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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA's Fiscal Years 2019
and 2018 Hazardous Waste
Electronic Manifest System
Fund Financial Statements
Report No. 21-F-0045
January 5, 2021
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Report Contributors: Paul Curtis
Mairim Lopez
Robert Hairston
Robert Evans
Edgar Dumeng
Kevin Haas
Abbreviations
Hazardous Waste Electronic Manifest Establishment Act
U.S. Environmental Protection Agency
Fiscal Year
Office of Inspector General
e-Manifest Act
EPA
FY
OIG
Cover Image: Trucks transporting hazardous waste. The EPA collects user fees to cover the
costs of operating the e-Manifest system, which tracks off-site shipments of
hazardous waste from a generator's site to the site of the receipt, as well as the
disposition of hazardous waste. (EPA photo)
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
21-F-0045
January 5, 2021
Why We Did This Audit
We performed this audit
pursuant to the Hazardous
Waste Electronic Manifest
Establishment Act, known as the
e-Manifest Act. The Act requires
the U.S. Environmental
Protection Agency to prepare
and the Office of Inspector
General to audit the
accompanying financial
statements of the EPA's
e-Manifest Fund. Our primary
objectives were to determine
whether:
• The financial statements
were fairly stated in all
material respects.
• The EPA's internal controls
over financial reporting were
in place.
• EPA management complied
with applicable laws and
regulations.
Launched on June 30, 2018, the
e-Manifest system tracks off-site
shipments of hazardous waste
from a generator's site to the
site of the receipt, as well as the
disposition of hazardous waste.
This report addresses the
following:
• Operating efficiently and
effectively.
This report relates to a top EPA
management challenge:
• Fulfilling mandated reporting
requirements.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
EPA's Fiscal Years 2019 and 2018 Hazardous
Waste Electronic Manifest System Fund
Financial Statements
EPA Receives an Unmodified Opinion
We rendered an unmodified opinion on the EPA's
fiscal years 2019 and 2018 e-Manifest Fund
financial statements, meaning that the statements
were fairly presented and free of material
misstatement.
Material Weaknesses Noted
We noted the following material weaknesses:
• The EPA made errors in its financial statement preparation process.
• The EPA improperly recorded accounts receivable and earned revenue.
• An EPA posting error creates the appearance of an Antideficiency Act
violation.
Compliance with Applicable Laws, Regulations, Contracts, and
Grant Agreements
We did not identify any instances of noncompliance that would result in a
material misstatement to the audited financial statements.
Recommendations and Planned Agency Corrective Actions
We make six recommendations to the Agency, including that it strengthen and
improve the preparation and management review of the financial statements so
that errors and misstatements are detected and corrected; analyze adjustments
and corrections to the financial statements so that such adjustments are
appropriate, accurate, and properly supported by documentation; analyze
billings and accounts receivable at the end of the fiscal year so that activity,
account balances, and respective accounts are reported accurately and in the
appropriate fiscal year; and correct the unexpended appropriations balance and
establish accounting models to properly record expenses from e-Manifest fees.
The Agency concurred with all six of our recommendations. For four of the
recommendations, the Agency provided acceptable planned corrective actions
and estimated completion dates, and we consider those four recommendations
resolved with corrective actions pending. The Agency completed corrective
actions for the remaining two recommendations.
We found the fund's
financial statements to be
fairly presented and free
of material misstatement.
List of OIG reports
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
January 5, 2021
MEMORANDUM
SUBJECT: EPA's Fiscal Years 2019 and 2018 Hazardous Waste Electronic Manifest System Fund
Financial Statements
Report No. 21-F-0045
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 is QA&E-FY20-0115. 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 the Chief Financial Officer and the Office of Land and Emergency Management are
responsible for the recommendations presented in this report.
This report contains six recommendations. In accordance with EPA Manual 2750, your offices provided
acceptable planned corrective actions and estimated milestone dates in response to Recommendations 1,
2, 3, and 4. These recommendations are resolved. The Office of the Chief Financial Officer also
implemented corrective actions in response to Recommendations 5 and 6, and we consider those
recommendations completed. No final response to this report is required. If you submit a response,
however, it will be posted on the OIG's website, along with our memorandum commenting on your
response. Your response should be provided as an Adobe PDF file that complies with the accessibility
requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final response should not
contain data that you do not want to be released to the public; if your response contains such data, you
should identify the data for redaction or removal along with corresponding justification.
FROM: Paul C. Curtis, Director
Financial Directorate
Office of Audit
TO:
David Bloom, Deputy Chief Financial Officer
Peter Wright, Assistant Administrator
Office of Land and Emergency Management
We will post this report to our website at www.epa.gov/oig.
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EPA's Fiscal Years 2019 and 2018
Hazardous Waste Electronic Manifest
System Fund Financial Statements
21-F-0045
Table of C
Inspector General's Report on EPA's Fiscal Years 2019
and 2018 Hazardous Waste Electronic Manifest System Fund
Financial Statements
Report on the Financial Statements 1
Report on Internal Control over Financial Reporting 2
Tests of Compliance with Laws, Regulations, Contracts, and Grant
Agreements 4
Management's Discussion and Analysis 6
Prior Audit Coverage 6
Agency Response and OIG Assessment 6
Attachments
1. Material Weaknesses 8
EPA Made Errors in Its Financial Statement Preparation Process 9
EPA Improperly Recorded Accounts Receivable and Earned Revenue 11
EPA's Posting Error Creates Appearance of Antideficiency Act Violation 13
2. Status of Recommendations and Potential Monetary Benefits 15
Appendices
A For the Fiscal Years Ending September 30, 2019 and 2018
Hazardous Waste Electronic Manifest System Fund (e-Manifest)
Financial Statements 16
B Agency Response to Draft Report 36
C Distribution 41
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Inspector General's Report on EPA's Fiscal
Years 2019 and 2018 Hazardous Waste Electronic
Manifest System Fund Financial Statements
The Administrator
U.S. Environmental Protection Agency
Report on the Financial Statements
We have audited the accompanying financial statements of the U.S. Environmental
Protection Agency's Hazardous Waste Electronic Manifest System Fund, known as
the e-Manifest Fund. These statements comprise the balance sheets as of
September 30, 2019, and September 30, 2018; related statements of net cost and
changes in net position; the statement of budgetary resources for the years then
ended; and related notes to the financial statements.
Management's Responsibility for the Financial Statements
Management is responsible for the preparation and fair presentation of these
financial statements in accordance with accounting principles generally accepted
in the United States. This includes the design, implementation, and maintenance
of internal control relevant to the preparation and fair presentation of financial
statements that are free from material misstatement, whether due to fraud or error.
Auditor's Responsibility
Our responsibility is to express an opinion on these financial statements based on
our audit. We conducted our audit in accordance with auditing standards generally
accepted in the United States; the standards applicable to financial statements
contained in Government Auditing Standards, issued by the comptroller general
of the United States; and Office of Management and Budget Bulletin 19-03, Audit
Requirements for Federal Financial Statements. These standards require that we
plan and perform the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatement.
An audit involves performing procedures to obtain audit evidence about the
amounts and disclosures in the financial statements. The procedures selected
depend on the auditor's judgment, including the assessment of the risks of
material misstatement of the financial statements, whether due to fraud or error. In
making those risk assessments, the auditor considers internal control relevant to
the entity's preparation and fair presentation of the financial statements in order to
design audit procedures that are appropriate in the circumstances. An audit also
includes evaluating the appropriateness of accounting policies used and the
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reasonableness of significant accounting estimates made by management, as well
as evaluating the overall presentation of the financial statements.
We believe that the audit evidence we have obtained is sufficient and appropriate
to provide a basis for our audit opinion.
Opinion
In our opinion, the financial statements referred to above, including the
accompanying notes, present fairly, in all material respects, the assets, liabilities,
net position, net cost, changes in net position, and budgetary resources of the
U.S. Environmental Protection Agency's Hazardous Waste Electronic Manifest
System Fund as of and for the years ended September 30, 2019 and 2018, in
accordance with accounting principles generally accepted in the United States.
Report on Internal Control over Financial Reporting
Opinion on Internal Control. In planning and performing our audit, we
considered the fund's internal control over financial reporting by obtaining an
understanding of the Agency's internal controls, determining whether internal
controls had been placed in operation, assessing control risk, and performing tests
of controls. We did this as a basis for designing our audit procedures for the
purpose of expressing an opinion on the financial statements and to comply with
Office of Management and Budget's audit guidance, not to express an opinion on
internal control. Accordingly, we do not express an opinion on internal control
over financial reporting. We limited our internal control testing to those controls
necessary to achieve the objectives described in Office of Management and
Budget Bulletin 19-03. We did not test all internal controls relevant to operating
objectives as broadly defined by the Federal Managers Financial Integrity Act
of 1982.
Material Weaknesses and Significant Deficiencies. Our consideration of the
internal control over financial reporting would not necessarily disclose all matters
in the internal control over financial reporting that might be significant
deficiencies. A deficiency in internal control over financial reporting exists when
the design or operation of a control does not allow management or employees, in
the normal course of performing their assigned functions, to prevent or detect and
correct misstatements on a timely basis. A material weakness is a deficiency or a
combination of deficiencies in internal control over financial reporting, such that
there is a reasonable possibility that a material misstatement of the entity's
financial statements will not be prevented or detected and corrected on a timely
basis. A significant deficiency is a deficiency or a combination of deficiencies in
internal control over financial reporting that is less severe than a material
weakness yet important enough to merit attention by those charged with
governance.
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Because of inherent limitations in internal control, misstatements, losses, or
noncompliance may nevertheless occur and not be detected. We noted three
matters that we consider to be material weaknesses. These issues are summarized
below and detailed in Attachment 1.
Material Weaknesses
EPA Made Errors in Its Financial Statement Preparation Process
We found multiple errors and misstatements in the e-Manifest Fund financial
statements. The Office of Management and Budget requires that information in
the financial statements be presented in accordance with generally accepted
accounting principles. Agency personnel prepared the e-Manifest Fund financial
statements and did not detect and correct, during their financial statement
preparation process, various errors and misstatements. Not properly recording
financial transactions and exercising due diligence in preparing the e-Manifest
Fund financial statements compromise the accuracy of the financial statements
and the reliance on them to be free of material misstatement.
EPA Improperly Recorded Accounts Receivable and Earned Revenue
We found that the Agency made two material errors in recording accounts
receivable and earned revenue. The Agency improperly recorded $1,187
million in billings during fiscal year 2019. We also found that the Agency did
not record $1,338 million of September 2019 billings until October 2019.
Federal accounting standards require federal entities to recognize accounts
receivable when a legal claim exists, as well as to recognize revenue when
services are provided. Federal standards for internal control require accurate
recording of transactions and events. The Agency recorded accounts
receivable and earned revenue without analyzing the e-Manifest bills,
erroneously compounding its monthly billings. Also, the Agency believed that
the September 2019 billings represented FY 2020 accounts receivable and
earned revenue. While these two errors offset to only approximately
$151,000, the compounding effect of the errors, if left undetected, could
materially distort e-Manifest accounts receivable and earned revenue, as well
as decrease confidence in the quality of its financial statements.
EPA's Posting Error Creates Appearance of Antideficiency Act Violation
We found that the Agency inappropriately recorded expenses totaling
$573,000, materially misstating the e-Manifest appropriations in its FY 2019
financial statements. Federal standards for internal control require accurate
recording of transactions and events. The Agency did not have accounting
models to properly record expenses from e-Manifest fees and inappropriately
reduced the e-Manifest appropriations accounts beyond the available balance.
If this error is not corrected, the resulting misstatement could raise concerns
21-F-0045
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because it will appear that the Agency violated the Antideficiency Act by
authorizing expenditures that exceeded the available appropriations.
Comparison of EPA's Federal Managers' Financial Integrity Act
Report with Our Evaluation of Internal Control
Office of Management and Budget Bulletin 19-03 requires the Office of Inspector
General to compare material weaknesses disclosed during the audit with those
material weaknesses reported in the Agency's Federal Managers' Financial Integrity
Act report that relate to the financial statements and identify material weaknesses
disclosed by the audit that were not reported in the Agency's report. The Agency's
report is prepared and submitted at the consolidated level, of which the e-Manifest
Fund is a component. Accordingly, there are no findings to report at the e-Manifest
Fund level.
Tests of Compliance with Laws, Regulations, Contracts, and
Grant Agreements
EPA management is responsible for complying with laws, regulations, contracts,
and grant agreements applicable to the Agency and the fund. As part of obtaining
reasonable assurance about whether the fund's financial statements are free of
material misstatement, we performed tests of the Agency's compliance with
certain provisions of laws, including those governing the use of budgetary
authority, regulations, contracts, and grant agreements that have a direct effect on
the determination of material amounts and disclosures in the fund's financial
statements.
Opinion on Compliance with Laws, Regulations, Contracts, and
Grant Agreements
The objective of our audit, including our tests of compliance with certain
provisions of laws, regulations, contracts, and grant agreements, was not to
provide an opinion on compliance with such provisions. Accordingly, we do not
express such an opinion.
We did not identify any instances of noncompliance that would result in a
material misstatement to the audited financial statements.
Specific Audit Requirements of the Hazardous Waste Electronic
Manifest Establishment Act
The Hazardous Waste Electronic Manifest Establishment Act, known as the
e-Manifest Act, 42 U.S.C. § 6939g, requires the OIG to perform an analysis,
which is included below, of (1) the fees collected and disbursed, (2) the
reasonableness of the fee structure in place as of the date of the audit to meet
current and projected costs of the system, (3) the level of use of the system by
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users, and (4) the success to date of the system in operating on a self-sustaining
basis and improving the efficiency of tracking waste shipments and transmitting
waste shipment data.
Fees Collected and Disbursed. The EPA began collecting e-Manifest user fees in
August 2018. As required by the e-Manifest Act, the EPA deposited fee
collections into the e-Manifest Fund. The EPA received a total of $15.7 million in
fee collections in FY 2019. The EPA is required, under the Consolidated
Appropriations Act, 2019, to reduce the appropriation provided by Congress for
necessary expenses to carry out the e-Manifest system by the amount of offsetting
collections. The Agency reimbursed the U.S. Department of the Treasury for
e-Manifest fee collections totaling $8.0 million in FY 2019.
Reasonableness of the Fee Structure to Meet Current and Projected Costs.
The EPA established fees for each manifest type (fully electronic, hybrid, data
plus image upload, scanned image upload, and mailed paper) based on a fee
model that focuses on the marginal labor cost of processing each manifest type.
Additionally, the EPA made a management decision to adjust the raw output of
this formula to distribute the costs across manifest types. Table 1 lists the fees per
manifest that were effective during FY 2019.
Table 1: FY 2019 fees by manifest type
Manifest type
Fee per manifest
Fully electronic and hybrid
$5.00
Data plus image upload
6.50
Scanned image upload
10.00
Mailed paper
15.00
Source: FY 2019 fee rates published on EPA's website. (EPA OIG table)
Level of Use of the System. The EPA launched the e-Manifest system on
June 30, 2018. A total of 632 registered facilities submitted 2.1 million manifests
through the e-Manifest system in FY 2019 (Table 2).
Table 2: Total manifests submitted through the e-Manifest system in FY 2019
Manifest type
Total manifests
Percentage
Fully electronic and hybrid
5,204
0.25%
Data plus image upload
1,625,310
77.75
Scanned image upload
353,060
16.89
Mailed paper
106,841
5.11
Total
2,090,415
100.00%
Source: OIG analysis of EPA data. (EPA OIG table)
The EPA estimated that it would receive approximately three million manifests
annually.
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Success to Date of the System in Operating on a Self-Sustaining Basis. The
e-Manifest system did not operate on a self-sustaining basis during FY 2019. The
Agency had not accumulated enough fees by the beginning of FY 2019 to cover
all e-Manifest costs. The Agency covered most of these costs through carryover
appropriations.
Management's Discussion and Analysis
Our audit was conducted for the purpose of forming an opinion on the financial
statements as a whole. The Management's Discussion and Analysis are presented
for the purpose of additional analysis and are not a required part of the basic
financial statements. Such information is the responsibility of management.
We obtained information from the fund's management about its methods for
preparing the Management's Discussion and Analysis, and we reviewed this
information for consistency with the financial statements.
We did not identify any material inconsistencies between the information
presented in the fund's financial statements and the information presented in the
Management's Discussion and Analysis.
Our audit was not designed to express an opinion and, accordingly, we do not
express an opinion on the fund's Management's Discussion and Analysis.
Prior Audit Coverage
During our prior year e-Manifest Fund financial statement audit—EPA's Fiscal
Years 2018 and 2017 Hazardous Waste Electronic Manifest System Fund
Financial Statements (Report No. 20-F-02441 issued August 10, 2020—we
reported two significant deficiencies and one issue related to compliance with
laws and regulations:
1. Improperly recorded e-Manifest receivables and earned revenue.
2. Misclassified e-Manifest user fee revenue.
3. Improperly calculated e-Manifest fees.
The Agency agreed with those findings and recommendations. The estimated
completion date for the corrective actions related to the improper recording of
receivables and earned revenues is September 30, 2021. The EPA has already
completed all corrective actions related to the misclassified fees and the
e-Manifest fee calculation error.
Agency Response and OIG Assessment
The Agency concurred with our recommendations but disagreed with the finding
of three material weaknesses. The Agency stated that these three findings are
related to the financial statement preparation and should be reported as one
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material weakness. We disagree. As previously stated, a material weakness is a
deficiency or a combination of deficiencies in internal control over financial
reporting, such that there is a reasonable possibility that a material misstatement
of the entity's financial statements will not be prevented or detected and corrected
on a timely basis. The three findings are material individually and identify
deficiencies in different processes, not only in the preparation of financial
statements.
The Agency also disagreed with the statement that the program is not sustainable.
We stand by our statement the e-Manifest system did not operate on a self-
sustaining basis during FY 2019. After the Agency began collecting e-Manifest
fees in August 2018, it had not accumulated enough fees to cover all program
costs by the beginning of FY 2019. The EPA therefore had to rely on carryover
appropriations. As a result, the program did not operate on a self-sustaining basis
during FY 2019.
Appendix B contains the Agency's response to our draft report. The Agency
provided acceptable corrective actions and estimated completion dates for four of
our six recommendations. We consider these four recommendations resolved with
corrective actions pending. The Agency completed corrective actions for the
remaining two recommendations.
Paul C. Curtis
Certified Public Accountant
Director, Financial Directorate
Office of Audit
Office of Inspector General
U.S. Environmental Protection Agency
August 27, 2020
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Attachment 1
Material Weaknesses
Table of Contents
1 EPA Made Errors in Its Financial Statement Preparation Process 9
2 EPA Improperly Recorded Accounts Receivable and Earned Revenue 11
3 EPA's Posting Error Creates Appearance of Antideficiency Act Violation 13
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1 - EPA Made Errors in Its Financial
Statement Preparation Process
We found multiple errors and misstatements in the e-Manifest Fund financial statements. The
Office of Management and Budget requires that information in the financial statements be
presented in accordance with generally accepted accounting principles. Agency personnel did not
detect and correct, during their financial statement preparation process, various errors and
misstatements. Not properly recording financial transactions and exercising due diligence in
preparing e-Manifest Fund financial statements compromise the accuracy of the financial
statements and the reliance on them to be free of material misstatement.
Office of Management and Budget Circular A-13 6, Financial Reporting Requirements,
Section II.3.1, requires that information in the financial statements be presented in accordance
with generally accepted accounting principles for federal entities issued by the Federal
Accounting Standards Advisory Board, Statement of Federal Financial Accounting Standards.
The U.S. Government Accountability Office's Standards for Internal Control in the Federal
Government defines the five components of internal control in government. Management should
design control activities to achieve objectives and respond to risks. The standard for control
activities requires appropriate documentation of transactions and internal controls. Management
is to clearly document internal control, all transactions, and other significant events in a manner
that allows the documentation to be readily available for examination. The standard for control
activities additionally requires the accurate and timely recording of transactions and events.
We found that the Agency misreported accounts receivable, earned revenue, and accrued
liabilities in its FY 2019 e-Manifest Fund financial statements. We also found various errors in
the financial statements. The EPA:
• Understated accounts receivable and earned revenue. We found errors in the posting
of accounts receivable and earned revenue that netted to an understatement of
approximately $151,000.
• Understated contract accruals. We estimated that the Agency understated FY 2019
e-Manifest contract accruals by approximately $183,000.
• Did not include all the FY 2019 activity in the financial statements. The Agency did
not include approximately $110,000 in activity for accounting period 15 (part of the
year-end closing process) in its FY 2019 e-Manifest Fund financial statements.
• Omitted two footnotes related to exchange revenue. The Agency omitted footnote
disclosures on exchange revenue as they relate to the Statement of Net Cost and
intragovernmental costs. Agency staff stated that the omission was an oversight.
• Posted adjustments that contained errors. We found that two out of four adjustments
that the Agency posted for the FY 2019 e-Manifest Fund financial statements contained
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errors. We found that the Agency's calculation for its payroll accrual was overstated and
the amounts were not posted to their proper accounts.
• Used an incorrect indirect cost rate. We found that the Agency used an incorrect
indirect cost rate to calculate expenses and income from other appropriations in FY 2018.
After various OIG inquiries about why the FY 2019 and FY 2018 indirect cost rates were
the same, Agency staff stated that the rate used in FY 2018 was incorrect.
Agency personnel did not detect and correct, during their financial statement preparation process,
the errors and misstatements stated above. After we conducted account analyses of the activity
and questioned the Agency, staff stated that the EPA would prepare additional adjustments and
revise the current adjustments to correct the errors and misstatements we found. Had it not been
for the intensive inquiry by our auditors, material errors would have impacted the e-Manifest
Fund financial statements. These issues highlight the need for the Agency to strengthen its
processes so that amounts and accounts are accurate, are properly posted, and comply with
federal accounting standards.
Failure to properly record accounting transactions and exercise due diligence in the preparation
and management review of the e-Manifest Fund financial statements compromises the accuracy
of the financial statements and the reliance on them to be free of material misstatement.
Recommendations
We recommend that the chief financial officer:
1. Strengthen and improve the preparation and management review of the financial
statements so that errors and misstatements are detected and corrected.
2. Analyze adjustments and corrections to the financial statements so that such adjustments
are appropriate, accurate, and properly supported by documentation.
Agency Response and OIG Assessment
The Agency concurred with our recommendations and provided acceptable planned corrective
actions with an estimated completion date of September 30, 2021. The Agency's response to our
draft report is included in Appendix B.
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2 - EPA Improperly Recorded Accounts Receivable
and Earned Revenue
We found that the Agency made two material errors in recording accounts receivable and earned
revenue. The Agency improperly recorded $1,187 million in billings during FY 2019. We also
found that the Agency did not record $1,338 million of September 2019 billings until
October 2019. Federal accounting standards require federal entities to recognize accounts
receivable when a legal claim exists, as well as to recognize revenue when services are provided.
Federal standards for internal control require accurate recording of transactions and events. The
Agency recorded accounts receivable and earned revenue without analyzing the e-Manifest bills,
erroneously compounding its monthly billings. Also, the Agency believed that the
September 2019 billings represented FY 2020 accounts receivable and earned revenue. While the
two errors offset to only approximately $151,000, the compounding effect of the errors, if left
undetected, could materially distort e-Manifest accounts receivable and earned revenue, as well
as decrease confidence in the quality of the fund's financial statements.
Statement of Federal Financial Accounting Standards 1, Accounting for Selected Assets and
Liabilities, states:
A receivable should be recognized when a federal entity establishes a claim to
cash or other assets against other entities, either based on legal provisions, such as
a payment due date, (e.g., taxes not received by the date they are due), or goods or
services provided. If the exact amount is unknown, a reasonable estimate should
be made.
Statement of Federal Financial Accounting Standards 7, Accounting for Revenue and Other
Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, states:
Revenue from exchange transactions should be recognized when goods or
services are provided to the public or another Government entity at a price.
The U.S. Government Accountability Office's Standards for Internal Control in the Federal
Government defines the five components of internal control in government. The standard for
control activities requires the accurate and timely recording of transactions and events.
The Office of Land and Emergency Management sends monthly invoices to treatment, storage,
and disposal facilities, as well as to users of the e-Manifest system, based on the total manifests
processed through the e-Manifest system during the previous month. These invoices are
cumulative and include any outstanding fees and penalties owed to the EPA in prior months. The
delinquent fees are added to all subsequent invoices until they are paid. The e-Manifest system is
not integrated with Compass, the EPA's financial system; therefore, the Office of Land and
Emergency Management compiles monthly aggregate billings by facility, such as current fees
owed in addition to any outstanding fees and penalties, and provides them to the Office of the
Chief Financial Officer. The Office of the Chief Financial Officer records a monthly standard
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voucher, based on the billings, to recognize the accounts receivable and earned revenue for
services provided.
During our test work, we found that the Agency improperly recorded $1,187 million in accounts
receivable and earned revenue by erroneously compounding its monthly billings. The Agency
erred by recording the entire invoice, which includes prior months' outstanding amounts, instead
of recording only the current fees. The Agency did not analyze e-Manifest bills to determine the
appropriate amount to record in its accounts receivable and earned revenue. By recording the
entire outstanding amount on the bills each month, the EPA inappropriately increased accounts
receivable and earned revenue.
We also found that the Agency did not record $1,338 million of September 2019 billings until
October 2019, misstating the FY 2019 e-Manifest Fund financial statements. The Agency
believed that the September 2019 billings represented FY 2020 accounts receivable and earned
revenue. By not recording the September 2019 bills in the appropriate fiscal year, the Agency
misstated the FY 2019 e-Manifest Fund financial statements.
While the two errors we found offset to only approximately $151,000, this amount was
coincidental, and the difference could have been much larger. The compounding effect of the
errors, if left undetected, could materially distort e-Manifest accounts receivable and earned
revenue, as well as decrease confidence in the quality of the fund's financial statements.
Recommendations
We recommend that the chief financial officer:
3. Record accounts receivable and earned revenue in the appropriate fiscal year.
We recommend that the chief financial officer, in coordination with the assistant administrator
for Land and Emergency Management:
4. Analyze e-Manifest billings so that accounts receivable and earned revenue are recorded
accurately.
Agency Response and OIG Assessment
The Agency concurred with our recommendations and provided acceptable planned corrective
actions with an estimated completion date of September 30, 2021. The Agency's response to our
draft report is included in Appendix B. In our draft report, we addressed Recommendations 3
and 4 to the chief financial officer. Upon further discussions with the Agency, we agreed that
Recommendation 4 should be addressed by the chief financial officer in coordination with the
assistant administrator for Land and Emergency Management.
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3 - EPA's Posting Error Creates Appearance
of Antideficiency Act Violation
We found that the Agency inappropriately recorded expenses totaling $573,000, materially
misstating the e-Manifest appropriations in its FY 2019 financial statements. Federal standards
for internal control require the accurate recording of transactions and events. The Agency did not
have accounting models to properly record expenses from e-Manifest fees and inappropriately
reduced the e-Manifest appropriations accounts beyond the available balance. If this error is not
corrected, the resulting misstatement could raise concerns because it will appear that the Agency
violated the Antideficiency Act by authorizing expenditures that exceeded the available
appropriations.
The U.S. Government Accountability Office's Standards for Internal Control in the Federal
Government defines the five components of internal control in government. The standard for
control activities requires the accurate and timely recording of transactions and events.
The Antideficiency Act, at 31 U.S.C. § 1341(a)(1)(A), states:
[A]n officer or employee of the United States Government... may not... make or
authorize an expenditure or obligation exceeding an amount available in an
appropriation or fund for the expenditure or obligation.
We found that the Agency erroneously impacted e-Manifest appropriations general ledger
accounts when it recorded $573,000 in operating expenses during FY 2019. This posting error
created a negative unexpended appropriations balance of $204,000 in the financial statements.
The Agency used e-Manifest fees collected from the public, not funds received through
appropriations acts, to pay for these expenses. The Agency records the appropriations received
and the e-Manifest fee collections separately under different general ledger accounts. The
e-Manifest fee collections do not impact the appropriations general ledger accounts.
Because of a lack of appropriate accounting models, the Agency increased the expended
appropriations general ledger account and reduced the unexpended appropriations account
regardless of the source of the funds used to pay for e-Manifest expenses. The unexpended
appropriations in the financial statements represent the balance of available appropriations for
the year presented. A negative unexpended appropriations balance indicates that the Agency
made erroneous charges or violated the Antideficiency Act by exceeding its appropriations.
Agency staff did not believe that the negative unexpended appropriations balance was
unreasonable until we made further inquiries. By not having appropriate accounting models, the
Agency made erroneous charges that created a negative unexpended appropriations balance in its
financial statements.
Due to the posting error, the Agency materially misstated its financial statements. If this error is
not corrected, the resulting misstatement could raise concerns because it will appear that the
Agency violated the Antideficiency Act by authorizing expenditures that exceeded the available
appropriations.
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Recommendations
We recommend that the chief financial officer:
5. Correct the expended and unexpended appropriations balance.
6. Establish accounting models to properly record expenses from e-Manifest fees.
Agency Response and OIG Assessment
The Agency concurred with our recommendations and stated in its response to our draft report
that all corrective actions were completed on August 3, 2020. Upon further analysis of the
Agency's support for their corrective actions, however, we determined that the corrective actions
for Recommendation 5 were completed on September 29, 2020, when the Agency corrected the
expended and unexpended appropriations balance in Compass, the EPA's financial system.
The Agency's response to our draft report is included in Appendix B.
21-F-0045
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Attachment 2
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
10
Strengthen and improve the preparation and management
review of the financial statements so that errors and
misstatements are detected and corrected.
R
Chief Financial Officer
9/30/21
$293
2
10
Analyze adjustments and corrections to the financial statements
so that such adjustments are appropriate, accurate, and properly
supported by documentation.
R
Chief Financial Officer
9/30/21
3
12
Record accounts receivable and earned revenue in the
appropriate fiscal year.
R
Chief Financial Officer
9/30/21
4
12
In coordination with the assistant administrator for Land and
Emergency Management, analyze e-Manifest billings so that
accounts receivable and earned revenue are recorded
accurately.
R
Chief Financial Officer
9/30/21
$151
5
14
Correct the expended and unexpended appropriations balance.
C
Chief Financial Officer
9/29/20
$573
6
14
Establish accounting models to properly record expenses from
C
Chief Financial Officer
8/3/20
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
21-F-0045
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Appendix A
For the Fiscal Years Ending September 30, 2019 and
2018 Hazardous Waste Electronic Manifest System
Fund (e-Manifest) Financial Statements
21-F-0045
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For the Fiscal Years Ending September 30, 2019 and 2018
Hazardous Waste Electronic Manifest System Fund (e-Manifest)
Financial Statements
Produced by the U.S. Environmental Protection Agency
Office of the Chief Financial Officer
Office of the Controller
21-F-0045
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Table of Contents
Management Discussion ant) Analysis ...1
Principal rinanchi! StiitenienK ft
Balance Sheet 6
Statement of Net Cost 7
Statement of Changes in Net Position 8
Statement of Budgetary Resources 9
Notes to Financial Statements...,. 10
Note 1 Summary of Significant Accounting Policies 10 -12
A Reporting Entity. 10
B. Basis of Presentation. "10
C. Budgets and Budgetary Accounting 10
D. Basis of Accounting 10
E. Revenues and Other Financing Sources 11
F. Funds with the Treasury. 11
G. General Property, Plant, and Equipment 11
II. Liabilities 11
I. Accrued Unfunded Annual Leave. 11
J. Retirement Plan 12
K. Use of Estimates, 12
L. Reclassification and Comparative Figures 12
Note 2. Fund Balance with Treasury (FBWT), 13
Note 3. Accounts Receivable, Net 13
Note 4. Other Assets 13
Note 5. Accounts Payable and Accrued Liabilities. 14
Note 6. General Property Plant and Equipment 14
Note 7. Other Liabilities 14-15
Note 8. Unobligated Balances Available 15
Note 9. Undelivered Orders at the End of the Period 15
Note 10. Payroll and Benefits Payable 15
Note 11. Income and Expenses from Other Appropriations. 16
Note 12. Exchange Revenues. Statement of Net Cost 16
Note 13. Intragovernmental Costs and Exchange Revenue. 16
Note 14. Reconciliation of Net Cost of Operations to Budget 17
21-F-0045 18
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Management's Discussion and Analysis
Tnlrodtii'lioii
The Hazardous Waste Electronic Manifest System fund (e-Manifest) was established as a result of the
Hazardous Waste Manifest Establishment Act (Public Law 112-195, October 5, 2012). The e-Manifest Act
requires the United States Environmental Protection Agency ('EPA' or 'the Agency") to establish and own a
hazardous waste electronic manifest program information technology ('IT') system that will enable electronic
manifesting as a means to augment or replace the use of paper manifests for tracking hazardous waste
shipments. The e-Manifest Act requires that the e-Manifest system:
1. Meets the needs of the user community;
2. Attracts sufficient user participation and service revenues to ensure the viability of the system (the
e-Manifest Act authorizes EPA to collect reasonable user fees); and
3. Decreases the administrative burden on the user community.
Current EPA RCRA Manifest Program
The EPA Office of Land and Emergency Management (OLEM) provides policy, guidance and direction for
the Agency's emergency response and waste programs. The Office of Resource Conservation and Recovery
(ORCR) within OLEM works to protect human health and the environment by ensuring responsible national
management of hazardous and nonhazardous waste. Working with delegated state waste programs, ORCR
implements the 1976 Resource Conservation and Recovery Act (RCRA), and ensures that the resource
conservation, recovery and waste management goals of RCRA are met. All states with the exception of Iowa
and Alaska have been delegated RCRA authority, meaning that states implement many if not all aspects of
RCRA policy.
The manifest program as implemented by EPA and the states ensures that hazardous waste shipments are
consistently tracked, and that hazardous wastes in fact arrive at permitted waste management facilities. The
manifest program is based on both RCRA and Department of Transportation (DOT) hazardous materials law
(The Hazardous Materials Transportation Act (HMTA)). These laws together require uniformity in the
content and use of the hazardous waste manifest form.
Launched at the end of June of 2018, e-Manifest now receives about 5,000 hazardous waste manifests a day
and generates more than $1 million in fees each month to support the system. EPA estimates that e-Manifest
will save state and industry users, on average, $50 million annually, once electronic manifests are widely
adopted.
c-MuiiifrsI Sjstein Planning Activities
Discussion of the e-Manifest system itself has taken place over many years: beginning back in the 1990's
when the concept of an electronic manifest system was first taking shape. Further activities continued over
the years to envision the e-Manifest system through various stakeholder discussions and pilots. For more
information EPA's efforts prior to the passage of the e-Manifest Act in 2012. please visit
http://www.epa.gov/osw/hazard/transportation/manifest/e-man-pastmeetings.htm.
EPA's FY 2019 e-Manifest Financial Statements.
1.
21-F-0045
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In early calendar year (CY) 2013, EPA conducted various stakeholder requirements meetings to reengage
with the user community. The purpose of these meetings was to build on past e-Manifest work to determine
high level system functional requirements. Following this, a system alternatives analysis was conducted to
look at various system implementation approaches, all assuming (among other things) a full electronic
mobile workflow. The alternatives analysis recommended that EPA leverage cloud hosting for initial system
development and system launch, and for long term operations and maintenance (O&M), consider re-
negotiating the cloud contract model or potentially migrate to an on-premise hosting model to keep costs
down.
Also, as a part of the planning work, a system Concept of Operations (CONQPS) was completed that, at a
high level, outlines both what the current manifest process entails for highway and rail transporters as well as
what the future system may look like. The CONOPS document provides a process and conceptual model for
how data will flow from stakeholder to stakeholder and through the system during the manifest workflow.
The technical architecture for e-Manifest was completed in FY 2015. This architecture includes the specific
components and data flows as currently defined to illustrate a technical solution for the e-Manifest system. In
doing so. it defines the specific boundaries of the e-Manifest system and how the different parts of the system
work together to provide the required services based on current requirements. For example, areas such as
system Cross-Media Electronic Reporting Regulation (CR0MERR) integration, paper manifest processing
and manifest data quality assurance (QA) were analyzed as a part of this effort.
As a part of this technical architecture planning work, EPA conducted targeted meetings with states and
industry separately in order to further flesh out current processes as well as expectations for the above areas.
The meetings were more detailed than previous discussions, and provided critical information to inform
system requirements.
The technical architecture work completed in FY 2015 serves as baseline for the current manifest program
and provides very strong foundation for future system buildout. It meets user needs and provides flexibility
for future iterations of the system.
Building on FY 2015. in FY 2016 the e-Manifest program realized significant progress while leveraging
existing ORCR software applications. EPA initially conceived e-Manifest as a standalone system and
allowed the system architects to consider a broad range of approaches without inherent constraints from an
existing system design. However, as designs matured, it was recognized that the e-Manifest technical
solution aligned closely with RCRAInfo in terms of end user functionality, data integration, and required
technical infrastructure. These factors led to the decision to implement e-Manifest as a unique module of
RCRAInfo.
Many of the new capabilities of e-Manifest can be implemented in RCRAInfo using the existing modular
architecture present in RCRAInfo. In addition, some of the more innovative design aspects of e-Manifest
could also be incorporated into RCRAInfo, improving both systems
Furthermore, by leveraging e-Manifest and RCRAInfo modules, opportunities for reuse of existing
technology investments were present, reducing the burden of e-Manifest implementation
These factors led to the decision to develop e-Manifest and RCRAInfo modules as distinct, but interrelated
entities which will meet the current and future needs of Industry, Government and Public
Acquisition Strategy Change
The EPA's system development work is focused on ensuring user needs are met from day one of national
system deployment. To accomplish this, the agency is conducting user-centered design and development, and
is utilizing agile software development methodologies. This approach embodies continuous improvement
EPA's FY 2010 e-Mamtesf financial Statements.
2.
21-F-0045
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through pilots and testing, using iterative processes, and continued regular engagement with users and
stakeholders throughout the process to provide on-going opportunities for input.
Instead of locking in on one source, the new e-Manifest Program services contract (multi- vendor indefinite
delivery/indefinite quantity (IDIQ)) will utilize a variety of vehicles for the following segments of the system:
• Project management including integration services.
• Paper manifest processing.
• User help desk and User training.
• Quality assurance for manifest data amongst industry, states, and the EPA.
• Sen ices to calculate, collect, and support reporting of user fees for paper and electronic manifest
processing.
• Support for stakeholder communication, including outreach and meeting support.
Research has shown that using this type of lean start-up methodology, with agile techniques, lowers the cost
of system development by addressing uncertainties promptly, and by ensuring that the work being completed
brings real value to users.
The agency will continue to work closely with users, adding more functionality in an incremental manner and
providing continuous improvement for the lifetime of the system. By taking this iterative approach the EPA
will refine remaining uncertainties from our architecture planning work in the most cost-effective manner.
o-M;i!iilosl System Development
As a follow-on to the completed technical and conceptual architecture, e-Manifest embarked on a pilot to
create initial system functionality with the General Service Administrations (GSA) 18F consulting shop. 18F
provided the IT expertise to create the foundation of e-Manifest and also provided agile project management
support. Specifically, 18F:
• introduced user-centered design/development, which engages industry/state users in the early
phases of development.
• created the development platform and hosting environment for e-Manifest,
• leveraged open source technologies (Trello, GitHub. biweekly online meetings showcasing recent
system updates) to allow users and other stakeholders to follow and participate in system
development.
As part of the agile development focus, in September 2015, EPA, in partnership with 18F, completed an
initial system demonstration. This focused on a key aspect of the system: the transaction at the end of the
chain-of-custody when the hazardous waste arrives at the designated waste management facility, and that
facility signs the electronic manifest to verify that all the hazardous waste types aind quantities were received.
Getting the system to properly electronically execute this all-important manifest transaction was a critical
first step. EPA worked with several industry users to complete this initial system functionality.
Although not as straightforward as standard government IT development projects, this course correction from
traditional lifecycle system development ("waterfall'') methodology to agile will ultimately deliver a better
system in a quicker, more value-added method going forward.
Starting with this initial system, EPA has been adding more functionality in an incremental manner. Research
has shown that using this type of lean start-up methodology with agile techniques lowers the cost of current
and future system development by addressing uncertainties sooner rather than later. Therefore, EPA has been
EPA's FY 2019 e-Manifest Financial Statements.
3.
21-F-0045
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conducting user-centered design and development, starting with the small-scale demonstration phase. Open
source code and project engages industry and state users in the early phases of development, creation of
development platform, and hosting environment. EPA will expand engagement efforts to all users overtime
(e.g., states with no systems, large and small generators, etc.).
The agile software development methodology embodies continuous improvement through iterative
development and delivers software in sprints. Agile embraces change, continuous and regular feedback and
improvement, value-driven delivery, full-team collaboration, and learning through discovery. Agile
techniques cannot eliminate the challenges intrinsic to high-discovery software development but by focusing
on continuous delivery of incremental value and shorter feedback cycles, they expose challenges as early as
possible to allow for immediate correction.
EPA has adopted the lean start-up product development strategies with agile, user-centered software
design/development methodologies and as implemented the following:
• Two-week sprint intervals
• Using modular development practices, relying heavily on available off-the-shelf software
modules, by building individual working pieces of the system and integrating them into the whole
• Addressing uncertainties that arose during the initial architecture planning work, and engaging
early with users and stakeholders
• Bringing down the cost of current and future development by addressing risk upfront and ensuring
lhat the work being completed brings actual value to stakeholders and users
• Continuously improving, using iterative processes, and engaging regularly with users and
stakeholders throughout the life of the program.
EPA has made every effort to involve industry users in the development process to build the strongest
possible system. During the system development phase, the e-Manifest team is working alongside industry,
states, and other stakeholders, by focusing on issues raised and addressing the issues, including the
following:
• How the national e-Manifest system will connect with state and industry systems
• User testing of the web application
» Addressing state data access needs
The e-Manifest team communicates regularly with states, industry, and related stakeholders about ongoing
developments (i.e., continued release and testing of system iterations), updates on e-Manifest related rules
(i.e., user fees for the e-Manifest system and amendments to manifest regulations), and the national launch of
the e-Manifest system.
EPA's FY 2019 e-Manifest Financial Statements.
21-F-0045
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Our primary methods of communication include the following;
• The e-Manifest website
• User testing
• Conferences
• Site visits
• Regional implementation working groups
• Listserv (general interest and development-focused)
• Public webinars
• Blog posts
• Git Hub - code repository and project management
• FACA Meetings
• Meetings with stakeholders.
e-Manifest will follow this path of milestones to system launch and beyond
• September 2015- initial system functionality completed.
• Spring of 2016 minimal viable product development.
• Spring through fall of 2016 - early full-scale development.
• Fall of 2016 through winter of 2018 - rolling iterative releases/testing of system.
• Winter 2018 - finalize user fee rule.
« June 30.2018 - System Launch.
• Continued development, enhancements and user outreach.
• Summer 2019 - update user fees.
EPA's FY 2019 e-Manifest Financial Statements.
21-F-0045
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Principal Financial Statements
I ,S. Emironmental Protection Agency
Hazardous Waste Klectronic Manifest System Fund
Balance Sheet
As or September 30, 2019 and 2018
(Dollars in Thousands)
2019 2018
ASSETS
Intragovernmental:
Fund Balance With Treasury (Note 2) $ 8,029 $ 4 m
Other (Note 4) 55 12
Total Intragovernmental 8.084 4 -w
Accounts Receivable, Net (Note 3) 1.338 1.781
General Property, Plant and Equipment, Net (Note 6) 5.008 6.389
Total Assets $„ 14.430 $ 12.503
LIABILITIES
Intragovertm lental:
Accounts Payable and Accrued Liabilites (Note 5)
$ 58 $
72
Other (Note 7)
3
10
Total Intragovernmental
61
82
Accounts Payable and Accrued Liabilities (Note 5)
748
393
Payroll and Benefits Payable (Note 10)
143
117
Total Liabilites
952
592
NET POSITION
Unexpended Appropriations - Funds from Dedicated Collections
186
3,851
Cumulative Results of Operations - Funds from Dedicated Collections
13.292
8.060
Total Net Position
13.478
11.911
Total Liabilities and Net Position
$ 14.430 $
12.503
The accompanying notes are an integial part ot these financial statements.
EPA'b FY 2019 e-Manifest Financial Statements
6.
21-F-0045 24
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Statement of Net Cost
For the Fiscal Years Ended September 30,2019 and 2018
(Dollars in Thousands)
2019 2018
COSTS
Gross Costs $ 13,896 $ 1,799
Expenses from Other Appropriations (Note 11) 2,139 281
Less:
Earned Revenue 15,265 2.192
NET COST OF OPERATIONS (Note 14) $ 770 $ (112)
The accompanying notes are an integral part of these financial statements.
EPA's FY 2019 e-Manifest Financial Statements
21-F-0045
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U.S. Emironnienlal Protection Agency
Hazardous Waste Fleetronic Manifest System Fund
Statement of Changes in Net Position
For the Fiscal Years Knded September 30,2019 and 2018
(Dollars in Thousands)
Cumulative Results of Operations:
Net Position - Beginning of Period
Budgetary Financing Sources;
Appropriations Used
Transfers ln.'Oi.i!
Income from Other Appropriations (Note 11)
Total Budgetary Financing Sources
Other Financing Sources (Non-Kxchange)
Imputed Financing Sources
Total Other Financing Sources
Net Cost of Operations
Net Change
Cumulative Results of Operations
Unexpended Appropriations:
Net Postilion - Beginning of Period
Budgetary Financing Sources:
Appropriations Received
Appropriations Used
Total Budgetary Financing Sources
Total Unexpended Appropriations
TOTAL NE I lOSHION
2019
2018
; 8,060 $
3,025
3,665
4,529
8
-
2.139
281
5.812
4,810
190
113
190
113
i (770) $
112
5.232
5.035
1 13.292 $
8.060
2019
2018
1 3,851 $
5,143
3.237
(3.665)
(4.529)
(3,665)
(1.292)
186
3.851
i 13.478 $
11.911
The accompanying notes are an integial part ot these financial statements.
EPA's FY 2019 e-Manifest Financial Statements
21-F-0045
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U.S. Em iromncntal Protection Agency
Ilazardmis Waste Electronic Manifest System Fund
Statement ol Budgetary Resources
For I he Fiscal Years Ended September 30,2019 and 2018
(l.)o II sirs in Thousands)
2019 2018
BUDGETARY RESOURCES
Unobligated Balance From Prior Year Budget Authority, Net (discretionary and
mandatory)
Appropriations (discretionary and mandatory)
Spending Authority from Offsetting Collections (discretionary and mandatory)
Total Budgetary Resources
STATUS OF BUDGETARY RESOURCES
New Obligations and Upward adjustments (total)
Unobligated Balance. End of Yea-
Apportioned. Unexpired Accounts
Unapportioned, Unexpired accounts
Expired Unobligated Balance, End of Year
Unobligated Balance. End of Year (total): (Note 8)
Total Status of Budgetary Resources
OUTI.AYS.NET
Outlays, Net (total) (discretionary and mandatory)
Distributed Offsetting Receipts (-)
Agency Outlays, Net (discretionary and mandatory)
; 931
$
2.539
-
3.237
15.581
437
1 16.512
$
6.213
i 14,486
$
5,379
1,764
659
-
(4)
262
179
2.026
834
i 16.512
$
6,213
1 (4,147)
$
4,785
i (4.147)
$
4.785
The accompanying notes are an integial part ot these financial statements.
EPA's FY 2019 e-Manifest Financial Statements
21-F-0045
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U.S. Emironniental Protection Agency
Hazardous Waste Electronic Manitest System Fund
Notes (o the Financial Statements
Fiscal Years Ended September 30, 201l> and September 30.201S
(Dollars in Thousands,!
Note 1. Summary of Significant Accounting Policies
A. Reporting Entity
The EPA was created in 1970 by executive reorganization from various components of other federal agencies
to better marshal and coordinate federal pollution control efforts. The Agency is generally organized around
the media and substances it regulates - air, water, waste, pesticides, and toxic substances.
The Hazardous Waste Electronic Manifest System Fund (e-Manifest) was authorized by the establishment of
the Hazardous Waste Electronic Manifest System Act. The act mandates that the Agency, within three years,
establish a hazardous waste electronic manifest system that can be accessed by any user. The act authorized
the administrator to impose users' fees to pay the costs incurred in developing, operating, maintaining, and
upgrading the system, including any costs incurred in collecting and processing data from paper manifests
submitted to the system after the date on which the system enters operations.
The e-Manifest lund charges some administrative costs directly to the fund, and charges the remainder of the
indirect administrative costs to Agency-wide appropriations. These amounts are included as "Income from
Other Appropriations" on the Statement of Changes in Net Position and as "Expenses from Other
Appropriations" on the Statement of Net Cost.
R. Basis of Presentation
These financial statements have been prepared to report the financial position and results of operations of the
EPA for the e-Manifest Fund in accordance with the Chief Financial Officers Act of 1990 and the
Government Management Reform Act of 1994. The reports have been prepared from the books and records
of the EPA in accordance with Office of Management and Budget (OMB) Circular A-] ?6 Financial
Reporting Requirements, and the EPA's accounting policies which are summarized in this note. These
statements are therefore different from the financial reports also prepared by the EPA pursuant to OMB
directives that are used to monitor and control the EPA's use of budgetary resources. The balances in these
reports have been updated from the EPA consolidated financial statements to reflect the use of fiscal year
2019 cost factors for calculating imputed costs for Federal civilian benefits programs. These updates impact
the Balance Sheet. Statement of Net Cost, and Statement of Changes in Net Position.
C. Budgets and Budgetary Accounting
For fiscal year 2019 the e-Manifest fund was funded through offsetting collections. For fiscal year 2018 the
e-Manifest fund was funded through appropriations and offsetting collections.
1). Basis of Accounting
Generally Accepted Accounting Principles (GAAP) for federal entities is the standard prescribed by the
Federal Accounting Standards Advisory Board (FASAB). which is the official standard-setting body for the
Federal Government and the American Institute of Certified Public Accountants (AICPA). The financial
statements are prepared in accordance with GAAP for federal entities.
EPA's FY 2019 e-Manifest Financial Statements.
10.
21-F-0045
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U.S. Emironmental Protection Agency
Hazardous Waste Electronic Manilest System Fund
Notes (o the Financial Statements
Fiscal Years Fnded September 30, 201l> and September 30.201S
(Dollars in Thousands,!
Transactions are recorded on an accrual accounting basis and a budgetary basis. Under the accrual method,
revenues are recognized when earned and expenses are recognized when liabilities are incurred, without
regard to receipt or payment of cash. Budgetary accounting facilitates compliance with legal constraints and
controls over the use of federal funds posted in accordance with OMB directives and the U.S. Treasury
regulations.
!•:. Revenues and Oilier Financing Sources
For fiscal years 2019 and 2018 EPA received funding from fees collected and recognized revenues from
collections to the extent that expenses were incurred during the fiscal year.
F. Funds with the Treasury
The e-Manifest fund deposits receipts and processes disbursements through its operating account maintained
at the U.S. Department of Treasury.
G. General Property, Plant, and Equipment
General property, plant and equipment for e-Manifest consists of software in development. Internal use
software includes purchased commercial off-the-shelf software, contractor developed software and software
that was internally developed by Agency employees. In fiscal year 2017, EPA reviewed its capitalization
threshold levels for PP&E. The Agency performed an analysis of the values of software assets and increased
capitalization threshold from $250 thousand to $5 million to better align with major software acquisition
investments. The $5 million threshold will be applied prospectively to software acquisitions and
modifications/enhancements placed into service after September 30, 2016. Software assets placed into
service prior to October 1, 2016 were capitalized at the $250 thousand threshold. Internal use software is
capitalized at full cost (direct and indirect) and amortized using the straight-line method over its useful life,
not exceeding five years. The Hazardous Waste Electronic Manifest System was placed into production
August 23,2018.
H. Liabilities
Liabilities represent the amount of monies or other resources that are more likely than not to be paid by the
Agency as the result of an Agency transaction or event that has already occurred and can be reasonably
estimated. However, no liability can be paid by the Agency without an appropriation or other collections
authorized for retention. Liabilities for which an appropriation has not been enacted are classified as
unfunded liabilities and there is no certainty that the appropriations will be enacted. Liabilities of the Agency
arising from other than contracts can be abrogated by the Government acting in its sovereign capacity.
I. Accrued Unfunded Annual Leave
Annual, sick and other leave is expensed as taken during the fiscal year. Annual leave earned but not taken at
the end of the fiscal year is accrued as an unfunded liability. Accrued unfunded annual leave is included in
the Balance Sheet as a component of "Payroll and Benefits Payable." Sick leave earned but not taken is not
accrued as a liability. It is expensed as it is used.
EPA's FY 2019 e-Manifest Financial Statements.
21-F-0045
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U.S. F.mironniental Protection Agency
Hazardous Waste FleeSronic Manilest System Fund
Notes (o the Financial Statements
Fiscal Years Fnded September 30, 201l> and September 30.201S
(Dollars in Thousands,!
J. Retirement Plan
There are two primary retirement systems for federal employees. Employees hired prior to January 1, J 987,
may participate in the Civil Service Retirement System (CSRS). On January 1,1987, the Federal Employees
Retirement System (FERS) went into effect pursuant to Public Law 99-335. Most employees hired after
December 31, 1986, are automatically covered by FERS and Social Security. Employees hired prior to
January 1.1987. elected to either join FERS and Social Security or remain in CSRS. A primary feature of
FERS is that it offers a savings plan to which the Agency automatically contributes one percent of pay and
matches any employee contributions up to an additional four percent of pay. The Agency also contributes the
employer's matching share for Social Security.
With the issuance of SFFAS No. 5. Accounting for Liabilities of the Federal Government, accounting and
reporting standards were established for liabilities relating to the federal employee benefit programs
(Retirement, Health Benefits, and Life Insurance). SFFAS No. 5 requires that the employing agencies
recognize the cost of pensions and other retirement benefits during their employees' active years of service.
SFFAS No. 5 requires that the Office of Personnel Management (OPM), as administrator of the CSRS and
FERS, the Federal Employees Health Benefits Program, and the Federal Employees Group Life Insurance
Program, provide federal agencies with the actuarial cost factors to compute the liability for each program.
K. Use of Estimates
The preparation of financial statements requires management to make certain estimates and assumptions that
affect the reported amounts of assets and liabilities, including environmental and grant liabilities, and the
reported amounts of revenue and expenses during the reporting period. Actual results could differ Itom those
estimates.
L. Reclassifications and Comparative Figures
Certain reclassifications have been made to the prior year's financial statements to enhance comparability
with the current year's financial statements in accordance with Office of Management and Budget (OMBj
Circular No. A-136, Financial Reporting Requirements revised June 28, 2019. As a result. Net Adjustments
to Unobligated Balance Brought Forward, Oct. 1 has been omitted in the Statement of Budgetary Resources.
EPA's FY 2019 e-Manifest Financial Statements.
12.
21-F-0045
30
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manilest System Fund
Notes (o the Financial Statements
Fiscal Years Ended September 30, 2019 and September 30.201S
(Dollars in Thousands,!
Note 2. Fund Balance Willi Treasurv (FBWT)
Fund Balance with Treasury as of September 30, consists of the following:
2019
2018
Entity Non-Entity Entity
Assets Assets Total Assets
Non-Entity
Assets
Total
Revolving Funds:
E-Manifest $ 8.029 S - $ 8.029 $ 4.294
$
$ 4.294
Total $ 8.029 $ - $ 8.029 3i 4.294
$ -
S 4.294
Status of Fund Balances:
2019
2018
Unobligated Amounts in Fund Balance:
Available for Obligation $
Obligated Balance not yet Disbursed
Total $
2.580
5.449
8.029
$ 982
3.312
$ 4.294
Note 3. Accounts Receivable, Net
Accounts Receivable as of September 30, 2019 and 2018, consist of the following;
2019
2018
Non-Federal:
Accounts & Interest Receivable $
Total $
1.338
1.338
S 1.781
$ 1.781
Note 4. Other Assets
Other Assets as of September 30, 2019 and 2018, consist of the following:
2019 2018
Intrago vernmental:
Advances to Working Capital Fund
$ 55 $
39
Total
$ 55 $
39
EPA's FY 2019 e-Manifest Financial Statements.
13.
21-F-0045
31
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U.S. Kmironmental Protection Agency
Hazardous Waste Fleet ronic Manilest System Fund
Notes (o the Financial Statements
Fiscal Years Fnded September 30, 2019 and September 30.201S
(Dollars in Thousands,!
Note 5. Accounts Payable and Accrued Liabilities
The Accounts Payable and Accrued Liabilities are current liabilities and consist of the following amounts as
of September 30, 2019 and 2018:
2019 2018
Intragovernmental:
Accounts Payable
$ 2 $
-
Accrued Liabilities
56
72
Total
$ 58 S
72
2019
2018
Non-Federal;
Accounts Payable
$ - $
266
Advances Payable
(2)
-
Other Accrued Liabilities
750
127
Total
$ 748 $
39^
Note 6, General Property, Plant and Equipment, Net
The e-Manifest svstem was moved into production August 23, 2018 with a total capitalized cost of $6,907.
As of September 30. 2019 and 2018, General PP&E consisted of the following:
2019 2018
Net
Net
Acquisition
Accumulated
Book
Acquisition Accumulated
Book
Value
Denreciation
Value
Value Denreciation
Value
Software (production)
$ 6.907
$ (1.899) $
5.008
$ 6.907 $ (518) $
6.389
Total
$ 6.907
$ (1.899) $
5.008
$ 6.907 $ (518)$
6.389
Note 7, Other Liabilities
Other Liabilities consist of the following as of September 30, 2019:
Covered by
Budgetary
Resources
Not Covered
by
Budgetary
Resources
Total
Current
Employer Contributions & Payroll Taxes
Total Intragovernmental
$
3 $
$ 3
$
3 $
$ 3
EPA's FY 2019 e-Manifest Financial Statements.
14.
21-F-0045
32
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U.S. Emironniental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes (o the Financial Statements
Fiscal Years Ended September 30, 2019 and September 30.201S
(Dollars in Thousands,!
Other Liabilities consist of the following as of September 30,2018:
Co\ered by
Budgetary
Resources
Not Covered
by
Budgetary
Resources
Total
Current
Employer Contributions & Payroll Taxes
Non-Current
Total Intragovernmental
$ 10 $ -
$
10
$ in s
$
10
Note 8. Unobligated Balances Available
Unobligated balances are a combination of two lines on the Statement of Budgetary Resources: Apportioned,
Unobligated Balances and Unobligated Balances Not Available. Unexpired unobligated balances are
available to be apportioned by the OMB for new obligations at the beginning of the following fiscal year.
The expired unobligated balances are only available for upward adjustments of existing obligations.
The unobligated balances available consist of the following as of September 30, 2019 and 2018:
2019 2018
Unexpired Unobligated Balance
$
1,764 $
659
I Iiiapportioned. Unexpired Accounts
-
(4)
F.xpired Unobligated Balance
262
179
Total
$
2.026 $
834
Note 9. Undelivered Orders at the End of the Period
Budgetary resources obligated for undelivered oidtt it September 30, 2019 and 2018, were $4,654 and
$2,844, respectively.
Note 10. Payroll and Benefits Payable
Payroll and benefits payable to the EPA employees for the years September 30, 2019, and 2018, consist of
the following:
FY 2019 Payroll and Benefits Payable
Accrued Funded Payroll and Benefits
Accrued Unfunded Annual Leave
Total - Current
Co\ered by Not Cohered
Budgetary by Budgetary
Resources Resources
47 $
47
Total
_96
96 $_
47
96
143
EPA's FY 2019 e-Manifest Financial Statements.
15.
21-F-0045
33
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U.S. Emironniental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes (o the Financial Statements
Fiscal Years Ended September 30, 2019 and September 30.201S
(Dollars in Thousands,!
Covered by
Not Covered
Budgetary
by Budgetary
Resources
Resources
Total
FY 2018 Payroll and Benefits Payable
Accrued Funded Payroll and Benefits
$ 34
$ - $
34
Accrued Unfunded Annual Leave
-
83
83
Total - Current
$ 34
$ 83 t,
117
Note 11. Income and Expenses from Other Appropriations
The Statement of Net Cost reports the program costs that include the full cost of the program outputs and
consist of the direct costs and all other costs that can be directly traced, assigned on a cause and effect basis,
or reasonably allocated to program outputs.
During FYs 2019 and 2018, the the indirect rate was 15.60%.
As illustrated below there is no impact on e-Manifest's Statement of Changes in Net Position.
2019 2018
Income from Other Appropriations
$
2,139 $
281
Expenses from Other Appropriations
2.139
281
Net Effect
$
$
-
Note 12. Exchange Revenues. Statement of Net Cost
For FYs 2019 and 2018, the exchange revenues reported on the Statement of Net Cost include both Federal
and non-Federal amounts.
Note 13.1 nt ragovernmental Costs and Exchange Revenue
2019 2018
Costs:
Intragovernmenlal
$ 2.837 $
2.370
With the Public
11.059
(571)
Expenses from Other Appropriations
2.139
281
Total Costs
$ 16.035 $
2.080
Rexenue:
With the Public
15.265
Total Revenue
15.265
i;
Net Cost of Operations:
$ 770 $
(1121
Intergovernmental costs relate to the source of the goods or services not the classification of the related
revenue.
EPA's FY 2019 e-Manifest Financial Statements.
16.
21-F-0045
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U.S. Emironmental Protection Agency
Hazardous Waste Electronic Manilest System Fund
Notes (o the Financial Statements
Fiscal Years Ended September 30, 2019 and September 30.201X
(Dollars in Thousands,!
Note 14. Reconciliation of Net Cost of Operations to Budget
Intra-
With the
governmenial
Public
Total 2019
NET COST
$ 2,837 '
$ (2,067)
$ 770
Components ol'Nel Cost That Are Not Part of Net Outlays:
Property. Plant and Equipment Depreciation
-
(1,381)
(1,381)
Expenses from Other Appropriations
-
(2,140)
(2,140)
Increase/*Decrease) in Assets:
Accounts Receivable
-
(443)
(443)
Other Assets
16
-
16
(Increase I/Decrease in I.iabilites:
Accounts Payable and Accrued Liabilites
14
"V
Payroll and Benefits Payable
-
( O
t'U
Other Liabilites
7
-
7
Other Financing Sources;
Transfer Out (In) Without Reimbursement.
8
-
8
Other Imputed Financing
190
-
190
Total Components of Net Cost That Are Not Part of Net
Outlays
3,072
(6,412)
'* "*4"
Other Temporary Timing Differences
-
(807)
(8
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Appendix B
? t
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON JC S'tSn
September 25. 2020
»'ir , it ;i >
1 M\A 'U.K I i |i I I
MEMORANDUM
SUBJECT:
FROM:
TO:
Response to The Office of Inspector General Draft Report. Project No. OA&E-FY20-
0115 "Ai;dir of EPA's Fiicul Years 2ul9 and 201$ Haz.irJom Wmre Electronic Maui/est
Sr stein Fund Fiihipcial Srnre'itcars " dated August 2". 2020
David A, Bloom. Deputy Chief Financial Officei DAVID
Office of the Chief Financial Officer BLOOM
Paul C. Curtis
Financial Directorate
Office of Audit and Evaluation
Office of Inspector General
Dlg.taliv signed by
DAVID BLOOM
Dare- 2020 >w.25
16.29-42 -MOT
Thank you for the opportunity to respond to the issues and recommendations in the subject
draft audit report. The following is a summary of the U.S. Environmental Protection Agency's
overall position, along with its position on each of the report's recommendations. The draft
report contained six recommendations for the Office of the Chief Financial Officer and no
recommendations for the Office of Land and Emergency Management.
The OCFO concurs with the Office of Inspector General's recommendations and has
provided proposed corrective actions, which have been reviewed by the Office of Land
and Emergency Management.
However, the OCFO strongly disagrees with the OIG's finding of three material
weaknesses. All three issues relate to financial statement preparation and should be
reported as one material weakness. In addition, the agency disagrees with the statement
in the audit that the program is not sustainable.
The fee structure was reviewed during this fiscal year's Biennial User Fee Review. The
comment is not supported with long-term data, which shows that the fee structure does
support the implementation of the program.
Below is additional information regarding the OCFO's position.
21-F-0045
36
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PIG STATEMENT
We found multiple errors and misstatements in the e-Manifest financial statements. The
Office of Management and Budget requires that information in the financial statements
be presented in accordance with generally accepted accounting principles. Agency
personnel prepared the e-Manifest financial statements and did not detect and correct,
during their financial statement preparation process, various errors and misstatements.
Not properly recording financial transactions and exercising due diligence in preparing
e-Manifest financial statements compromises the accuracy of the financial statements
and the reliance on them to be free of material misstatement.
AGENCY RESPONSE
The agency concurs with the OIG statement and has developed internal
checklists to assist with the financial statement preparation and review
process and to find and prevent errors. In FY 2021 and going forward, the
agency will prepare and release all component financial statements
together, early in the second quarter to allow for uniform footnote
disclosures and to ensure that adjustments are applied in the same manner
for all statements.
OIG STATEMENT
We found that the Agency made two material errors in recording accounts
receivable and earned revenue. The Agency improperly recorded $1,187 million in
billings during FY 2019. We also found that the Agency did not record $1,338
million of September 2019 billings until October 2019. Federal accounting
standards require federal entities to recognize accounts receivable when a legal
claim exists, as well as to recognize revenue when services are provided. Federal
standards for internal controls require accurate recording of transactions and
events. The Agency recorded accounts receivable and earned revenue without
analyzing the e-Manifest bills, erroneously compounding its monthly billings.
Also, the Agency believed that the September 2019 billings represented FY 2020
accounts receivable and earned revenue. While the two errors offset to
approximately $151,000, if left undetected, the compounding effect of the errors
could materially distort e-Manifest accounts receivable and earned revenue as well
as decrease confidence in the quality of its financial statements.
AGENCY RESPONSE
The agency concurs and made both adjustments prior to issuance of the final
financial statements. The agency will continue to work with other agency
stakeholders to develop a more efficient process to ensure accounts receivables
are recorded completely and timely. This work is outlined in our FY 2020
Federal Managers' Financial Integrity Act Assurance Letter.
21-F-0045
37
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PIG STATEMENT
We found that the Agency inappropriately recorded expenses totaling $573,000,
materially misstating the e-Manifest appropriations in its FY 2019 financial statements.
Federal standards for internal controls require accurate recording of transactions and
events. The Agency did not have accounting models to properly record expenses from
e-Manifest fees and inappropriately reduced the e-Manifest appropriations accounts
beyond the available balance. If this error is not corrected, the misstatement could raise
concerns because it will appear that the Agency violated the Antideficiency Act by
authorizing expenditures that exceeded the available appropriations.
AGENCY RESPONSE
The agency concurs that the accounting model was incorrect. The
accounting model has been corrected to prevent this error in the future and
an adjustment was made to properly record the expenses from e-Manifest
fees prior to the issuance of the final financial statements. Because
expenditures did not exceed the available balance, there was not an
Antideficiency Act violation.
AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATIONS
Agreements
No. Recommendation Assigned
High-Level Intended Estimated
Corrective Action(s) Completion Date
to:
1 Strengthen and improve OCFO
the preparation and
management review of
the financial statements so
that errors and
misstatements are
detected and corrected.
The agency has 9/30/2021
implemented numerous
actions in FY 2020
which will improve the
preparation and review
of financial statements,
including a new financial
statement preparation
checklist and software
package. The agency
will continue to review
its processes for
preparing financial
statements and identify
additional improvements
to strengthen the
preparation process
further. In addition, the
agency will prepare and
release all component
statement audits at the
same time in order to
21-F-0045
38
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allow for uniform
footnote disclosures and
to ensure that accrual
adjustments are applied
in the same manner for all
statements.
2
Analyze adjustments
and corrections to the
financial statements so
that such adjustments
are appropriate,
accurate, and properly
supported by
documentation.
OCFO
The agency makes every
effort to ensure that
adjustments and
corrections appropriate,
accurate, and properly
supported, however, in
addition to the actions
taken under
recommendation one, we
will continue to review
with staff the need to
include more of the
supporting analysis and
rationale behind the
adjustments made and the
accounting basis for
them. Management
reviews of journal
vouchers will
continue, and
additional training
will be provided as
needed.
9/30/2021
3
Record accounts
receivable and earned
revenue in the
appropriate fiscal
year.
OCFO
The FY 2019
adjustments were
completed prior to
issuance of the final
financial statements.
Monthly reconciliations
will be performed to
ensure the accounts
receivable and earned
revenue are recorded in
the appropriate period.
9/30/2021
4
Analyze e-Manifest
billings so that accounts
receivable and earned
revenue are recorded
accurately.
OCFO
Monthly reconciliation
will be performed to
ensure the accounts
receivable and earned
revenue are recorded
accurately.
9/30/2021
21-F-0045
39
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5
Correct the expended
and unexpended
appropriations
balance.
OCFO
The agency has corrected
the unexpended
appropriations balance.
Completed
08/03/2020
6
Establish accounting
models to properly record
expenses from e-Manifest
fees.
OCFO
The agency has updated
the accounting model to
properly record expenses
from e-Manifest fees.
Completed
08/03/2020
C ONTAC T INFORMATION
If you have any questions regarding this response, please contact the OCFO Audit Follow-up
Coordinator, Andrew LeBlanc, at leblanc.aiidrew@,epa.gov or (202) 564-1761 or the OLEM
Audit Follow-up Coordinator, Kecia Thornton, at thornton.kecia@epa.gov or (202) 566-1913.
cc: Peter Wright
Barry Breen
Steven Cook
Kathrine Trimble
Charles Sheehan
Rashmi Bartlett
James Hatfield
Carol Terris
C. Paige Hanson
Barry Breen
Steven Cook
Lek Kadeli
Charlie Dankert
Jeanne Conklin
Meshell Jones-Peeler
Richard Gray
Carolyn Hoskinson
Greg Sullivan
Nigel Simon
OCFO-OC-MANAGERS
Richard Eyermann
Mai rim Lopez
Robert Hairston
Andrew LeBlanc
Kecia Thornton
Jose Kercado-Deleon
21-F-0045
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Appendix C
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff/Operations
Chief Financial Officer
Assistant Administrator for Land and Emergency Management
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Land and Emergency Management
Deputy Chief Financial Officer
Associate Chief Financial Officer
Associate Chief Financial Officer for Policy
Controller
Deputy Controller
Associate Deputy Controller
Director, Accounting and Cost Analysis Division, Office of the Chief Financial Officer
Director, Policy, Training, and Accountability Division, Office of the Controller
Branch Chief, Management, Integrity and Accountability Branch, Policy, Training, and
Accountability Division, Office of the Controller
Director, Office of Program Management, Office of Land and Emergency Management
Director, Office of Resource Conservation and Recovery, Office of Land and
Emergency Management
Associate Director, Program Implementation and Information Division, Office of Resource
Conservation and Recovery, Office of Land and Emergency Management
Branch Chief, Permits Branch, Office of Resource Conservation and Recovery, Office of Land
and Emergency Management
Branch Chief, Information Collection and Analysis Branch, Office of Resource Conservation
and Recovery, Office of Land and Emergency Management
Associate Branch Chief, Information Collection and Analysis Branch, Office of Resource
Conservation and Recovery, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of the Controller
Audit Follow-Up Coordinator, Office of Resource Conservation and Recovery, Office of Land
and Emergency Management
21-F-0045
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