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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Audit Report
EPA Can Improve Its Preparation
and Use of Independent
Government Cost Estimates
for Superfund Contracts
Report No. 10-P-0065
February 16, 2010

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Report Contributors:
Nancy Dao
Doug LaTessa
Kevin Lawrence
Michael Petscavage
Abbreviations
CMM
Contracts Management Manual
EPA
U.S. Environmental Protection Agency
ERRS
Emergency and Rapid Response Services
ESAT
Environmental Services Assistance Team
FAR
Federal Acquisition Regulation
GAO
Government Accountability Office
IGCE
Independent Government Cost Estimate
OAM
Office of Acquisitions Management
OARM
Office of Administration and Resources Management
OIG
Office of Inspector General
OSRTI
Office of Superfund Remediation and Technology Innovation
OSWER
Office of Solid Waste and Emergency Response
QAP
Quality Assessment Plan
RAC
Remedial Action Contract
SOW
Statement of Work
START
Superfund Technical Assessment and Response Team
TDF
Technical Direction Form

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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
10-P-0065
February 16, 2010
Catalyst for Improving the Environment
Why We Did This Review
We conducted this audit to
determine whether the U.S.
Environmental Protection
Agency (EPA) is preparing
quality Independent
Government Cost Estimates
(IGCEs) that can be used to
evaluate whether EPA receives
the best value for dollars
expended on Superfund
contracts.
Background
An IGCE is a detailed estimate
of what a reasonable person
should pay to obtain the best
value for a product or service.
EPA's training guide for
IGCEs states that, "they are an
integral part of any effective
acquisition program." IGCEs
are used to plan costs for new
contracts and new work under
existing contracts. Once
program personnel prepare the
IGCE, the IGCE should then be
compared to the contractor's
proposal to help determine
price reasonableness.
For further information, contact
our Office of Congressional,
Public Affairs and Management
at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2010/
20100216-10-P-0065.pdf
EPA Can Improve Its Preparation and Use of
Independent Government Cost Estimates for
Superfund Contracts
What We Found
EPA can improve its Superfund IGCEs and the corresponding cost estimating
process. In 30 of the 42 cases we reviewed, EPA did not sufficiently document
information in its Superfund IGCEs. Additionally, in 9 of the 42 cases, EPA did
not update the IGCEs when significant changes occurred. In 8 of the 42 cases,
EPA program staff accepted the contractor's estimate without evaluating why it
differed from the IGCE. Finally, in some cases EPA did not prepare an IGCE for
actions with a potential value in excess of $100,000, the Federal Acquisition
Regulation threshold for simplified acquisitions. These actions are contrary to
the Government Accountability Office Cost Estimating and Assessment Guide
and the EPA Contracts Management Manual. They occurred because there is an
overall lack of emphasis by EPA management on the preparation and use of
IGCEs. EPA limits its ability to negotiate a fair and reasonable price when it
does not have a well-supported IGCE.
What We Recommend
We recommend that EPA place greater emphasis on IGCEs through training and
tools for creating IGCEs. EPA should prepare IGCEs for all contract actions
expected to exceed the simplified acquisition threshold and discontinue the
practice of relying only on the contractors' estimates.
EPA agreed with all of our recommendations and provided a corrective action
plan for most of the recommendations. EPA indicated it will provide its entire
corrective action plan as part if its response to the final report.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
February 16, 2010
MEMORANDUM
SUBJECT: EPA Can Improve Its Preparation and Use of Independent Government
Cost Estimates for Superfund Contracts
Report No. 10-P-0065
FROM: Melissa M. Heist
Assistant Inspector General for Audit
TO:	Craig E. Hooks
Assistant Administrator
Office of Administration and Resources Management
Mathy Stanislaus
Assistant Administrator
Office of Solid Waste and Emergency Response
Karl Brooks
Regional Administrator, Region 7
This is our report on the U.S. Environmental Protection Agency's (EPA's) preparation and use of
Independent Government Cost Estimates (IGCEs). This audit report contains findings that
describe the problems the EPA Office of Inspector General (OIG) has identified and corrective
actions the OIG recommends. This report represents the position of the OIG and does not
necessarily represent the final EPA position. Final determinations on matters in this report will
be made by EPA managers in accordance with established audit resolution procedures.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $449,120.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective actions plan for agreed-upon
actions, including milestone dates. We have no objections to the further release of this report to
the public. This report will be available at http://www.epa.gov/oig.

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If you or your staff have any questions, please contact me at 202-566-0899 or
heist.melissa@epa.gov; or Janet Kasper, Product Line Director, at 312-886-3059 or
kasper.ianet@epa.gov.

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EPA Can Improve Its Preparation and Use of Independent
Government Cost Estimates for Superfund Contracts
10-P-0065
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Noteworthy Achievements		2
Scope and Methodology		2
2	EPA Superfund Can Improve Its Independent Government Cost Estimates ..	5
Superfund Staff Need to Better Document Rationale,
Assumptions, and Changes		5
Superfund Staff Should Not Rely on Contractor Proposed Amounts		6
Superfund Staff Need to Prepare IGCEs for All Contract Actions
Over the Simplified Acquisition Threshold		7
EPA Should Place Greater Emphasis on IGCEs		8
Conclusion		9
Recommendations		10
Agency Comments and OIG Evaluation		10
3	EPA Region 7 Improved Cost Management for Its ESAT Contract		12
Status of Recommendations and Potential Monetary Benefits		13
Appendices
A List of Superfund Contracts Reviewed	 14
B Agency Response	 16
C Distribution	 19

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10-P-0065
Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency's (EPA's) Office of Inspector
General (OIG) conducted this audit to determine whether the Agency is preparing
quality Independent Government Cost Estimates (IGCEs) that can be used to
evaluate whether it receives the best value for dollars expended on Superfund
contracts.
Background
An IGCE is a detailed estimate of what a reasonable person should pay to obtain
the best value for a product or service. It should include priorities and
assumptions that exist at the time the estimate is made. In a training guide on
IGCEs, EPA's Office of Acquisition Management (OAM) states, "They are an
integral part of any effective acquisition program." OAM further states, "EPA's
goal for cost estimates is to achieve predictions that are as accurate as possible
using the information available and the best estimating technique for a given
situation. Both involve the use of any historical data available."
Quality cost estimates help EPA ensure it obtains fair and reasonable prices for
desired goods and services. EPA's Strategic Plan states, "EPA is committed to
being a good steward of our environment and a good steward of America's tax
dollars. To provide the public with the environmental results it expects and
deserves, we must operate as efficiently and effectively as possible...."
EPA uses IGCEs to plan costs for new contracts as well as modifications, new
work assignments, and task or delivery orders under existing contracts. EPA's
program offices are responsible for preparing IGCEs. In preparing the IGCE, the
program office uses various methods to estimate the resources necessary to
perform the activities detailed in the Statement of Work (SOW). The program
office compares the IGCE to the contractor's proposal to help determine cost
reasonableness. According to the Federal Acquisition Regulation (FAR), the
contracting officer's responsibility is to provide necessary support for contractual
issues, including assuring the reasonableness of costs.
EPA's Office of Solid Waste and Emergency Response (OSWER) oversees the
Superfund program. Superfund is the name given to the environmental program
established to address abandoned hazardous waste sites. It is also the name of the
fund established by the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, as amended. This law was enacted in the wake of the
discovery of toxic waste dumps. It allows the EPA to clean up such sites and to
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compel responsible parties to perform clean-ups or reimburse the government for
EPA-led clean-ups.
Noteworthy Achievements
We identified noteworthy achievements in the form of a student guide and tools
available to assist EPA personnel in preparing IGCEs. However, these resources
need to be updated and re-emphasized. EPA made IGCE related resources
available following previous OIG and Government Accountability Office (GAO)
reports that cited issues regarding EPA's preparation and use of IGCEs.
In 1998, OAM developed a guide for preparing and using IGCEs. The guide
details the importance of IGCEs and the important components that should be
contained in IGCEs. The guide also specifies the potential uses of an IGCE.
The Office of Superfund Remediation and Technology Innovation (OSRTI)
developed a cost estimating toolbox. The toolbox is a database resource that
provides comprehensive information for staff to use when preparing IGCEs for
Remedial Action Contracts (RACs). It defines IGCEs and the associated cost
elements and provides the purpose for developing IGCEs. Spreadsheet templates
are provided for several phases of RAC contracts and can serve as a basis for staff
to prepare their own IGCEs. The toolbox emphasizes the importance of
documenting assumptions when preparing IGCEs. It also provides model SOWs,
as well as IGCE checklists.
Scope and Methodology
GAO and the OIG have historically raised concerns regarding EPA's preparation
and use of IGCEs. In a report issued in 2007, the OIG discussed problems
relating to EPA's use and management of IGCEs. To address these concerns, we
performed this audit from June 2008 to October 2009 in accordance with
generally accepted government auditing standards issued by the Comptroller
General of the United States. These standards require that we plan and perform
the audit to obtain sufficient and appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
The scope of this report deals only with IGCEs for EPA Superfund contracts. We
reviewed the active contracts listing to determine which to include in our sample.
We judgmentally selected contracts based on factors such as contract type, region
or area where the contract is located, dollar value, period of performance, etc. In
total, we selected 17 Superfund contracts from Headquarters and Regions 2, 4, 5,
and 7. For each contract we reviewed, we judgmentally selected multiple work
assignments, task orders, and/or technical direction documents for further review.
We reviewed the corresponding files for information relating to cost estimates.
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Appendix A contains a complete list of the Superfund contracts we reviewed as
well as the work assignments, task orders, and/or technical direction documents
reviewed from each.
We conducted site visits to each location within our sample. During the site
visits, we reviewed the overall contract, SOW, and documents from the preaward
file relating to cost estimating for each contract in our sample. We reviewed
documents ordering work (i.e., work assignments, task orders, and technical
direction documents) from each contract for information relating to cost
estimating. We interviewed contracting officers and project officers associated
with the contracts in our sample. In several instances, we also interviewed
personnel at the level where work is ordered to gain a better understanding of the
cost estimating and negotiation processes.
We reviewed IGCEs to determine their overall quality. To measure the quality of
IGCEs, we developed a list of the following five criteria that were taken from
EPA's Guide for Preparing Independent Government Cost Estimates and an
exposure draft of GAO's Cost Assessment Guide, which became final in March
2009.
•	The task is clearly identified: Estimator must be provided with a clear
description of the task, including ground rules, assumptions, and technical
and performance characteristics relating to the task. The estimate's
constraints and conditions must be clearly identified to ensure the
preparation of a well-documented estimate. A well-written SOW is
integral to the development of an IGCE.
•	Relevant data is identified and used: To the extent possible, multiple
sources of data should be used. The estimator(s) should determine the
availability of historical data and use that which relates to the applicable
task.
•	A defined/structured estimating process is used: The estimator(s)
should determine and document the process for estimating prior to starting
the process and document why the method was selected. The estimating
process should be accomplished at the task level through the use of the
work breakdown structure, created using either a bottom-up or top-down
approach.
•	The cost estimate is revised as program changes occur because large
changes that affect costs can significantly influence program
decisions: Cost estimates need to be fluent and refined as work and
planning progress. A fluent cost estimating process provides an allowance
for uncertainties to be addressed as they become known.
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• The assumptions for the IGCE are documented, and the IGCE is
complete: The rationale for the IGCE should be documented and the
IGCE should contain all required tasks.
Related Audit Coverage
While conducting this audit, we determined that EPA's Acquisition Regulation
contains language that requires EPA to provide total labor hour estimates to the
contractor within work assignments. If this information is provided to the
contractor prior to receiving the proposal, EPA jeopardizes the assurance of cost
reasonableness and overall effectiveness of the estimating process. To address
this issue, we issued a separate report, "EPA Should Stop Providing Estimates of
Total Labor Hours to Contractors, " on September 9, 2009 (OIG Report No.
09-P-0229).
Internal Control Structure
In planning and performing our audit, we reviewed management controls related
to our objectives. Specifically, we examined EPA's Contracts Management
Manual (CMM), EPA's Acquisition Regulation, the OAM guide for developing
IGCEs, an Office of Federal Procurement Policy letter, and several OSWER
Directives. We reviewed Quality Assessment Plans (QAP) from each program
operating division. We also looked at OAM's review of the QAPs.
We reviewed documents EPA completed in compliance with the Federal
Managers' Financial Integrity Act. This included a review of numerous
documents within EPA's Office of Administration and Resources Management's
(OARM) Fiscal Year 2008 Federal Managers' Financial Integrity Act Assurance
Letter. EPA did not report any material or Agency weaknesses related to its
preparation and use of IGCEs.
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Chapter 2
EPA Superfund Can Improve Its
Independent Government Cost Estimates
EPA can improve Superfund IGCEs and the cost estimating process. Superfund
program staff are not sufficiently documenting rationale, assumptions, and
changes relating to its IGCEs. Program staff sometimes rely on the contractor's
cost estimates without evaluating why it differs from the IGCE. In some cases,
EPA program staff do not prepare an IGCE for contract actions in excess of the
simplified acquisition threshold. GAO and OAM guides address these issues by
indicating that all aspects of cost estimating should be documented and IGCEs
should be updated when significant changes occur. Further, the CMM requires
project officers to submit IGCEs for all contract actions with a potential value that
will exceed the simplified acquisition threshold of $100,000. A primary reason
Superfund IGCEs need improvement is because there is an overall lack of
emphasis by management on the preparation and use of IGCEs. The guide and
other resources related to IGCEs are outdated and employees responsible for
preparing and reviewing IGCEs are undertrained. As a result, the value of the
IGCE as a tool for ensuring fair and reasonable contract prices is diminished.
Superfund Staff Need to Better Document Rationale, Assumptions,
and Changes
Superfund IGCEs lacked documentation for the basis of the estimated costs for
30 of the 42 contract actions we reviewed. OAM's IGCE guide specifies that the
reasons costs are included within IGCEs should be documented as well as any
assumptions made that may impact costs. Documenting the rationale and
assumptions associated with cost estimates will provide sound support to use
during negotiations with the contractor. GAO's Cost Estimating and Assessment
Guide specifies that all aspects of cost estimates should be documented.
Documentation supporting IGCEs should include information that will allow a
cost analyst unfamiliar with the program to determine how the estimate was
developed.
The IGCEs were missing supporting documentation such as the reason for
proposed labor hours, the labor mix, travel costs, etc. For example, one work
assignment under a RAC contract was broken down into nine different tasks. The
IGCE contained level-of-effort estimates by task and was developed using a
template that factors in historical rates such as average labor category rates, and
historical indirect rates. However, Superfund program staff did not document
assumptions for specific level-of-effort estimates for the number of hours or other
direct cost amounts included in the IGCE. As another example, a task order under
an Emergency and Rapid Response Services (ERRS) contract contained a SOW
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that clearly described 11 different tasks to be carried out. Even though the SOW
clearly described the tasks, the IGCE did not explicitly document the
assumptions, rationale, or historical basis (if any) for the number of hours
estimated. GAO recommends that to the extent possible, multiple sources of data
should be used when preparing an IGCE. GAO also recommends that cost
estimators determine the availability of historical data and use that which relates
to the applicable task. Without adequate documentation of the rationale,
assumptions, or historical data to support cost estimates, the IGCE does not
provide the information needed to evaluate the contractor's proposed prices.
For 9 of 42 contract actions, Superfund program staff did not update IGCEs to
reflect significant changes to the scope of work. GAO's cost estimating guide
states that estimates should be updated to reflect changes, especially large
changes, since they can significantly impact program decisions. However, nine
IGCEs were not updated when significant changes occurred to the corresponding
task order/work assignment. For example, one work assignment under a RAC 2
contract underwent changes resulting in a substantial decrease in the cost
estimate, but the IGCE was not updated. The initial IGCE, completed in June
2006, estimated costs would range from $21 million to $31.5 million. After a
third contract revision in March of 2008, the contractor's estimate was approved
for $15.8 million. For each revision, the contractor submitted a revised workplan.
However, program staff did not revise the IGCE during a 2Vi year span of the
work assignment. The only revised IGCE was completed in October 2008,
one week prior to the OIG site visit. If IGCEs are not updated when significant
changes occur, Superfund program staff may not have the necessary information
to make important program decisions, such as distribution of resources and
negotiation of contract price.
Superfund Staff Should Not Rely on Contractor Proposed Amounts
When there was a difference between the IGCE and contractor's proposed price,
Superfund program staff accepted the contractor's price without additional
analysis in 8 of 42 (19 percent) cases reviewed. The IGCE is a tool program staff
use when reviewing the contractor's proposed price. Program staff should
compare the hours and rates contained in the proposal to those estimated within
the IGCE. Such an analysis would allow program staff to determine whether
proposals overstate or understate work, or whether prices are too high or low, and
determine the fair and reasonable price for labor hours. Superfund program staff
are not always using the IGCE to conduct this analysis.
In eight cases, the final agreed-to price was the same as the contractor's proposal
and there was no evidence that program staff examined the reasons for the
difference between the IGCE and proposed price (see Table 2-1 below).
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Table 2-1: Examples where Superfund relied on contractor estimates
Between
Contractor H Approved H Contractor
Example J IGCE J Estimate J Amount J Estimate
1	$12,935	$64,988	$64,988	$52,053
2	$71,383	$72,435	$72,435	$1,052
3	$27,862,037	$14,845,475	$14,845,475 $-13,016,562
4	$2,193,769	$2,332,238	$2,332,238	$138,469
5	$109,789	$119,316	$119,316	$9,527
6	$65,046	$48,151	$48,151	$-16,895
7	$110,452	$117,335	$117,335	$6,883
8	$111,948	$106,531	$106,531	$-5,417
Source: OIG analysis of EPA data.
Program staff sometimes accept the contractor's proposal if it is within a certain
percentage of the IGCE. However, the percentage used was not consistent and
varied among those interviewed. For example, the program staff responsible for
items 7 and 8 in Table 2-1 stated that they generally accept any proposed costs
within 10 percent of the IGCE without further analysis. In the case of example 6,
program staff stated that they generally accept any proposal within 20 percent of
the IGCE without additional analysis. In this case, the program staff accepted the
contractor's proposal without additional analysis even though the proposal was
26 percent less than the IGCE. Even though the amount proposed was less,
Superfund program staff cannot be reasonably assured that some of the individual
amounts within the proposal were not overstated. The costs may be significantly
understated and relying on these amounts could impact the program's ability to
reasonably plan future work. By not analyzing why there was a difference in the
price, or documenting the analysis of reasons for the difference, Superfund
program staff diminished the value of the IGCE in determining the reasonableness
of the final price.
Superfund Staff Need to Prepare IGCEs for All Contract Actions Over
the Simplified Acquisition Threshold
Superfund program staff are not always producing IGCEs for work ordered with
estimated costs expected to exceed the simplified acquisition threshold of
$100,000. The CMM states that, "POs [project officers] shall submit IGCEs for
all contract actions with a potential value in excess of the FAR threshold for
simplified acquisitions." The CMM further states that, "COs [contracting
officers] may also require IGCEs for actions below the FAR threshold for
simplified acquisitions" if deemed necessary and appropriate. However, for three
contracts in our sample, POs did not prepare IGCEs as required.
• The PO for the Region 5 Superfund Technical Assessment and Response
Team (START) contract did not prepare IGCEs at the task order or
technical direction level. This contract establishes large task orders that
generally describe the work to be done in broad terms. These task orders
act as a sort of overall budget for the task. During contract performance,
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work is ordered under these task orders using technical direction
documents. These technical direction documents specifically describe the
work to be done (location, scope, etc.). The project officer indicated that
she does not prepare IGCEs for the START contract because she does not
believe they are useful.
•	Region 7 does not prepare IGCEs at the technical direction level for its
Environmental Services Assistance Team (ESAT) contract. The ESAT
contract uses 11 task orders that describe the work to be performed in
broad terms. Under these task orders, work is later specifically defined
and ordered using technical direct documents. However, Region 7 only
prepares IGCEs at the broader task order level. For example, one of the
task orders broadly directs work to be performed for Superfund program
support. Later, specific descriptions of work to be performed are
presented in a technical direction document, such as "Analyze 1 PT water
sample for Selenium, by Region 7 approval methods. Process the data and
prepare final data reports."
•	Region 4 did not prepare an IGCE for one task order totaling almost
$1.3 million under its ERRS contract. The task order was funded through
the Coast Guard's National Pollution Fund (but managed by EPA) and no
IGCE was prepared. EPA staff informed us that the on-site coordinator is
warranted up to $50,000 to respond to an oil spill emergency. Beyond
that, approval must be given by the Coast Guard case officer. The initial
award for this task order was for $150,000 and no IGCE was done because
it was an emergency situation. However, the task order was amended
three times, bringing the total approved cost ceiling to almost $1.3 million,
and no IGCE was ever prepared. While we recognize that the initial
emergency should be responded to without delay, we believe Superfund
program staff should prepare an IGCE once the situation has stabilized
and before it awards further funding.
EPA Should Place Greater Emphasis on IGCEs
A primary reason Superfund IGCEs need improvement is because management
does not adequately emphasize the preparation and use of IGCEs. The OAM
IGCE guide has not been updated since 1998. Additionally, training on IGCEs
has been minimal and program office and regional reviews of the acquisition
process do not directly address IGCEs. The lack of emphasis has resulted in the
conditions identified in this audit and diminished the value of the IGCE as a tool
for ensuring that contractor prices are reasonable.
OAM and the Superfund program office developed tools and guidance relating to
IGCEs more than 10 years ago. The CMM refers program staff to the student
guide for guidance on preparing IGCEs. The guide has not been updated in the
last 10 years, and does not include some current practices, such as using a
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technical direction document to order work. Also, in March 2009, GAO
completed a cost estimating guide. EPA's guide needs to reflect the information
contained in GAO's cost estimating guide.
Superfund program staff involved in the cost estimating process informed us that
training relating to IGCEs has been minimal within the last 10 years. EPA does
not have a specific training course for IGCEs. Project Officers receive some
IGCE training as part of their Contracting Officer Representative training.
However, IGCEs make up only a few pages of the training text.
Additionally, some employees were not aware of the guidance and tools available
to assist in preparing IGCEs. For example, OSRTI developed a cost estimating
toolbox. It provides comprehensive information for staff to use when preparing
IGCEs for RAC contracts. Six of the nine RAC project officers/work assignment
managers interviewed were not aware of the toolbox. This toolbox is of little use
for those employees who are not aware it exists.
EPA also needs to better emphasize IGCEs in its QAPs. QAPs are management
plans developed by EPA program offices and regions to help ensure an overall
effective acquisition process. The QAPs for EPA program offices and regions did
not address the preparation and/or use of IGCEs.
Conclusion
The IGCE is a tool that the Superfund program can use to evaluate the
reasonableness of the contractor's proposed price. A quality IGCE includes
documentation of assumptions and reflects updates based on changed conditions.
When Superfund prepares IGCEs, the assumptions and rationale are not always
documented and updated. Additionally, Superfund does not always document the
reasons for accepting the contractor's price when it differs from the IGCE.
Finally, IGCEs are not used for all contract actions. Superfund program staff
should be preparing IGCEs and comparing the estimated hours and rates to those
contained within the contractor's proposal. This comparison will enhance the
program's ability to determine whether proposals overstate or understate work, or
whether prices are too high or low. Without a fully supported IGCE, Superfund
program staff cannot conduct such an analysis. As a result, Superfund is
diminishing the IGCE's value as a tool to ensure fair and reasonable contract
prices.
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Recommendations
We recommend that the Assistant Administrator for Administration and
Resources Management:
2-1 Require OAM to update its IGCE guide to address:
•	Technical direction documents that exceed the simplified
acquisition threshold.
•	Emergency acquisitions.
•	The GAO Cost Estimating and Assessment Guide.
2-2 After the OAM IGCE guide is updated, require EPA regions and program
operating divisions to conduct a review to verify compliance with the
updated guide.
We recommend that the Assistant Administrator for Administration and
Resources Management and the Assistant Administrator for Solid Waste and
Emergency Response:
2-3 Eliminate the practice of accepting contractor estimates that differ from
IGCEs without examining the reason for the difference.
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response:
2-4 Require the Superfund program to update, distribute, and maintain its
supplemental tools and guidance used for IGCE preparation (e.g.,
OSRTI's cost estimating toolbox).
We recommend that the Assistant Administrator for Administration and
Resources Management and the Assistant Administrator for Solid Waste and
Emergency Response:
2-5 Instruct OAM and the Superfund program office to provide training to
Superfund program staff on IGCE tools and databases, as well as OAM
and Superfund IGCE guidance.
Agency Comments and OIG Evaluation
EPA agreed with recommendations 2-1, 2-4, and 2-5, and provided milestone
dates for completion of the following items:
•	Revise OAM's IGCE guide (June 1, 2010)
•	Update, distribute, and maintain Superfund's supplemental tools for IGCE
preparation (September 30, 2010)
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• Provide training to Superfund staff on IGCE tools and guidance
(September 30, 2010).
The Agency's response will address these recommendations.
Regarding recommendation 2-2, EPA did not agree that it should incorporate
compliance with the IGCE guide into its QAP because the QAP is an OAM tool
and not a program tool. EPA stated that preparation of IGCEs is the
responsibility of the program office. EPA believes that by updating the IGCE
guide and providing training to the program office, IGCE quality will improve.
At the exit conference, OAM officials agreed that a review to verify compliance
was needed, but expressed a preference to not include that as part of the QAP.
Based on the discussion, we revised the recommendation. EPA will need to
provide an action plan, with milestone dates, for addressing the recommendation
when responding to the final report.
In response to recommendation 2-3, the Agency stated that the recommendation
should be addressed to OSWER and that the offices will work together to update
the IGCE guide and training. We revised the recommendation to include
OSWER as suggested. At the exit conference, OAM officials clarified that the
updated IGCE guide will address the practice of accepting contractor estimates
that differ from IGCEs without examining the reason for the difference. With the
clarification, the response addresses the recommendation.
See EPA's full response in Appendix B.
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Chapter 3
EPA Region 7 Improved Cost Management
for Its ESAT Contract
Based on our audit work, EPA Region 7 took actions to improve the cost
management of the ESAT contract. EPA Region 7 had not been reviewing and
managing ESAT contract costs at the Technical Direction Form (TDF) level,
which is the level where work is ordered. EPA's CMM provides that it is the
policy of the Government to review contract invoices thoroughly for cost
reasonableness to facilitate payment of costs which are allowable, allocable, and
reasonable. Adequate invoice reviews were not occurring because the Region 7
ESAT contract gives the project officer the flexibility to determine the level of
detail that needs to be contained in monthly financial reports. The PO did not
require the contractor to provide cost data at the TDF level. Without detailed cost
data broken out by TDF, the project officer could not determine the
reasonableness of invoiced costs charged for specific work performed.
During the audit, we discussed with Region 7 management and staff our concerns
about the reporting under the ESAT contract. Region 7 believed that the invoices
did contain all the necessary information to ensure charges were fair and
reasonable. However, the Region did acknowledge that the information was not
contained in an effective format for review and that efficiencies in the review
process could be realized by requiring data at the TDF level in monthly reports.
Therefore, Region 7 management and staff fully implemented our planned
recommendation to require the contractor to include detailed cost breakouts by
task order and TDF in its monthly invoices. Based on Region 7's timely
response, we determined no further recommendations are needed regarding this
finding in this report.
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10-P-0065
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Agreed To
Amount
2-1 10 Require OAM to update its IGCE guide to address:
•	Technical direction documents that exceed
the simplified acquisition threshold.
•	Emergency acquisitions.
•	The GAO Cost Estimating and Assessment
Guide.
2-2 10 After the OAM IGCE guide is updated, require EPA
regions and program operating divisions to conduct
a review to verify compliance with the updated
guide.
2-3 10 Eliminate the practice of accepting contractor
estimates that differ from IGCEs without examining
the reason for the difference.
2-4 10 Require the Superfund program to update,
distribute, and maintain its supplemental tools and
guidance used for IGCE preparation (e.g., OSRTI's
cost estimating toolbox).
2-5 10 Instruct OAM and the Superfund program office to
provide training to Superfund program staff on
IGCE tools and databases, as well as OAM and
Superfund IGCE guidance.
Assistant Administrator for 06/01/2010
Administration and
Resources Management
Assistant Administrator for
Administration and
Resources Management
Assistant Administrator for 06/01/2010
Administration and
Resources Management and
Assistant Administrator for
Solid Waste and Emergency
Response
Assistant Administrator for 09/30/2010
Solid Waste and Emergency
Response
Assistant Administrator for
Administration and
Resources Management and
Assistant Administrator for
Solid Waste and Emergency
Response
09/30/2010
1 O = recommendation is open with agreed-to corrective actions pending;
C = recommendation is closed with all agreed-to actions completed;
U = recommendation is undecided with resolution efforts in progress
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10-P-0065
Appendix A
List of Superfund Contracts Reviewed
Region
Contract
WA/TO/TDD*
Type of Contract




Region 4
68-W-99-043
WA-015
RAC

68-W-99-043
WA-648
RAC





EP-S4-07-02
TO 0035
ERRS III

EP-S4-07-02
TO 0035 - Mod 1
ERRS III

EP-S4-07-02
TO-0035 - Mod 2
ERRS III

EP-S4-07-02
TO-0035 - Mod 3
ERRS III

EP-S4-07-02
TO 0039
ERRS III

EP-S4-07-02
TO 0052
ERRS III





EP-W-05-053
TO 001/TDD 026
START III

EP-W-05-053
TO 001/TDD 049
START III

EP-W-05-053
TO 003/TDD 041
START III




Region 5
EP-S5-06-04
TDD-S05-0005-0609-067
START III

EP-S5-06-04
TDD-S05-0001-0711-022
START III





EP-S5-06-01
WA 021-RARA-1523
RAC 2

EP-S5-06-01
WA 044-RDRD-B51Z
RAC 2





EP-S5-06-06
TO 3
ROC 3

EP-S5-06-06
TO 8
ROC 3




Headquarters
EP-W-06-019
TO 3
Region 7ESAT

EP-W-06-019
TO 10
Region 7 ESAT





68-W-02-073
WA 7
OSRE2

68-W-02-073
WA 19
OSRE2





EP-W-05-060
WA 1-08
HW Methods Support

EP-W-05-060
WA 1-11
HW Methods Support




Region 7
EP-S7-05-06
TO 005
RAC II

EP-S7-05-06
TO 0027
RAC II

EP-S7-05-06
TO 0062
RAC II

EP-S7-05-06
TO 0010
RAC II





EP-S7-05-05
TO 0028
A&E Services

EP-S7-05-05
TO 003
A&E Services

EP-S7-05-05
TO 0010
A&E Services

EP-S7-05-05
TO 015
A&E Services
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10-P-0065
Region
Contract
WA/TO/TDD*
Type of Contract





EP-R7-07-02
TO 0011
ERRS, Region 10

EP-R7-07-02
TO 0013
ERRS, Region 10

EP-R7-07-02
TO 007
ERRS, Region 10





EP-S7-06-01
TO 0023
START III

EP-S7-06-01
TO 0048
START III

EP-S7-06-01
TO 0051
START III








Region 2
EP-W-04-054
TO 0065
ERRS

EP-W-04-054
TO 0057
ERRS





68-W-98-214
153-RDRD-0291
RAC

68-W-98-214
158-RARA-01G1
RAC





EP-W-05-041
TO 0010
ROC III

EP-W-05-041
TO 014
ROC III





EP-W-05-048
WA 081
Site Assessment Team 2

EP-W-05-048
WA 057
Site Assessment Team 2
Source: OIG analysis of contract data.
A&E
Architect and Engineering
HW
Hazardous Waste
OSRE
Office of Site Remediation Enforcement
ROC
Regional Oversight Contract
TDD
technical direction document
TO
task order
WA
work assignment
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10-P-0065
Appendix B
Agency Response
December 17, 2009
MEMORANDUM
SUBJECT: Response to Draft Audit Report: EPA Superfund Can Improve its Preparation and
Use of Independent Government Cost Estimates, Project OA-FY08-0255
FROM: Craig E. Hooks
Assistant Administrator
TO:	Janet Kasper
Director, Contracts and Assistance Agreements
Office of the Inspector General
We appreciate the opportunity to comment on the draft report entitled "EPA Superfund
Can Improve its Preparation and Use of Independent Government Cost Estimates," dated
November 13, 2009. Our comments on the report and recommendations are below:
Specific Recommendations and Responses:
Recommendation 2-1 - We recommend the Assistant Administrator for OARM
require OAM to update its IGCE guide to address:
•	Technical direction documents that exceed the Simplified Acquisition
Threshold
•	Emergency acquisitions
•	The Government Accountability Office's cost estimating guide
Response - We concur with this recommendation. This will be a development process to
fold in the three new areas above into the current IGCE guide. OAM will begin the
development and stakeholder review process immediately with completion of guide
revisions by June 1, 2010.
Recommendation 2-2 - We recommend that the Assistant Administrator for
OARM, after the OAM IGCE guide is updated, require EPA regions and program
operating divisions to include compliance with the IGCE guide as part of their
Quality Assurance Programs.
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10-P-0065
Response - While we agree that OAM will update the IGCE guide (see Recommendation
2-1 response above) and work with OSWER to provide IGCE training to Superfund
program staff (see Recommendation 2-5 response below), we do not believe that
contracting offices should be required to modify their QAPs. Section 4.2 of the
Acquisition Handbook states that QAPs shall contain oversight activities for "all primary
contracting workload functions performed by the contracting organization." Page 1 of
this report states that "EPA's program offices are responsible for preparing IGCEs." We
do not believe that the QAPs need to be modified to specifically focus on primary
activities which fall within EPA's program offices.
The Contract Management Manual Section 7.3, "Procurement Initiation and Related
Documentation," lists the Guide for Preparing IGCEs as a guidance source for program
officials, in addition to providing an on-line link to this document. The updated guidance
will be posted on the intranet by June 30, 2010. By updating the guide, assisting
OSWER in providing IGCE training to program officials, and performing current QAP
oversight activities related to reviewing procurement request packages, we believe OAM
will help improve the quality of IGCEs prepared by its customers.
Recommendation 2-3 - We recommend the Assistant Administrator for OARM
eliminate the practice of accepting contractor estimates that differ from IGCEs
without examining the reason for the difference.
Response - We believe this recommendation should be directed to the Assistant
Administrator of OSWER, as well as OARM. These Offices share IGCE responsibilities,
and they will work together to update the guidance and provide training, which will
effectively address this recommendation by June 1, 2010.
Recommendation 2-4 - We recommend the Assistant Administrator for OSWER:
require the Superfund program to update, distribute and maintain its supplemental
tools and guidance used for IGCE preparation (e.g., OSRTI Cost Estimating
Toolbox).
Response - We concur with this recommendation. OSWER will work closely with OAM
to complete this action by September 30, 2010. It should be noted that OSWER provided
formal IGCE training at the Superfund National Association of Remedial Project
Managers' (NARPM) annual training conference and the Superfund Project
Officers/Contracting Officers' (PO/CO) annual conference in July 2009.
Recommendation 2-5 - We recommend the Assistant Administrator for OARM and
Assistant Administrator for OSWER instruct OAM and the Superfund program
office to provide training to Superfund program staff on IGCE tools and databases,
as well as OAM and Superfund IGCE guidance.
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10-P-0065
Response - We concur with this recommendation. OSWER will work closely with OAM
(after guidance updates are completed) to complete the action by September 30, 2010.
General Comments:
Abbreviations - RAC stands for Remedial Action Contract, it is written as Response
Action Contract in the report. This also needs to be corrected in Chapter 1, under
Noteworthy Achievements.
Chapter 1 - Scope and Methodology, page two, second paragraph, first sentence - We
recommend listing the various types of Superfund contracts included in review (e.g.,
Removal, Lab, Remedial, Federal Facilities or Enforcement).
Chapter 2 - Superfund Needs to Better Document Rationale, Assumptions, and
Changes, page five, first paragraph, last sentence - We recommend changing the
sentence to read, "Documentation supporting IGCEs should be included that will allow a
cost analyst unfamiliar with the program to determine how the estimate was developed."
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10-P-0065
Appendix C
Distribution
Office of the Administrator
Assistant Administrator for Administration and Resources Management
Assistant Administrator for Solid Waste and Emergency Response
Regional Administrator, Region 7
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
General Counsel
Director, Office of Superfund Remediation and Technology Innovation,
Office of Solid Waste and Emergency Response
Acting Director, Office of Acquisition Management, Office of Administration
and Resources Management
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Audit Follow-up Coordinator, Office of Administration and Resources Management
Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response
Audit Follow-up Coordinator, Region 7
Acting Inspector General
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