*. U.S. Environmental Protection Agency	12-P-0160
I JBL - Office of Inspector General	December 28, 2011
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At a Glance
Why We Did This Review
In July 2011, a U.S. Senator
asked the U.S. Environmental
Protection Agency (EPA) to
look into a complaint that EPA
had not paid for services
provided in 2007 by Laboratory
for Scientific Interrogation, Inc.
(LSI), of Phoenix, Arizona.
Background
In March 2007, EPA issued
purchase order EP07H001074
to LSI for training seminars for
the Office of Inspector General
(OIG). The price set in the
purchase order was $4,000. LSI
presented a 1-day seminar to
OIG staff on May 9, 2007, and
a second 1-day seminar on
May 10, 2007.
Training Contractor Not Promptly Paid
Under Purchase Order EP07H001074
What We Found
EPA did not pay LSI for services rendered in 2007 because EPA did not receive
an invoice from LSI until after the July 2011 congressional inquiry. Contrary to
regulation, the EPA contracting officer in the Office of Administration and
Resources Management apparently did not provide LSI with a copy of the
purchase order to provide training for the OIG. Because EPA procured the
service through a purchase order, LSI did not have to sign and return it to EPA to
indicate that it had accepted the contract terms. The Federal Acquisition
Regulations state that performance of a purchase order is acceptance. The
purchase order provided instructions for submitting an invoice. However,
because LSI did not receive a copy of the purchase order, LSI did not properly
submit its invoice and did not know who to contact when it was not promptly
paid.
In June 2008, OIG staff realized that LSI had not submitted an invoice. However,
no one in the OIG contacted LSI or the contracting officer to find out why LSI
had not been paid for the services rendered.
After the congressional inquiry, the OIG obtained an invoice from LSI that
exceeded the price in the purchase order. The difference of $ 1,031.90 was the
travel costs of the instructor who provided the training. EPA modified the
purchase order in September 2011 so it could pay LSI for the claimed training
and travel costs. However, we found no evidence that the travel was authorized
by the government. In November 2011, EPA paid LSI $5,031.90.
What We Recommend
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2012/
20111228-12-P-0160.pdf
We recommend that the Inspector General assure that invoices are obtained,
reviewed, and paid within a reasonable period of time after receiving services.
We also recommend that the Director, Headquarters Procurement Operations
Division, Office of Administration and Resources Management, require that
contracting officers properly document contract actions in contract files. These
officials agreed with these recommendations, although corrective actions are not
yet completed. We further recommend that the Director, Headquarters
Procurement Operations Division, obtain adequate support to pay the travel costs.
The Director disagreed that additional action was needed and offered an alternate
justification to support paying the travel costs. We have accepted the alternate
justification and consider that recommendation closed.

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