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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Spending Taxpayer Dollars
EPA's Tracking and
Reporting of Its Conference
Costs Need Improvement
Report No. 16-P-0081
January 7, 2016

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Report Contributors:	Eileen Collins
Janet Kasper
Mona Mafi
Madeline Mullen
Michael Petscavage
Nicole Pilate
Abbreviations
CDW
Compass Data Warehouse
EPA
U.S. Environmental Protection Agency
FY
Fiscal Year
NARPM
National Association of Remedial Project Managers
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
PL
Public Law
PRD
Peer Review Division
WEFTEC
Water Environment Federation Annual Technical Exhibition and Conference
Cover photo: EPA booth at Water Environment Federation Annual Technical Exhibition and
Conference 2012. (EPA photo)
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Learn more about our OIG Hotline.
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Washington, DC 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
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U.S. Environmental Protection Agency	16-P-0081
^	\ Office of Inspector General	January 7,2016
ISIS/

At a Glance
Why We Did This Audit
On May 11, 2012, the Office of
Management and Budget
issued Memorandum M-12-12,
Promoting Efficient Spending to
Support Agency Operations.
It calls for agencies to ensure
that conference expenses are
appropriate, necessary and
managed in a manner that
minimizes expenses to
taxpayers. M-12-12 and Public
Law 113-76, Consolidated
Appropriations Act, 2014, set
forth oversight and reporting
requirements for agencies with
conferences that cost over
$100,000.
In light of this scrutiny over
conference spending, the
U.S. Environmental Protection
Agency (EPA), Office of
Inspector General (OIG),
sought to determine whether
the EPA's internal controls and
conference oversight ensure
that conference expenses are
appropriate and reported
accurately.
This report addresses the
following EPA goal or
cross-agency strategy:
• Embracing EPA as a
high-performing
organization.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oia.
EPA's Tracking and Reporting of Its
Conference Costs Need Improvement
What We Found
The EPA established internal controls to report
conferences both publicly and to the OIG as
required by M-12-12 and Public Law 113-76.
However, we found improvements are needed
to address the following:
Accurate data on conference
costs will provide the EPA
with the information it needs
to be more efficient in how
funds are spent.
•	We found $6,916 of inappropriate expenses attributed to two conferences
out of the $985,851 of expenses reviewed for eight conferences.
•	The EPA required the use of conference project codes to track and
monitor conference spending, but this did not always occur.
•	Conference costs were underreported.
•	Two conferences totaling $350,782 were in the EPA conference spending
tool but were not reported publicly as required.
•	Sixty-four percent of the 227 fiscal year 2014 conferences were reported
late or not reported to the OIG as required. Two of the eight conferences
sampled were not reported to the OIG at all.
Addressing these issues will result in more accurate reporting on types of costs
for conferences and allow the EPA to better analyze costs and identify
efficiencies.
Recommendations and Planned Corrective Actions
We recommend that the Office of the Chief Financial Officer (OCFO) provide
additional guidance or training on how to identify unallowable conference costs,
use correct conference project codes, identify all conference costs in the financial
system, report all conference costs paid with EPA funds, and classify
conferences properly. We also recommend that OCFO work with program offices
to identify EPA Form 5170A cost reporting issues and revise the form as needed.
The OCFO agreed with all recommendations and provided planned corrective
actions with milestone dates. When implemented, the corrective actions should
address the recommendations. The recommendations are considered open with
agreed-to-corrective actions pending.
Noteworthy Achievements
The OCFO has proactively taken steps to improve the conference spending tool
for conference reporting. In addition, refresher training sessions were held to
address recent changes to the conference spending tool as well as concerns
raised by the OIG during this audit.
Listing of OIG reports.

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^£DSX
s JHt? ^	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
|	j?	WASHINGTON, D.C. 20460
\ S
PRO"^
THE INSPECTOR GENERAL
January 7, 2016
MEMORANDUM
SUBJECT: EPA's Tracking and Reporting of Its Conference Costs Need Improvement
Report No. 16-P-0081
FROM: Arthur A. Elkins Jr.	I	'
TO:	David Bloom, Deputy Chief Financial Officer
Office of the Chief Financial Officer
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems
the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of
the OIG and does not necessarily represent the final EPA position.
Action Required
You are not required to provide a written response to this final report because you provided agreed-to
corrective actions and planned completion dates for the report recommendations. The agency should
track corrective actions not implemented in the Management Audit Tracking System. Should you choose
to provide a final response, we will post your response on the OIG's public 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's Tracking and Reporting of Its
Conference Costs Need Improvement
16-P-0081
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Office		2
Noteworthy Achievements		3
Scope and Methodology		3
2	Improvements Needed in EPA's Conference Oversight		5
Federal Regulations and EPA Policy Establish Guidance		5
Minor Improvements Needed		5
Categorization of Reported Costs Cannot Be Verified		7
EPA Needs to Improve Oversight of Incurred Conference Costs 		7
Recommendations		8
Agency Response and OIG Evaluation		8
3	EPA Needs to Improve Tracking of Conference Expenses in Its
Financial System		9
Conference Expense Tracking Is Required		9
Conference Project Codes Are Not Always Used		9
Additional Guidance Needed to Identify Conference Costs		10
Unidentified Costs Resulted in Underreported Conference Cost Data		11
Recent Agency Actions Prompted by OIG Work		11
Recommendation		11
Agency Response and OIG Evaluation		11
4	EPA's Conference Reporting Needs Improvement		13
EPA Required to Report on Conference Spending		13
EPA Did Not Always Comply With Reporting Requirements		14
Additional Oversight and Guidance Needed to Improve Reporting		15
Noncompliance Leads to Lack of Transparency		15
Recent Agency Actions Prompted by OIG Work		15
Recommendation		15
Agency Response and OIG Evaluation		16
Status of Recommendations and Potential Monetary Benefits		17
Appendices
A Agency Response to Draft Report	 18
B Distribution	 23

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Chapter 1
Introduction
Purpose
The Office of Inspector General (OIG) of the U.S. Environmental Protection
Agency (EPA) conducted this audit to determine whether the EPA's internal
controls and oversight of conferences ensure that expenses are appropriate and
reported accurately.
Background
According to the EPA, conferences are important in government operations and
an efficient and cost-effective means for achieving the EPA's mission. A
conference includes a meeting, retreat, seminar, symposium or event. The EPA
hosts conferences for a variety of reasons, such as program reviews, presentations
of scientific findings, and oversight boards or advisory groups to achieve its
mission. According to the EPA, it spent $11,315,047 on 227 hosted or sponsored
conferences that had costs exceeding $20,000 during fiscal year (FY) 2014.
The President signed Executive Order 13589, "Promoting Efficient Spending," on
November 9, 2011. The order focused on reducing agencies' travel, information
technology, printing, fleet costs and conferences. On May 11, 2012, the Office of
Management and Budget issued Memorandum M-12-12, Promoting Efficient
Spending to Support Agency Operations. The memorandum states:
The Federal Government has a responsibility to act as a careful
steward of taxpayer dollars, ensuring that Federal funds are used
for purposes that are appropriate, cost effective, and important to
the core mission of executive departments and agencies (agencies).
Further, regarding conferences, M-12-12 advises:
Federal agencies and employees must exercise discretion and
judgment in ensuring that conference expenses are appropriate,
necessary, and managed in a manner that minimizes expense to
taxpayers.
M-12-12 set forth oversight requirements for conferences. It requires public
reporting of sponsored conferences in excess of $100,000. These requirements
include the total costs, location, date, a brief explanation of how the conference
advanced the mission of the agency, and the number of individuals whose travel
expenses or other conference expenses were paid by the agency.
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Public Law (PL) 113-76, Consolidated Appropriations Act, 2014, requires
compliance with M-12-12 and has additional reporting requirements for
conferences. PL 113-76 requires annual reporting to the OIG for conferences held
by the agency with costs exceeding $100,000 on the purpose, number of
participants, contracting procedures, cost detail for food or beverage and audio
visual services, and the cost of employee and contractor travel to and from the
conference. The law requires agencies holding conferences with costs over
$20,000 to notify the OIG within 15 days of the date, location and number of
employees attending the conference. These requirements to notify the OIG
continued with PL 113-235, Consolidated and Further Continuing
Appropriations Act, 2015, for FY 2015.
The EPA implemented M-12-12 and PL 113-76 through various guidance,
memoranda and interim policy notices. On June 27, 2014, the Office of the Chief
Financial Officer (OCFO) issued the Conference Spending Guide, condensing
EPA requirements into a single document.
The OCFO developed the conference spending tool to fulfill the requirements of
M-12-12. It is used for obtaining approval of conferences hosted or sponsored by
the EPA with net expenses of $20,000 or more. These conferences must be
approved by the relevant official prior to obligation of conference related
expenses. The EPA's Form 5170 is the designated form for obtaining conference
approvals from EPA senior officials and documents the estimated conference
costs. The primary EPA organization hosting or sponsoring the conference must
submit EPA Form 5170A within 91 calendar days of the conclusion of the
conference. This form updates the estimated conference information with the
actual expenses.
The EPA also established conference project codes for the purpose of tracking
conference expenses and to provide management with insight and timely data
analytics. Conference codes are required on all conference-related funding
documents to track and monitor conference spending.
Responsible Office
The Office of Financial Management within the EPA's OCFO manages and
implements conference policies and procedures on behalf of the Deputy
Administrator. Specifically, the Office of Financial Management:
•	Maintains a conference website with current policies and procedures.
•	Collects conference approvals.
•	Ensures conference packages have sufficient detail.
•	Assigns conference project codes.
•	Notifies EPA organizations of the requirement to report to the OIG within
15 calendar days of the conference.
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•	Collects actual conference data via EPA Form 5170A and follows up for
required approvals as appropriate.
•	Prepares an annual report for the Office of Management and Budget and
the public.
Noteworthy Achievements
The EPA has strengthened internal controls, and reported that costs for
conferences exceeding $100,000 have been reduced over the past 3 years from
FYs 2012 through 2014.
Scope and Methodology
We conducted this audit from October 2014 to October 2015 in accordance with
generally accepted government auditing standards, issued by the Comptroller
General of the United States. The standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objective. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objective.
To obtain an understanding of conference spending requirements, we reviewed
Office of Management and Budget Memorandum M-l 1-35, Memorandum to the
Heads of Executive Departments and Agencies, issued on September 21, 2011; as
well as Executive Order 13589, Public Law 113-76, M-12-12, Federal Travel
Regulations, and Federal Acquisition Regulations. Further, we reviewed EPA
policies, guidance and memoranda. We also reviewed conference audit reports
issued by other OIG offices and the U.S. Government Accountability Office.
To determine whether the EPA's internal controls and oversight of conferences
ensured expenses were appropriate and reported accurately, we selected a
stratified random sample of eight conferences held during the third and fourth
quarters of FY 2014. The sampled conferences each had reported costs over
$20,000 and totaled $985,851 of the $11,315,047 of the EPA's reported
conference costs (9 percent), as shown in Table 1.
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Table 1: Stratified random sample
Sampled conferences
Abbreviated
conference name
Reported actual costs
(EPA Form 5170A)
National Association of Remedial
NARPM
$407,229
Project Managers Annual Training
Program


National Forum on Contaminants in
Fish Forum
330,703
Fish


2014 US-Chin GHG MRV Technical
US-China
65,796
Capacity Building Workshop


Peer Review Division (PRD) - Peer
Review Panel Meeting (GRO
Undergraduate Fellowship 2014)
PRD Meeting
59,326
2014 River Rally
2014 River Rally
35,823
US EPA Water Technology Innovation
Cluster Leaders Meeting - September
28,2014
Water Technology
35,779
AgSTAR Workshop in conjunction with
BioCycle REFOR14
AgSTAR
29,591
Office of Policy Strategic Management
Meeting
OP Strategic
Meeting
21,604
Total

$985,851
Source: OIG random sample from universe supplied by OCFO.
We interviewed OCFO and program staff for each of the sampled conferences.
We determined whether conference costs were appropriate, accurate and reported
as required by analyzing data provided by the EPA and data we obtained from the
EPA's Compass Data Warehouse (CDW) and the conference spending tool.
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Chapter 2
Improvements Needed in EPA's
Conference Oversight
The EPA's internal controls over conference spending resulted in only two of
eight reviewed conferences with inappropriate costs totaling $6,916, or less than
1 percent of reviewed costs. Also, for three of eight conferences, the costs were
not categorized correctly on EPA Form 5170A. The cost categories on the form
do not closely align with how the contractor reports information on their invoices,
resulting in EPA staff estimating some cost categories. Addressing these issues
will result in more accurate tracking of the types of costs for conferences and
allow the EPA to better analyze and manage costs.
Federal Regulations and EPA Policy Establish Guidance
Federal agencies and employees must exercise discretion and judgment in
ensuring that conference expenses are appropriate, necessary and managed in a
manner that minimizes expenses. Federal regulations and EPA policies provide
details on the authority for various types of costs. For example, Federal Travel
Regulations detail what types of costs are allowable for travel. Federal
Acquisition Regulations provide uniform policies and procedures for government
acquisitions and may be applicable when the EPA uses contractors to assist with a
conference. To assist agencies in analyzing the fiscal, procurement and ethics
issues that often arise when planning or participating in a conference, the U.S.
Office of Government Ethics issued A Collection of Federal Resources Relating
to Conferences in September 2012.
Minor Improvements Needed
For two of the eight sampled conferences reviewed, we identified inappropriate
costs totaling $6,916. These inappropriate costs equate to 0.7 percent of the
$985,851 of costs reported for the eight sampled conferences, as shown in
Table 2.
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Table 2: Conferences with inappropriate costs for eight sampled conferences

Reported actual costs
Inappropriate
Percent of
Conference
(EPA Form 5170A)
cost
conference costs
NARPM
407,229
0
0
Fish Forum
$330,703
$4,114
1
US-China
65,796
0
0
PRD Meeting
59,326
2,802
5
2014 River Rally
35,823
0
0
Water Technology
35,779
0
0
AgSTAR
29,591
0
0
OP Strategic Meeting
21,604
0
0
Total
$985,851
$6,916
0.7
Source: OIG analysis of conference documentation and CDW data.
We defined inappropriate costs as costs that were either improper or
noncompliant with regulations. The inappropriate costs are attributed to incorrect
billing and unallowable travel costs. Specifically:
• The OIG notified the EPA that it was not clear how Fish Forum
conference costs were aggregated and reported on EPA Form 5170A from
submitted documentation. In response, EPA program management
performed a review of conference data and determined that five contractor
invoices should be revised. The EPA identified $4,134 of overpayments
and $20 of under payments ($4,
these improper payments.
• For the PRD Meeting, the EPA
paid unallowable travel costs
totaling $2,802 for non-federal
employees serving as peer
reviewers. Specifically, $603
relates to 17 of the 21 travelers
that were reimbursed 100
percent of the applicable meals
and incidental expense rates for
the first and last days of travel.
Per Federal Travel Regulation
§301-11.101(a), travelers are only allowed to be paid 75 percent of the
applicable meals and incidental expense rates on the first and last days of
travel. In addition, the EPA did not provide reasonable justification as to
why one traveler was reimbursed $2,199 for traveling by privately owned
vehicle for a 3,926-mile round trip when airfare would cost less. The EPA
concurred that it had an opportunity to save on travel costs and estimated
that this traveler would have had about $750 in costs for air fare, local
travel to and from both airports and airport parking. While we agree that
some travel expenses would have been incurred and paid, there is no way
of knowing how much would have been incurred if this traveler's
privately owned vehicle travel was handled differently.
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16-P-0081
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Categorization of Reported Costs Cannot Be Verified
For three of eight conferences, the EPA provided support for the reported
conference costs in total, but we were unable to verify the breakout of $141,865
(14 percent) of the costs among cost categories on EPA Form 5170A. While
reporting of some categorical costs is required by PL 113-76 (food and beverages,
audio visual and travel costs), the EPA requires additional cost categorization on
the form. Cost categories on the form also include: facility, conference planning
and facilitation/note taking. For some conferences, the EPA used contractors, and
their invoices did not always break out costs in the same categories as EPA Form
5170A. In those cases, the program offices did their best to divide contractor costs
among the different cost categories, but these costs were not always categorized
accurately. The breakout by conference of costs not properly categorized is shown
in Table 3.
Table 3: Expense categorization issues
Conference
Reported actual costs
(EPA Form 5170A)
Cost not properly
categorized
Fish Forum
$330,703
$102,033
PRD Meeting
59,326
14,532
AgSTAR
29,591
25,000
Total

$141,565
Source: OIG analysis of conference documentation and CDW data.
EPA Needs to Improve Oversight of Incurred Conference Costs
Although the EPA has provided conference spending guidance, the OCFO does
not ensure the accuracy of costs reported for the categories on EPA Form 5170A,
and relies on program offices for year-end certifications. As a result:
•	The program offices reported conference costs that were not accurate for
the cost categories on EPA Form 5170A. In two cases, program offices did
not always perform thorough reviews to ensure that costs are appropriate
to prevent waste and promote efficient spending of tax payer dollars.
•	The EPA constructed cost categories on EPA Form 5170A that do not
closely align with categories listed on contractor invoices. Because of this,
program offices had difficulty reporting information accurately. Program
office management stated that reconciling conference expenses when there
are differences in categories between the invoices and the form would be a
waste of resources. A program manager suggested the invoices and
categories on EPA Form 5170A should be standardized for ease of
reporting.
While we identified $6,916 in inappropriate costs, addressing issues relating to
the classification of types of costs, such as planning or audio visual, will provide
16-P-0081
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more accurate reporting. The EPA can then analyze the information to identify
areas for future efficiencies in conference spending.
(Left): Audio visual equipment and staff at Water Technology 2011. (Right): Audience at Water
Technology 2011. (EPA Photos)
Recommendations
We recommend that the Chief Financial Officer:
1.	Provide additional guidance or training on how to identify instances when
conference costs are unallowable.
2.	Work with program offices to identify EPA Form 5170A cost reporting
issues and revise the form to allow for easier user reporting.
Agency Response and OIG Evaluation
The EPA agreed with the recommendations and provided planned corrective
actions with milestone dates. In response to Recommendation 1, the OCFO will
provide training and update conference guidance. In response to
Recommendation 2, the OCFO will update the conference spending request form.
When implemented, the corrective actions should address Recommendations 1
and 2.
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Chapter 3
EPA Needs to Improve Tracking of Conference
Expenses in Its Financial System
The EPA underreported $20,470 (2 percent) of conference costs in the conference
spending tool for the eight reviewed conferences. The EPA requires the use of
conference project codes to track and monitor conference spending. However,
because of a lack of guidance, EPA staff did not always know how to ensure the
use of the conference code or identify all conference costs. The EPA cannot rely
on its financial system to identify all conference costs or on the conference
spending tool for reported costs.
Conference Expense Tracking Is Required
In accordance with M-l 1-35, agencies, as responsible stewards of taxpayer
dollars, must seize every opportunity to improve government performance and
management to save money and deliver a higher quality of service to the
American people. To meet the M-12-12 requirements, the EPA's Deputy
Administrator required conference expenses to be tracked. In October of 2013,
projects codes were established to track conference expenses to implement the
Deputy Administrator's requirement.
Conference Project Codes Are Not Always Used
The EPA did not always use its system of assigning conference project codes to
track and identify conference costs. According to OCFO staff, using the
conference code for all costs should allow the EPA to obtain all costs from the
financial system. Of the eight conferences sampled, one conference was approved
prior to implementation of the conference spending tool and was not assigned a
specific conference code. The remaining seven were assigned conference codes,
but these conference codes were not always used to track travel, procurement and
training-related costs. As a result, the assigned conference code could not be
relied upon to track all conference-related costs in the financial system.
Five of the seven conferences with assigned conference codes had EPA travelers.
However, the applicable conference code was not always used. Of the five
conferences with EPA travelers, the conference with the most travelers (over 200)
had only 1 percent of travelers that did not use the conference code. However, for
the remaining four conferences, which had less than 20 travelers, 25 to 100
percent of their travelers did not use the code. For one conference, no travelers
used the appropriate conference code. Because they attended more than one
conference during the period of travel, they did not include all applicable
16-P-0081
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conference codes. Table 4 identifies the lack of compliance with the requirement
to use the conference code for all EPA travel.
Table 4: Non-use of conference codes for EPA travel

Number of EPA
Travelers who did not

Conference
travelers
use conference code
Percent
NARPM
239
2
1
Fish Forum
7
4
57
2014 River Rally
14
5
36
Water Technology
6
6
100
AgSTAR
4
1
25
Total
270
18
7
Source: OIG analysis of conference documentation and CDW.
Three of the seven conferences used the assigned conference code to identify
some but not all of the procurement and training-related costs. The remaining four
conferences did not use the conference code to identify any such costs. Table 5
describes the extent of these costs that were not identified and tracked using the
conference code.
Table 5: Non-use of conference codes for procurement and training-related costs

Total procurement
and training-
Identified using
the conference
Percent
Conference
related costs
code
without codes
NARPM
$88,966
$40,000
55
Fish Forum
319,157
0
100
PRD Meeting
59,326
44,794
24
2014 River Rally
24,190
8,165
66
Water Technology
29,599
0
100
AgSTAR
25,000
0
100
OP Strategic Meeting
23,839
0
100
Total
$570,077
$92,959
84
Source: OIG analysis of conference documentation and CDW.
Additional Guidance Needed to Identify Conference Costs
The OCFO did not provide clear-cut guidance for ensuring all conference travel,
contract and training-related costs are identified and coded properly in its financial
system. Because of this lack of guidance, program staff did not always understand
the requirement to include all travel costs and included just the travel costs of the
program office that hosted the conference. EPA travelers need to be reminded to
include correct conference project codes on travel documents so that travel costs
associated with conferences can be identified through the financial system. EPA
guidance can also be improved in regard to how program offices can use the
conference codes to identify procurement and training-related costs associated with
specific conferences. OCFO needs to provide program staff with tools and training
to assist in identifying conference costs when the conference code is not used.
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Unidentified Costs Resulted in Underreported Conference Cost Data
The lack of clear guidance to ensure use of the conference code and inclusion of
all conference costs resulted in underreporting the cost of four of eight
conferences reviewed by $20,470, as shown in Table 6.
Table 6: Conferences with underreported costs

Total costs



reported
Underreported
Percentage
Conference
(Table 1)
costs
underreported
2014 River Rally
$35,823
$16,050
45
Water Technology
35,779
358
1
AgSTAR
29,591
1,827
6
OP Strategic Meeting
21,604
2,235
10
Total for eight conferences
$985,851
$20,470
2
Source: OIG analysis of conference documentation and CDW data.
Recent Agency Actions Prompted by OIG Work
On May 27, 2015, OCFO's Office of Financial Management hosted two training
sessions on conferences. The purpose of the sessions was to provide refresher
training for the agency's conference community; clarify policy, guidance, and
current statutes; and provide a demonstration of the conference spending tool's
enhancements. The training session also addressed issues raised by the OIG
during this audit.
Recommendation
We recommend that the Chief Financial Officer:
3. Provide additional guidance or training to EPA staff on how to:
a.	Include conference project codes on procurement and training-
related costs entered into the financial system.
b.	Code conference travel authorizations with the correct conference
project code.
c.	Identify all costs associated with a conference in the financial
system.
d.	Report all conference costs paid with EPA funds, not just those paid
by the reporting office.
Agency Response and OIG Evaluation
The EPA agreed with the recommendation and provided planned corrective
actions with milestone dates. In response to Recommendation 3, the EPA
included four corrective actions. These corrective actions include:
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•	Implementing a process/policy to ensure that procurements will utilize
conference project codes.
•	Working with the Funds Control Officer community to ensure travelers
use the correct conference code on vouchers.
•	Emphasizing the need to identify all costs in the financial system.
•	Implementing enhancements to facilitate the reporting of all conference
costs. (Completed May 2015)
When all of these corrective actions are implemented, they should address
Recommendation 3.
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Chapter 4
EPA's Conference Reporting Needs Improvement
The EPA did not comply with some reporting requirements for FY 2014
conferences. Two conferences with reported costs totaling $350,782 were not
reported publicly. Also, 64 percent of the EPA's conferences were either reported
late or not reported to the OIG. M-12-12 and PL 113-76 require agencies to report
conference-related expenses. The EPA was not in compliance because OCFO was
not conducting oversight activities to ensure (1) program offices fully understand
the distinction between different types of conferences and (2) compliance with the
15 day reporting requirement. The EPA's noncompliance with conference
reporting requirements results in a lack of transparency. The EPA has since
instituted corrective actions to reduce the risk of late and missing reports.
EPA Required to Report on Conference Spending
Federal policy and public law require agencies to report on conference spending:
•	M-12-12 requires agencies to publicly report agency-sponsored
conferences with costs in excess of $100,000.
•	PL 113-76 requires the head of any executive branch department, agency,
board, commission or office funded by the applicable public law for
FY 2014 to submit reports to the OIG on conferences held by the agency.
It requires:
o On an annual basis, report cost details (food and beverages, audio
visual services, and employee and contractor travel) and
contracting procedures related to each conference when costs to
the government exceed $100,000.
o For conferences with government costs of more than $20,000,
reports are to be submitted to the OIG within 15 days of the date of
the conference with the date, location and number of attending
employees.
The EPA provides guidance on the different classifications of conferences in its
Conference Spending Guide. It states that the EPA is the host if the agency was
the primary convener of the event and provider of funding. The EPA is the
sponsor of a conference if the agency provided funding, tangible support (i.e.,
financial assistance, material goods or services); or appeared as a sponsor on any
event materials. The EPA is a co-sponsor if the agency shares in decisions,
including agenda planning, speaker selection and logistics. The Conference
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Spending Guide does not define instances when the EPA would be considered an
attendee of a conference.
EPA Did Not Always Comply With Reporting Requirements
The EPA did not always comply with reporting requirements. The EPA did not
publicly report two conferences with $350,782 in conference costs as required. The
EPA erroneously classified the conferences as attended instead of sponsored.
Conferences classified as attended are not reported publicly or to the OIG. Based
upon the EPA's Conference Spending Guide and further clarifying information
from the OCFO, these conferences should have been classified as sponsored in the
conference spending tool and reported publicly.
•	The EPA had direct involvement in the development of 11 sessions at the
Water Environment Federation Annual Technical Exhibition and
Conference (WEFTEC), funded on site contractor support, and provided
technical expertise. The development of the sessions and use of the EPA's
technical contractor were done in conjunction with the Water Environment
Federation's co-sponsorship agreement. The EPA also used its technical
contractor to provide support in the form of note taking and shared those
notes with the Water Environment Federation. The EPA incurred $253,846
in conference expenses for the WEFTEC meeting.
•	The EPA incurred $114,936 in conference expenses for the 9th National
Water Monitoring Conference. The EPA entered into a contract for
conference planning services including support for agenda development and
logistics.
We found that 145 of the 227 FY 2014 conferences (64 percent) that should have
been reported to the OIG were reported late or not reported. Of the 227
conferences, 96 (42 percent) were reported after the 15-day deadline and 49
(22 percent) were not reported to the OIG. Of the eight conferences in our sample,
three were reported timely, three were reported late, and two were not reported, as
shown in Table 7.
Table 7: Conference reporting to OIG
Conference
Conference dates
Date reported to OIG
Timely?
NARPM
06/16-06/20/2014
06/25/2014
Yes
Fish Forum
09/22 - 09/24/2014
03/31/2015
No
US-China
07/22 - 07/23/2014
11/05/2014
No
PRD Meeting
07/29- 07/31/2014
05/01/2014
Yes a
2014 River Rally
05/30 - 06/02/2014
Not reported
No
Water Technology
09/28/2014
Not reported
No
AgSTAR
04/07- 04/10/2014
5/13/2014
No
OP Strategic Meeting
09/16- 09/17/2014
09/25/2014
Yes
Source: OIG analysis of conference documentation,
a This conference was reported early.
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Additional Oversight and Guidance Needed to Improve Reporting
Lack of EPA oversight resulted in noncompliance with conference reporting
requirements. OCFO is the responsible office for conference reporting. OCFO's
quality assurance process depends on the program offices to report timely and
accurately. OCFO relies on the program offices for year-end certifications of
conference expenses. This reliance results in noncompliance with reporting
requirements. Program office errors included:
•	Program offices misinterpreting the definition of hosted, sponsored and
attended conferences. This led to the inaccurate classification for two
conferences with expenses in excess of $100,000 that should have been
reported publicly.
•	Program offices not ensuring that all conferences with stated expenses in
excess of $20,000 were reported to the OIG within 15 days of the
conference because OCFO time and resources to send out manual reminders
was cost prohibitive. Initially OCFO sent out reminders to the program
offices regarding specific conferences, but later discontinued this practice.
Noncompliance Leads to Lack of Transparency
The EPA's noncompliance with M-12-12 and PL 113-76 resulted in a lack of
transparency regarding conference spending. The public and the OIG are not fully
informed of conferences and the appropriated funds expended on those
conferences. Public knowledge of conference spending increases scrutiny and helps
to ensure taxpayer funds are spent efficiently, effectively and appropriately.
Recent Agency Actions Prompted by OIG Work
In March 2015, the OCFO instituted a function within the conference spending
tool to help reduce the occurrences of late or missing reports. Notices are to be
automatically sent to the program offices regarding the requirement to report
hosted or sponsored conferences over $20,000 to the OIG 10 days after the
conference end date and daily thereafter until a report is submitted within the
conference spending tool. The program offices generate the 15-day notification
report from within the conference spending tool certifying that the information
reported to the OIG is accurate. On May 13, 2015, the OCFO team indicated that
the reporting application was fully operational.
Recommendation
We recommend that the Chief Financial Officer:
4. Provide additional guidance or training on how to classify conferences
based upon definitions in the EPA's Conference Spending Guide.
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Agency Response and OIG Evaluation
The EPA agreed with the recommendation and provided a planned corrective
action with a milestone date. The EPA has agreed to revise the sponsor definition
in the EPA's Conference Spending Guide to provide more specificity and clarity.
When implemented, the corrective actions should address Recommendation 4.
The EPA did not agree with the OIG's interpretation that the agency was a
sponsor for WEFTEC in 2014. The EPA stated that it was not a sponsor of the
WEFTEC conference because the EPA did not provide funding and was not
shown in the sponsor section of WEFTEC materials. The OIG stands by its
interpretation that EPA was a sponsor based on OCFO's conference spending
guide definition. The definition states that the EPA is a sponsor of an event if the
agency provided funding or tangible support to a conference or appeared as a
sponsor on any event materials, and tangible support is the provision of financial
assistance, material goods or services. The EPA participated in WEFTEC's 11
Technology Innovation Blueprint sessions and the program noted that "EPA and
WEF are convening working sessions throughout WEFTEC." We note that the
EPA had direct involvement in the development of those sessions and provided
technical expertise. Therefore, the EPA was a sponsor by its own definition.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
No.
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Ag reed-To
Amount
8 Provide additional guidance or training on how to 0
identify instances when conference costs are
unallowable.
8 Work with program offices to identify EPA Form 0
5170A cost reporting issues and revise the form to
allow for easier user reporting.
11 Provide additional guidance or training to EPA staff 0
on how to:
a.	Include conference project codes on
procurement and training-related costs
entered into the financial system.
b.	Code conference travel authorizations with
the correct conference project code.
c.	Identify all costs associated with a
conference in the financial system.
d.	Report all conference costs paid with EPA
funds, not just those paid by the reporting
office.
15 Provide additional guidance or training on how to 0
classify conferences based upon definitions in the
EPA's Conference Spending Guide.
Chief Financial Officer
Chief Financial Officer
Chief Financial Officer
2/29/16
3/31/16
6/30/16
$6.9
Chief Financial Officer
2/29/16
1 0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Draft Report
November 13, 2015
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Audit Report No. OA-FY14-0381,
"EPA's Tracking and Reporting of Its Conference Costs Need Improvement"
dated October 13, 2015
FROM: David A. Bloom /Signed/
Deputy Chief Financial Officer
TO:	Michael Petscavage, Director
Contract and Assistance Agreement Audits
Thank you for the opportunity to respond to the issues and recommendations in the subject draft
audit report. Following is a summary of the agency's overall position, along with its position on
each of the report recommendations. We have provided high-level intended corrective actions
and estimated completion dates. We have also attached technical comments which explains the
agency's position on Chapter 4, "EPA's Conference Reporting Needs Improvement."
AGENCY'S OVERALL POSITION
The agency concurs with all of the draft report recommendations.
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
by Quarter and FY
1
Provide additional guidance
or training on how to
identify instances when
conference costs are
unallowable.
OCFO will continue to offer as
needed ad-hoc training and
annual refresher training. OCFO
is currently updating the
Conference Guidance.
February 29, 2016
2
Work with program offices
to identify EPA Form
5170A cost reporting issues
and revise the form to allow
for easier user reporting.
OCFO is currently working with
OTS to implement updates to
the Conference Spending
Request Form. These updates
should enhance cost accounting
efforts and make the form more
user friendly.
March 31, 2016
3
Provide additional guidance
or training to EPA staff on
how to:


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a. Include conference
project codes on
procurement and training
related costs entered into the
financial system.
b. Code conference travel
authorizations with the
correct conference project
code.
c. Identify all costs
associated with a conference
in the financial system.
d. Report all conference
costs paid with EPA funds,
not just those paid by the
reporting office.	
a.	OCFO will collaborate with
the Office Administration and
Resources Management to
implement a process/policy for
users to ensure procurements
will utilize the conference
project codes.
b.	OCFO will continue to work
with the Funds Control Officer
community to ensure travelers
use the correct conference code
on vouchers.
c. OCFO will continue to
emphasize the need to identify
all costs associated with a
conference in the financial
system.
d. OCFO has implemented
enhancements to facilitate the
reporting of all conference costs
paid with EPA funds.	
a. June 30, 2016
b.	Complete. Provided
agency wide and FCO
training (May 2015;
November 2015). Will
continue to provide as
needed.
c.	Complete. Provided
agency wide and FCO
training (May 2015;
November 2015). Will
continue to provide as
needed.
d.	Completed May 2015
Provide additional guidance
or training on how to
classify conferences based
upon definitions in the
EPA's Conference Spending
Guide.
OCFO will provide additional
guidance on how to classify
conferences in future ad-
hoc/annual training and in
revised Conference Guidance.
February 29, 2016
CONTACT INFORMATION
If you have any questions regarding this response, please contact Stefan Silzer at (202) 564-
4905.
Attachment
cc: Howard Osborne
Kevin Christensen
Richard Eyermann
Stefan Silzer
John Showman
Meshell Jones-Peeler
Madeline Mullen
Jill Beresford
Donald Giamporcaro
Nikki Wood
Brandon McDowell
Lorna Washington
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Eileen Collins
Janet Kasper
Mona Mafi
Nicole Pilate
Dale Miller
Attachment
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Response to Office of Inspector General Draft Audit Report No. OA-FY14-0381, "EPA's
Tracking and Reporting of Its Conference Costs Need Improvement" dated October 13,
2015
OIG Finding/Issue - Chapter 4 "EPA 's Conference Reporting Needs Improvementpage 13
section titled. "EPA Did Not Always Comply with Reporting Requirements"
OIG Statement: "The EPA had direct involvement in the development of 11 sessions at the
Water Environment Federation Annual Technical Exhibition and Conference (WEFTEC),
funded on site contractor support, and provided technical expertise. The development of the
sessions and use of the EPA's technical contractor were done in conjunction with the Water
Environment Federation's co-sponsorship agreement. The EPA also used its technical
contractor to provide support in the form of note taking and shared those notes with the Water
Environment Federation. The EPA incurred $253,846 in conference expenses for the
WEFTEC meeting."
Agency Position: The EPA has agreed to revise the sponsor definition in the Conference
Spending Guide to provide more specificity and clarity; however, we disagree with the OIG's
interpretation that the agency was a sponsor for the Water Environment Federation Annual
Technical Exhibition and Conference in 2014. WEFTEC is an annual conference centered on
water quality and is trademarked as "the water quality event." The Water Environment
Federation has hosted this conference for more than 80 years and the WEFTEC 2014 included
31 day-long workshops, more than 1,000 presentations, 70 poster sessions, hundreds of
committee meetings and other forums, an "Operations Challenge" with 42 competing teams,
and an exhibition with 1,027 exhibitors covering over 300,000 square feet of exhibit space.
More than 20,000 people attended WEFTEC 2014.
•	The WEFTEC Program explicitly identifies the sponsors at a variety of levels: President
Club, Corporate Sponsors, Diamond, Platinum, Gold, Partner, and Supporting. These are
shown on pages 35, 50, and 51 of the WEFTEC Program. The EPA is not a sponsor and is
not shown as a sponsor in the WEFTEC program, materials and displays.
•	The EPA provided no funding to WEF in support of a sponsorship of WEFTEC.
•	The EPA did not pay WEF or WEFTEC for any line items reported, excluding training.
All line items, such as the audio visual equipment, facility costs, and supplies, were paid
to the facility (in 2014, the New Orleans Memorial Convention Center) and its contractors
to support EPA's exhibition booth. Training costs reported were WEFTEC 2014
registration costs for EPA attendees.
Page 26 of the 208 page WEFTEC Program describes a series of eleven 30-90 minute long
working sessions to discuss the EPA's Technology Innovation Blueprint (issued by
Administrator Gina McCarthy in April 2014) and ways the entire water community can foster
technology, innovation, and sustainability. These eleven sessions were a new venue for WEF
to exemplify its commitment to innovation outlined in WEF's strategic direction. All
Blueprint sessions were open to all WEFTEC attendees. Given EPA's ownership of the
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Technology Innovation Blueprint, WEF wanted EPA's participation in the planning of these
sessions and to use the EPA logo in the program promoting these sessions. The Office of
Water consulted with EPA's Office of General Counsel on whether and how this collaboration
should be coordinated and documented. OGC agreed that the relative roles of WEF and EPA
should be framed and memorialized. OGC confirmed that a "co-sponsorship agreement,"
consistent with EPA Ethics Advisory 96-15 (August 17, 1996), was the ideal means of
accomplishing this partnership for these discussions. The fact that a "co-sponsorship
agreement" was used as the means to lay out roles for this extremely small venue at WEFTEC
does not constitute a sponsorship of WEFTEC. The agreement was simply the best means to
enunciate the terms of coordination between WEF and EPA and to satisfy an ethics
responsibility. Again, this cooperation does not constitute sponsorship of WEFTEC 2014. The
EPA utilized two contract vehicles in support of EPA's attendance at WEFTEC 2014.
•	The conference planning contract was used solely to support EPA's outreach to the
attendees of WEFTEC through the EPA booth space in the exhibit hall of the conference.
Contract support for the EPA booth involved, but was not limited to, coordinating
shipment of the booth and materials from the EPA Warehouse to the exhibition facility,
arranging assembly and break down of the physical booth with the onsite labor company,
placing orders for CPU and floral rentals with the facility, scheduling preshow vacuuming
with the facility, and coordinating connections for electricity and internet. All items paid
for by EPA through the conference planning contract were for the use of the EPA
exhibition space only. All exhibitors at WEFTEC operate in the same manner. Payments
were made to the facility itself (in 2014, the New Orleans Memorial Convention Center)
and the facility's contractors, not to WEF or WEFTEC.
•	The Office of Water also used one of its technical support contractors through an existing
contract work assignment to support EPA's design, planning, and execution of the "EPA
Water Technology Innovation Blueprint Series." The costs associated with this contractor
support were reported under "Facilitation and Note Taking Contracts." While the
contractor did not provide any facilitation, the contractor did serve as "note taker" for the
sessions, per the "co-sponsorship agreement." The EPA contractor also assisted the EPA
staff in collecting information from WEFTEC attendees about the EPA's Blueprint
including information and dialogues at the eleven discussion sessions. The contractor's
summary of the discussions will greatly benefit the EPA as it moves forward with
implementation of the EPA Blueprint and the commitment to promoting technology
innovation. As part of the partnership with WEF, the EPA made the contractor's summary
available to WEF to better guide the EPA's future collaboration with WEF with regards to
promoting technology innovation in the water sector, consistent with the EPA-WEF
agreement supported and approved by the EPA's Office of General Counsel.
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Appendix B
Distribution
Office of the Administrator
Chief Financial Officer
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Assistant Deputy Chief Financial Officer
Director, Office of Financial Management, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
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