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%	/ OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Audit Report
EPA Did Not Fully Comply
With Guidance Regarding
OMB Circular A-123
Unliquidated Obligation Reviews
Report No. 11-1-0069
January 19, 2011

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Report Contributors:	Paul Curtis
Arthur Budelier
Cynthia R. Poteat
Robert Hairston
Sabrina Berry
Abbreviations
AA
Assistant Administrator
CFO
Chief Financial Officer
EPA
U.S. Environmental Protection Agency
FMFIA
Federal Managers' Financial Integrity Act
FY
Fiscal Year
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
OMB
Office of Management and Budget
RA
Regional Administrator
ULO
Unliquidated Obligation

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U.S. Environmental Protection Agency	11-1-0069
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|	\ Office of Inspector General	January 19 2011
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At a Glance
Why We Did This Review
We performed this review to
evaluate the U.S. Environmental
Protection Agency's (EPA's) fiscal
year (FY) 2009 Office of
Management and Budget (OMB)
Circular A-123 reviews of internal
controls over the unliquidated
obligation (ULO) review process.
Our objectives were to determine
whether EPA's regions and program
offices (1) complied with guidance
for conducting the FY 2009 A-123
reviews of the ULO review process;
and (2) reported their A-123 review
methodology, findings, and
corrective actions in their FY 2009
management integrity assurance
letters.
Background
The Federal Managers' Financial
Integrity Act (FMFIA) requires
federal agencies to report annually to
the President and Congress on the
effectiveness of internal controls.
OMB Circular A-123 guidance for
implementing FMFIA requires
federal agencies to assess internal
controls over financial reporting. In
prior audits, we reported on
problems EPA had in deobligating
funds no longer needed. In FY 2009,
EPA expanded its internal control
reviews to include ULOs.
For further information,
contact our Office of Congressional,
Public Affairs and Management at
(202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2011/
20110119-11-1-0069.pdf
Catalyst for Improving the Environment\
EPA Did Not Fully Comply With Guidance
Regarding OMB Circular A-123 Unliquidated
Obligation Reviews
What We Found
Seventeen of 22 EPA regions and program offices did not fully comply
with the guidance for conducting and reporting on their FY 2009 OMB
Circular A-123 reviews of internal controls over the ULO process.
OMB A-123 guidance requires agencies to assess the effectiveness of
internal controls over financial reporting. The Office of the Chief
Financial Officer (OCFO) requested offices to conduct a thorough
internal control review of their ULO review process. The following
factors contributed to EPA's noncompliance:
•	Some regions and program offices did not properly plan and
staff the reviews.
•	EPA's OCFO did not closely monitor the reviews.
•	Neither the OCFO nor the Assistant Administrators and
Regional Administrators held the review teams accountable for
performing the reviews.
EPA benefits from internal control reviews by identifying control
deficiencies and corrective actions for improvement. The reviews also
provide support for the Administrator's assurance statement on the
effectiveness of EPA's internal controls.
What We Recommend
We recommend that the Chief Financial Officer:
•	Develop and implement procedures to oversee the regional and
program office A-123 ULO internal control reviews.
•	Require regions and program offices to develop plans that
address staffing A-123 ULO reviews and training reviewers.
•	Develop an A-123 ULO review guide to assist those
conducting the reviews.
•	Implement standard performance measures to assess assurance
letter completeness and timeliness.
The Agency concurred with our findings and recommendations.

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< JflL ?
# . . . . . \	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
° VWV I	WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
January 19, 2011
MEMORANDUM
SUBJECT:
FROM:
EPA Did Not Fully Comply With Guidance Regarding
OMB Circular A-123 Unliquidated Obligation Reviews
Report No. 11-1-0069
Arthur A. Elkins, Jr.
Inspector General

TO:
Barbara J. Bennett
Chief Financial Officer
This is our report on the subject review conducted by the Office of Inspector General (OIG) of
the U.S. Environmental Protection Agency (EPA). 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. EPA
managers will make the final determinations on matters in this report in accordance with
established audit resolution procedures.
The estimated cost of this report, calculated by multiplying the project's staff days and expenses
by the applicable daily full cost billing rates in effect at the time, is $267,632.
Action Required
You concurred with the draft report recommendations and submitted an acceptable corrective
action plan and milestone dates. Therefore, we will close the report in our tracking system upon
issuance. We have no objections to the further release of this report to the public. We will post
this report to our website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Melissa Heist
at (202) 566-0899 or heist.melissa@epa.gov. or Paul Curtis at (202) 566-2523 or
curtis.paul@epa.gov.

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EPA Did Not Fully Comply With Guidance Regarding
OMB Circular A-123 Unliquidated Obligation Reviews
11-1-0069
Table of C
Chapter
1	Introduction		1
Purpose		1
Background		1
Noteworthy Achievements		3
Scope and Methodology		3
2	Most Regions and Program Offices Did Not Fully Comply with
Guidance Regarding A-123 Unliquidated Obligation Reviews		4
EPA Did Not Fully Comply with A-123 ULO Review Guidance		4
Several Factors Contributed to EPA's Noncompliance		5
Conclusions		6
Recommendations		7
Preliminary Agency Actions		7
Agency Comments and OIG Evaluation		8
Status of Recommendations and Potential Monetary Benefits		9
Appendices
A Details on Scope and Methodology	 10
B Agency Response to Draft Report	 11
C Distribution	 14

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Chapter 1
Introduction
Purpose
We performed this review to evaluate the U.S. Environmental Protection
Agency's (EPA's) fiscal year (FY) 2009 Office of Management and Budget
(OMB) Circular A-123 reviews of internal controls over the unliquidated
obligation (ULO) review process. The Office of the Chief Financial Officer
(OCFO) requested our review because FY 2009 was the first year it asked the
regions and program offices to conduct A-123 reviews of the ULO review
process. The objectives of our review were to determine whether EPA's regions
and program offices:
•	Complied with OCFO guidance for conducting the FY 2009 A-123
reviews of the ULO review process
•	Reported their A-123 review methodology, findings, and corrective
actions in their FY 2009 management integrity assurance letter
Background
The Federal Managers' Financial Integrity Act of 1982 (FMFIA) requires
agencies to establish and maintain a system of internal controls to reasonably
ensure that programs are protected from fraud, waste, abuse, and mismanagement.
FMFIA requires an annual assessment of internal controls and a statement of
assurance from agency heads to the President and Congress on the effectiveness
of internal controls over programmatic and financial operations.
OMB Circular A-123, Management's Responsibility for Internal Control, dated
December 21, 2004, describes federal managers' responsibilities for internal
control. Management is responsible for establishing and maintaining internal
control to achieve the following objectives:
1.	Effective and efficient operations
2.	Reliable financial reporting
3.	Compliance with applicable laws and regulations
Appendix A of the Circular requires federal agencies to separately assess
effectiveness of internal controls over financial reporting. The senior assessment
team must document the assessment process to include:
•	Assessing internal controls at the process, transaction, or application level.
•	Testing controls and related results.
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•	Identifying deficiencies.
•	Suggesting improvements.
The documentation should be available for review.
EPA Order 1000.24 CHG 2, Management's Responsibility for Internal Control,
outlines the roles and responsibilities of Agency personnel and organizations
charged with implementing FMFIA and A-123. Some of the key roles and
responsibilities are:
•	The Administrator: Responsible for providing an annual assurance
statement to the President and Congress on the overall adequacy and
effectiveness of the Agency's internal controls.
•	The Agency Senior Assessment Team: The team, which includes the
Chief Financial Officer (CFO), Assistant Administrators (AAs), and
Regional Administrators (RAs), is responsible for providing oversight and
accountability for the Agency's management integrity program and
internal controls over program operations and financial reporting.
•	The CFO: Provides annual management integrity and A-123 guidance to
the Agency and ensures that the appropriate organizational levels
implement FMFIA and A-123.
•	Management Integrity Advisors: These advisors, designated by the
Senior Assessment Team, disseminate pertinent management integrity
program information to the regions and program offices.
OCFO's management integrity guidance, Management Integrity: EPA's FY 2009
Responsibilities and Major Milestones, dated December 22, 2008, stated that EPA
was expanding its reviews of internal controls over financial activities to include
more regional and program office participation. OCFO's guidance requested that
all AAs and RAs conduct a more formal internal control review with supporting
documentation of their ULOs.
OCFO's supplemental guidance, FY 2009 Guidance for Conducting A-123
Internal Control Reviews of Unliquidated Obligations, dated March 18, 2009,
requested the AAs and RAs perform a thorough A-123 review of the ULO
process and supporting documents. FY 2009 was the first year that OCFO
requested the regions and program offices to conduct an A-123 ULO review. The
reviews were to determine whether:
•	Evidence was on file to support the decisions to deobligate or retain funds.
•	The review's sample size was large enough to provide the confidence
necessary to support the assurance statement.
•	The ULO reviewers followed standard operating procedures.
•	Internal controls identified in the standard operating procedures functioned
effectively.
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OCFO requested that the AAs and RAs discuss the A-123 review methodology,
findings, and corrective actions in their management integrity assurance letter due
August 14, 2009.
Noteworthy Achievements
Some regions and program offices achieved positive results from their internal
control reviews that may lead to improved future ULO reviews. For example, the
reviewers offered ways to improve the ULO reviews by:
•	Identifying control deficiencies and recommending corrective action.
•	Providing clarity and guidance on the types of documentation needed to
support decisions to retain or deobligate funds.
•	Proposing more effective techniques to research the ULOs and make
supportable decisions.
•	Identifying a need for project officers and contracting officers to monitor
the funding for their projects more carefully.
During our review, OCFO issued guidance for the FY 2010 management integrity
process and for conducting A-123 internal control reviews of financial activities.
The FY 2010 guidance was more detailed and easier to understand than the
FY 2009 guidance. The FY 2010 guidance included a management integrity
assurance letter template with specific instructions for the A-123 ULO review and
reporting requirements.
OCFO developed an FY 2010 assurance letter checklist to confirm whether the
regional and program offices addressed the required elements. OCFO also
provided several tools for the FY 2010 A-123 ULO reviews, such as a risk criteria
matrix and instructions for selecting a random sample.
OCFO provided Agency-wide A-123 training sessions on January 28, February 3,
March 31, and April 1, 2010. The training provided an overview of A-123
requirements and specific A-123 review techniques and concepts.
Scope and Methodology
We conducted this review in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the review
to obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our review objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our review objectives. We conducted our review from February through
September 2010. Appendix A contains a detailed discussion of our scope and
methodology.
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Chapter 2
Most Regions and Program Offices Did Not
Fully Comply with Guidance Regarding
A-123 Unliquidated Obligation Reviews
Seventeen of 22 EPA regions and program offices did not fully comply with the
guidance for conducting and reporting the FY 2009 A-123 ULO review of
internal controls. This occurred because:
•	Some regions and program offices did not properly plan and staff the
reviews.
•	OCFO did not closely monitor the reviews.
•	Neither OCFO nor the AAs and RAs held the review teams accountable
for their reviews.
•	OCFO's guidance was not clear.
•	Some personnel performing the A-123 reviews did not have a review
guide to ensure they performed a complete review.
•	Some personnel did not comply with all the reporting requirements.
The noncompliant reviews did not help EPA identify areas for improvement and
ensure the internal controls were effective. The review work in the noncompliant
regions and program offices did not support their assurance statements on internal
controls.
EPA Did Not Fully Comply with A-123 ULO Review Guidance
OCFO's management integrity guidance stated that EPA was expanding its
reviews of internal controls over financial activities to include more regional and
program office participation. OCFO's guidance requested that all AAs and RAs
perform a thorough A-123 review of the ULO process and supporting documents.
Seventeen of 22 EPA regions and program offices did not fully comply with the
guidance for conducting and reporting the FY 2009 A-123 ULO review of
internal controls. We considered a review to be incomplete if it did not:
•	Include sufficient testing and documentation to support the assurance
statement;
•	Report the review methodology, findings, and corrective actions in the
assurance letter; and/or
•	Complete the requirements by the assurance letter due date.
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Eight either did not perform a review or had no supporting documentation that a
review was performed. Six performed an incomplete review because they did not
comply with all the guidance. Three completed their reviews but reported the
results in an assurance letter addendum submitted after the August 14, 2009,
assurance letter due date.
The types of noncompliance included:
•	Not testing a sample of unliquidated obligations
•	Testing only the deobligations and not the retained obligations
•	Not maintaining supporting documentation for the samples tested
•	Conducting a review (by a contractor) that did not cover the FY 2009
period needed for the assurance statement
•	Not including an A-123 review discussion in the FY 2009 assurance letter
While the 22 regions and program offices certified completion of the ULO
reviews by June 30, 2009, and generally discussed the ULO review, 13 regions
and program offices did not report their A-123 review methodology, findings, and
corrective actions in their assurance letters as required.
Several Factors Contributed to EPA's Noncompliance
We identified the following causes of noncompliances:
•	Some regions and program offices did not properly plan and staff the
A-123 ULO reviews, train the reviewers, and perform the reviews.
Although many personnel said they did not understand the guidance, they
did not contact OCFO to ask questions or seek clarification about how to
fulfill their A-123 review responsibilities. Some personnel said they asked
questions about the guidance but did not receive satisfactory answers.
•	OCFO did not monitor the A-123 review process closely enough to detect
the compliance problems in a timely manner. OCFO communicated
primarily with the Management Integrity Advisors, who disseminated
guidance information to the regions and program offices. The OCFO
manager responsible for coordinating the A-123 reviews informed us that
OCFO did not require status reports from the A-123 review teams and was
not aware of the compliance problems until it received the assurance
letters.
•	OCFO and the regions and program offices did not have an effective
method to hold the A-123 review teams accountable for their reviews.
They did not have formal procedures to require regions and program
offices to plan and staff the A-123 ULO reviews, train the reviewers, and
submit status reports to OCFO and the AAs and RAs. They did not have
performance measures for assurance letter completeness and timeliness.
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For example, the U.S. Department of Defense uses a scorecard to rate
statements of assurance for timeliness, proper format, program execution,
training, and reporting material weaknesses.
•	OCFO's guidance was not clear because it did not always clearly
distinguish the A-123 internal control review guidance from the ULO
review guidance.
•	Some personnel performing the A-123 reviews did not have a review
guide to use as a tool to ensure they performed a complete review. A
review guide is a description or outline of the procedures undertaken or
particular work done. The review guide serves as a planning document and
a control on the work to be done. It serves to document the work
performed, completion dates, and information on the persons performing
the work.1
•	Although some personnel used the FY 2009 management integrity
guidance with the assurance letter template to help them meet the
reporting requirements, they did not comply with all the requirements for
the A-123 ULO review. For example, personnel who prepared the
assurance letters would have benefited from using a checklist to ensure
they included all financial reporting requirements in the assurance letter.
EPA regional and program office personnel offered several reasons why they did
not comply with the guidance for the FY 2009 A-123 ULO reviews, including:
•	OCFO's guidance was not clear and personnel did not understand the new
FY 2009 requirements. Some of the personnel overlooked parts of the
guidance and other personnel said they asked questions about the guidance
but did not receive satisfactory answers.
•	Personnel performing the reviews did not receive the training needed to
perform an effective A-123 review.
•	Regions and program offices did not have sufficient time or resources to
perform the review.
Conclusions
EPA achieved some positive results from its FY 2009 A-123 internal control
reviews of the ULO process that may lead to improved future ULO reviews.
Program and regional offices that performed the reviews identified control
deficiencies and recommended corrective actions. One region provided clarity and
guidance regarding the types of documentation needed to support
1 Kohler's Dictionary for Accountants, 6th Edition, Prentice Hall, 1983.
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retain/deobligate funding decisions. Finally, they proposed more effective
techniques to research ULOs and make supportable decisions. However, many
EPA regions and program offices did not fully comply with the review guidance
and perform complete reviews. Some regions and program offices did not
properly plan and staff the reviews. OCFO did not closely monitor the reviews
and neither OCFO nor the AAs and RAs held the review teams accountable.
OCFO's guidance was not clear. Some personnel performing the A-123 reviews
did not have a review guide to ensure they performed a complete review and some
personnel did not comply with all reporting requirements. As a result, EPA did
not properly determine and report whether the internal controls were effective.
Internal control reviews that do not fully comply with guidance are an internal
control deficiency. To correct the deficiency, EPA should conduct thorough
internal control reviews that ensure the controls are effective, comply with
applicable guidance, and support the annual assurance statement. EPA would
improve its A-123 ULO reviews by implementing headquarters oversight
procedures and promoting accountability for proper reviews in the regions and
program offices.
Recommendations
We recommend that the Chief Financial Officer:
1.	Improve accountability for the A-123 ULO reviews by developing and
implementing oversight procedures to promote accountability by the
regions and program offices and ensure the proper performance of their
A-123 reviews.
2.	Require AAs and RAs to develop plans for the design and staffing of the
A-123 ULO reviews and train the reviewers. Require AAs and RAs to
submit their review plans to OCFO on a standard form provided by
OCFO.
3.	Develop an A-123 ULO review guide to assist those conducting the
reviews.
4.	Implement performance measures for assurance letter completeness and
timeliness.
Preliminary Agency Actions
During our review, OCFO issued guidance for the FY 2010 management integrity
process and for conducting A-123 internal control reviews of financial activities.
The FY 2010 guidance was more detailed and easier to understand than the
FY 2009 guidance and included an assurance letter template with specific
instructions and reporting requirements. Since OCFO improved its A-123 review
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guidance in FY 2010 and developed a template and checklist for reporting
requirements, we did not make a recommendation for improving the guidance or
developing a checklist for reporting requirements.
During our review, OCFO addressed the need for training by conducting Agency-
wide A-123 training sessions. Therefore, we did not make a recommendation for
A-123 training.
Agency Comments and OIG Evaluation
EPA agreed with our recommendations and proposed acceptable corrective action
plans to address them. Appendix B provides the full text of the Agency's
comments.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
7 Improve accountability for the A-123 ULO reviews
by developing and implementing oversight
procedures to promote accountability by the
regions and program offices and ensure the proper
performance of their A-123 reviews.
7 Require AAs and RAs to develop plans for the
design and staffing of the A-123 ULO reviews and
train the reviewers. Require AAs and RAs to submit
their review plans to OCFO on a standard form
provided by OCFO.
7 Develop an A-123 ULO review guide to assist
those conducting the reviews.
7 Implement performance measures for assurance
letter completeness and timeliness.
Chief Financial Officer
Chief Financial Officer
Chief Financial Officer
Chief Financial Officer
Planned
Completion
Date
12/31/10*
12/31/10*
01/12/11**
12/31/10*
POTENTIAL MONETARY
BENEFITS (in $000s)
Claimed
Amount
Agreed To
Amount
1 0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
* The Agency has developed draft guidance that, as of January 5, 2011, was still in the signature chain for final approval; therefore, we consider these
recommendations to be in an open status
** The Agency issued an A-123 ULO review guide on January 12, 2011.
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Appendix A
Details on Scope and Methodology
We reviewed EPA guidance for conducting the FY 2009 A-123 ULO reviews. We interviewed
personnel and reviewed the management integrity assurance letters for EPA's 10 regions and
12 program offices. We examined the A-123 review supporting documentation for 10 selected
regions and program offices that had more complete narratives of results in the A-123 assurance
letters.
During our review, EPA issued FY 2010 A-123 review guidance and conducted A-123 training.
We compared the FY 2010 and FY 2009 guidance and reviewed the content of EPA's training
sessions to identify the improvements that EPA achieved in FY 2010.
We assessed EPA's internal controls related to the A-123 ULO reviews. We gained an
understanding of the internal controls through examination of management integrity assurance
letters, interviews with applicable region and program office personnel, and examination of
A-123 review supporting documentation for 10 selected regions and program offices.
We reviewed the following prior EPA OIG reports that had findings and recommendations
related to EPA's implementation of FMFIA or problems with deobligating funds no longer
needed.
Table A-1: Prior Reports Reviewed
Report Title
Report No.
Date
EPA Has Improved Efforts to Reduce Unliquidated
Obligations in Superfund Cooperative Agreements, But a
Uniform Policy Is Needed
09-P-0241
September 22, 2009
EPA Should Use FMFIA to Improve Programmatic
Operations
09-P-0203
August 6, 2009
EPA Should Strengthen Internal Controls over Interagency
Agreement Unliquidated Obligations
09-P-0086
January 26, 2009
EPA Should Continue Efforts to Reduce Unliquidated
Obligations in Brownfields Pilot Grants
08-P-0265
September 16, 2008
Source: OIG analysis.
Report No. 09-P-0203 disclosed that EPA offices had not developed strategies to assess the
effectiveness of their programmatic internal controls. OCFO had not devoted needed
resources to validate assurance letters. EPA agreed with the report's recommendations that
OCFO provide FMFIA training for managers and staff and revise the internal checklist for
validating Agency-wide FMFIA compliance. Report Nos. 09-P-0241, 09-P-0086, and
08-P-0265 disclosed Agency problems with deobligating unneeded funds. We used the
findings of these reports in conducting this review of FMFIA reviews of financial operations.
We did not evaluate whether EPA has taken appropriate corrective action to address the
findings and recommendations from these reports because they were not significant to our
review objectives.
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Appendix B
Agency Response to Draft Report
October 21, 2010
MEMORANDUM
SUBJECT: Response to the Office of Inspector General Draft Audit Report: EPA Did Not
Fully Comply With Guidance Regarding OMB Circular A-123 Unliquidated
Obligation Reviews, Project No. OA-FY10-A-0058, dated September 22, 2010
FROM: Barbara J. Bennett
Chief Financial Officer
TO:	Arthur A. Elkins, Jr.
Inspector General
Thank you for providing us with the opportunity to comment on and respond to the
findings and recommendations made in the "Draft Audit Report: EPA Did Not Fully Comply
With Guidance Regarding OMB Circular A-123 Unliquidated Obligation Reviews."
We appreciate the annual opportunity to provide project topics to your office, such as the
FY 2009 A-123 ULO review process, for improving operating efficiencies. We agree with the
findings and recommendations in the draft report; our corrective action plan is attached.
If you have any questions concerning the audit response, please contact Stefan Silzer,
Acting Director, Office of Financial Management, at (202) 564-5389 or Sandy Dickens of the
Office of Financial Management at (202) 564-0606.
Attachment
cc: MarkBialek
Melissa Heist
Paul Curtis
Arthur Budelier
Maryann Froehlich
Joshua Baylson
Stefan Silzer
David Bloom
Howard Corcoran
John Bashista
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Attachment
OCFO's Response to OIG Draft Report
"EPA Did Not Fully Comply With Guidance Regarding OMB Circular A-123
Unliquidated Obligation Reviews''
Project No. OA-FY10-A-0058, dated September 22, 2010
Rec.
No.
OIG Recommendation
Action
Official(s)
Proposed Corrective
Action
Proposed
Completion
Date
1.
Improve accountability for
the A-123 ULO reviews by
developing and
implementing oversight
procedures to promote
accountability by the regions
and program offices and
ensure the proper
performance of their
A-123 reviews.
OCFO/Office of
Financial
Management
(OFM)
OCFO agrees with this
recommendation.
1.1	OCFO will issue
Resources Management
Directives System (RMDS)
2520-03-P1,
Responsibilities for
Reviewing Unliquidated
Obligations.
1.2	OCFO will issue
FY 2011 Annual OCFO
Guidance which will
include ULO performance
measures.
11/1/10
12/31/10
2.
Require AAs and RAs to
develop plans for the design
and staffing of the A-123
ULO reviews and train the
reviewers. Require AAs and
RAs to submit their review
plans to OCFO on a standard
form provided by OCFO.
OCFO/OFM
OCFO agrees with this
recommendation.
2.1 OCFO will issue
FY 2011 A-123 guidance
which will require
AAs/RAs to: (1) develop
plans for the design and
staffing of the A-123 ULO
reviews and training for the
reviewers; and (2) submit
plans to OCFO on a
standard form provided by
OCFO.
12/31/10
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Rec.
No.
OIG Recommendation
Action
Official(s)
Proposed Corrective
Action
Proposed
Completion
Date
3.
Develop an A-123 ULO
review guide to assist those
conducting the reviews.
OCFO/OFM
and Office of
Budget (OB)
OCFO agrees with this
recommendation.
3.1 OCFO/OFM and OB
will jointly develop an
A-123 ULO review guide
to assist those conducting
the reviews.
1/31/11
4.
Implement performance
measures for assurance letter
completeness and timeliness.
OCFO/OFM
OCFO agrees with this
recommendation.
4.1 OCFO will issue a
checklist in the FY 2011
A-123 guidance.
12/31/10
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Appendix C
Distribution
Office of the Administrator
Chief Financial Officer
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, Office of Financial Management, Office of the Chief Financial Officer
Director, Office of Regional Operations
Audit Followup Coordinator, Office of the Chief Financial Officer
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