1
8
Establish the following internal controls:
a. Complete an assessment of risks associated with using
audio conference services.
b. Implement policies and procedures that define customer
roles and responsibilities for using audio conference
services.
c. Provide training on the use of audio conference services
and avenues for potential cost savings.
U
Assistant Administrator
for Environmental
Information and Chief
Information Officer
$8,465
2
13
Design and implement internal controls that allow EPA program
offices and regions to monitor audio conference activities to
prevent unauthorized use and waste.
U
Assistant Administrator
for Environmental
Information and Chief
Information Officer
$66
3
17
Increase the EPA's internal customer awareness of the Working
Capital Fund Policy Standard's mandatory services
requirements, and establish controls that require EPA program
offices and regions to comply with the requirements.
R
Chief Financial Officer
12/30/17
$264
4
20
Maintain documentation to support Reseivationless Plus usage
rate formulation, approvals and calculations.
U
Assistant Administrator
for Environmental
Information and Chief
Information Officer
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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o
12IS/
Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
August 29, 2017
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Audit Report No. OA-FY16-0275
"EPA Needs to Improve Oversight of Its Audio Conference Servicesdated July
25, 2017
FROM: David A. Bloom, Acting Chief Financial Officer
Office of the Chief Financial Officer
Steven Fine, Acting Assistant Administrator and Chief Information Officer
Office of Environmental Information
TO: Kevin Christensen, Assistant Inspector General
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject draft
audit report. Following is a summary of the U.S. Environmental Protection Agency's overall
position, along with its position on each of the draft report recommendations. We have provided
high-level intended corrective actions and estimated completion dates to the extent we can.
AGENCY'S OVERALL POSITION:
The agency concurs with all of the recommendations.
AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATIONS:
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
by Quarter and FY
1
Establish the following
internal controls:
Complete an assessment
of risks associated with
using audio conference
services.
The Office of
Environmental Information
has assessed risks with the
service and made significant
4th Quarter FY 2018
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Implement policies and
procedures that define
customer roles and
responsibilities for using
audio conference
services.
Provide training on the
use of audio conference
services and avenues for
potential cost savings.
efforts to control costs of the
service, but offices that use
the service must also
consider risks and costs.
Sufficient service
information, reports and
reviews are available to
individual offices to make
informed decision on service
consumption levels within
their respective resource
constraints. The OEI has
been exploring opportunities
to further reduce costs and is
exploring promoting Skype
as a lower cost replacement
for ReservationlessPlus, and
plans to promote the
transition to Skype through
an adoption outreach
campaign during FY 2018.
The OEI considers the
policies and procedures and
customer roles and
responsibilities to be well
defined already. The
Working Capital Fund
Policy Standard outlines
policy for these services,
and the OEI informs agency
staff with information on
these services through the
various links on the intranet,
and through periodic
training sessions and the
eBusiness application.
Please see link in "Training
Related Links" section
below.
The EPA's intranet provides
training via several links,
guides and artifacts showing
the user how to use the
various services and what
Completed
4th Quarter FY 2018
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they cost. The OEI has made
this form of training
available along with
additional means to inquire
about the services and how
they work. The links
provided in the "Training
Related Links" section fully
covers the functions of the
services provided. For those
users that would like to
request additional
information, there are
contact numbers provided
for their convenience.
During FY 2018, the OEI
plans to do additional
training and outreach to
promote adoption of the use
of Skype for audio
conferencing.
2
Design and implement
internal controls that allow
EPA program offices and
regions to monitor audio
conference activities to
prevent unauthorized use
and waste.
The OEI considers the necessary
controls exist to allow the EPA
program offices and regions to
monitor audio conference
activities. eBusiness contains all
current and historical
consumption data for individual
headquarters and regional
offices. The information is
based on customer consumption
and subsequent invoicing of
audio conferencing services.
Over ten years of ordering,
usage and billing data is
available and can be accessed
through direct query and
organizational report formats in
the eBusiness application.
Headquarters and regional
offices using audio-
conferencing services currently
have the tools to routinely
monitor their billed usage of this
and all WCF services. In
addition to eBusiness, customers
Completed
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receive a Conference Summary
Report with pertinent
conference information. The
OEI also provides periodic
training that reviews and
refreshes user knowledge, and
an annual audit by an external
commercial certified public
accounting firm assesses the
adequacy of the agency's
internal controls.
Related to the discussion of
waste and unauthorized use, the
OEI wishes to address certain
reasons for choosing to use
Reservationless-Plus as opposed
to the Headquarters Personal
Audio Conferencing system.
HP AC use is at no cost to the
agency, however, it only
accommodates six
participants. While there are
many calls on Reservationless-
Plus with six or fewer
participants, this can be
accounted for by many
legitimate reasons.
At the headquarters location,
the number of available six-
line audio conferencing
accounts is less than the
number of voice system
users (1,800 versus 8,000).
In some cases, users
established a
Reservationless-Plus
conference line expecting
more than six users, and
then less called in to
participate.
Several offices work with
international stakeholders in
developing nations who
need to be "dialed out" to in
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order to participate. That
capability is only available
through Reservationless-
Plus.
There are also other options
that are only available via
Reservationless-Plus, such
as operator assistance and
recording, that may have
resulted in users using that
system instead of the less
expensive HPAC system.
3
Increase the EPA's internal
customer awareness of the
Working Capital Fund
Policy Standard's
mandatory services
requirements, and establish
controls that require EPA
program offices and regions
to comply with the
requirements.
The Office of the Chief
Financial Officer will prepare an
annual memorandum to be
distributed to the WCF Board,
with a copy to WCF service
agreement originators, that will
outline all of the sole provider,
preferred provider and
discretionary services provided
by the WCF. The memorandum
will include the related policy
information from the OCFO's
Policv Procedure 5: WCF Exit
Procedures (RMDS 2540-14-P5Y
The memorandum will serve as
reminder of WCF service
classifications and the related
ability to request departure from
these services.
The OCFO also will prepare a
memorandum for distribution to
the Office of Administration and
Resources Management's Office
of Acquisition Management that
will outline all of the sole
provider, preferred provider and
discretionary services provided
by the WCF. The memorandum
will include the related policy
information from the OCFO's
Policv Procedure 5: WCF Exit
Procedures CRMDS 2540-14-
1st Quarter FY 2018
1st Quarter FY 2018
P5). The memorandum will
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serve as notification to OAM to
not award contracts or task
orders related to WCF sole
provider services, as they must
be purchased through the WCF
and a waiver cannot be
requested to purchase services
from an outside vendor. The
memorandum also will be
distributed to regional
acquisition offices to ensure
regional compliance.
4
Maintain documentation to
support Reservationless
Plus usage rate formulation,
approvals and calculations.
This process is well
documented. The service rate is
developed as part of the detail
rate budget formulation process
overseen by the OCFO's WCF
staff, the WCF Board of
Directors and the Chief
Financial Officer. There are
very distinct steps in the rate
formulation process with
required reviews and approvals
at each step to include a final
overall approval of upcoming
fiscal year service rate schedules
by the CFO. Sufficient
documentation exists to support
rate formulation and approvals.
This overall process is
documented in the OCFO's
WCF Operating Instructions. In
addition, the actual service
revenue and costs are posted at
the end of each month to
generate the overall service net
operating results. We believe
the process contains adequate
reviews and approvals to
document rate development.
The Audio Conferencing
Service rate determination is
based on over ten years of
recorded consumption data,
projections on current-year
Completed
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usage and customer
requirements. Attached is the
FY 2016 WCF Financial
Statements and Independent
Auditor's Report which further
shows that WCF processes are
found to be acceptable.
Training Related Links:
Audio Collaboration Service Quick Reference Guide
http://workplace.epa.gov/pdfs/Audio One Pager ORG.pdf
Conferences and Meetings
https ://intranet. ord.epa. gov/conferences-meetings/meetings-using-reservationless-plus-audio-
conferencing
Reservationless-Plus Audio Conferencing Quick Reference Guide
http://intranet.epa.gov/otopintr/webconferencing/pdf/Quick Reference Guide Reservationless
Plus 4-28-16.pdf
Reservationless-Plus Audio Conferencing Options and Pricing
http://intranet.epa.gov/otopintr/webconferencing/pdf/FY16 Options Pricing Info Reservationle
ss-Plus 4-27-16 V2.pdf
Voice Services for Headquarter Employees
http ://intranet. epa. gov/otopintr/phoneservices/phoneservices. html
Reservationless-Plus Teleconferencing Instructions
http://www.r5intra.epa.gov/div/LCD/psb/reservationless-teleconference-instructions-tm-04-
2017.pdf
Reservationless-Plus Conference Call Accounts
https ://intranet. ord.epa. gov/sites/default/files/media/NHEERL/MED/admin-facilitv/ conference-
reservationless-plus.pdf
CONTACT INFORMATION:
If you have any questions regarding this response, please contact Bob Trent, Management
Integrity and Accountability Branch, Office of the Controller, at (202) 566-0983.
Attachment
cc: Donna Vizian
John Showman
Kimberly Patrick
Pam Legare
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Harvey Simon
Howard Osborne
Jeanne Conklin
Meshell Jones-Peeler
Sherri' L. Anthony
Michael D. Davis
Bob Trent
Carrie Hallum
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Distribution
Appendix B
The Administrator
Chief of Staff
Chief of Staff for Operations
Deputy Chief of Staff for Operations
Assistant Administrator for Environmental Information and Chief Information Officer
Chief Financial Officer
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Environmental Information
and Deputy Chief Information Officer
Associate Chief Financial Officer
Controller, Office of the Controller, Office of the Chief Financial Officer
Director, Office of Information Technology Operations, Office of Environmental Information
Director, Service and Business Management Division, Office of Environmental Information
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Environmental Information
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
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