EPA Did Not Conduct Agencywide Risk Assessment of CARES Act Appropriations, Increasing Risk of Fraud, Waste, Abuse, and Mismanagement


OFFICE OF INSPECTOR GENERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY

May 4, 2021
Report No. 21 E 0128
EPA Did Not Conduct Agencywide Risk Assessment
of CARES Act Appropriations, Increasing Risk of Fraud, Waste,
Abuse, and Mismanagement
EPA OIG's response to the
COVID-19 pandemic
Source: Centers for Disease Control and
Prevention image.
Evaluation Purpose:
Document and assess the internal
controls that the EPA implemented to
mitigate risks of fraud, waste, abuse,
and mismanagement over the CARES
Act appropriations.
This evaluation addresses the
following:
•	Compliance with the law,
•	Operating efficiently and effectively.
This evaluation addresses these top
EPA management challenges:
•	Maintaining operations during
pandemic responses,
•	Complying with key internal control
requirements (risk assessments).
•	Fulfilling mandated reporting
requirements.
Address inquiries to our public affairs
office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.aov.
Full list of EPA OIG reports.
Why We Did This Evaluation
In response to the coronavirus pandemic—that is, the SARS-CoV-2 virus
and resultant COVID-19 disease—the Office of Inspector General for the
U.S. Environmental Protection Agency initiated an evaluation under
Project No. OA&E-FY2Q-Q234 of the Agency's internal controls for the
emergency supplemental appropriations provided to the EPA in the
Coronavirus Aid,, Relief, and Economic Security Act, known as the CARES
Act. The objectives of this evaluation were to document and assess the
internal controls that the EPA implemented to mitigate risks of fraud,
waste, abuse, and mismanagement over the CARES Act appropriations.
Background
In March 2020, the Agency was appropriated $7.23 million in
supplemental funds to "prevent, prepare for, and respond to
coronavirus, domestically or internationally." All Agency CARES Act
funds expire on September 30, 2021. As of March 31, 2021, the EPA had
$2.81 million (38.9 percent) of unspent CARES Act funds. Funds were
allocated to three EPA program offices (Table 1), and all appropriations
were designated as an "emergency requirement" under the Balanced
Budget and Emergency Deficit Control Act of 1985.
Table 1: Allocation of CARES Act appropriations
CARES Act funding
requirements
Appropriation
(millions)
Responsible
program office
Researching methods to reduce
the risks from environmental
transmission of coronavirus via
contaminated surfaces or materials
$1.50
Office of Research
and Development
Expediting registration and other
actions related to pesticides to
address coronavirus
1.50
Office of Chemical
Safety and Pollution
Prevention
Cleaning and disinfecting EPA
equipment and facilities®
4.23
Office of Mission
Support
TOTAL
$7.23
Source: OIG analysis of Agency data. (EPA OIG table)
a Includes operational continuity of EPA programs and related activities.
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1

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EPA's CARES Act funding
total CARES Act
appropriations
Research.
Pesticide registration and other
actions.
Cleaning and disinfecting EPA
facilities and equipment.
Source: OIG analysis of EPA information.
(EPA OIG image)
Interdependence of federal internal
control requirements
Source: OIG analysis. (EPA OIG image)
*Federal Managers' Financial Integrity Act.
"""Resource Management Directive
System.
Guidance for Supplemental Funding
On April 10, 2020, the Office of Management and Budget issued
Memorandum M-20-21, Implementation Guidance for Supplemental
Funding Provided in Response to the Coronavirus Disease 2019 (COVID-
19). This guidance highlights the importance of rapidly spending funds
while requiring transparency and regular reporting for accountability
purposes and safeguarding taxpayer dollars. Agencies receiving these
supplemental funds are reminded that they must review progress as part
of their performance, evidence-building, and enterprise risk management
responsibilities to the maximum extent possible, consistent with guidance
included in OMB Circular A-ll, Preparation, Submission and Execution of
the Budget, and OMB Circular A-123, Management's Responsibility for
Enterprise Risk Management and Internal Control.
Reporting on Use of CARES Act Funds
The Agency is required to report to the OMB any obligations and
expenditures on a monthly basis, per Section 15011(b)(1)(A) of the
CARES Act. Section 15011(b)(1)(B) requires the Agency to submit a plan
describing how the funds will be used to the Pandemic Response
Accountability Committee, an independent oversight committee within
the Council of the Inspectors General on Integrity and Efficiency, within
90 days of the March 27, 2020 enactment.
Federal Internal Control Requirements
The Federal Managers' Financial Integrity Act of 1982 requires each
executive federal agency to establish an internal control system that
provides reasonable assurance of achieving three objectives:
(1) obligations and costs comply with applicable law; (2) funds, property,
and other assets are safeguarded against waste, loss, unauthorized use,
or misappropriation; and (3) revenues and expenditures applicable to
agency operations are properly recorded and accounted for to permit
the preparation of accounts and reliable financial and statistical reports
and to maintain accountability over the asset.
On July 15, 2016, OMB Circular A-123 modernized the Federal
Managers' Financial Integrity Act's requirements by integrating risk
management and agency internal control systems in an Enterprise Risk
Management framework. The circular establishes specific requirements
for federal agencies to assess and implement internal controls for
identified risks. It also provides guidance for addressing risk at the
strategic level and defines management's responsibilities for the ERM
process to integrate and coordinate internal control assessments.
Further, OMB Circular A-123 documentation processes require an audit
trail and verifiable results, as well as specify documentation retention
periods so that anyone can understand the risk assessment process.
The U.S. Government Accountability Office's Standards for Internal
Control in the Federal Government, known as the Green Book, serves as
the framework for federal agencies to develop, implement, and operate
21-E-0128
•FMFIA
OMB
Circular
A 123
EPA
*RMDS
2520
Policy

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Responsible program offices:
•	The Office of the Chief Financial
Officer at the agencywide entity
level.
•	The Office of Mission Support at
the cross-program entity level.
•	The Office of Research and
Development at the division level.
•	The Office of Chemical Safety and
Pollution Prevention at the division
level.
The OIG assessed whether the
EPA acted consistently with the:
•	CARES Act.
•	Federal Managers' Financial
Integrity Act.
•	OMB Circular A-123.
•	GAO Green Book.
•	OCFO's Resource Management
Directives System Policy Manual
2520, Administrative Control of
Appropriated and Other Funds.
CARES Act funds are high risk
The Pandemic Response Accountability
Committee's June 2020 report, Top
Challenges Facing Federal Agencies:
COVID-19 Emergency Relief and
Response Efforts, identified the CARES
Act appropriations to be high risk for
fraud, waste, abuse, and
mismanagement governmentwide. The
report also identified various challenges
that the EPA faces in implementing the
CARES Act, including preexisting
organizational risks in its programs and
operations and maintaining a safe and
productive work force.
an effective internal control system. The GAO Green Book identifies five
major components and underlying principles that are relevant for an
effective internal control system. Through the implementation of Green
Book standards, federal agencies will have the ability to comply with
OMB Circular-123 assessment and reporting requirements.
The OCFO's Resource Management Directives System Policy
Manual 2520, Administrative Control of Appropriated and Other Funds
(effective December 2015), implements OMB Circular A-123. The policy
manual provides guidance to Agency managers on using a variety of
tools to achieve desired program results and meeting the requirements
of the Federal Managers' Financial Integrity Act. It also details what is
classified as a supplemental appropriation and the EPA's processes for
risk management and internal controls, based on OMB Circular A-123.
The EPA policy manual identifies the EPA's fund control principles, as
well as the policies and procedures that apply to all program offices.
The Federal Managers' Financial Integrity Act, OMB Circular A-123, GAO
Green Book, and the EPA policy manual together emphasize the risk
assessment process, both financial and operational, for all levels of the
organization. Appendix A of OMB Circular A-123 states, "ERM includes
strategic, operations, reporting, and compliance objectives, and is an
effective agency-wide approach to addressing the full spectrum of
significant risks by understanding the combined impact of risks as an
interrelated portfolio, rather than addressing risks only within silos."
Levels of Organizational Structure
The GAO Green Book identifies the four levels of a federal agency that
are responsible for internal control implementation. The OCFO and the
Office of Mission Support established language that bridges the Agency's
structural hierarchy and the GAO Green Book levels of organizational
structure (Table 2).
Table 2: GAO Green Book internal control organizational hierarchy
Levels of organizational structure
Entity	EPA administrator or national program office delegated entity
level duties. Agencywide controls that influence the entire
organization (executive level), such as budget and human
resources.
Division	National program office. An organization within the Agency
that has national policy oversight responsibilities that is
focused on a particular mission, such as Air, Water, Land,
and Enforcement.
Program or regional office. An organization within the division
that has overall responsibility for managing a program and is
responsible for implementing national policy.
Program or regional office. Activity performed by a program or
regional office, such as local facilities' management, regional
tribal programs, purchase cards, grant and contract
management, and records management.
Source: OIG summary of GAO Green Book and EPA organizational information.
(EPA OIG table)
Operating unit
Function
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Office of the Chief Financial Officer
Entity Level (agencywide)
Lack of oversight by not conducting a risk
assessment.
Office of Mission Support
Entity Level (cross-program)
Completed a risk assessment and established
internal controls.
Office of Research
and Development
Division Level
(program specific)
Completed a risk
assessment and
established internal
controls.
Office of Chemical
Safety and Pollution
Prevention
Division Level
(program specific)
Completed a risk
assessment and
established internal
controls.
Source: OIG analysis of EPA information.
(EPA OIG image)
Responsible Offices
The OCFO, the Office of Mission Support, the Office of Research and
Development, and the Office of Chemical Safety and Pollution
Prevention are responsible for the issues discussed in this report.
Scope and Methodolo
See Appendix A for a description of our scope and methodology in
conducting this evaluation.
What We Found
Our evaluation of the EPA's CARES Act appropriations determined that
the Agency did not fully comply with federal laws, OMB Circular A-123,
and the GAO Green Book. Specifically, the OCFO, which is responsible
for agencywide ERM and internal controls, does not have processes to
develop, communicate, and mitigate any entity-level risks through
implementation of internal controls related to the CARES Act
supplemental appropriations. The OCFO stated that it manages the ERM
and internal control process but that the individual program offices are
responsible for designing, implementing, and monitoring internal
controls.
The OCFO did not conduct an agencywide risk assessment of internal
controls for the CARES Act's supplemental appropriations or document
its rationale for relying on the internal control risk assessments
conducted by the program offices at the division level. Instead, the
OCFO followed the procedures identified in Resource Management
Directive System 2520, which has not been updated to reflect the
July 2016 OMB Circular A-123's ERM requirements. Therefore, the
Agency's approach did not incorporate OMB Circular A-123 ERM
requirements and the GAO Green Book entity-level internal control
requirements.
There is no process in place at the entity level to perform risk
assessments on supplemental appropriations, which increases the risk
of fraud, waste, abuse, and mismanagement. As a result, program
offices in the Office of Mission Support (at the cross-program entity
level), the Office of Research and Development (at the division level),
and the Office of Chemical Safety and Pollution Prevention (at the
division level) designed internal controls to identify and mitigate fraud,
waste, abuse, and mismanagement regarding the CARES Act's funds.
OCFO Did Not Conduct Agencywide Risk Assessment
Despite OMB Circular A-123 and GAO Green Book requirements, the
OCFO did not conduct an agencywide risk assessment of CARES Act
funding to identify risks that could impact the success of CARES Act
objectives. By not having processes in place to conduct agencywide risk
assessments on a high-risk emergency supplemental appropriation, the
risk of fraud, waste, abuse, and mismanagement increases due to the
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Results of evaluation:
•	The OCFO does not have processes
in place to conduct an agencywide
risk assessment on supplemental
appropriations, which is a
significant oversight.
•	The OCFO did not comply with
CARES Act reporting requirements.
•	The Office of Mission Support, the
Office of Research and
Development, and the Office of
Chemical Safety and Pollution
Prevention complied with federal
and external Agency requirements.
Missed reporting deadline
The Agency missed the 90-day
congressionally mandated reporting
requirement on CARES Act spending, which
was due June 25, 2020.
June 2020





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Source: OIG summary of EPA data.
(EPA OIG image)
lack of consideration of internal controls. OMB Circular A-123 requires
an integrated approach to ERM because the silo approach does not
consider the combined impact of program office risks. Instead, the
OCFO relied on the individual program offices that received CARES Act
funds to conduct an internal control risk assessment of only their own
program's objectives. By not performing an agencywide risk assessment,
internal cross-division control gaps could not be identified.
For example, the OCFO did not identify any cross-divisional risks, even
though the CARES Act contained three separate supplemental
appropriations for cleaning and disinfecting EPA facilities, and each
location could have different logistical considerations and requirements
for using the funding. Without assessing risk for the use of these funds
across its various program offices and physical locations, the Agency
cannot be sure it is maximizing the use of these funds.
OCFO Did Not Comply with CARES Act Reporting Requirements
The CARES Act has specific statutory reporting requirements, including
reporting to the OMB any obligations and expenditures on a monthly
basis and submitting a plan to the Pandemic Response Accountability
Committee on the Agency's use of the appropriated funds within
90 days after the Act was passed. The OCFO has been providing the
OMB with monthly funds reports. Because the OCFO does not have a
process in place to conduct an agencywide risk assessment and
because division-level program offices are not responsible for
interpreting fiscal legislation, the Agency missed the 90-day reporting
requirement, which was due on June 25, 2020. The OCFO said missing
the statutory requirement was "an oversight." The Pandemic Response
Accountability Committee notified the OCFO on July 29, 2020, that it
missed the statutory deadline. The OCFO sent the required plan on
July 31, 2020.
Three Program Offices Complied with Federal and Agency
Requirements
We found that, at the cross-program entity level and the division levels,
the Office of Mission Support, the Office of Research and Development,
and the Office of Chemical Safety and Pollution Prevention completed
risk assessments and established internal controls. Upon notification of
the CARES Act supplemental appropriations, each of the key program
offices conducted a risk assessment related to its program objectives. By
designing, implementing, and monitoring the effectiveness of the
internal controls, the three offices are in compliance with OMB
Circular A-123 and the GAO Green Book.
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CARES Act fund availability
38.9%
61.1%
¦ Expended, obligated, and coininitted
funds ($4.41 million).
Available uncommitted CARES Act funds
[$2.31).
Source: OIG analysis of EPA information.
(EPA OIG image)
Conclusions
The OCFO is responsible for interpreting fiscal legislation, leading and
managing compliance with OMB Circular A-123, and conducting
agencywide risk assessments for all appropriations. Risk assessment
should drive internal control activities and monitor their effectiveness.
The OCFO delegated all CARES Act risk assessment and internal control
development to the lower levels of the EPA without documenting how
the cross-program entity-level and division-level internal controls
address federal and Agency requirements. While the risk assessment
can be delegated, the entity-level organization must document its
determination that the established controls are sufficient to assure
compliance with federal and Agency requirements. With 38.9 percent of
its supplemental appropriations still available, it is important that the
Agency take steps to manage risks and maximize the use of its CARES
Act funds.
Recommendations
We recommend that the chief financial officer:
1.	Perform a risk assessment for the Coronavirus Aid, Relief, and
Economic Security Act supplemental appropriations at the entity
level. Based upon the results of the risk assessment, either
(a) design, implement, and monitor mitigating agencywide
internal controls or (b) document that the existing controls at
the cross-program entity and division levels are sufficient to
assure compliance with federal and Agency requirements.
2.	Revise Resource Management Directives System Policy
Manual 2520, Administrative Control of Appropriated and Other
Funds, to require the Office of the Chief Financial Officer to
perform and document risk assessments of emergency
supplemental appropriations (a) when these funds are received
and (b) if there is a subsequent change in the level of risk(s) in
order to design, implement, and monitor internal controls for
these inherently high-risk funds. In cases where the Agency
determines that an entity-level risk assessment is not necessary,
document how the other program offices' internal controls will
mitigate agencywide risks.
Agency Comments and OIG Assessment
The OCFO provided its initial response to the draft report on January 29,
2021, in which it nonconcurred with the two recommendations. During
a subsequent meeting to discuss the draft report and the Agency
response, the OIG clarified the intent of the recommendations and
agreed to modify specific language in the draft report, based upon the
OCFO's technical comments. The OCFO provided a revised response on
March 29, 2021, which is in Appendix B.
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The Agency's response to our recommendations and our assessment is
as follows:
1.	For Recommendation 1, the Agency asserted that it completed
the corrective actions in June 2020. However, during our
fieldwork, and in response to the draft report, the Agency did
not provide records to support its conclusion that it conducted
these actions in June 2020 or after. Recommendation 1 is
unresolved with resolution efforts in progress.
2.	For Recommendation 2, the Agency stated that it would update
the Resource Management Directive System 2520
requirements to perform entity-level risk assessments of
emergency supplemental appropriations and document the
results of these assessments by September 30, 2021. We
consider this recommendation resolved with corrective actions
pending.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Potential
Planned Monetary
Rec. Page Completion Benefits
No. No. Subject Status1 Action Official Date (In $000s)
1 6 Perform a risk assessment for the Coronavirus Aid, Relief, and U Chief Financial Officer
Economic Security Act supplemental appropriations at the entity
level. Based upon the results of the risk assessment, either (a)
design, implement, and monitor mitigating agencywide internal
controls or (b) document that the existing controls at the cross-
program entity and division levels are sufficient to assure
compliance with federal and Agency requirements.
2 6 Revise Resource Management Directives System Policy R Chief Financial Officer 9/30/21
Manual 2520, Administrative Control of Appropriated and Other
Funds, to require the Office of the Chief Financial Officer to
perform and document risk assessments of emergency
supplemental appropriations (a) when these funds are received
and (b) if there is a subsequent change in the level of risk(s) in
order to design, implement, and monitor internal controls for
these inherently high-risk funds. In cases where the Agency
determines that an entity-level risk assessment is not necessary,
document how the other program offices' internal controls will
mitigate agencywide risks.
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Scope and Methodology
We conducted this evaluation from June to December 2020. We analyzed the Agency's CARES Act spending as of
March 31, 2021, and updated this information accordingly. This evaluation was conducted in accordance with the
Quality Standards for Inspection and Evaluation published in January 2012 by the Council of the Inspectors General on
Integrity and Efficiency. These standards require that we perform the evaluation to obtain sufficient, competent, and
relevant evidence to provide a reasonable basis for our findings, conclusions, and recommendations based on our
objectives. We believe that the evidence obtained provides a reasonable basis for our findings, conclusions, and
recommendations.
To address our objectives, we assessed the actions taken by the Agency's program offices and the guidance they issued
related to the CARES Act appropriations, risk assessment, and mitigating internal controls.
This report is based on the evidence collected and verified from each program office's management, which we assessed
to determine whether the Agency's actions were consistent with:
• The CARES Act statutory requirements.
• The Federal Managers' Financial Integrity Act requirements for the Agency to establish an internal control
system that provides reasonable assurance of achieving internal control objectives.
• The OMB Circular A-123 requirement that the Agency integrate and coordinate internal control assessments
with other internal control-related activities.
• The GAO Green Book framework to establish and maintain an effective internal control system.
• The Resource Management Directives System Policy Manual 2520 requirement to manage funds effectively and
efficiently while following applicable rules, statutes, and regulations.
We interviewed Agency representatives and evaluated the processes the Agency followed for compliance with
applicable federal requirements and Agency policies and procedures.
The key challenges faced by the Agency are complying with the requirements of the CARES Act, which include designing,
implementing, and monitoring internal controls over the CARES Act funds and meeting statutory deadlines.
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Appendix B
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C. 20460
March 29, 2021
OFFICE OF THE
CHIEF FINANCIAL OFFICER
MEMORANDUM
SUBJECT: Revised Response to the Office of Inspector General Draft Report,
Project No. OA&E-FY20-0234 "EPA Did Not Conduct an Agencywide
Risk Assessment of the CARES Act Appropriations, Increasing the Risk
of Fraud, Waste, Abuse, and Mismanagement, " dated December 15,
2020
I \
\ 35/
V	,
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AGENCY'S RESPONSE TO DRAFT REPORT RECOMMEND A TT ON S
Agreements
No.
Recommendation
Assigned
to:
High-Level Corrective Action(s)
Estimated
Completion
Date
1
Perform a risk assessment
for the Coronavirus Aid,
Relief, and Economic
Security Act supplemental
appropriations at the
entity level. Based upon
theresults of the risk
assessment, either (a)
design, implement, and
monitor mitigating
agencywide internal
controls; or (b) document
that the existing controls
at the cross-program
entity and division levels
are sufficient to assure
compliance with federal
and Agency requirements.
OCFO
The OCFO agrees in principle
with the OIG's recommendation
and has completed corrective
actions consistent with the OIG's
recommendation as described
below. The agency should
document high-level risk
assessments for supplemental
appropriations. The OCFO's
evaluation on the CARES Act
supplemental appropriation did
notcategorize these funds as
having high-level risk. For the
CARES Act supplemental
appropriation, the OCFO worked
closely with theOffice of
Congressional and
Intergovernmental Relations,
Office of General Counsel, and
program offices to identify
requirements for additional
tracking, reporting, and internal
controls for these funds. In
addition, the OCFO provided
guidance documenting how the
appropriation will be managed,
highlighting specific issues, and
providing financial coding and
related instructions.
In addition to following
ResourceManagement
Directives System Policy
Manual 2520, the OCFO will
also adhere to practices and
procedures discussing
requirements for risk
assessments associated with
supplemental appropriations.
When the agency receives
additional supplemental
appropriations, the OCFO
June 28, 2020
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updatesfinancial coding within
the agency's financial system
and develops reports for
managers to use for tracking
and reporting purposes.

2
Revise Resource
ManagementDirectives
System Policy Manual
2520, Administrative
Control of Appropriated
and Other Funds, to
require the Office of the
Chief Financial Officer
to perform and document
entity-level risk
assessments of
emergency supplemental
appropriations
(a) when these funds are
received and (b) if there
is asubsequent change in
the risk(s) in order to
design, implement, and
monitor internal controls
for these inherently high-
risk funds. In cases where
the Agency determines
that an entity-levelrisk
assessment is not
necessary, document how
the other program
offices' internal controls
will mitigate
agencywide risks.
OCFO
The OCFO will update RMDS
Policy Manual 2520,
Administrative Control of
Appropriated and Other Funds,
to require OCFO to perform and
document risks assessment of
emergency supplemental
appropriations (a) when these
funds are received, or (b) if there
is a subsequent change in the
risk(s). In addition, the OCFO
will updateRMDS 2520 to
incorporate the updates to the
Office of Management and
Budget's Circular A-123
regarding federal agencies
requirements to fully implement
Enterprise Risk Management
(2016) and updated Improper
Payment reporting review and
compliance
requirements (2021).
September
30,
2021
CONTACT INFORMATION
If you have any questions regarding this response, please contact the OCFO Audit Follow-up
Coordinator, Andrew LeBlanc, at leblanc.andrew@epa.gov or (202) 564-1761.
cc: Carol Terris
Lek Kadeli
Jeanne Conklin
Maria Williams
Charles Sheehan
Edward Shields
Katherine Trimble
James Hatfield
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Meshell Jones-Peeler
Angel Robinson
Richard Gray
OCFO-OC MANAGERS
Leah Nikaidoh
Stephen Seifert
Andrew LeBlanc
Jose Kercado Deleon
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Appendix C
Distribution
The Administrator
Deputy Administrator
Associate Deputy Administrator
Assistant Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff, Office of the Administrator
Chief Financial Officer
Assistant Administrator for Chemical Safety and Pollution Prevention
Assistant Administrator for Mission Support
Assistant Administrator for Research and Development
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Chief Financial Officer
Associate Deputy Chief Financial Officer
Associate Deputy Chief Financial Officer for Policy
Controller
Deputy Controller
Director, Policy, Training, and Accountability Division, Office of the Controller
Chief, Management, Integrity, and Accountability Branch; Policy, Training, and Accountability Division,
Office of the Controller
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
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