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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA Needs to Improve Oversight
of the Senior Environmental
Employment Program
Report No. 19-P-0198
June 24, 2019



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Report Contributors:
Myka Bailey-Sparrow
LaTanya Furdge
Madeline Mullen
Michael Petscavage
Abbreviations
EPA	U.S. Environmental Protection Agency
FTE	Full-Time Equivalent
FY	Fiscal Year
GAO	U.S. Government Accountability Office
IGMS	Integrated Grants Management System
OGD	Office of Grants and Debarment
OIG	Office of Inspector General
OMB	Office of Management and Budget
OROM	Office of Resources, Operations, and Management
SEE	Senior Environmental Employment
U.S.C.	United States Code
Cover Image: Graphic depicting types of positions held by SEE enrollees. (EPA OIG image)
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* — *	U.S. Environmental Protection Agency	June 24,2019
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	 \ Office of Inspector General
At a Glance
Why We Did This Project
The U.S. Environmental
Protection Agency's (EPA's)
Office of Inspector General
(OIG) conducted this audit to
determine whether internal
controls for the Senior
Environmental Employment
(SEE) program cooperative
agreements provide reasonable
assurance that the agency is
complying with the
Environmental Programs
Assistance Act (P.L. 98-313)
and EPA guidance and
policies.
According to the EPA, the SEE
program provides opportunities
for workers at least 55 years
old to assist the EPA on
federal, state and local
environmental projects,
including pollution prevention,
abatement and control. Also,
workers can assist with
administrative, clerical,
technical and professional
support.
This report addresses the
following:
• Operating efficiently and
effectively.
EPA Needs to Improve Oversight of the
Senior Environmental Employment Program
What We Found
The EPA's oversight of SEE cooperative agreements
needs to be improved. Specifically, we found that the
EPA did not:
• Timely comply with requirements to document
SEE program monitoring reviews.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBPOSTINGS@epa.gov.
The SEE program can
reduce the risk of
fraud, waste and
abuse and make the
program more efficient
through additional
controls.
•	Document oversight of SEE organizations'
quarterly reports or communications with the SEE organizations.
•	Provide adequate communications or guidance for SEE monitors regarding
their responsibilities.
•	Update the 2010 pay scale that established the worker (SEE enrollee)
minimum and maximum hourly wages.
These findings resulted from factors such as EPA project officers having
difficulties with the Grantee Compliance Database, not realizing that documenting
oversight was required, and lack of mechanisms to effectively provide information
or review reimbursement paid to grantees.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Mission Support implement
internal controls to verify that required annual baseline monitoring reports are
timely placed into the database, develop a mechanism or quality review process
for the SEE program manager to verify effective oversight, and implement
additional communications and guidance. In addition, we recommend that the
Assistant Administrator issue a memorandum to the leadership of program and
regional offices that participate in the SEE program to emphasize compliance
with guidance and communication provided by the program. Further, we
recommend that the Assistant Administrator revise guidance on reviewing and
setting wage rates.
The EPA agreed to take corrective actions on all five recommendations and
provided planned corrective action dates. The agency's planned corrective
actions and completion dates meet the intent of the recommendations.
Corrective actions are completed for Recommendation 2 and pending for the
other recommendations.
List of OIG reports.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
June 24, 2019
MEMORANDUM
SUBJECT: EPA Needs to Improve Oversight of the Senior Environmental Employment Program
Report No. 19-P-0198
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY18-0053.
This report contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. This report represents the opinion of the OIG and does not necessarily represent the
final EPA position. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
At the start of our audit, the Office of Resources, Operations, and Management within the EPA's Office
of Administration and Resources Management was responsible for planning, awarding and
administrating Senior Environmental Employment (SEE) program cooperative agreements. However,
program and regional staff are responsible for recruiting, hiring and monitoring SEE enrollees within
their programs and regional offices, and they are overseen by the Office of the Administrator. Effective
November 26, 2018, the EPA reorganized to form the Office of Mission Support, in which the Office of
Resources and Business Operations is now responsible for the issues in this report.
In accordance with EPA Manual 2750, your office provided acceptable corrective actions and milestone
dates in response to OIG recommendations. All recommendations are resolved with corrective actions
complete or pending, and no final response to this report is required. However, if you submit a response,
it will be posted on the OIG's website, along with our memorandum commenting on your response.
Your response should be provided in an Adobe PDF file that complies with the accessibility
requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final response should
not contain data that you do not want to be released to the public; if your response contains such data,
you should identify the data for redaction or removal along with corresponding justification.
FROM: Charles J. Sheehan, Deputy Inspector General
TO:
Donna Vizian, Principal Deputy Assistant Administrator
Office of Mission Support
We will post this report to our website at www.epa.gov/oig.

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EPA Needs to Improve Oversight of the
Senior Environmental Employment Program
19-P-0198
	Table of Contents
Chapters
1	Introduction	 1
Purpose	 1
Background	 1
Responsible Office	 4
Scope and Methodology	 4
2	SEE Program Did Not Timely Comply with Monitoring Requirements	 7
Documented Monitoring Is Required	 7
SEE Management Does Not Verify Updates of Grantee
Compliance Database	 7
Project Officers Experienced Difficulties with Grantee
Compliance Database	 8
EPA's OGD Was Not Able to Rely on Grantee Compliance Database	 8
Recommendation	 8
Agency Comments and OIG Evaluation	 8
3	EPA Did Not Document Oversight of SEE Grantees'
Quarterly Reports	 10
Oversight of SEE Cooperative Agreements Is Required	 10
SEE Program Tracks but Does Not Document Oversight of
Quarterly Reports	 11
SEE Program Staff Not Aware that Third Parties Would
Look at Reports	 12
Recommendation	 12
Agency Comments and OIG Evaluation	 12
4	SEE Program Management Needs to Improve Guidance	 13
EPA and GAO Provide Guidance and Internal Control Standards	 13
Guidance Needs to Improve	 13
Information Does Not Reach Monitors	 16
Agency Actions Taken as a Result of OIG Audit	 16
Recommendations	 17
Agency Comments and OIG Evaluation	 17
5	SEE Program Needs to Address Enrollee Pay Scale	 18
Internal Control Standards Apply	 18
Pay Scale Has Not Changed Since 2010 and the EPA
Has No Procedure for Review	 18
Recommendation	 20
Agency Comments and OIG Evaluation	 20
- continued -

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EPA Needs to Improve Oversight of the
Senior Environmental Employment Program
19-P-0198
Status of Recommendations and Potential Monetary Benefits		21
Appendices
A Agency Response to Draft Report		22
B Distribution		25

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Chapter 1
Introduction
Purpose
Our objective was to determine whether internal controls for the U.S.
Environmental Protection Agency's (EPA's) Senior Environmental Employment
(SEE) program cooperative agreements provide reasonable assurance that the
agency is complying with the Environmental Programs Assistance Act and EPA
guidance and policies.
Background
Title V of the Older Americans Act of 1965 (P.L. 89-73), also referred to as the
Community Service Senior Opportunities Act, was the first federal-level initiative
aimed at providing comprehensive services for older adults. In 1984, the
Environmental Programs Assistance Act (P.L. 98-313; codified as 42 U.S.C. §
4368a) authorized the EPA to establish a program of grants/cooperative
agreements to organizations that were designated in the Older Americans Act of
1965 for federal, state and local environmental agencies to use the talents of older
Americans in pollution prevention, abatement and control.
According to the EPA, the SEE program provides opportunities for workers at
least 55 years old to assist the EPA on federal, state and local environmental
projects, including pollution prevention, abatement and control. Also, workers can
assist with administrative, clerical, technical and professional activities. The SEE
program awards cooperative agreements to grantee organizations, which then
provide workers (SEE enrollees) to the EPA. The EPA's SEE public website
explains that SEE enrollees are neither federal employees nor employees of
grantee organizations. The grantee organization is responsible for managing and
administering enrollees' salaries, benefits, vacation, sick leave, and any personnel
actions or issues that occur.
The SEE program office within the headquarters Office of Mission Support is the
central point for policy and funding for the SEE program. The EPA's SEE
Guidance and Procedures Manual defines responsibilities:
• Within the SEE program, the program manager is responsible for overall
administration, monitors funding, and acts as a liaison with SEE grantees
and SEE coordinators. The program manager establishes guidance and
procedures, monitors implementation and coordinates program operation
nationwide.
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•	SEE enrollees are individuals at least 55 years of age enrolled under a SEE
cooperative agreement with a grantee organization.
•	SEE coordinators are senior EPA decision-making officials for
programmatic and financial aspects of SEE cooperative agreements within
funding offices.
•	SEE monitors are EPA employees who review and verify each enrollee's
time and attendance reports, direct daily tasks, and provide assessments of
enrollee performance and conduct to the grantees.
Within the SEE program office, EPA project officers are responsible for oversight
of the grantee organizations. This includes the following activities:
•	Review of quarterly enrollment, awards and financial reports provided by
the grantee organizations to determine whether outputs and outcomes have
been achieved.
•	Completion of required monitoring of grantee organizations and
documenting it in the EPA's Grantee Compliance database.
The program meets monthly with the SEE organizations, communicates with
agency SEE coordinators, and is responsible for updating the SEE manual and
pay scale.
The grantee organization manages and administers enrollees' salaries, however, it
is the SEE program office that sets the pay scale establishing the minimum and
maximum hourly wages. The EPA set the current pay scale in 2010 and that wage
and pay rate represents the maximum that the EPA will reimburse the grantee
organization for enrollee hourly wages. Between the entry and maximum wages,
enrollees can annually receive an increase of $0.50 per hour up to the maximum
hourly wage for their level (Table 1).
Table 1: 2010 SEE pay scale
Position
Entry hourly wage
Maximum hourly wage
Clerical/Non-Typing
$7.27
$9.70
Clerical/Typing
8.78
12.12
Technical
10.30
13.92
Professional
12.72
18.16
Source: EPA SEE program.
The grantee organizations are responsible for supervision of the SEE enrollees,
but the EPA is responsible for providing direction and monitoring enrollee
productivity. Specific responsibilities are described in Table 2.
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Table 2: SEE organization and EPA responsibilities
Action
Supervision
by SEE
organization
Direction
by EPA
Giving day-to-day tasking and feedback

X
Writing periodic formal performance evaluations
X

Recommending training

X
Recommending travel

X
Taking a formal disciplinary action with an enrollee
X

Taking action to separate an enrollee
X

Signing an enrollee's timesheet verifying hours worked

X
Offering to enroll a person

X
Reviewing potential enrollees and recommending an
applicant for enrollment
X

Source: EPA's SEE Manual.
The dollars obligated and the number of SEE enrollees have dropped between
fiscal years (FYs) 2015 and FY 2017, as shown in Table 3. According to the EPA,
this decline has accompanied declines in agency Full-Time Equivalent (FTE)
employees.
Table 3: SEE obligations and enrollees for FYs 2015-2017
Obligations and enrollees
FY 2015
FY 2016
FY 2017
Obligated
$50,621,126
$41,934,566
$43,497,241
Number of enrollees
1,111
1,061
972
Source: EPA SEE program.
As of June 1, 2018, SEE active cooperative agreements had expended almost
$86 million (Table 4).
Table 4: SEE active cooperative agreements
Organization
No. of
active
assistance
agreements
Obligation
amount
Expenditure
amount
National Asian Pacific Center
on Aging
10
$22,769,600
$19,498,592
National Association for
Hispanic Elderly
6
12,321,148
7,415,206
National Caucus & Center on
Black Aging
17
9,053,804
6,764,585
National Council on Aging a
7
6,799,077
5,684,295
National Older Worker Career
Center
19
40,432,139
31,650,259
Senior Service America
11
20,462,377
14,958,130
Total
70
$111,838,145
$85,971,067
Source: Office of Inspector General (OIG) analysis of Business Objects data as of June 1, 2018.
a This organization's SEE cooperative agreements ended in June 2018.
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SEE enrollees are acknowledged for their contributions toward the EPA's
mission. Surveyed EPA colleagues of SEE enrollees reported the following:
•	The SEE program harnesses the wisdom and expertise of an older work
force at an inexpensive cost.
•	With scarce federal administrative staff, SEE enrollees perform key
functions.
•	Given the inability to hire FTE employees, the SEE program is the only
avenue to get badly needed support.
Responsible Office
At the start of our audit, the Office of Resources, Operations, and Management
(OROM), within the EPA's Office of Administration and Resources
Management, was responsible for management oversight. This included
establishing guidance and procedures, monitoring, and awarding SEE cooperative
agreements. However, OROM did not supervise program and regional staff
responsible for recruiting, hiring and monitoring SEE enrollees within the EPA's
program and regional offices. Effective November 26, 2018, the EPA reorganized
to form the Office of Mission Support, in which the Office of Resources and
Business Operations is now responsible for the issues in this report.
Scope and Methodology
We conducted this performance audit from November 2017 through March 2019,
in accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objective.
To answer our objective, we reviewed applicable laws, requirements established
by the U.S. Government Accountability Office (GAO) and the Office of
Management and Budget (OMB), and EPA policy and procedures, including:
Laws
•	Older Americans Act of 1965 (P.L. 89-73).
•	Environmental Programs Assistance Act of 1984 (P.L. 98-313; codified as
42 U.S.C. § 4368a).
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GAO
•	Standards for Internal Control in the Federal Government, GAO-14-704G
(Sep. 2014).
OMB
•	OMB Circular A-123, Management's Responsibility for Enterprise Risk
Management and Internal Control, M-16-17 (Jul. 15, 2016).
EPA
•	EPA Order 5700.6A2 CHG 2, Policy on Compliance Review and
Monitoring (Sep. 24, 2007).
•	EPA's Assistance Agreement Almanac.
•	EPA's IGMS Post-Award Database: Programmatic Baseline Monitoring
for Grants.
•	EPA Order 5700.7A1, Environmental Results under EPA Assistance
Agreements (Jan. 1, 2005).
•	EPA's SEE Guidance and Procedures Manual.
•	EPA's Interim Records Management Policy, Transmittal 18-007 (Aug. 22,
2018).
We obtained and verified SEE funding obligations and expense information from
the EPA's Business Objects Reporting system for FYs 2015 through 2018. We
judgmentally selected a sample of two of the six not-for-profit organizations;
these two organizations had the highest unliquidated obligation amounts of the six
organizations at the time the samples were selected:
•	National Asian Pacific Center on Aging.
•	National Older Worker Career Center.
We further selected four cooperative agreements (two from each organization) for
closer review:
•	National Asian Pacific Center on Aging - 83589601 and 83623001.
•	National Older Worker Career Center - 83562501 and 83562301.
We obtained documents from the Integrated Grants Management System (IGMS)
and from OROM to determine compliance with EPA policies and procedures. We
analyzed Quarterly Financial Status, Quarterly Enrollee, and Quarterly Awards
reports from two SEE grantees for FYs 2016 and 2017.
We interviewed staff within OROM and the Office of Grants and Debarment
(OGD). We judgmentally selected and interviewed four SEE coordinators,
11 SEE monitors, and 17 SEE enrollees associated with the selected cooperative
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agreements to obtain an understanding of their roles and responsibilities and
gauge if they are complying with the Environmental Programs Assistance Act and
following EPA guidelines and policies relative to the SEE program. We also
conducted a survey of SEE enrollee co-workers and compared the SEE hourly
wages and categories with those of the U.S. Department of Agriculture agencies
that have senior employment programs.
Neither the GAO nor the EPA OIG conducted previous audits of senior
employment programs.
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Chapter 2
SEE Program Did Not Timely Comply with
Monitoring Requirements
The EPA's SEE program did not timely comply with requirements to place annual
SEE program monitoring reviews in the Grantee Compliance Database within
IGMS. EPA Order 5700.6A2 CHG 2, Policy on Compliance, Review and
Monitoring, establishes agency standards for assistance agreements, and
documented programmatic baseline monitoring is required for all awards. SEE
program management was not verifying that the Grantee Compliance Database is
routinely updated because project officers experienced difficulties with the
database and, instead, kept monitoring results on a shared drive. SEE program
management could not demonstrate that required program monitoring activities
were complete in the database and OGD was not able to rely on the database.
Documented Monitoring Is Required
EPA Order 5700.6A2 CHG 2, Policy on Compliance Review and Monitoring,
establishes agency standards for the oversight and monitoring of EPA assistance
agreements (i.e., grants and cooperative agreements). Baseline monitoring is the
periodic review of a grantee's progress and compliance with an award's scope of
work, terms, conditions and regulatory requirements. In lieu of conducting
baseline monitoring on each cooperative agreement, the SEE program may
substitute reports of oversight visits to EPA facilities, provided reports are
retained in the Grantee Compliance Database and that such reviews are conducted
annually.
SEE Management Does Not Verify Updates of Grantee Compliance
Database
The EPA did not comply with requirements to place annual SEE programmatic
monitoring reviews in the Grantee Compliance Database within IGMS. After the
OIG requested documents, the EPA uploaded reports for FYs 2016 and 2017.
Project officers sent FY 2016 monitoring report emails to grantee organizations
1 year after the activity dates (Table 5).
Table 5: FY 2016 programmatic monitoring
Organization
Activity
date per
IGMS
Report date
per IGMS
Date
organization
notified
National Asian Pacific Center on Aging
12/8/16
12/8/17
12/12/17
National Older Worker Career Center
11/1/16
12/1/17
12/11/17
Source: OIG analysis of programmatic monitoring information.
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The SEE program manager stated that the SEE program routinely reviews and
discusses monitoring results. Rather than using the Grantee Compliance Database
as required, the manager stated that project officers stored documents on a shared
drive.
Project Officers Experienced Difficulties with Grantee Compliance
Database
The SEE program manager did not verify that the Grantee Compliance Database
was routinely updated because project officers experienced difficulties with the
database. The manager was aware that monitoring was taking place, but noted that
entering information into a database was burdensome and bureaucratic when staff
had other pressing tasks, and project officers were not required to comply with
database updating requirements. The manager did not consider the database to be
the most effective technology to meet business needs for post-award monitoring.
Although it is time-consuming and a challenge to document monitoring activities,
this does not negate the requirement to clearly demonstrate monitoring activities.
EPA's OGD Was Not Able to Rely on Grantee Compliance Database
SEE program management could not demonstrate that required program
monitoring activities were complete in the database, and the EPA's OGD was not
able to rely on the database for its comprehensive performance review
responsibilities. The OGD Deputy Director explained that the OGD validates
reviews that are uploaded into the database and does not receive copies of reviews
or reports outside of the database. SEE management disagreed, indicating that the
SEE program shares requested program information with the OGD. However, the
OIG believes that SEE management needs to place required monitoring in the
OGD database.
Recommendation
We recommend that the Assistant Administrator for Mission Support:
1. Implement Senior Environmental Employment program internal controls
to verify that required annual monitoring reports are placed into the
Grantee Compliance Database in a timely manner, and that grantees
receive timely notification of results.
Agency Comments and OIG Evaluation
In response to Recommendation 1, the Office of Mission Support began adding
monitoring results to the database. Also, the Office of Mission Support reported
that the updated SEE guidance will include requirements to meet biannually with
project officers to review the database and require that project officers enter
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reports and email grantees within 5 business days of review completion. The
agency's response meets the intent of the recommendation. The EPA provided an
estimated completion date of April 30, 2020. This recommendation is considered
resolved with corrective actions pending.
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Chapter 3
EPA Did Not Document Oversight of
SEE Grantees' Quarterly Reports
The EPA did not document oversight of SEE grantee quarterly reports or any
communications with the grantees regarding those reports. Standards and policies
require oversight of SEE cooperative agreements, and documenting oversight for
third-party review provides support that recipients of federal funds have achieved
results. SEE program management was not aware that auditors (third parties)
would ever look at the reports and did not realize that documenting oversight was
required. Without uniform oversight of required quarterly reports, the EPA cannot
reasonably verify compliance with EPA guidance and policies. Also, the lack of
oversight puts government funds at risk of fraud, waste and abuse.
Oversight of SEE Cooperative Agreements Is Required
Standards for Internal Control in the Federal Government, GAO-14-704G
(Sep. 2014), states that management should use quality information to achieve
objectives and address risks. Management should also identify, analyze and
respond to risks related to achieving objectives.
EPA Order 5700.6A2 CHG 2, Policy on Compliance Review and Monitoring
(Sep. 24, 2007), establishes agency standards for oversight, monitoring and
closeout of assistance agreements (which include grants and cooperative
agreements).
The EPA's Assistance Agreement Almanac requires project officers to maintain
records used for programmatic direction, such as correspondence and progress
reports.
EPA Order 5700.7A1, Environmental Results under EPA Assistance Agreements
(Jan. 1, 2005), requires program offices to review both interim and final
performance reports to determine whether the grantee achieved outputs and
outcomes per the assistance agreement work plan. The project officer's review is
documented in the official project file.
The EPA's Interim Records Management I)olicy, Transmittal No. 18-007
(Aug. 22, 2018), states that records typically include information that is:
•	Created in the course of agency business.
•	Received for action.
•	Needed to document activities and decisions.
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It further states that all EPA staff generate records and are legally required to
maintain them.
The SEE Guidance and Procedures Manual states that each grantee is required to
submit reports each quarter on or before April 30, July 31, October 31 and
January 31 with the following three sections:
•	Financial Status Report (total expenditures to date including the most
recent quarter).
•	Quarterly Enrollee Report (listing each enrollee by site with current status,
date enrolled, date terminated, hourly rate of pay and work hours per pay
period).
•	Quarterly Financial Award Report (listing of each funding award by
site/sub account and date).
SEE Program Tracks But Does Not Document Oversight of Quarterly
Reports
Oversight of SEE grantee quarterly reports was not documented in an official
project file as required by EPA Order 5700.7A1, and EPA project officers did not
document any communications with the grantee regarding quarterly reports.
Rather than documenting quarterly report oversight in the official project file, the
SEE program's own SEE enrollee was recording information in a quarterly
comparison spreadsheet. Also, quarterly reports were saved on a shared drive
instead of within an official project file.
SEE program management noted that its oversight consisted of tracking and
reviewing the grantee organizations' required quarterly reports. The SEE program
provided all the quarterly reports to the OIG for the requested cooperative
agreements. However, we found that oversight was not documented. Specifically:
® One organization's financial reconciliation was not possible to verify
without the assistance of SEE project officers. The OIG reviewed the
awards reports from two grantees for accuracy and to reconcile portions of
the reports to other financial data. The OIG confirmed the accuracy of the
National Older Worker Career Center's reports. The National Asian
Pacific Center on Aging presented most of its information correctly, but
the OIG could not reconcile the quarterly total award amounts. SEE
program staff needed to provide an additional spreadsheet to make the
financial information more transparent for a third-party reviewer (such as,
in this case, the OIG).
•	The EPA did not have evidence that quarterly reports were reviewed.
However, the EPA SEE program manager did say that a full-time SEE
enrollee maintains a quarterly comparison report and contacts the grantee
organization when there are discrepancies. Also, the manager said every
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quarterly report is reviewed by three people. We found that project
officers did not document that they completed reviews or that they decided
reports were complete or needed correction. The EPA manager stated that
project officers did not save emails documenting internal discussions on
the quarterly report submissions.
Progress report reviews were not documented for any of the reviewed cooperative
agreements during a time period when eight reviews should have been
documented.
SEE Program Staff Not Aware that Third Parties Would Look at
Reports
The SEE program staff did not have a practice of documenting oversight of
quarterly reports because they were not aware of this requirement. Also, the SEE
program staff were not aware that auditors (third parties) would ever look at
grantees' financial reports. The SEE program manager stated that he did not know
of statutory or grants guidance requiring a program to save email correspondence.
Also, the manager said that the SEE program has 60 cooperative agreements and
numerous reports to review, and although staff (a SEE enrollee) places summary
data in a quarterly comparison spreadsheet and saves every submission, they do
not document internal discussions on the status of submissions.
Recommendation
We recommend that the Assistant Administrator for Mission Support:
2. Develop a mechanism or quality review process so that the Senior
Environmental Employment program manager can verify that project
officers exercise and document effective oversight.
Agency Comments and OIG Evaluation
In response to Recommendation 2, the Office of Mission Support reported that the
office will save email communications to document actions taken on quarterly
reports regarding timeliness, revisions, extensions and questions. Also, the agency
will use an internal shared drive to track all quarterly reports, email receipts and
files. The EPA reported that the corrective actions were complete as of
February 1, 2018. The OIG verified that the corrective actions were complete and
met the intent of the recommendation.
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Chapter 4
SEE Program Management Needs to
Improve Guidance
The SEE program did not provide adequate guidance to the EPA SEE monitors
who provide daily direction to SEE enrollees. The EPA and GAO provide
guidance and internal control standards. Interviewed SEE enrollees and monitors
were not clear about SEE program requirements because the SEE program does
not have a mechanism to effectively provide information. Confusion increases the
risk of noncompliance.
EPA and GAO Provide Guidance and Internal Control Standards
The EPA's SEE Guidance and Procedures Manual provides program guidance
such as:
•	Enrollees must have prior approval from EPA monitors to work more than
40 hours in a week. Enrollees who work over 40 hours must be paid
overtime.
•	The SEE Manual includes but does not define the word "temporary."
Standards for Internal Control in the Federal Government, GAO-14-704G
(Sep. 2014), states that management should identify and respond to risks for
achieving objectives; and should communicate quality information to achieve
objectives and address risks.
Guidance Needs to Improve
Based on interviews, the SEE program did not institute internal controls to
provide adequate guidance for monitors, and SEE enrollees and monitors were
unclear about program requirements. SEE program oversight includes monthly
telephone calls and an annual meeting with grantees as well as programmatic
monitoring. Examples of programmatic monitoring activity included:
•	October 17, 2017 - An EPA SEE program project officer met with the
National Older Worker Career Center and spoke with one monitor and one
enrollee in Region 4.
•	December 7, 2017 - An EPA SEE program project officer met with the
National Asian Pacific Center on Aging in Region 5 and spoke with one
monitor and one enrollee in Region 5.
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According to the SEE program manager, 400 to 500 monitors are guided by SEE
coordinators through emails that the SEE program sends to the coordinators.
Details regarding concerns noted for enrollees, monitors and coordinators follow.
SEE Enrollees
Extra Hours
During our interviews with SEE enrollees, we learned that SEE enrollee
rules on working extra hours were not always enforced. Only four of 17
interviewed enrollees said they could modify their schedules to reflect
overtime hours worked. After we notified the SEE program about this, the
SEE program requested that grantee organizations remind enrollees that
they must report all time that they work.
Temporary Status
Interviewed SEE enrollees did not consider themselves as temporary
because some of them had worked as SEE enrollees for a long time. Hire
dates on enrollee reports documented that some SEE enrollees had been
working with the EPA for over 20 years. Eight interviewed SEE enrollees
did not see their assignment as temporary, as shown in Figure 1:
Figure 1: Enrollee understanding of SEE temporary status
¦ Not temporary "Temporary "Other
Source: OIG analysis of interview responses.
Two of the interviewed enrollees who had been at the EPA for at least
20 years explained that initially they believed the assignments to be
temporary. However, considering the length of time they have been
working on the same assignments, they subsequently viewed their
positions as permanent. Another enrollee explained that she did not
consider the position to be temporary and planned to continue working
until she could not work anymore.
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The SEE program office pointed out that enrollee status is made clear in
the enrollee handbooks. The National Asian Pacific Center on Aging's
(NAPCA's) handbook states:
NAPCA is an "at-will" company and operates under the
provision that Enrollees have the right to resign their
position at any time, with or without notice and with or
without cause. NAPCA has similar rights to terminate the
enrollment relationship with or without notice and with or
without cause.
Although enrollment agreements are renewed on an annual basis, eight of
the 17 interviewed SEE enrollees did not consider their positions
temporary.
SEE Monitors
Some of the interviewed SEE monitors needed more guidance about what to do
aside from assigning tasks and approving time and leave. For example, six of the
11 interviewed monitors were not aware of written guidance. Three of 11 said
they needed training on certain responsibilities. One said there was no official
training for SEE monitors despite yearly grantee visits; this monitor suggested
training before placing staff in the monitor role. Two monitors said they did not
know how to prepare performance feedback for SEE enrollees. Another monitor
said that if an enrollee works longer than the required hours it is the enrollee's
choice despite the requirement that enrollees must have approval to work more
than 40 hours and must be paid overtime. These are examples of concerns that
could have been addressed through improved communication and guidance.
SEE program management disagreed, stating that SEE monitors can provide the
needed oversight through (1) the policy and procedures guidance on the intranet,
(2)	the grantee organization's handbook available online or hardcopy, and
(3)	contacting the SEE program officer or grantee with questions. However, the
OIG believes that making information available to monitors and being open to
questions was not effective.
SEE Coordinators
The OIG identified concerns based on comments made during interviews with
SEE coordinators. One coordinator said that she did not initially receive training,
so she suggested training for coordinators and monitors regarding roles and
responsibilities when they are first assigned. Two coordinators said they did not
consider enrollees temporary because (1) the EPA cannot get regular FTE
employees so hiring a SEE enrollee was the best option, and (2) it costs a lot to
train enrollees.
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Information Does Not Reach Monitors
The EPA does not have an internal control mechanism to effectively provide
information to SEE monitors.
Guidance
SEE program guidance is vague and does not address a common misconception
regarding temporary employment. Although the SEE guidance mentions temporary
employment it does not outline how the temporary status applies to SEE enrollees.
The SEE program manager said enrollees are renewed on an annual basis and
should be aware that their status is temporary, but the guidance is silent.
Communications
Communications do not reach all the monitors and are not effective because:
•	SEE monitors are unaware of what to do because the SEE program has not
reached down to the monitor level to train and emphasize compliance with
the SEE Manual.
•	When SEE program management needs to reach out to monitors, program
coordinators are contacted, but the SEE program office has no mechanism
to verify that information shared with the SEE coordinators is
disseminated to the SEE monitors.
•	The SEE program manager said that because the hundreds of coordinators
and monitors across the agency do not directly report to SEE program
management, the SEE program cannot mandate attendance at training.
Agency Actions Taken as a Result of OIG Audit
After the OIG notified the SEE program about concerns regarding SEE enrollees
working extra hours, the SEE program sent an email to the organizations to
remind them that enrollees must report all time that they work and asked the
organizations to notify enrollees and monitors.
SEE program management recognized that the SEE Manual needs to be revised
and indicated it will remove all references to the word "temporary." The SEE
program has also recognized that due to greater turnover among coordinators and
monitors, additional training was needed and is underway.
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Recommendations
We recommend that the Assistant Administrator for Mission Support:
3.	Implement additional communication and guidance for monitors regarding
Senior Environmental Employment policies and procedures.
4.	Issue a memorandum to the leadership of program and regional offices
that participate in the Senior Environmental Employment Program to
emphasize compliance with guidance and communication provided by the
program.
Agency Comments and OIG Evaluation
In response to Recommendation 3, the Office of Mission Support responded with
two corrective actions. One action was to initiate robust training for coordinators,
monitors and grantees; and continued grantee-specific training that will extend to
all coordinators and monitors serviced by the grantee. The EPA reported that this
part of the corrective action has begun and provided an example of a regional
monitor training invitation, but the 2019 training schedule has been delayed. The
second corrective action was to create a method to maintain information about
SEE coordinator and monitor training sessions using an internal shared drive. The
EPA provided an estimated completion date of July 18, 2019. The planned
corrective action meets the intent of the recommendation. This recommendation is
considered resolved with corrective actions pending.
In response to Recommendation 4, the EPA reported that it will issue a
memorandum to emphasize compliance with guidance and communication
provided by the program. Although the action was initially reported as complete,
the EPA later reported that it would be complete by June 7, 2019. The corrective
action date has passed, and we have not been provided a new date. The planned
corrective action meets the intent of the recommendation. This recommendation is
considered resolved with corrective actions pending.
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Chapter 5
SEE Program Needs to Address
Enrollee Pay Scale
The SEE enrollee pay scale has not changed since 2010, and the basis for the
current pay scale is not defined. The SEE Manual does not include a mechanism
or procedure for reviewing the reimbursement paid to grantees for SEE enrollees.
Interviewed SEE enrollees, monitors and coordinators expressed concerns about
pay scale equity.
Internal Control Standards Apply
Standards for Internal Control in the Federal Government, GAO-14-704G
(Sep. 2014), provides an overall framework for establishing and maintaining
effective internal control systems for the federal government. These standards
require that management document internal control responsibilities in policies and
periodically review them for their relevance and effectiveness in achieving
objectives or addressing risks. Risk is defined as the possibility that an event will
adversely affect the achievement of objectives.
The SEE Guidance and Procedures Manual establishes reimbursement to
grantees for wage ranges paid to SEE enrollees and includes the following
information in Chapter 2, Section 10:
The monitor shall not discuss wage with the candidates, as wage is
to be discussed between the grantee and the enrollee. ... A SEE
enrollee's wage and benefits are determined by the grantee. Wage
ranges for the various levels are set. The wage ranges represent the
amounts EPA will reimburse the grantees for paying wages to SEE
enrollees.
Pay Scale Has Not Changed Since 2010 and the EPA Has
No Procedure for Review
SEE enrollee reimbursable pay scale ranges have not changed since 2010. The
SEE Manual states that wages are determined by the grantee, but the manual does
not include a mechanism or procedure for pay scale review despite the EPA
controlling the pay scale and funding for SEE enrollees. During the period 2011
through 2018, SEE enrollees received no raises while federal employees received
raises totaling 5.4 percent. According to the SEE program manager, low hourly
wages are the biggest challenge facing the program.
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The SEE Manual does not include a procedure to review SEE pay scale
reimbursement. The SEE Manual does not include who is responsible for setting
the pay scale, the timing of pay scale review, or the basis for reviewing and
establishing the rates included in the pay scale.
The SEE program manager explained the following factors related to setting pay:
•	It is inappropriate to compare a "work experience program" such as SEE
with actual federal employment because there is not a comparable labor
market for Americans 55 and older.
•	The SEE program does not have trouble filling vacancies, and other
benefits such as health benefits make up for the lower wages.
•	Wages have been a regular subject of review and discussion with senior
management over the last 2 years, but the current wage structure suffices.
•	Raising wages would have an unintended consequence of reducing the
number of SEE enrollees.
SEE enrollees, monitors and coordinators have concerns regarding the equity of
the pay offered to SEE enrollees. At least 50 percent of interviewed enrollees,
monitors and coordinators expressed concerns about enrollee pay, as shown in
Figure 2. It is the EPA's responsibility per the Standards for Internal Control in
the Federal Government to establish a policy addressing the mechanism, timing
and basis for pay scale reviews.
Figure 2: Percentage of interviewees, by category, expressing pay scale concerns
ivv?¥
90%
80%
70%
60%
50%
AO%
30%
J0%
10%
0%
EnroJIees	Monitors	Coordinators
Source: OIG analysis of interviews of 17 enrollees, 11 monitors and four coordinators.
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Examples of specific comments made by interviewed enrollees, monitors and
coordinators are provided below.
Enrollees
One enrollee said that the starting pay for a SEE professional engineer is
extremely low. After the enrollee inquired about this issue with the grantee, the
enrollee was told that Congress must increase the pay rates. However, the enrollee
later learned that it is the EPA's responsibility. According to the SEE Manual,
"pay is reimbursable to the grantee only to the extent allowed by the EPA...."
Another enrollee said that at a recent SEE meeting, the enrollee mentioned salary
to a monitor and the monitor said that the procedure states the top pay. As far as
the enrollee was aware, there was no way to get a raise unless procedures were
changed. The enrollee cited not receiving a raise in more than 10 years and has
been with the agency almost 20 years.
A third enrollee stated that 2 years ago there was a conversation about an increase
in salary but nothing was done about it.
Monitors
One monitor said the enrollees work very hard and the pay scale should be
re-evaluated. Another monitor said the enrollees do a great deal of work and the
compensation is very low.
Coordinators
A coordinator said that SEE enrollee services are greatly needed, and the SEE
enrollees need more pay.
Recommendation
We recommend that the Assistant Administrator for Mission Support:
5. Revise the SEE Guidance and Procedures Manual to include internal
controls related to reviewing and setting wage rates, the timing for pay
scale reviews, and responsibilities.
Agency Comments and OIG Evaluation
In response to Recommendation 5, the EPA reported that it would revise the
SEE Manual to include internal controls for reviewing and setting wage rates, the
time for reviews, and responsibilities. The EPA provided an estimated completion
date of April 30, 2020. This recommendation is considered resolved with
corrective actions pending.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
1
8
Implement Senior Environmental Employment program internal
controls to verify that required annual monitoring reports are
placed into the Grantee Compliance Database in a timely
manner, and that grantees receive timely notification of results.
R
Assistant Administrator for
Mission Support
4/30/20

2
12
Develop a mechanism or quality review process so that the
Senior Environmental Employment program manager can verify
that project officers exercise and document effective oversight.
C
Assistant Administrator for
Mission Support
2/1/18

3
17
Implement additional communication and guidance for monitors
regarding Senior Environmental Employment policies and
procedures.
R
Assistant Administrator for
Mission Support
7/18/19

4
17
Issue a memorandum to the leadership of program and regional
offices that participate in the Senior Environmental Employment
Program to emphasize compliance with guidance and
communication provided by the program.
R
Assistant Administrator for
Mission Support
6/7/19 2

5
20
Revise the SEE Guidance and Procedures Manual to include
internal controls related to reviewing and setting wage rates, the
timing for pay scale reviews, and responsibilities.
R
Assistant Administrator for
Mission Support
4/30/20

1
C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
The corrective action date has passed, and we have not been provided a new date.
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Appendix A
Agency Response to Draft Report
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 1 5 2019
OFFICE OF MISSION SUPPORT
MEMORANDUM
SUBJECT:
FROM:
TO:
Response to the Office of Inspector General Draft Report No. OA-FY-18-0053 "EPA's
Lack of Oversight Puts the Senior Environmental Employment Program at Risk" dated
March 18,2019
Donna Vizian. Principal Deputy Assistan
Office of Mission Support
Charles J. Sheehan, Acting Inspector General
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. Following is a summary of the agency's overall position, along with its position on each
of the report recommendations. The agency agrees with the recommendations in the report and
has provided high-level corrective actions and estimated completion dates.
AGENCY'S OVERALL POSITION
The EPA agrees with the Office of Inspector General's (OIG) overall report, that there were
areas for improvement in the agency's Senior Environmental Employment (SEE) program. The
EPA further agrees with the OIG's report that the EPA has already begun making many of the
improvements identified in the report.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended Corrective
Action(s)
Completion Date
1
Implement Senior
Environmental
Employee program
Monitoring results are now input
into the Grantee Compliance
Database in a timely manner and

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internal controls to
verify that required
annual monitoring
reports are input into
the Grantee
Compliance Database
in a timely manner,
and that grant
recipients receive
timely notification of
results.
two more project officers were
hired to keep up with the workload.
The SEE program manager
committed to:
1.1 Include these requirements in
the updated SEE Guidance.
-	Meet biannually with
project officers to review
the Grantee Compliance
Database.
-	Have project officers enter
post-award monitoring
reports in the Grantee
Compliance database and
email recipients within five
(5) business days of
completing reviews.
April 30, 2020
2
Develop a mechanism
or quality review
process so that the
Senior Environmental
Employment program
manager can verify
that project officers
exercise and document
effective oversight.
2.1	Save email communications
to document actions taken on
quarterly reports regarding
timeliness, revisions, extensions
and questions.
2.2	Use OneDrive to track all
quarterly reports, email receipts and
files.
Completed
Completed
3
Implement additional
communication and
guidance for monitors
regarding Senior
Environmental
Employee policies and
procedures.
3.1	Initiate a robust training for
coordinators, monitors and
grantees, and continue grantee-
specific training that will extend to
all coordinators and monitors
serviced by that grantee.
3.2	Create a folder on OneDrive to
maintain information related to
SEE coordinator and monitor
training.
Completed
July 18,2019
4
Issue a memorandum
to the leadership of
program and regional
offices that participate
in the Senior
4.1 Issue a memorandum to the
leadership of program and regional
offices that participate in the Senior
Environmental Employee program
to emphasize compliance with
Completed
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Environmental
Employee program to
emphasize compliance
with guidance and
communication
provided by the
program.
guidance and communication
provided by the program.

5
Revise the SEE
Guidance and
Procedures Manual to
include internal
controls related to
reviewing and setting
wage rates
reimbursable to
grantees, the timing
for pay scale reviews,
and responsibilities.
5.1 Revise the SEE Guidance and
Procedures Manual to include
internal controls related to
reviewing and setting wage rates
reimbursable to grantees, the timing
for pay scale reviews and
responsibilities.
April 30, 2020
Disagreements
The EPA suggests that the title of the audit should be modified to better reflect the magnitude of
the findings. The OIG has agreed to the EPA's recommendation that the title for this audit be
changed to "Enhanced Oversight Can Improve the EPA's Senior Environmental Employee
Program".
CONTACT INFORMATION
If you have any questions regarding this response, please contact Janice Jablonski, Director
Administrative Operations Division, Office of Mission Support on (202) 564-9922 or Marilyn
Armstrong on (202) 564-1876.
cc: Wesley Carpenter
Lynnann Hitchens
Daniel Coogan
Janice Jablonski
Juanita Standifer
Marian Cooper
Michael Petscavage
Madeline Mullen
Marilyn Armstrong
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Appendix B
Distribution
The Administrator
Associate Deputy Administrator and Chief of Operations
Chief of Staff
Deputy Chief of Staff
Assistant Administrator for Mission Support
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Administrator
Principal Deputy Assistant Administrator for Mission Support
Deputy Assistant Administrator for Administration and Resources Management, Office of
Mission Support
Director, Office of Grants and Debarment, Office of Mission Support
Director, Grants and Interagency Agreements Management Division, Office of Mission Support
Director, Office of Resources and Business Operations, Office of Mission Support
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Mission Support
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