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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
Without E-lnvoicing and
Stronger Payment Process
Controls, EPA Is Placing
$1.2 Billion at Risk Annually
Report No. 18-P-0231	August 16, 2018
1 0/ 1
! /o! Not taking advantage of discounts

$1.2 Billion 1	% Not avoiding interest penalties
taxpayer dollars
at greater risk	Not performing critical oversight
^-Invoking

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Report Contributors:	Michael Davis
Madhu Dev
Kevin Haas
Nicole Pilate
Gloria Taylor-Upshaw
Abbreviations
CFR
Code of Federal Regulations
CO
Contracting Officer
COR
Contracting Officer Representative
CPS
Contract Payment System
E-Invoicing
Electronic Invoicing
EPA
U.S. Environmental Protection Agency
EPAAG
Environmental Protection Agency Acquisition Guide
FAR
Federal Acquisition Regulation
FSSP
Federal Shared Service Provider
FY
Fiscal Year
OARM
Office of Administration and Resources Management
OIG
Office of Inspector General
OMB
Office of Management and Budget
OTS
Office of Technology Solutions
PARS
Performance Appraisal and Recognition System
RTP-FC
Research Triangle Park-Finance Center
Cover Image: The EPA has placed $1.2 billion of taxpayer funds at greater risk by not taking
advantage of prompt payment discounts, not avoiding interest penalties, not
performing critical oversight, and not having a plan to comply with the federal
deadline to implement e-invoicing. (EPA OIG graphic)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
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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* *. U.S. Environmental Protection Agency	18-P-0231
J" ftS \ Office of Inspector General	August 16,2018
IS3SJ
At a Glance
Why We Did This Project
We conducted this audit to
determine whether the
U.S. Environmental Protection
Agency (EPA) implemented a
contract invoice payment
process that allows for the
efficient processing of accurate
and supportable invoice
payments and that complies
with federal laws, federal
regulations and agency
policies.
The Prompt Payment Act
requires executive branch
agencies to pay interest
penalties when they do not pay
their invoices by the due date.
As a result, invoice reviews and
approvals are critical functions
that impact the management of
public funds. The EPA's policy
is to review invoices thoroughly
to determine whether adequate
information, proper rationale
and documentation exist to
support the payment of contract
invoices in a timely manner.
Responsibility for invoice
review and approval is first
vested with the contracting
officer (CO), who may delegate
this authority to the contracting
officer representative (COR).
This report addresses the
following:
• Operating efficiently and
effectively.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oia.
Without E-lnvoicing and Stronger Payment Process
Controls, EPA Is Placing $1.2 Billion at Risk Annually
What We Found
The EPA can maximize the efficiency
of its contract invoice payment
process by focusing on four areas:
The EPA places an annual average of
$1.2 billion in taxpayer funds at greater
risk by not using an e-invoicing
process, not taking advantage of
prompt payment discounts, not
avoiding interest penalties and not
performing critical oversight duties.
•	Implementing an electronic
invoicing (e-invoicing) system.
•	Addressing administrative and
contract modification processing errors.
•	Taking prompt payment discounts offered on contract invoices.
•	Performing critical CO and COR oversight duties.
The EPA does not have a plan to implement an e-invoicing system, even though
the Office of Management and Budget directed agencies to transition to
e-invoicing by the end of fiscal year 2018. Also, the EPA's administrative and
contract modification processing errors result in interest penalties, and the EPA
does not always take discounts when offered. In addition, agency COs and
CORs could not provide or locate documentation demonstrating the performance
of their oversight duties.
If the EPA does not address these areas, the agency will remain vulnerable to
waste, fraud and abuse; will continue to put taxpayer dollars at risk due to
discounts lost and interest penalties paid; and will miss opportunities to put these
funds to better use to protect human health and the environment.
Recommendations and Planned Agency Corrective Actions
We recommend that the Chief Financial Officer develop a plan with milestone
dates to implement an e-invoicing system. We also recommend that the Chief
Financial Offer develop and implement measurable controls that address
processing delays, provide staff with guidance on taking prompt payment
discounts, and notify approving officials of expiring discount periods.
In addition, we recommend that the Assistant Administrator for Administration
and Resources Management, in coordination with the Office of the Chief
Financial Officer, develop and implement measurable controls for each office's
role in processing contract invoices and contract modifications to address
administrative and processing errors. Also, we recommend that the Assistant
Administrator for Administration and Resources Management verify that COs are
performing oversight responsibilities per the agreed-upon corrective actions from
prior Office of Inspector General reports and implement agencywide measurable
controls to address nonperformance of CO oversight responsibilities.
Listing of OIG reports.
The agency did not provide a response to our draft report within 30 days, as
required by EPA Manual 2750. We will meet with the agency to obtain resolution
for our recommendations.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
August 16, 2018
MEMORANDUM
SUBJECT: Without E-Invoicing and Stronger Payment Process Controls,
EPA Is Placing $1.2 Billion at Risk Annually
Report No. 18-P-02:"
FROM: Arthur A Elkins Jr.
TO:
Donna J. Vizian, Principal Deputy Assistant Administrator
Office of Administration and Resources Management
Holly Greaves, 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-FY17-0256.
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.
The EPA offices responsible for responding to issues in this report are the Office of Administration and
Resources Management and the Office of the Chief Financial Officer.
Action Required
We did not receive the agency's response to our draft report submitted on June 14, 2018. This report
contains unresolved recommendations. In accordance with EPA Manual 2750, the resolution process
begins immediately with the issuance of this report. We are requesting a meeting within 30 days
between the Principal Deputy Assistant Administrator for Administration and Resources Management,
the Chief Financial Officer, and the OIG's Assistant Inspector General for Audit and Evaluation. If
resolution is still not reached, the Principal Deputy Assistant Administrator for Administration and
Resources Management is required to complete and submit a dispute resolution request to the Chief
Financial Officer to continue resolution.
We will post this report to our website at www.epa.gov/oig.

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Without E-lnvoicing and Stronger
Payment Process Controls, EPA Is
Placing $1.2 Billion at Risk Annually
18-P-0231
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Offices		2
Scope and Methodology		2
Prior Reports		3
2	EPA Needs a Plan to Comply with OMB's Electronic Invoicing
Requirements		5
OMB Directs Agencies to Transition to E-invoicing		5
EPA's Manual Invoice Process Requires Personnel Resources, Incurs
Interest Penalties		5
EPA Has Not Transitioned to E-lnvoicing		6
EPA Risks Noncompliance, Errors with Manual Invoice Process		7
Recommendation		7
Agency Comments and OIG Evaluation		7
3	EPA's Contract Invoice Payment Process Needs Improvements		8
Federal Regulations and EPA Policy Require Prompt Invoice
Payment and Review		8
EPA Processed Invoices Late and Incurred Interest Penalties		9
Late Payments Were Due to Invoice Processing Errors		10
EPA Is at Risk for Interest Penalties and Missed Opportunities to
Save Taxpayer Dollars		11
Recommendation		12
Agency Comments and OIG Evaluation		12
4	EPA Needs to Improve Its Processing of Discounts		13
Prompt Payment Act and EPA Policy Address Discounts		13
EPA Did Not Take Discounts Offered on Contract Invoices		13
EPA Needs More Controls to Maximize Prompt Payment Discounts		14
EPA May Continue to Miss Discount Deadlines and Opportunities to
Save Taxpayer Dollars		15
Recommendations		15
Agency Comments and OIG Evaluation		15
- continued -

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Without E-lnvoicing and Stronger
Payment Process Controls, EPA Is
Placing $1.2 Billion at Risk Annually
18-P-0231
5 Systemic Improvements Are Needed to CO and COR Oversight
Responsibilities	 16
Federal Regulations and EPA Policies Outline CO and COR
Responsibilities 	 16
EPA Could Not Locate or Provide Invoice Process Documentation	 17
COs and CORs Continue to Not Comply with Federal Regulations,
EPA Policies	 18
Lack of Accountability Increases Risk for Fraud, Waste and Abuse	 19
Recommendation	 19
Agency Comments and OIG Evaluation	 19
Status of Recommendations and Potential Monetary Benefits	 20
Appendices
A Contract Invoice Payment Samples Selected for Audit	 21
B Distribution	 22

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Chapter 1
Introduction
Purpose
The Office of Inspector General (OIG) conducted an audit of the
U.S. Environmental Protection Agency's (EPA's) contract invoice payment
process. The objective of our audit was to determine whether the EPA has
implemented a contract invoice payment process that allows for the efficient
processing of accurate and supportable invoice payments and that complies with
federal laws, federal regulations and agency policies.
Background
From October 1, 2015, to September 30, 2017, the EPA paid out more than
$2.4 billion in contract invoice payments for 55,549 contract invoices (an average
of $1.2 billion annually). It is the EPA's policy to review contract invoices
thoroughly to determine whether adequate information, proper rationale and
documentation exist to support payment in a timely manner. Invoice reviews are
therefore a critical function impacting the management of public funds.
The Prompt Payment Act, as amended, requires executive branch agencies—
including the EPA—to pay interest penalties when they do not pay their invoices
by the due date. The Prompt Payment Act also allows federal agencies to take
discounts for prompt payments if such a discount is contractually authorized or
offered on an invoice. The EPA Acquisition Guide (EPAAG) confirms the
agency's adherence to the Prompt Payment Act and specifies that the agency
"diligently seeks discounts for prompt payment."
EPA employees who review invoices are required to assess contract invoices
thoroughly, process invoices in a timely manner, and maintain records of their
reviews and the resulting actions taken. The responsibility for invoice review and
approval is first vested with the contracting officer (CO), but the CO may delegate
authority for reviews and approvals of contract invoices to the contracting officer
representative (COR).
The EPA's current invoice payment process starts when a contractor submits an
invoice to the EPA's Research Triangle Park-Finance Center (RTP-FC). RTP-FC
staff enter the invoice into the EPA's Contract Payment System (CPS), review the
invoice to verify that it meets Prompt Payment Act standards, and determine
whether a discount is available for prompt payment. If the invoice is determined
to be proper, RTP-FC staff notify the approving official that an invoice is ready
for review and approval. Once the invoice is approved for payment, the
information flows back to the RTP-FC for the certification process. After the
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invoice is certified, it is ready for payment. Figure 1 depicts the EPA's invoice
review-and-approval process.
Figure 1: Contract invoice review-and-approval process calendar
1-3
workdays
•The RTP-FC date-
or time-stamps the
invoice; records
the invoice in the
CPS; and performs
an initial audit of
the invoice for
validity, funding
and prompt
payment
discounts.
15
calendar days
•COs and/or CORs
review and
approve the
invoice.
22-28
calendar days
•The RTP-FC
performs the
certification
process, which
includes reviewing
appropriations and
verifying that
payments are
justified.
29-30
calendar days
•The EPA's Las
Vegas Finance
Center certifies
and sends the
payment file to
Treasury.
•Treasury pays the
contractor.
Source: OIG adaptation of image in the EPA's Invoice Review & Approval Desk Guide.
Responsible Offices
The Office of Administration and Resources Management (OARM) provides
national leadership, policy and management of many essential support functions
for the EPA, including acquisition activities (contracts). The Office of Acquisition
Management, within OARM, is responsible for the EPA's acquisition function,
including the policies, procedures, operations and support of the agency's
procurement and contracts management programs.
The Office of the Chief Financial Officer, which includes the RTP-FC, provides
financial services for the EPA and makes payments to EPA grant recipients,
contractors and other vendors. The Chief Financial Officer's Office of
Technology Solutions (OTS) is responsible for information technology planning,
as well as the development and deployment of financial and resources
management systems for the EPA.
Scope and Methodology
We conducted this audit from July 2017 to June 2018 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 following laws, federal regulations,
agency procedures and agency policies related to the contract invoice payment
process:
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•	Federal Acquisition Regulation (FAR) Subpart 1.6, "Career Development,
Contracting Authority, and Responsibilities."
•	FAR Subpart 32.9, "Prompt Payment."
•	5 CFR Part 1315, "Prompt Payment."
•	Office of Management and Budget (OMB), Improving Government
Efficiency and Saving Taxpayer Dollars Through Electronic Invoicing,
Memorandum M-15-19, July 17, 2015.
•	EPAAG, Subsection 32.9.1, "Invoice Review," 2017.
•	EPA, Invoice Review & Approval Desk Guide, March 13,2015.
•	Treasury Financial Manual, Volume I, Part 4A, Chapter 2000, "Overall
Disbursing Rules for All Federal Agencies."
We obtained a universe of 55,549 contract invoice payments from October 1,
2015, to September 30, 2017. The team judgmentally selected the program office
and the region with the highest total dollar amount of invoices, as well as the
program office with the largest number of invoices: the Office of Environmental
Information, Region 5, and the Office of Land and Emergency Management.
From these three offices, we judgmentally selected a sample of 18 contract
invoice payments based on the nine highest invoice amounts and nine highest
negative disbursements, and we audited supporting documentation and data for
these 18 payments from the EPA's staff and financial system. Appendix A
provides a summary of the 18 selected samples.
We interviewed OARM and Office of the Chief Financial Officer staff to learn
their processes related to, procedures for and relationships with invoice contract
payments. Also, we interviewed COs and CORs from the Office of
Environmental Information, Region 5, and the Office of Land and Emergency
Management who were responsible for the 18 selected contract invoice payments
to determine whether those invoices were reviewed, supported, accurate and
approved for payment in a timely manner according to federal regulations and
agency policy.
Prior Reports
The EPA OIG issued the following prior reports that relate to this audit:
1. OIG Report No. 16-P-0078. EPA's Background Investigation Support
Contracts and OPMBillings Need Better Oversight and Internal Controls,
issued December 2015, found that the EPA did not monitor support
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contracts for compliance with the terms and conditions of the contracts.
Specifically, the OIG found that the COR certification was expired, the
COs did not perform annual contract invoice reviews, the COR did not
maintain proper contract documentation, and the COR was not aware of
documentation requirements. This report made 14 recommendations; the
agency reported that the corrective actions for all recommendations have
been completed as of October 2016.
2.	OIG Report No. 16-P-0135. EPA Should Timely Deobligate Unneeded
Contract, Purchase and Miscellaneous Funds, issued April 2016, found
that EPA personnel did not adequately review or monitor outstanding
obligations to verify that the amounts remaining were valid. This report
made three recommendations; the agency reported that the corrective
actions for all recommendations have been completed as of October 2016.
3.	OIG Report No. 15-P-0215. Internal Controls Needed to Control Costs of
Superjund Technical Assessment & Response Team Contracts, as
Exemplified in Region 7, issued July 2015, found that Region 7 did not
sufficiently review contract invoices, contractor billings included double-
billed items and other unallowable items, Region 7's annual invoice
reviews were lacking, adjustment vouchers were not submitted in a timely
manner, and Region 7's CO did not appoint CORs for the contract in a
timely manner. This report made 26 recommendations; the agency
reported that all recommendations were completed in June 2017.
4.	OIG Report No. 17-P-0380. EPA's Alternative Dispute Resolution and
Public Involvement Contract Needs Better Management, issued
September 2017, found that the management of the subject contract
needed improvement to comply with contractual and acquisition
requirements. Specifically, we found that the CO for the subject contract
did not perform contract invoice reviews in a timely manner and did not
issue the COR appointment memorandum in a timely manner. In addition,
the OIG found that Task Order CORs did not provide written technical
direction as required. This report made three recommendations; the agency
reported that the corrective actions for all recommendations have been
completed as of September 2017. Additionally, as a result of the audit, the
CO began performing and documenting quarterly invoice reviews.
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Chapter 2
EPA Needs a Plan to Comply with
OMB's Electronic Invoicing Requirements
As of April 2018, the EPA did not have an established plan or finalized approach
for implementing an electronic invoicing (e-invoicing) system. In July 2015, the
OMB directed federal agencies to transition to e-invoicing for appropriate federal
procurements by the end of fiscal year (FY) 2018. The OTS said that it has
reviewed three options for e-invoicing but is not sure what kind of e-invoicing
system to implement. Not having an e-invoicing system implemented by the end
of FY 2018 means the agency will not meet federal requirements and will
continue to rely on its manual invoice process, placing contract invoice payments
at risk of errors, which cause late payments and interest penalties.
OMB Directs Agencies to Transition to E-invoicing
OMB Memorandum M-15-19, Improving Government Efficiency and Saving
Taxpayer Dollars Through Electronic Invoicing, issued July 17, 2015, directs
agencies to transition to e-invoicing for appropriate federal procurements by the
end of FY 2018 (Figure 2) using one of the following means:
1.	"Migration to a designated Federal
Shared Service Provider (FSSP)1
and adoption of the FSSP
e-invoicing solution.
2.	"Use of an OMB-approved
e-invoicing solution that aligns with
agency mission and support
requirements.
3.	"Cessation of any investments in
new e-invoicing solutions."
EPA's Manual Invoice Process Requires Personnel Resources,
Incurs Interest Penalties
The EPA's invoice process starts when an invoice is received at the RTP-FC by
email or postal mail. If the invoice is received by email, RTP-FC staff manually
save the invoice into the CPS. If the invoice is received by postal mail, RTP-FC
staff will scan the invoice, create an electronic file, and manually bar code the
electronic file to prepare it for entry into the CPS. The RTP-FC is responsible for
Figure 2: E-invoicing transition
deadline
E-invoicing
Source: OIG image
1 The term "shared services" refers to an operational unit (including people, processes and technologies) that is a
centralized point of service and is focused on defined business functions within an organization.
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confirming and annotating official receipt of the invoice in addition to verifying
and entering the terms of any discounts into the CPS.
The EPA's Invoice Review & Approval Desk Guide, Section VIII. 1 .c, states that if
RTP-FC staff determine that the invoice does not comply with federal and EPA
requirements, they must return the invoice to the vendor within 7 days after
receipt, along with the reasons why the invoice was determined to be improper.
Section VIII.2, states that if the invoice is determined to be proper, RTP-FC staff
will notify the approving official that it is ready for review and approval.
In addition to the personnel resources required to manually review and approve
invoices, the EPA incurred more than $95,000 in interest penalties due to late
payments in FYs 2016 and 2017. The EPA also was unable to take advantage of
over $197,000 in prompt payment discounts during this same period. Chapters 3
and 4 of this report detail these findings. RTP-FC staff said that automating
processes would help reduce costs, error rates and the personnel resources
required to manually review and approve invoices.
EPA Has Not Transitioned to E-lnvoicing
As of March 2018, the EPA had not transitioned to or established a plan to
implement e-invoicing. Since the OMB issued Memorandum M-15-19 in
July 2015, the OTS said that it has reviewed options with outside sources to
implement e-invoicing, but it has not finalized an approach.
The EPA said that it has reviewed the following options from outside sources:
•	U.S. General Services Administration. Provides a wide range of quality
technical services that can improve a federal agency's performance and
help meet mission goals.
•	CGI (contractor). Offers a span of shared services in the federal
government, including information technology infrastructure, enterprise
information technology, programmatic and back-office services, and
mission services.
•	U.S. Department of the Treasury's Invoice Processing Platform. Provides
a web-based, integrated and secure system to simplify the management of
vendor invoices. It is offered at no charge to federal agencies and their
vendors.
Initially, in January 2018, the OTS told us that it could not comply with the OMB
requirements due to a lack of funding for a contract but that it had selected a
project manager for the e-invoicing project. However, the OTS was not sure what
kind of e-invoicing system to implement. In March 2018, the OTS indicated that
it had a sole source contract to implement e-invoicing but stated that "due to
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limitations on the sole source contract that [would have been] awarded, we have
decided to take another route." The OTS informed us that it has a roadmap of
anticipated implementation but that the roadmap needs to be updated after the
agency establishes and finalizes its approach. The OTS did not say whether the
EPA would meet the federal requirement to implement e-invoicing by the end of
FY 2018.
EPA Risks Noncompliance, Errors with Manual Invoice Process
The EPA is at risk of not complying with the OMB requirement to implement an
e-invoicing system by the end of FY 2018. Additionally, by using manual
processes to review and approve contract invoices, which cause late payments and
interest penalties, the EPA continues to put taxpayer dollars at risk for errors. An
e-invoicing system would benefit the EPA by helping to reduce the resources and
costs associated with its manual contract invoice payment process.
Recommendation
We recommend that the Chief Financial Officer:
1. Develop a plan with milestone dates to implement an electronic invoicing
system to meet the Office of Management and Budget fiscal year 2018
requirement.
Agency Comments and OIG Evaluation
We issued our draft report on June 14, 2018, but did not receive a response from
the agency within 30 days of the issuance date, as requested by the OIG and
required by EPA Manual 2750. We consider this recommendation unresolved and
will work with the agency to reach a resolution.
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Chapter 3
EPA's Contract Invoice Payment Process
Needs Improvements
The EPA did not always pay its contract invoices on time and therefore did not
always avoid interest penalties. The EPA paid interest penalties on nine of the
18 invoices we reviewed, and eight of those interest penalties were due to
administrative and contract modification processing errors. OMB regulations
require federal agencies to pay their bills on a timely basis and to pay interest
penalties when payments are late. In addition, the EPAAG states that the
government's policy is to review and process invoice submittals in a timely
manner. The EPA needs to implement additional controls to accurately process its
contract invoices in a timely manner. The EPA could have saved taxpayers over
$95,000 in interest penalties in FYs 2016 and 2017 if contract invoice payments
were made in accordance with federal and EPA regulations.
Federal Regulations and EPA Policy Require Prompt Invoice Payment
and Review
FAR Part 32.9, "Prompt Payment," states that, with exceptions, the general
payment due date is the 30th day after the later of two events: (1) the designated
billing office receives a proper invoice from the contractor or (2) acceptance of
supplies delivered or services performed. For construction contracts, the payment
due date is 14 days after the designated billing office receives a proper payment
request.
The OMB's "Prompt Payment" regulations at 5 CFRPart 1315 require federal
agencies to pay their bills on a timely basis and to pay interest penalties when
payments are late. Per these regulations, agencies may take prompt payment
discounts when payments are made. The regulations also mandate that agencies
review each invoice as soon as practicable after receipt to determine whether it is
proper.
The Treasury Financial Manual, Volume I, Part 4A, Chapter 2000, "Overall
Disbursing Rules for All Federal Agencies," Section 2070, states that "[ejffective
control over disbursements requires the preaudit and approval of vouchers before
they are certified for payment." One of the principal objectives of the preaudit of
a voucher is to determine whether "[f]unds are available at the time the obligation
is incurred. If an obligation is incurred when funds are not available, then the
payment may not be certified and a payment voucher may not be disbursed."
The EPAAG, Subsection 32.9.1, "Invoice Review," states that "[i]t is the policy
of the government to review invoices thoroughly for cost reasonableness and to
process invoice submittals in a timely manner." The EPAAG emphasizes that
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federal agencies adhering "to this policy will result in payment of costs which are
allowable, allocable, and reasonable, and avoid interest penalties due to late
payment of such costs."
EPA Processed Invoices Late and Incurred Interest Penalties
The EPA processed contract invoices after the 30-day time period specified in the
FAR and incurred interest penalties as a result. Of the 18 total invoices we
sampled, the EPA paid interest penalties on nine of them. Of these nine invoices,
eight (89 percent) were paid late as a result of administrative and processing
errors, while one was paid late as a result of a database system error. The eight
invoices that incurred interest penalties due to administrative and processing
errors were paid from 30 to 138 days after the allowable 30-day period (i.e., from
60 to 168 days total, as shown in Table 1). As a result of these errors, the EPA
paid $10,386—below 1 percent of the approximately $3.5 million disbursed on
the eight invoices—in interest penalties.
Table 1: Interest payment penalties due to administrative and processing errors
Sample
Days to process
payment
Invoiced
amount
Disbursed
amount
Interest
penalty paid
1
Invoice B
168
$285,774
$288,524
$2,749
2
Invoice O
117
177,132
177,936
804
3
Invoice P *
109
68,973
69,257
284
4
Invoice J *
66
208,181
208,702
521
5
Invoice N
63
1,885,515
1,889,837
4,322
6
Invoice F
62
209,008
209,357
348
7
Invoice K
60
224,050
224,517
467
8
Invoice L
60
427,822
428,713
891
Totals
$3,486,455
$3,496,843
$10,386
Source: EPA contract invoice data.
* Reissued due to improper payment. See Table 2.
From October 1, 2015, to September 30, 2017, the EPA paid out more than
$2.4 billion in contract invoice payments for 55,549 contract invoices. These
invoices included 1,482 late payments
that caused the EPA to incur over
$95,000 in interest penalties
(Figure 3). While the percentage of
interest penalties paid in comparison
to the overall dollar amount of
invoices paid is well under 1 percent,
OMB Memorandum M-15-19 seeks to
improve government efficiency by
requiring agencies to adopt
9
Figure 3: Late payments and interest penalties
(FYs 2016-2017)
WW	.	$95,000
—	interest
S	Orpenal,ies
V-X1,482	Vq
late payments
Source: OIG image.
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e-invoicing solutions for government contracts. The memorandum also states that
invoices that are processed using a mix of electronic and manual processes can
result in taxpayer dollars being used for late payments fees rather than to support
critical agency missions.
We also noted that two contract invoice payments in our sample (P and J) were
reissued due to improper payments made by the agency. However, for Invoice P,
the EPA did not report the original contract invoice payment as improper in
FY 2016. Reporting improper payments is required by the Improper Payments
Information Act of 2002, as amended by the Improper Payments Elimination
Recovery Act of 2010 and the Improper Payments Elimination and Recovery
Audit Improvement Act of 2012.
Late Payments Were Due to Invoice Processing Errors
Of the nine invoices in our sample that incurred interest penalties, we found that
eight of the late payments were primarily due to administrative and contract
modification2 processing errors. Table 2 summarizes the reasons EPA staff
provided for these late payments. The EPA needs to address these processing
errors to improve its contract invoice payment process.
Table 2: Administrative and processing errors that resulted in interest penalties
Sample
Type of error
Reason provided for lateness
Invoice B
Program office project
officer error
Project officer said payments were made out of
incorrect fiscal years.
Invoice F
RTP-FC administrative
error
There were issues with labeling and paying the
invoice.
Invoice J
RTP-FC administrative
error
Invoice was reissued because it was paid to the
incorrect vendor code. The initial payment was
reported as improper in FY 2016.
Invoice K
Regional office delay of
funds error
COR said that payment was delayed because
the region needed to obligate funds.
Invoice L
OARM Office of
Acquisition Management
contract modification error
Payment of invoice was delayed until a contract
funding modification was processed.
Invoice N
OARM Office of
Acquisition Management
contract modification error
Option periods were entered wrong. Payment of
invoice was delayed until funds were made
available in the contract for the correct line of
accounting.
Invoice O
RTP-FC administrative
import error
Manual invoice entry was missed.
Invoice P
RTP-FC administrative
error
Invoice was reissued because it was initially sent
to the wrong vendor. The initial payment was not
reported as improper in FY 2016.
Source: EPA contract invoice data.
2 "Contract modification" means any written change in the terms of a contract.
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In addition, RTP-FC management told us that it is aware of general entry
accounting line errors that cause invoices to go unpaid until corrected. The
RTP-FC indicated that late payments were caused by the following errors:
•	Insufficient funding because funding documents were not submitted in a
timely manner.
•	Project officer/COR late approvals.
•	Payment office errors.
The EPA's Office of Acquisition Management staff also informed us of common
reasons for late invoice payments, including the following:
•	Administrative issues due to staff availability to approve.
•	Vendor listing different rates in invoices than in the contract.
•	Vendor billing outside of the payment period.
•	Vendor invoicing for products not delivered.
The EPA has implemented some oversight of the invoice review-and-approval
process. For example, the RTP-FC provided us with a list of the "top five" highest
interest payments for January 2018, along with reasons why interest penalties
were incurred and the actions taken to address these errors. Also, the RTP-FC
occasionally conducts an "Invoice Payment Section Shut Down" payment blitz,
which allows the office to focus on a particular part of the payment process to
maximize timely payments. However, these actions occur on an occasional basis
and are not a part of the agency's established policies and procedures. Additional
controls should be created to formally address the administrative and processing
errors detailed in Table 2, as well as other errors identified by RTP-FC and Office
of Acquisition Management staff.
During interviews, RTP-FC management and staff suggested that the EPA adopt
e-invoicing, which may detect many vendor data entry errors automatically, thus
helping to eliminate interest payments; enable the finance center staff to perform
other tasks; and allow the EPA to take advantage of prompt payment discounts.
EPA Is at Risk for Interest Penalties and Missed Opportunities to Save
Taxpayer Dollars
The EPA on average pays out more than $1.2 billion annually to contractors. We
found that the agency could have saved taxpayers over $95,000 in interest
penalties over a 2-year period if contract invoices were paid in accordance with
the Prompt Payment Act and OMB regulations. The EPA will continue to put
taxpayer dollars at risk for interest penalties due to manual processing errors.
Implementation of an e-invoicing system may aid the EPA in reducing
administrative and processing errors, as well as any related interest penalties.
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Recommendation
We recommend that the Assistant Administrator for Administration and
Resources Management:
2. Develop and implement measurable controls in coordination with the
Office of the Chief Financial Officer for each office's role in processing
contract invoices and contract modifications to address administrative and
processing errors.
Agency Comments and OIG Evaluation
We issued our draft report on June 14, 2018, but did not receive a response from
the agency within 30 days of the issuance date, as requested by the OIG and
required by EPA Manual 2750. We consider this recommendation unresolved and
will work with the agency to reach a resolution.
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Chapter 4
EPA Needs to Improve Its Processing of Discounts
The EPA did not always process invoices within the specified prompt payment
discount periods when such discounts were offered. From October 1, 2015, to
September 30, 2017, the EPA failed to take advantage of 56 percent of the total
amount of discounts offered, which represents over $197,000 in missed discounts.
OMB regulations at 5 CFR § 1315.7(a) state that an agency may take discounts if
they are "economically justified," but only after "acceptance has occurred."
However, the RTP-FC said that late receipt of invoice approvals from CORs often
caused the EPA to miss deadlines for prompt payment discounts. The EPA
therefore missed the opportunity to save taxpayer dollars, which would have
provided the agency with additional funds for mission-critical programs.
Prompt Payment Act and EPA Policy Address Discounts
As discussed in Chapter 3 of this report, the OMB's "Prompt Payment"
regulations at 5 CFR Part 1315 require federal agencies to pay their bills on a
timely basis and to pay interest penalties when payments are late. Per these
regulations, agencies may take prompt payment discounts when payments are
made. The regulations also mandate that agencies review each invoice as soon as
practicable after receipt to determine whether it is proper.
Furthermore, 5 CFR § 1315.7(a) states that if an agency is offered a discount by a
vendor, whether stipulated in the contract or offered on an invoice, the agency
may take the discount if "economically justified," but only after "acceptance has
occurred." Agencies are encouraged to include discount terms in a contract to
give them adequate time to process any economically justified discounts.
In addition to stating the government's policy to "review invoices thoroughly for
cost reasonableness and to process invoice submittals in a timely manner," the
EPAAG, Subsection 32.9.1, "Invoice Review," emphasizes the EPA's
commitment to taking advantage of prompt payment discounts:
The Agency also diligently seeks discounts for prompt payment.
"Discount for prompt payment" means an invoice payment
reduction offered by the contractor in exchange for payment prior
to the due date, which is typically 30 calendar days after receipt of
a proper invoice.
EPA Did Not Take Discounts Offered on Contract Invoices
Of the 653 invoices that offered prompt payment discounts from October 1, 2015,
to September 30, 2017, the EPA did not take advantage of discounts offered by
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259 of them. The missed discount
opportunities represented
$197,024 (56 percent) out of a
total of $352,636 in discounts
offered in FYs 2016 and 2017
(Figure 4). The EPA did not take
these discounts even though the
agency considered the discounts
economically justifiable and
accepted the services rendered as
conforming to the contract
requirements.
Table 3 details the payment totals for contract invoices processed during
FYs 2016 and 2017.
Table 3: EPA prompt payment discounts in FYs 2016 and 2017
Total number of invoices paid
55,549
Total amount disbursed
$2406,518,295
Discounts offered and advantageous
$352,636
Discounts lost
$197,024
56% of value offered
Discounts taken
$155,612
44% of value offered
Source: OIG analysis of EPA contract invoice data.
The EPA's CPS is designed to automatically notify staff of upcoming payment
deadlines, according to the general 30-day allowable period specified in the FAR.
We did observe that automated reminder notices of upcoming contract invoice
payment due dates were provided to invoice approving officials. However, the
CPS does not notify EPA staff of expiring discount periods.
EPA Needs More Controls to Maximize Prompt Payment Discounts
The EPA needs more controls over contract invoice payments that offer prompt
payment discounts. While the EPAAG, Subsection 32.9.1, states that the EPA
diligently seeks discounts for prompt payment, we only observed policies to
record and track discounts. The EPA does not have policies or procedures to aid
staff in taking the discounts.
In the EPA's FY 2016 Agency Financial Report, the agency states that it continues
to explore ways in which the "discount taken" rate can be increased to reduce
improper payments. For example, the Office of Acquisition Management told us
that while the EPA does not always include prompt payment discounts within the
terms of its contracts, it is smarter to leverage the agency's buying power to
include discounts as contractually negotiated rates than to obtain discount terms in
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Figure 4: Percentage of total dollar value of
discounts offered and lost (FYs 2016-2017)
Source: OIG image.

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individual invoices. In addition, the RTP-FC, which tracks the EPA's performance
in taking prompt payment discounts, provided us with a list of the "top five"
invoices with lost discounts for December 2017 and January 2018, along with the
corrective actions taken for those five instances. The RTP-FC cited several reasons
why the agency failed to take advantage of offered discounts, including the late
receipt of invoice approvals from the COs and CORs and internal processing
delays. The corrective actions taken by the RTP-FC to address the causes of these
five lost discounts included reinforcing current internal control procedures and
reassigning contracts with discounts to a specific workload.
Because more than 50 percent of discounts were lost in FYs 2016 and 2017 and
because the agency is aware of some causes of the lost discounts, the EPA should
create internal controls to improve the amount of offered discounts taken.
EPA May Continue to Miss Discount Deadlines and Opportunities to
Save Taxpayer Dollars
Because of lost discounts, the EPA missed the opportunity to save taxpayers over
$197,000 during a 2-year period and put those funds to better use. The EPA may
continue to waste taxpayer dollars—which could instead be used to protect human
health and the environment—if discounts are not taken. Implementation of e-
invoicing may help EPA lower the amount of discounts lost by reducing manual
invoice processes and the time to approve invoices.
Recommendations
We recommend that the Chief Financial Officer:
3.	Develop and implement measurable controls that address internal
processing delays identified by the agency as reasons why prompt
payment discounts were not taken.
4.	Develop and implement measurable controls that provide staff with
guidance on taking prompt payment discounts before the discount period
ends and that notify approving officials of expiring discount periods, so
that prompt payment discounts can be taken when economically justified
in compliance with the Prompt Payment Act and Office of Management
and Budget regulations at 5 CFR Part 1315.
Agency Comments and OIG Evaluation
We issued our draft report on June 14, 2018, but did not receive a response from
the agency within 30 days of the issuance date, as requested by the OIG and
required by EPA Manual 2750. We consider these recommendations unresolved
and will work with the agency to reach a resolution.
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Chapter 5
Systemic Improvements Are Needed to
CO and COR Oversight Responsibilities
The EPA's COs and CORs did not always perform the federally required
oversight responsibilities when processing contract invoices for payment. EPAAG
Subsection 32.9.1, "Invoice Review," states that the CO may delegate the
authority to review and approve contract invoices to the COR, but that the CO is
still responsible for periodically monitoring the COR invoice reviews, including
at least one annual detailed invoice review each contract year. Additionally, the
FAR and agency policy require that COs and CORs maintain a file for each
assigned contract to document the actions taken. However, we found that COs
lacked documentation to support the delegation of duties to CORs and did not
perform the required annual contract invoice reviews due to time constraints. In
addition, CORs did not provide documentation to show that invoice reviews were
completed prior to approval and payment. We identified similar issues in two
prior audit reports issued in FYs 2016 and 2017. The nonperformance of critical
CO and COR oversight duties is a systemic issue that leaves the EPA vulnerable
to fraud, waste and abuse. Furthermore, when documentation for completed
reviews is not available, the EPA does not have reasonable assurance that invoice
payments for contractor work were allowable, allocable and reasonable.
Federal Regulations and EPA Policies Outline CO and COR
Responsibilities
FAR Subpart 1.6, "Career Development, Contracting Authority, and
Responsibilities," Section 1.602-2(d), requires that COs, in accordance with
agency procedures, designate and authorize in writing a COR for all contracts
other than firm-fixed-price contracts, unless the CO retains and executes the COR
duties. Additionally, Section 1.604 of these regulations specifies that CORs "shall
maintain a file for each assigned contract," along with "[documentation of COR
actions taken in accordance with the delegation of authority."
Subsection 32.9.1 of the EPAAG, "Invoice Review," provides the following
guidance regarding CO and COR responsibilities for the invoice review-and-
approval process:
The Contracting Officer (CO) is ultimately responsible and
accountable for invoice processing under individual contracts. ...
the CO may delegate authority to review and approve contract
invoices/vouchers to the Contracting Officer's Representative
(COR). However, the CO still retains the responsibility to ensure
that invoices are processed accurately and in a timely manner.
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Specific CO responsibilities outlined in the EPAAG include "[maintaining record
of invoices submitted, payments, discounts taken, suspensions, disallowances, and
refunds" and "periodic monitoring" of a COR's invoice review. The policy
stipulates that "at least one detailed review of a contract invoice for each contract
year" must be part of this periodic monitoring. Furthermore, EPAAG
Subsection 32.9.1.5 states that "[ajpproving officials involved in invoice reviews
must ... maintain records of their invoice reviews and actions taken as a result of
the reviews."
The EPA's Invoice Review & Approval Desk Guide outlines the responsibilities,
procedures and instructions governing the review and approval of contract
invoices. The guide includes the following direction:
All CORs must document in their files that invoice reviews were
performed. A file of all invoices, monthly progress reports, invoice
review checklists, and all other documentation associated with the
reviews must be maintained for the life of the contract or
applicable records retention requirements, whichever is longer. ...
ALL payment authority, under contractual instruments, must be
specifically delegated in writing by the CO in accordance with
current COR Policy, before anyone other than a CO is authorized
to approve invoices, vouchers, progress payments, advance
payments or any other payments made under an EPA contract.
Furthermore, the EPA's Performance Appraisal and Recognition System (PARS)
for the CO and COR positions we reviewed includes standards, measures and
metrics related to invoice processing (Table 4).
Table 4: CO and COR PARS standards related to invoice processing
CO standards
COR standards
•	Managing contracts in accordance with
applicable laws, the FAR, and agency
regulations and policies.
•	Reviewing documents generated by
contract specialists and COs for contract
placement, management and closeout in
accordance with established milestones or
agreed-upon time frames.
•	Monitoring project progress.
•	Approving, disapproving or
suspending invoices to ensure that
the government receives the services
purchased according to the details of
the contractual agreement.
•	Approving payments of vouchers by
the approval due date.
Source: OIG analysis of the EPA's PARS.
EPA Could Not Locate or Provide Invoice Process Documentation
Some COs lacked documentation to support the delegation of duties to CORs for
their assigned contracts. COs did not designate and authorize in writing CORs for
three of the 18 contract invoices we sampled. Additionally, records documenting
COR invoice reviews were not always available upon request. COs either did not
perform or did not have documentation for the required annual contract invoice
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reviews for 10 of the 18 contract invoices we sampled. In addition, CORs could
not provide documentation (such as a checklist) that indicated invoice reviews
were performed prior to approving five of the 18 contract invoices we sampled.
Three COs said that delegation memorandums were either not drafted or not signed.
Two COs said that they did not perform the required annual contract invoice
reviews due to staff limitations and other priorities. One OARM staff member
stated that, in some cases, the CORs' contract duties are a small percentage of their
overall workload and therefore invoice reviews are not taken seriously.
Prior audits related to contracts and invoice processing identified similar findings
and causes. Specifically, COs interviewed during fieldwork for OIG Report
Nos. 16-P-0078 and 17-P-0380 cited workload as a reason for not completing the
required annual contract invoice reviews. Additionally, the COR interviewed for
Report No. 16-P-0078 did not have knowledge of the specific invoice review
requirements. That COR was also unaware of and did not use an available
checklist to review monthly invoices.
COs and CORs Continue to Not Comply with Federal Regulations,
EPA Policies
The recurrent findings of CO and COR nonperformance of their duties cited in
this and prior OIG reports indicate a systemic issue throughout the EPA. COs and
CORs have measures and metrics specified within the EPA's PARS, against
which their supervisors are to annually evaluate their performance of oversight
duties related to contract management. COs and CORs should be performing their
duties as required by EPA policies and their individual PARS.
As described in the "Prior Reports" section in Chapter 1 of this report, we have
issued previous audit reports that highlight instances of CO and COR
nonperformance of oversight responsibilities related to contract invoices and
reviews. Specifically, we issued two reports with recommendations addressing
these deficiencies:
• OIG Report No. 16-P-0078 recommended the implementation of a
management internal control to ensure that CO invoice reviews are
performed in accordance with the EPA's Invoice Review & Approval Desk
Guide (Recommendation 5). The report also recommended that the CO
periodically review the COR's contract files to verify that proper
documentation is maintained (Recommendation 8). The agency agreed with
these recommendations and said that it completed corrective actions for
Recommendation 5 in October 2016 and Recommendation 8 in
October 2015. The agency stated that corrective actions for
Recommendation 5 would include developing and implementing an
approach to oversee compliance with invoice review polices and guidance.
OARM planned to address Recommendation 8 as a performance issue.
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• EPA OIG Report No. 17-P-0380 recommended that the COR perform
periodic spot checks to verify that all required information is included in
the contract invoices (Recommendation 3). The agency agreed with the
recommendation and said that it completed corrective action in June 2017.
The agency stated that corrective actions for Recommendation 3 would
include written follow-up documentation that reviews of invoices are
comprehensive and documented appropriately.
These two prior reports—along with our findings in this and other reports, as
detailed in the "Prior Reports" section in Chapter 1—indicate that CO and COR
nonperformance of their oversight duties is an agencywide systemic issue that the
EPA should address. The agency needs to verify that the corrective actions
addressing the prior report findings, which it stated were completed, have been
performed and are effective, since similar nonperformance of CO and COR
oversight duties have been identified in this report.
Lack of Accountability Increases Risk for Fraud, Waste and Abuse
Across the agency, COs and CORs may lack accountability for the contract
management oversight duties outlined in their individual PARS. The
nonperformance of critical CO and COR oversight duties, which act to safeguard
taxpayer dollars, is a systemic issue that leaves the EPA vulnerable to fraud, waste
and abuse. Furthermore, when documentation demonstrating CO and COR
contract invoice reviews is not available, the EPA lacks reasonable assurance that
invoice payments for contractor work were allowable, allocable and reasonable.
Recommendation
We recommend that the Assistant Administrator for Administration and
Resources Management:
5. Verify that contracting officers are performing oversight responsibilities
per the agreed-upon corrective actions from prior OIG reports, and
implement agencywide measurable controls to address nonperformance of
contractor officer invoice process oversight responsibilities in accordance
with Federal Acquisition Regulation Subpart 1.6, EPA Acquisition Guide
Subsection 32.9.1, and the EPA's Performance Appraisal and Recognition
System, as applicable.
Agency Comments and OIG Evaluation
We issued our draft report on June 14, 2018, but did not receive a response from
the agency within 30 days of the issuance date, as requested by the OIG and
required by EPA Manual 2750. We consider this recommendation unresolved and
will work with the agency to reach a resolution.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
7 Develop a plan with milestone dates to implement an electronic
invoicing system to meet the Office of Management and Budget
fiscal year 2018 requirement.
Chief Financial Officer
12 Develop and implement measurable controls in coordination with
the Office of the Chief Financial Officer for each office's role in
processing contract invoices and contract modifications to
address administrative and processing errors.
15 Develop and implement measurable controls that address
internal processing delays identified by the agency as reasons
why prompt payment discounts were not taken.
15 Develop and implement measurable controls that provide staff
with guidance on taking prompt payment discounts before the
discount period ends and that notify approving officials of
expiring discount periods, so that prompt payment discounts can
be taken when economically justified in compliance with the
Prompt Payment Act and Office of Management and Budget
regulations at 5CFR Part 1315.
19 Verify that contracting officers are performing oversight
responsibilities per the agreed-upon corrective actions from prior
OIG reports, and implement agencywide measurable controls to
address nonperformance of contractor officer invoice process
oversight responsibilities in accordance with Federal Acquisition
Regulation Subpart 1.6, EPA Acquisition Guide Subsection
32.9.1, and the EPA's Performance Appraisal and Recognition
System, as applicable.
Assistant Administrator for
Administration and
Resources Management
Chief Financial Officer
Chief Financial Officer
95
197
Assistant Administrator for
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
Contract Invoice Payment Samples
Selected for Audit
Sample
Program office/region
Invoiced
amount *
Disbursed
amount *
Invoice A
Office of Land and Emergency Management
$15,554
($15,554)
Invoice B
Office of Land and Emergency Management
285,774
288,524
Invoice C
Office of Land and Emergency Management
632,061
634,301
Invoice D
Office of Land and Emergency Management
6,407
(6,407)
Invoice E
Office of Land and Emergency Management
26,852
(26,852)
Invoice F
Office of Land and Emergency Management
209,008
209,357
Invoice G
Office of Environmental Information
25,232
(25,232)
Invoice H
Office of Environmental Information
9,134
(9,134)
Invoice I
Office of Environmental Information
30,023
(30,023)
Invoice J
Office of Environmental Information
208,181
208,702
Invoice K
Office of Environmental Information
224,050
224,517
Invoice L
Office of Environmental Information
427,822
428,713
Invoice M
Region 5
37,457
(37,457)
Invoice N
Region 5
1,885,515
1,889,837
Invoice O
Region 5
177,132
177,936
Invoice P
Region 5
68,973
69,257
Invoice Q
Region 5
92,165
(92,165)
Invoice R
Region 5
62,532
(62,532)
Totals
$4,423,872
$3,825,786
Source: EPA contract invoice data.
* Invoiced amounts have disbursed negative amounts due to financial transaction corrections or
payments made to the EPA from the contractor.
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Appendix B
Distribution
The Administrator
Deputy Administrator
Chief of Staff
Chief of Operations
Special Advisor, Office of the Administrator
Assistant Administrator for Administration and Resources Management
Chief Financial Officer
Regional Administrators, Regions 1-10
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Assistant Administrator for Administration and Resources Management
Deputy Chief Financial Officer
Associate Chief Financial Officer
Director, Office of Continuous Improvement, Office of the Administrator
Director, Office of Regional Operations
Director, Office of Acquisition Management, Office of Administration and Resources
Management
Director, Office of Resources, Operations and Management, Office of Administration and
Resources Management
Director, Research Triangle Park-Finance Center, Office of the Chief Financial Officer
Director, Office of Technology Solutions, Office of the Chief Financial Officer
Deputy Director, Office of Resources, Operations and Management, Office of Administration
and Resources Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinators, Regions 1-10
Audit Follow-Up Coordinator, Office of Acquisition Management, Office of Administration and
Resources Management
Audit Follow-Up Coordinator, Office of Technology Solutions, Office of the Chief Financial
Officer
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