*. U.S. Environmental Protection Agency	12-P-0864

|	\ Office of Inspector General	September 25, 2012
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At a Glance
Why We Did This Review
Based on a request from the
U.S. Environmental Protection
Agency (EPA) Assistant
Administrator for the Office of
Research and Development
(ORD), we examined EPA's
review process for Science to
Achieve Results (STAR) grant
Request for Applications (RFA)
"Advancing Public Health
Protection through Water
Infrastructure Sustainability."
We sought to determine
whether EPA followed
applicable policies and
procedures, and communicated
with applicants appropriately.
ORD's National Center for
Environmental Research's
(NCER's) STAR grant program
funds research through a
competitive solicitation process
and independent peer review.
For the RFA reviewed, NCER
conducted two peer reviews.
NCER voided results of a
December 2009 peer review
panel due to concerns over
expertise and innovativeness,
and completed a second peer
review in June 2010.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
 Advancing science, research,
and technological innovation
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
EPA's Review of Applications for a Water Research
Grant Did Not Follow All Review Procedures and
Lacked Transparency
What We Found
NCER did not follow all applicable policies and procedures in reviewing
applications submitted under RFA EPA-G2009-STAR-F1, and lacked procedures
for a key aspect of its STAR grant application peer review process. Specifically:
	NCER did not follow the review process required by the Code of Federal
Regulations (C.F.R) under 40 C.F.R Part 40.150. EPA subsequently issued
a class exception from 40 C.F.R 40.150 that retroactively applied to the
process for this and other RFAs, but NCER did not make this known to the
	For more than half of the 72 applications reviewed during each peer review,
at least one of the three assigned peer reviewers did not provide written
comments addressing each evaluation criterion as required.
	NCER did not have a clearly defined "firewall" policy for its peer review
process. The process used to select reviewers for the June 2010 review, in
our view, was inconsistent with descriptions of NCER's firewall practice
published in 2002 and 2003 National Academies reports.
NCER did not communicate with all applicants for the RFA in a transparent,
appropriate, accurate, and timely manner. For example, NCER was not
transparent in communicating its decision to conduct a second review, the
expected delays resulting from the second review, and whether the results sent
to applicants were based on the December 2009 or June 2010 review. NCER's
declination letters did not sufficiently explain why applicants were not selected or
inform them of the option to request a debriefing. NCER informally communicated
results to some applicants prior to final selection decisions.
The issues noted stemmed from a lack of program procedures and management
controls, resulting in delays and additional costs for NCER to review applications
for the RFA. In addition, the control weaknesses identified could also harm the
reputation of EPA's STAR program that has been characterized in the past as a
program with an independent, rigorous process that funds high-quality research.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Research and Development
ensure that NCER makes the public aware of its class exception from 40 C.F.R
40.150, establishes and adheres to improved procedures and management
controls for administering the STAR grant program, and improves its guidance
and management controls for communicating with grant applicants. The Agency
agreed with our conclusions and agreed with the intent of our recommendations.
Planned corrective actions will be addressed in the Agency's 90-day response.