U.S. ENVIRONMENTAL PROTECTION AGENCY
CUSTOMER SERVICE ~ INTEGRITY ~ ACCOUNTABILITY
Operating efficiently and effectively
EPA Needs to Measure and
Track Performance of
Programs Eliminated in
President's Budget but
Later Funded by Congress
Report No. 21-E-0219
September 2, 2021
TRACKING
r
MI	I k.
President's Budget
Eliminated
Congress
Funded

-------
Report Contributors: Erin Barnes-Weaver
Jaya Brooks
Lauretta Joseph
Chad Kincheloe
Roopa Mulchandani
Thane Thompson
Abbreviations:
EPA
ETF
FY
GPRAMA
OCFO
OIG
OPAA
U.S. Environmental Protection Agency
Eliminated-Then-Funded
Fiscal Year
Government Performance and Results Act Modernization
Act of 2010
Office of the Chief Financial Officer
Office of Inspector General
Office of Planning, Analysis, and Accountability
Key Definitions:	ETF Program
Internal Controls
A program eliminated from the President's
Budget but funded by Congress in an
appropriation bill that the president then
signed into law.
A process used by management to help an
entity achieve its objectives.
Cover Image:	The EPA is not tracking required performance measures for all programs
that were eliminated in the President's Budget but later funded by
Congress. (EPA OIG image)
Are you aware of fraud, waste, or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, D.C. 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoiq
Send us your Project Suggestions

-------
Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
21-E-0219
September 2, 2021
Why We Did This Evaluation
We conducted this evaluation to
determine whether the
U.S. Environmental Protection
Agency's Office of the Chief
Financial Officer has processes
in place to ensure that EPA
programs eliminated in the
President's Budget but later
funded by congressional
appropriation have the required
performance measures.
The President's Budget outlines
an administration's yearly
priorities. While the President's
Budget eliminates federal
programs that do not align with
the administration's priorities,
those programs may still be
funded by Congress. In
accordance with the Government
Performance and Results Act
Modernization Act of 2010, each
agency must develop an annual
performance plan that
establishes performance goals
for each funded program activity
in the agency appropriation. The
Act also specifies that
performance goals be expressed
in an objective, quantifiable, and
measurable form unless an
alternative format is authorized.
This evaluation supports an EPA
mission-related effort:
•	Operating efficiently and
effectively.
This evaluation addresses a top
EPA management challenge:
•	Complying with key internal
control requirements (policies
and procedures).
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
EPA Needs to Measure and Track Performance of
Programs Eliminated in President's Budget but Later
Funded by Congress
Without internal controls
to track ETF program
performance, the EPA
risks underreporting
environmental and
human health outcomes.
What We Found
From fiscal years 2018 through 2020, the EPA
was appropriated nearly $2.4 billion for programs
that were eliminated in the President's Budget but
then later funded by congressional appropriation.
During that time frame, the EPA did not have
internal controls in place for these eliminated-
then-funded, or ETF, programs to ensure that
program activities were measured and tracked. In that same time period, the
EPA saw a more than 1,400-percent increase in the average number of annual
ETF programs. The Office of the Chief Financial Officer indicated that the
repeated ETF nature of these programs contributed to the challenges in
tracking performance.
The OCFO does issue yearly guidance regarding the development and tracking
of performance measures for EPA programs included in the Agency's annual
performance plans and Congressional Justifications, which are written in
conjunction with and in support of the President's Budget. The OCFO had not,
however, issued written guidance that explicitly instructs ETF programs to
develop and track performance measures after they receive funds from
Congress. The OCFO also does not verify whether ETF programs have
developed performance measures and, if so, where those measures are
tracked. For the five ETF programs we reviewed, three were not centrally
tracked in the EPA's system that houses Agency performance measurement
data, one centrally tracked only partial performance measures, and one
centrally tracked all performance measures.
Recommendations and Planned Agency Corrective Actions
We recommend that the OCFO develop (1) written guidance that explicitly
states that ETF programs must develop performance measures if funded by
congressional appropriations and (2) an annual process to verify that ETF
programs have performance measures in place and identify where those
measures are tracked. All recommendations are resolved with corrective
actions pending.
Noteworthy Achievement
As a result of our evaluation, the OCFO surveyed program offices to better
understand which ETF programs had developed performance measures. The
OCFO reported that 35 of the 43 programs it identified as ETF in fiscal year
2021 are tracking performance measures and provided this documentation to
the Office of Inspector General.

-------
^£Dsr/%
' JL \
\«/
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 2, 2021
MEMORANDUM
SUBJECT: EPA Needs to Measure and Track Performance of Programs Eliminated in President's
Budget but Later Funded by Congress
Report No. 21-E-0219
This is our report on the subject evaluation conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this evaluation was OE-FY21-Q135. 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 is responsible for the issues discussed in this report.
In accordance with EPA Manual 2750, your office provided acceptable planned corrective actions in
response to the two OIG recommendations. All recommendations are resolved with corrective actions
pending, and 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: Sean W. O'Donnell
TO:
Faisal Amin, Chief Financial Officer
We will post this report to our website at www.epa.gov/oig.

-------
EPA Needs to Measure and Track Performance	21-E-0219
of Programs Eliminated in President's Budget
but Later Funded by Congress
		Table of C	
Purpose	1
Background	1
Federal and EPA Budget Process and Priorities	1
Roles and Responsibilities	2
Eliminated-Then-Funded Programs	3
Internal Controls and Measurement	6
Responsible Office	6
Noteworthy Achievement	6
Scope and Methodology	6
Results	7
Explicit Guidance and Processes Needed for ETF Program Performance Measures	8
Performance Measures Not Centrally Tracked for All ETF Programs	8
OCFO Needs to Verify Whether ETF Programs Track Performance Measures	10
Conclusions	10
Recommendations	10
Agency Response and OIG Assessment	10
Status of Recommendations	11
Appendixes
A Agency Response to Draft Report	12
B Distribution	15

-------
Purpose
The U.S. Environmental Protection Agency's Office of Inspector General conducted this evaluation to
determine whether the Office of the Chief Financial Officer has processes in place to ensure that EPA
programs eliminated in the President's Budget but later funded by congressional appropriation have the
required performance measures.
Top Management Challenge Addressed
This evaluation addresses the following top management challenge for the Agency, as identified in OIG
Report No. 20-N-0231. EPA's FYs 2020-2021 Top Management Challenges, issued July 21, 2020:
• Complying with key internal control requirements (policies and procedures).
Background
Federal and EPA Budget Process and Priorities
For each upcoming fiscal year, which runs from October 1 through September 30, the president
develops the Budget of the U.S. Government, also referred to as the President's Budget. The President's
Budget outlines an administration's priorities and is based upon the budget proposals that the federal
agencies submit to the White House for consideration. The president typically transmits the President's
Budget to Congress the first week of February, eight months before the upcoming fiscal year begins and
in correlation with the State of the Union speech. Congress then analyzes the President's Budget and
drafts a budget resolution that sets fiscal-year spending levels for the federal government. Once
Congress passes the appropriations bills and the president signs those bills into law, the total funding
stipulated becomes the enacted federal budget for that fiscal year. See Figure 1 for additional details on
the federal budget process, including the EPA's actions.
Figure 1: EPA's budget process
Appropriations bills
enact federal agency
budgets into law upon the
president's signature.
The appropriation bill that
includes funding for the EPA
becomes the blueprint for
the EPA's budget activities
during the fiscal year.
Congress considers the
President's Budget and
passes appropriations bills.
From April to January before
the upcoming fiscal year:
The EPA develops a proposed Agency
budget for the upcoming fiscal year.
Typically, no later than the first Monday in
February before the upcoming fiscal year:
The president sends the President's Budget,
which includes the proposals from the
federal agencies, to Congress for
deliberation.
Source: OIG summary of federal budget materials. (EPA OIG image)
The President's Budget highlights the "Agency Priority Goals" that advance the EPA's strategic goals,
priorities, and specific programs. These "Agency Priority Goals" are detailed in the EPA's strategic plan,
which describes how the Agency will work toward its mission to protect human health and the
21-E-0219
1

-------
environment. The EPA's strategic plan also identifies the long-term performance goals that describe the
measurable environmental and human health outcomes that the public can expect from the EPA's
efforts.
Tracking of such outcomes is one component of the Government Performance and Results Act
Modernization Act of 2010, or GPRAMA, which requires federal agencies to plan for, measure, and be
accountable for achieving program results. For example, the GPRAMA emphasizes setting priorities,
cross-organizationally collaborating to achieve shared goals, and using goal and measure analyses to
improve outcomes of federally funded programs. Not all programs have the same types of program
measures. If it is not feasible to express performance goals for a particular program activity in an
objective, quantifiable, and measurable form, the GPRAMA allows an agency, in consultation with the
director of the Office of Management and Budget, to develop an alternative form of program
measurement for that activity.
Roles and Responsibilities
The EPA's OCFO:
•	Implements GPRAMA, including:
o Formulating and managing the EPA's annual budget and Annual Performance Plan.
Annual Performance Plan
The EPA develops an annual performance plan, which is incorporated into its budget request submitted
to the White House. This annual performance plan outlines what the programs will use the requested
funds for, what environmental or human health risks those programs will address, and how those
programs will attempt to reduce those risks.
o Coordinating the EPA's strategic planning efforts.
o Developing the EPA's annual Performance and Accountability Report,-which is issued as
part of the Annual Performance Plan and the Justification of Appropriation Estimates for
the Committee on Appropriations document, also called the Congressional Justification.
Congressional Justification
When the president submits the President's Budget to Congress, the EPA also submits a Congressional
Justification to Congress, which includes information about the Agency's spending for the current and
prior federal fiscal year, as well as the Agency's proposed budget for the upcoming fiscal year. The
Congressional Justifications typically provide updates on the Agency's programs, initiatives, projects,
activities, and use of the previous fiscal year's appropriations.
•	Provides policy, reports, and oversight that are essential for the EPA's financial operations.
•	Helps plan, develop, and deploy financial- and resource-management systems for the Agency.
Two offices within the OCFO play important roles in planning, budgeting, and reporting:
•	The Office of Budget, which serves as the Agency's central budget office responsible for the
formulation and defense of the EPA's Annual Performance Plan and proposed budget submitted
for the President's Budget. The Office of Budget provides guidance to the Agency regarding the
proper use, accounting, and reporting of resources. The Office of Budget also allocates the EPA's
21-E-0219
2

-------
resources through a multiyear- and annual-planning process, the annual budget process, and
accounting processes.
•	The Office of Planning, Analysis, and Accountability, which serves as the Agency's lead for
strategic planning, annual planning, and performance management and reporting efforts. The
OPAA implements the GPRAMA and works to align strategies, measures, and budget resources
to accomplish Agency goals. Before the upcoming fiscal year begins, the OPAA sends guidance to
the EPA's program offices describing how to develop and track performance measures for those
programs included in the Agency's Annual Performance Plan and the Congressional Justification.
The EPA develops these documents in conjunction with and in support of the priorities outlined
in the President's Budget.
According to the OPAA, it worked with the Office of Budget to create a Performance Module within the
Agency's internal Budget Formulation System. The OPAA told us that this Performance Module:
•	Centrally houses and tracks performance measurement data, including performance measures
externally reported in the Annual Performance Plan and internally tracked by Agency senior
leaders.
•	Includes a reporting tool, called the Performance Dashboard, that displays the performance
measurement data. The Performance Dashboard was developed in and displays data starting
from FY 2019 but, according to the OPAA, does not include all performance measures reported
into the Performance Module.
Program offices implement actions to help meet the goals and objectives included in the EPA's strategic
plan. Program offices are responsible for measuring not only program performance but also human health
and environmental outcomes. By measuring outcomes, the EPA can both show proper use of appropriated
funds and provide reasonable assurance to the public that those funds achieve results. Program offices
accomplish this through appropriate measure development, data collection, and annual reporting.
Eliminated-Then-Funded Programs
Every fiscal year, the EPA manages the current year's budget and performance activities; plans for the
next year's activities; and reports to the president, Congress, and the American public on the prior year's
achievements and challenges. Each administration uses the President's Budget to give an indication of
its priorities for the coming year. Programs that are eliminated from the President's Budget can be seen
as signals to Congress that the administration no longer considers those programs as priorities. Congress
then has the discretion to either fund or not fund those programs in the final appropriation bill.
However, if Congress does fund those programs in an appropriation bill and the president signs the bill
into law, all programs funded in that bill must be administered, implemented, and measured according
to applicable laws and policies. For the purpose of this report, these programs are referred to as
eliminated-then-funded, or ETF, programs. Figure 2 depicts ETF programs as a portion of the EPA's
budget from FYs 2018 through 2020.
21-E-0219
3

-------
Figure 2: ETF funding, in millions, as a portion of EPA's budget, FYs 2018-2020
FY 2020
<
5680








$9,057
FY 2019
FY 2018






^	





$8,800
$8,752
$- $1,000 $2,000 $3,000 $4,000 $5,000 $6,000 $7,000 $8,000 $9,000 $10,000
¦ ETF funding, in millions ¦ EPA funding, in millions
Source: OIG analysis of EPA budget information. (EPA OIG image)
From FYs 2015 through 2017, the average number of EPA ETF programs in each President's Budget was
less than three. From FYs 2018 through 2020, the average number of annual ETF programs increased
more than 1,400 percent compared to prior fiscal years. During FYs 2018 through 2020, the same group
of 35 to 46 EPA programs were eliminated from each President's Budget and then ultimately funded
through congressional appropriations.
The EPA's ETF program areas ranged from Alternative Dispute Resolution activities to waste-reduction
and water-protection efforts, with individual program funding levels for FY 2020 that ranged between
$808,000 and $172 million. These ETF programs had an average total annual funding level of
$791 million and an overall total of $2,373 billion over all three fiscal years. Table 1 lists all the EPA's ETF
programs from FYs 2018 through 2020.
Table 1: FYs 2018-2020 ETF programs ($ in millions)*
ETF program
FY 2020
FY 2019
FY 2018
Estimated
Enacted
Budget3
President's
Budget
Annualized
Continuing
Resolution11
President's
Budget
Annualized
Continuing
Resolution11
President's
Budget
1 Alternative Dispute Resolution
$1,600
$0
$1,898
$0
$1,682
$0
2
Beach/Fish
1.600
0
2.014
0
1.638
0
3
Beaches Program
9.200
0
9.549
0
9.484
0
4
Lead Program


14.049
0
13.954
0
5
Nonpoint Source (Section 319)
172.300
0
170.915
0
169.754
0
6
Pollution Prevention Program
4.600
0
4.765
0
4.733
0
7
Radon Program
7.800
0
8.051
0
7.996
0
8 Underground Storage Tanks	1.500	0	1.498	0	1.488	0
9 Endocrine Disruptor Screening
7.500
0
7.553
0
7.502
0
Program






10 Environmental Education	8.600	0	8.702	0	8.643	0
11
Environmental Justice




6.691
0
12
Chesapeake Bay




72.504
0
13
Gulf of Mexico
17.600
0
12.542
0
8.484
0
14 Lake Champlain	13.400	0	8.399	0	4.369	0
15 Long Island Sound
21.000
0
12.000
0
7.946
0
16 Other
9.600
0
7.393
0
7.343
0
21-E-0219
4

-------


FY 2020
FY 2019
FY 2018


Estimated

Annualized

Annualized


ETF program
Enacted
Budget3
President's
Budget
Continuing
Resolution11
President's
Budget
Continuing
Resolution11
President's
Budget
17
Puget Sound
33.000
0
28.000
0
27.810
0
18
San Francisco Bay
5.900
0
4.819
0
4.786
0
19
South Florida

17.704
0
1.692
0
20
Gold King Mine Water Monitoring
4.000
0
4.000
0
3.973
0
21
Great Lakes Restoration




297.963
0
22
Homeland Security: Critical
Infrastructure Protection




10.109
0
23
Indoor Air: Radon Program
3.300
0
3.295
0
3.273
0
24
Infrastructure Assistance: Alaskan
Native Villages




19.864
0
25
Infrastructure Assistance: Mexico
Border
25.000
0
10.000
0
9.932
0
26
LUST Prevention
25.400
0
25.369
0
25.197
0
27
Marine Pollution

11.065
0
10.102
0
28
National Estuary Program/Coastal
Waterways
29.800
0
26.723
0
26.542
0
29
Safer Choice Program
11.100
0
11.236
0
12.194
0
30
Radiation: Protection




12.487
0
31
RCRA: Waste Minimization &
Recycling


9.534
0
9.141
0
32
Reduce Lead in Drinking Water


10.000
0


33
Reduce Risks from Indoor Air
11.800
0
13.695
0
13.386
0
34
Regional Science and Technology
0.808
0
1.205
0
1.406
0
35
Safe Water for Small and
Disadvantaged Communities
25.400
0
20.000
0


36
Science Policy and Biotechnology
1.600
0
2.040
0
1.479
0
37
Small Minority Business Assistance

1.574
0
1.573
0
38
Stratospheric Ozone: Multilateral
Fund
8.700
0
8.736
0
8.677
0
39
Targeted Airshed Grants
56.300
0
40.000
0
29.796
0
40
Toxic Substances: Lead Risk
Reduction (Lead Renovation, Repair
and Painting) Program
11.600
0
12.627
0
13.203
0
41
Trade and Governance
5.400
0
5.463
0
5.777
0
42
Border 2020: U.S.-Mexico
Environmental Program
2.700
0
3.033
0
3.012
0
43
Water Quality Research and Support
Grants
23.700
0
16.800
0
16.686
0
~44~
Atmospheric Protection
66.000
0
66.000
0
66.000
0
45
Global Change Research
19.300
0
19.014
0
16.520
0
46
Office of Public Engagement




1.933
0
47
STAR Research Grants
28.600
0
28.536
0
28.284
0
48
WaterSense (Surface Water
Protection)
$4,500
$0
$3,100
$0
$3,079
$0
Total Appropriation Across All Three Fiscal Years: $2,373,191
Source: OIG summary of EPA funding information provided in the "Eliminated Programs" sections of the FYs 2018-
2021 Congressional Justifications. (EPA OIG table)
Legend: LUST = Leaking Underground Storage Tanks; RCRA= Resource Conservation and Recovery Act;
STAR = Science to Achieve Results.
* Not all ETF programs were eliminated in the President's Budget each fiscal year. The gray cells represent the
fiscal years that those programs were maintained in the President's Budget.
a Based on the FY 2021 Congressional Justification, the programs eliminated from the FY 2021 budget used the
funding amounts from the FY 2020 Estimated Enacted Budget.
b Based on the FYs 2020 and 2019 Congressional Justifications, the programs eliminated from these budgets
used the funding amounts from the FYs 2019 and 2018 Annualized Continuing Resolution Budgets.
21-E-0219
5

-------
Internal Controls and Program Performance
Every federal program is required to have internal controls, which consists of the plans, policies, and
procedures used to implement program operations and to achieve the program's goals and objectives.
Management is responsible for an effective internal control system by, first, identifying the program
objective and, second, developing and implementing controls with the reasonable expectation of
achieving the objective.
Two documents outline the requirements for internal controls. The U.S. Government Accountability
Office's Standards for Internal Control in the Federal Government, also known as the Green Book, issued
September 10, 2014 (GAO-14-7Q4G), contains standards to implement internal control requirements for
the federal government, including program operations, data collection and reporting, and consistent
implementation. Office of Management and Budget Circular A-123, Management's Responsibility for
Enterprise Risk Management and Internal Control, issued July 15, 2016, requires that federal managers
implement Green Book standards and defines management's responsibilities for the risk-management
process.
Similarly, Office of Management and Budget Circular A-ll. Preparation, Submission, and Execution of the
Budget, revised April 28, 2021, requires agencies, in accordance with the GPRAMA, to develop an
Annual Performance Plan that outlines strategic goals and objectives and the annual performance goals
and measures for programs presented in the President's Budget. Office of Management and Budget
Circular A-ll requires that each agency update its performance goals "to reflect final congressional
action on appropriations" and other changes, as necessary.1 Finally, the GPRAMA requires that each
agency publish an Annual Performance Report that describes the outcomes and results of federally
funded programs and activities through the previous fiscal year.
Responsible Office
The OCFO is responsible for the issues discussed in this report.
Noteworthy Achievement
After we initiated this evaluation, the OCFO surveyed program offices to better understand whether
performance measures existed for ETF programs. Specifically, the OCFO sought to determine whether
ETF performance measures existed outside of the OPAA's Performance Dashboard and, if so, where and
how program offices track those performance measures. The OCFO reported that 35 of the 43 programs
identified as ETF in fiscal year 2021 had developed measures at the program level.
Scope and Methodology
We conducted our work from March to June 2021 in accordance with the Quality Standards for
Inspection and Evaluation published in January 2012 by the Council of the Inspectors General on
Integrity and Efficiency. Those standards require that we plan and perform the evaluation to obtain
sufficient, competent, and relevant evidence to provide a reasonable basis for our findings, conclusions,
1 Office of Management and Budget Circular A-ll, Part 6, Section 240.6.
21-E-0219
6

-------
and recommendations based on our objective. We believe that the evidence obtained provides a
reasonable basis for our findings, conclusions, and recommendations.
We reviewed statutory language, guidance, and procedure documents. We also interviewed staff from the
OCFO to gather information and to discuss their current processes for measuring and tracking ETF programs.
In previous evaluations, the OIG reviewed several programs that had been eliminated, then funded.
During the course of those evaluations, the OIG found that some of those programs lacked program
measures. To better understand the EPA's ETF programs and the environmental and human health
outcomes of these programs, we selected five ETF programs to review. To identify the programs for our
review, we compared the list of FYs 2018-2020 ETF programs to a list of OIG reports and notification
memorandums issued in those same years. We identified four OIG reports and one notification
memorandum addressing the five EPA ETF programs outlined in Table 2.
Table 2: EPA ETF programs selected for review


Associated OIG report
or notification memorandum

EPA ETF program
Report or project number
Date issued
(fiscal year)
1
Beaches Proqram
Report No. 20-E-0246
August 13, 2020
(FY 2020)
2
Border 2020: U.S.-Mexico Environmental Proqram
Report No. 20-P-0083
February 18, 2020
(FY 2020)
3
Lead Renovation. Repair and Paintina Proaram
Report No. 19-P-0302
September 9, 2019
(FY 2019)
4
Safer Choice Proaram
Report No. 20-P-0203
June 30, 2020
(FY 2020)
5
Endocrine DisruDtor Screenina Proaram
Proiect No. OE-FY20-0379
(notification memorandum)
October 21, 2020
(FY 2021)
Source: OIG analysis of EPA ETF data and OIG reports and notification memorandums. (EPA OIG table)
For each of these five programs, we reviewed their websites to understand their purpose, as well as to
identify the responsible offices and program-specific environmental or human health outcomes that the
Agency recorded from FYs 2018 through 2020. We also reviewed the Performance Dashboard for
program performance measures, and we considered entries to be complete if the programs included
performance measures recorded for all applicable responsible offices. We also collected budget
information for each program.
Results
From FYs 2018 through 2020, the EPA was appropriated nearly $2.4 billion for its ETF programs, but the
EPA did not have internal controls in place to ensure that program activities were measured and
tracked. The OCFO does issue written guidance each year outlining how program offices should develop
and track performance measures for programs that are included in the Agency's Annual Performance
Plan and Congressional Justification, which are developed in conjunction with and in support of the
President's Budget. The OCFO had not issued written guidance that explicitly instructs ETF programs to
develop and track performance measures after they receive congressional appropriations. Further, the
OCFO did not develop a process to verify whether ETF programs have developed performance measures
and where those measures are tracked. For three of the five ETF programs we reviewed, we found no
performance measures centrally tracked in the Performance Dashboard. Without explicit guidance or
21-E-0219
7

-------
processes in place to instruct program offices to develop and track ETF program performance measures,
the EPA risks underreporting environmental and human health outcomes.
Explicit Guidance and Processes Needed for ETF Program Performance Measures
The OCFO's OPAA works to align strategies, measures, and budget resources to accomplish Agency
goals. The Green Book provides standards for agencies in implementing internal control requirements,
including data collection and reporting. The Green Book also describes the need for performance
measures, which are what management uses to evaluate performance in achieving objectives. Office of
Management and Budget Circular A-123 requires that federal managers implement Green Book
standards to, in part, properly assess and evaluate program objectives, as well as reduce the risk that
program objectives are not met.
Before FY 2018, the EPA averaged less than three ETF programs annually. From FYs 2018 through 2020,
the average number of annual ETF programs increased by more than 1,400 percent. In addition, OPAA
staff said that the same set of programs were repeatedly eliminated in the President's Budget but then
later funded by Congress during that same time frame. The OPAA indicated that the repeated ETF
nature of these programs contributed to the challenges in tracking performance measures.
During our interviews with OCFO staff, we asked whether the OPAA had a process to identify ETF
programs and to verify whether ETF programs develop and track performance measures after they
received congressional funding. While we found that the OPAA does have a process in place to collect
and consolidate performance measures from program offices included in the Agency's Annual
Performance Plan and Congressional Justification, which are developed in conjunction with and in
support of the President's Budget, the OPAA does not have internal controls in place to explicitly ensure
that ETF programs develop and track performance measures.
Performance Measures Not Centrally Tracked for All ETF Programs
We examined the Performance Dashboard to determine whether the five ETF programs we reviewed
centrally tracked their performance measures. As shown in Table 3, we found that the dashboard did
not include any performance measures for three of these five programs. The dashboard partially
reported performance measures for one of these five programs, with data recorded from one of the
three offices responsible for that program. The dashboard included performance measures for all the
offices responsible for the remaining program.
Table 3: Performance measures included in the dashboard*
ETF program I
I FY 2019 I
I FY 2020
Beaches Program
No
No
Safer Choice Program
No
No
Endocrine Disruptor Screening Program
No
No
Border 2020: U.S.-Mexico Environmental Program
Partial
Partial
Lead Renovation, Repair and Painting Program
Yes
Yes
Source: OIG analysis of EPA performance data. (EPA OIG table)
* The Performance Dashboard was not introduced until FY 2019, so no data are shown for FY 2018.
Specifically, we found that the Beaches Program, Safer Choice Program, and Endocrine Disruptor
Screening Program did not have any performance measures included in the dashboard. The dashboard
did include performance measures for the Border 2020 Program from Region 6 but not from the two
21-E-0219
8

-------
other offices responsible for the program: the Office of International and Tribal Affairs and Region 9. The
dashboard also included performance measures from all offices responsible for the Lead Renovation
Repair and Painting Program. Figure 3 details the health and environmental outcomes that these five
programs are designed to achieve.
Figure 3: Intended ETF program outcomes and whether performance measures are centrally
tracked in the Performance Dashboard
Beaches Program
The BEACH Act requires the EPA to develop performance criteria for
testing, monitoring, and notifying public users of possible coastal
recreation water problems.
SAFER
CHOICE
O
Measures not included in the
Performance Dashboard
Safer Choice Program
Safer Choice helps consumers, businesses, and purchasers find
products that perform and contain ingredients that are safer for human
health and the environment. SaferChoice includes practices that
reduce, eliminate, or prevent pollution at its source, such as using safer
ingredients in products.
o
Measures not included in the
Performance Dashboard
Endocrine Disruptor Screening Program
The EPA implements screening, testing and research programs to
gather information the Agency uses to evaluate possible endocrine
effects associated with the use of a chemical The EPA takes
appropriate steps to mitigate any related risks to ensure protection of
public health and the environment
o
Measures not included in the
Performance Dashboard
Border 2020: U.S. - Mexico Environmental Program
The Border 2020 Program is the latest environmental program
implemented under the 1983 La Paz Agreement. It emphasizes
regional, bottom-up approaches for decision-making, priority setting,
and project implementation to address the environmental and public
health problems in the border region.
Measures partially included in
the Performance Dashboard
Lead Renovation, Repair and Painting Program
EPA's Lead Renovation, Repair and Painting Rule requires that firms
performing renovation, repair, and painting projects that disturb lead-
based paint in homes, childcare facilities, and preschoots built before
1978 be certified by the EPA use certified renovators who are trained
by EPA-approved training providers and follow lead-safe work
practices
r

>
A
Measures included inthe

w
Performance Dashboard

V


Source: OIG review of the EPA's program websites and analysis of the Performance Dashboard, (EPA OIG image)
21-E-0219

-------
OCFO Needs to Verify Whether ETF Programs Track Performance Measures
According to the OCFO, programs can track performance measures outside the dashboard through
internal, program-specific websites. If the Performance Dashboard does not include performance
measures for an ETF program, it is possible that the ETF program tracks the performance measures at
the program level. However, if performance measures are not tracked centrally via the dashboard, the
OCFO would need to contact the ETF program to ascertain whether the performance measures are
tracked elsewhere and, if so, where those measures are tracked.
As noted previously, the OCFO surveyed ETF programs for this information after we initiated this
evaluation. The Agency discovered, for example, that, while the dashboard did not include performance
measures for either the Beaches Program or the Safer Choice Program, both programs tracked
performance measures on their program-specific websites. The OCFO's survey identified, however, that
the Endocrine Disruptor Screening Program did not track performance measures either via the
dashboard or elsewhere.
Conclusions
From FYs 2018 to 2020, the OCFO had not issued guidance to explicitly instruct ETF programs to develop
performance measures, and it did not have a process for verifying that ETF programs develop and track
performance measures. These conditions increased the risk that performance measures for ETF
programs would not be consistently tracked, and nearly $2.4 billion in total ETF program funding was
appropriated to the EPA from FYs 2018 through 2020 without the Agency having internal controls in
place to ensure performance measurement tracking. Absent explicit guidance that communicates
requirements to develop and track performance measures and a process to verify that ETF programs
develop and track performance measures once funding is received, the EPA risks underreporting
environmental and human health outcomes.
Recommendations
We recommend that the chief financial officer:
1.	Develop written guidance that explicitly states that eliminated-then-funded programs must
measure and track performance.
2.	Develop an annual process to verify that eliminated-then-funded programs have performance
measures in place and to identify where those measures are tracked.
Agency Response and OIG Assessment
The Agency agreed with both of our recommendations and provided acceptable corrective actions and
completion dates. After we initiated this evaluation, the OCFO issued guidance for the FY 2022
Congressional Justification, which asks programs to identify performance measures or specific
mechanisms to monitor progress for FY 2021 ETF programs. The OCFO also stated that it plans to
incorporate language in future planning and budget guidance, including the guidance for the FY 2023
Office of Management and Budget submission. The recommendations are resolved with corrective
actions pending. The Agency's full response is in Appendix A.
21-E-0219
10

-------
Status of Recommendations
RECOMMENDATIONS





Planned
Rec.
Page



Completion
No.
No.
Subject
Status1
Action Official
Date
10 Develop written guidance that explicitly states that eliminated-
then-funded programs must measure and track performance.
Chief Financial Officer
2/28/22
10 Develop an annual process to verify that eliminated-then-funded
programs have performance measures in place and to identify
where those measures are tracked.
Chief Financial Officer
2/28/22
21-E-0219
C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
11

-------
Appendix A
Agency Response to Draft Report
^0ST^,
$
<
33
O
\
SB.
%pro^
o
p*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
July 21,2021
OFFICE OF THE
CHIEF FINANCIAL OFF1CEH
MEMORANDUM
SUBJECT: Response to the Office of Inspector General Draft Report, Project No. OE-FY21-0135,
"EPA Needs to Measure and Track Performance of Programs Eliminated in President's
Budget but Later Funded by Congress, " dated June 21, 2021
FROM: Faisal Amin, Chief Financial Officer AlTlin,
Office of the Chief Financial Officer Faisal
TO:
Renee McGhee-Lenart, Acting Director
Programs, Offices, and Centers Oversight Directorate
Office of Special Review and Evaluation
Thank you for the opportunity to respond to the issues and recommendations in the subject draft
report. The following is a summary of the U.S. Environmental Protection Agency's (EPA)
overall position and position on the report's recommendations.
AGENCY'S OVERALL POSITION
The Office of the Chief Financial Officer (OCFO) agrees with the Office of the Inspector
General's overall finding that the EPA should identify and track systematically the performance
of programs eliminated in the President's Budget and later funded by Congress, as well as the
two recommendations. As a result of this engagement, the OCFO included instructions in the
agency guidance for the FY 2022 Congressional Justification, which asks programs to identify
performance measures or specific mechanisms to monitor progress for FY 2021 eliminated-then-
funded programs. We are incorporating this request in future planning and budget guidance,
including the guidance for the FY 2023 Office of Management and Budget (OMB) submission
that will be issued later this month.
The OCFO does want to raise a concern with the language used to describe the requirement for
performance measures, which could leave the impression that all program activities in the budget
must have quantifiable performance measures. The Government Performance and Results
Modernization Act provides for exceptions to this under section 1115(c), in consultation with the
21-E-0219
12

-------
OMB. The 0CF0 has provided suggested alternative language, as well as a few additional
technical corrections and comments in the attached document.
RESPONSE TO DRAFT REPORT RECOMMENDATIONS
Agreements
No
Recommendation
High-Level Intended Corrective
Action(s)
Estimated
Completion
Date
1
Develop written guidance
that explicitly states that
eliminated-then-funded
programs must measure and
track performance.
The OCFO will include specific guidance
in our Fall 2021 guidance for the FY 2023
Congressional Justification that programs
identify measures and track performance
for any eliminated-then-funded programs
for FY 2022. (Exceptions consistent with
the GPRA Modernization Act will be
considered.)
Note: The OCFO included specific
instructions in guidance for the FY 2022
CJ in April 2021 and will include
instructions with the FY 2023 OMB
Submission guidance to be issued in late
July.
February 2022
2
Develop an annual process to
verify that eliminated-then-
funded programs have
performance measures in
place and to identify where
those measures are tracked.
The OCFO will include in its annual
measures development and tracking a
specific process to verify that eliminated-
then-funded programs have performance
measures in place and to identify where
those measures are tracked.
February 2022
CONTACT INFORMATION
If you have any questions regarding this response, please contact the OCFO's Audit Follow-up
Coordinator, Andrew LeBlanc, epa.gov or (202) 564-1761.
Attachment
cc: David Bloom
Carol Terris
Lek Kadeli
Jeanne Conklin
Meshell Jones-Peeler
Kathy O'Brien
Maria Williams
21-E-0219
13

-------
Richard Gray
John M. Hall
Angel Robinson
OCFO-OC-MANAGERS
Hamilton Humes
Chad Kincheloe
Erin Barnes-Weaver
Jaya Brooks
Thane Thompson
Andrew LeBlanc
Jose Kercado DeLeon
21-E-0219
14

-------
Appendix B
Distribution
The Administrator
Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff, Office of the Administrator
Chief Financial Officer
Deputy Chief Financial Officer
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Chief Financial Officer
Associate Chief Financial Officer for Policy
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
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
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
21-E-0219
15

-------