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pro^ฐ OFFICE OF INSPECTOR GENERAL
I	I u-s- ENVIRONMENTAL protection agency
Operating efficiently and effectively
EPA May Have Overpaid for
Its $13 Million Time and
Attendance System by
Not Following Information
Technology Investment
Requirements
Report No. 20-P-0134	April 13, 2020
$8 million
Taxpayer
I savings? y
ALTERNATIVE

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Report Contributors:	Michael Davis
Sabrina Jones
Nicole Pilate
Gloria Taylor-Upshaw
Abbreviations
CIO
Chief Information Officer
EA
Enterprise Architecture
EPA
U.S. Environmental Protection Agency
IBC
U.S. Department of Interior's Interior Business Center
IT
Information Technology
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
OMB
Office of Management and Budget
SLCM
System Life Cycle Management
Cover Image: The EPA missed the opportunity to save up to $8 million in taxpayer funds by
not performing cost and alternatives analyses. (EPA OIG image)
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
20-P-0134
April 13, 2020
Why We Did This Project
We conducted this audit to
determine whether the
U.S. Environmental Protection
Agency's PeoplePlus—its time
and attendance reporting
system—is efficient and
effective for use in time and
attendance and cost allocation
processes and whether the
system has effective practices,
programs, and policies.
The EPA upgraded its
PeoplePlus time and attendance
system in October 2017. The
Office of Management and
Budget requires agencies to
consider existing shared service
centers and conduct an
alternatives analysis before
making decisions to improve,
enhance, or modernize existing
information technology
investments. The OMB also
requires agencies to conduct
definitive technical, cost, and
risk analyses of alternative
design implementations over the
full life cycle costs of IT products
and services.
The Office of the Chief Financial
Officer manages PeoplePlus.
This report addresses the
following:
• Operating efficiently and
effectively.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
EPA May Have Overpaid for Its $13 Million Time and
Attendance System by Not Following Information
Technology Investment Requirements
What We Found
The EPA's OCFO did not perform a required cost
analysis or consider alternative options before
awarding contracts worth more than $13 million to
upgrade PeoplePlus to the 9.2 version.
Additionally, the OCFO did not conduct four of the
five reviews required by the EPA's Chief
Information Officer Classification No. 2121-P-03.0, System Life Cycle
Management Procedure, which provides management control and direction
over decision-making.
Because the EPA did not perform the cost and alternative time and attendance
systems analyses, it cannot confirm that the PeoplePlus upgrade was the best
use of taxpayer funds. Also, the EPA may have missed the opportunity to
reduce costs through its shared service provider, the U.S. Department of
Interior's Interior Business Center. If the EPA had selected to use the IBC's
system rather than PeoplePlus, the Agency could have saved approximately
$7.7 million to $8.1 million, based on IBC estimates.
When internal control reviews are not performed, it puts the Agency at risk for
making investment choices that waste taxpayer funds. The lack of reviews
resulted in a missed opportunity for the Agency to be able to identify the most
cost-effective system with the potential to realize the most operational
efficiencies.
Recommendations and Planned Agency Corrective Actions
We recommend that the chief financial officer 1) perform the required cost
analysis over the full life cycle of PeoplePlus and 2) analyze alternatives to the
system. Also, for Recommendations 1 and 2, we recommend that the Agency
determine whether to exercise remaining extension options in the PeoplePlus
contract, which would cost $3.1 million through February 2023. In addition, we
recommend that the chief financial officer design and implement internal
controls to 3) verify that staff complete the necessary reviews to obtain the
necessary approvals and maintain the required documentation, and 4) verify
that staff are following the system life cycle policy and procedure.
The EPA agreed with our recommendations. Recommendations 1 and 2 are
resolved with corrective action pending, and Recommendations 3 and 4 are
complete.
By not performing cost
and alternative
analyses, the EPA
missed the opportunity
to save taxpayer funds.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
April 13, 2020
MEMORANDUM
SUBJECT: EPA May Have Overpaid for Its $13 Million Time and Attendance System by Not
Following Information Technology Investment Requirements
Report No. 20-P-0134
This is our report on the subject audit conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this audit was OA&E-FY18-0283. This
report contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. Final determinations on matters in this report will be made by EPA managers in accordance
with established audit resolution procedures.
The EPA's Office of the Chief Financial Officer is responsible for implementing the recommendations in
this report.
In accordance with EPA Manual 2750, your office provided or completed acceptable corrective actions in
response to the OIG recommendations. Corrective actions are pending for Recommendations 1 and 2.
Recommendations 3 and 4 are complete. 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 as 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
Sean W. O'Donnell
TO
David Bloom, Deputy Chief Financial Officer
We will post this report to our website at www.epa.gov/oig.

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EPA May Have Overpaid for Its $13 Million
Time and Attendance System by Not Following
Information Technology Investment Requirements
20-P-0134
	Table of Contents
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Office		2
Scope and Methodology		2
Prior Reports		4
2	EPA Did Not Follow IT Investment Requirements with
Its PeoplePlus Upgrade		5
Federal Law and Policy Require Cost and Alternatives Analyses		5
EPA Awarded Contracts Totaling Over $13 Million Without Cost or
Alternatives Analyses		6
EPA Did Not Have Authorization to Not Perform
Required Analyses and Relied on Outdated Estimates		8
EPA Missed Opportunities to Save Taxpayer Dollars		8
Recommendations		11
Agency Response and OIG Assessment		11
3	EPA Did Not Perform Oversight Reviews and Maintain
Required Documentation		12
Federal Regulations and EPA Policy Require Multiple Reviews
and Maintenance of Documentation When Making IT Investments		12
EPA Did Not Perform SLCM Reviews or Maintain Related Documentation ...	14
EPA Was Not Focused on PeoplePlus 9.2 Upgrade		15
EPA Missed Opportunities to Potentially Save Taxpayer Funds
and Is Noncompliant with Federal Instructions		15
Recommendations		16
Agency Response and OIG Assessment		16
Status of Recommendations and Potential Monetary Benefits		17
Appendices
A Agency Response to Draft Report	 18
B OIG's Assessment of Agency's Response to Draft Report	 23
C Distribution	 24

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Chapter 1
Introduction
Purpose
The Office of Inspector General of the U.S. Environmental Protection Agency
conducted an audit to determine whether EPA's time and attendance system,
PeoplePlus, is efficient and effective for use in the time and attendance and cost
allocation processes and whether the system has effective practices, programs,
and policies.
Background
The EPA uses PeoplePlus as its official time and attendance reporting system.
PeoplePlus supports the Office of Chief Financial Officer's payroll processing
requirements and the Office of Mission Support's human capital management
responsibilities.
In October 2004, the EPA deployed PeoplePlus, a highly customized, complex
application that provided an agencywide integrated system based on the federal
PeopleSoft version 8.3 commercial off-the-shelf application.
In 2013, the EPA selected the U.S. Department of Interior's Interior Business
Center to provide human resources and payroll services in response to the Office
of Management and Budget Human Resources Line of Business program. The
Office of Management and Budget program sought to improve customer service,
achieve cost savings, and increase operational efficiencies by implementing
governmentwide interoperable human resources and addressing duplicative
human resource systems across the federal government. The IBC is a federal
shared services provider offering acquisition, financial management, and human
resources systems and services for the Department of the Interior and other
federal agencies.
The interagency agreement between the EPA and the IBC to migrate services to
the federal shared services provider included human resources, payroll, and a time
and attendance system called webTA. The EPA performed an alternative analysis
of webTA and PeoplePlus in 2013, which showed that retaining the existing
PeoplePlus time and attendance system was a less costly option than moving to
webTA due to technical and time constraints. In 2014, the Agency decided to
retain the PeoplePlus time and attendance system, upgrade it from the 8.3 to the
8.9 version, and remove the IBC's webTA system. However, the EPA identified
webTA as a viable choice for future implementation. The EPA also retained the
IBC for human resources and payroll services.
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The EPA upgraded the PeoplePlus system from version 8.9 to 9.2 in
October 2017. The OCFO stated that this system upgrade:
•	Removed most of the customizations from the PeoplePlus
time and attendance system.
•	Moved the support of the EPA's cost recovery requirements to
a delivered (commercial off-the-shelf) payroll cost accounting
component of Compass, which is the Agency's financial
management system.
•	Removed highly customized features to position the Agency
and the PeoplePlus time and attendance system for an easier
and less costly transition to a future shared service provider.
In conjunction with the upgrade to PeoplePlus 9.2, the EPA implemented a new
payroll cost allocation system. EPA employees use the PeoplePlus system to
record labor and leave hours; that data is then passed to the IBC for payroll
processing. The IBC's payroll data is imported into the EPA's financial system
for the allocation of labor costs.
Responsible Office
The OCFO provides financial services for the EPA and is responsible for
formulating and providing policies, reports, and oversight essential for the
financial operations of the EPA. The Office of Technology Solutions within the
OCFO is responsible for information technology planning, as well as the
development and deployment of financial and resource management systems for
the EPA. The OCFO manages the PeoplePlus system.
Scope and Methodology
We conducted this performance audit from October 2018 to December 2019, in
accordance with generally accepted government auditing standards issued by the
Comptroller General of the United States. 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 objectives.
We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
To answer our objectives, we reviewed the following laws, federal regulations,
and Agency policies and procedures related to PeoplePlus:
•	Clinger-Cohen Act of 1996 (Public Law 104-106).
•	OMB Circular A-13 0, Managing Information as a Strategic Resource,
July 28, 2016.
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•	OMB Circular No. A-123, Management's Responsibility for Enterprise
Risk Management and Internal Control, July 15, 2016.
•	OMB Memorandum, M-13-23, Appendix D to Circular No. A-123,
Compliance with the Federal Financial Management Improvement Act of
1996, September 20, 2013.
•	OMB Memorandum, M-17-26, Reducing Burden for Federal Agencies by
Rescinding and Modifying OMB Memoranda, June 15, 2017.
•	OMB Memorandum, M-11-31, Delivering an Efficient, Effective, and
Accountable Government, August 17, 2011.
•	EPA Classification No. CIO-2121-P-03.0, System Life Cycle Management
(SLCM) Procedure, September 21, 2012 (updated December 21, 2017).
•	EPA Directive No. CIO-2121.1, System Life Cycle Management (SLCM)
Policy, December 21, 2017.
•	EPA Directive No. CIO-2120.1, Capital Planning and Investment Control
Program Policy for the Management of Information Technology
Investments, December 21, 2017.
•	EPA Directive No. CIO-2122-P-01.1, Enterprise Architecture Governance
Procedures, December 21, 2017.
•	EPA Resource Management Directive System Number 2540-08-P1,
Payroll Time and Attendance Reporting, September 12, 2018, version 2
(updated June 27, 2019).
To determine whether the PeoplePlus system is efficient and effective, we:
•	Reviewed the EPA contracts related to the upgrade to PeoplePlus 9.2 and
the labor cost allocation system to determine the cost of the systems and
contractual and operational requirements.
•	Obtained a list of 15,846 PeoplePlus help desk tickets for fiscal year 2017,
fiscal year 2018, and through the second quarter of fiscal year 2019.
•	Surveyed 22 PeoplePlus coordinators, one from each EPA office and
region, and asked a standard set of questions related to the PeoplePlus
system and its ability to support their time and attendance needs.
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•	Interviewed the Office of Mission Support and OCFO staff members to
learn their duties and processes related to processing employee time and
attendance and using the PeoplePlus system.
•	Compared data obtained from the help desk tickets, interviews, and
surveys to identify patterns and the Agency's actions to resolve recurring
issues.
•	Obtained cost estimates from the IBC for its time and attendance systems
(webTA and Quicktime) and compared the cost of the two systems to
PeoplePlus 9.2 for fiscal years 2017 through 2022. The system cost
estimates include help desk services, which are provided as part of its
operations and maintenance cost. However, the cost estimates do not
include customization costs.
•	Held interviews and reviewed contract data for the cost allocation process.
We identified that EPA employees use PeoplePlus to record labor and
leave hours, which is then passed to the IBC for payroll processing.
Therefore, we concluded that PeoplePlus has limited involvement in the
cost allocation process.
Prior Reports
The EPA OIG issued several prior reports that relate to this audit:
•	Report No. 09-P-0206, EPA's Human Resources Management System Did
Not Deliver Anticipated Efficiencies to the Shared Service Centers, issued
August 11, 2009. The EPA's Office of Administration and Resources
Management lacked necessary cost analysis and OMB approval to upgrade
PeoplePlus with an automated workflow feature in support of the EPA
shared service centers. The Agency indicated that all corrective actions
were completed subsequent to the issuance of the report.
•	Report No. 2005-P-00019. PeoplePlus Security Controls Need
Improvement, issued July 28, 2005. The OIG found that, among other
things, PeoplePlus was implemented without adequate security controls
for user identifications and separation of security administrator duties. The
Agency indicated that all corrective actions were completed subsequent to
the issuance of the report.
•	Report No. 2005-P-00023, EPA Needs to Improve Oversight of Its
Information Technology Projects, issued September 14, 2005. The report
identified that the increased cost to deploy PeoplePlus could have been
averted or lessened if there was adequate oversight. The Agency indicated
that all corrective actions have since been completed subsequent to the
issuance of the report.
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Chapter 2
EPA Did Not Follow IT Investment Requirements with
Its PeoplePlus Upgrade
The EPA did not follow IT investment requirements, including conducting a cost
analysis before awarding contracts worth more than $13 million, when upgrading
PeoplePlus to the 9.2 system version. It also did not consider using a shared
service center or another alternative for its time and attendance system. The EPA
did not comply with the OMB Circular A-130, which requires agencies to make
decisions to improve, enhance, or modernize existing IT investments or to
develop new IT investments only after conducting an alternatives analysis to
determine the best value to the agency. The EPA also did not conduct a cost
analysis and consider existing federal shared services.
EPA management said that the chief information officer authorized the OCFO to
not perform a cost-benefit analysis for the PeoplePlus 9.2 upgrade. The OCFO
said that an alternatives analysis of a shared service center was not performed
because a review would have only returned the same decision as in 2013, which
was to not use the services. Based on federal shared center estimates, the EPA
missed saving up to $8 million and continues to miss the opportunity to put
$1.2 million of the $8 million to better use within the Agency. Also, the EPA
missed the opportunity to obtain help desk efficiencies by not using a federal
agency shared service center.
Federal Law and Policy Require Cost and Alternatives Analyses
Per 40 U.S. C., Subtitle III Information Technology Management, 11315, the
duties of the CIO include monitoring the performance of the Agency's IT
programs based on the applicable performance measurements and advising the
head of the Agency regarding whether to continue, modify, or terminate a
program or project.
OMB Circular A-130, Section 5.d.3.f, requires agencies to make:
Decisions to improve, enhance, or modernize existing IT
investments or to develop new IT investments are made only after
conducting an alternatives analysis that includes both government-
provided (internal, interagency, and intra-agency where applicable)
and commercially available options, and the option representing
the best value to the Government has been selected.
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The OMB Circular A-130 sections also identify the following requirements:
•	Section 5.(l.l.b—"Conduct definitive technical, cost, and risk analyses of
alternative design implementations, including consideration of the full life
cycle costs of IT products and services, including but not limited to,
planning, analysis, design, implementation, sustainment, maintenance, re-
competition, and retraining costs, scaled to the size and complexity of
individual requirements."
•	Section 5.(l.l.c—"Consider existing Federal contract solutions or shared
services when developing planned information systems, available within
the same agency, from other agencies, or from the private sector to meet
agency needs to avoid duplicative IT investments."
•	Section 5.d.l.e—"Ensure that decisions to improve existing information
systems with custom-developed solutions or develop new information
systems are initiated only when no existing alternative private sector or
governmental source can efficiently meet the need, taking into account
long-term sustainment and maintenance."
EPA Awarded Contracts Totaling Over $13 Million Without Cost or
Alternatives Analyses
The EPA did not perform a cost analysis and did not consider other alternatives
for its time and attendance services before contracting over $13 million to
improve and upgrade PeoplePlus from version 8.9 to version 9.2. We concluded
that PeoplePlus is effective for use in the time and attendance process but may not
be the most efficient use of Agency resources. The EPA contracted services for
the acquisition, operation, and maintenance of its PeoplePlus 9.2 system. Figure 1
summarizes the contracted cost for the system.
Figure 1: EPA contract services for PeoplePlus 9.2 with periods of performance
Operations &
maintenance contract
$9 M
Total contracted
services
(Acquisition contract
$4 M
February 2017-
February 2023
Source: EPA OIG image.
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The acquisition contract is for approximately $4 million with a period of
performance from July 1, 2015, through June 30, 2018. The operations and
maintenance contract for EPA's PeoplePlus system is ongoing. Table 1 outlines
the period of performance and award amounts for the PeoplePlus 9.2 operations
and maintenance contract. The contract has a base period and five option periods,
which total more than $9 million.
Table 1: PeoplePlus ongoing operations and maintenance contract details
PeoplePlus 9.2 operations
and maintenance contract
Period of performance
Award amount
Base Period
2/23/2017-2/22/2018
$1,412,671
Option Period 1
2/23/2018-2/22/2019
1,480,966
Option Period 2
2/23/2019-2/22/2020
1,492,231
Option Period 3
2/23/2020-2/22/2021
1,522,020
Option Period 4*
2/23/2021-2/22/2022
1,552,334
Option Period 5*
2/23/2022-2/22/2023
1,565,314
Total awarded

$9,025,536
Source: EPA OIG analysis.
*Option Periods 4 and 5, which total $3,117,648, have not been obligated.
As of April 2020, Contract Option Periods 4 and 5, which have a total award
amount of $3,117,648, had not begun and funds had not been obligated. The
contract allows the government to not elect Option Periods 4 and 5 for the
government's convenience if necessary. The contract also states that if the
government terminates the contract pursuant to the convenience termination
provision, it will not be obligated, under any circumstances, to reimburse the
contractor more than the amount payable by the government.
The OCFO's PeoplePlus 9.2 project manager referred the audit team to the EPA's
PeoplePlus Project Management SharePoint site for all the documents associated
with the PeoplePlus 9.2 upgrade. The audit team's review of the project site
revealed that the site did not have documentation showing that the EPA
considered the cost of PeoplePlus over the life of the system or alternative
systems. When the audit team requested data to support a cost analysis for
PeoplePlus, EPA management stated that it did not perform a cost analysis for the
time and attendance system.
The EPA did not consider other alternatives for its time and attendance services
while performing the PeoplePlus 9.2 upgrade, even though the Agency's shared
service provider, IBC, had a time and attendance system that the OCFO
considered a viable option for future use during the 2013 upgrade of the
PeoplePlus system from version 8.3 to 8.9. The audit team found that the project
site included documentation that noted the required project tasks, start and end
dates, and the completion percentage for each task. Two required tasks were to
review time and attendance system capability at other federal agencies and in the
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private sector. On the project site, the two tasks were identified as 100 percent
complete in September 2015. There was no documentation on the project site to
support the completion of the two tasks. We concluded that this was due to poor
management oversight since the EPA stated that an alternatives analysis was not
performed.
EPA Did Not Have Authorization to Not Perform Required Analyses
and Relied on Outdated Estimates
OCFO management and staff stated that the CIO authorized them to not perform a
cost analysis for the upgrade to PeoplePlus 9.2 because a cost analysis was
performed in 2013 during the system's upgrade from 8.3 to 8.9. Our review of
documentation provided by the OCFO did not support the statement, and we
concluded that the CIO did not authorize the OCFO to proceed with the upgrade
without a cost analysis. The 2013 cost analysis should not have been relied upon
because it was at least three years old and was for PeoplePlus 8.9, which included
customization costs that are no longer in the PeoplePlus 9.2 version. Additionally,
the CIO does not have the authority to waive OMB Circular A-130 requirements,
as a waiver may only be granted by the OMB director upon written request by the
Agency.
OCFO management and staff stated that they did not consider the use of a shared
service center because this option was considered in 2013 when the Agency
transitioned to the IBC. They believed another review would have returned the
same decision to not use the IBC's webTA timekeeping system. Additionally, the
OCFO stated that the costs for migration and customization for the IBC's webTA
system would not have changed from its 2013 estimates, so it would have been
wasteful to perform another analysis. The EPA could not reach these conclusions
without performing a current analysis and should not have relied on information
that was at least three years old. Alternative options, including the use of a shared
service provider for time and attendance, should have been considered because it
is required by OMB Circular A-130. The EPA's project documentation listed the
review of time and attendance systems at other agencies and in the private sector
in its plans during the PeoplePlus 9.2 upgrade. Therefore, it is the OIG's opinion
that the EPA knew that an alternatives analysis should have been performed.
EPA Missed Opportunities to Save Taxpayer Dollars
Without current cost and alternatives analyses, the EPA cannot be sure its
timekeeping system is the most economical and efficient use of taxpayer funds.
The OIG obtained cost estimates from the IBC for its two time and attendance
systems: webTA and QuickTime. Based on the IBC's cost estimates, the EPA
could have saved up to $8 million in taxpayer funds. Additionally, approximately
$1.2 million of the $8 million could be put to better use if the remaining options
years for the operations and maintenance contract are not elected and one of the
payroll solutions available from the IBC is used.
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The cost estimates for the IBC systems that the EPA could have considered
instead of PeoplePlus are shown in Tables 2 and 3.
Table 2: IBC cost estimate for webTA services
webTA cost type
Amount estimated
Implementation cost
S716.560
Operations and maintenance costs by year
FY 2017
571,060
FY 2018
587,376
FY 2019
692,614
FY 2020
901,459
FY 2021*
936,538
FY 2022*
967,086
Total estimated cost
$5,372,693
Source: EPA OIG analysis.
*The total cost for 2021 and 2022 is $1,903,624.
Table 3: IBC cost estimate for QuickTime services
QuickTime cost type
Amount estimated
Implementation cost
S266.950
Operations and maintenance costs by year
FY 2017
620,008
FY 2018
636,324
FY 2019
743,520
FY 2020
870,132
FY 2021*
885,959
FY 2022*
905,231
Total estimated cost
$4,928,124
Source: EPA OIG analysis.
*The total cost for 2021 and 2022 is $1,791,190.
Figures 2 and 3 show estimated cost comparisons of the IBC's webTA and
QuickTime systems to the EPA's PeoplePlus 9.2 contracted cost. Also, the tables
show our estimated savings if the IBC systems were selected as an alternative
system and the amounts still available were put to better use.
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Figure 2: PeoplePlus 9.2 contracted cost and IBC's webTA estimated cost
comparison
$13 M
Estimated savings if
IBC webTA used:
$7.7 M*
lEPA's PeoplePlus
i IBC's webTA
Estimated future
savings if
IBC webTA used:
$1.2 M
$3.1 M
Total cost for six years	Total cost for future years
Source: EPA OIG image.
"Costs that could be avoided. Actual difference between $13,025,000 and $5,372,693 is
$7,652,307. Therefore, it is rounded to $7.7 million.
Figure 3: PeoplePlus 9.2 contracted cost and IBC's QuickTime estimated cost
comparison
$13 M
ฆ EPA's PeoplePlus ฆ IBC's QuickTime
Estimated savings if
IBC QuickTime
used:
$8.1 M
Total cost for six years
•Source: EPA OIG image.
"Costs that could be avoided.
Estimated future
savings if
IBC QuickTime
used:
$1.3 M*
$3.1 M
$1.3 M
Total cost for future years
Additionally, the EPA missed the opportunity to reduce some of the help desk
support contract costs since the IBC includes help desk services with its time and
attendance systems.
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Recommendations
We recommend that the chief financial officer:
1.	Perform the required cost analysis over the full life cycle of PeoplePlus.
Also, determine whether the PeoplePlus operations and maintenance
contract should not be extended for any remaining option years.
2.	Perform an alternatives analysis to determine whether solutions from the
Department of Interior's Interior Business Center and other federal
shared service centers would be the best value option to meet the time
and attendance needs of the Agency, and decide whether the PeoplePlus
operations and maintenance contract should not be extended for any
remaining option years.
Agency Response and OIG Assessment
The EPA agreed with Recommendations 1 and 2.
For Recommendation 1, the OCFO will perform a full cost-benefit analysis as
part of the Agency's decision to move to another time and attendance provider no
later than June 2021 or within 60 days after selecting one of the systems offered
through the IBC. The Agency will make option year decisions as a part of the full
cost-benefit analysis. The proposed corrective action and planned completion date
for Recommendation 1 satisfy the recommendation, and we consider the
recommendation resolved with corrective action pending.
For Recommendation 2, the OCFO will perform an analysis of alternatives as part
of the Agency's decision to move to another time and attendance provider no later
than June 2021 or within 60 days after selecting one of the systems offered
through the IBC. The Agency will make option year decisions as a part of the
alternative analysis. The proposed corrective action and planned completion date
for Recommendation 2 satisfy the recommendation, and we consider the
recommendation resolved with corrective action pending.
The complete Agency response to the draft report is in Appendix A. The OIG's
assessment of the Agency's overall position is in Appendix B.
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Chapter 3
EPA Did Not Perform Oversight Reviews and
Maintain Required Documentation
The EPA did not perform necessary oversight duties as required in its system life
cycle management, or SLCM, procedures. The procedures require the EPA to
complete five reviews that provide management control and direction over
software selection decisions. The EPA did not perform four of the reviews and did
not have supporting documentation as required by its system life management
procedures. One of the four reviews that was not performed required certification
that the PeoplePlus system aligned with the Agency's Enterprise Architecture.1
OMB Circular A-130 requires agencies to develop an EA that aligns with the
Agency's Information Resources Management strategic plan, which must
demonstrate how the technology and information resources goals align with the
Agency's mission and organizational priorities. OCFO management stated that it
did not perform the reviews because it was focused on the Agency's financial
system upgrade, not PeoplePlus. Not performing oversight duties caused the
Agency to be noncompliant with OMB Circulars No A-123 and A-130, as well as
with the EPA's CIO-2121-P-03.0, which puts the Agency at risk for making poor
investment choices that potentially waste taxpayer funds.
Federal Regulations and EPA Policy Require Multiple Reviews and
Maintenance of Documentation When Making IT Investments
OMB Circular A-123 states that managers are responsible for ensuring
compliance with relevant laws and regulations. Per the Circular, "Management is
also responsible for establishing and maintaining internal controls to achieve
specific objectives related to operations, reporting and compliance. Management
must consistently apply these internal control standards to meet the internal
control principles."
OMB Circular A-130 requires agencies to develop an EA that describes the
baseline architecture, the target architecture, and a transition plan to get to the
target architecture. The Agency's EA must also align business and technology
resources to achieve strategic outcomes. The EA should include Agency plans for
significant upgrades, replacements, and disposition of information systems when
the systems can no longer effectively support missions or business functions. The
process of describing the current and future state of the Agency and laying out a
plan for transitioning from the current state to the desired future state helps
1 The EA is a strategic information asset base that describes the Agency's business, the information necessary to
operate the business, the technologies necessary to support the business operations, and the transitional processes
necessary to implement new technologies in response to changing business needs.
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agencies to eliminate waste and duplication, increase shared services, and close
performance gaps.
OMB Circular A-130, Section 5.d.3.b, also states that an agency's business cases
need to contain appropriate evidence to support the agency's decisions related to
major IT investments.
The EPA's CIO 2121-P-03.0 provides for the integration of SLCM with IT
investment management practices, EA, quality, and information security
requirements. A system life cycle at the EPA consists of six phases: pre-
definition, definition, acquisition and development, implementation, operations
and maintenance, and termination. The SLCM states that during each phase,
documentation is created, updated, or modified. The procedure notes that
although there could be variances, each SLCM phase must be completed for all
EPA systems. The six phases of the system life cycle require the Agency to:
•	Document business needs.
•	Justify the system.
•	Certify compliance with the Agency' s EA.
•	Authorize system operation.
•	Determine whether to continue or terminate the investment and, if
appropriate, retire the system.
There are five control gate reviews that are completed during the SLCM
procedure. Control gates are phase driven decision points where SLCM activities
are reviewed to confirm that appropriate OMB and EPA requirements are
observed. Table 4 summarizes the required phases and associated reviews (control
gates) for a system migration or upgrade.
Table 4: SLCM procedure outlining six phases and related reviews
Phase
Summary of phase
Required gate review
Pre-definition
Determines if an IT system is needed to fulfill an
Agency need or performance gap in any
functional areas, including administrative,
financial, or technological functions.
Gate 1: Requires a decision
memorandum that approves the
system to progress to the next
phase or halts system development
until requirements are met. The
memorandum must document the
business or mission needed for
system migration or upgrade.
Definition
Establishes the business justification for the
system and a concrete plan for implementation
or acquisition.
Gate 2: Requires (for major
investments) an IT Investment
Business Case to be added to the
Agency's IT Investment Portfolio.
The Quality and Information Council
makes a final decision on approving
the business case. The business
case develops and evaluates
alternatives for improving the
business based on readily available
information.
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Phase
Summary of phase
Required gate review
Acquisition and
development
Uses information gathered in the definition
phase to design, develop, and acquire the
information system that meets the EPA's
business needs.
Gate 3: Requires the Agency's
Chief Architect to conduct the EA
Compliance Certification Review,
which ensures that the system's
design conforms to the planned
solution and continues to address
business needs while aligning with
the Agency EA.
Gate 4: Requires the senior
information officer to conduct the
Authorization to Operate Review to
determine if it is appropriate to allow
the system to move into the
operational state.
Implementation
Establishes the system in a production
environment.
No related gate reviews.
Operation and
maintenance
Includes activities for the system's ongoing
functions and maintenance.
Gate 5: Determine if the IT
investment should continue to be
modified or be terminated. The
review will coincide with the annual
IT investment review.
Termination
Ends the operation of the system in a planned,
secure, and orderly manner, which includes
archiving system components and data, or
incorporating them into other systems as
required, and securely disposing of hardware
and software as appropriate.
No related gate reviews.
Source: Internal OIG document.
EPA Did Not Perform SLCM Reviews or Maintain Related
Documentation
The EPA did not perform necessary oversight duties as required in the SLCM
procedure. The Agency also did not perform four of the five required gate reviews
and did not maintain the required documentation to support its system upgrade to
PeoplePlus 9.2 as required in its SLCM procedure. Not performing oversight
duties is not effective and has caused the Agency to be noncompliant with OMB
and EPA requirements.
Our review of the EPA's SharePoint PeoplePlus Upgrade Project site, which is
used to store all project-related and system life cycle documents, revealed that
several critical documents to support the required reviews were missing and all
the SLCM folders on the site were empty. The OIG requested documents to
support the five required reviews and found that many of the documents provided
by the OCFO were related to the 2013 PeoplePlus upgrade rather than the 2017
upgrade. Figure 4 includes a description of the five gate reviews, the required
documentation, and the OIG's determination of whether the review was
completed.
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Figure 4: System life cycle compliance versus EPA actions taken
SYSTEM LIFE CYCLE
FRAMEWORK
Gate 1 review
|Completed?|
|Yes |No|
[ Gate 2 review ]
|Completed?| 1

Yes
l_
I No

Gate 3 review
[Completed?
|Yes | [""No
Gate 4 review
|Completed?| *
fYesl fNo
Gate 5 review
[Completed?
IYesJ [No
ฉ
Source: EPA OIG image.
EPA ACTIONS
TAKEN
Gate 1 review
Completed?!
Gate 2 review
Completed?!
Gate 3 review
Completed?!
No
Gate 4 review
Completed?]
Gate 5 review
Completed?!
ฉ
=1 Decision
_~l memorandum
=1 Approved IT
_^| business
proposal
=| Enterprise
| architecture
certification
=1 Authorization
to operate
= | Modification or
_x| termination
reviews
CORRECT ACTION
IF INCOMPLIANCE
Gate 1 review
|Completed?|
>/!
The first four reviews listed in Figure 4 require documentation to proceed to the
next phase of the project. The EPA proceeded to the next phase of the PeoplePlus
project without the required documentation. In our opinion, the upgrade to
PeoplePlus 9.2 should not have occurred until proper approval was obtained.
EPA Was Not Focused on PeoplePlus 9.2 Upgrade
OCFO management did not apply the EPA's internal controls, which is why many
of the required steps for IT investment approval were not performed. OCFO
management and staff stated that it did not comply with SLCM requirements
because they were focused on implementing the Agency's financial system
upgrade, not the PeoplePlus upgrade.
EPA Missed Opportunities to Potentially Save Taxpayer Funds and Is
Noncompliant with Federal Instructions
The EPA did not comply with its own SLCM procedure and weakened the
Agency's internal controls with respect to the PeoplePlus system by not
performing the required reviews. Since a decision memorandum, business
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proposal, compliance certification, and a modify or terminate review were not
developed or performed for the PeoplePlus 9.2 upgrade, the EPA cannot
demonstrate that the PeoplePlus system is the best investment for the Agency and
potentially missed the opportunity to save taxpayer money.
Furthermore, the PeoplePlus system may not align with the EPA's EA and
strategic plan because the OCFO did not perform an EA certification review for
the PeoplePlus system. As a result, the Agency is at risk of not complying with
OMB Circular A-130.
Recommendations
We recommend that the chief financial officer:
3.	Design and implement internal controls to verify that staff complete the
necessary reviews to obtain the necessary approvals before proceeding
to the next phase of the system life cycle and maintain the required
documentation.
4.	Design and implement internal controls that verify that staff members
are following the EPA's System Life Cycle Management Procedure
(Chief Information Officer Classification No. 2121-P-03.0) when
performing information technology systems application projects,
including PeoplePlus.
Agency Response and OIG Assessment
The EPA agreed with Recommendations 3 and 4.
For Recommendation 3, the OCFO completed its review of all active financial
systems projects using a new process called Project Health Checks on March 31,
2020. The OCFO provided support for the completion of the corrective action on
April 6, 2020. The Agency's Project Health Checks verify that the necessary
approvals have been obtained, and supporting documentation is on file for the life
cycle phases. We concur that the corrective action for Recommendation 3 is
complete.
For Recommendation 4, the OCFO provided support for the completion of the
corrective action on February 7, 2020. The Agency implemented its Project
Health Checks process in September 2019 to review the compliance of its projects
with system development and maintenance procedures. We concur that the
corrective action for Recommendation 4 is complete.
The complete Agency response to the draft report is in Appendix A. The OIG's
assessment of the Agency's overall position is in Appendix B.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
No.
Subject
Status1
Action Official
Planned
Completion
Date
16
16
Perform the required cost analysis over the full life cycle
of PeoplePlus. Also, determine whether the PeoplePlus
operations and maintenance contract should not be
extended for any remaining option years.
Perform an alternatives analysis to determine whether
solutions from the Department of Interior's Interior
Business Center and other federal shared service
centers would be the best value option to meet the time
and attendance needs of the Agency and decide
whether the PeoplePlus operations and maintenance
contract should not be extended for any remaining
option years.
Design and implement internal controls to verify that
staff complete the necessary reviews to obtain the
necessary approvals before proceeding to the next
phase of the system life cycle and maintain the required
documentation.
Design and implement internal controls that verify that
staff members are following the EPA's System Life
Cycle Management Procedure (Chief Information
Officer Classification 2121-P-03.0) when performing
information technology systems application projects,
including PeoplePlus.
Chief Financial Officer
Chief Financial Officer
6/30/21
6/30/21
Potential
Monetary
Benefits
(in $000s)
$1,200
Chief Financial Officer	3/31120
Chief Financial Officer	9/20/19
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
January 22; 2020
OFFICE OF THE
CHIEF FINANCIAL OFFICER
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Audit Report, Project No. OA&E-
FY18-0283, "EPA May Have Overpaidfor Its $13 Million Time and Attendance
System by Not Following IT Investment Requirements, " dated December 18, 2019
FROM: David A. Bloom, Acting Chief Financial Officer /s/
Office of the Chief Financial Officer
TO:	Michael Davis, Director
Efficiency Audits
Office of Audit and Evaluation
Thank you for the opportunity to respond to the issues and recommendations in the subject draft
audit report. The following is a summary of the U.S. Environmental Protection Agency's overall
position, along with responses for each of the report recommendations. We have provided high-
level intended corrective actions and estimated completion dates to the extent we can.
AGENCY'S OVERALL POSITION
While the EPA agrees with your four recommendations, there are many statements in the draft
which leave an incorrect impression. The report states that the agency did not follow proper
procedures and did not maximize value to the agency. That is not accurate, and our analysis
showed that we saved between $3 and $4 million in system costs, when migration costs are
included, as they should be as part of the total cost of ownership.
Many factors were considered during the migration to the Department of Interior's Interior
Business Center. In 2013, the agency entered into an agreement with the IBC for human resource
systems services in response to the Office of Management and Budget's Human Resources Line
I vฎp7 *
% ^
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of Business initiative. The primary benefit of this agreement was to retire the human resources
portion of the agency PeoplePlus system and reduce system cost to the Office of Mission
Support (formerly the Office of Administration and Resources Management). The IBC's solution
would not have decoupled the human resources and payroll systems services, so the decision to
move to the IBC meant the agency would also have to migrate from its existing payroll system
provider, the Defense Finance and Accounting Service, to the IBC payroll system as well. The
initial interagency agreement with the IBC was written to include human resources, payroll, and
time and attendance system services.
The IBC stated that the available window to migrate to their systems was March 2014. If the EPA
could not meet that date, the next available window would be two years later. The problem this
timeline presented to the agency was that the EPA time and attendance and payroll cost
accounting systems were highly customized to support the EPA's existing collective bargaining
agreements and statutory cost recovery requirements. The IBC's time and attendance offerings,
WebTA and Quick Time, did not support these requirements. Therefore, the agency was faced
with two choices; either request changes to the IBC time and attendance systems driving up the
cost and risk of the IBC migration, or develop interfaces between the IBC's human resources and
payroll systems to the EPA's existing PeoplePlus time and attendance system. An alternative
analysis was performed which showed that retaining the existing PeoplePlus time and attendance
system was less costly and presented less risk to the overall IBC migration. The agency made the
decision to retain the PeoplePlus time and attendance system. However, the long-term strategy
was to remove the customizations from PeoplePlus to allow more flexibility in the future.
In October 2017, the OCFO moved forward with the long-term approach, the system was
upgraded a second time from version 8.9 to version 9.2. This system upgrade provided the
following:
•	Removed highly customized features to position the EPA and the PeoplePlus time and
attendance system for an easier and less costly transition to a future shared service
provider; and
•	Moved the support of the EPA cost recovery requirements to a delivered commercial off
the shelf Payroll Cost Accounting component of the Compass financial system.
The OCFO has provided a detailed financial breakdown of the costs to migrate to the IBC
systems which were part of the presentation to the Chief Information Officer and Chief Financial
Officer for determining our path forward. Tables 1 and 2 provide a better representation of the
actual costs associated with moving to either of these platforms. Decisions on whether to migrate
from PeoplePlus, which would be supported by a full alternatives' analysis, are now on hold,
pending the implementation of the OMB's guidance which will further consolidate federal
payroll services.
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Table 1: PeoplePlus 9.2 and IBC's WebTA Cost Comparison with Details
UK 's Wcbl
A
PeoplePlus 9.2
IBC Annual Costs for 6
Years
$5,372,693
PeoplePlus 9.2. Annual O&M
Costs for 6 Years
$9,026,000
PeoplePlus 8.3 O&M Costs
$1,831,000
PeoplePlus 8.3 O&M Costs
$1,831,000
Migration Cost Breakdown to Customize
WebTA


Requirements/Impact
Analysis
$ 175,000


NBC(IBC) Migration Fees
$2,500,000


Interface
$1,200,000
No additional Costs
Adaptive Maintenance
$1,330,000


Adaptive Maintenance for
Downstream Systems for Org
Code and WebTA
$210,000


Training for Employees
$ 750,000


IBC Change Requests for
WebTA
$2,000,000


Total Migration Costs
$8,165,000


Total Costs to Agency
$15,368,693'
rotal Costs to Agency
$10,857,000
Additional Cost to Agency
$4,511,6931
Cost Saving for the Agency
$ 4,511,693
Table 2: PeoplePlus 9.2 and IBC's QuickTime Cost Comparison with Details
UK 's Quick
ime
PeoplePlus 9.2
IBC Annual Costs for 6
Years
$ 4,928,142
PeoplePlus 9.2. Annual
O&M Costs for 6 Years
$9,026,000
PeoplePlus 8.3 O&M Costs
$1,831,00C
PeoplePlus 8.3 O&M Costs
$1,831,000
Migration Cost Breakdown to Customize
WebTA


Requirements/Impact
Analysis
$ 175,00C


NBC(IBC) Migration Fees
$2,500,00C


Interface
$1,200,00C
No additional Costs
Adaptive Maintenance
$1,330,00C


Adaptive Maintenance for
Downstream Systems for Org
Code and WebTA
$210,00C


Training for Employees
$ 750,00C


IBC Change Requests for
WebTA
$2,000,00C


Total Migration Costs
$8,165,00C


Total Costs to Agency
$14,924,142
.Total Costs to Agency
$10,857,000
Additional Cost to Agency
$ 4,067,142
.Cost Saving for the Agency

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AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
Date
1
Perform the required cost
analysis over the full life
cycle of PeoplePlus. Also,
determine whether the
PeoplePlus operations and
maintenance contract should
not be extended for any
remaining option years.
The EPA concurs with
performing a full cost benefit
analysis as part of the agency's
decision to move to a NewPay
initiative provider. Option year
decisions will be determined as
part of the above analysis. As
referenced in Tables 1 and 2, the
OCFO did conduct detailed
analysis on both the IBC
solutions, QuickTime and
WebTA.
No later than June 2021 or
within 60 days of the IBC
identification of system
selection.
2
Perform an alternatives
analysis to determine if
solutions from Department
of Interior, Interior Business
Center and other federal
shared service centers
would be the best value
option to meet the time and
attendance needs of the
agency and decide if the
PeoplePlus operations and
maintenance contract should
not be extended for any
remaining option years.
The EPA concurs with
performing an alternatives
analysis as part of the agency's
decision to move to a NewPay
initiative provider. Option year
decisions will be determined as
part of the above analysis. As
referenced in Tables 1 and 2, the
OCFO did conduct detailed
analysis on both the IBC
solutions, QuickTime and
WebTA.
No later than June 2021 or
within 60 days of the IBC
identification of system
selection.
3
Design and implement
internal controls to verify
that staff complete the
necessary reviews to obtain
the necessary approvals
before proceeding to the
next phase of the system life
cycle and maintain the
required documentation.
Starting in the third quarter of
FY 2019, the EPA conducted a
review of all active financial
systems projects (Project Health
Checks) and by September 2019
identified gaps against the
agency's System Life Cycle
Management procedure. Project
Managers are currently
resolving applicable gaps. The
progress of this effort is
currently being monitored and
March 31, 2020
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an estimated completion for this
effort is March 31, 2020.

No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
Date
4
Design and implement
internal controls that verify
that staff members are
following the EPA's System
Life Cycle Management
procedure (CIO 2121-P-
03.0) when performing
Information Technology
systems and applications
projects, including
PeoplePlus.
The EPA confirms that
processes and procedures are
already in place. As described
above, the OCFO instituted
Project Health Checks for each
of our projects in May 2019.
The results of the Project Health
Check were discussed with
every staff member involved
and they have been provided
specific feedback on each of
their respective efforts. Bi-
weekly project updates are
presented to executive
management and follow ups are
being addressed.
Completed
September 20, 2019
CONTACT INFORMATION
If you have any questions regarding this response, please contact the OCFO's Audit Follow-up
Coordinator, Andrew LeBlanc, at (202) 564-1761 or leblanc.andrew@epa.gov.
cc: Charles Sheehan
Ed Shields
Carol Terris
Jeanne Conklin
Meshell Jones-Peeler
Eva Ripollone
David DeVere
Michael L. Roberts
Andrew Leblanc
Alana Maye
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Appendix B
OIG's Assessment of the Agency's
Response to the Draft Report
The EPA's response to our draft report asserted that there were many statements that left
incorrect impressions and were not accurate. Although the Agency explained the factors it
considered in the decision to migrate to PeoplePlus 9.2, the EPA's primary argument that it
saved between $3 million and $4 million in systems costs is unsubstantiated. Our evaluation of
the Agency's response determined that the OCFO's analysis (see Tables 1 and 2 in Appendix A)
did not include the $4 million in acquisition contract cost for the upgrade, as shown in Figure 1
of our report.
The OIG conducted an exit conference with the OCFO on February 12, 2020, to discuss our
assessment of its response to the draft report. When we presented the omission of the contract
cost for the PeoplePlus 9.2 system upgrade during the exit conference, OCFO officials did not
refute our analysis or provide additional information after the meeting to support the EPA's
position that the PeoplePlus 9.2 upgrade saved the Agency between $3 million and $4 million.
The Agency did not perform a cost analysis or alternatives analysis prior to upgrading to
PeoplePlus 9.2 in 2017, yet the Agency provided a cost analysis that identified cost savings in
response to our audit report, which is concerning. The only analysis that the EPA provided to
support its upgrade decision was shared during the course of the audit and appeared to be from
an analysis for its 2013 upgrade from PeoplePlus 8.3 to PeoplePlus 8.9, which does not appear to
be relevant to the PeoplePlus 9.2 upgrade.
We maintain our position that the EPA did not comply with OMB Circular A-130. The Circular
requires agencies to make decisions to 1) improve, enhance, or modernize existing IT
investments; 2) develop new IT investments only after conducting an alternatives analysis; and
3) determine the best value to the agency. The Agency did not perform an alternative analysis or
cost analysis for the October 2017 PeoplePlus update to the 9.2 version. In addition, the EPA did
not comply with CIO 2121-P-03.0 by not performing four reviews or maintaining the required
supporting documentation.
The EPA needs to follow procedures, comply with the OMB Circular A-130, and perform a cost
and alternative analyses to determine the best value option to meet its time and attendance needs.
The complete Agency response to the draft report is in Appendix A.
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Appendix C
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff/Operations
Chief Financial Officer
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
Deputy Chief Financial Officer
Associate Chief Financial Officer
Associate Chief Financial Officer for Policy
Director, Office of Technology Solutions, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Technology Solutions, Office of the Chief
Financial Officer
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