CUSTOMER SERVICE * INTEGRITY ~ ACCOUNTABILITY
Compliance with the law
Operating efficiently and effectively
EPA's Fiscal Year 2020
Fourth-Quarter Compliance
with the Digital
Accountability and
Transparency Act of 2014
Report No. 22-P-0001
November 8, 2021
Sub-Award
Attributes
(File F)
Additional
Awardee
Attributes
Appropriations
Account
(File A)
Public Website:
USAspending.gov
DATA Act
Reporting
Object Ciass
and Program
Activity
(File B)
Award
Financial
(File E) Award and Awardee Attributes
[Procurement] (File Dl)
[Financial Assistance]
(File D2)
(FileC)
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Report Contributors:
Paul Curtis
Amir Eskarous
Amanda Ipema
Allison Krenzien
Shannon Lackey
Doug LaTessa
Sheila May
Claire McWilliams
Kevin Ross
Abbreviations:
CFDA Catalog of Federal Domestic Assistance
C.F.R. Code of Federal Regulations
CIGIE Council of the Inspectors General on Integrity and
Efficiency
DAIMS DATA Act Information Model Schema
DATA Act Digital Accountability and Transparency Act of 2014
EPA U.S. Environmental Protection Agency
FPDS-NG Federal Procurement Data System - Next Generation
FY Fiscal Year
ID Identification
OIG Office of Inspector General
OMB Office of Management and Budget
Pub. L. Public Law
U.S.C. United States Code
Key Definitions:
Please see Appendix A for key definitions.
Cover Image:
Illustration of the EPA's DATA Act Broker files being submitted for
publication on USAspending.gov. (EPA OIG image)
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Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
22-P-0001
November 8, 2021
Why We Did This Audit
The Digital Accountability and
Transparency Act of 2014
requires the inspector general to
review a statistically valid sample
of the U.S. Environmental
Protection Agency's spending
data submitted under the Act to
assess the completeness,
accuracy, timeliness, and quality
of the data sampled, as well as
the EPA's implementation and
use of the data standards
established by the Office of
Management and Budget and
U.S. Department of the Treasury.
To satisfy this requirement, we
performed this audit on fiscal
year 2020 fourth-quarter financial
and award data submitted to the
Department of the Treasury by
the EPA's Office of the Chief
Financial Officer.
This audit supports EPA mission-
related efforts:
• Compliance with the law.
• Operating efficiently and
effectively.
This audit addresses top EPA
management challenges:
• Complying with key internal
control requirements (data
quality).
• Fulfilling mandated reporting
requirements.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
EPA's Fiscal Year 2020 Fourth-Quarter
Compliance with the Digital Accountability
and Transparency Act of 2014
The DATA Act requires
the EPA to report
accurate financial and
award data on
USAspending.gov.
What We Found
We found that the EPA substantially complied with
the requirements of the Digital Accountability and
Transparency Act of 2014 and submitted financial
and award data to the Department of the
Treasury's DATA Act Broker on time. Our
nonstatistical and statistical tests of the
EPA's DATA Act submissions—including those tests that assessed the data
attributes of completeness, accuracy, and timeliness—determined that the
EPA's fiscal year 2020 fourth-quarter financial and award data were of "higher"
quality, as defined by the CIGIE FAEC Inspectors General Guide to
Compliance under the DATA Act, dated December 4, 2020. The CIGIE DATA
Act Guide outlines four levels of data quality: excellent, higher, moderate, and
lower.
While the data achieved an assessment of "higher" quality, we found that the
EPA had not fully implemented the data standards established by the Office of
Management and Budget and the Department of the Treasury. We identified
specific data inconsistencies and control deficiencies that indicate the EPA
could improve its internal controls over implementing data standards and
preparing its DATA Act submissions.
Recommendations and Planned Agency Corrective Actions
We recommend that the assistant administrator for Mission Support update
the EPA's policies and procedures to address the errors identified in this audit,
as well as update the EPA's grants management system to align with the
DATA Act data standards and provide training to improve the consistency of
data entry.
The EPA agreed with our six recommendations and provided acceptable
planned corrective actions and estimated completion dates. We consider the
recommendations resolved with corrective actions pending.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
November 8, 2021
MEMORANDUM
SUBJECT: EPA's Fiscal Year 2020 Fourth-Quarter Compliance with the Digital Accountability and
Transparency Act of 2014
Report No. 22-P-0001
This is our report on the subject audit conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this audit was OA-FY21-0080. This
report contains findings that describe the problems the OIG has identified and the 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 has primary responsibility for the implementation of the
Digital Accountability and Transparency Act of 2014. Other EPA offices with responsibility for file
submissions for the DATA Act include the Office of the Controller and the Office of Mission Support's
Office of Acquisition Solutions and Office of Grants and Debarment.
In accordance with EPA Manual 2750, your offices provided acceptable planned corrective actions and
estimated milestone dates in response to the OIG's recommendations. All recommendations are resolved,
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 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
Lynnann Hitchens, Acting Principal Deputy Assistant Administrator
Office of Mission Support
We will post this report to our website at www.epa.gov/oig.
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EPA's Fiscal Year 2020 Fourth-Quarter
Compliance with the Digital Accountability
and Transparency Act of 2014
22-P-0001
Table of C
Chapters
1 Introduction 1
Purpose 1
Background 1
Responsible Offices 4
Scope and Methodology 4
Prior Reports 5
Assessment of Internal Controls and Compliance with Laws and Regulations 5
2 EPA Complied with DATA Act, but Errors Affected Data Quality 7
Timeliness of Agency Submissions 7
Completeness of Summary-Level Data: Files A and B 7
Completeness of Agency Submissions 7
Suitability of File C for Sample Selection 8
Results of Linkages from File Cto Files B, Dl, and D2 8
COVID-19 Outlay Testing: Nonstatistical Sample 8
Sample Results for Files C, Dl, and D2 8
Testing Limitations for Data Reported from Files E and F 11
Supplemental Results 12
Implementation and Use of Data Standards 18
Conclusions 18
Recommendations 18
Agency Response and OIG Assessment 19
Status of Recommendations 20
Appendixes
A Key Definitions from the CIGIE DATA Act Guide 21
B DAIMS Information Flow Diagram 22
C OMB Guidance 23
D CIGIE's DATA Act Anomaly Letter 25
E Sampling Methodology 27
F Standardized Data Element Reporting 29
G Comparative Results Table 31
H Agency Response to Draft Report 33
I Distribution 36
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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency's Office of Inspector General initiated this audit to determine
whether the Agency's submission of financial and award data for the fourth quarter of fiscal year 2020
complied with the Digital Accountability and Transparency Act of 2014 and to assess the:
• Completeness, accuracy, timeliness, and quality of the financial and award data submitted for
publication on USAspending.gov.
• EPA's implementation and use of the governmentwide financial data standards established by
the Office of Management and Budget and the U.S. Department of the Treasury.
Top Management Challenges Addressed
This audit addresses the following top management challenges for the Agency in fiscal year 2021, 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 (data quality).
• Fulfilling mandated reporting requirements.
Background
DATA Act: Overview
The DATA Act (Pub. L. 113-101), signed into law on May 9, 2014, requires federal agencies to report
financial and award data in accordance with the established governmentwide financial data standards.
The DATA Act expands the Federal Funding Accountability and Transparency Act of 2006 by "disclosing
direct Federal agency expenditures and linking Federal contract, loan, and grant spending information to
programs of Federal agencies to enable taxpayers and policy makers to track Federal spending more
effectively." To facilitate implementation of the DATA Act, the OMB and the Treasury issued guidance on
57 data definition standards, commonly called data elements, and required federal agencies to report
financial data in accordance with these standards beginning in May 2017. In addition, the OMB and the
Treasury created the DATA Act Information Model Schema, or DAIMS, to be "the authoritative source for
the terms, definitions, formats and structures for hundreds of distinct data elements, which tell the
story of how federal dollars are spent."1 The DAIMS version 2.0 Information Flow Diagram in Appendix B
of this report identifies the files that agencies must submit under the DATA Act, how often these files
must be submitted, and the process by which these files are validated and uploaded to the public
website and database.
In April 2020, the OMB issued Memorandum M-20-21, Implementation Guidance for Supplemental
Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19), which requires agencies that
receive COVID-19 supplemental relief funding to submit Files A, B, and Cto the Treasury's DATA Act
1 DAIMS version 2.0, "Overview," October 2, 2018.
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Broker on a monthly basis beginning with the June 2020 reporting period. These monthly submissions
must include a running total of outlays for each award in File C funded with COVID-19 supplemental
relief funds. In addition, the OMB and the Treasury added two data elements—for a total of 59—to the
DATA Act reporting requirements to promote full and transparent reporting of COVID-19 spending.
The EPA, which receives COVID-19 supplemental relief funds, is required to submit spending data
monthly in the files shown in Table 1. The EPA submits data for Files A, B, and C from its financial system
to the Broker, which then runs a series of validations and produces warnings and error reports for the
Agency to review. The Broker also extracts procurement and financial assistance data from the award
submissions to populate Files Dl, D2, E, and F.
Table 1: DATA Act submissions*
File name
File contents
File description
EPA-uploaded data from Agency financial system
File A
Appropriations Account Detail
Includes fiscal year cumulative federal appropriation account
summary-level data.
File B
Object Class and Program
Activity Detail
Includes fiscal year cumulative federal object class and program
activity summary-level data.
FileC
Award Financial Detail
Includes the obligation amounts for awards made and/or modified
during the reporting period.
Broker-extracted data from external award systems
File D1
Award and Awardee Attributes
(Procurement)
Contains detailed information for record-level procurement
transactions reported in File C.
File D2
Award and Awardee Attributes
(Financial Assistance)
Contains detailed information for record-level financial assistance
transactions reported in File C.
File E
Additional Awardee Attributes
Contains detailed information for record-level transactions reported in
File C.
File F
Sub-Award Attributes
Contains detailed information for record-level transactions reported in
File C.
Source: OIG analysis of the CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act, issued
December 4, 2020. (EPA OIG table)
* The EPA-uploaded data are submitted from the EPA's financial system. The Broker-extracted data are
submitted by external award reporting systems to the Broker.
The chief financial officer is the Agency's senior accountable official. The senior accountable official
certifies the EPA's DATA Act submissions to attest that the Agency's internal controls provide assurance
that the data are valid and reliable. The certified data are displayed on USAspending.gov.
USAspending.gov Figure 1 illustrates how information from agencies is collected and
USAspending.gov is the official made available to the public,
depository for spending data for the
U.S. government. It shows the
American public how taxpayer money
is being used.
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Figure 1: Operation of the Broker for monthly submissions
DATA Act Broker
File D1 is
extracted from the
Federal Procurement
Data System
(FPDS-NG)
Checks include field length
and data type to help ensure
consistency and comparability
of data
Validation of data
in selected Files
Agency
certification
File D2 from the Award
Submission Portal (ASP)
File E from the System for Award
Management (SAM)
File F from the Federal Funding
Accountability and Transparency Act
Subrecipient Reporting System (FSRS)
Senior Accountable Officials (SAO)
document their assurance of data
reliability and accuracy
Trt
d«
Treasury
tabase
Storage architecture designed to hold
data extracted from transactional
systems, operational data stores, and
external sources
~
~
Data submission from
agencies
Data extracted from existing
award data system
Beta.USAspending.gov
Source: U.S. Government Accountability Office, GAO-18-138, OMB, Treasury, and Agencies Need
to Improve Completeness and Accuracy of Spending Data and Disclose Limitations, November 8,
2017. (Government Accountability Office image)
DATA Act: OIG Requirements
The DATA Act requires each federal agency's OIG to review a statistically valid sample of the spending
data and to submit a report to Congress assessing the completeness, accuracy, timeliness, and quality of
the data sampled, as well as the implementation and use of the data standards.
The Council of the Inspectors General on Integrity and Efficiency's Federal Audit Executive Council DATA
Act Working Group released its updated CIGIE FAEC Inspectors General Guide to Compliance under the
DATA Act on December 4, 2020. This guide, hereafter referred to as the CIGIE DATA Act Guide, provides
a common methodology and reporting approach to use in performing work mandated by the DATA Act.
We conducted our audit in accordance with the CIGIE DATA Act Guide.
OMB Guidance
The OMB issued several memorandums regarding transparency in federal spending and, more
specifically, DATA Act implementation and guidance. The OMB issued additional memorandums in 2020
to provide guidance for and oversight of COVID-19 spending. We provide a comprehensive list of OMB
guidance considered during our audit in Appendix C.
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DATA Act Date Anomaly
CIGIE identified a timing anomaly with the oversight requirements contained in the DATA Act. That is,
the first inspector general reports were due to Congress in November 2016; however, federal agencies
were not required to report spending data until May 2017. To address this reporting date anomaly, the
inspectors general provided Congress with their first required reports by November 8, 2017, one year
after the statutory due date, with subsequent reports to be submitted on a two-year cycle. This report is
the third and final report required under the DATA Act.
On December 22, 2015, CIGIE's chair issued a letter detailing the strategy for dealing with the inspector
general reporting date anomaly and communicated the strategy to the Senate Committee on Homeland
Security and Governmental Affairs and the House Committee on Oversight and Government Reform. We
include that letter in Appendix D of this report.
Responsible Offices
The EPA's Office of the Chief Financial Officer maintains responsibility for the EPA's implementation of
the DATA Act. The chief financial officer is the senior accountable official who approves and provides
assurance that the DATA Act submissions are valid and reliable. EPA offices responsible for DATA Act file
submissions include the Office of the Controller and the Office of Mission Support's Office of Acquisition
Solutions and Office of Grants and Debarment.
Scope and Methodology
We conducted this performance audit from January through November 2021 in accordance with
generally accepted government auditing standards issued by the Comptroller General of the United
States. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings and conclusions based on our
audit objectives.
To accomplish our objectives, the audit team sought to:
• Obtain an understanding of any regulatory criteria related to the EPA's responsibilities to report
financial and award data under the DATA Act.
• Review the EPA's Data Quality Plan.
• Assess the internal controls and information system controls in place as they relate to the
extraction of data from the source systems and the reporting of data to the Broker to determine
audit risk and design audit procedures.2
• Review and reconcile the FY 2020 fourth-quarter summary-level data submitted by the EPA for
publication on USAspending.gov.
2 OMB Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal Control, July 15,
2016. OMB Circular A-123, Appendix A, "Management of Reporting and Data Integrity Risk," June 6, 2018.
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• Review a statistically valid sample of financial and award data submitted by the EPA for
publication on USAspending.gov for the quarter selected.
• Assess the completeness, accuracy, timeliness, and quality of the financial and award data
sampled.
• Assess the EPA's implementation and use of the 59 data elements established by the OMB and
the Treasury.
We selected 239 records for data element testing based on the EPA's DATA Act submissions of
7,551 fourth-quarter FY 2020 records, in accordance with the sampling methodology outlined in
Appendix E of this report. We used stratified random sampling to select the records to test.
Prior Reports
The EPA OIG conducted two prior audits of the EPA's DATA Act submissions and issued the following
two reports, as required by the Act:
• EPA OIG Report No. 18-P-0037, EPA Reported Its Fiscal Year 2017 Second Quarter Financial and
Award Data in Accordance With the DATA Act, issued November 9, 2017, found that the EPA
assessed the completeness, accuracy, timeliness, and quality of the FY 2017 second-quarter
financial and award data submitted for publication on USAspending.gov. The EPA also
implemented governmentwide financial data standards established by the OMB and the
Treasury.
• EPA OIG Report No. 20-P-0026. EPA's Fiscal Year 2019 First Quarter Compliance with the Digital
Accountability and Transparency Act of 2014, issued November 8, 2019, found that the EPA's
first-quarter financial and award data were of "higher" quality, as defined by the highest error
rate found in testing the completeness, accuracy, and timeliness of data submitted. While we
found reporting errors and some issues with documentation of policies and procedures, the EPA
complied, overall, with the requirements of the DATA Act; submitted financial and award data to
the Treasury Broker on time; and implemented data standards as defined by the OMB and the
Treasury.
Assessment of Internal Controls and Compliance with Laws and
Regulations
As detailed in OIG Report No. 21-F-0014, EPA's Fiscal Years 2020 and2019 (Restated) Consolidated
Financial Statements, issued November 16, 2020, our FY 2020 audit of the EPA's financial statements
assessed Compass, the Agency's financial management system. We partially relied on internal control
testing conducted for the EPA's FY 2020 financial statement audit, and we believe that the EPA's internal
controls related to the DATA Act are effective and that the Agency can certify with reasonable assurance
that the data are complete, accurate, and timely. During the financial statement audit, no material
weaknesses or management challenges were found that would impact the internal controls that the EPA
relies on for the DATA Act.
We assessed internal controls and compliance with laws and regulations necessary to satisfy the
objective of this audit. In particular, we assessed the following related internal control components and
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underlying principles, as set forth in the U.S. Government Accountability Office's Standards for Internal
Control in the Federal Government, dated September 2014:
• Control environment: "Management should establish an organizational structure, assign
responsibility and delegate authority to achieve the entity's objectives."
• Control activities: "Management should design the entity's information system and related
control activities to achieve objectives and respond to risks."
• Control activities: "Management should implement control activities through policies."
• Information and Communication: "Management should use quality information to achieve the
entity objectives."
Our audit was limited to these internal control components and underlying principles; accordingly, our
audit may not have detected all internal control deficiencies that may have existed at the time of this
audit.
The Broker interfaces with Compass through the DATA Act Evaluation and Approval Repository, a tool
that extracts, transforms, and prepares data. The EPA also uses the DATA Act Evaluation and Approval
Repository to reconcile data and validate DATA Act Files A, B, and C for submission to the Broker. The tool
performs edit checks and generates exception reports. The validation checks and warning lists produced
by the DATA Act Evaluation and Approval Repository must be addressed before the data can be
submitted to the Broker. The generation of these files and the Agency's correction of file warnings show
the effectiveness of the internal controls related to the DATA Act Evaluation and Approval Repository.
Enterprise Risk Management Plan
The EPA's risk profile for 2020 lists human capital, pollutants/contaminants, and aging infrastructure as
the Agency's enterprise risks. These risks have no direct impact on controls over DATA Act source
systems and reporting.
DATA Act Assurance Statement
The Environmental Protection Agency DATA Act Assurance Statement and DATA Act Evaluation and
Approval Repository Certification, FY 2020, 4th Quarter, revised March 2021, certified that the Agency
complied with the OMB's guidance to manage risks and maintain effective internal controls to support
the reliability and validity of the Agency's account-level and award-level data. Along with the
certification of compliance, the Agency's statement documented certain source data anomalies,
including historical program activity code and budget class levels noncompliance, timing issues, data
entry errors, and business process limitations.
Data Quality Plan
Pursuant to OMB A-123, Appendix A, "Management of Reporting and Data Integrity Risk," agencies were
required to develop a Data Quality Plan in FY 2019. The EPA finalized its Data Quality Plan on
September 30, 2019. We concluded that the Data Quality Plan meets the requirements outlined in the
CIGIE guide.
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Chapter 2
EPA Complied with DATA Act,
but Errors Affected Data Quality
The EPA has substantially complied with the requirements of the DATA Act and submitted financial and
award data to the Treasury's DATA Act Broker on time. Our nonstatistical and statistical tests of the
EPA's DATA Act submissions—including those tests that assessed the data attributes of completeness,
accuracy, and timeliness—determined that the EPA's FY 2020 fourth-quarter data published on
USAspending.gov was of "higher" quality. We found, however, that the EPA had not fully implemented
the data standards as defined by the OMB and the Treasury. We identified specific data inconsistencies
and control deficiencies that indicate the EPA could improve its internal controls over implementing
data standards and preparing its DATA Act submissions.
Timeliness of Agency Submissions
We evaluated the EPA's FY 2020 fourth-quarter DATA Act submissions to the Broker and determined
that the submissions were timely. We also noted that the senior accountable official's certification of
the data was timely. Although the Agency had to resubmit and recertify its FY 2020 fourth-quarter
submissions on March 5, 2021, the submissions are still considered timely because the original
publications and certification were timely. To be considered timely, DATA Act submissions must follow
the reporting schedule established by the Treasury's Program Management Office and be certified by
the senior accountable official traditionally within 45 days of the end of the corresponding quarter.
Completeness of Summary-Level Data: Files A and B
We performed summary-level data reconciliations and linkages for Files A and B and identified
variances. Specifically, the dollar amounts in Files A and B were not equal because some dollar amounts
were shown in one file as outlays and in the other as obligations. Also, some dollar amount differences
resulted from mapping issues between direct and reimbursable attributes.
The Agency adequately explained how it reviews the errors and reconciles Files A and B both with one
another and with Standard Form 133, Report on Budget Execution and Budgetary Resources. The
Standard Form 133 is a quarterly report that contains information on the sources of budget authority
and the status of budgetary resources by individual fund or appropriation. Based on the immateriality of
the variances identified, we determined that the variances would not have an adverse impact on the
overall quality of DATA Act submissions.
Completeness of Agency Submissions
We evaluated the EPA's DATA Act submissions to the Broker and determined that they were complete.
We evaluated Files A, B, and C to determine that all transactions and events that should have been
recorded were recorded in the proper period.
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Suitability of File C for Sample Selection
We determined that File C was suitable for sampling. The EPA uses the DATA Act Evaluation and Approval
Repository to simulate the Broker submissions in advance of the Broker submission due date, which
allows the EPA to determine the validity of its data, resolve any fatal errors, and address warnings.
Results of Linkages from File C to Files B, D1, and D2
We tested the linkages between Files C and B by Treasury Account Symbol, object class, and program
activity. All of the Treasury Account Symbol, object class, and program activity data elements from File C
existed in File B.
In addition, we tested the linkages between Files C and D1 by both the Procurement Instrument
Identifier Number and the Parent Award ID, as well as between Files C and D2 by the Federal Award
Identification Number. We identified the following variances:
• 339 records in File C that were not reported in File Dl.
• 347 records in File C that were not reported in File D2.
• 204 records in File Dl that were not reported in File C.
• 92 records in File D2 that were not reported in File C.
Based on our test results, we determined that File C did not align properly with Files Dl and D2. As
reported in the EPA's internal analysis and referenced by the EPA's FY 2020 fourth-quarter Assurance
Statement, these variances were primarily caused by timing issues, business processes, data entry
errors, system errors, and purchase card use issues. We determined that the variances would not have
an adverse impact on the overall quality of the DATA Act submission. The File C variations comprised
less than 5 percent of the total Files Dl and D2 populations. Based on our analysis, we determined that
File C was suitable for sample testing.
COVID-19 Outlay Testing: Nonstatistical Sample
We identified and tested two File C COVID-19 outlay records from the EPA's FY 2020 fourth-quarter
DATA Act submissions. Our testing included assessing the Parent Award ID, Procurement Instrument
Identifier Number or Federal Award Identification Number, object class, appropriations account,
obligation, program activity, outlay, and Disaster Emergency Fund Code of File C COVID-19 outlay
records for completeness, accuracy, and timeliness. We found that the File C outlays were 83.3 percent
complete, accurate, and timely. This was a test of 100 percent of the population of COVID-19 outlays.
Sample Results for Files C, D1, and D2
We selected a stratified random sample of 239 records from File C, including 134 contracts and
105 grants. These samples consisted of up to 47 data elements for contract testing and up to 45 data
elements for grant testing for the attributes of completeness, accuracy, and timeliness. We define these
attributes in Appendix A of this report.
We found that four of the 134 contract samples extracted from File C did not have a corresponding
File Dl record. We determined that the financial system transactions for these samples were not timely.
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We found that four of the 105 grant samples extracted from File C did not have a corresponding File D2
record. As a result, the required File D2 data elements for these four samples are considered errors for
completeness, accuracy, and timeliness.
Projected Error Rate Calculation
We projected error rates for the attributes of completeness, accuracy, and timeliness. Projected error
rates estimate the number of errors in all DATA Act records. These projected error rates are
automatically calculated using embedded formulas in the CIGIE DATA Act Guide, Attachment 3, "Testing
Spreadsheet."
The total projected error rate by attribute is calculated using the formula expressed in Figure 2 and is
presented as a percentage.
Figure 2: Formula to calculate attribute error rate
Sum of Error Rates for Attribute at the Record Level
¦T- Total Number of Sample Records
= Total Projected Error Rate for Attribute
Source: CIGIE DATA Act Guide, Attachment 3, "Testing Spreadsheet." (EPA OIG image)
All error rates for the attributes of completeness, accuracy, and timeliness at the data element-level can
be found in Appendix F of this report.
Completeness of Data Elements
A data element is complete if the required data element that should have been reported was reported
in the appropriate Files A through D2. The projected error rate for completeness of data elements is
2.48 percent.3 Based on a 95-percent confidence level, the projected error rate for the completeness of
the data elements is between 0.95 percent and 5.34 percent.
We found that the primary reasons for completeness errors were grant samples that were missing from
File D2 and grant samples that were missing data for four data elements: Funding Agency Name,
Funding Agency Code, Funding Sub Tier Agency Name, and Funding Sub Tier Agency Code. These four
data elements should have been derived from Funding Office Code.
Accuracy of Data Elements
A data element is accurate when amounts and other data relating to reported transactions:
• Were recorded in accordance with the DAIMS version 2.0 Reporting Submission Specification,
the DAIMS version 2.0 Interface Definition Document, and the USAspending.gov online data
dictionary.
• Agree with the originating award documentation/contract file.
3 Calculated based on the formula presented in Figure 2. The sum of error rates at the record level is
593.35 percent, and the total number of sample records is 239.
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The projected error rate for accuracy of data elements is 7.73 percent.4 Based on a 95-percent
confidence level, the projected error rate for the accuracy of the data elements is between 4.9 percent
and 12.06 percent.
We found a variety of errors in the contract and grant samples. Accuracy errors are detailed in the
"Supplemental Results" section below.
Timeliness of Data Elements
Timeliness of data elements is based on reporting schedules defined by the financial, procurement, and
financial assistance requirements outlined in the Federal Funding Accountability and Transparency Act
of 2006; Federal Acquisition Regulation; Federal Procurement Data System - Next Generation, or FPDS-
NG; Financial Assistance Broker Submission; and DAIMS. The projected error rate for the timeliness of
data elements is 6.25 percent.5 Based on a 95-percent confidence level, the projected error rate for the
timeliness of the data elements is between 3.6 percent and 10.08 percent.
We found that the primary reason for timeliness errors in the contract samples was late submission of
contract records. The primary reasons for timeliness errors in the grant samples were the failure to
submit grant records and the late submission of grant records.
Overall Determination of Quality
The CIGIE DATA Act Guide defines quality of data as "data that is complete, accurate, timely, and
includes statistical and non-statistical testing results." A quality determination is based on several
factors, including timeliness of the DATA Act submissions to the Broker; completeness of summary-level
data; the suitability and use of File Cfor sample selection; the connections between files; and attribute
testing for sample records, including COVID-19 outlay testing. Table 2 provides ranges of levels used in
determining the overall quality of the data elements.
Table 2: Quality level
Range
Level
0
69.999
Lower
70
84.999
Moderate
85
94.999
Higher
95
100
Excellent
Source: CIGIE DATA Act Guide. (CIGIE table)
Based on the results of our statistical and nonstatistical testing for the EPA's DATA Act audit for FY 2020
quarter four, the EPA scored 92.65 points, which is a quality rating of "higher" (Figure 3).
4 Calculated based on the formula presented in Figure 2. The sum of error rates at the record level is
1846.44 percent, and total number of samples is 239.
5 Calculated based on the formula presented in Figure 2. The sum of error rates at the record level is
1492.79 percent, and the total number of samples is 239.
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Figure 3: Quality Scorecard
Environmental Protection Agency
Maximum Points Possible
FY 2021 DATA Act
Quality Scorecard
Without Outlays
(No COVID-19
Funding)
With Outlays
(COVID-19
Funding)
Criteria
Score
Non-Statistical
Timeliness of Agency
Submission
5.0
5.0
5.0
Completeness of
Summary
Level Data (Files A & B)
8.9
13.0
10.0
Suitability of File C for
Sample Selection
9.0
13.0
10.0
Record-Level Linkages
(Files C & D1/D2)
6.8
9.0
7.0
COVID-19 Outlay Testing
Non-Statistical Sample
6.7
0.0
8.0
Statistical
Completeness
14.6
15.0
15.0
Accuracy
27.7
30.0
30.0
Timeliness
14.1
15.0
15.0
Quality
Score
Higher
92.65
100.0
100.0
Source: OIG data input into the CIGIE DATA Act Guide, Attachment 4, "Quality
Scorecard." (CIGIE spreadsheet; EPA OIG data)
Testing Limitations for Data Reported from Files E and F
File E of the DAIMS contains additional awardee attribute information that the Broker extracts from the
System for Award Management, SAM.gov, the official government website for people who make,
receive, and manage federal awards. File F contains subaward attribute information the Broker extracts
from the Federal Funding Accountability and Transparency Act of 2006 Subaward Reporting System.
Files E and F data remain the responsibility of the awardee in accordance with the terms and conditions
of federal agreements, and the quality of these data remains the legal responsibility of the recipient.
Therefore, agency senior accountable officials are not responsible for certifying the quality of Files E and F
data reported by awardees, but they are responsible for assuring controls are in place to verify that grant
awardees register in SAM.gov at the time of the award. As such, we did not assess the completeness,
accuracy, timeliness, and quality of the data extracted from SAM.gov and the Federal Funding
Accountability and Transparency Act of 2006 Subaward Reporting System via the Broker.
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Supplemental Results
We identified the following significant issues during data element testing of information reported to
USAspending.gov for contracts and grants. Comprehensive error rates for each data element can be
found in Appendix F of this report. Appendix G of this report includes comparative results for data
element accuracy errors from FY 2019 and FY 2021 audit results. The error rates reported in
Appendixes F and G are based on all samples, whereas the error rates in this section are calculated
separately for contract and grant samples.
Data Element Analysis: Contract Samples
Figure 4 depicts accuracy error rates over 10 percent for the contract samples, illustrating the specific
data element issues encountered during our audit.
Figure 4: Data element accuracy error rates over 10 percent in contract samples
0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0%
Error Rate
Source: OIG analysis of contract samples. (EPA OIG image)
Note: DE = Data Element
Ultimate Parent Legal Entity Name
We tested the accuracy of the Ultimate Parent Legal Entity Name by comparing the File D1 Broker data
with the data in SAM.gov at the time of the award or modification. The Ultimate Parent Legal Entity
Name is extracted from SAM.gov based on the Awardee/Recipient Unique Identifier, a nine-digit number
assigned by Dun & Bradstreet.
Midway through our audit testing, beta.SAM.gov was merged with SAM.gov, and the source for
Ultimate Parent Unique Identifier and Ultimate Parent Legal Entity Name was removed from the site. As
a work-around, OIGs were instructed to access Dun & Bradstreet's website, dnb.com. On dnb.com, we
searched by the Awardee/Recipient Unique Identifier. The "Related Companies" section lists the name of
the ultimate parent in the case of a subsidiary. If the entity is neither a subsidiary nor a parent, the
website indicates "Independent." We then looked up the Ultimate Parent Unique Identifier to determine
whether the name in the Ultimate Parent Legal Entity Name field matched the Ultimate Parent Unique
Identifier. In the few cases we were unable to verify this information, we marked the data element "not
applicable" for that record.
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We tested the Ultimate Parent Legal Entity Name of 130 contracts and found 30 accuracy exceptions, an
error rate of 23.1 percent.6 Exceptions to this data element are not attributable to the Agency. In
comparison, the error rate for Ultimate Parent Legal Entity Name in contract samples during the
2019 audit period was 7.5 percent.
Legal Entity Address
For contracts, the Federal Acquisition Regulation at 48 C.F.R. § 4.1102 generally provides that "[ojfferors
and quoters are required to be registered in SAM at the time an offer or quotation is submitted." The
CIGIE DATA Act Guide states, "This must be the physical address at time of award for the transaction
being reviewed. ... If the vendor has changed physical address in SAM, it is the responsibility of the
awarding Agency to process the modification to update agency documentation."
Contract data are input in the EPA's contract acquisitions system and then transferred to FPDS-NG for
reporting on USAspending.gov. On original—that is, base or new—contracts, FPDS-NG extracts the Legal
Entity Address from SAM.gov. For amended contracts, FPDS-NG does not access SAM.gov.
We tested the accuracy of Legal Entity Address for the contract samples by comparing the File D1 Broker
data with the award system data and then verifying the address with SAM.gov. When the address in
SAM.gov did not match File Dl, we reviewed the historic record on SAM.gov and compared it with the
base contract in the EPA's contract acquisitions system. When the historic record on SAM.gov matched
the base contract, we did not attribute the exception to the Agency. When the historic record on
SAM.gov did not match the base contract, we attributed the exception to the Agency. We also identified
errors when the address in the award system was a post office box instead of a physical address.
We tested the Legal Entity Address of 130 contracts and found 33 accuracy exceptions, an error rate of
25.4 percent.7 We determined that 24 of these exceptions were attributable to the Agency, while nine
were not. In comparison, the error rate for Legal Entity Address in contract samples during the
2019 audit period was 9.9 percent.
Award Description
OMB Memorandum M-18-16 directs agencies to report Award Descriptions in "plain English." The
DAIMS version 2.0 Interface Definition Document defines Award Description as a "brief description of
the purpose of the award." We found that the Agency used jargon, acronyms, and technical terminology
that may be difficult for people outside of the Agency to understand. We also found that the Agency did
not always describe the purpose of the award and sometimes only described the purpose of a
modification (in other words, an increase or decrease in funding).
6 Of the 134 contract samples extracted from File C, four samples did not have corresponding File Dl records. This
data element is located in File Dl; therefore, the number of contracts tested for this data element is 130.
7 Of the 134 contract samples extracted from File C, four samples did not have corresponding File Dl records. This
data element is located in File Dl; therefore, the number of contracts tested for this data element is 130.
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We tested the Award Description of 130 contracts and found 42 accuracy exceptions, an error rate of
32.3 percent.8 In comparison, the error rate for Award Description in contract samples during the
2019 audit period was 0.8 percent.
Program Activity
We compared the assigned Program Activity with the Award Description to determine reasonableness.
When the Award Description for a modification was unclear, we reviewed the Award Description for the
base contract.
We tested the Program Activity of 134 contracts and found 34 exceptions, an error rate of 25.4 percent.
In comparison, the error rate for Program Activity in contract samples during the 2019 audit period was
2.1 percent.
Data Element Analysis: Grant Samples
Figure 5 depicts accuracy error rates over 10 percent for the grant samples, illustrating the specific data
element issues encountered during the audit.
Figure 5: Data element accuracy error rates over 10 percent in grant samples
DE 1 Awardee/Recipient Legal Entity Name
DE 5 Legal Entity Address
DE 16 Award Type
DE 20 CFDA Title
£ DE 30 Primary Place of Performance Address 40.0%
-------
We tested the accuracy of Awardee/Recipient Legal Entity Name in grant samples by comparing the
File D2 Broker data with the grants management system and verifying that name with SAM.gov. Any
exceptions are attributable to the Agency.
We tested the Awardee/Recipient Legal Entity Name of 105 grants and found 55 exceptions, an error
rate of 52.4 percent. In comparison, the error rate for Awardee/Recipient Legal Entity Name in grant
samples during the 2019 audit period was 36.3 percent.
Legal Entity Address
The Legal Entity Address must be identical to SAM.gov at the time of the grant award and any award
modification. Grant data are input in the agencies' grants management systems and transferred to the
Financial Assistance Broker Submission for reporting on USAspending.gov. Agencies are responsible for
ensuring that award-level data in their systems match data on SAM.gov at the time of the award and
any modification.
We tested the accuracy of Legal Entity Address for grant samples by comparing the File D2 Broker data
with the grants management system and verifying the address with SAM.gov. Any exceptions are
attributable to the Agency.
We tested the Legal Entity Address of 105 grants and found 92 exceptions, an error rate of 87.6 percent.
In comparison, the error rate for Legal Entity Address in grant samples during the 2019 audit period was
57.5 percent.
Award Type
Award Type comprises Assistance Type, which is a numerical value identifying the type of assistance, and
Assistance Type Description Tag, which is a text field. Assistance Type is extracted from the Financial
Assistance Broker Submission to File D2, and Assistance Type Description Tag is derived from Assistance
Type.
We tested the accuracy of Award Type by comparing the File D2 Broker data for Assistance Type and
Assistance Type Description Tag with the related field for the original grant in the Agency's grants
management system.
The DAIMS version 2.0 Reporting Submission Specification lists ten acceptable values each for Assistance
Type and Assistance Type Description Tag. We found that the Agency's grants management system does
not include a field for Assistance Type. The Agency used only two values for Assistance Type Description
Tag: one is listed as an acceptable value and one is not listed as an acceptable value in the DAIMS
version 2.0 Reporting Submission Specification.
We tested the Award Type of 105 grants and found 61 exceptions, an error rate of 58.1 percent. In
comparison, the error rate for Award Type in grant samples during the 2019 audit period was
82.5 percent.
Catalog of Federal Domestic Assistance Title
The Catalog of Federal Domestic Assistance Title, or CFDA Title, is derived from CFDA Number. The
Financial Assistance Broker Submission downloads and integrates the information from SAM.gov into its
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internal validation tables. DAI MS version 2.0 Practices and Procedures, Appendix F, "Update Cadence for
Data Sources/' required agencies to update "CFDAs on an annual basis."
To test this data element, we researched the CFDA Number on SAM.gov, compared the corresponding
CFDA Title with the CFDA Title in File D2, and noted inaccuracies.
We tested the CFDA Title of 105 grants and found 14 exceptions, an error rate of 13.3 percent. In
comparison, the error rate for CFDA Title in grant samples during the 2019 audit period was 52.5 percent.
Primary Place of Performance Address
Primary Place of Performance Address comprises Primary Place of Performance City Name, Primary
Place of Performance State Name, and Primary Place of Performance ZIP+4.
We tested the accuracy of Primary Place of Performance Address by comparing the File D2 Broker data
with the Agency's grants management system. We found that Primary Place of Performance Address
was often presented inconsistently.
We tested the Primary Place of Performance Address of 105 grants and found 42 exceptions, an error
rate of 40.0 percent. In comparison, the error rate for Primary Place of Performance Address in grant
samples during the 2019 audit period was 77.5 percent.
Primary Place of Performance Congressional District
Primary Place of Performance Congressional District is extracted from the Financial Assistance Broker
Submission to File D2. We tested this data element by inputting the ZIP code from the authoritative
source for the Primary Place of Performance Address, which is the Agency's grants management system,
on House.gov and comparing the resulting congressional district with that in File D2.
We tested the Primary Place of Performance Congressional District of 105 grants and found
37 exceptions, an error rate of 35.2 percent. In comparison, the error rate for Primary Place of
Performance Congressional District in grant samples during the 2019 audit period was 57.0 percent.
Business Types
Business Types comprises two components: Business Types, which is an alphabetical value identifying
the type of business, and Business Types Description Tag, which is a text field. Business Types is
extracted from the Financial Assistance Broker Submission to File D2, and Business Types Description
Tag is derived from Business Types.
We tested the accuracy of Business Types by comparing the File D2 Broker data for Business Types and
Business Types Description Tag with the related field in the Agency's grants management system.
The DAIMS version 2.0 Reporting Submission Specification lists 24 acceptable values each for Business
Types and Business Types Description Tag. We found that the Agency's grants management system does
not include a specific field for Business Types. The Agency did not use the acceptable values for Business
Types Description Tag but in most cases used similar values.
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We tested the Business Types of 105 grants and found 41 exceptions, an error rate of 39.0 percent. In
comparison, the error rate for Business Types in grant samples during the 2019 audit period was
35.0 percent.
Funding Agency and Sub Tier Agency Names and Codes
Funding Agency Name, Funding Agency Code, Funding Sub Tier Agency Name, and Funding Sub Tier
Agency Code are derived from Funding Office Code. We identified 22 instances in which the Funding
Office Code field was populated but the other four data elements were blank.
We tested the Funding Agency Name, Funding Agency Code, Funding Sub Tier Agency Name, and
Funding Sub Tier Agency Code of 81 grants and found 22 exceptions, an error rate of 27.2 percent for
each of these four data elements.9 In comparison, the error rate for Funding Agency Name and Funding
Agency Code in grants during the 2019 audit period was 100 percent. Funding Sub Tier Agency Name
and Funding Sub Tier Agency Code were not applicable to any samples tested during the 2019 DATA Act
audit because those data elements were optional at that time.
Awarding Office Code
We found that the Awarding Office Code in the Agency's grants management system does not match
the values in the Federal Hierarchy, which is a directory that establishes relationships between each
department's or independent agency's sub-tiers and offices. The Federal Hierarchy is used by federal
agencies as the authoritative source for managing and referencing federal funding and awarding
organizations.
We tested the Awarding Office Code of 105 grants and found 20 exceptions, an error rate of
19.0 percent. In comparison, the error rate for Awarding Office Code in grant samples during the
2019 audit period was 100 percent.
Analysis of the Accuracy of Dollar-Value-Related Data Elements
Our analysis of the accuracy of dollar-value-related data elements for financial assistance samples
revealed:
• Three dollar-value exceptions totaling $741,652 in Non-Federal Funding Amount. We found that
state and other contributions were not included in File D2.
• Two dollar-value exceptions totaling $75,641 in Federal Action Obligation. These grant
transactions were not recorded in the Agency's grants management system and did not have
any dollar amount reported in File D2.
• Five dollar-value exceptions totaling $817,293 in Amount of Award.
9 These data elements were not applicable for 24 grant samples that were issued before October 1, 2018. The
Funding Office Code field, from which these four data elements are derived, was not required for grants issued
before October 1, 2018.
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Analysis of Errors in Data Elements Not Attributable to the Agency
Our analysis of errors in data elements not attributable to the Agency revealed:
• Ultimate Parent Legal Entity Name is extracted from SAM.gov based on the Awardee or
Recipient Unique Identifier. The Agency does not record this information, nor does it have
control over these data. The 30 exceptions we found are thus not attributable to the Agency.
• Legal Entity Address errors in the contract samples are attributable to the Agency if the File D1
address at the action date of the base contract does not match the Agency system and SAM.gov.
Errors are not attributable to the Agency if the File D1 address at the action date of the base
contract matches the Agency system and SAM.gov. We found that nine of the 33 contract errors
for this data element were not attributable to the Agency.
Implementation and Use of Data Standards
We evaluated the EPA's implementation and use of the governmentwide financial data standards for
spending information, as developed by the OMB and the Treasury. The EPA has not fully implemented
the data standards defined by the OMB and the Treasury. Internal control deficiencies affected the
accuracy of the Agency's submission of Files C, Dl, and D2. These deficiencies include the following:
• Management has not fully designed the entity's information system and related control
activities to achieve objectives and respond to risks.
• Management has not fully used quality information to achieve the entity's objectives.
In our analysis of data elements, we found that EPA systems do not allow for input of information as
required by the data standards. Additionally, we found inconsistencies in processing data that created
errors in terms of completeness, accuracy, and timeliness for DATA Act reporting purposes.
Conclusions
The EPA has substantially complied with the requirements of the DATA Act and submitted financial and
award data to the Treasury Broker on time. Our nonstatistical and statistical tests of the EPA's DATA Act
submissions—including those tests that assessed the data attributes of completeness, accuracy, and
timeliness—determined that the EPA's FY 2020 fourth-quarter data published on USAspending.gov were
of "higher" quality. We found, however, that the EPA had not fully implemented the data standards as
defined by the OMB and the Treasury. We identified specific data inconsistencies and control
deficiencies that indicate the EPA could improve internal controls over implementing data standards and
preparing its DATA Act submissions.
Recommendations
We recommend that the assistant administrator for Mission Support:
1. Update policies and procedures to require that Awardee/Recipient Legal Entity Name and Legal
Entity Address data elements match SAM.gov at the time of the award and any award
modifications for all contracts and grants. At the time of any award modification, update the
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Agency's contracts or grants management system and the Federal Procurement Data System
with any changes to these data elements.
2. Update policies and procedures to require that Award Descriptions be written in plain English
and that Award Descriptions for modifications explain the purpose of the contract, not merely
the purpose of the modification.
3. Update the EPA's grants management system to align with the data standards of the Digital
Accountability and Transparency Act of 2014, including all parts of data elements reported
therein, and to allow input only of the acceptable values outlined for each data element in DATA
Act Information Model Schema, Reporting Submission Specification.
4. Update the Catalog of Federal Domestic Assistance Titles on an annual basis, as required in
DATA Act Information Model Schema, Practices and Procedures, Appendix F, "Update Cadence
for Data Sources."
5. Provide training to improve consistency of data entry for all data elements, particularly Primary
Place of Performance Address and Award Description.
6. Include all categories for the Non-Federal Funding Amount data element—including the
Recipient, State, Local, and Other Contributions categories—in the EPA's grants management
system.
Agency Response and OIG Assessment
The EPA agreed with our six recommendations and provided acceptable planned corrective actions and
estimated completion dates. We consider the recommendations resolved with corrective actions
pending. The Agency's response can be found in Appendix H of this report.
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Status of Recommendations
RECOMMENDATIONS
Rec.
Page
Planned
No.
No.
Subject
Status1
Action Official
Completion Date
18 Update policies and procedures to require that Awardee/Recipient Legal
Entity Name and Legal Entity Address data elements match SAM.gov at
the time of the award and any award modifications for all contracts and
grants. At the time of any award modification, update the Agency's
contracts or grants management system and the Federal Procurement
Data System with any changes to these data elements.
19 Update policies and procedures to require that Award Descriptions be
written in plain English and that Award Descriptions for modifications
explain the purpose of the contract, not merely the purpose of the
modification.
Assistant Administrator for 10/31/22
Mission Support
Assistant Administrator for 3/31/22
Mission Support
19 Update the EPA's grants management system to align with the data
standards of the Digital Accountability and Transparency Act of 2014,
including all parts of data elements reported therein, and to allow input
only of the acceptable values outlined for each data element in DATA Act
Information Model Schema, Reporting Submission Specification.
19 Update the Catalog of Federal Domestic Assistance Titles on an annual
basis, as required in DATA Act Information Model Schema, Practices and
Procedures, Appendix F, "Update Cadence for Data Sources."
19 Provide training to improve consistency of data entry for all data elements,
particularly Primary Place of Performance Address and Award
Description.
19 Include all categories for the Non-Federal Funding Amount data
element—including the Recipient, State, Local, and Other Contributions
categories—in the EPA's grants management system.
Assistant Administrator for 9/30/23
Mission Support
Assistant Administrator for 9/30/22
Mission Support
Assistant Administrator for 4/30/22
Mission Support
Assistant Administrator for 3/31/22
Mission Support
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
Key Definitions from the CIGIE DATA Act Guide
Accuracy of Data Elements: Amounts and other data relating to reported transactions have been
recorded in accordance with the DAIMS, Reporting Submission Specification (RSS), Interface Definition
Document (IDD), and the online data dictionary, and agree with the original award
documentation/contract file.
Completeness of Agency Submission: Transactions and events that should have been recorded are
recorded in the proper period.
Completeness of Data Elements: For each of the required data elements that should have been
reported, the data element was reported in the appropriate Files A through D2.
Quality of Data: Data that is complete, accurate, and timely, and includes statistical and non-statistical
testing results.
Timeliness of Agency Submission: Reporting of the agency monthly or quarterly DATA Act submission to
the DATA Act Broker is in accordance with the schedule established by the Treasury DATA Act PMO.
Timeliness of Data Elements: For each of the required data elements that should have been reported,
the data elements were reported in accordance with the reporting schedules defined by the financial,
procurement, and financial assistance requirements (FFATA, FAR, FPDS-NG, Financial Assistance Broker
Submission (FABS), and DAIMS).
Note: PMO = Program Management Office.
FFATA = Federal Funding Accountability and Transparency Act of 2006.
FAR = Federal Acquisition Regulation.
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DAIMS Information Flow Diagram
Monthly or Quarterly Reporting - DATA Act Daily/Twice-Monthly Reporting - FFATA
OJ
3?
Award Linkage
Agency Uploaded Data (see note i)
(A)
Appropriations
Account
~~\
(B)
Object Class
and Program
Activity
(C)
Award
Financial
In accordance with SF 133/OMB Circular A-11/USS6L
Defined in the Reporting Submission
Specification (RSS)
Field-level validations for A, B, and C
¦
DATA Act Broker
Broker Extracted Data
Award and Awardee Attributes
(Dl) Award and Awardee Attributes
(Procurement)
(D2) Award and Awardee Attributes
(Financial Assistance]
(E) Additional Awardee Attributes
(F) Sub-award Attributes
Defined in the Interface Definition Document (IDD)
External Data Sets
- Defined In the Consumption
Focused Metadata (CFM)
Cross-file validation for A to D
"I
Agency-Certified Data
I
{
Award,
Sub-award,
and
Awardee
Attributes
(see note 2)
At least
Quarterly
Public Website and Database
Note 1: Agencies receiving COVID-19 supplemental funding must report three monthly submissions covering April, May, and June 2020 in July 2020. Afterwards, they must report all data on a monthly cadence. Agencies
that have not received any COVID-19 supplemental funding may continue to report quarterly until FY22 P02, when they must begin full monthly submissions.
Note 2: Dl and D2 pull in all award data associated with the funding or awarding agency and action dates as specified by the agency. E pulls in highly-compensated officer Information for DUNS numbers that appear In an kh4im4 vw%l0(1
agency's Dl and D2. F pulls in all sub-award data associated with the awards that appear In an agency's Dl and D2. m»v 6.2020
Note 3: Per OMB M-20-21, agencies should report non-loan financial assistance (including aggregates) to FABS at least twice a month (appropriately spacing apart the reporting dates), in each case reporting all issued-but-
yet-to-be-reported awards. Issued-but-yet-to-be-reported loans can continue to be reported on a monthly cadence; refer to the Practices & Procedures Section 2.1.1 for more information.
Source: DAIMS v 2.0, Information Flow Diagram (Department of the Treasury image)
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Appendix C
OMB Guidance
OMB Memorandum M-10-06, Open Government Directive, dated December 8, 2009, directs executive
departments and agencies to take specific actions to implement the principles of transparency,
participation, and collaboration set forth in the president's January 21, 2009 Memorandum on
Transparency and Open Government.
OMB Memorandum M-15-12, Increasing Transparency of Federal Spending by Making Federal Spending
Data Accessible, Searchable, and Reliable, dated May 8, 2015, provides guidance to federal agencies on
reporting requirements under the Federal Funding Accountability and Transparency Act of 2006 and the
DATA Act.
OMB Management Procedures Memorandum 2016-03, Additional Guidance for DATA Act
Implementation: Implementing Data-Centric Approach for Reporting Federal Spending Information,
dated May 3, 2016, provides additional guidance to federal agencies on reporting federal appropriations
and award-level data to USAspending.gov.
OMB Memorandum M-16-17, OMB Circular No. A-123, Management's Responsibility for Enterprise Risk
Management and Internal Control, dated July 15, 2016, defines management's responsibilities for
enterprise risk management and internal control.
OMB Memorandum M-17-04, Additional Guidance for DATA Act Implementation: Further Requirements
for Reporting and Assuring Data Reliability, dated November 4, 2016, defines responsibilities for
agencies to report financial information for awards involving intragovernmental transfers. It also
provides guidance for reporting financial assistance award (grant) records containing personally
identifiable information and the requirement for the agencies' senior accountable officials to certify
quarterly submissions to USAspending.gov.
OMB Memorandum M-18-16, Appendix A to OMB Circular No. A-123, Management of Reporting and
Data Integrity Risk, dated June 6, 2018, includes a specific requirement for agencies to develop a Data
Quality Plan to achieve the objectives of the DATA Act beginning in FY 2019 and continuing through
FY 2021 at a minimum or until agencies determine that they can provide reasonable assurances over the
appropriate data quality controls.
OMB Memorandum M-20-11, Administrative Relief for Recipients and Applicants of Federal Financial
Assistance Directly Impacted by the Novel Coronavirus (COVID-19), dated March 9, 2020, allows specific
flexibilities in certain emergency response federal financial assistance instances.
OMB Memorandum M-20-17, Administrative Relief for Recipients and Applicants of Federal Financial
Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations, dated
March 19, 2020, allows additional specific flexibilities in certain emergency response federal financial
assistance instances.
OMB Memorandum M-20-18, Managing Federal Contract Performance Issues Associated with the Novel
Coronavirus (COVID-19), dated March 20, 2020, identifies specific flexibilities in certain emergency
response procurement instances; encourages agencies to use emergency procurement authorities
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authorized in connection with the president's emergency declaration under section 501(b) of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. §§ 5121-5207, and the Federal
Acquisition Regulation § 18.202; and provides guidance for tracking acquisition costs related to the
COVID-19 response.
OMB Memorandum M-20-20, Repurposing Existing Federal Financial Assistance Programs and Awards
to Support the Emergency Response to the Novel Coronavirus (COVID-19), dated April 9, 2020, issues a
class exception that allows federal awarding agencies to repurpose their federal assistance awards, in
whole or part, to support the COVID-19 response, as consistent with applicable laws.
OMB Memorandum M-20-21, Implementation Guidance for Supplemental Funding Provided in Response
to the Coronavirus Disease 2019 (COVID-19), dated April 10, 2020, provides reporting guidance for
federal agencies and amends the reporting requirements of financial data spending on
USAspending.gov, including the addition of a monthly submission requirement.
OMB Memorandum, Risk-Based Financial Audits and Reporting Activities in Response to COVID-19,
dated June 17, 2020, directs agencies to leverage enterprise risk management techniques to identify
reporting, audit, and other due dates that are lower priority than COVID-19 work. It also identifies
auditing and reporting requirements that are essential to critical reporting needs of the government
and, therefore, still mandated.
OMB Memorandum M-20-26, Extension of Administrative Relief for Recipients and Applicants of Federal
Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations,
dated June 18, 2020, "describes the two flexibilities extended under this memorandum to recipients
affected by the loss of operational capacity due to the COVID-19 pandemic."
OMB Memorandum M-20-27, Additional Guidance on Federal Contracting Resiliency in the Fight Against
the Coronavirus Disease (COVID-19), dated July 14, 2020, provides additional and updated guidance and
highlights information and examples from agency guidance and activities that may further assist the
acquisition workforce as it addresses impacts due to COVID-19. It also extends the use of the COVID-19
National Interest Action Code through September 30, 2020.
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Appendix D
CIGIE's DATA Act Anomaly Letter
Council of the
Inspectors General
on INTEGRITY and EFFICIENCY
December 22, 2015
The Honorable Ron Johnson
Chairman
The Honorable Thomas Carper
Ranking Member
Committee on Homeland Security
and Governmental Affairs
United States Senate
Washington, D.C.
Dear Mr. Chairmen and Ranking Members:
The Council of the Inspectors General on Integrity and Efficiency (CIGIE) recognizes and
appreciates your leadership on issues of Government transparency and accountability. In
particular, we believe the enactment last year of the Digital Accountability and Transparency Act
of 2014 (DATA Act) will significantly improve the quality of Federal spending data available to
Congress, the public, and the accountability community if properly implemented. To make sure
this happens, the DATA Act provides for strong oversight by way of the Federal Inspectors
General and the Government Accountability Office (GAO). In particular, the DATA Act
requires a series of reports from each to include, among other things, an assessment of the
completeness, timeliness, quality, and accuracy of data submitted by agencies under the DATA
Act.
I am writing this letter on behalf of CIGIE to inform you of an important timing anomaly with
the oversight requirement for Inspectors General in the DATA Act. Your staffs have been
briefed on this timing anomaly, which affects the first Inspector General reports required by the
DATA Act. Specifically, the first Inspector General reports are due to Congress in November
2016 However, the agencies we oversee are not required to submit spending data in compliance
with the DATA Act until May 2017. As a result, Inspectors General would be unable to report
on the spending data submitted under the Act, as this data will not exist until the following year.
This anomaly would cause the body of reports submitted by the Inspectors General in November
2016 to be of minimal use to the public, the Congress, the Executive Branch, and others.
To address this reporting date anomaly, the Inspectors General plan to provide Congress with
their first required reports in November 2017, a one-year delay from the due date in statute, wit
subsequent reports following on a two-year cycle, in November 2019 and November 2021. We
believe that moving the due dates back one year will enable the Inspectors General to meet the
1717 H Street, NW, Suite 825, Washington, DC 20006
The Honorable Jason Chaffetz
Chairman
The Honorable Elijah Cummings
Ranking Member
Committee on Oversight and Government Reform
U.S. House of Representatives
Washington, D.C.
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Page 2
intent of the oversight provisions in the DATA Act and provide useful reports for the public, the
Congress, the Executive Branch, and others.
Although we think the best course of action is to delay the Inspector General reports, CIGIE is
encouraging the Federal Inspector General Community to undertake DATA Act "readiness
reviews" at their respective agencies well in advance of the first November 2017 report.
Through a working group, CIGIE has developed guidance for these reviews. I am pleased to
report that several Inspectors General have already begun reviews at their respective agencies,
and many Inspectors General are planning to begin reviews in the near future. We believe that
these reviews, which are in addition to the specific oversight requirements of the Act, will assist
all parties in helping to ensure the success of the DATA Act implementation.
We have kept GAO officials informed about our plan to delay the first Inspector General reports
for one year, which they are comfortable with, and our ongoing efforts to help ensure early
engagement through Inspector General readiness reviews.
Should you or your staffs have any questions about our approach or other aspects of'our
collective DATA Act oversight activities, please do not hesitate to contact me at (202) 514-3433.
Michael E. Horowitz
Chair, Council of the Inspectors General on Integrity and Efficiency
Inspector General, U.S. Department of Justice
cc: The Honorable David Mader, Controller, OMB
The Honorable Gene Dodaro, Comptroller General, GAO
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Sincerely,
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Appendix E
Sampling Methodology
Define Target Population
We downloaded the EPA's File C (target population) from the DATA Act Broker into Excel format and
also into IDEA format. Based on our analysis, File C has 7,551 records totaling $3,804,934,311.68.
Construct Sampling Frame
Most records within the population are statistically valid. For those that are not, such as micropurchase
transactions, we generated replacement samples. As stated in the CIGIE DATA Act Guide:
If a sample item is a procurement micro purchase transaction or deviates from award
amounts due to discounts, penalties or interest, the sample item should not be tested
and should be replaced with another sample item. One method to plan for this is to
randomly sort File C and select the sample as the first 385 records from the random
sort. Thus, for example, if there is one out-of-scope record in a sample of 385 the
Inspector General can then select the 386th record from the random sort of File C as
a replacement sample unit. Note that the sample size of 385 was used only for
purposes of the example, many Inspectors General will have a statistical sample size
which is less than 385.
Define Stratum Boundaries
We determined that File C should be stratified into two categories: contracts and grants. CIGIE sample
testing attributes are separated by Procurement Instrument Identifier Numbers (for contracts) and
Federal Assistance Identification Numbers (for grants), so stratification is logical.
Determine Sample Size
The audit team determined the sample size to be 239. Sample size was calculated by using a 20-percent
error rate, 95-percent confidence level, and 5-percent sample precision.
Allocate Sample to Strata
To ensure that both contracts and grants were properly represented in our sample, we used
proportional allocation to stratify our sample. Proportional allocation is easy to implement, and
stratification allows for more precision over a simple random sample. Our population had the following
number and percentage breakdown between grants (Federal Assistance Identification Numbers) and
contracts (Procurement Instrument Identifier Numbers). See Table E-l.
Table E-1: Percentage of contracts and grants in the population
Grant records
Federal Assistance Identification Numbers
Contract records
Procurement Instrument Identifier Numbers
Total
3,315
4,236
7,551
44%
56%
100%
Source: OIG calculation. (EPA OIG table)
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Select the Sample Independently in Each Stratum
After separating the two groups, we used IDEA'S random sample function with each group to extract
134 (56 percent) samples from contracts and 105 (44 percent) samples from grants. See Table E-2.
Table E-2: Number of grants and contracts in sample
Procurement Instrument Identifier Number
239 x 56 percent
134
Federal Assistance Identification Numbers
105
Total
239
Source: OIG calculation. (EPA OIG table)
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5
37
16
1
22
30
4
31
56
20
38
39
40
41
49
11
12
42
43
6
17
18
19
35
34
2
32
33
3
36
24
27
7
8
13
23
25
26
Appendix F
Standardized Data Element Reporting
EPA's results for data elements
in descending order by accuracy error rate
Data element name
Sample error rate
(percentages)
ACT
Accuracy Completeness Timeliness
Legal Entity Address
53.19
1.70
Business Types
39.05
3.81
Award Type
25.96
1.70
Awardee/Recipient Legal Entity Name
25.53
1.70
Award Description
22.13
1.70
Primary Place of Performance Address
19.15
3.40
Ultimate Parent Legal Entity Name
17.22
2.39
Primary Place of Performance Congressional District
17.02
2.98
Program Activity
15.77
0.00
Catalog of Federal Domestic Assistance Title
13.33
3.81
Funding Agency Name
10.43
10.43
Funding Agency Code
10.43
10.43
Funding Sub Tier Agency Name
10.43
10.43
Funding Sub Tier Agency Code
10.43
10.43
Awarding Office Code
8.51
1.70
Amount of Award
6.67
3.81
Nonfederal Funding Amount
6.67
6.67
Funding Office Name
6.16
0.00
Funding Office Code
6.16
0.00
Legal Entity Congressional District
5.53
2.55
NAICS Code
3.85
0.00
NAICS Description
3.85
0.00
Catalog of Federal Domestic Assistance Number
3.81
3.81
Record Type
3.81
3.81
Award ID Number (Procurement Instrument Identifier
Number/Federal Assistance Identification Number)
3.78
1.68
Awardee/Recipient Unique Identifier
2.98
1.70
Primary Place of Performance Country Code
2.98
2.98
Primary Place of Performance Country Name
2.98
2.98
Ultimate Parent Unique Identifier
2.38
0.00
Action Type
2.09
2.09
Parent Award ID
2.02
0.00
Period of Performance Current End Date
1.72
1.72
Legal Entity Country Code
1.70
1.70
Legal Entity Country Name
1.70
1.70
Federal Action Obligation
1.70
1.70
Award Modification / Amendment Number
1.70
1.70
Action Date
1.70
1.70
Period of Performance Start Date
1.70
1.70
29
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EPA's results for data elements
in descending order by accuracy error rate
Sample error rate
(percentages)
DAI MS
element #
Data element name
ACT
Accuracy Completeness Timeliness
44
Awarding Agency Name
1.70
1.70
4.26
45
Awarding Agency Code
1.70
1.70
4.26
46
Awarding Sub Tier Agency Name
1.70
1.70
4.26
47
Awarding Sub Tier Agency Code
1.70
1.70
4.26
48
Awarding Office Name
1.70
1.70
4.26
14
Current Total Value of Award
1.54
1.54
4.62
28
Period of Performance Potential End Date
0.79
0.00
3.15
50
Object Class
0.41
0.00
1.66
15
Potential Total Value of Award
0.00
0.00
3.08
29
Ordering Period End Date
0.00
0.00
0.00
51
Appropriations Account
0.00
0.00
1.66
53
Obligation
0.00
0.00
1.67
163
National Interest Action
0.00
0.00
3.08
430
Disaster Emergency Fund Code
0.00
0.00
1.66
Source: OIG summary of audit test results based on CIGIE DATA Act Guide, Appendix 8, "Standardized Data Element
Reporting." (CIGIE table, EPA OIG data)
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Appendix G
Comparative Results Table
The table below identifies the error rate by data element from the FYs 2019 and 2021 audit results. The
information is being provided for illustrative purposes only and may not necessarily be indicative of
actual percentage change based on differences in testing procedures, such as population size, sample
methodology, quarter tested, file tested, and changes to data definition standards.
EPA's comparative results for data elements
in descending order based on accuracy error rate
Error rate
(percentages
)
DAI MS
element #
Data element name
2021
2019
% change
5
Legal Entity Address
53.19
21.39
31.81
37
Business Types
39.05
35.00
4.05
16
Award Type
25.96
19.88
6.08
1
Awardee/Recipient Legal Entity Name
25.53
10.24
15.29
22
Award Description
22.13
8.73
13.39
30
Primary Place of Performance Address
19.15
21.23
-2.08
4
Ultimate Parent Legal Entity Name
17.22
17.85
-0.62
31
Primary Place of Performance Congressional District
17.02
17.28
3.57
56
Program Activity
15.77
5.26
10.50
20
Catalog of Federal Domestic Assistance Title
13.33
52.50
-39.17
38
Funding Agency Name
10.43
3.08
7.35
39
Funding Agency Code
10.43
3.08
7.35
40
Funding Sub Tier Agency Name
10.43
0.00
10.43
41
Funding Sub Tier Agency Code
10.43
0.00
10.43
49
Awarding Office Code
8.51
24.70
-16.19
11
Amount of Award
6.67
8.13
-1.47
12
Non-Federal Funding Amount
6.67
37.50
-30.83
42
Funding Office Name
6.16
4.23
1.93
43
Funding Office Code
6.16
4.23
1.93
6
Legal Entity Congressional District
5.53
14.20
-8.24
17
NAICS Code
3.85
1.19
2.66
18
NAICS Description
3.85
1.19
2.66
19
Catalog of Federal Domestic Assistance Number
3.81
33.75
-29.94
35
Record Type
3.81
33.75
-29.94
34
Award ID Number (Procurement Instrument Identifier
Number/Federal Assistance Identification Numbers)
3.78
7.08
-3.30
2
Awardee/Recipient Unique Identifier
2.98
10.84
-7.86
32
Primary Place of Performance Country Code
2.98
8.62
-5.64
33
Primary Place of Performance Country Name
2.98
8.31
-5.33
3
Ultimate Parent Unique Identifier
2.38
10.46
-8.08
36
Action Type
2.09
10.31
-8.22
24
Parent Award ID
2.02
6.15
-4.13
27
Period of Performance Current End Date
1.72
10.40
-8.67
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EPA's comparative results for data elements
in descending order based on accuracy error rate
Error rate
(percentages)
DAI MS
element # Data element name
2021 2019 % change
7
Legal Entity Country Code
1.70
8.13
-6.43
8
Legal Entity Country Name
1.70
8.43
-6.73
13
Federal Action Obligation
1.70
37.50
-35.80
23
Award Modification / Amendment Number
1.70
9.61
-7.91
25
Action Date
1.70
8.43
-6.73
26
Period of Performance Start Date
1.70
8.13
-6.43
44
Awarding Agency Name
1.70
8.13
-6.43
45
Awarding Agency Code
1.70
8.13
-6.43
46
Awarding Sub Tier Agency Name
1.70
8.13
-6.43
47
Awarding Sub Tier Agency Code
1.70
8.13
-6.43
48
Awarding Office Name
1.70
24.70
-23.00
14
Current Total Value of Award
1.54
2.04
-0.50
28
Period of Performance Potential End Date
0.79
2.04
-1.25
50
Object Class
0.41
0.00
0.41
15
Potential Total Value of Award
0.00
1.59
-1.59
29
Ordering Period End Date
0.00
0.00
0.00
51
Appropriations Account
0.00
0.00
0.00
53
Obligation
0.00
0.30
-0.30
163
National Interest Action
0.00
N/A
N/A
430
Disaster Emergency Fund Code
0.00
N/A
N/A
Source: OIG summary of audit test results based on CIGIE DATA Act Guide, Appendix 9, "Comparative Results Table."
(CIGIE table, EPA OIG data)
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Appendix I I
Agency Response to Draft Report
; A v
PRO^
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
November I, 2021
OFFICE OF MISSION SUPPORT
MEMORANDUM
SUBJECT
FROM:
Response to Office of Inspector General Draft Report No. OA-FY21-0080, "EPA's
Fiscal Year 2020 Fourth Quarter Compliance with the Digital Accountability and
Transparency Act of 2014," dated October 27, 2021
I YNMANN Digitally signed by
1_ T IMIMAAINIIM LYNNANN KITCHENS
Lynnann Hitchens, Acting Principal Deputy Assistant AdministratorHITCHENS ^i^wcc?1
TO: Paul C. Curtis, Director
Financial Directorate
Office of Audit
Thank you for the opportunity to respond to the issues and recommendations in the subject audit report.
Following is a summary of the agency's overall position, along with its position on each of the report
recommendations. For the report recommendations with which the agency agrees, we have provided
high-level intended corrective action and an estimated completion date
AGENCY'S OVERALL POSITION
The Office of Mission Support concurs with each of the recommendations found in the draft report. Tt
should be noted, however, that the data assessed for this audit with respect to grants was based on the
legacy Integrated Grants Management System that has been decommissioned. While the same data was
incorporated into the new Next Generation Grants System (NGGS), the audit does not assess or reflect
the capabilities of NGGS.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreement
No
Recommendation
High-Level Intended Corrective
Action
Estimated
Completion Date
1
Update policies and procedures to
require that Awardee/Recipient Legal
Entity Name and Legal Entity Address
data elements match SAM.gov at the
time of the award and of any award
modifications for all contracts and
grants. At the time of any award
modification, update the Agency's
contracts or grants management
1.1 OMS-OGD will update policies
and/or procedures, such as
guidance, SOPs, or pre-award
checklists, to require that
Awardee/Recipient Legal Entity
Name and Legal Entity Address data
elements match SAM.gov at the
time of the award and of any award
modifications for all grants.
October 31, 2022
Internet Address (URL) • http://www.epa.gov
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system and the Federal Procurement
Data System with any changes to
these data elements.
OMS-OGD will require, at the time
of any award modification, an
update to the Agency's grants
management system with any
changes to these data elements.
OMS-OGD will also incorporate the
new requirements in training
materials.
1.2 OMS-OGD will evaluate the
feasibility of and resources needed
to make additional system
enhancements to NGGS to enforce
SAM.gov entity data as the
authoritative address information
for a grant entity.
1.3 OMS-OAS will update its policies,
training, and guidance documents
to align with the requirements of
this recommendation.
October 31, 2022
March 31, 2022
2
Update policies and procedures to
require that Award Descriptions be
written in plain English and thatAword
Descriptions for modifications explain
the purpose of the contract, not
merely the purpose of the
modification.
2.1. OMS-OAS will update policies and
procedures to require that Award
Descriptions be written in plain
English and that Aware/ Descriptions
for modifications explain the
purpose of the contract, not merely
the purpose of the modification.
March 31, 2022
3
Update the EPA grants management
system to align with the DATA Act data
standards, including all parts of data
elements reported therein, and to
allow input only of the acceptable
values outlined for each data element
in DATA Act Information Model
Schema, Reporting Submission
Specification.
3.1 OMS-OGD will update NGGS to align
with the DATA Act data standards
including all parts of data elements
reported therein and allow input
only of the acceptable values
outlined for each data element in
DATA Act Information Model
Schema, Reporting Submission
Specification.
September 30,
2023
4
Update the Catalog of Federal
Domestic Assistance Titles on an
annual basis, as required in DATA Act
Information Model Schema, Practices
and Procedures, Appendix F, "Update
Cadence for Data Sources."
4.1 OMS-OGD will update the Catalog
of Federal Domestic Assistance Titles
on an annual basis, as required in
DATA Act Information Model
Schema, Practices and Procedures,
Appendix F, "Update Cadence for
Data Sources."
September 30,
2022
5
Provide training to improve
consistency of data entry for all data
elements, particularly Primary Place of
5.1 OMS-OGD will provide training to
improve the consistency of data
entry for all data elements,
particularly Primary Place of
April 30, 2022
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Performance Address a nd Award
Description.
Performance Address and Award
Description.
5.2 OMS-OAS will revise existing or
develop new training to address
data quality for all data entry
elements.
April 30, 2022
6
Include all categories for the Non-
Federal Funding Amount data
element—including the Recipient,
State, Local, and Other Contributions
categories—in the EPA's grants
management system.
6.1 OMS-OGD will include all categories
for the Non-Federal Funding Amount
data element—including the
Recipient, State, Local, and Other
Contributions categories—in NGGS.
March 31, 2022
CONTACT INFORMATION
If you have any questions regarding this response, please contact Marilyn Armstrong, Audit Follow-up
Coordinator, Office of Resources and Business Operations, at armstrong.marilyn@epa.gov or (202) 564-
1876.
cc: Amir Eskarous
Amanda Ipema
Allison Krenzien
Shannon Lackey
Doug LaTessa
Sheila May
Claire McWilliams
Kevin Ross
Arron Helm
Marilyn Braxton
Kimberly Patrick
Pamela Legare
Celia Vaughn
Michael Osinski
Bruce Binder
Kysha Holliday
William Etheredge
Laurice Jones
Jennie Bae
Darryl Hobbs
Dan Coogan
Jan Jablonski
Marilyn Armstrong
Brittany Wilson
Jeanne Conklin
Andrew LeBlanc
Jose Deleon Kercado
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Appendix I
Distribution
The Administrator
Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff, Office of the Administrator
Chief Financial Officer
Assistant Administrator for Mission Support
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Administrator for Policy, Office of the Administrator
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Deputy Chief Financial Officer
Associate Chief Financial Officer
Associate Chief Financial Officer for Policy
Controller
Deputy Controller
Associate 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
Principal Deputy Assistant Administrator for Mission Support
Deputy Assistant Administrator for Administration and Resources Management, Office of Mission
Support
Director, Office of Resources and Business Operations, Office of Mission Support
Director, Office of Acquisition Solutions, Office of Mission Support
Director, Office of Grants and Debarment, Office of Mission Support
Deputy Director, Office of Grants and Debarment, Office of Mission Support
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Mission Support
Audit Liaison, Office of Acquisition Solutions, Office of Mission Support
Audit Liaison, Office of Grants and Debarment, Office of Mission Support
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