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Report Contributors: Jerri Dorsey-Hall
Michael Petscavage
Abbreviations
CMR
Compliance Monitoring Review
CPE
Continuing Professional Education
EPA
U.S. Environmental Protection Agency
FY
Fiscal Year
GAGAS
Generally Accepted Government Auditing Standards
OA&E
Office of Audit and Evaluation
OIG
Office of Inspector General
PMH-A
Project Management Handbook for Auditing
Are you aware of fraud, waste, or abuse in an
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Washington, D.C. 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
20-N-0230
July 16, 2020
Why We Did This Project
The U.S. Environmental
Protection Agency's Office of
Inspector General operates and
maintains a system of quality
control designed to provide
reasonable assurance that
personnel performing audits
comply with the generally
accepted government auditing
standards, known as GAGAS,
and established OIG policies
and procedures.
Quality assurance directors
from the OIG's Office of Audit
and Evaluation report annually
on systemic issues identified
during referencing and
compliance monitoring reviews.
They also make observations
on compliance with GAGAS
and OIG policy.
In addition, GAGAS requires
that each organization
performing audits in
accordance with these
standards have an external
peer review. Peer reviews must
be performed at least once
every three years.
This report addresses the
following EPA OIG goal:
• Improving OIG processes,
resource allocation, and
accountability to meet
stakeholder needs.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.oiq.
List of OIG reports.
Internal Quality Assurance Review of EPA OIG
Audit Assignments Completed in Fiscal Year 2019
What We Found
OIG audit reports issued in
FY 2019 demonstrated high
levels of compliance with OIG
quality assurance procedures,
receiving an average
compliance score of 92 percent.
Internal compliance reviews of EPA OIG
audit assignments completed in fiscal
year 2019 found that the OIG complied with
GAGAS and substantially complied with OIG
policies and procedures. An external peer
review conducted in FY 2018 also found that
the EPA OIG's system of quality control was suitably designed and complied
with, providing the OIG with reasonable assurance that audits were performed
and reported in conformity with GAGAS.
As part of our internal quality assurance review, we evaluated the OIG's audit
activities for reports issued during FY 2019 and found that the projects complied
with GAGAS and generally complied with OIG policies and procedures. The
average compliance monitoring score was 91.95 out of 100. Similar to FY 2017
and FY 2018, the only systemic issue identified was the estimation and approval
of project time frames and cost estimates. This issue continued to occur in
FY 2019, in part, because corrective actions for a related recommendation—
which was originally issued in the FY 2017 quality assurance review report and
reissued in the FY 2018 quality assurance review report—were not implemented
until October 2019. When reports are not timely and current, their relevance and
usefulness can be diminished.
In addition, our internal quality assurance review assessed the OIG's compliance
with GAGAS independence and competence standards, and we did not identify
any significant issues. However, while all staff met the continuing professional
education requirement for the FY 2018-FY 2019 cycle, we found some minor
discrepancies. The OIG should ensure that all training records of completion are
adequately documented in the training records system. Additionally, the OIG
should ensure that it is maintaining all personal impairment forms for record-
keeping purposes.
Finally, our internal quality assurance review assessed the eight non-GAGAS
reports issued by the EPA OIG in FY 2019 and found that four did not contain the
required statement that the work was not performed in accordance with GAGAS.
Additionally, we noted a significant increase in non-GAGAS work from the
previous year. OIG Policy 101, Project Management Handbook for Auditing, has
been revised to address these issues.
We make no recommendations in this report but will review the implementation of
corrective actions taken to address our findings during the FY 2020 internal
quality assurance review. The acting assistant inspector general for Audit and
Evaluation agreed with our findings and committed to the continued monitoring of
the corrective actions already in place.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
July 16, 2020
MEMORANDUM
SUBJECT: Internal Quality Assurance Review of EPA OIG Audit Assignments Completed in
Fiscal Year 2019
Report No. 20-N-0230
This is our final report on the U.S. Environmental Protection Agency Office of Inspector General's
adherence to quality control elements and compliance with generally accepted government auditing
standards in OIG audit assignments completed in fiscal year 2019.
This report offers observations to enhance and strengthen the OIG's audit execution process.
cc: Sean W. O'Donnell, Inspector General
Charles J. Sheehan, Deputy Inspector General
Edward S. Shields, Associate Deputy Inspector General
Rashmi Bartlett, Deputy Assistant Inspector General for Audit and Evaluation
Christine El-Zoghbi, Deputy Assistant Inspector General for Audit and Evaluation
James Hatfield, Associate Deputy Assistant Inspector General for Audit and Evaluation
FROM: Richard Eyermann, Deputy Assistant Inspector General
Office of Audit and Evaluation
TO:
Kathlene Butler, Acting Assistant Inspector General
Office of Audit and Evaluation
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Internal Quality Assurance Review of
EPA OIG Audit Assignments
Completed in Fiscal Year 2019
20-N-0230
Table of C
Purpose 1
Background 1
Scope and Methodology 2
Prior Reports 3
Results 4
Estimation and Approval of Project Time Frames and Cost Estimates
Need Improvement 4
OIG Complied with Education Requirements 5
Improvements Made in the Approval and Documentation of Annual
Personal Impairment 6
Review of Non-GAGAS Reports 6
Assistant Inspector General Response and OIG Assessment 8
Appendices
A CMR Results for FY 2019 9
B Reports Without CMRs in FY 2019 10
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Purpose
The U.S. Environmental Protection Agency's Office of Inspector General
operates and maintains a system of quality control designed to provide reasonable
assurance that all personnel performing audit functions comply with generally
accepted government auditing standards, known as GAGAS, and with OIG
policies and procedures. Quality assurance directors from the OIG's Office of
Audit and Evaluation analyze and summarize the results of their monitoring
activities at least annually to identify any systemic or repetitive issues needing
improvement, along with recommendations for corrective action.
This quality assurance report summarizes the results of our compliance
monitoring reviews of 32 audit reports issued in fiscal year 2019. Appendix A
lists the audits we reviewed.1
Background
The Inspector General Act of 1978, as amended, requires that federal inspectors
general comply with the audit standards established by the comptroller general of
the United States. The EPA OIG conducts its audits in accordance with these
standards. All in-text citations in this report refer to the 2018 version of GAGAS;
however, because the 2011 version was still in effect for some of the audits we
reviewed, we also include citations to those relevant sections in footnotes. The OIG
also maintains an internal system of quality control to provide the organization with
reasonable assurance that its products, services, and personnel comply with
professional standards and applicable legal and regulatory requirements.
GAGAS Section 5.44 states that an audit organization:2
[SJhould analyze and summarize the results of its monitoring
process at least annually, with identification of any systemic or
repetitive issues needing improvement, along with
recommendations for corrective action. The audit organization
should communicate to the relevant engagement partner or
director, and other appropriate personnel, any deficiencies noted
during the monitoring process and recommend appropriate
remedial action.
A measuring process should provide a mechanism to evaluate individual products
against specific quality criteria. The process should also present the information in
a manner that, over time, will allow the OIG to assess adherence to quality control
elements so that necessary adjustments can be made to policies, procedures, and
activities.
1 A CMR is prepared for each audit. Some audits may have multiple reports, but only one CMR is completed for
each audit. Appendix B lists the reports issued without CMRs and the reason CMRs were not performed.
2 2011 GAGAS Section 3.95.
20-N-0230
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Our system of quality control uses CMRs to assess completed work and determine
whether the OIG followed professional standards and operated according to OIG
Policy 101, Project Management Handbook for Auditing.
Each CMR encompasses an analysis of the audit activities that occurred, from
initiating the audit to the issuance of the final report. Additionally, some
post-audit activities are also reviewed. The CMR results, trends, and subsequent
recommendations are summarized in an annual quality control report.
Compliance with general auditing standards, such as independence, professional
judgment, competence, and adherence to continuing professional education
requirements, is not part of the CMR. The CMR examines fieldwork and
reporting standards conducted in accordance with GAGAS and the PMH-A by
checking for compliance with identified activities associated with planning and
execution, communication, supervision, reporting, and data quality. The specific
categories evaluated in the CMR and their associated point values are presented in
Table 1.
Table 1: CMR categories for FY 2019 reports
Category
Point value
Planning and Execution
12
Communication
13
Supervision
25
Report Quality
25
Timeliness
15
Post Reporting/Data Quality
10
Total
100
Source: The EPA OIG.
Scope and Methodology
We performed this internal quality assurance review on projects with final reports
issued from October 1, 2018, through September 30, 2019. This internal review
covered GAGAS-compliant reports scored by the OIG's quality assurance staff.
We did not include any reports with work performed by external auditors. The
work performed in this internal review does not constitute an audit conducted in
accordance with GAGAS.
The scores for each report were reviewed, and any audit that received less than
80 percent of the possible points in any of the six CMR categories (outlined in
Table 1) was further reviewed to assess the issues identified. Identified issues
were then analyzed to determine whether any were systemic. An issue was
considered systemic if it occurred in more than 20 percent of the reports.
20-N-0230
2
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As part of the quality assurance review, we also assessed compliance with two
GAGAS general standards: independence and competence. Records documenting
compliance with these standards are maintained on an organizational basis, rather
than by assignment.
We also reviewed non-GAGAS reports issued during FY 2019, excluding
evaluations conducted in accordance with the Council of the Inspectors General
on Integrity and Efficiency's Quality Standards for Inspection and Evaluation and
with OIG Policy 109, Project Management Handbook for Evaluation, to
determine whether:
1. Additional controls are needed to address risks associated with the
issuance of non-GAGAS reports.
2. Guidance is needed to obtain reasonable assurance that we are capturing
results in a consistent and accurate manner in the Performance
Measurement Results System.
3. Non-GAGAS reports include the required language indicating that the
auditors did not follow GAGAS standards.
Prior Reports
On June 18, 2018, the Department of Defense OIG issued a report on its external
peer review of the EPA OIG's system of quality assurance as of September 30,
2017. The peer review included a sample of reports issued in FY 2017. The
Department of Defense OIG's overall conclusion was that the EPA OIG's system
of quality control was suitably designed and complied with, providing the EPA
OIG with reasonable assurance that audits are performed and reported in
adherence with applicable professional standards. In its management letter, the
Department of Defense OIG identified some issues that were not of sufficient
significance to affect its overall conclusion. In response, the EPA OIG proposed
corrective actions to address the issues.
On June 4, 2019, the EPA OIG issued Report No. 19-N-0167. Quality Assurance
Review of EPA OIG Audit Assignments Completed in Fiscal Year 2018. Based on
the results of the CMRs conducted that year, we recommended that the assistant
inspector general for Audit and Evaluation finalize the planned corrective actions
to address the quality control review recommendation originally issued in EPA
OIG Report No. 18-N-0219. Quality Assurance Review of EPA OIG Reports
Issued in Fiscal Year 2017, dated July 9, 2018. We also recommended that the
assistant inspector general for Audit and Evaluation establish internal controls to
verify that personal impairment forms are completed in a timely manner and
readily accessible for all staff. The assistant inspector general for Audit and
Evaluation agreed with the findings and recommendations and implemented
corrective actions.
20-N-0230
3
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Results
OIG audit assignments completed in FY 2019 complied with GAGAS and
generally complied with OIG policies and procedures. The average compliance
monitoring score was 91.95 out of 100, which is a decrease from FY 2018's
average of 94.31. Similar to FY 2017 and FY 2018, the only systemic issue
identified was the estimation and approval of project time frames and cost
estimates. The issue continued to occur in FY 2019, in part because the corrective
action to address the related recommendation—which was originally issued in the
EPA OIG's FY 2017 quality assurance review report and reissued in the FY 2018
quality assurance review report—was not fully implemented until after FY 2019
ended. When reports are not timely and current, their relevance and usefulness
can be diminished. We will evaluate the implementation of the corrective action
as part of the FY 2020 internal quality assurance review.
Our FY 2019 quality assurance review also found no significant issues regarding
the OIG's compliance with GAGAS independence and competence standards.
In addition, we found that controls were needed when the organization issued
non-GAGAS reports. Subsequently, guidance was incorporated into the revised
PMH-A; therefore, we did not issue a recommendation. We will review non-
GAGAS reports as part of the FY 2020 internal quality assurance review.
Estimation and Approval of Project Time Frames and Cost Estimates
Need Improvement
The FY 2019 CMRs continued to show a systemic issue related to the timeliness
and cost of projects. The CMRs found that some projects exceeded estimated staff
days and calendar days and that revisions to milestone dates were not always
approved. This issue continued to occur in FY 2019, in part because a related
recommendation—which was first issued in the EPA OIG's FY 2017 quality
assurance review report and reissued in the FY 2018 quality assurance review
report—was not completed until after FY 2019 ended. The PMH-A was updated
in October 2019 to include specific milestone approval and documentation
requirements.
GAGAS paragraph 9.17g identifies timeliness as a report quality element, noting
that "timely issuance of the report is an important reporting goal for auditors."3
OIG procedures describe requirements relating to the estimated project time
frames, approval of revisions to time frames, and documentation of approval of
time frames. When reports are not timely and current, their relevance and
usefulness can be diminished.
Eleven of the 32 reports we reviewed scored less than 80 percent in the timeliness
category. The timeliness score is based on a comparison of the approved
3 2011 GAGAS Section A.7.02.
20-N-0230
4
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milestone date and staff-day estimate with the actual milestone date and staff-day
estimate.
In response to EPA OIG Report No. 19-N-0167,4 the assistant inspector general
for Audit and Evaluation agreed to clarify the following issues in the PMH-A:
• Key information regarding assignment calendar days and staff days that
must be approved.
• When key information revisions are needed.
• Who can approve revisions to key information.
• How to document key information and revisions.
However, the revised PMH-A was not issued until October 2019, after FY 2019
ended. We will evaluate the implementation of these controls as part of the
FY 2020 internal quality assurance review.
OIG Complied with Education Requirements
Auditors performing work in accordance with GAGAS should maintain their
professional competence through CPE.5 Over a two-year period, auditors must
take 80 hours of CPE, including 56 training hours related to conducting audits
and 24 training hours related to government auditing, the government
environment, or specialized information. We reviewed information entered into
the Inspector General Enterprise Management System training module and found
that all staff in OA&E who conduct audit work met the CPE requirement in the
FY 2018-FY 2019 cycle.
Additionally, we reviewed a judgmental sample of the training documentation for
ten OA&E staff to determine whether their training was adequately documented
in the Inspector General Enterprise Management System training module.
Evidence of completion of CPE, such as a certificate from the CPE provider,
should be documented in the Inspector General Enterprise Management System
training module. If the CPE provider does not provide a certificate, staff should
complete the CPE self-certification form available on the OIG intranet audit
resources page. While we found that all ten staff had adequate support to meet the
CPE requirements, we found some minor discrepancies in the documentation.
All OA&E staff were reminded to include the following training documentation
in the Inspector General Enterprise Management System training module:
• The name of the organization providing the CPE.
• The title of the training program, including subject matter or field of
study.
4 OIG, Quality Assurance Review of EPA OIG Reports Issued in Fiscal Year 2018, Report No. 19-N-0167. issued
June 18, 2018.
5 The term "auditor" refers to all people who conduct audits, regardless of their official position title.
20-N-0230
5
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• Dates attended or completed.
• Number of CPE hours earned toward the 56-hour and 24-hour
requirements.
Additionally, in cases where staff are claiming CPE for nontraditional training,
such as preparing training materials, staff should document the justification and
support for the number of CPE hours claimed in the Inspector General Enterprise
Management System training module, along with supervisory approval.
Employees and supervisors are expected to continue to meet CPE requirements
and have periodic discussions to ensure continued compliance.
Improvements Made in the Approval and Documentation of Annual
Personal Impairment
GAGAS Section 3.108 states that independence documentation must provide
evidence of the auditor's judgments in forming conclusions regarding compliance
with independence requirements.6 OIG Policy and Procedure 102 states that staff
and contractors must be independent, in fact and appearance, and sign a personal
impairment form upon joining the OIG and as performance agreements are
established. Directors are asked to save copies of completed impairment forms on
the OIG shared drive.
As reported in the FY 2018 quality assurance review report, an analysis of the
shared drive in February 2019 found that 23 percent of the forms were missing. In
response, the OA&E established an internal control to require directors to attest
that all personal impairment forms are completed and properly stored prior to
their end-of-year performance reviews. An analysis of the shared drive in
January 2020 found that only 4 percent of the forms were either missing or
lacking supervisory review. When notified of these missing forms, a deputy
assistant inspector general for Audit and Evaluation requested that staff submit
the missing impairment forms.
Review of Non-GAGAS Reports
Our review found that additional controls were needed when the organization
issued non-GAGAS reports. In response to that review, the PMH-A was updated
to emphasize that the OIG's expectation is that all EPA OIG assignments will
comply with GAGAS or the Quality Standards for Inspection and Evaluation.
Furthermore, the PMH-A established controls for the rare circumstances when
management may decide that it is beneficial to issue a report or memorandum that
does not comply with GAGAS or the Quality Standards for Inspection and
Evaluation. These instances should be consistent with the requirements of the
Inspector General Act of 1978, as amended, which states that each inspector
general shall comply with standards established by the comptroller general of the
6 2011 GAGAS Section 3.59.
20-N-0230
6
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United States for audits of federal establishments, organizations, programs,
activities, and functions.
In FY 2019, the issuance of non-GAGAS reports significantly increased from the
prior fiscal year. Specifically, in FY 2019, eight out of 44 reports, or 18.2 percent,
were non-GAGAS, while in FY 2018, the EPA OIG only issued one such report
out of 49, or 2 percent.7 The public and Congress trust the work the EPA OIG
produces, in part, because we follow the standards of the profession. Those
standards require that our work is done independently, supported by sufficient
evidence, and performed with adequate supervision. Not following standards can
undermine the trust and confidence that the public and Congress have in our
work. The controls put in place with the issuance of the revised PMH-A will help
further ensure that the EPA OIG is doing its work in accordance with accepted
standards, which helps ensure public trust in the work performed by the
organization. Further, on May 21, 2020, the OA&E acting assistant inspector
general issued a memorandum to OA&E staff stating that not following standards
would occur in "extraordinarily rare cases."
Additionally, in FY 2019, four of the eight non-GAGAS reports did not contain
required GAGAS language. If audit work is not done in accordance with GAGAS,
the resulting report should include language indicating that the auditors did not
follow those standards. According to the October 2019 PMH-A, all non-GAGAS
reports that have a report number and are posted on the OIG's public website
must include a statement that GAGAS was not followed. An example is:
[T]his report does not constitute an audit done in accordance with
generally accepted government auditing standards.
We were not able to determine why these reports were issued without this or a
similar statement. However, in the first quarter of FY 2020, a non-GAGAS report
that was issued without the required non-GAGAS statement was not sent through
the quality assurance staff, who verify that reports comply with required
standards. We believe further controls are necessary to ensure that under the rare
circumstances that non-GAGAS reports are issued, those reports contain the
required language. To that end, the OA&E acting assistant inspector general
issued a memorandum in May 2020 to OA&E staff that:
• Clarified that all OA&E audits, evaluations, reviews, and similar
projects—whether they are issued in compliance with standards, under a
modified statement of compliance, or not in compliance with standards—
must be reviewed by quality assurance personnel.
• Referred the OA&E to the PMH-A for specific guidance for non-GAGAS
projects.
7 These non-GAGAS numbers exclude the Semiannual Report to Congress, as well as the management challenges
and quality assurance reports.
20-N-0230
7
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Finally, we also found inconsistencies in how teams were counting the results
from non-GAGAS assignments in the OIG's Performance Measurement Results
System. Guidance was provided to OA&E staff to ensure consistent and accurate
reporting of results.
Since guidance was provided to OA&E staff and the PMH-A was updated to
incorporate controls in FY 2020, we make no recommendations in this report. We
will review the implementation of these corrective actions as part of our FY 2020
internal quality assurance review.
Assistant Inspector General Response and OIG Assessment
The acting assistant inspector general for Audit and Evaluation agreed with the
findings and committed to continued monitoring of the corrective actions already
in place. While we make no recommendations in this report, we will review the
implementation of the corrective actions as part of the next annual internal quality
assurance review.
20-N-0230
8
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Appendix A
CMR Results for FY 2019
Report No.
Planning
and
execution
Communication
Supervision
Report
quality
Timeliness
Post
reporting/
data quality
Compliance
review score
19-P-0001
12
10
23
25
15
7
92
19-P-0002
12
11
22
20
13
10
88
19-F-0003
12
13
21
25
15
10
96
19-P-0041
11.5
13
20
21
5
8
78.5
19-P-0045
10
12
25
25
10.5
10
92.5
19-P-0058
12
13
24
25
15
10
99
19-F-0086
12
13
19
25
5
10
84
19-P-0123
12
13
25
25
15
10
100
19-P-0146
12
13
24
25
14
10
98
19-P-0147
12
12
25
25
15
10
99
19-P-0155
12
13
25
25
13
8
96
19-P-0157
11.5
11
24
25
7
8
86.5
19-P-0158
12
13
25
24
15
10
99
19-P-0163
12
13
23
23
15
10
96
19-P-0168
12
12
24.2
24
14
10
96.2
19-P-0195
11
11
25
16
0
8
71
19-P-0198
12
13
25
24
7
10
91
19-P-0201
9.5
11.5
24.2
25
15
6
91.2
19-P-0207
12
13
23
25
15
8
96
19-F-0214
11
7
23
25
0
3
69
19-F-0215
11
8
23
25
0
1
68
19-P-0245
11.5
13
25
25
15
8
97.5
19-P-0251
12
13
25
24
15
10
99
19-P-0267
9
11
25
25
15
10
95
19-P-0275
12
12.9
24
25
15
10
98.9
19-P-0277
12
13
25
25
15
10
100
19-P-0278
12
13
25
25
10.5
10
95.5
19-P-0279
12
9
20
25
9
10
85
19-P-0283
12
13
23
23
10.5
10
91.5
19-P-0302
12
13
23
25
14.75
10
97.75
19-P-0307
12
13
25
25
15
10
100
19-P-0318
12
11.5
22
25
14.9
10
95.4
Average
11.63
12.00
23.58
24.19
11.66
8.91
91.95
Source: The OIG.
Note: The associated point values are presented in Table 1 of this report.
20-N-0230
9
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Appendix B
Reports Without CMRs in FY 2019
Report
No.
Report title
Reason for no CMR
19-F-0004
Audit of U.S. Chemical Safety and Hazard Investigation Board's Fiscal
Years FY 2018 and 2017 Financial Statements
Contracted audit
19-N-0044
Crowe Tribe Public Water Systems Concerns
Non-GAGAS report
19-N-0070
US Chemical Safety and Hazard Investigation Board's Compliance with
Fiscal Year 2018 Improper Payments Legislation and Guidance
Non-GAGAS report
19-N-0084
EPA Finalized a Study of the Historical Applications of Coal Ash as
Structural Fill
Non-GAGAS report
19-N-0085
Management Alert - Destruction of a Document Used to Certify Security
of EPA's Budget Formulation System
Non-GAGAS report
19-N-0087
Management Alert - Hotline Concerns over Region 9 Regional
Administrator's Duty Station and Travel
Non-GAGAS report
19-N-0115
Management Alert - Certain Toxic Release Inventory Data Disclosed to
the Public Are Inaccurate
Non-GAGAS report
19-N-0154
EPA Region 5 Needs to Act on Transfer Request and Petition Regarding
Ohio's Concentrated Animal Feeding Operation Permit Program
Non-GAGAS report
19-N-0156
FY 2019 U.S. Chemical Safety and Hazard Investigation Board
Management Challenges
Non-GAGAS report
19-N-0167
Quality Assurance Review of EPA OIG Audit completed in Fiscal Year
2018
Non-GAGAS report
19-N-0217
Management Alert-Certain Risk Communication Information for
Community Not Up to Date for Amphenol/Franklin Power Products Site in
Franklin, Indiana
Non-GAGAS report
19-N-0235
EPA Fiscal Year 2019 Management Challenges
Non-GAGAS report
19-P-0236
EPA Region 6 Quickly Assessed Water Infrastructure after Hurricane
Harvey but Can Improve Emergency Outreach to Disadvantaged
Communities
First report of multiple
expected from assignment.
19-P-0252
EPA's 2017 Glider Vehicle Testing Complied with Standard Practices
Work evaluated as part of
Report No.19-P-0168.
Source: The EPA OIG.
20-N-0230
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