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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
EPA Needs Workload Data
to Better Justify
Future Workforce Levels
Report No. 11-P-0630
September 14, 2011

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Report Contributors:	Patrick Gilbride
Randy Holthaus
Raul Adrian
Lawrence Gunn
Kevin Lawrence
Abbreviations
EPA
U.S. Environmental Protection Agency
FTE
Full-time equivalent
FY
Fiscal year
GAO
U.S. Government Accountability Office
OAM
Office of Acquisition Management
OAR
Office of Air and Radiation
OB
Office of Budget
OCFO
Office of the Chief Financial Officer
OGD
Office of Grants and Debarment
OIG
Office of Inspector General
OMB
Office of Management and Budget
OPAA
Office of Planning, Analysis, and Accountability
OSWER
Office of Solid Waste and Emergency Response
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone: 1-888-546-8740	1200 Pennsylvania Avenue NW
fax:	703-347-8330	Mailcode 8431P (Room N-4330)
online:	http://www.epa.qov/oiq/hotline.htm	Washington, DC 20460

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.* *. U.S. Environmental Protection Agency	ii-p-0630
Office of Inspector General	September 14,2011
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At a Glance
Catalyst for Improving the Environment
Why We Did This Review
We sought to determine
whether the U.S. Environmental
Protection Agency (EPA) has
collected and used workload
data to determine its workforce
size, and whether there are
workload models that EPA
could use or benefit from when
trying to determine workforce
size.
Background
During the 1980s, EPA
conducted comprehensive
workload analyses to determine
appropriate workforce levels.
Around the early 1990s, EPA
discontinued these analyses
and, since then, it has adjusted
the size of its workforce via
incremental shifts. The U.S.
Government Accountability
Office and the EPA Office of
Inspector General have reported
on the importance of basing
workforce levels on workload.
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/
20110914-11-P-0630.pdf
EPA Needs Workload Data to Better Justify
Future Workforce Levels
What We Found
EPA has not collected comprehensive workload data or conducted workload
analysis in about 20 years. EPA does not require program offices to collect and
maintain workload data, and the programs do not have databases or cost
accounting systems in place to collect data on time spent on specific mission-
related outputs. Federal guidance and standards emphasize the importance of
planning work to determine staffing needs. Office of Management and Budget
guidance states that agencies should identify their workloads to help determine the
proper workforce size, and federal accounting standards require that agencies
establish cost accounting systems to allow them to determine resources consumed
for work performed. Without sufficient workload data, program offices are limited
in their ability to analyze their workloads and justify resource needs, and EPA's
Office of Budget must base budget decisions primarily on subjective justifications
at a time when budgets continue to tighten and data-driven decisions are needed.
Organizations of varying sizes and missions have used workload models for years
to justify resource needs. During our audit, we identified some basic concepts of
workload modeling from which EPA could benefit. EPA would need to tailor such
concepts to its own mission, structure, and culture.
What We Recommend
We recommend that the Chief Financial Officer conduct a pilot project requiring
EPA offices to collect and analyze workload data on key project activities. The
Chief Financial Officer should use information from the pilot project, along with
data from an ongoing contractor study, to issue guidance to EPA program offices
on how to collect and analyze workload data, the benefits of workload analysis,
and how the information should be used to prepare budget requests. EPA partially
concurred with our recommendations in its response to our draft report. EPA
stated that it needs time to collect more data and develop a final corrective action
plan with milestones for completion. Therefore, our report recommendations will
remain unresolved with resolution efforts in progress.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 14, 2011
MEMORANDUM
SUBJECT: EPA Needs Workload Data to Better Justify Future Workforce Levels
Report No. ll-P-0630
FROM: Arthur A. Elkins, Jr.
Inspector General
TO:
Barbara J. Bennett
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). 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 determination on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
The estimated direct labor and travel costs for this report are $451,155.
Action Required
The Agency partially concurred with recommendations 1 and 2, and these recommendations are
considered unresolved with resolution efforts in progress. Therefore, in accordance with EPA
Manual 2750 and ongoing resolution efforts, you are required to provide a written response to
recommendations 1 and 2, including a proposed corrective action plan, within 90 calendar days
of the report date. The response will be posted on the OIG's public website, along with our
memorandum commenting on the response. The response should be provided as an Adobe PDF
file that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of
1973, as amended. Please e-mail your response to Patrick Gilbride at Gilbride.Patrick@epa.gov.
The final response should not contain data that should not be released to the public; if the
response contains such data, the data for redaction or removal should be identified. 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,
Assistant Inspector General for Audit, at (202) 566-0899 or Heist.Melissa@epa.gov; or Patrick
Gilbride, Product Line Director, at (303) 312-6969 or Gilbride.Patrick@epa.gov.

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EPA Needs Workload Data to Better Justify
Future Workforce Levels
11 -P-0630
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Noteworthy Achievements		4
Scope and Methodology		4
2	EPA Needs to Collect Workload Data to Conduct Workload Analysis 		7
Federal Agencies Should Collect and Analyze Workload Data		7
EPA Does Not Collect Data to Conduct Workload Analysis		8
EPA Has Attempted to Analyze Its Workload Wth Limited Results		9
EPA Needs Processes or Systems to Track Time Spent on Projects		10
EPA Cannot Assure Resources Are Planned or Allocated in the
Most Efficient or Effective Manner		11
Conclusions		11
Recommendations		12
Agency Comments and OIG Evaluation		13
3	Various Workload Modeling Concepts and Workload Models
Used by Other Organizations		14
Basic Workload Modeling Concepts		14
Examples of Workload Models		15
Conclusions		17
Agency Comments and OIG Evaluation		17
Status of Recommendations and Potential Monetary Benefits		19
Appendices
A Details on Scope and Methodology		20
B Prior GAO and EPA OIG Reports		22
C Agency Response		23
D Distribution		30

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Chapter 1
Introduction
Purpose
In June 2010, the Office of Management and Budget (OMB) issued guidance
instructing each nonsecurity federal agency, such as the U.S. Environmental
Protection Agency (EPA), to submit a budget request 5 percent below its
discretionary spending total for fiscal year (FY) 2011. As federal budgets
continue to tighten, the need for federal agencies to justify the size of their
workforce is readily apparent. From 1999 to 2010, the number of full-time
equivalent (FTE) positions that Congress authorized provided to EPA decreased
over 5 percent, from 18,366 FTEs to 17,417.
The purpose of this audit was to determine whether EPA has collected and used
workload data to justify the size of its workforce. We also sought to identify any
workload analysis concepts or models from which EPA could benefit.
Background
For an organization to operate efficiently and effectively, it must know what its
workload is. While there is no one exact definition of workload, it is commonly
thought to be the amount of work assigned to, or expected to be completed by, a
worker in a specified time period. Workload that is set too high or too low can
negatively affect overall performance. The main objectives of assessing and
predicting workload are to achieve an evenly distributed, manageable workload
and to accurately determine the resource levels needed to carry out the work.1
Workload data, for purposes of this report, consist of two components:
(1) identified activities that must be conducted to complete a project or work
effort, and (2) the actual or estimated time it takes to perform each of the
identified activities. Workload data are a required component of workload
analysis or modeling. Workload modeling is an analytical technique used to
measure and predict workload. Because there is no one agreed-upon definition of
workload, there is no one agreed-upon method of assessing or modeling
workload.2
During the 1980s, EPA conducted comprehensive workload analyses to determine
appropriate workforce levels. EPA used approximately 70 models, and each
1	EPA had not previously defined the term "workload." As a result, we used common industry definitions
pertaining to workload.
2	EPA had not previously defined the term "workload modeling/' As a result, we used common industry
definitions pertaining to workload data and workload modeling.
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model used different factors and equations to estimate workload. The models
focused on how regional offices implement programs. Because the workload was
spread across all program elements, each region typically played a part in every
model. EPA used the models each year to evaluate the need to adjust FTEs based
on changes from the preceding year. EPA then went through a consensus call
process to see whether the regions agreed on the results of the model. When the
regions reached consensus, EPA allocated the resources.
According to EPA personnel, around the early 1990s, the Deputy Administrator
decided that EPA would discontinue such analyses. EPA managers and staff
thought that the consensus process had become overly burdensome and time
consuming, and focused on small changes to FTEs. Another perception was that
regions did not always use the personnel as allocated. As EPA's programs were
maturing and becoming more established, budgets began to level off. Since the
early 1990s, EPA has adjusted the size of its workforce via incremental shifts
from prior-year levels (table 1).
Table 1: Change in FTEs from 1999 to 2010
Year
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
FTE
18,366
18,100
18,000
17,832
17,802
17,909
17,759
17,631
17,560
17,324
17,252
17,417
Source: EPA Office of the Chief Financial Officer.
Many Offices Contribute to EPA's Budget Formulation and Execution
The Office of Budget (OB) within the Office of the Chief Financial Officer
(OCFO) is responsible for formulating and executing the budget, and issuing
annual planning and budget memoranda. It also takes the lead on discussing and
determining workforce levels, evaluating emerging issues, and determining
administrative priorities.
EPA's Office of Planning, Analysis, and Accountability (OPAA), along with OB,
works to integrate goal-based decisionmaking into the allocation of Agency
resources. The Agency does this through multiyear and annual planning in the
budget process. OPAA staff designs, develops, implements, and maintains an
Agency-level process for identifying, collecting, analyzing, and reporting
performance and resource information as required by the Government
Performance and Results Act.
The EPA Administrator and 12 Assistant Administrators in headquarters program
offices are national program managers who control resources. National program
manager responsibilities include planning, formulating, and justifying budgets for
national and regional EPA programs, adjusting national program budgets (e.g.,
headquarters/regional splits) as needed, and preparing program operating
guidance. EPA also has 10 Regional Administrators who are responsible for
regional administration and budget execution for all programs in the states and
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territories within their region. Regional Administrators coordinate with national
program managers on budget formulation and execution.
EPA Has Conducted Workload Studies in Last 5 Years
Since 2005, EPA offices have studied workload issues at least six different times
(table 2). However, for the most part, EPA has not used the findings resulting
from the workload assessments. According to EPA, the results from the
completed studies were not feasible to implement. These studies are discussed in
greater detail in chapter 2.
Table 2: EPA workload analysis studies since 2005
EPA office
Conducted by
Date completed
Outcome
Office of Grants
and Debarment
Contractor
April 2005
Report: Management of
Assistance Agreements at the
Environmental Protection Agency:
Workload Analysis and Models
OCFO
Contractor
June 2006
Report: Environmental Protection
Agency: Workload Assessment
and Benchmarking Options
Office of Research
and Development
EPA + Contractor
November 2006
Administrative Efficiencies Project
Office of Acquisition
Management
EPA
June 2007
No report produced; project
discontinued
Office of Solid
Waste and
Emergency
Response
EPA + Contractor
December 2008
Report: Superfund Workload
Assessment Report
OCFO
Contractor
Estimated
completion
September 2011
Contractor to provide suggestions
on how EPA could develop a
model
Source: Data obtained from EPA offices listed.
EPA paid contractors nearly $3 million related to five of the six workload studies
conducted since 2005. Contractors produced reports for EPA in each of those five
instances, but EPA generally did not take action.
OMB Requires EPA to Reduce its 2012 Budget Request by 5 Percent
On June 8, 2010, OMB issued guidance to federal agencies regarding FY 2012
budget submissions. OMB instructed each nonsecurity agency, such as EPA, to
submit a budget request 5 percent below its discretionary spending total for
FY 2011. Rather than reducing spending across the board, OMB informed
agencies that they were to restructure operations by (1) eliminating programs that
have a low impact on an agency's mission so that resources can be freed up to
continue investments in priority areas even as overall budgets are constrained,
(2) reengineering staffing plans and other processes to squeeze waste out of
existing operations and produce better outcomes, and (3) focusing management
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attention on high-priority performance goals to better deliver services to the
American people using available resources. OMB's guidance also stated that the
FY 2012 budget submissions should include analysis and evidence showing the
effects of any reductions and explaining why reductions were warranted.
Noteworthy Achievements
EPA has taken steps to improve workforce planning. In 2009, OCFO awarded a
contract to study best practices for identifying appropriate workforce size based
on workload. The study is targeting key EPA functions: (1) regulatory
development, (2) scientific research, (3) enforcement, (4) financial management,
(5) environmental monitoring, and (6) permitting. The results of this effort,
however, have yet to be determined.
Scope and Methodology
We conducted our audit from March 2010 to March 2011 in accordance with
generally accepted government auditing standards. Those standards require that
we obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our evaluation objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our objectives.
During our work, we reviewed:
•	Laws, regulations, guidance, and other background data related to
workload and workforce planning, including OMB circulars and Office of
Personnel Management documents
•	National program manager guidance from the program offices
•	EPA's Annual Commitment System as well as some regional annual
commitment documents
•	Budget justification documents that the Office of Air and Radiation
(OAR), the Office of Solid Waste and Emergency Response (OSWER),
and the Office of Water (OW) submitted to OCFO for FYs 2009-2011
•	Prior studies and reports on workload analysis that EPA and its contractors
conducted
•	Prior audit work performed by the U. S. Government Accountability Office
(GAO) and EPA's Office of Inspector General (OIG)
During our audit, we interviewed managers and staff from seven headquarters
offices and four regions. We also interviewed the Associate Administrator for
OMB's Office of Federal Procurement Policy. See appendix A for further details
on our scope and methodology, including a list of the offices we visited.
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Prior Audit Reports
Prior reports by both GAO and the EPA OIG have highlighted the importance of
managing resources and workload effectively, and identified instances in which
inadequate resource management hindered EPA in fulfilling its mission. See
appendix B for a detailed listing of such reports.
GAO
In GAO-10-413, Workforce Planning: Interior, EPA, and the Forest
Service Should Strengthen Linkages to Their Strategic Plans and Improve
Evaluation, issued in March 2010, GAO found that EPA's process for
allocating resources involved making annual incremental adjustments to
prior-year allocations and did not directly link to workforce plans. GAO
concluded that EPA has not comprehensively analyzed its workload and
workforce to determine the optimal numbers and distribution of staff
Agency-wide since the late 1980s.
In GAO-09-434, Environmental Protection Agency: Major Management
Challenges, issued in March 2009, GAO reported that EPA had struggled
for several years to identify its human resource needs and to deploy its
staff throughout the country in the most beneficial manner. GAO found
that EPA's process for budgeting and allocating resources did not fully
consider the Agency's current workload, and that in preparing requests for
funding and staffing, EPA made incremental adjustments largely based on
an antiquated workforce planning system that did not reflect a bottom-up
review of the nature or distribution of the current workload. Moreover,
EPA's human capital management systems had not kept pace with
changing legislative requirements and priorities, changes in environmental
conditions in different regions of the country, and the much more active
role that states now play in carrying out day-to-day-activities of federal
environmental programs.
EPA OIG
In OIG Report No. 1 l-P-0031, EPA Needs to Strengthen Internal Controls
for Determining Workforce Levels, issued December 20, 2010, we
concluded that EPA's policies and procedures do not include a process for
determining employment levels based on workload as prescribed by OMB.
We recommended, among other things, that OB amend its guidance to
require that the Agency complete a workload analysis for all critical
functions to support the Agency's budget request for FTEs.
In OIG Report No. 2005-P-00006, Office of Acquisition Management Can
Strengthen Its Organizational Systems issued February 17, 2005, we
concluded that EPA's Office of Acquisition Management (OAM) needed
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to perform workload and workforce analysis to identify FTE and skill
gaps. The report stated that OAM did not have data to measure its progress
toward achieving its vision of being the preferred business partner for all
EPA contracts. OAM also could not determine the percentage of EPA
contracts managed by its own personnel.
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Chapter 2
EPA Needs to Collect Workload Data to
Conduct Workload Analysis
EPA has not collected comprehensive workload data or conducted workload
analysis in about 20 years. EPA does not require program offices to collect and
maintain workload data, and the programs do not have databases or cost
accounting systems in place to collect data on time spent on specific mission-
related outputs. Federal guidance and standards emphasize the importance of
planning work to determine staffing needs. OMB guidance states that agencies
should identify their workloads to help determine the proper workforce size, and
federal accounting standards require that agencies establish cost accounting
systems to allow them to determine resources consumed for work performed.
Without sufficient workload data, program offices are limited in their ability to
analyze their workloads and justify resource needs, and EPA's OB must base
budget decisions primarily on subjective justifications at a time when budgets
continue to tighten and data-driven decisions are needed.
Federal Agencies Should Collect and Analyze Workload Data
We reviewed federal guidance and standards pertaining to preparing budgets.
These documents address the importance of workload in determining resource
needs. The Statement of Federal Accounting Standards No. 4 also contains
information relating to the need for agencies to account for the cost of the services
they provide, including the cost of labor (i.e., FTEs consumed).
OMB Circular A-l 1, Preparation, Submission and Execution of the Budget,
issued July 2010, suggests that calculations should be made to convert workload
estimates to required personnel. Those estimates should include available work
hours per employee. The circular specifically states that budget submissions
"must identify the human capital management and development objectives, key
activities, and associated resources that are needed to support agency
accomplishment of programmatic goals."
OMB Guidance Memorandum M-09-26, Managing the Multi-Sector Workforce,
issued July 2009, instructs agencies to determine the mix of skills and amount of
labor needed for the agency to perform efficiently and effectively. Agencies
should take into account the mission, functions, desired performance standards,
and workload. The memorandum also states that each federal agency should
conduct a pilot human capital analysis of at least one program, project, or activity
for which the agency has concerns about the extent of reliance on contractors. The
pilot will provide agencies with an opportunity to develop processes and practices
that support the broader vision of multisector workforce management.
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The Statement of Federal Financial Accounting Standards Number 4—issued by
the Federal Accounting Standards Advisory Board—relates to managerial cost
accounting concepts and standards for the federal government. It states that
information on the costs of program activities can be used as a basis to estimate
future costs in preparing and reviewing budgets. The statement requires federal
agencies to establish cost accounting systems to allow them to determine the full
cost, in terms of resources consumed, of the services and products they provide.
EPA Does Not Collect Data to Conduct Workload Analysis
Workload data generally do not exist within the program offices we reviewed.
Although program offices were aware of overall work outputs they plan to
accomplish in a given year, they were not able to determine resource needs at the
task level based on quantitative analysis. For example, a program office may
know the number of permits it needs to issue in a given year, but it does not have
data relating to the resources used to issue specific types of permits in the past.
We reviewed budget documents for FYs 2009-2011 that OAR, OW, and OSWER
prepared to support their budget requests. We found that those program offices
submitted budget requests based on subjective estimates; we were not provided
any form of quantitative support for the requests. We found little correlation
between program office requests and OCFO's budget recommendations. The lack
of program office workload data contributed to the differences between the
offices' proposed estimates and the FTE levels that OB approved.
For example, in FY 2009 budget documents, OAR cited potential negative
impacts that a reduction in funding would cause to its air toxics program.
However, OAR did not provide any quantitative analysis of the program's
operations and FTE costs with its narrative. For FY 2010, OAR proposed
increased funds and FTEs for the Agency's homeland security program, one of
the EPA Administrator's top priorities. However, OAR again did not support the
proposed increases with workload data or an analysis of the program's costs. This
lack of support was evident in all the budget documents we reviewed for OAR,
OW, and OSWER. Without workload data, EPA cannot determine, and
quantifiably support in budget documents, the resource needs for planned work.
EPA has prepared estimates in recent years to support budget requests for
additional FTEs in some high-priority work areas, including energy permitting,
Chesapeake Bay, and mountaintop mining. Those estimates were also based on
subjective formulas developed by subject-matter experts. Relying solely on
subject-matter experts, without using actual workload data, increases the
likelihood for inaccurate resource projections.
For example, Region 8 experts initially determined that the region needed about
20 FTEs to alleviate a growing backlog of energy permits. In the end, however,
Region 8 was able to eliminate the backlog with just six new FTEs that OCFO
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provided to the region. Region 8 worked with OB and other experts nationally to
develop its estimate; however, they had no quantifiable data on past resource
needs for energy permitting from which to draw. Region 8 does not have a system
in place to track the time and cost for energy permitting activities and could have
developed a better national estimate if it and each region had actual data on
resource availability and needs.
We also identified isolated examples of data systems that some EPA water
programs could use for workload analysis. Region 3's Water Protection Division
has been using a Permit Tracking System since 2000. While the system does not
track the number of hours spent by Region 3 personnel on individual tasks, the
system does track the different stages and milestones of the permit review
process. The system contains comprehensive technical information on the water
permits themselves, and identifies the permit reviewer and the review workloads
and backlogs based on permit expiration dates. In another example, Region 4's
Water Protection Division developed a pilot workload database that tracks
resources assigned to projects for endangered watersheds. The database has been
in use for about a year and contains information on staff and FTEs assigned to
each watershed project. Region 4 Water Protection Division supervisors update
this information every time they reach a project milestone. EPA personnel,
however, told us that they did not use data from these systems to support the
resource estimates we reviewed. According to EPA, while these systems were
designed to track work progress, they do contain data that could be useful for
conducting workload analysis.
EPA Has Attempted to Analyze Its Workload With Limited Results
EPA has taken steps in recent years that indicate it understands the importance of
having a workload analysis process. Various EPA offices have studied how to
develop methods for analyzing workload. For the most part, however, EPA has
not used the results of those efforts.
In 2005, EPA's Office of Grants and Debarment (OGD) contracted with a firm to
identify the workload drivers that affect the work of grant specialists and project
officers. EPA paid the contractor about $220,000, and OGD took action on certain
suggestions from that report. However, OGD did not adopt a comprehensive
process for collecting and analyzing workload data as a result of the study.
Although the OGD director placed some value in the study and the contractor's
suggested workload model, he acknowledged during our field work that the study
needs to be updated. One regional grants manager stated that he did not believe
the numbers generated by the study's suggested model were reliable and that the
model did not allow for changes, such as the addition of new programs. The OGD
director told us that his office is currently working to develop updated alternatives
for analyzing its workload.
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In 2006, OCFO contracted with a firm that issued a report to EPA on workload
and workforce planning methods used by nine federal agencies. The contractor,
which EPA paid $92,000, recommended that EPA draw from the ideas and
methodologies in the study to develop its own approach for assessing staffing in
relation to workload. OCFO did not take action on that report recommendation.
The OB deputy director told us that her office felt additional information was
needed to make any decisions on this matter. As a result, OB contracted in 2009
with another firm for an additional study.
In 2006, OSWER began a 2-year effort involving over 200 EPA managers and
staff to study its workload, issuing a report in December 2008. OSWER paid a
contractor over $1.7 million for assistance with the study, in addition to the time
and cost of over 200 EPA employees who participated. The study found that
regional staffing levels were not proportional to future workload demands.
OSWER ultimately did not take action on the results of the study. The Superfund
board of directors decided that moving or rebalancing personnel resources across
regions would likely produce substantial disruption. The board stated that such a
disruption could cause a decrease in national output, at least in the short term, and
was unadvisable.
In 2007, OAM spent about a year trying to develop a workload model for its
contracting staff, but was unsuccessful and abandoned the effort. OAM informed
us that its attempted model was too cumbersome to use because there were too
many variables, and that it would not have provided reliable output.
In 2009, OCFO contracted with a firm to summarize the pros and cons of
different processes and issues relating to workload analysis. The basic contract
has a value of $607,024, with options that can be exercised that would raise the
total to $713,369. According to EPA, the contractor will be summarizing the pros
and cons of different processes and issues relating to workload analysis. EPA
hopes to better understand some of the variables (functions, techniques,
structures, etc.) related to workload analysis not currently being used at EPA
during work planning. The contractor is about 6 months behind schedule, and
EPA currently expects the work to be completed by September 2011.
EPA Needs Processes or Systems to Track Time Spent on Projects
Systemic workload data do not exist at EPA because most of the Agency's
programs either do not have or do not use databases or cost accounting systems
for employees to charge their time to specific activities. To meet federal financial
accounting standards, EPA tracks costs at a high level—the program/project level.
EPA currently tracks costs for about 140 program/projects. A program is defined
as what EPA does based upon specific statutory authority, and a project is defined
as a significant task or problem the Agency is addressing. Examples of current
program/projects include Indoor Air: Radon Program, Superfund: Enforcement,
and Research: Water Quality. Within most of these 140 program/projects, EPA
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personnel are engaged in many activities, resulting in many significant outputs
and deliverables. EPA's tracking of costs at the program/project level is at too
high a level to be useful for workload analysis.
EPA managers indicated that doing a comprehensive workload analysis like those
done decades ago, including tracking the hours that people work on specific
activities, would be an inefficient use of limited EPA resources. We found,
however, that when required, the Agency tracked and accounted for each hour
spent by over 240 employees on the Deepwater Horizon oil spill response effort
in the Gulf of Mexico in 2010. In June 2010, the Region 6 Comptroller's office
issued guidance to employees on how to charge time spent on the oil spill
response. EPA's funding to respond to the oil spill came from a reimbursable
authorization that the U.S. Coast Guard provided. According to the Region 6
guidance, the authorization established allowable tasks and a site identification
code to enable the region to capture costs associated with the oil spill response.
The guidance stated the importance of being able to track and account for all
expenditures for potential cost recovery from responsible parties. According to
data that the Region 6 Comptroller provided us, as of the end of August 2010,
over 240 employees had charged approximately 32,067 hours, or 15.4 FTEs, to
the oil spill response. This example indicates EPA's ability to track time spent on
projects and activities when it is required.
EPA Cannot Assure Resources Are Planned or Allocated in the
Most Efficient and Effective Manner
Without sufficient workload data, program offices have limited ability to analyze
workload and determine adequate FTE levels to carry out their mission. Program
offices also cannot analytically justify the need for more resources or assure
existing resources are used in the most efficient and effective manner. As a result,
OB has to rely primarily on subjective justifications at a time when budgets
continue to tighten and data-driven decisions are needed.
Sound workload analysis based on sufficient and reliable data can help assure that
the highest-priority work is completed. Workload analysis could also highlight
areas where EPA could use resources more effectively.
Conclusions
EPA is basing its resource needs primarily on subjective data. It does not have the
systems to collect and maintain quantifiable workload data. Program managers
believe they cannot influence budget allocations and believe developing models
or data systems would not be a wise use of time. Therefore, programs continue to
depend on experienced staff and subject-matter experts to estimate workload and
resource needs. We acknowledge the high value of experienced staff and subject-
matter experts, and believe their input should always be an important component
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of workload analysis. However, discretionary budget allocations are better
justified when supported by accurate, timely, and complete data.
In the examples we reviewed, EPA's efforts to identify its workload were too
broad, resource intensive, and/or complex. For example, the current contract that
OCFO is using is designed to provide feedback that will broadly look at EPA as a
whole from a top-down management perspective. We believe EPA would benefit
from a bottom-up approach. Workload should be collected and analyzed first at
the level at which it is conducted. That information can then move upward
through management until a budget request is submitted. We also believe that a
broad, one-size-fits-all approach is unrealistic for a diversely structured agency
like EPA. We believe that this broad approach is a primary reason prior attempts
were unsuccessful and ultimately discontinued.
In addition, we learned that workload models containing too many variables
(workload drivers) were complex and did not provide reliable data. Therefore,
workload analysis may be more useful if the process is simplified and carried out
at a project level within the larger programs. However, EPA cannot undertake
workload modeling without workload data.
Considering the current economic climate and declining budgets, workload
analysis and resource estimates must be as accurate as possible. Further, when
EPA's expert employees retire or leave for other reasons, substantial workload
knowledge is potentially lost. Therefore, EPA programs should develop systems
to collect and maintain quantifiable workload data. This information, combined
with input from EPA's experts, will substantially improve the accuracy and
transparency of workload analysis.
Recommendations
We recommend that the Chief Financial Officer:
1.	Conduct a pilot project requiring EPA organizations to collect and
analyze workload data on key project activities.
2.	Use information learned from the pilot and the ongoing contracted
workload study to issue guidance to EPA program offices on:
a.	How to collect and analyze workload data
b.	The benefits of workload analysis
c.	How this information should be used to prepare budget
requests
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Agency Comments and OIG Evaluation
EPA partially concurred with both of our recommendations. Regarding
recommendation 1, EPA stated that it is following up on recent air and water
workload pilot projects conducted by Regions 1 and 6, and it is continuing to look
at how other organizations collect and analyze workload data and use workload
methodologies.
Regarding recommendation 2, EPA stated that the ongoing workload
survey/benchmarking study, to be completed in September 2011, will include
input from over 1,000 managers, informational interviews with other agencies that
manage similar functions, and discussions with over a dozen similar agencies
about what workload tools they employ. EPA also said that it would explore the
use of external variables such as population, land area, gross domestic product,
and/or other reliable and available environmental or public data to help better
understand major drivers for EPA's geographic workload.
EPA also stated that it would use perspectives gained from the pilots, its
contractor study, and geographic analyses to develop intelligent, cost-effective
options for strengthening its planning processes. EPA stated that its paramount
goal is to consider how to best use increasingly limited resources when making
decisions and conducting evaluations. However, OCFO also stated that it cannot
commit to issuing detailed guidance to the rest of the Agency on collecting and
using workload data until it has developed or found viable methodologies for
EPA's functions.
We recognize that EPA is in the process of studying this issue and is taking steps,
including its recent pilots in Region 1 and Region 6, that will help the Agency
make decisions regarding how best to allocate its resources in the future. We also
believe, however, that EPA should fully commit to analyzing the Agency's
workload, since EPA has revisited this issue with various studies over the last
6 years. EPA must provide the OIG a specific plan within 90 days after issuance
of this report that includes milestone dates for completing its corrective actions.
Until EPA does so, we will consider our recommendations to be unresolved.
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Chapter 3
Various Workload Modeling Concepts and
Workload Models Used by Other Organizations
Organizations of varying sizes and missions have used workload models for years
to analytically justify resource needs. Federal and state agencies, such as the U.S.
Department of State, the Internal Revenue Service, the U.S. Army, and the
Washington State Department of Ecology, have used workload models to help
determine resource needs.3 Private-sector entities such as hospitals, academic
institutions, and firms in other industries have also used workload models. Based
on concepts used by other organizations, EPA could benefit from using a model
or models tailored to its own mission, structure, and culture.
Basic Workload Modeling Concepts
We reviewed examples of workload analysis from external sources, including the
State Department and the Washington State Department of Ecology. We also
looked at EPA's prior efforts to study its own workload. Finally, we consulted
various publications on the subject of workload analysis. As a result, we identified
the following key concepts that EPA should consider as it decides how best to
develop a model or models for its use:
•	Workload models help to logically and analytically justify requests for
resources.
•	Responsible officials must clearly communicate the need for, and impact
of, resource requests.
•	Three common elements in most workload models, in sequence, are
identifying activities (individual tasks necessary to meet the
driver/output), identifying drivers (measurable events or outputs
associated with a particular function), and determining the duration (the
time it takes to accomplish an activity).
•	Durations can be determined using several different methods and can be
affected by many variables. For transactional-type activities, developing a
guide for estimating average times could be helpful. For activities of a less
predictable nature, the best option is to track duration data over time to
develop realistic estimates based on history.
•	An organization should determine its mission-critical functions first and
conduct workload analyses for them. Administrative support positions
should be analyzed last, because they generally depend on the functions
and workload that they support.
3 EPA's 2006 contracted study on workload assessment and benchmarking documented the methods used
by the Internal Revenue Service and the U.S. Army.
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•	It is crucial to have a good understanding of which tasks can be quantified,
and which are more qualitative or subjective in nature.
•	In a complex organization, such as EPA, a single, standard workload
model is not practical or feasible. Rather, local units should adopt an
approach that fits their mission and operations.
•	A consistent timeframe should be established for running the models,
perhaps every 2 years. Longer horizons generally will result in less
accurate projections.
Examples of Workload Models
We reviewed some examples of workload models from sources outside of EPA as
well as the attempts that EPA made to analyze workload issues. Below are some
concepts and details from the U.S. Department of State and the Washington State
Department of Ecology examples, as well as two EPA examples. These examples
incorporate concepts that EPA should consider when developing any future
models.
State Department
The State Department has used workload analysis to justify its resource needs
since 1996. In a June 2006 benchmarking study conducted for EPA by a
contractor, State was considered a valid benchmark for EPA. In fact, the
contractor identified the State Department in its study as most relevant to EPA
based on three main criteria: agency functions, data update cycles, and
predictability of workload changes. State had about 17,000 domestic employees in
2006, about the same number as EPA. Key among the features of the State
Department model are:
•	Employing separate models for domestic staff and overseas staff
•	Completing the administrative/support functions in its models last,
after the mission-related parts of the model are determined
•	Running its models every 2 years
The State Department was able to use its models to analytically justify the need
for more resources and received them during 2002-2004.
Washington State
In 2001, the Washington State Department of Ecology produced an assessment of
the workload required to meet a 15-year schedule of work to address polluted
waters, as contained in a memorandum of agreement with EPA. As a followup,
the department again assessed workload in 2006, resulting in an updated set of
recommendations and proposals for resource needs to more efficiently achieve its
workload demands. Other features of this study were that the department:
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•	Used raw data to identify the number of impaired water bodies
•	Determined which measures could be quantified
•	Developed formulas differing by complexity or type of activity to
estimate resources for some of the tasks that could be quantified
•	Used past experience to determine FTE needs for some of its work
relating to impaired waters
•	Established an accountability team charged with improving the flow of
communication and establishing a system for tracking and maintaining
workload data
EPA's Superfund Workload Assessment
OSWER conducted a study beginning in 2006 of its Superfund program
resources. Some of the main features of the study were that OSWER:
•	Used a rigorous methodology that broke down the analysis into the
following categories:
>	Work elements—activities with a common purpose/output
>	Outputs—the end product for each work element
>	Pricing factors—an estimated measure of the effort
required, expressed in work years
•	Used available EPA databases when possible
•	Grouped sites by resource intensity (low, medium, high)
•	Assigned a full pricing factor to planned work elements, and half of a
pricing factor to work elements underway, to determine annual work
years needed per site
•	Estimated the total work years for a typical site by combining the
above data on work elements and pricing factors with activity data in
databases
•	Looked at workload as a whole, including in all the regions, and then
distinguished between work to be performed by in-house resources
versus through contracts and grants
•	Developed estimates of FTE needs based on workload allocation
projections for each of the 10 regions
EPA's Study on Assistance Agreements Workload
OGD contracted out for a study related to workload issues for managing
assistance agreements. The contractor's report, issued in April 2005, produced
recommendations aimed at achieving efficiencies by streamlining the workload of
grants specialists and project officers. The contractor also provided templates for
OGD to use in determining future allocations of work and resources for grants
specialists and project officers. Relevant features of this study were that EPA:
•	Developed separate grant specialist and project officer workload
models for EPA
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•	Measured all activities associated with the preaward, award, and
postaward monitoring phases for grants, cooperative agreements, and
interagency agreements, totaling about 325 total activities
•	Categorized activities as either core, noncore, or other activities
•	Used data from EPA's Integrated Grants Management System, EPA
documents such as grants management policies, interviews with EPA
personnel, Web-based surveys of grant specialists and project officers,
an organizational questionnaire for grants management officers, and
knowledge of practices in other agencies
Conclusions
Workload analysis is the key to attaining a meaningful, data-driven, resource
allocation system. Organizations of various sizes, including some larger than
EPA, in both the private and public sectors, have successfully used workload
modeling for many years to justify their decisions on how resources are allocated
and used. In the last 20 years, EPA's mission and workload have changed and
expanded significantly. In an era of diminishing budgets, EPA should implement
policies that promote and support workload data gathering and analysis at the
program and regional levels. Such policies will result in more effective resource
allocation decisions.
Agency Comments and OIG Evaluation
In its response, EPA stated that it does not dispute that many organizations use
detailed workload models to plan resources for specific, clearly defined, and
repeatable tasks. EPA stated that what is at issue is whether EPA can cost-
effectively adapt existing models or develop new models for the many different
functions and processes that EPA manages. EPA is looking for workable models
and has piloted efforts in Region 1 and 6, but stated that designing useful
workload models for complex, nonrepeatable, and evolving tasks is difficult and
expensive. In its most recent pilot, EPA Region 6 reported that staff devoted
160 hours to analyze the workload of 35 FTE. EPA stated that if extrapolated for
EPA as a whole, analyzing the workload of the Agency's FTEs would require
37 FTE and nearly $5 million in payroll costs. As a financial manager, EPA said
that it must the weigh the costs of developing such systems with the benefits to
informing decisionmaking.
We agree that any models that EPA uses in the future should be practical and cost
effective. That said, if EPA's extrapolated figures are accurate, that would mean
that EPA could potentially spend 37 FTE out of 17,417 (2010 FTE level), or just
0.2 percent of EPA's total FTE, to determine the best allocation of the other
99.8 percent of FTE. Further, the pilots that EPA conducted in Region 1 and
Region 6 were resource intensive because there was no process in place to gather
the data, and the data were not readily available. As workload data are more
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routinely collected and tracked, and methodologies for analyzing it are improved,
the burden for conducting such analyses should be reduced in future years.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Planned
Completion
Action Official	Date
12 Conduct a pilot project requiring EPA organizations to
collect and analyze workload data on key project
activities.
Chief Financial Officer
Claimed
Amount
Agreed To
Amount
2 12 Use information learned from the pilot and the ongoing U Chief Financial Officer
contracted workload study to issue guidance to EPA
program offices on:
a.	How to collect and analyze workload data
b.	The benefits of workload analysis
c.	How this information should be used to
prepare budget requests
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
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Appendix A
Details on Scope and Methodology
We conducted our audit from March 2010 to January 2011 in accordance with generally
accepted government auditing standards. Those standards require that we obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
evaluation objectives. We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our objectives.
During our audit, we reviewed:
•	Laws, regulations, guidance, and other background data related to workload and
workforce planning, including OMB circulars and Office of Personnel Management
documents
•	National program manager guidance from the program offices
•	EPA's Annual Commitment System, as well as some regional annual commitment
documents
•	Budget justification documents that OAR, OSWER, and OW submitted to OCFO for FYs
2009-2011
•	Prior studies and reports on workload analysis that EPA issued or had conducted by
contractors
•	Prior audit work performed by GAO and the EPA OIG
During our audit, we conducted site visits and interviewed managers and staff from the following
seven headquarters offices and four regions:
•	OCFO, including OB and OP A A
•	Office of Administration and Resources Management, including the Office of Human
Resources
•	OAR
•	Office of Chemical Safety and Pollution Prevention
•	Office of Research and Development
•	OSWER
•	OW
•	Regions 3, 4, 6, and 8
We selected the program offices and regions we audited based on a variety of factors, including
size and mission of the program office, as well as examples of workload analysis that EPA staff
suggested we review. We also interviewed personnel from Region 4 and Region 6 about the level
of FTEs they dedicated to the Deepwater Horizon oil spill response effort in the Gulf of Mexico.
During our site visits, we questioned personnel about processes they used within their offices to
plan work and determine resource needs. When available, we also reviewed documentation
relating to workload analysis.
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In the early stages of our audit, OB provided us with three examples in which EPA completed a
process to determine specific labor needs to complete estimated work activities. One of those
examples was an effort Region 8 led to determine resources needed by each region related to
energy permits. The other two examples involved resource estimates to complete major projects
relating to mountaintop mining and the Chesapeake Bay. We spoke to Regions 3 and 4 regarding
the mountaintop mining project, and Region 3 for the Chesapeake Bay project.
We also interviewed employees from entities outside EPA to obtain information relating to
workload analysis. We interviewed the Associate Administrator for OMB's Office of Federal
Procurement Policy regarding OMB's July 2009 memo to agencies on managing the multisector
workforce of federal employees and contractors. That OMB memo discussed workload issues.
We also spoke with personnel from the National Aeronautics and Space Administration during
the early stages of our work about its work planning processes. We reviewed documents from the
U.S. Department of State related to the workload models it uses. We also reviewed a report that
the Washington State Department of Ecology issued related to its process for analyzing workload
for state water pollution actions.
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Appendix B
Prior GAO and EPA 01G Reports
GAO reports
Report No./date
Workload issues identified
Effects
GAO-07-883,
July 2007
EPA did not complete an overall assessment
of workload to determine resources needed
by the states. From 1997 to 2006, EPA's
regional enforcement workforce was reduced
by about 5 percent.
Given the reductions in funding and
personnel, states are finding it difficult
to respond to new enforcement
requirements in the Clean Water Act,
Clean Air Act, and Resource
Conservation and Recovery Act. EPA
information on the workload and
staffing needs of its regions and the
states is incomplete and, thus, it is
not possible with existing data to
determine their overall capacity to
meet their enforcement
responsibilities.
GAO-09-434,
March 2009
EPA's process for budgeting and allocating
resources does not fully consider the
Agency's current workload. In preparing
requests for funding and staffing, EPA makes
incremental adjustments, largely based on an
antiquated workforce planning system that
does not reflect a bottom-up review of the
nature or distribution of the current workload.
EPA cannot assure that its resource
allocation is optimal.
GAO-10-413,
March 2010
EPA has not comprehensively analyzed its
workload and workforce since the late 1980s
to determine the optimal numbers and
distribution of staff Agency-wide.
EPA cannot assure that its resource
allocation is optimal.
EPA OIG reports
Report No./date
Workload issues identified
Effects
2005-P-00006,
February 2005
Office of Acquisition Management needs to
complete workload and workforce analysis
to identify FTEs and skill gaps.
OAM does not have the data to
measure its progress toward achieving
its vision of being the preferred business
partner for all EPA contracts.
2005-P-00017,
June 2005
EPA's management tools and dispersion of
authority for Brownfields prevent the
Agency from effectively allocating, utilizing,
and accounting for staff resources. Staff is
either under- or overutilized and staffing
models are outdated due to incomplete
workload assumptions.
EPA cannot assure that Brownfields
program costs are accurately
determined, that its staff is pursuing the
best actions to achieve program goals,
or that the program is spending
resources efficiently and effectively.
11-P-0031,
December 2010
EPA's policies and procedures do not
require that employment levels be based
on workload.
EPA cannot demonstrate that it has the
right number of resources to accomplish
its mission.
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Appendix C
Agency Response
MEMORANDUM
SUBJECT: EPA's Comments on the Office of Inspector General (OIG) Draft Report "EPA
Needs Workload Data to Better Justify Future Workforce Levels" Project Number
2010-1211
FROM: Barbara J. Bennett /s/ August 9, 2011
Chief Financial Officer
TO:	Arthur A. Elkins, Jr.
Inspector General
Below are EPA's written comments on the Office of Inspector General Draft Report "EPA
Needs Workload Data to Better Justify Future Workforce Levels".
Thank you for agreeing to some direct discussions about workload recommendations in this and
related OIG reports. Our conversations helped connect common threads from different reports
and provided a higher level perspective on the challenges involved in finding a balanced
approach to the workload/workforce allocation issue. These helped inform Agency-level
workload discussions at the Executive Management Council (EMC) and Budget Forum last
month.
At these meetings, Regions 1 and 6 presented the results of their air and water pilot projects,
which they developed over the last few months. Their experience showed that workload
methodologies can be designed for some of EPA's functions but that they require a significant
level of Subject Matter Expert (SME) time and effort to develop due to highly variable inputs
and outputs, levels of state participation, process data needs, etc. During discussions managers
expressed concerns that EPA does not produce widgets - most EPA functions do not have
clearly defined and measurable inputs and outputs, making it extremely challenging and
potentially costly to develop practical workload methodologies that would provide actionable
results.
Based on these discussions, the Deputy Administrator asked Agency managers to continue
workload efforts but aim for a "medium" level of detail, possibly targeting certain core work,
and to strive for less resource intensive approaches. OCFO implemented this direction by
including this language in recent budget guidance to the Agency:
"Thanks again to Regions 6 and 1 for your hard work on the air and water programs
workload analytics. Over the next few months, OCFO will work with OAR, OW and
regions on options and an estimation process that captures more detail than the 2010
managers' survey but less detail than the original set of analytics. In addition, this effort
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will consider potential core activities for review and factors that may signal workload
shift concerns. OCFO also will consult with other offices as needed."
The goal is to help the agency manage EPA's resources within multiple Congressional and
Office of Management and Budget (OMB) mandates and constraints. The question is not
whether we have enough resources to meet all our obligations, but rather, how we can most
effectively use the limited resources EPA receives.
You also suggested considering population as an overarching factor. I agree that we should be
looking at more global measures as well, and suggest that we evaluate using population and other
external data such as such as land area, Gross Domestic Product (GDP), and / or certain
environmental statistics. This would help us better understand EPA's overall workload to protect
human health and the environment, but with the understanding that these factors do not apply to
all activities.
Below is a discussion of four general points raised in the report, followed by EPA's responses to
the IG's recommendations. The attachment contains more specific comments
Item 1 - Quantifiable support for EPA's budget. Page 7 states that "Without workload data,
EPA cannot determine, and quantifiably support in budget documents, the resource needs for
planned work" and page 10 states that "EPA cannot assure resources are planned or allocated in
the most efficient and effective manner."
These statements imply that the OMB Circular A-l 1, Preparation, Submission and Execution of
the Budget requires complete, detailed, task level workload data. However, OMB has not
indicated that EPA fails to comply with A-l 1. EPA is one of the few agencies which
consistently submits it proposed budget to OMB on time every year, and definitely one of the
very few that submits its complete one thousand page submission with detailed descriptions,
charts and tables on time. Our reading of A-l 1 is that workload analyses are listed as just one of
the many items that an Agency should consider in developing resource requests.
Page 3 also cites OMB's FY 2012 budget guidance which told agencies that "they were to
restructure operations by:
(1)	eliminating programs that have low impact on an Agency's mission so that resources can be
freed up to continue investments in priority areas even as overall budgets are constrained,
(2)	reengineering staffing plans and other processes to squeeze waste out of existing operations
and produce better outcomes, and
(3)	focusing management attention on high performance goals to better deliver services to the
American people using available resources."
In the 2012 budget guidance items 1 and 3 require informed assessments on which programs
have low impact or high impact (or potential performance) goals - not workload models. Item 2
requires informed agency planning on how to become more efficient within budget constraints.
After more than a year of participating in many difficult decision-making discussions on how to
manage resources within the Congressional and OMB limits, I can attest that Agency senior
decision-makers review a host of critical financial, performance, risk and other data to inform
tough choices about scarce resources. In designing our budget and planning processes, we have
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to be mindful of the work we are asking of the agency and consider the cost / benefit of any
added requirements.
Item 2 - Correlation between program requests and final decisions. Page 7 states, "We
found little correlation between program office requests and OCFO's budget recommendations.
The lack of program office workload data contributed to the differences between the offices'
proposed estimates and the FTE levels that OB approved." This statement implies that workload
data would explain those changes.
For example, the draft OIG report cites the Region 8-led request for additional energy permitting
resources, but neglects to mention three points:
(1)	Region 8's request included both FTE to address its existing backlog and new anticipated
permitting needs. EPA decided, given other priorities, to provide resources to address the
permit backlog only.
(2)	The initial request was made under one administration - and the final decision was made
under another. Each administration has discretion over agency priorities and resource
decisions.
(3)	The initial Region 8 request was made when petroleum prices had dramatically jumped and
seemed to be going higher - while the final figures were decided after prices (and thus the
number of estimated projects) had declined considerably.
Item 3 - Federal Financial Accounting Standards Number 4. It is unclear how these
accounting standards relate to OIG's workload planning suggestions. I would suggest removing
the reference from the report.
Item 4 - EPA acting upon previous workload analyses. The draft report offers six examples
of how EPA looked at its workload methods (grants, planning methods, research administrative
efficiencies, Superfund, contracting and workload benchmarking) and in each case writes that
EPA "did not take action". But I believe that EPA management did take action - just not in the
direction of immediately implementing detailed workload modeling. In these cases EPA
managers decided, based on the studies, not to invest additional resources in developing detailed
models - because the studies did not indicate that the additional information generated would be
worth the cost.
Responses to Recommendations
Recommendation 1. We recommend the Chief Financial Officer conduct a pilot project
requiring EPA organizations to collect and analyze workload data on key project activities.
Agency Response: Concur in part. As discussed above we are following up on recent air and
water workload pilot projects conducted by Regions 1 and 6 and are continuing to look at how
other organizations collect and analyze workload data and use workload methodologies.
Recommendation 2. We recommend the Chief Financial Officer use information learned from
the pilot and the ongoing contracted workload study to issue guidance to EPA program offices
on:
a. how to collect and analyze workload data,
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b.	the benefits of workload analysis, and
c.	how this information should be used to prepare budget requests.
Agency Response: Concur in part. We are completing the workload survey / benchmarking study
in September 2011, which includes input from over 1,000 managers, informational interviews
with other agencies that manage similar functions, and discussions with over a dozen similar
agencies about what workload tools they employ. We will also explore the use of external
variables such as population, land area, Gross Domestic Product (GDP), and/or other reliable and
available environmental or public data to help better understand major drivers for EPA's
geographic workload.
We will use perspective(s) gained from the pilots, study, and geographic analyses to develop
intelligent, cost-effective options for strengthening planning processes. EPA's paramount goal is
to inform decision-making and evaluations regarding how to best use increasingly limited
resources. However, OCFO cannot commit to issuing detailed guidance to the rest of the Agency
on collecting and using workload data until we have developed or found viable methodologies
for EPA's functions.
Conclusion
Thank you for the opportunity to comment on the draft report and for agreeing to some direct
discussions. We remain committed to partnering with your staff on findings and
recommendations that help efficiently protect human health and the environmental and support
the Agency's efforts to do so. We are always looking for innovative ideas to improve the ability
of EPA's programs to strengthen resource stewardship while also achieving better environmental
results.
Again, I appreciate your willingness to meet with me to discuss these recommendations and how
they relate to other ongoing IG efforts. If you have questions or comments, please contact me.
Staff may wish to follow up with Carol Terris, Deputy Director, Office of Budget/OCFO at (202)
564-0533 or Hamilton Humes, Senior Advisor, Office of Budget/OCFO at (202) 564-2835.
Attachment
cc:
Maryann Froehlich, Deputy Chief Financial Officer
Josh Baylson, Associate Chief Financial Officer
David Bloom, Director, Office of Budget
Carol Terris, Deputy Director, Office of Budget
Kimberly Dubbs,
Barbara Freggens,
Hamilton Humes,
Diane Kelty
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Attachment: EPA's Specific Comments to OIG Draft Report "EPA Needs Workload Data
to Better Justify Future Workforce Levels" Project Number 2010-1211
Below are some specific comments about the Draft Report "EPA Needs Workload Data to Better
Justify Future Workforce Levels" Project Number 2010-1211 in the order that they appeared in
the report.
Specific Comments
Page 1, footnotes 1 and 2.
•	Replace "EPA" with "one". Using EPA as the subject implies that EPA chose not to use a
commonly accepted definition, while the report acknowledges there is "no one exact
definition of workload" and, thus, no definition of workload modeling.
Page 2.
•	Suggest recognizing Government Performance and Results Act (GPRA) Modernization Act,
enacted in January 2011 at end of the OPAA paragraph.
Page 3, 1st paragraph.
•	Add "because the results were not implementable and one study is not yet completed" "after
"assessments".
Page 5, Prior GAO and OIG Audit Reports.
•	The summary of the audit reports implies that EPA concurred with all the recommendations
and analyses presented in these reports, which isn't the case. EPA managers did not believe
that it was a cost-effective to invest resources to implement many of the recommendations
contained in the reports.
Page 6, 1st paragraph.
•	Suggest recognizing that some EPA offices do conduct regular workload analysis, e.g.,
FFRRO, and that some EPA offices do cost accounting of time for cost recovery purposes.
•	The statement "EPA's Office of Budget must base budget decision primarily on subjective
justifications at a time when budgets continue to tighten and data-driven decisions are
needed" is misleading. Agency resource allocation decisions are made based on a
comprehensive assessment of the Agency's priorities as aligned with the Strategic Plan, with
large amounts of input from program officials and assessment of performance results as well
as consideration of Administrator and Administration priorities and of course OMB and
Congressional decisions. This analysis includes looking at the FTE (or workforce) used by
particular programs and organizations.
Page 8
•	1st paragraph, first sentence. Add "some" before EPA and "water" after EPA. These specific
examples of water-related data are not necessarily transferrable to all Water programs let
alone all of EPA's programs, e.g., research, air, etc.
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•	1st paragraph. Delete Region 4 system example and revise remaining paragraph to refer to a
single system example rather than two. Since the Region 4 system "has been in use for about
a year", it likely did not inform the FY 2011 FTE estimates which would have been
developed largely in 2009 for the FY 2011 President's Budget.
•	Last sentence: Suggest adding "EPA advised that" before "while".
Page 9, 2nd paragraph.
•	Add to last sentence: "... and promoting work sharing among regional offices could be a
viable alternative."
Page 10,
•	1st paragraph, next to last sentence: Replace "each" with "most." Some program/projects,
such as STAG grants, do not include EPA personnel costs.
•	1st paragraph's description that EPA currently tracks cost for about 140 program/projects
understates the level of detail with which the financial systems track EPA costs. In addition
to the 140 program projects, financial and other systems capture significant additional detail.
First of all most program projects are broken out by National Program Office (NPM) and
Region, which frequently means up to 23 pieces. Second, most program projects are broken
out by Object Class (salaries, contracts, grants, etc.) which means up to 8 pieces. Budget
systems also must capture IT coding (mandated by OMB) that track how much money in
certain programs is designated for particular IT projects. BAS (the Budget Automation
System) also captures estimated budgets for many specific items requested by Congress, such
as earmarks. Payroll and financial systems must also track Superfund site-specific charging,
as well as pesticide fees charging. Superfund site-specific for potential payment by
Potentially Responsible Parties (PRPs) and the pesticide fees for charging to reimbursable
agreements. Overall these examples of the many financial and programmatic categories of
data tracked means that EPA's budget is actually divided and tracking in thousands of pieces.
EPA's tracking is so detailed that OCFO has no more characters in its accounting codes that
it can use to track different items.
•	2nd paragraph, first sentence: Add "EPA" before "resources".
•	2nd paragraph, last sentence: After "required," add "and recoverable from responsible
parties."
•	2nd paragraph general. This paragraph implies EPA is ignoring its financial duty by not
doing detailed tracking like it did for Deep Water Horizon. However, there is another
interpretation, EPA implements this type of tracking when needed and carefully judges the
costs and benefits of tracking additional items. In this case, EPA acted promptly to address
the need to put in place additional tracking so costs could be recovered from the responsible
parties for the disaster rather than have the American taxpayer pay.
Page 11,
•	2nd paragraph states "For example, the current contract that OCFO is using is designed to
provide feedback that will broadly look at EPA as a whole from a top-down management
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perspective. We believe that EPA would benefit from a bottom-up approach." These
sentences imply that the workload benchmarking did not include a bottom-up approach.
However the managers' survey obtained direct input from over 1,000 front-line managers
whose staff work in the six functions identified. The survey was specifically designed to
provide bottom-up insight on level of effort, work drivers, and work tasks.
Page 14,
•	2nd bullet "In a complex organization, such as EPA a single, standard workload model in not
practical or feasible. Rather local units should adopt an approach that fits their mission and
operations." I agree with this statement - huge, complicated workload models that try to
foresee every conceivable analytical need are neither practical nor feasible. EPA's present
budget process permits local units to use tracking and workload estimation tools. However,
there is some risk in using locally developed workload methodologies for Agency-level
decision-making if they are not comparable.
•	Comparison to State Department. EPA's workload benchmarking exercise includes looking
at specific comparable agencies. For each of the 6 functions, the contractor, working with
EPA experts, carefully assessed which other agencies would provide the best comparison to
EPA. This includes looking at the State Department because the IG suggested it, but I would
emphasize that the State Department is very dis-similar to EPA in many ways — it is an
international organization with a very different mission, it is not a scientific, regulatory, nr
enforcement agency, it does not issue permits, conduct environmental monitoring, etc.
•	Comparison to Washington State. This example does not provide a case for detailed
workload models. It was a two-step analysis in a particular media and in a particular state -
and not a model used for ongoing budget analysis.
Page 16.
•	The Conclusion states that "Organizations of various sizes, including some larger than EPA,
in both the private and public sectors have successfully used workload modeling for many
years, to justify their decision on how resources are allocated and used." EPA does not
dispute that many organizations use detailed workload models for planning resources needed
for specific, clearly defined and repeatable tasks. What is at issue is whether EPA can cost-
effectively adapt existing models or develop new models for the many different functions
and processes that EPA manages. EPA is looking for workable models and has piloted efforts
in Region 1 and 6, but recognizes that it is difficult and expensive to design useful workload
models for complex, non-repeatable and evolving tasks. In its pilot, Region 6 reported that
staff devoted 160 hours to analyze 35 FTE. Extrapolated for EPA as whole that would
require 37 FTE and nearly $5 M in just payroll costs. As financial managers, we must the
weigh the costs of developing such systems with the benefits to informing decision-making.
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Appendix D
Distribution
Office of the Administrator
Assistant Administrator for Administration and Resources Management
Chief Financial Officer
Director, Office of Budget, Office of the Chief Financial Officer
Director, Office of Human Resources, Office of Administration and Resources Management
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Audit Followup Coordinator, Office of the Chief Financial Officer
Audit Followup Coordinator, Office of Administration and Resources Management
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