OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA's Office of the Chief
Financial Officer Lacks
Authority to Make Decisions
on Employee-Debt Waiver
Requests
Report No. 20-P-0194	June 15, 2020
Office of the Chief Financial Officer
A
AUTHORITY?
EMPLOYEE-DEBT WAIVER REQUESTS

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Report Contributors:	John Trefry
Jean Bloom
Leah Nikaidoh
Kevin Collins
Robert Hairston
David Penman
Elizabeth Moreira
Abbreviations
ACO	Agency Claims Officer
C.FR.	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
OCFO	Office of the Chief Financial Officer
OIG	Office of Inspector General
U.S.C.	United States Code
Cover Image: The EPA's Office of the Chief Financial Officer does not have the authority to
make employee-debt waiver decisions. (OIG image)
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At a Glance
Why We Did This Project
The U.S. Environmental
Protection Agency's Office of
Inspector General conducted
this audit to determine
(1) whether the Agency is
properly forgiving debts owed
by its employees through its
waiver or compromise process
and (2) the activities that are
causing salary overpayments.
Federal law, 5 U.S.C. § 5584,
allows an agency to waive, in
whole or in part, claims against
a person arising out of an
erroneous payment of pay. The
agency claims officer is
responsible for reviewing
waiver requests and may
approve, in whole or in part, or
deny the requests.
This report addresses the
following:
• Operating efficiently and
effectively.
EPA's Office of the Chief Financial Officer Lacks
Authority to Make Decisions on Employee-Debt
Waiver Requests
What We Found
We found that the Office of the Chief Financial	The OCFO made
Officer improperly made decisions on 15 employee- unauthorized decisions
debt waiver requests totaling $53,539. As set forth for employee-debt waiver
in 5 U.S.C. § 5584, erroneous overpayments for	requests totaling $53,539.
salary, travel, transportation, or relocation expenses
or allowances to employees may be waived if it "would be against equity and
good conscience and not in the best interests of the United States." The agency
claims officer—who is located in the Office of General Counsel, not in the
OCFO—has the authority up to $100,000 to waive employee debts for erroneous
payments of pay and other allowances. Because the OCFO does not have
authority to approve employee-debt waiver requests, it should have instead
referred these 15 requests to the agency claims officer to issue the decisions.
Recommendations and Planned Agency Corrective Actions
We recommend that the chief financial officer (1) update policies and procedures
to require employee-debt waiver requests be submitted to the agency claims
officer for review; (2) submit any employee-debt waiver requests currently under
review by the EPA Finance Center directors to the agency claims officer for
processing; and (3) update policies and procedures to state that the EPA will
process debt compromise requests in compliance with 31 U.S.C. § 3711 and
Resource Management Directive System 2540-9-P2, as well as will maintain
required supporting documentation. We also recommend that the general counsel
direct the agency claims officer to review and render employee-debt waiver
decisions on the 15 debt waiver requests in question.
The EPA agreed with our recommendations. Recommendation 3 is resolved with
corrective action pending. Planned corrective actions for Recommendations 1, 2,
and 4 were not acceptable, and these recommendations are unresolved with
resolution efforts in progress.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
June 15,2020
MEMORANDUM
SUBJECT: EPA's Office of the Chief Financial Officer Lacks Authority to
Make Decisions on Employee-Debt Waiver Requests
Report No. 20-P-0194
FROM: Sean W. O'Donnell
TO:
David Bloom, Deputy Chief Financial Officer
Matthew Leopold, General Counsel
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-FY18-0084. This
report contains findings that describe the problems the OIG has identified and improvements the OIG
recommends. The final determination on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
This report contains four recommendations. In accordance with EPA Manual 2750, your Office provided
acceptable corrective actions and estimated milestone dates for Recommendation 3, which is resolved. No
further response is required for this recommendation.
Action Required
We consider Recommendations 1, 2, and 4 to be unresolved. In accordance with EPA Manual 2750, the
resolution process begins immediately with the issuance of the report. We are requesting that the
Agency initiate the audit resolution process within 30 days of final report issuance. We also request a
written response to the final report within 60 days of this memorandum. Your response 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. If a resolution is not reached, the Agency is
required to complete and submit a dispute resolution request to the appropriate official to continue
resolution.
We will post this report to our website at www.epa.gov/oig.

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EPA's Office of the Chief Financial Officer
Lacks Authority to Make Decisions on
Employee-Debt Waiver Requests
20-P-0194
Table of C
Chapters
1	Introduction	 1
Purpose	 1
Background	 1
Responsible Offices		2
Scope and Methodology		2
Prior Audit Report		3
2	OCFO Lacks Authority to Make Decisions on Employee-Debt
Waiver Requests	 4
Other Matter		5
Recommendations	 5
Agency Response and OIG Assessment		6
Status of Recommendations and Potential Monetary Benefits		8
Appendices
A Agency Response to Draft Report	 9
B Distribution	 12

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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency's Office of Inspector General
conducted this audit to determine (1) whether the Agency is properly forgiving
debts owed by its employees through its waiver or compromise process and
(2) the activities that are causing salary overpayments.
Background
EPA employees may owe debts to the Agency due to erroneous overpayments for
salary, travel, transportation, or relocation expenses or allowances. According to
5 U.S.C. § 5584, the EPA has the authority to waive such debts against its
employees if the collection of the debt "would be against equity and good
conscience and not in the best interests of the United States." A debt, however,
may not be waived if there is any indication of fraud, misrepresentation, fault, or a
lack of good faith on the part of the employee seeking the waiver. As set forth in
EPA Order 3155.1, Waiver of Claims for Overpayments, and Delegation 1-26,
Waiver of Claims for Erroneous Payment of Pay, the authority to waive debts
under the authority of 5 U.S.C. § 5584 has been delegated to the general counsel
and redelegated to the Agency's "Claims Officer."
Distinct from the Agency's specific authority to waive such debts, the EPA has
the authority to compromise a debt of not more than $100,000 under the authority
of 31 U.S.C. § 3711(a)(2). The EPA's regulations at 40 C.F.R. Part 13—
applicable to all debts for which a statute, regulation, or contract does not
prescribe different standards or procedure—provide that the Agency may
compromise claims where the claim does not exceed $20,000. Under 40 C.F.R.
§13.25, Standards for compromise, the EPA may compromise a debt if
the debtor does not have the financial ability to pay the full amount of
the debt within a reasonable time, or if the debtor refuses to pay the claim in full
and the government does not have the ability to enforce collection in full within a
reasonable time by initiating collection proceedings. Pursuant to 31 U.S.C.
§ 3711(c), compromises are final unless they are a result of fraud,
misrepresentation, false claims, or a mutual mistake.
In addition to the authority to compromise a debt, 31 U.S.C. § 3711(a)(3)
provides the EPA the authority to terminate collection on a debt when it appears
that no person liable on the claim has the present or prospective ability to pay a
significant amount of the claim or that the cost of collecting the claim is likely to
be more than the amount recovered. The EPA's regulation at 40 C.F.R. § 13.32,
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Standards for termination, sets forth the criteria to consider when terminating a
debt owed to the Agency.
The EPA's Resource Management Directive System 2540-09-P2, Non-Federal
Delinquent Debt, describes the EPA's process for recording, collecting, and
resolving debts owed to the Agency by nonfederal sources. It states that the Office
of the Chief Financial Officer is authorized to approve compromises and
terminations not exceeding $20,000. The directive also provides that debt
terminations approved by the OCFO are subject to review by the agency claims
officer.
Responsible Offices
The Office of General Counsel provides legal counsel to Agency
policymakers. The authority to make decisions regarding the waiver of
government claims for erroneous payment of pay or allowances under the
authority of 5 U.S.C. § 5584 is delegated to the general counsel who, in turn,
redelegated the authority to the ACO. The ACO is authorized to approve
employee-debt waiver requests up to $100,000.
The OCFO is responsible for providing financial services for the Agency,
including related policy development, reporting, and oversight of the EPA's
financial operations. The OCFO is authorized to compromise or terminate claims
up to $20,000.
Scope and Methodology
We conducted this performance audit from January 2018 through January 2020 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
To determine whether the EPA properly forgave employee debts, we:
•	Reviewed federal laws and regulations as well as Agency policy regarding
waivers of salary payments to federal employees and the compromise and
termination of debts to the Agency.
•	Interviewed the acting ACO, OCFO officials, and selected employees and
their supervisors to gain an understanding of the debt waiver process.
•	Reviewed the 15 employee-debt waiver requests that the OCFO
compromised or ended debt collection for to determine whether the Office
20-P-0194
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complied with federal requirements and Agency rules, directives, and
applicable delegations.
To determine the activities that caused salary overpayments, we:
•	Analyzed employee-salary-overpayment data from the EPA's payroll
provider to determine what events resulted in salary overpayments from
January 2017 to May 2018.
•	Judgmentally selected 13 employees with the largest number of debt
notifications to determine the cause of their salary overpayments. This
sample represents 11 percent of salary overpayments (143 of
1,334 overpayments) and 5 percent of the dollar value of salary
overpayments ($78,635 of $1,642,915) in our population.
Prior Audit Report
OIG Report No. 18-P-0250. Management Alert: EPA Oversight of Employee Debt
Waiver Process Needs Immediate Attention, dated September 12, 2018, found,
among other concerns, that the OCFO's internal controls failed to detect 18 EPA
employee-debt waiver requests totaling $22,015. The report stated that some of the
missing employee-debt waiver requests that had since been located were processed
by the OCFO and forwarded to the Office of General Counsel for review. The
report recommended that the OCFO identify any remaining employee-debt waiver
requests and take immediate action to process them. The Agency agreed with our
recommendations and completed the corrective actions.
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Chapter 2
OCFO Lacks Authority to Make Decisions on
Employee-Debt Waiver Requests
The OCFO mistakenly believed that it had the authority to process employee-debt
waiver requests pursuant to 5 U.S.C. § 5584. This occurred because the OCFO
believed it could review employee-debt waiver requests as debt compromises
under 31 U.S.C. §3711. As a result, the OCFO received, evaluated, and made
decisions on 15 employee-debt waiver requests totaling $53,539. The OCFO
should submit all employee-debt waiver requests to the ACO, who has the
delegated authority to make those decisions.
Beginning in 2015, the OCFO reviewed and approved 15 employee-debt waiver
requests totaling $53,539. OCFO officials stated that they began this practice after
they were asked by the former ACO to assist the Office of General Counsel with
employee-debt waiver requests. The current acting ACO had no knowledge of
such an arrangement and was unaware that the OCFO was reviewing employee-
debt waiver requests. In February 2018, when we brought this matter to the
OCFO's attention, it discontinued reviewing employee-debt waiver requests.
After the OCFO was provided preliminary audit results stating that only the ACO
had the authority to waive employee debts, the OCFO asserted that it had
"compromised" the debts pursuant to its debt compromise authority under
31 U.S.C. § 3711. We found, however, that when the OCFO reviewed the
employee-debt waiver requests, it did not make decisions based on the financial
ability of the debtor to pay as required in 31 U.S.C. §3711 and the applicable
EPA regulations. Instead, we found that the OCFO had applied the less stringent
equity and good conscience standard of 5 U.S.C. § 5584 pertaining to debt
waivers and then claimed that it "compromised" the debts of the employees
pursuant to 31 U.S.C. § 3711. The OCFO should have instead referred the
employee-debt waiver requests to the ACO to be evaluated.
Because the OCFO had issued employee-debt waiver decisions without authority,
the OIG requested that the ACO review the determinations made by the OCFO.
The ACO concluded that he did not have the authority to reconsider the OCFO
decisions for 14 of the 15 employee debts. For the reasons set forth in the Agency
Response and OIG Assessment section below, the OIG disagrees with this
conclusion. The ACO agreed to review one debt waiver request and rendered a
new decision.
The Office of Management and Budget Circular No. A-123, Management's
Responsibility for Enterprise Risk Management and Internal Control, states that
management is responsible for complying with applicable federal laws and
regulations and for designing, implementing, and monitoring internal controls to
4
20-P-0194

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achieve its objectives. When effective policies and procedures are in place,
compliance with laws and regulations becomes more likely. We found that the
OCFO did not follow its current policy to submit all debt waiver requests to the
ACO, in accordance with 5 U.S.C. § 5584.
Together, 5 U.S.C. § 5584 and 31 U.S.C. § 3711 create a framework by which an
EPA employee could have a debt discharged for erroneous overpayments.
However, the applicability of 31 U.S.C. § 3711 to employee debts is not identified
in Agency policy and procedures. While the Agency has procedures for filing a
debt waiver request under 5 U.S.C. § 5584, the Agency does not have procedures
that identify how an employee can apply for a discharge of debt under 31 U.S.C.
§ 3711. Existing policies and procedures must be modified to specifically identify
how employee debts can be processed and discharged in accordance with
31 U.S.C. §3711. Without clear policies and procedures, the discharge of
employee debt under 31 U.S.C. § 3711 will continue to be misunderstood.
Other Matter
On December 10, 2019, during the course of this audit, we sent a memorandum
titled Time and Attendance Records Not Updated Prior To Payroll Certification
Causing Salary Overpayments to the controller about a nonsignificant internal
control deficiency we encountered. No follow-up action was required.
Recommendations
We recommend that the chief financial officer:
1.	Update policies and procedures to require requests for employee-debt
waivers to be submitted to the agency claims officer for review under
5 U.S.C. § 5584 and EPA Order 3155.1, Waiver of Claims for
Overpayments.
2.	Require EPA Finance Center directors to stop any reviews of employee-
debt waiver requests in accordance with Resource Management Directive
System 2540-09-P2, Non-Federal Delinquent Debt, and forward any such
requests to the agency claims officer for processing.
3.	Update policies and procedures to state that the EPA will process
employee-debt compromise requests in compliance with 31 U.S.C. § 3711
and Resource Management Directive System 2540-9-P2, Non-Federal
Delinquent Debt, and maintain required documentation for debt collection,
compromise, suspension, and termination activities.
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We recommend that the general counsel:
4. Direct the agency claims officer to review and render employee-debt
waiver decisions on the 15 employee-debt waiver requests in accordance
with 5 U.S.C. § 5584. Take steps to recover any funds due to the Agency
if appropriate.
Agency Response and OIG Assessment
The Agency concurred with the report's recommendations and provided proposed
corrective actions and completion dates for its actions. However, the Agency's
proposed corrective actions for Recommendations 1, 2, and 4 were not acceptable.
For Recommendation 1, the Agency said that the EPA's Resource Management
Directive System 2540-09-P1 requires employee-debt waiver requests to be
submitted to the ACO for review and identifies this action as complete. Our report
clearly documents that none of the 15 employee-debt waiver requests were
submitted to the ACO for review. Consequently, the policy has not been effective
and should be updated and enforced. We consider this recommendation
unresolved.
For Recommendation 2, we agree with the Agency's assessment that the OCFO
does not have the authority to approve employee-debt waivers and that Resource
Management Directive System 2540-09-P2 provides the controller the authority to
compromise debt. Our recommendation addresses employee-debt waiver requests,
not debt compromises or debt terminations. The directive identified by the Agency
does not grant the OCFO the authority to convert employee-debt waiver requests to
debt compromises or terminations. In these instances, the OCFO is required to
submit the employee-debt waiver requests to the ACO. We consider this
recommendation unresolved.
For Recommendation 3, the OCFO agreed to update its policies and procedures
related to debt compromises and terminations to comply with 31 U.S.C. § 3711,
with a proposed completion date of June 30, 2020. We consider this
recommendation resolved with corrective action pending.
For Recommendation 4, the ACO only addressed one of the 15 employee-debt
waiver decisions for compliance with 5 U.S.C. § 5584. He determined that he
lacks the authority to address any of the remaining 14 claims, which collectively
total $29,608, because:
[A]n EPA decision to compromise or terminate a debt pursuant to
31 U.S.C. 3711 "is final and conclusive unless gotten by fraud,
misrepresentation, presenting a false claim, or mutual mistake of
fact." 31 U.S.C. 3711(c). Given that these decisions did not include
documentation evidencing fraud, misrepresentation, a false claim,
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or mutual mistake of fact as required by 31 U.S. C. 3711(c), and
that 14 out of 15 of them were within OCFO's properly
redelegated authority to compromise or terminate debts, I view
OCFO's decisions as final and conclusive and therefore I am
without authority to reconsider them.
We disagree. The OCFO terminated collection of employee debts and labeled
them all "compromises." As set forth in the Resource Management Directive
System 2540-09-P2, debt termination decisions by the OCFO are subject to
review by the ACO. Second, in our view, the ACO did not exercise due diligence
to determine whether the requests made by the employees were properly
evaluated against the waiver requirements of 5 U.S.C. § 5584. The ACO simply
relied upon statements made by OCFO officials that their determinations were
made in accordance with debt compromise standards.
The ACO evaluated one employee-debt waiver request and rendered a new
decision. The ACO determined that it would be appropriate to approve this
employee-debt waiver request based on equity considerations. The OIG finds that
this determination was within the ACO's discretion and authority. However, for
the 14 employee-debt waiver decisions totaling $29,608 that remain, we consider
the recommendation unresolved.
The Agency's full response to our draft report can be found in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
Update policies and procedures to require requests for U Chief Financial Officer
employee-debt waivers to be submitted to the agency
claims officer for review under 5 U.S.C. § 5584 and EPA
Order 3155.1, Waiver of Claims for Overpayments.
Require EPA Finance Center directors to stop any	U Chief Financial Officer
reviews of employee-debt waiver requests in accordance
with Resource Management Directive System 2540-09-
P2, Non-Federal Delinquent Debt, and forward any such
requests to the agency claims officer for processing.
Update policies and procedures to state that the EPA will R Chief Financial Officer	6/30/20
process employee-debt compromise requests in
compliance with 31 U.S.C. § 3711 and Resource
Management Directive System 2540-9-P2, Non-Federal
Delinquent Debt, and maintain required documentation
for debt collection, compromise, suspension, and
termination activities.
Direct the agency claims officer to review and render	U	General Counsel
employee-debt waiver decisions on the 15 employee-debt
waiver requests in accordance with 5 U.S.C. § 5584.
Take steps to recover any funds due to the Agency if
appropriate.
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
-	s	WASHINGTON, D C. 20460
.5322
FEB 2 8 2020
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Audit Report, Project No. OA-FY18-0084,
"EPJusOffice of Chief Financial Officer Does Not Have Authority to Review and Make
Decisiotfaxm Employee Debt Waiver Requests, " dated January 23, 2020
FROM: Hjayffi AJlpWrnTT^Ltin^ CIiiilTiiiiiiiciai Officer
OffioFofthe Chief Financial Officer
Matthew Z, Leopold. General Counsel A jf
Office of General Counsel	\	J
TO:	John Trefry, Director, Forensic 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 agency's overall position, along with its position
on 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
The agency concurs with all of the recommendations.
AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
Date
1
Update policies and procedures
to require requests for employee
Complete. OCFO policy RMDS
2540-9-P1, page 10, requires
Completed
April 13, 2011
9
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debt waivers to be submitted to
the Agency Claims Officer for
review under 5 U.S.C. § and
EPA Order 3155.1.
employee debt waivers to be
submitted to the Agency Claims
Officer for review.

2
Require EPA Finance Center
Directors to stop any reviews of
debt waiver requests in
accordance with RMDS 2540-9-
P2, Non-Federal Delinquent
Debt, and forward any such
request to the Agency Claims
Officer for processing.
Complete. Under Delegation 1-
28, Claims of the EPA, signed
September 9, 2019, the
authority to compromise debt
may only be redelegated to the
Controller with no further
redelegation to the Finance
Center Directors. OC does not
have the authority to waive
debt. In accordance with RMDS
2540-09-P2, the OC may
compromise debt up to $20K.
Requests over $20K are
forwarded to the Agency
Claims Officer for processing.
Completed
September 9, 2019
3
Update policies and procedures
to state that the EPA will process
employee debt compromise
requests in compliance with 31
U.S.C. § 3711 and Resource
Management Directive System
2540-9-P2, Non- Federal
Delinquent Debt, and maintain
required documentation for debt
collection, compromise,
suspension and termination
activities.
OCFO will update policies and
procedures for Delegation 1-28,
Claims of the EPA, signed
September 9, 2019. The update
will include documentation
necessary for the Controller to
support debt collection,
compromise suspension and
termination activities.
June 30, 2020
4
Review and render debt waiver
decisions on the 15 debt waiver
requests in accordance with 5
U.S.C. §5584. Take steps to
recover any funds due to the
agency if appropriate.
Complete. OGC issued an email
to OFCO on 02/12/20 rendering
a decision on the one debt
waiver request that exceeded
OCFO's debt compromise
authority of $20K. OGC
determined that the employee
reasonably relied on OCFO's
2017 decisions compromising
his debt and found it was not
equitable to reinstitute a debt of
$23,931.24 against the
employee. Therefore, no steps
need to be taken to recover any
funds due to the agency. OCFO
Completed
February 13, 2020
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forwarded OGC's decision to
OIG on February 13, 2020.

CONTACT INFORMATION
If you have any questions regarding this response, please contact OCFO's Audit Follow-up
Coordinator, Andrew LeBlanc, at (202) 564-1761.
cc: Carol Terris
Jeanne Conklin
Richard Gray
Dany Lavergne
Greg Luebbering
Aileen Atcherson
Kenneth Redden
Leah Nikaidoh
Annette Morant
Andrew LeBlanc
20-P-0194
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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
Deputy Chief Financial Officer
Associate Chief Financial Officer
Associate Chief Financial Officer for Policy
Principal Deputy General Counsel
Deputy General Counsel
Agency Claims Officer, Office of General Counsel
Director, Office of Continuous Improvement, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of General Counsel
20-P-0194

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