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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Hotline Report:
Operating efficiently and effectively
EPA Needs to Improve
Oversight of Invoice
Reviews and Contractor
Performance Evaluation
Report No. 21-E-0031
December 1, 2020
PERFORMANCE
EVALUATION

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Report Contributors:
Rudolph M. Brevard
Vincent Campbell
Nancy Dao
Shaheryar Qureshi
Gina Ross
Abbreviations
C.F.R.
Code of Federal Regulations
CO
Contracting Officer
COR
Contracting Officer's Representative
CPARS
Contractor Performance Assessment Reporting System
EPA
U.S. Environmental Protection Agency
ITSSS
Information Technology System Security Staff
OIG
Office of Inspector General
Cover Image: Improvements are needed in invoice reviews and contractor performance
evaluation. (EPA OIG graphic)
Are you aware of fraud, waste, or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
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	21-E-0031
^	T>	^ffl/v/\ /\f InpnA^Af	December 1, 2020
	U  O  ^11V11 Ul 111ICIIIOI I I UICUII
\ Office of Inspector General
At a Glance
Why We Did This Evaluation
The U.S. Environmental
Protection Agency's Office of
Inspector General received a
hotline complaint in September
2019 regarding a $12 million
contract for information
technology support services
performed by Attain, the
Agency's contractor for
information technology support.
The objective of this evaluation
was to determine whether the
EPA paid Attain for services
that were either not performed
or performed by other EPA
contractors.
This evaluation addresses the
following:
	Operating efficiently and
effectively.
This evaluation addresses a top
EPA management challenge:
	Complying with key internal
control requirements (policies
and procedures).
EPA Needs to Improve Oversight of Invoice
Reviews and Contractor Performance
Evaluation
Effective contract
management
practices safeguard
the EPA from
remitting costs that
are not allowable,
allocable, and
reasonable.
What We Found
We did not find evidence that the EPA paid Attain for
information security services that were either not
performed or performed by other EPA contractors. We
found, however, that the EPA did not perform certain
contract management duties for the Attain contract. In
particular, the multiple contracting officers overseeing
the Attain contract did not complete (1) the required
invoice review during the task order's base year
period and (2) the contractor performance evaluation. EPA directives prescribe
the requirements for performing these key management oversight activities.
These activities were not completed because the outgoing contracting officers did
not complete the contract transition checklist and transition memorandum, which
would have notified the incoming contracting officer about critical contract
monitoring tasks that needed to be completed. Further, the EPA lacked
processes to notify contract management when contracting officers did not
review invoices periodically or initiate the contractor performance evaluation in
the Contractor Performance Assessment Reporting System.
Recommendations and Planned Agency Corrective Actions
We recommend that the assistant administrator for Mission Support
(1) implement controls to alert the Office of Acquisition Solutions management
when required annual invoice reviews are not completed and contractor
performance evaluations are not initiated; (2) review all Attain task order invoices
commencing with the base year and recoup any overpayments; (3) remind
contracting officers to complete contract transition checklists and transition
memorandums when transferring task orders, including contracts, between
contracting officers; and (4) require the contracting officer to complete the base
year performance evaluation.
The Agency concurred with all recommendations and provided acceptable
corrective actions and estimated milestone dates. The Agency completed
corrective actions for one of the recommendations. The remaining four
recommendations are resolved with corrective actions pending.
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
December 1, 2020
MEMORANDUM
SUBJECT: EPA Needs to Improve Oversight of Invoice Reviews and Contractor
Performance Evaluation
Report No. 21-E-0031
FROM: Sean W. O'Donnell
''yfbVi
J
TO:
Donna Vizian, Principal Deputy Assistant Administrator
Office of Mission Support
This is our report on the subject evaluation conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this evaluation was OA&E-FY20-0107.
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 Office of Acquisition Solutions within the Office of Mission Support is primarily responsible for the
issues discussed in this report.
In accordance with EPA Manual 2750, your office completed the corrective actions for Recommendation 3
and provided acceptable corrective actions and estimated milestone dates in response to the remaining OIG
recommendations. All recommendations are resolved, and no final response to this report is required.
However, if you submit a response, it will be posted on the OIG's website, along with our memorandum
commenting on your response. Your response should be provided 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.
We will post this report to our website at www.epa.gov/oig.

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EPA Needs to Improve Oversight
of Invoice Reviews and Contractor
Performance Evaluation
21-E-0031
Table of C
Purpose		1
Background		1
Responsible Office		2
Scope and Methodology		3
Actions Taken by the Agency		4
Results of Evaluation		5
Contracting Officers Did Not Perform Required Periodic Invoice Reviews	 5
Contracting Officers Did Not Perform Required Performance Evaluation	 6
Conclusions	 7
Recommendations	 8
Agency Response and OIG Assessment	 8
Status of Recommendations and Potential Monetary Benefits	9
Appendices
A Agency Response to Draft Report	 10
B Distribution	 15

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Purpose
This evaluation is the
result of an anonymous
hotline complaint sent on
September 17, 2019, to the
U.S. Environmental
Protection Agency's Office
of Inspector General
regarding information
security support services
performed by Attain, the
Agency's contractor for
information security
support. The objective was to determine whether the EPA paid Attain for services
that were either not performed or performed by other EPA contractors.
Background
The hotline complaint stated that there is significant fraud, waste, and abuse
concerning the Office of Information Technology Systems Security Staff, known
as ITSSS, and its director. The hotline complaint alleged that the EPA paid Attain
millions of taxpayer dollars for work not completed or completed by other
contractors.
Snapshot of Task Order
On August 27, 2018, the EPA awarded Attain Task Order No. 68HE0H18F1516
under Contract No. GS-35F-0534W, valued at $12,527,900. The task order has a
one-year base period that started on August 28, 2018, and four one-year options
ending August 27, 2023. The task order is for information security support for
Agency systems and applications, as well as:
	Baseline compliance with the Agency's information security directives.
	Risk management framework evaluations.
	Plan of Action and Milestones reviews.
Relevant Invoice Review and Performance Evaluation Requirements
The EPA Acquisition Guide, dated December 2019, states:
	Under section 32.9.1.5(b)(4), the responsibility for invoice review
and approval is first vested with the contracting officer, but with
the CO's approval, may be delegated to the contracting officer's
representative. A CO's periodic monitoring must include at least
one detailed review of a contract invoice for each contract year.
Top Management Challenge
This evaluation addresses the following top
management challenge for the Agency, as
identified in OIG Report No. 20-N-0231. EPA's FYs
2020-2021 Top Management Challenges, issued
July 21, 2020:
 Complying with key internal control
requirements (policies and procedures).
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	Under section 32.9.1,5(b)(4)(xv), "COs perform periodic monitoring of a
COR/Invoice/Voucher Approving Official's invoice review."
The Office of Acquisition Management's Invoice Review & Approval Desk
Guide, dated March 13, 2015, states:
It is EPA's policy to review invoices thoroughly to ensure that
adequate information, proper rationale, and documentation exists
to support payment of contractor invoices in a timely manner.
The following Federal Acquisition Regulation provisions pertain to this
evaluation:
	48 C.F.R.  42.1502(a) requires that past performance evaluations
be prepared at least annually and at the time the work under a
contract or order is completed.
	48 C.F.R.  42.1503(e) requires agencies to conduct frequent
evaluations for compliance with the reporting requirements in 48
C.F.R.  42.1502 so that agencies can promptly identify delinquent
past performance reports.
	48 C.F.R.  42.1503(f) requires agencies to prepare and submit
performance evaluations in the Contractor Performance
Assessment Reporting System.
EPA Acquisition Guide sections 42.15.1.5.1 and 42.15.1.5.3 require contractor
performance evaluations to be completed in CPARS within 120 days from
contract completion for contracts less than one year or within 485 days from the
contract award date for multiyear contracts and every 365 days thereafter. When
transferring a contract to another contracting officer, section 42.15.1.5.1(e) of the
Guide requires the CO to prepare a transition memorandum summarizing the
contractor's performance to date and to include the memorandum in the contract
file.
Responsible Office
The EPA's Office of Acquisition Solutions, within the Office of Mission Support,
is responsible for planning, awarding, and administering contracts. COs in the
Office of Acquisition Solutions are responsible for awarding and administering
contracts, reviewing invoices periodically, and submitting the contractor's past
performance evaluations into CPARS.
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Scope and Methodology
We conducted this evaluation from February through September 2020 in
accordance with the Quality Standards for Inspection and Evaluation published in
January 2012 by the Council of the Inspectors General on Integrity and
Efficiency. Those standards require that we plan and perform the evaluation to
obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings, conclusions, and recommendations based on our objectives. We believe
that the evidence obtained provides a reasonable basis for our findings,
conclusions, and recommendations based on our review.
To understand contractual and acquisition requirements, we reviewed the
following documentation:
	Task Order No. 68HE0H18F1516 under Contract No. GS-35F-0534W, as
well as modifications associated with information technology support
services.
	Federal Acquisition Regulation provisions 48 C.F.R.  42.1502(a),
48 C.F.R.  42.1503(e), and 48 C.F.R.  42.1503(f).
	EPA Acqui siti on Gui de.
	Office of Acquisition Management's Invoice Review & Approval Desk
Guide.
We also performed the following activities related to the EPA's contract
administration of this task order:
	Selected seven information technology systems with the highest labor
hours charged from June through September 2019 to evaluate Attain's
work performance. Those sample systems included:
o	Drupal Web Content Management System for one EPA Web.
o	Email & Collaboration Services,
o	Enterprise Voice System,
o	EPA Acquisitions System,
o	Headquarters Physical Access Control System,
o	National Advanced Utility Metering System,
o	System of Registries.
	Interviewed the COs and the contracting officer's representative to
understand their responsibilities under the task order.
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	Interviewed the current COR about the invoice review and approval
process. We did not interview the former COR who left the EPA in
December 2019 before we started the evaluation.
	Interviewed the ITSSS director to obtain an overview of processes used
to monitor the contractor's work performance.
	Interviewed the information security officer and information system
security officers associated with the sample systems to obtain feedback
on the quality of the contractor's work performance.
	Reviewed invoices from June through September 2019 to determine
whether the COR maintained documentation to support review and
approval of invoices for payments.
	Reviewed CPARS.gov to determine whether Attain's performance
evaluation was reported for the task order's base year, which was from
August 28, 2018, through August 27, 2019.
	Interviewed the EPA's information technology security official and
reviewed other information technology security contracts to determine
whether there were contract services duplicative of the Attain task order.
We obtained a copy of the unsigned contract transition checklist prepared by the
previous CO, which identified outstanding actions requiring the next CO's
attention, such as completing the CPARS evaluation for the base year. We noted
that the unsigned checklist had erroneous contractor personnel information. We
could not verify the validity of the checklist because the CO at the time of this
evaluation stated that the official signed copy of the transition checklist is located
in the office. The EPA was under mandatory telework during the evaluation
process for this report because of the coronavirus pandemic and therefore, we
were not able to review it.
Actions Taken by the Agency
During the evaluation, we found that the ITSSS did not have controls in place to
maintain records to validate that billed costs for the reviewed monthly invoices
were allowable, allocable, and reasonable as required by the Federal Acquisition
Regulation and EPA contract management directives. The former ITSSS COR,
who reviewed the sampled invoices, used Attain's monthly status reports to
validate billed invoice amounts. However, the reports' totals did not match the
sampled invoice amounts for June, July, August, and September 2019.
We issued a discussion document on May 14, 2020, and subsequently met with
management in the Office of Mission Support to discuss these issues. The ITSSS
director provided us with additional internal control documents used to monitor
21-E-0031
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Attain's progress on completing contract deliverables, which were not included in
the former COR's invoice review file. Additionally, we met with the current COR
who provided sufficient evidence that the COR (1) reviewed monthly invoices
starting with the January 2020 invoice; and (2) maintained documentation to
support that invoice costs were allowable, allocable, and reasonable. Since the
current COR followed the internal control procedures established by the ITSSS
director, we did not make recommendations for ITSSS to implement controls to
maintain records to validate billed costs.
Results of Evaluation
We did not find evidence to support the hotline allegation that the EPA paid
Attain for information security services that were either not performed or
performed by other EPA contractors. The EPA did not, however, perform certain,
required contract management duties for the Attain contract. Throughout the task
order's base year, there were four COs overseeing the Attain contract at different
times. These COs did not complete the required invoice review or the contractor
performance evaluation because the outgoing COs did not complete the contract
transition checklist and transition memorandum, which would have notified the
incoming CO about critical contract monitoring tasks that needed to be
completed. Further, the EPA lacked processes to notify contract management
when COs did not review invoices periodically or initiate the contractor
performance evaluation in CPARS.
The EPA reviewed the January 2019 invoice, valued at $22,533, after we brought
the lack of periodic invoice reviews to the CO's attention. The EPA's invoice
review indicated that Attain submitted inaccurate labor rates on the invoice. Since
this was the only invoice review conducted by the CO, the EPA could have
overpaid Attain for the entire 2019 calendar year. Additionally, when contractor
performance evaluations are not conducted, the EPA lacks the performance-based
information required to make an informed decision about whether it should
continue a business relationship with the contractor.
COs Did Not Perform Required Periodic Invoice Reviews
The EPA COs did not perform the required invoice reviews for the task
order's base year as required by EPA's Acquisition Guide. Per the
Acquisition Guide section:
 32.9.1.5(b)(4), "The responsibility for invoice review and approval
is first vested with the CO, but with the CO's approval, may be
delegated to the COR. A CO's periodic monitoring must include at
least one detailed review of a contract invoice for each contract
year."
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	32.9.1.5(b)(4)(xv), "COs perform periodic monitoring of a
COR/Invoice/Voucher Approving Official's invoice review."
The EPA lacks a process to alert contract management when COs do not perform
the required invoice reviews, required by EPA policy, for each contract year. We
noted that multiple COs oversaw the task order during the base year, and each
provided various reasons why they did not complete the invoice review.
In response to our March 2020 inquiry regarding the lack of a periodic invoice
review, one of the previous COs reviewed the January 2019 invoice in March
2020, seven months after the August 27, 2019 end date of the task order's base
year, which was the latest date the CO should conduct an invoice review
(Figure 1). The CO who completed the invoice review discovered that some of the
labor rates on the January 2019 invoice, totaling $22,533, did not match the
hourly labor rates in the contractor's price submission. That CO requested that the
existing CO coordinate with the COR to ask the contractor to submit a revised
invoice with the correct hourly rates for the January 2019 invoice. However, the
existing CO at the time of this evaluation had not taken action necessary to have
the contractor submit an updated invoice or conduct subsequent invoice reviews
for the remaining months of the base year through the first option year to identify
any irregularities in billing cost.
Figure 1: Timeline of CO periodic invoice review for task order's base year
i-hl
i	i
		Base year		Seven-month late period	
August 2018	August 27,2019	^	March 2020
Begin base	End base year	Desk review
year	completed
Source: OIG analysis. (EPA OIG graphic)
The COs would have been aware of the incorrect labor rates and prevented
overcharges prior to our evaluation if the periodic invoice review had been
completed on time. Therefore, the EPA does not know if it overpaid for services.
As of the date of this report, the invoice reviews for the base year were still
unresolved.
COs Did Not Perform Required Performance Evaluation
The EPA COs did not complete the required contractor performance evaluation in
CPARS for the Attain task order's base year that ended on August 27, 2019. The
Federal Acquisition Regulation and the EPA Acquisition Guide require past
performance evaluations to be prepared at least annually and submitted in
CPARS.
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We noted that multiple COs managed the task order during the base year but none
of them prepared the required contract transition checklist and transition
memorandum to document the status of the CPARS evaluation and the
contractor's performance before transitioning the task order to the next CO.
One CO stated that the procedures do not
require a CO to complete CPARS
evaluations prior to transferring the contract
to the next CO. Although the procedures do
not mandate completing the evaluation, the
procedures require the CO to complete the
checklist and include it in the contract file.
The checklist includes a line item on the
status of the CPARS evaluation and an area
to include notes or instructions to inform the
next CO of necessary actions to take. The
EPA has not established a process to alert
contract management personnel when the
required annual evaluation has not been
initiated in CPARS.
It is incumbent upon contract management to ensure that COs are aware of their
responsibilities to complete the required contract transition documents and have a
process in place to ensure contractor performance evaluations are completed in a
timely manner. As a result, as of July 7, 2020, the noted contractor performance
evaluation had not been completed and was overdue by 196 days (Figure 2).
Figure 2: Delayed CPARS reporting for task order's base year
Office of Acquisition Solutions'
Workload Realignment Contract File
Transition Procedures require a
contract transition checklist to be
completed by the CO when
transferring contract files.
EPA Acquisition Guide section
42.15.1.5.1(e)(4) requires the CO to
include a transition memorandum
summarizing the contractor's
performance when transferring a
contract to another CO in the official
contract file.
<
z
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Base year
Aug 28, 2018
Award date
Source: OIG analysis. (EPA OIG graphic)
Conclusions
i Z5 s
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U
 S'

Dec 24, 2020
Evaluation due
120 days- 	
. < i
5
As of July 7, 2020
No evaluation
^ completed
196 days
When the CO does not periodically monitor the COR's invoice reviews, the EPA
does not have reasonable assurance that invoiced costs were properly approved
for payments to prevent fraud, waste, and abuse. Similarly, when contractor
performance evaluations are not conducted, the EPA lacks the information to
facilitate the Agency's decisions to invest taxpayer dollars in contractual services
and products that add value to the Agency's environmental mission and goals.
21-E-0031
7

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Recommendations
We recommend that the assistant administrator for Mission Support:
1.	Develop and implement internal controls to alert the Office of Acquisition
Solutions management, contracting officers' supervisors, and regional
acquisition managers when contracting officers have not conducted the
required invoice review in accordance with EPA Acquisition Guide
32.9.1.5(b)(4) and Office of Acquisition Management's Invoice Review &
Approval Desk Guide.
2.	Require the EPA's contracting officer, in coordination with the contracting
officer's representative, to review all invoices for Contract No. GS-35F-
0534W, Task Order No. 68HE0H18F1516, commencing with the base
year to validate labor rates, billed costs, and recoup any overpayments
from the contractor.
3.	Develop and implement internal controls to alert Office of Acquisition
Solutions management, contracting officers' supervisors, and regional
acquisition managers when contractor performance evaluations have not
been initiated in the Contractor Performance Assessment Reporting
System within the required time frame.
4.	Issue a memorandum to remind Office of Acquisition Solutions
contracting officers, contracting officers' supervisors, and regional
acquisition managers to complete the EPA's contract transition checklist
and transition memorandum when transferring task orders, including
contracts between contracting officers.
5.	Require the contracting officer for Task Order No. 68HE0H18F1516,
under Contract No. GS-35F-0534W, to prepare and submit the required
performance evaluations in the Contractor Performance Assessment
Reporting System for the base year and all option years, if exercised by
the EPA, as required by federal directives.
Agency Response and OIG Assessment
The Agency concurred with all the recommendations and provided acceptable
planned corrective actions and estimated milestone dates. We consider
Recommendations 1, 2, 4, and 5 resolved with corrective actions pending.
Recommendation 3 is completed as the Office of Mission Support provided
documentation of completed corrective actions. We revised the language in
Recommendations 1, 3, and 4 to include the COs' supervisors and regional
acquisition managers. The Agency concurred with the revisions. The Agency's
response to our draft report is in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
1
8
Develop and implement internal controls to alert the Office of
Acquisition Solutions management, contracting officers'
supervisors, and regional acquisition managers when contracting
officers have not conducted the required invoice review in
accordance with EPA Acquisition Guide 32.9.1.5(b)(4) and Office
of Acquisition Management's Invoice Review & Approval Desk
Guide.
R
Assistant Administrator for
Mission Support
1/30/21

2
8
Require the EPA's contracting officer, in coordination with the
contracting officer's representative, to review all invoices for
Contract No. GS-35F-0534W, Task Order No. 68HE0H18F1516,
commencing with the base year to validate labor rates, billed
costs, and recoup any overpayments from the contractor.
R
Assistant Administrator for
Mission Support
1/30/21

3
8
Develop and implement internal controls to alert Office of
Acquisition Solutions management, contracting officers'
supervisors, and regional acquisition managers when contractor
performance evaluations have not been initiated in the
Contractor Performance Assessment Reporting System within
the required time frame.
C
Assistant Administrator for
Mission Support
9/30/20

4
8
Issue a memorandum to remind Office of Acquisition Solutions
contracting officers, contracting officers' supervisors, and
regional acquisition managers to complete the EPA's contract
transition checklist and transition memorandum when
transferring task orders, including contracts between contracting
officers.
R
Assistant Administrator for
Mission Support
11/30/20

5
8
Require the contracting officer for Task Order No.
68HE0H18F1516, under Contract No. GS-35F-0534W, to
prepare and submit the required performance evaluations in the
Contractor Performance Assessment Reporting System for the
base year and all option years, if exercised by the EPA, as
required by federal directives.
R
Assistant Administrator for
Mission Support
1/30/21

1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
21-E-0031
9

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Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
September 29, 2020
OFFICE OF MISSION SUPPORT
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report Project No.
OA&E-FY20- 0107, ''EPA Needs to Improve Oversight of Invoice
Reviews and Contractor Performance Evaluation, " dated September
2, 2020
Vizian,
FROM: Donna J. Vizian, Principal Deputy Assistant Administrator Donna
TO:	Rudy Brevard, Director
Information Resources Management Directorate
Office of Audit and Evaluation
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. The Office of Mission Support is providing high-level intended corrective actions and
estimated completion dates for each recommendation in the report.
AGENCY'S OVERALL POSITION
The agency concurs with the recommendations of this report and has included a summary
response with high-level corrective actions and estimated completion dates in the table below.
wj
PROl*
Digitally signed by Vizian,
Donna
Date: 2020.09.30
10:22:54 -04'00'
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QMS RESPONSE TO REPORT RECOMMENDATIONS
No.
Recommendation
High-Level Intended Corrective Actions
Estimated
Completion Date
1
Develop and
implement internal
controls to alert the
Office of Acquisition
Solutions management
when contracting
officers have not
conducted the required
invoice review in
accordance with EPA
Acquisition Guide
32.9.1.5(b)(4) and
Office of Acquisition
Management Invoice
Review & Approval
Desk Guide.
OMS concurs with the recommendation to
develop and implement internal controls to alert
the Office of Acquisition Solutions management
when contracting officers have not conducted the
required invoice review in accordance with EPA
Acquisition Guide 32.9.1.5(b)(4) and Office of
Acquisition Management Invoice Review &
Approval Desk Guide.
The Office of Acquisition Solutions (OAS) will
send out a communication to operational OAS
division directors and regional acquisition
managers to strengthen each acquisition office's
emphasis on contract management and
administration. Procedural enhancements should
include implementation of a calendar alert or
similar mechanism to help assure management's
awareness of the status of key administrative
milestones on active contracts under its purview,
particularly, the completion and documentation of
the contracting officers' periodic monitoring of
contracting officers' representatives invoice
approving official duties.
Furthermore, OAS will utilize its existing
primary internal control mechanism, OAS'
Balance Scorecard, Acquisition System
Performance Measurement and Management
Program Guide, Part 6 - Contract Management
Assessment Program, to require contract
administration and oversight enhancements to
Internal Control Plans including the
implementation of key milestones calendar alert
as described above. OAS will also require in the
submission of the annual assessment report for
a minimum duration of the next two calendar
years, the specific reporting of COs' periodic
invoice review completion as a special interest
item.
January 30, 2021
21-E-0031
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No.
Recommendation
High-Level Intended Corrective Actions
Estimated
Completion Date
2
Require the EPA's
contracting officer, in
coordination with the
contracting officer's
representative, to
review all invoices for
Contract No. GS-35F-
0534W, Task Order
No. 68HE0H18F1516,
commencing with the
base year to validate
labor rates, billed
costs, and recoup any
overpayments from the
contractor.
OMS concurs with the recommendation to
require the EPA's CO, in coordination with the
COR, to review all invoices for Contract No. GS-
35F-0534W, Task Order No. 68HE0H18F1516,
commencing with the base year to validate labor
rates, billed costs, and recoup any overpayments
from the contractor.
January 30, 2021
3
Develop and
implement internal
controls to alert Office
of Acquisition
Solutions management
when contractor
performance
evaluations have not
been initiated in the
Contractor Performance
Assessment Reporting
System within the
required time frame.
OMS concurs with the recommendation to
develop and implement internal controls to alert
OAS management when contractor performance
evaluations have not been initiated in the
Contractor Performance Assessment Reporting
System within the required time frame.
The Policy, Training and Oversight Division in
OAS currently has in place an assigned point of
contact who provides OAS acquisition offices a
monthly status of their respective CPARS
reporting. The POC ensures that managers and
division directors are provided with said reports
to alert them on the status of performance
evaluations completion for procurement actions
that exceed the simplified acquisition threshold.
In addition, to further assist the acquisition
community, OAS/PTOD has posted training
material on the Knowledge Management
SharePoint site:
https://usepa. shareDoint.com/sites/OARM Comm
unitv/oam. km s/T oolkits/CPARS. aspx.
The Toolkit was developed to consolidate into
one location internal training material related to
CPARS and CPARS reporting and lists CPARS
POCs.
September 30,
2020
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No.
Recommendation
High-Level Intended Corrective Actions
Estimated
Completion Date
4
Issue a memo to
remind Office of
Acquisition Solutions
contracting officers to
complete the EPA's
contract transition
checklist and transition
memo when
transferring task
orders, including
contracts between
contracting officers.
OMS concurs with the recommendation to issue a
memo to remind OAS COs to complete the
EPA's contract transition checklist and transition
memo when transferring task orders, including
contracts between COs.
November 30,
2020
5
Require the contracting
officer for Task Order
No. 68HE0H18F1516
under Contract No.
GS-35F-0534W to
prepare and submit the
required performance
evaluations in the
Contractor
Performance
Assessment Reporting
System for the base
year and all option
years, if exercised by
the EPA, as required
by federal directives.
OMS concurs with the recommendation to
require the CO for Task Order No.
68HE0H18F1516 under Contract No. GS-35F-
0534W to prepare and submit the required
performance evaluations in the Contractor
Performance Assessment Reporting System for
the base year and all option years, if exercised by
the EPA, as required by federal directives.
January 30, 2021
If you have questions, please have your staff contact Mitchell Hauser, audit follow-up
coordinator, Administrative Operations Division, at (202) 564-7636 or hauser.mitchell@epa.gov.
Cc: Vincent Campbell
Nancy Dao
Shaheryar Qureshi
Gina Ross
Lynnann Hitchens
Kimberly Patrick
Pam Legare
Celia Vaughn
Daniel Coogan
Janice Jablonski
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Monisha Harris
Marilyn Armstrong
Mitchell Hauser
Allison Thompson
Nikki Wood
Andrew LeBlanc
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Appendix B
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff/Operations
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Assistant Administrator for Mission Support
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Mission Support
Associate Deputy Assistant Administrator for Mission Support
Director, Office of Continuous Improvement, Office of the Administrator
Director, Office of Resources and Business Operations, Office of Mission Support
Director, Office of Continuous Improvement, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Mission Support
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
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