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PLAN


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This plan is available at www.ena.gov/oig.

Definitions

Carryover

Discretionary

Mandated

Assignments started in a prior fiscal year that are still in progress.

Assignments not required by law or regulation but address areas of high risk.
Assignments that the Office of Inspector General is required to conduct by law or
regulation.

Abbreviations



CIGIE

Council of the Inspectors General on Integrity and Efficiency

CSB

U.S. Chemical Safety and Hazard Investigation Board

EPA

U.S. Environmental Protection Agency

FIFRA

Federal Insecticide, Fungicide, and Rodenticide Act

FISMA

Federal Information Security Modernization Act

FY

Fiscal Year

GAO

U.S. Government Accountability Office

IT

Information Technology

OA&E

Office of Audit and Evaluation

OC

Office of Counsel

OCCPA

Office of Counsel and Congressional and Public Affairs

OCPA

Office of Congressional and Public Affairs

OI

Office of Investigations

OIG

Office of Inspector General

OM

Office of Management

PRIA

Pesticide Registration Improvement Act of 2003

U.S.C.

United States Code

Are you aware of fraud, waste, or abuse in an
EPA or CSB 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 (241OT)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq

Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Report Suggestions


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Message from the Inspector General

I am pleased to present the U.S. Environmental Protection Agency's Office of
Inspector General Annual Plan for fiscal year 2020. This plan describes how the OIG
will promote economy, efficiency, and effectiveness in the programs and operations
of the EPA and the U.S. Chemical Safety and Hazard Investigation Board. It also
describes how the OIG prevents and detects waste, fraud, and abuse in those programs
and operations. Further, the Annual Plan shows how the OIG will continue to promote
the goals and objectives of OIG's Strategic Plan.

The Annual Plan identifies mandated and discretionary assignment topics continuing

from FY 2019, as well as mandated and discretionary assignments scheduled to start	

during FY 2020. The OIG often performs unanticipated work based on legislative mandates, congressional
inquiries, or hotline requests. It is important that we remain flexible to address these and other priorities as
they arise. Readers are encouraged to visit our website periodically to view reports about projects that are
discussed in our Annual Plan.

As set forth in this plan, our Office of Audit and Evaluation seeks to support the EPA's mission of protecting
human health and the environment through audits and evaluations performed in accordance with applicable
professional standards. For example, in 2018, the EPA Administrator identified risk communication as a top
priority of the Agency. In 2020, our auditors will continue to evaluate the EPA's communication of risk to
human health, and, where appropriate, identify areas for improvement. We will also examine other programs
and functions that the OIG has identified as key management challenges for the Agency, such as oversight
of states and tribes, enhancing information security to combat cyber threats, improving data quality, and
filling data gaps.

Our Office of Investigations also seeks to further the OIG's mission by investigating allegations of criminal
activity and serious misconduct involving EPA and CSB programs and operations. For example, every year
the EPA awards a significant portion of its budget in grants and other assistance to further the protection of
human health and the environment. Our investigators will continue to investigate allegations of fraud and
other crimes involving money or property that is to be spent to advance EPA interests and programs.

The success of our Annual Plan also lies in the efficiency and effectiveness promoted by our leadership and
support offices, which work to ensure our core mission offices function at optimum levels in support of the
OIG mission. The Office of Management helps the OIG effectively and efficiently achieve its mission by,
among other things, developing programs to attract and retain high-talent staff. The Office of Congressional
and Public Affairs supports the OIG mission by innovatively communicating the OIG's work to Congress
and the public. And the Office of Counsel supports the OIG by providing independent legal and policy advice
to all OIG components, covering a variety of substantive and procedural matters relating to the OIG's
audits, evaluations, investigations, and other activities.

The Annual Plan reflects the priority work that the OIG believes is necessary to keep the EPA, the CSB, and
Congress fully informed about problems and deficiencies relating to the administration of Agency programs
and operations. We look forward to meeting our goals and fulfilling our mission. For those interested in our
planning process, we welcome feedback on the quality and value of our products and services via
OIG WEBCOMMENTS@epa.gov.

Sean W. O'Donnell

Inspector General


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Table of Contents

About the U.S. Environmental Protection Agency Office of Inspector General	1

The Plan: OIG's Overall Strategy	2

The Plan: Office of Audit and Evaluation Carryover and New Assignments for FY 2020	5

Identifying Risks at EPA	10

Identifying Risks at CSB	15

Air Directorate	16

Contract and Assistance Agreement Directorate	17

Efficiency Directorate	19

Environmental Research Programs Directorate	20

Financial Directorate	21

Forensic Directorate	22

Information Resources Management Directorate	23

Land Cleanup and Waste Management Directorate	24

Toxics, Chemical Management and Pollution Prevention Directorate	25

Water Directorate	27

Immediate Office	28

The Plan: Office of Investigations FY 2020 Focus	29

The Plan: Office of Counsel and Congressional and Public Affairs FY 2020 Focus	34

The Plan: Office of Management FY 2020 Focus	38

Appendix A: Overview of the OIG Strategic Plan 2019-2023 	39

Appendix B: OIG Strategic Measures 2019-2023	39


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About the U.S. Environmental Protection
Agency Office of Inspector General

EPA OIG

The OIG is an independent office within the EPA that detects and prevents fraud, waste, and
abuse, and promotes economy and efficiency to help the Agency protect human health and the
environment more efficiently and cost effectively. The EPA Inspector General was also
designated by Congress in fiscal year 2004 to serve as the Inspector General for the U.S.
Chemical Safety and Hazard Investigation Board.

The OIG was established under the Inspector General Act of 1978, as amended (5 U.S.C. app.).
The Act required the establishment of Inspectors General as independent and objective units for
the following purposes:

1.	Conduct and supervise audits and investigations relating to the programs and
operations of their agencies.

2.	Provide leadership and coordination, and recommend policies for activities designed
to promote economy, efficiency, and effectiveness, and to prevent and detect fraud,
waste, and abuse.

3.	Provide a means for keeping the head of the Agency and Congress fully and currently
informed about problems and deficiencies, as well as the necessity and progress of
corrective actions.

The OIG conducts independent audits, evaluations, and investigations; makes evidence-based
recommendations to promote economy, efficiency, and effectiveness; and prevents and detects
fraud, waste, abuse, mismanagement, and misconduct for the EPA and the CSB. The OIG
Hotline provides a channel for anyone, including EPA and CSB employees, participants in EPA
and CSB programs, Congress, organizations, and members of the public, to report instances of
fraud, waste, and abuse, and submit requests pertaining to Agency programs. Each year, the OIG
receives hundreds of complaints, referrals, suggestions, and allegations. The OIG promptly
processes this information and, when warranted, initiates OIG investigations, refers issues for
audits or evaluations, or refers issues to the appropriate EPA office or other agency if not within
EPA's jurisdiction. The OIG often uses data analysis methodologies to analyze hotline matters.
This analysis assists the OIG in identifying trends that are reported to the hotline to improve the
overall efficiency and effectiveness of our investigations and audits.

We discuss issues with the EPA, the CSB, and others, including Congress members, and provide
detailed reports. We publish a Semiannual Report to Congress that identifies significant EPA and
CSB deficiencies and proposed corrective actions, as well as profiles our accomplishments.

The OIG staff are located at headquarters in Washington, D.C.; all ten EPA regional offices; and
at Research Triangle Park in North Carolina, and Cincinnati, Ohio.

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The Plan: OIG's Overall Strategy

Annual planning is a dynamic process and requires adjustments throughout the year to meet
priorities and anticipate and respond to emerging issues with available resources. The OIG has
examined the cross-agency risk assessments, Agency challenges, the EPA 2018-2022 Strategic
Plan, the CSB 2017-2021 Strategic Plan, the OIG 2019-2023 Strategic Plan, prior work, future
priorities, and stakeholder input to develop and prioritize its FY 2020 work.

Goal Oriented, Mission Focused

The OIG is dedicated to fulfilling its mission as established in the Inspector General Act with
excellence and the highest level of commitment to service. In doing so, we will exemplify our
core values of customer service, integrity, and accountability. For FY 2020, we will execute the
following priorities:

1.	Work toward developing a robust enterprise risk management program.

2.	Aggressively pursue high-risk/high-vulnerability programs for audits, evaluations, and
investigations.

3.	Meet or exceed established performance targets.

4.	Execute a clear messaging strategy geared toward increased visibility in support of
ensuring the free-flow of information from the public that would assist in rooting out
fraud, waste, and abuse in environmental and health and human services programs and
associated initiatives.

5.	Continue to be responsive to congressional inquiries and actively assess and address
hotline complaints.

6.	Maintain a well-trained, well-equipped workforce of professionals and give them the
opportunity to excel in their fields.

7.	Increase collaborations with the Council of Inspectors General on Integrity and
Efficiency and sister organizations within the Inspector General community in order to
leverage learned best practices that will increase our effectiveness and efficiency.

Each office within the OIG will prioritize work in accordance with the above organizational
priorities and will adhere to its respective internal priorities. Our organization expects that
objectives will be met with excellence, professionalism, accuracy, and the highest regard for our
greatest asset—our workforce.

The OIG's Strategic and Annual Plans align with the Inspector General Act and the EPA's and
CSB's strategic goals, and help these agencies achieve their performance goals in the most
economical, efficient, and effective manner. The list below identifies the EPA's FY 2018-2022
strategic goals, followed by the CSB's mission and goals, which we consider when planning
audits, evaluations, and investigations. Within this document, we provide more details about the

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OIG's FY 2020 annual performance measures and targets. Appendix A provides a summary of
the OIG's Strategic Plan 2019-2023.

EPA's Mission

The EPA's mission is to protect human health and the environment by ensuring that:

•	Americans have clean air, land, and water.

•	National efforts to reduce environmental risks are based on the best available science.

•	Federal laws protecting human health and the environment are administered and enforced
fairly, effectively, and as intended.

•	Environmental stewardship is integral to U.S. policies concerning natural resources,
human health, economic growth, energy, transportation, agriculture, industry, and
international trade, and these factors are similarly considered in establishing
environmental policy.

•	All parts of society - communities, individuals, businesses, and state, local, and tribal
governments - have access to accurate information to effectively participate in managing
human health and environmental risks.

•	Contaminated lands and toxic sites are cleaned up by potentially responsible parties and
revitalized.

•	Chemicals in the marketplace are reviewed for safety.

EPA's FY 2018-2022 Strategic Goals	

Strategic Goals

Goal 1: A Cleaner, Healthier Environment: Deliver a cleaner, safer, and healthier

environment for all Americans and future generations by carrying out the Agency's core

mission.

•	Objective 1.1 - Improve Air Quality: Work with states and tribes to accurately measure air quality and ensure
that more Americans are living and working in areas that meet high air quality standards.

•	Objective 1.2 - Provide for Clean and Safe Water: Ensure waters are clean through improved water
infrastructure and, in partnership with states and tribes, sustainably manage programs to support drinking
water, aquatic ecosystems, and recreational, economic, and subsistence activities.

•	Objective 1.3 - Revitalize Land and Prevent Contamination: Provide better leadership and management to
properly clean up contaminated sites to revitalize and return the land back to communities.

•	Objective 1.4 - Ensure Safety of Chemicals in the Marketplace: Effectively implement the Toxics
Substances Control Act, and the Federal Insecticide, Fungicide, and Rodenticide Act, to ensure new and
existing chemicals and pesticides are reviewed for their potential risks to human health and the environment,
and actions are taken when necessary.

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Goal 2: More Effective Partnerships: Provide certainty to states, localities, tribal nations, and
the regulated community in carrying out shared responsibilities and communicating results to all
Americans.

•	Objective 2.1 - Enhance Shared Accountability: Improve environmental protection through shared
governance and enhanced collaboration with state, tribal, local, and federal partners using the full range of
compliance assurance tools.

•	Objective 2.2 - Increase Transparency and Public Participation: Listen to and collaborate with impacted
stakeholders and provide effective platforms for public participation and meaningful engagement.

Goal 3: Greater Certainty, Compliance, and Effectiveness: Increase certainty, compliance,
and effectiveness by applying the rule of law to achieve more efficient and effective Agency
operations, service delivery, and regulatory relief.

•	Objective 3.1 - Compliance with the Law: Timely enforce environmental laws to increase compliance rates and
promote cleanup of contaminated sites through the use of all of EPA's compliance assurance tools, especially
enforcement actions to address environmental violations.

•	Objective 3.2 - Create Consistency and Certainty: Outline exactly what is expected of the regulated
community to ensure good stewardship and positive environmental outcomes.

•	Objective 3.3 - Prioritize Robust Science: Refocus the EPA's robust research and scientific analysis to inform
policy making.

•	Objective 3.4 - Streamline and Modernize: Issue permits more quickly and modernize our permitting and
reporting systems.

• Objective 3.5 - Improve Efficiency and Effectiveness: Provide proper leadership and internal operations
management to ensure that the Agency is fulfilling its mission.

CSB's Mission

The CSB's mission is to drive chemical safety change through
independent investigations to protect people and the
environment. The CSB investigates industrial chemical accidents
at facilities, reports on the root causes to the public, and
recommends measures to prevent future occurrences. The OIG
has the responsibility to audit and investigate CSB programs and
review proposed laws and regulations to determine their potential
operations.

The following are the CSB's strategic goals:

•	Prevent recurrence of significant chemical incidents through independent investigations.

•	Advocate safety and achieve change through recommendations, outreach and education.

•	Create and maintain an engaged, high-performing workforce.

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The Plan: Office of Audit and Evaluation
Carryover and New Assignments for
FY 2020

The OIG's OA&E:

•	Plans and conducts complex audits and evaluations, including follow-ups on EPA
programs, systems, and operations.

•	Serves as the OIG's national technical expert for assigned areas of responsibility,
advising OIG personnel and others on program operations and audit and evaluation
approaches.

•	Works with senior officials from the EPA; the Office of Management and Budget; other
federal, state and local government offices; and professional and environmental
organizations to improve coordination, customer service, and results.

•	Prepares reports and delivers presentations on audit and evaluation methods, findings,
and recommendations.

•	Conducts research on, and stays attuned to, methods and best practices within the OIG
community to use in our audits and evaluations.

The ten directorates within the OA&E are responsible for auditing and evaluating EPA and CSB
programs and recommending improvements to programs and operations. The directorates are:

•	Air.

•	Contract and Assistance Agreement.

•	Efficiency.

•	Environmental Research Programs.

•	Financial.

•	Forensic.

•	Information Resources Management.

•	Land Cleanup and Waste Management.

•	Toxics, Chemical Management and Pollution Prevention.

•	Water.

Projects	are also undertaken by the Immediate Office within the OA&E.

Point of Contact: Christine El-Zoghbi, Acting Assistant Inspector General for Audit and
Evaluation, (202) 566-2063.

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In FY 2020, the OA&E will focus its efforts on ensuring the timely completion of mandatory
projects as well as identifying discretionary projects. The OA&E's work priorities support efforts
toward successfully fulfilling the following overall strategic measures (see full list of OIG
Strategic Measures at Appendix B):

Strategic
Measure
#

Strategic Measure Description

1.1.1

By September 30, 2023, the OIG will have conducted audits and evaluations resulting in
recommendations in specific areas geared toward improved EPA policies, procedures, and practices
contributing to improved human health, safety, or environmental quality in each of its major offices
and sub-offices. Further, the OIG will continue to work with the Agency to track implementation of
OIG recommendations.

1.2.1

By September 30, 2023, the OIG will be able to show quantitative measures supporting the OIG's
contribution to the reduction or elimination of environmental risks and challenges by conducting
audits, evaluations, or investigations. We will conduct at least one audit, evaluation, or investigation
addressing an emerging environmental risk or challenge.

1.2.2

By September 30, 2023, the OIG will have contributed to the reduction and elimination of
environmental risks and challenges by conducting at least one audit or evaluation in each of the
EPA's six priority goal areas rendering impactful recommendations.

2.2.1

By September 30, 2023, the OIG will perform audits and evaluations in each EPA priority area,
resulting in documented, data-supported improvements in efficiency and accountability across the
Agency.

2.3.1

By September 30, 2023, the OIG will have reduced risk of loss by detecting monetary benefits
through audits and evaluations targeting initiatives within the EPA's six priority goals.

2.4.2

By September 30, 2023, the OIG will have increased the effectiveness of audits and evaluations using
quantifiable impact in implemented recommendations as our measure.

2.4.3

By September 30, 2023, the OIG will increase its return on investment to a minimum ratio of 12 to 1
as an average from 2019 to 2023.

3.2.3

By September 30, 2023, the OIG will identify high-risk and high-vulnerability OIG activities,
implement appropriate review for activities that are considered high risk, and minimize them to an
appropriate degree. The OIG will implement at least one mitigation plan.

3.3.2

By September 30, 2023, the OIG's Federal Employee Viewpoint Survey scores in at least three of the
five Office of Personnel Management embedded indexes (Employee Engagement, Global
Satisfaction, Effective Communications, New Inclusion Quotient, and Human Capital Assessment and
Accountability Framework) and will increase by at least 10 percent from each index's 2018 average.

3.3.3

By September 30, 2023, due to various programs that we put into place, the OIG will work to
increase its "Best Places to Work" score for an Agency subcomponent (as administered by the
Partnership for Public Service) by at least one quartile from FY 2018 levels.

OA&E work that is not mandated by Congress is proposed, considered, and selected through a
rigorous process using the criteria listed in the section below. From these criteria, we develop a

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portfolio of assignments that represents the best return on investment in terms of monetary or
public value, and responsiveness in addressing the needs, risks, challenges, priorities, and
opportunities of OIG stakeholders. We also invite our staff to formulate assignment suggestions
from their immediate knowledge of EPA and CSB operations and from their consideration of
stakeholder input and risks.

In FY 2019, the EPA OIG initiated a pilot effort to implement evaluations of Agency programs
and operations in compliance with the CIGIE Quality Standards for Inspection and Evaluation,
also known as the "Blue Book." These evaluations will be performed in addition to audits that
comply with the U.S. Government Accountability Office's generally accepted government
auditing standards, also known as "GAGAS." Section 11(c)(2) of the Inspector General Act
provides that members of CIGIE shall "adhere to professional standards developed by the
Council" to the extent that they are not inconsistent with standards established by the
Comptroller General of the United States for audits of federal establishments (5 U.S.C. app.). In
June 2010, CIGIE officially adopted the Blue Book as the professional standard for all inspection
and evaluation work performed by member organizations.

The Blue Book defines inspections or evaluations as "systematic and independent assessments of
the design, implementation and/or results of an Agency's operations, programs or policies."
Evaluations provide information that is timely, credible, and useful for Agency managers,
policymakers, and other stakeholders. Evaluations can be used to determine the efficiency,
effectiveness, impact, and sustainability of Agency operations, programs, and policies.
Evaluations often recommend improvements and identify where administrative action is
necessary. The Blue Book identifies other uses of evaluations, including, but not limited to:

•	Providing factual and analytical information.

•	Measuring performance.

•	Determining compliance with applicable laws, regulations, and policies.

•	Identifying savings and funds to be put to better use.

•	Sharing best practices.

•	Assessing allegations of fraud, waste, abuse, and mismanagement.

Criteria Considered in Identifying and Selecting New Discretionary
Assignments for FY 2020

Potential threats to OIG independence:

•	Are there any potential threats to OIG independence if we perform this project?

•	Will the OIG be able to comply with professional standards, legal requirements, and
ethical principles?

Significance of proposed project:

•	What is the known extent of the issue (e.g., sensitive or other populations impacted, area
involved, and environmental justice)?

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•	Is the topic of the project generating interest from Congress, the public, or news
organizations? Why?

•	What is the potential environmental or human health benefit (return on investment) to be
derived, and how extensive is the potential for reduction or prevention of environmental,
human health, or business risks?

•	What is the expected return on investment (e.g., potential questioned costs, funds put to
better use, or other potential monetary benefits, improved decision-making, improved
data quality and reliability, reduced vulnerabilities, and strengthened internal control)?

•	Are programs performing with the greatest efficiency and effectiveness regarding
allocation and application of resources?

•	What resources, data, physical or cybersecurity equipment, program integrity, and
potential violations of laws/regulations are involved?

•	How does the project align with the OIG's current management challenges or internal
control weaknesses identified at the EPA or the CSB?

•	Are programs providing timely, accurate, complete, and useful information for decision-
making?

•	Are computer security and privacy programs comprehensive and actively implemented
throughout the organization to balance risk and mission requirements?

•	What are the conditions or changes since the prior audit was conducted by the OIG, the
GAO, or other auditing body?

•	What new information or indications of auditable issues are available?

Estimated return on investment:

•	What is the potential environmental or human health benefit (return on investment) to be
derived, and how extensive is the potential for reduction or prevention of environmental,
human health, or business risks?

•	What is the expected return on investment (e.g., potential questioned costs, funds put to
better use, or other potential monetary benefits, improved decision-making, improved
data quality and reliability, reduced vulnerabilities, and strengthened internal control)?

•	Are programs performing with the greatest efficiency and effectiveness regarding
allocation and application of resources?

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Risk of fraud, waste, or abuse:

•	What resources, data, physical or cybersecurity equipment, program integrity, and
potential violations of laws and regulations are involved?

Impact of current management challenges or internal control weaknesses:

•	How does the project align with the OIG's current management challenges or internal
control weaknesses identified at the EPA or the CSB?

•	Are programs providing timely, accurate, complete, and useful information for decision-
making?

•	Are computer security and privacy programs comprehensive and actively implemented
throughout the organization to balance risk and mission requirements?

Prior audit results:

•	What are the conditions or changes since the prior audit was conducted by the OIG, the
GAO, or other auditing body?

•	What new information or indications of auditable issues are available?

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Identifying Risks at EPA

Top EPA Management Challenges - Reported by OIG in FY 2019

The OIG reviewed major challenges (including an analysis of relevant risks) and planning
priorities across the EPA and solicited input from Agency leadership to identify OIG topics of
interest that would be of greatest benefit to the Agency and the American public. This section
summarizes the Agency's key management challenges identified by the OIG in FY 2019, which
will help guide the general direction and focus of OIG audits, evaluations, and investigative work
in FY 2020.

OIG-identified key management challenges for the EPA

FY 2018

FY 2019

Oversight of states, territories, and tribes authorized to accomplish environmental goals:

The EPA has made important progress, but our work continues to identify challenges
throughout Agency programs and regions, and many of our recommendations to establish
consistent baselines and monitor programs are still not fully implemented.

•

•

Enhancing information technology security to combat cyber threats (formerly Limited
Capability to Respond to Cyber Security Attacks): Though the EPA continues to initiate
actions to further strengthen or improve its information security program, the Agency
lacks a holistic approach to managing accountability over its contractors and lacks follow-
up on corrective actions taken.

•

•

Workforce planning/workload analysis: The EPA needs to identify its workload needs so
that it can more effectively prioritize and allocate limited resources to accomplish its work.

•

•

Mandated reporting requirements: The Agency faces challenges in tracking and
submitting reports mandated by law that contain key program information for Congress,
the EPA Administrator, and the public.

•

•

Data quality for program performance and decision-making: Poor data quality negatively
impacts the EPA's effectiveness in overseeing programs that directly impact public health.

•

•

The EPA needs to improve risk communication to provide individuals and communities
with sufficient information to make informed decisions to protect their health and the
environment: In 2018, the EPA Administrator identified risk communication as a top
priority. Our recent reports indicate risk communication challenges across many EPA
programs.



•

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Matrix of EPA Goals and Strategies OA&E Plans to Address with
Audits and Evaluations

When conducting our audits and evaluations during FY 2020, we will consider the EPA's FY
2018-2022 strategic goals. The table below shows how our planned audits and evaluations align
with each of the Agency's objectives.



EPA's FY 2018-2022 Strategic Objectives





Provide for



Ensure

Prioritize



Partner with





Improve air

clean and

Revitalize land

safety of

robust

Compliance

states and other

Operate efficiently



quality

safe water

and prevent

chemicals

science

with the law

stakeholders

and effectively

Planned FY 2020 OIG Projects

(Objective

(Objective

contamination

(Objective

(Objective

(Objective

(Objectives 2.1,

(Objectives 3.2, 3.4,



1.1)

1.2)

(Objective 1.3)

1.4)

3.3)

3.1)

2.2)

3.5)

Air Directorate

















Status of the Clean Air Act State

















Implementation Plan Submittals

X









X



X

and Approvals

















Audit Follow-Up Assignment

X









X





EPA's School Siting Guidelines

X









X

X



Contract and Assistance

















Agreement Directorate

















EPA Improper Payments











X



X

Reporting for FY 2019

















Cincinnati Finance Center - Travel











X



X

Card Audit

















Purchase Card and Convenience











X



X

Check Audit

















Agency Use of Blanket Purchase











X



X

Agreements













Enterprise Acquisition System











X



X

Data Integrity- Input into The

















System

















Enterprise Acquisition System











X



X

Data Integrity - Controls over

















Contract Clauses

















Efficiency Directorate

















EPA's Lab Consolidation Efforts at









X





X

Three of Its Laboratory Facilities













Implementation of Federal Green

















Challenge and Compliance with











X



X

Executive Order 13834

















Awarded Diesel Emissions

X













X

Reduction Act Grants













Compliance with Regulations

















Concerning Federal Contractors











X



X

that Have Tax Debt

















Environmental Research

















Programs Directorate

















Action Development Process for

X

X







X



X

Rulemaking









Hotline: Evaluating EPA's

















Response to Findings from Audits

















and Inspections Related to Its









X





X

National Enforcement

















Investigations Center

















EPA's Peer Review Process









X





X

Financial Directorate

















FY 2019 Financial Statements:

















Hazardous Waste Electronic





X









X

Manifest System Fund

















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EPA's FY 2018-2022 Strategic Objectives

Planned FY 2020 OIG Projects

Improve air
quality

(Objective
1.1)

Provide for
clean and
safe water

(Objective
1.2)

Revitalize land
and prevent
contamination

(Objective 1.3)

Ensure
safety of
chemicals

(Objective
1.4)

Prioritize
robust
science

(Objective
3.3)

Compliance
with the law

(Objective
3.1)

Partner with
states and other
stakeholders

(Objectives 2.1,
2.2)

Operate efficiently
and effectively

(Objectives 3.2, 3.4,
3.5)

FY 2019 Financial Statements:
Pesticides Registration Fund
(Pesticide Registration
Improvement Act of 2003) (PRIA)







X







X

FY 2019 Financial Statements:
Pesticides Reregistration and
Expedited Processing Fund
(FIFRA)







X







X

FY 2020 EPA Financial Statements















X

FY 2019 Financial Statements:
Frank R. Lautenberg Chemical
Safetyforthe 21st Century Act







X







X

Forensic Directorate

















FY 2020 Single Audit Program













X

X

Office of Air and Radiation's
National Center for Radiation
Field Operations Preparedness

X









X





EPA's Working Capital Fund
Operations, Expenditures, and
Rate Establishment















X

EPA's Awarding of Performance
Partnership Grants













X

X

Puerto Rico Follow-Up Audit











X

X

X

Information Resources
Management Directorate

















EPA's Compliance with the
Federal Information Security
Modernization Act for FY 2020











X



X

Evaluation of Region 5 Processes
for Investigating Potential Loss of
Records











X



X

Evaluation of Practices for
Identifying Potential Information
Technology Vulnerabilities that
Could Compromise EPA Systems
and Data











X



X

Evaluation of the Information
Technology Support Services
Performed Underthe ATTAIN
Contract











X



X

Land Cleanup and Waste
Management Directorate

















Congressional Request Regarding
the Use of EPA Data to Prevent
Disproportionate Burden of
Exposure





X









X

Reviewing and Updating Soil
Sampling and Analysis Techniques
in EPA's Superfund Program





X









X

Toxics, Chemical Management,
and Pollution Prevention
Directorate

















Cape Fear North Carolina GenX
Contamination







X



X

X

X

EPA's Adherence to Pesticide
Registration Risk Assessment
Regulations, Policies, and
Procedures







X



X





12


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EPA's FY 2018-2022 Strategic Objectives





Provide for



Ensure

Prioritize



Partner with





Improve air

clean and

Revitalize land

safety of

robust

Compliance

states and other

Operate efficiently



quality

safe water

and prevent

chemicals

science

with the law

stakeholders

and effectively

Planned FY 2020 OIG Projects

(Objective

(Objective

contamination

(Objective

(Objective

(Objective

(Objectives 2.1,

(Objectives 3.2, 3.4,



1.1)

1.2)

(Objective 1.3)

1.4)

3.3)

3.1)

2.2)

3.5)

EPA's Implementation of the

















Endocrine Disruption Screening







X





X

X

Program

















FIFRA Special Local Needs





X

X





X

X

Exemptions for Pesticides









Dicamba New Use Registration







X



X



X

Water Directorate

















Plastics in U.S. Waters



X











X

Follow-Up Evaluation of OIG

















Report "EPA Has Not Reported to

















Congress on BEACH Act Progress



X











X

as Statutorily Required or Fully

















Documented Budget Decisions"

















Harmful Algal Blooms



X











X

EPA's Oversight of Tribal Drinking
Water Systems



X

X

X

X

X

X



Protecting Drinking Waterfrom



X



X

X

X





Effects of Wildfires









Immediate Office for OA&E

















EPA FY 2020 Management
Challenges

X

X

X

X



X

X

X

Quality Control Review of OIG















X

Reports Issued in FY 2019















FY 2020 Semiannual Report to

















Congress (for the period ending















X

March 31, 2020)

















As of February 2020, the following reports have been issued for FY 2020:

13


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Report Title

Directorate

Report No.

Date Issued

1

Region 4 Quickly Assessed Water Systems After Hurricane Irma but Can
Improve Emergency Preparedness

Water

20-P-0001

October 7, 2019

2

EPA's Purchase Card and Convenience Check Program Merits an Audit
in Fiscal Year 2020

Contracts and
Assistance Agreement

20-P-0006

October 18, 2019

3

Management Alert: EPA Still Unable to Validate that Contractors Received
Role-Based Training for Information Security Protection

Information Resources
Management

20-P-0007

October 21, 2019

4

EPA Adequately Managed Hurricane Harvey Funding Received from FEMA

Efficiency

20-P-0010

October 23, 2019

5

While EPA Regions Enforce at Six Superfund Sites Reviewed, Four of Those
Sites Remain in Significant Noncompliance, and Nationwide Reporting and
Tracking Can Be Improved

Land Cleanup and
Waste Management

20-P-0011

October 24, 2019

6

Tribal Pesticide Enforcement Comes Close to Achieving EPA Goals, but
'Circuit Rider' Inspector Guidance Needed

Toxics, Chemical
Management, and
Pollution Prevention

20-P-0012

October 29, 2019

7

EPA Budget Systems Need Improved Oversight of Security Controls Testing

Information Resources
Management

20-P-0015

November 1, 2019

8

EPA's Fiscal Year 2019 First Quarter Compliance with the Digital
Accountability and Transparency Act of 2014

Financial

20-P-0026

November 8, 2019

9

Management Alert: Unapproved Use of Slag at Anaconda Co. Smelter
Superfund Site

Land Cleanup and
Waste Management

20-N-0030

November 18,
2019

10

Audit of the U.S. Chemical Safety and Hazard Investigation Board's Fiscal
Years 2019 and 2018 Financial Statements

Financial

20-F-0032

November 19,
2019

11

EPA's Fiscal Years 2019 and 2018 (Restated) Consolidated Financial
Statements

Financial

20-F-0033

November 19,
2019

12

EPA Failed to Develop Required Cost and Benefit Analyses and to Assess
Air Quality Impacts on Children's Health for Proposed Glider Repeal Rule
Allowing Used Engines in Heavy-Duty Trucks

Environmental
Research Programs

20-P-0047

December 5, 2019

13

Despite Requirements of Inspector General Act, Chief of Staff Refuses to
Provide Agency Information for OIG Evaluation; Required Whistleblower
Training Does Not Address Interference with or Intimidation of
Congressional Witnesses

Forensic

20-E-0053

December 10,
2019

14

EPA Needs to Improve Its Emergency Planning to Better Address Air
Quality Concerns During Future Disasters

Air

20-P-0062

December 16,
2019

15

Outdated EPA Leave Manual and Control Weaknesses Caused Irregularities
in the Office of Air and Radiation's Timekeeping Practices

Forensic

20-P-0063

December 19,
2019

16

EPA Needs to Improve Management and Monitoring of Time-Off Awards

Forensic

20-P-0065

December 30,
2019

17

EPA Can Improve Incident Readiness with Better Management of
Homeland Security and Emergency Response Equipment

Efficiency

20-P-0066

January 3, 2020

18

EPA Should Improve Oversight of Mobile Phones

Efficiency

20-P-0068

January 10, 2020

19

U.S. Chemical Safety and Hazard Investigation Board's Compliance in Fiscal
Year 2019 with Improper Payments Legislation and Guidance

Efficiency

20-N-0064

January 23, 2020

20

CSB's Information Security Program Is Defined, but Improvements Needed
in Risk Management, Identity and Access Management, and Incident
Response

Information Resources
Management

20-P-0077

February 12, 2020

21

Management Controls Needed to Verify and Report Border 2020 Program
Accomplishments

Toxics, Chemical
Management, and
Pollution Prevention

20-P-0083

February 18, 2020

14


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Identifying Risks at CSB

Top CSB Management Challenges — Reported by OIG in FY 2019

The OIG reviewed the major risks, challenges, and planning priorities across the CSB and
solicited input from leadership to identify and select OIG topics of interest that would be of
greatest benefit to the board and the American public. This section summarizes the CSB's key
management challenges identified by the OIG in FY 2019, which will help guide the general
direction and focus of OIG audit and investigative work in FY 2020.

Without New Members by August 2020, the CSB Governing Body Cannot Complete Its
Mission or Meet Its Goals

As of May 2019, there was a risk that the CSB could have a governing body consisting of one
member by February 2020 and have no governing body by August 2020 because of term
expiration dates and the time it takes to select, nominate, and confirm a board member. With one
member, it is uncertain whether a quorum can be established. The governing body must obtain a
quorum to meet its mission and goals because staff do not have the authority to carry out
functions such as budgeting, planning, oversight, and approval of investigations.

Congress has documented its support of the CSB mission to the current administration in letters
to the White House Chief of Staff in August 2018 and October 2018. In those letters, members
urged the administration to fill the Chairperson position and other governing body vacancies.
The CSB Interim Executive Authority met with the White House Office of Presidential
Personnel in February 2019 and discussed the roles and responsibilities of the board members
and what experiences the nominees should have. Given the amount of time necessary to identify,
nominate, and confirm a board member, there is a high risk that the governing body could be
reduced to a level that would not allow a quorum required to govern CSB operations.

The CSB Has Not Developed Guidance on Board Member Responsibilities

CSB board members and managers asserted that there were multiple instances in FY 2018 when
a board member acted inconsistently with established practices or inappropriately provided
information to entities outside the CSB. Specifically, a board member publicized budget
information before it was presented to Congress, attempted to share information with one
stakeholder before sharing it with all stakeholders, and made comments on a proposed rule
before a CSB position was developed.

In December 2018, the board members stated that there have been no new incidents of improper
communications from board members. Several people we interviewed—including board
members, the acting General Counsel and the Senior Advisor to the CSB—attributed this
development to better communication among staff and the board members.

The lack of additional incidents in FY 2019 is a positive sign for the board; however, guidance is
needed to define the roles of the board members. The CSB authorizing legislation does not create
a supervisory role for the Chairperson with respect to the other board members. Without the
explicit authority for the Chairperson to hold board members accountable, an environment exists

15


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that enables behaviors that impede the CSB's mission and lowers morale among CSB career
staff.

Matrix of CSB Goals OIG Plans to Address with Audits

When conducting our mandated work during FY 2020, we will consider the CSB's three
strategic goals outlined in its FY 2017-2021 Strategic Plan. The table below shows how our
planned FY 2020 audits and evaluations align with each of the CSB's goals.



CSB's FY 2017-2021 Strategic Goals



Prevent







recurrence of

Advocate safety





significant

and achieve

Create and



chemical incidents

change through

maintain an



through

recommendations,

engaged,



independent

outreach, and

high-performing

Planned FY 2020 OIG projects

investigations

education

workforce

Financial Directorate







FY 2020 CSB Financial Statements (Contracted)





X

Information Resources Management







Directorate







CSB Compliance with the FISMA for FY 2020





X

Immediate Office for OA&E







CSB FY 2020 Management Challenges

X

X

X

The following sections detail specific work that will be continued or initiated in FY 2020 within
each OA&E directorate.

Air Directorate

The Air Directorate is responsible for conducting assignments to assess the EPA's programs and
activities to protect human health and the environment through air quality goals.

Point of Contact: Jim Hatfield, Director, (919) 541-1030

Title

Primary objectives

Estimated/actual
start date

Carryover

EPA's Indian Country New
Source Review Program
(OA&E-FY18-0267)

Determine the EPA's progress in implementing a Clean Air
Act preconstruction permitting program for new sources
and modifications in Indian Country.

Fourth Quarter
2018

Landfill Emissions
(OA&E-FY18-0273)

Determine whether active landfills are operating under
the appropriate air quality permit.

Fourth Quarter
2018

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Title

Primary objectives

Estimated/actual
start date

EPA Actions to Address
Elevated Cancer Risks from Air
Toxics Emissions from Point
Sources

(OA& E-FY19-0091)

Determine whether EPA's residual risk and technology
review process has sufficiently identified and addressed
any elevated cancer risks from air toxics emitted by major
facilities.

Second Quarter
2019

EPA Oversight of Synthetic
Minor Sources
(OA&E-FY19-0093)

Determine whether the EPA and state/local oversight is
sufficient to assure that "synthetic minor" sources comply
with the emission or operational limits in their air
permits.

First Quarter
2020

EPA's External Civil Rights
Compliance Office's Response
to Title VI Complaints
(OA&E-FY19-0357)

Determine whether the EPA's External Civil Rights
Compliance Office has implemented an oversight system
to provide reasonable assurance that organizations
receiving EPA funds comply with Title VI requirements.

First Quarter
2020

Mandated

NONE

New Discretionary

Status of the Clean Air Act
State Implementation Plan
Submittals and Approvals

To determine (1) the number of Clean Air Act State
Implementation Plans awaiting EPA approval; (2) factors
causing delays in approvals; (3) the extent to which states
have not submitted required implementation plans to the
EPA; (4) the potential impact of delays in implementation
plans processing on achieving air quality standards; and
(5) what steps EPA is taking to address delays in
processing.

Second Quarter
2020

Audit Follow-Up Assignment

Determine whether the EPA implemented the audit
report's recommendations.

Second Quarter
2020

EPA's School Siting Guidelines

Determine whether and how the EPA is measuring the
success or progress of the School Siting Guidelines to
improve indoor air quality in schools.

Third Quarter
2020

Contract and Assistance Agreement Directorate

The Contract and Assistance Agreement Directorate is responsible for conducting assignments
on the EPA's management of contracts, grants, cooperative agreements, and interagency
agreements.

Point of Contact: Khadija Walker, Director, (312) 886-3106

Title

Primary objectives

Estimated/actual
start date

Carryover

Hotline Compliant 2018-0227
- Contract Compliance for EPA
Contract EP-C-16-001
(OA& E-FY18-0234)

Determine whether funding actions taken by the EPA are
allowed; they cause risks to the Agency; and invoices are
being approved and paid without proper review of costs.

Third Quarter
2018

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Estimated/actual

Title

Primary objectives

start date

Oversight of Office of

Determine whether (1) the Office of Research and

Third Quarter

Research and Development

Development oversees and monitors grants awarded to

2018

Grants to Universities

universities in accordance with applicable laws,



(OA& E-FY18-0248)

regulations, policies, and procedures and (2) university
grantees are completing agreed upon work which meets
the defined purpose of the grant.



EPA Oversight of Assistance

Eetermine (1) the dollar amount of EPA awards that have

Fourth Quarter

Agreement Close-Out (per the

expired at least two years ago with unliquidated

2018

Grants Oversight and New

obligations or zero obligations remaining, and whether



Efficiency Act)

the EPA has complied with RMDS 2520-03-p2, EPA Order



(OA& E-FY18-0250)

5700.6A2 Policy on Compliance, EPA Order 1610, and
Office of Management and Budget Uniform Grants
Guidance §200.343; (2) the reasons the EPA carried
expired awards for two or more years (potential scenarios
include administrative documentation not submitted to
the EPA, programmatic documentation (final reports) not
submitted to the EPA, or projects not completed); and (3)
the impact of the expired awards, such as the financial
impact of unliquidated obligations and debt costs,
potential environmental and public health results from
projects not completed, or unspent funds.



Office of the Chief Financial

To determine whether (1) contracts EPW18007 and

First Quarter

Officer Contract Award -

EPW18008 were properly awarded in accordance with

2019

Hotline Complaint

Federal Acquisition Regulation competition requirements,



(OA&E-FY19-0035)

and (2) equipment purchased under EPW07024 was
properly purchased and transferred to current contracts
in accordance FAR requirements.



Mandated

EPA Improper Payments

To evaluate EPA's reporting of improper payments during

First Quarter

Reporting for FY 2019

FY 2019.

2020

Cincinnati Finance Center -

Evaluate the EPA's internal control over travel cards and

Second Quarter

Travel Card Audit

determine the risk of illegal, improper, or erroneous use
of travel cards.

2020

Purchase Card and

Determine whether the EPA has implemented corrective

Fourth Quarter

Convenience Check Audit

actions to reduce the potential for illegal, improper, or
erroneous use of purchase cards and convenience checks.

2020

New Discretionary

Agency Use of Blanket

Determine whether (1) blanket purchase agreements

Second Quarter

Purchase Agreements

comply with applicable laws, regulations, contract
provisions, and other requirements; and (2)
the EPA is maximizing usage of current blanket purchase
agreements to achieve savings and whether other blanket
purchase agreement opportunities exist.

2020

Enterprise Acquisition System

To determine the validity, completeness, and accuracy of

Second Quarter

Data Integrity - Input into the

Enterprise Acquisition System data for reliability purposes

2020

System

and to assess its timeliness, availability, and ease of use to
obtain data needed.



Enterprise Acquisition System

To determine compliance with FAR regulations and EPA

Third Quarter

Data Integrity - Controls over

criteria.

2020

Contract Clauses





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Efficiency Directorate

The Efficiency Directorate is responsible for identifying ways for EPA and CSB programs and
operations to improve processes and realize cost savings, thus freeing resources for high-priority
environmental projects.

Point of Contact: Mike Davis, Director, (513) 487-2363

Title

Primary objectives

Estimated/actual
start date

Carryover

PeoplePlus Efficiency and
Effectiveness
(OA&E-FY18-0283)

Determine whether PeoplePlus is efficient and effective for
use in the time and attendance and cost allocation
processes and has effective practices, programs, and
policies.

First Quarter
2019

EPA's Risk Assessment
Process

(OA& E-FY19-0034)

Determine whether the EPA is following GAO's standards
for required risk assessments among its 104 programs (or a
sample within the 104). We would determine the Internal
Control in the Federal Government and Office of
Management and Budget Circular A-123 for preparing risk
assessments for programs. We would determine the rate
at which the EPA has not conducted why risk assessments
were not conducted. Our audit will focus on the GAO's
second of the five internal control standards for federal
programs—risk assessment.

First Quarter
2019

Indian Tribal Grants
(OA& E-FY 19-0314)

Determine whether the costs claimed under selected,
individual Indian tribal grants are reasonable, allocable,
and allowable in accordance with applicable laws,
regulations, and grant terms and conditions.

Fourth Quarter
2019

Mandated

NONE

New Discretionary

EPA's Lab Consolidation
Efforts at Three of Its
Laboratory Facilities

Determine whether the EPA's consolidation efforts at
laboratories in Athens, Georgia; Corvallis, Oregon; and
Grosse lie, Mississippi; are within cost and on schedule.

First Quarter
2020

Implementation of Federal
Green Challenge and
Compliance with Executive
Order 13834

Determine the extent to which the EPA has implemented
the Federal Green Challenge and whether implementation
has influenced reducing building operations cost in
compliance with Executive Order 13834.

First Quarter
2020

Awarded Diesel Emissions
Reduction Act Grants

Determine whether (1) competitive grants funded under
the Diesel Emissions Reduction Act for the Clean Diesel
Funding Assistance Program and spent by recipients were
allowable, allocable, and reasonably awarded, and (2) the
program was executed efficiently.

Second Quarter
2020

Compliance with Regulations
Concerning Federal
Contractors that Have Tax
Debt

Determine whether the EPA is (1) awarding contracts to
contractors with tax debt and (2) complying with applicable
laws, regulations, policies, and procedures for the
management of federal contractors with tax debts.

Second Quarter
2020

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Environmental Research Programs Directorate

The Environmental Research Programs Directorate conducts independent assignments that look
at the EPA's research and development programs, with a focus on areas that support human
health and environmental protection.

Point of Contact: Patrick Gilbride, Director, (303) 312-6969

Title

Primary objectives

Estimated/actual
start date

Carryover

Implementation of the
EPA's Scientific Integrity
Policy (OA&E-FY18-0272)

Examine whether the EPA's Scientific Integrity Policy is
being implemented as intended to assure scientific integrity
throughout the EPA. In particular, the project will examine
(1) extent and type of employee concerns, if any, with
scientific integrity at the EPA; (2) employee awareness of
the EPA's Scientific Integrity Policy, including the process for
reporting potential violations; (3) reasons for any non-
reporting of potential violations; and (4) the adjudication
process in general and any concerns, such as satisfaction
with complaint resolution, timeliness of resolution, and
other process-related issues.

Fourth Quarter
2018

Congressional Request on
Glider Proposed Rule
Making

(OA&E-FY19-0053)

Determine whether the EPA complied with Executive Orders
12866 and 13045 in developing EPA proposed rulemaking
"Repeal of Emission Requirements for Glider Vehicles, Glider
Engines, and Glider Kits."

First Quarter
2019

Hotline: Office of Mission
Support Controls for
Carrying Out Its
Responsibility to Develop
and Coordinate an
Agencywide Quality System
(OA&E-FY19-0329)

Determine whether the Office of Mission Support has
controls in place to carry out its responsibility in developing
and coordinating the mandatory Agencywide Quality
System.

Fourth Quarter
2019

Mandated

NONE

New Discretionary

Action Development
Process for Rulemaking
(OA&E-FY20-0067)

Determine whether the EPA adhered to its Action
Development Process for selected rulemakings.

First Quarter
2020

Hotline: Evaluating EPA's
Response to Findings from
Audits and Inspections
Related to Its National
Enforcement Investigations
Center (OA&E-FY20-0099)

Determine whether the Office of Enforcement and
Compliance Assurance's Office of Criminal Enforcement,
Forensics, and Training and the National Enforcement
Investigations Center are addressing findings and
implementing corrective actions from audits, inspections,
and documented concerns related to the National
Enforcement Investigations Center.

Second Quarter
2020

EPA's Peer Review Process

Determine whether the EPA complies with its peer review
process, including documenting decisions/justifications to
not conduct peer reviews and any potential impacts to
Agency decision-making stemming from noncompliance.
The Office of Research and Development's Office of the
Science Advisor is responsible for peer reviews.

Fourth Quarter
2020

20


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Financial Directorate

The Financial Directorate is responsible for rendering opinions on financial statements produced
by the EPA and the CSB, and it conducts audits of other EPA financial matters for efficiency
and effectiveness.

Point of Contact: Paul Curtis, Director, (202) 566-2523

Title

Primary objectives

Estimated/actual
start date

Carryover

FY 2018 Financial
Statements: Hazardous
Waste Electronic Manifest
System Fund
(OA&E-FY19-0120)

Determine whether (1) financial statements were fairly
presented in all material respects; (2) internal control over
financial reporting was in place; and (3) management
complied with applicable laws and regulations.

First Quarter
2019

FY 2018 Financial
Statements: Pesticides
Registration Fund (PRIA)
(OA& E-FY19-0121)

Render an opinion on the Agency's PRIA financial
statements and determine compliance with laws and
regulations, effectiveness of internal control, and accuracy
of reported performance information.

First Quarter
2019

FY 2018 Financial
Statements: Pesticides
Reregistration and
Expedited Processing Fund
(FIFRA) (OA&E-FY19-0122)

Render an opinion on the Agency's FIFRA financial
statements and determine compliance with laws and
regulations, effectiveness of internal control, and accuracy
of reported performance information.

First Quarter
2019

Mandated

FY 2019 Financial
Statements: Hazardous
Waste Electronic Manifest
System Fund

Determine whether (1) financial statements were fairly
presented in all material respects, (2) internal control over
financial reporting was in place, and (3) management
complied with applicable laws and regulations.

Second Quarter
2020

FY 2019 Financial
Statements: Pesticides
Registration Fund (Pesticide
Registration Improvement
Act of 2003) (PRIA)

Render an opinion on the Agency's PRIA financial
statements and determine (1) compliance with laws and
regulations, (2) effectiveness of internal control, and
(3) accuracy of reported performance information.

Second Quarter
2020

FY 2019 Financial
Statements: Pesticides
Reregistration and
Expedited Processing Fund
(FIFRA)

Render an opinion on the Agency's FIFRA financial
statements and determine (1) compliance with laws and
regulations, (2) effectiveness of internal control, and
(3) accuracy of reported performance information.

Second Quarter
2020

FY 2020 EPA Financial
Statements

Determine whether (1) consolidated financial statements
were fairly stated in all material respects, (2) internal
control over financial reporting were in place, and (3)
management complied with applicable laws and
regulations.

Third Quarter
2020

21


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Title

Primary objectives

Estimated/actual
start date

FY 2019 Financial
Statements: Frank R.
Lautenberg Chemical Safety
for the 21st Century Act

Render an opinion on the Agency's financial statements and
determine whether (1) the financial statements required by
the Frank R. Lautenberg Chemical Safety for the 21st
Century Act were fairly presented in all material respects,
(2) the EPA's internal control over financial reporting were
in place, and (3) EPA management complied with applicable
laws and regulations.

Third Quarter
2020

FY 2020 CSB Financial
Statements (Contracted)

Determine whether (1) financial statements were fairly
stated in all material respects, (2) internal control over
financial reporting were in place, and (3) management
complied with applicable laws and regulations.

Fourth Quarter
2020

Forensic Directorate

The Forensic Directorate is responsible for conducting audits of EPA assistance agreements and
contracts to identify potentially fraudulent actions. This directorate also determines the
acceptability of costs claimed under specific financial instruments. Forensic audits apply
auditing skills to situations with legal consequences and use risk assessment tools to represent
the first line of defense against fraud, waste, and abuse in Agency programs.

Point of Contact: John Trefry, Director, (202) 566-2474





Estimated/actual

Title

Primary objectives

start date

Carryover

Office of Air and

Examine the Office of Air and Radiation's timekeeping

Second Quarter

Radiation Timekeeping

practices to determine whether they comply with Agency

2017

Practices

policies and procedures, and relevant regulations.



(OA-FY17-0090)





Salary Overpayment and

The purpose of this audit is to determine whether the Agency

Second Quarter

Debt Forgiveness Process

is properly collecting salary overpayments from its employees.

2018

(OA-FY18-0084)





EPA's Use of

Determine whether the EPA is using the Intergovernmental

Fourth Quarter

Intergovernmental

Personnel Act Agreements and detail instruments to achieve

2019

Personnel Act

the results intended.



Agreements and Details





(OA& E-FY19-0271)





EPA's Administration of

Determine whether the EPA is effectively managing its Federal

Fourth Quarter

its Federal Employees

Employees Compensation Act program; that it pays only valid

2019

Compensation Act

claims for continuation of benefits; and that adequate case



Program

management exists.



(OA&E-FY19-0292)





22


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Title

Primary objectives

Estimated/actual
start date

Military Pay-Setting For
Reservist Differential and
Active Duty Pay
(OA&E-FY19-0286)

Determine whether (1) the EPA has established effective
controls to prevent or detect reservist differential errors and
overpayments and collect any resulting debt; and (2) reservists
called to active duty under 5 U.S.C. § 6323 (a and b) are having
their civilian pay reduced as required. Under 5 U.S.C. 5538,
employing agencies must pay differential payments to eligible
federal civilian employees who are members of the Reserve or
National Guard called or ordered to active duty under certain
specified provisions of law.

Fourth Quarter
2019

Mandated

FY 2020 Single Audit
Program

Conduct reviews of and process single audit reports that are
prepared by Certified Public Accountant firms and state audit
organizations.

First Quarter
2020

New Discretionary

Office of Air and
Radiation's National
Center for Radiation Field
Operations Preparedness

Determine whether the National Center for Radiation Field
Operations is prepared for and capable of performing its
current roles and responsibilities in responding to radiological
emergencies.

Second Quarter
2020

EPA's Working Capital
Fund Operations,
Expenditures, and Rate
Establishment

Determine whether the EPA's (1) Working Capital Fund is
operating efficiently by keeping expenditures low; (2) the basis
of rates established for various services is properly supported;
and (3) allocations of costs to the Working Capital Fund are
reasonable, allowable, and proper.

Second Quarter
2020

EPA's Awarding of
Performance Partnership
Grants

Determine whether the EPA is awarding Performance
Partnership Grants to eligible applicants.

Second Quarter
2020

Puerto Rico Follow-Up
Audit

Determine whether Puerto Rico has implemented controls to
maintain the integrity of its Clean Water State Revolving Fund
and Drinking Water State Revolving Fund, and has the
resources needed to provide effective management and
oversight of the programs.

Fourth Quarter
2020

Information Resources Management Directorate

The Information Resources Management Directorate reviews the economy, efficiency, and
effectiveness of EPA and CSB investments in systems for achieving environmental goals and
ensuring the integrity of data used for decision-making. The directorate also reviews strategies
for setting priorities and developing plans to accomplish priorities and measure performance.

Point of Contact: Rudolph Brevard, Director, (202) 566-0893

Title

Primary objectives

Estimated/actual
start date

Carryover

CSB's Compliance with
the FISMAfor FY 2019
(OA&E-FY19-0213)

Determine whether the CSB implemented an information
security management program compliant with the FISMA of
2014.

Third Quarter
2019

EPA's Compliance with
the FISMAfor FY 2019
(OA& E-FY19-0208)

Determine whether the EPA implemented an information
systems security program that is compliant with the
requirements outlined in the FISMA of 2014.

Third Quarter
2019

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Title

Primary objectives

Estimated/actual
start date

Mandated

CSB's Compliance with
the FISMAfor FY 2020

Determine whether the CSB implemented an information
security management program compliant with the FISMA of
2014.

Third Quarter
2020

EPA's Compliance with
the FISMAfor FY2020

Determine whether the EPA implemented an information
systems security program that is compliant with the
requirements outlined in the FISMA of 2014.

Third Quarter
2020

New Discretionary

Evaluation of Region 5
Processes for
Investigating Potential
Loss of Records

Determine whether (1) Region 5 lost federal records when
transferring computer files during its annual data backup
process and (2) Region 5 followed its processes to investigate
the potential loss of records.

Second Quarter
2020

Evaluation of Practices
for Identifying Potential
Information Technology
Vulnerabilities that Could
Compromise EPA Systems
and Data

Evaluate the completeness of the EPA processes for testing its
network to identify potential vulnerabilities that could
compromise the Agency's systems and data. Conduct
independent automated vulnerability testing of IT resources
connected to EPA's network to identify potential
vulnerabilities that could be used to compromise the
confidentiality, integrity, and availability of Agency
information systems and data.

Second Quarter
2020

Evaluation of the
Information Technology
Support Services
Performed Under the
ATTAIN Contract

Determine whether the EPA paid ATTAIN, its IT support
contractor, for services that were either (1) not performed or
(2) performed by other EPA contractors.

Second Quarter
2020

Land Cleanup and Waste Management Directorate

The Land Cleanup and Waste Management Directorate is responsible for conducting
assignments to assess EPA programs, activities, and initiatives to protect human health and the
environment through cleanup and waste management, accident prevention, and emergency
response.

Point of Contact: Tina Lovingood, Director, (202) 566-2906

Title

Primary objectives

Estimated/actual
start date

Carryover





EPA Enforcement of Toxic
Release Inventory Late
Reporter

(OA&E-FY18-0002)

Determine whether the EPA is taking enforcement actions
against companies that delay reporting chemical release data
required by Toxic Release Inventory criteria.

First Quarter
2019

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Title

Primary objectives

Estimated/actual
start date

Communication of Human
Health Risk at Sites in
Office of Land and
Emergency Management's
Programs
(OA&E-FY19-0031)

Determine whether the EPA is communicating sampling
results or other indicators of human health risk at select EPA-
led sites in the Office of Land and Emergency Management
programs in a manner that allows the impacted communities
to avoid exposure to harmful contaminants or substances.

First Quarter 2019

Superfund Site Visits
(OA& E-FY19-0090)

Verify the effectiveness of institutional controls.

Fourth Quarter
2019

Post-Closure Care at
Hazardous Waste Units
Closed with Waste in Place
(OA&E-FY19-0323)

Evaluate the EPA's oversight of hazardous waste units closed
with waste in place to verify continued protection of human
health and the environment.

Fourth Quarter
2019

Mandated

NONE

New Discretionary

Congressional Request
Regarding the Use of EPA
Data to Prevent
Disproportionate Burden
of Exposure

Determine how the EPA Land programs (Superfund and
Resource Conservation and Recovery Act) are using EPA data
to prevent disproportionate burden of exposure to any
community.

Second Quarter
2020

Reviewing and Updating
Soil Sampling and Analysis
Techniques in EPA's
Superfund Program

Determine whether the EPA's Superfund program is
effectively reviewing and updating soil sampling and analysis
techniques.

Third Quarter
2020

Toxics, Chemical Management, and Pollution Prevention Directorate

The Toxics, Chemical Management, and Pollution Prevention Directorate is responsible for
conducting assignments to assess the EPA's management of chemical risks and programs to
prevent pollution.

Point of Contact: Jeffrey Harris, Director, (202) 566-0831



Title

Primary objectives

Estimated/actual
start date

Carryover

Lautenberg Chemical
Safety Act Resource
Planning and Management
(OA&E-FY19-0127)

Determine whether (1) Office of Chemical Safety and
Pollution Prevention/Office of Prevention, Pesticides, and
Toxic Substances has met all Lautenberg Act deadlines to
date, and whether the Office of Prevention, Pesticides, and
Toxic Substances has developed management plans and
internal management controls to meet the ongoing
statutory requirements of the law; and (2) the Office of
Prevention, Pesticides, and Toxic Substances developed and
implemented all requirements of the Lautenberg Act,
including management and planning steps, implementation
processes, internal control, and alternative plans for
meeting statutory deadlines regardless of resource or
human capital allocations.

Third Quarter
2019

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Title

Primary objectives

Estimated/actual
start date

Border 2020 Program
(OA&E-FY19-0245)

To evaluate the effectiveness of the Border 2020 program
controls implemented in response to the 2008 OIG review,
determine: (1) whether current program controls (strategic
plan, performance measures, action plans in EPA Regions 6
and 9, grantee and partner guidance on project
documentation, and data quality) are sufficient for verifying
that program objectives and activities are accomplished and
are linked to the achievement of desired environmental and
human health goals and benefits; and (2) the progress the
program demonstrates toward achieving environmental
objectives (e.g. promote access to safe drinking water for
5,000 households, maintain effective air monitoring
networks) in its strategic plan that were scheduled for
completion in 2014, 2015, and 2018.

Fourth Quarter
2019

Mandated

NONE

New Discretionary

Cape Fear North Carolina
GenX Contamination
(OA&E-FY19-0348)

Determine what actions the EPA took to verify compliance
with requirements of its administrative 2009 Toxic
Substances Control Act consent order with Chemours
(Dupont) to prevent release of the chemical GenX in the
Cape Fear River basin.

Second Quarter
2020

EPA's Adherence to
Pesticide Registration Risk
Assessment Regulations,
Policies, and Procedures

Determine the EPA's adherence to applicable regulations,
policies, and procedures in assessing risks to human health
and the environment in the pesticide registration process.

Second Quarter
2020

EPA's Implementation of
the Endocrine Disruption
Screening Program

Determine the Office of Pesticides Program's (1) progress in
implementing the requirement of Section 408(p)(3)(A) of the
Food Quality Protection Act to test all active pesticides for
endocrine disruption activity; and (2) compliance with
implementing Section 408(p)(6) of the Food Quality
Protection Act, which requires the EPA to take action (e.g.,
conduct an endocrine disruption risk assessment for the
pesticide) if the testing shows that the pesticide disrupts the
human endocrine system.

Third Quarter
2021

FIFRA Special Local Needs
Exemptions for Pesticides

Determine what controls the EPA has in place to verify states
and whether the EPA is following procedures and policies for
review and approval of Special Local Needs Exemptions for
pesticides.

Third Quarter
2021

Dicamba New Use
Registration

Determine whether the EPA adheres to federal requirements
and scientifically sound principles for the 2016 registration
and 2018 renewal for the new uses of the Dicamba herbicide.

Fourth Quarter
2021

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Water Directorate

The Water Directorate is responsible for conducting assignments to assess the EPA's protection
and restoration of healthy aquatic communities and waters that sustain human health.

Point of Contact: Kathryn Hess, Acting Director, (617) 918-1487

Title

Primary objectives

Estimated/actual
start date

Carryover



Hurricane Response for
2017 Storms in Regions 6,
4, and 2

(OPE-FY18-0005)

Determine whether the EPA's preparedness and response
efforts during three 2017 hurricanes protected human health
and water resources from storm-related drinking and surface
water contamination.

Second Quarter
2018

EPA Enforcement Results

(2006-2018)

(OA& E-FY19-0030)

Identify the (1) trends in enforcement results stemming from
the EPA enforcement actions (injunctive relief,
supplementary environmental projects, and penalties) over
time (2006-2018); and (2) key factors explaining differences
in enforcement results stemming from EPA enforcement
actions over time among the EPA regions and among
environmental statutes.

Fourth Quarter
2019

EPA National Pollutant
Discharge Elimination
System Permit Review
(OA& E-FY19-0340)

Determine whether the EPA's reviews of state-proposed
National Pollutant Discharge Elimination System verify that
the permits adhere to Clean Water Act requirements.

Fourth Quarter
2019

Mandated

NONE

New Discretionary

Plastics in U.S. Waters
(OA&E-FY19-0086)

Determine how the EPA's Clean Water Act programs protect
human health and the environment from plastic pollution
and the effectiveness of EPA's research efforts to assess and
reduce plastics in U.S. waters.

First Quarter
2020

Follow-Up Evaluation of
OIG Report "EPA Has Not
Reported to Congress on
BEACH Act Progress as
Statutorily Required or
Fully Documented Budget
Decisions"
(OA&E-FY20-0062)

Determine whether the EPA implemented a key OIG
recommendation in OIG Report "EPA Has Not Reported to
Congress on BEACH Act Progress as Statutorily Required or
Fully Documented Budget Decisions" issued January 18,
2018.

First Quarter
2020

Harmful Algal Blooms
(OA&E-FY19-0085)

Determine how the EPA is addressing harmful algal blooms
under the Clean Water Act and Safe Drinking Water Act
authorities to protect human health and the environment.

Third Quarter
2020

EPA's Oversight of Tribal
Drinking Water Systems

Determine to what extent the EPA has implemented
compliance assistance and enforcement activities to help
public water systems in Indian Country provide safe drinking
water to customers.

Fourth Quarter
2020

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Title

Primary objectives

Estimated/actual
start date

Protecting Drinking Water
from Effects of Wildfires

Determine the extent to which the EPA uses its authorities to
confirm that large community water systems adequately
assess the risks from wildfires on their ability to provide safe
and clean drinking water under the revised Safe Drinking
Water Act risk assessment requirement and the Clean Water
Act Source Water Protection provision.

Fourth Quarter
2020

Immediate Office





The OA&E's Immediate Office is responsible for conducting new and follow-up audits to assess
Agency programs and functions and determining whether sufficient controls are in place to
reduce the Agency's risk of fraud, waste, and abuse in its operations. The Immediate Office also
develops, coordinates, and reports on OIG-identified Agency management challenges and
internal control weaknesses.

Points of Contact: Jerri Dorsey-Hall, Auditor, (919) 541-3601

Michael Petscavage, Auditor, (202) 566-0897
Eric Lewis, Auditor, (202) 566-2664



Title

Primary objectives

Estimated/actual
start date

Carryover

NONE

Mandated

EPA FY 2020 Management
Challenges

Identify the issues the OIG determines to be major
management challenges for the EPA in FY 2020.

First Quarter
2020

CSB FY 2020 Management
Challenges

Identify the issues the OIG has determined to be major
management challenges for the CSB in FY 2020.

First Quarter
2020

Quality Control Review of
OIG Reports Issued in
Fiscal Year 2019

Assess whether there are systemic issues during referencing,
compliance monitoring reviews, and compliance with
generally accepted government auditing standards and OIG
policy.

Second Quarter
2020

FY 2020 Semiannual
Report to Congress (for
the period ending
March 31, 2020)

Prepare data for the Semiannual Report to Congress for the
period ending March 31, 2020, to include the status of
unimplemented recommendations, corrective actions, and
monetary benefits up to the preceding six-month period
ending September 30, 2019.

Third Quarter
2020

New Discretionary

NONE

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The Plan: Office of Investigations
FY 2020 Focus

The OIG's 01 is responsible for investigating allegations of criminal activity and serious
misconduct involving EPA and CSB programs and operations. Due to the size and scope of the
EPA and its mission to protect human health and the environment, the 01 often collaborates with
other law enforcement entities and external stakeholders to enhance the effectiveness of its work.
We participate in interagency task forces and working groups. We also participate in OIG
outreach programs by providing fraud awareness briefings to educate Agency employee groups
and external organizations that receive EPA funds on potential indicators of fraud.

The Inspector General Act identifies the Assistant Inspector General for Investigations as being
responsible for supervising the performance of the investigative activities. The Assistant
Inspector General for Investigations' primary responsibilities include conducting criminal, civil,
and administrative investigations involving allegations of fraud, waste, and abuse relating to
EPA and CSB programs and activities; investigating allegations of serious misconduct by EPA
and CSB employees; interfacing with the Department of Justice on OIG-related criminal matters;
and coordinating investigations and OIG initiatives with other federal, state, local, and tribal
investigative agencies.

Investigations are opened in accordance with priorities set forth in the OIG Strategic Plan for
2019-2023 and in consideration of prosecutorial guidelines established by local U.S. Attorneys.
OIG investigations are governed by th q Attorney General Guidelines for Offices of Inspector
General with Statutory Law Enforcement Authority and by the CIGIE Quality Standards for
Investigations, as well as federal statutes and regulations.

Investigative efforts often lead to criminal convictions and civil and administrative remedies.
Investigations are initiated as a result of allegations or referrals from private citizens; audits and
evaluations; EPA and CSB employees; Congress; other federal, state, local, and tribal law
enforcement agencies; and proactive efforts directed at areas bearing a high potential for fraud,
waste, and abuse.

This annual investigative plan was developed to focus our OIG investigative priorities on more
fraud cases, and ensure our resources are used in the most effective and efficient manner. The
plan provides strategies and planned investigative work for FY 2020 in conjunction with the OIG
Strategic Plan. The most serious management and performance challenges facing the EPA and
the CSB were also considered in developing this plan.

Point of Contact: Helina Wong, Assistant Inspector General for Investigations, (202) 566-2841

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The following strategic measures will include what the 01 will be working toward in FY 2020
and beyond:

Strategic
Measure
#

Strategic Measure Description

1.2.1

By September 30, 2023, the OIG will be able to show quantitative measures supporting the OIG's
contribution to the reduction or elimination of environmental risks and challenges by conducting
audits, evaluations, or investigations. We will conduct at least one audit, evaluation, or investigation
addressing an emerging environmental risk or challenge.

2.1.1

By September 30, 2023, the OIG will have conducted investigations geared toward protecting the
integrity of programs and operations addressing the EPA's six priority goals.

2.1.2

By September 30, 2023, the OIG will have conducted investigations for the prevention of cyber-
related attacks. These investigations will result in increased protective measures codified in policy
and procedure.

2.4.1

By September 30, 2023, the OIG will have increased its capacity for case management of
investigations involving mismanagement and misconduct that result in fraud, waste, or abuse.

2.4.3

By September 30, 2023, the OIG will increase its return on investment to a minimum ratio of 12 to 1
as an average across the five years from 2019 to 2023.

3.3.2

By September 30, 2023, the OIG's Federal Employee Viewpoint Survey scores in at least three of the
five Office of Personnel Management embedded indexes (Employee Engagement, Global
Satisfaction, Effective Communications, New Inclusion Quotient, and Human Capital Assessment and
Accountability Framework) and will increase by at least 10 percent from each index's 2018 average.

3.3.3

By September 30, 2023, due to various programs that we put into place, the OIG will work to
increase its "Best Places to Work" score for an Agency subcomponent (as administered by the
Partnership for Public Service) by at least one quartile from FY 2018 levels.

Pending Investigative Activities

The 01 plays a critical oversight role helping to ensure that the EPA and the CSB funds are
properly expended and not subject to fraud, waste, or abuse. Pending cases as of
September 30, 2019, totaled 142 cases, as shown in Figure 1. It provides a summary of OIG
ongoing investigative activities by case category as of September 30, 2019. Of the 142 open
investigations, 75, or 53 percent, are fraud-related; and 42 cases, or 30 percent, involve employee
misconduct.

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Figure 1: Ongoing OIG investigation activities

Pending Cases as of September 30,2019
(142 Total)

4.2%

¦	Employee Misconduct

¦	Contract Fraud

¦ Grant Fraud

¦	Program Fraud

¦	*Other

¦	Computer Crime

¦	Threat

¦ Lab Fraud

Source: The OIG Ol.

*The "other" category covers investigations such as Falsifying Official Documents/Forgery, Misuse of
Government Property (by non-employee), and Destruction of Government Property (by non-employee).

The following section provides the actions the 01 will be taking to achieve each of the OIG
Strategic Goals.

Goal 1: Contribute to improved EPA and CSB programs and operations that protect
human health and the environment and enhancing safety.

The 01 will conduct investigations into allegations of fraud and other crimes involving EPA
grants and contracts that assist state, local, and tribal governments; universities; and nonprofit
recipients. The following are our FY 2020 priorities:

•	Financial fraud (grants and contracts). These investigations may involve multiple
agencies and focus on criminal activities related to Agency grants, state revolving funds,
interagency agreements, and assistance agreements that provide financial support to state,
local, and tribal governments; universities; and nonprofit recipients. Collectively, these
programs account for about half of the EPA's budget. These investigations also focus on
acquisition management, contracts, and procurements. The 01 specifically focuses on
mischarging, defective pricing, defective products, kickbacks, and collusion.

•	Program fraud. These investigations focus on activities that could undermine the
integrity of Agency programs involving public health and safety and erode the public
trust in the EPA and its employees. These cases involve serious misconduct or criminal
activity that relies on, takes advantage of, or exploits systematic weaknesses or
vulnerabilities of the Agency for personal gain. This can include individuals
misrepresenting themselves as EPA employees in a scheme or attempt to defraud, or the
fraudulent use of EPA seals, certifications, letterhead, or logos.

•	Laboratory fraud. These investigations deal with contract laboratory fraud relating to
water quality and superfund data, as well as payments made by the EPA for erroneous

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environmental testing data. Such activities could undermine the basis for EPA decision
making, regulatory compliance, and enforcement actions.

•	Computer intrusion. These investigations involve attacks against the EPA's computer
and network systems; suspicious behavior regarding EPA computer data; spear phishing;
and the protection of critical data, resources, infrastructure, and intellectual property.

Goal 2: Conduct audits and investigations that enable the EPA and the CSB to improve
business practices and accountability.

The OI's investigations of employee misconduct help the OIG improve operations at the EPA
and the CSB. The following are our FY 2020 priorities:

•	Employee integrity and alleged criminal conduct or serious administrative
misconduct. These investigations involve allegations made against EPA and CSB
employees involving matters that could threaten the credibility of the Agency and the
integrity of its resources. To communicate and coordinate on employee misconduct cases,
the 01 participates in biweekly meetings with the EPA's Office of General Counsel and the
Office of Mission Support.

•	Travel and purchase card fraud. These investigations include improper, abusive, or
questionable transactions using government travel and purchase cards. The 01
coordinates with the EPA's Office of the Chief Financial Officer to investigate instances
of abuse involving individual travel cards issued to Agency employees as well as
purchase cards issued for the procurement of supplies and equipment.

•	Small Business Innovative Research program fraud. The National Defense
Authorization Act for FY 2012 requires OIGs to report on reducing fraud, waste, and
abuse in the Small Business Innovative Research program. The 01 investigates
allegations of fraud against EPA Small Business Innovative Research contracts awarded
to recipients.

•	Disaster relief spending oversight. The 01 participates in investigations that involve
examining disaster relief spending for fraud, waste, and abuse. After a disaster, the EPA
assists the affected area to make it is safe for human habitation. This assistance may be
through grants and contracts from the EPA for safe drinking water, sewer treatment
facilities, and debris removal.

Goal 3: Improve OIG processes, resource allocation, and accountability to meet
stakeholder needs.

The 01 considers its workforce as its most important and valued resource. We will continue to
recruit, develop, and retain a well-qualified diverse workforce with the ability to meet twenty-
first century challenges. Additionally, we will enhance the use of technology to conduct our
business in a more effective and efficient manner. Our FY 2020 priorities are:

•	Workforce professional development. The 01 will recruit, develop, and retain a
diverse, dedicated workforce to fulfill critical mission requirements. The 01 will provide

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training opportunities to our staff so they are better equipped to investigate matters
involving emerging criminal trends and fraud schemes.

•	Proactive initiative. The 01 will work collaboratively with the OIG Data Analytics team
to identify potential investigative leads through data mining contract and grant databases
using known fraud indicators. The 01 will continue to look for opportunities to use data
analytics tools and methodologies to improve the overall efficiency and effectiveness in
the way it conducts investigations.

•	Computer forensics. The 01 continues to build a robust forensic lab and expand on its
digital forensic capabilities while improving its processes and procedures to effectively
identify and collect electronically stored information from various forms of media and
networks as well as the cloud and social media websites. The 01 provides the OIG
Special Agents and OA&E with an enhanced review capability of electronic data through
the use of forensic software.

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The Plan: Office of Counsel and
Congressional and Public Affairs
FY 2020 Focus

The OIG's OCCPA provides support to audits, evaluations, investigations, and management
services. The OCCPA provides legal, editing, and communication services, as described in more
detail below, which support the OIG in achieving Strategic Goal 1 to contribute to improved
EPA and CSB programs and operations protecting human health and the environment, and
enhancing safety. Further, the OCCPA's support services advance the OIG's Strategic Goal 2,
which is to enable the EPA and the CSB to improve business practices and accountability.
Finally, the OCCPA embraces Strategic Goal 3 objectives so that our services are timely,
efficient, and supported by a high-performing professional staff.

Point of Contact: Eric Hanger, Deputy Counsel to the Inspector General, (202) 566-0866

The OCCPA provides support to the OIG's overall achievements of the three strategic goals and
the objectives established for each component office (see Appendices A and B for a complete list
of OIG's goals, objectives, and strategic measures). In FY 2020, OCCPA activities also will
specifically support the following strategic measures.

Strategic
Measure
#

Strategic Measure Description

1.2.3

By September 30, 2023, the OIG will have refined its performance metrics to better align with mission
objectives, improve our ability to "tell the OIG story" of our influence, and impact on our contribution
to the elimination of environmental risks and challenges, and confirm that we maintain relevance with
current goals and objectives.

3.1.1

By September 30, 2023, the OIG will implement new timeliness measures and goals on products and
services provided to our stakeholders and to the Agency.

3.2.2

By September 30, 2023, the OIG will have implemented an enterprise risk management system whose
governance and cycle of accountability will increase our organization's effectiveness.

3.2.3

By September 30, 2023, the OIG will identify high-risk and high-vulnerability OIG activities, implement
appropriate review for activities that are considered high-risk, and minimize them to an appropriate
degree. The OIG will implement at least one mitigation plan.

3.3.1

By September 30, 2023, the OIG will match or improve on federal government retention rates and will
continue to develop programs to attract and retain high-talent staff.

3.3.2

By September 30, 2023, the OIG's Federal Employee Viewpoint Survey scores in at least three of the
five Office of Personnel Management embedded indexes (Employee Engagement, Global Satisfaction,
Effective Communications, New Inclusion Quotient, and Human Capital Assessment and
Accountability Framework) and will increase by at least 10 percent from each index's 2018 average.

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Strategic
Measure
#

Strategic Measure Description

3.3.3

By September 30, 2023, due to various programs that we put into place, the OIG will work to increase
its "Best Places to Work" score for an Agency subcomponent (as administered by the Partnership for
Public Service) by at least one quartile from FY 2018 levels.

FY 2020 OCCPA Annual Plan

Office of Congressional and Public Affairs

Within the OCCPA, the OCPA is charged with supporting the OIG's Strategic Measure 1.2.3 to
"tell the OIG story" of our influence and impact toward mitigating environmental risks and
challenges, promoting efficiency, and making progress toward established OIG goals and
objectives. This mission supports the OIG's priority to "execute a clear messaging strategy
geared toward increased visibility in support of ensuring the free-flow of information from the
public that would assist in rooting out fraud, waste, and abuse in environmental and health and
human services programs and associated initiatives."

The OCPA also has primary responsibility for addressing a second OIG priority: "Continue to be
responsive to congressional inquiries and actively assess and address hotline complaints."

The OCPA communicates with Congress, the news media, and the general public about the
OIG's work. In FY 2019, the OCPA received about 269 congressional and 250 media inquiries,
and 15 congressional requests for the OIG to conduct audits and investigations on specific topics.
The OCPA staff also actively pursue outreach meetings with journalists who cover the EPA in
order to introduce the OIG's mission, and to learn more about the needs and interests of media
outlets. Further, the OCPA staff regularly research and respond to questions about the OIG's
work from individuals and stakeholder groups.

In addition, the OCPA edits, publishes online, and disseminates OIG reports and correspondence.
The office's writer-editors provide quality assurance by working closely with auditors,
evaluators, and investigators to ensure that OIG products are thorough, clear, and adhere to
established writing standards. In FY 2020, the OCPA looks forward to providing communication
support to the OIG's OA&E as it expands its program to include targeted evaluation work.

Anyone who is interested in keeping abreast of the OIG's public reports and correspondence may
subscribe via the OIG's website to receive email updates that provide timely notifications of
postings. This service includes "coming soon" messages that provide advance notice of reports
scheduled for issuance. Illustrative of the OCPA's work toward achieving the OIG strategic
goals, these efforts contribute to the OIG's achievement of Objective 1.2 by improving the OIG's
ability to communicate with Congress, the news media, and the public about OA&E project
results that contribute to identifying, reducing, and eliminating environmental risks and
challenges.

Along with the public website, the OCPA is responsible for managing the OIG's social media
platforms. Through the OIG's Twitter account, the OCPA connects with thousands of followers about

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recently published reports, available resources, planned events, and oversight topics. Moreover, the
OCPA creates multimedia products to enhance and amplify the OIG's audit and investigative work
for public consumption, a portfolio that will expand to include evaluation work in FY 2020. A
YouTube channel serves as a platform for videos created by the OIG, which include standalone
products or clickable features within reports. Graphics and photographs are used on the covers and
within the reports, as well as embedded in tweets. Podcasts illuminate select audit and evaluation
reports and complex investigative subjects.

Closely tied to the OIG's objectives under Strategic Goal 2, protecting the integrity of programs
and operations reducing risk of loss through prevention of fraud, waste, abuse, and
mismanagement, the OCPA manages the OIG Hotline. In FY 2019, the hotline received nearly 400
complaints. The OCPA promptly processes this information; refers issues for audits, evaluations,
or investigations, when warranted; and refers issues to the appropriate office or Agency if not
within the OIG's jurisdiction. The OIG encourages the submission of suggestions to the hotline for
assessing the efficiency and effectiveness of Agency programs, along with complaints of fraud,
waste, abuse, misconduct, and mismanagement in the EPA programs and operations, as well as
violations of law, regulations, and policies by EPA and CSB employees, grantees, contractors, and
program participants.

The OCPA also is responsible for operating the OIG's main phone line and email inbox, which
directs anyone who contacts the OIG to the right place.

Office of Counsel

The OC within the OCCPA provides independent legal and policy advice to all components of
the OIG, covering a variety of substantive and procedural matters relating to the OIG's
audits, evaluations, investigations, and other activities. The OC supports the OIG activities that
implement OIG strategic goals and objectives. The OC provides legal support to the OI's
Strategic Goal 2 activities, protecting the integrity of program and operations through criminal
and administrative investigations. Further, the OC reviews the OIG reports to ensure their legal
sufficiency in support of the OIG's strategic objectives to influence actions and change that
contribute to improved human health, safety, and environmental quality. The OC's activities also
include legal reviews as deemed necessary by the Inspector General in response to requests by
members of Congress, the EPA or the CSB, and the public.

OIG employees are expected to maintain high ethical standards and adhere to applicable federal
ethics laws. To support this vital function, the OC manages the OIG ethics program, including
ensuring that OIG staff complete ethics training each year, reviewing financial disclosure
reviews submitted by OIG employees designated to file these forms, and responding to any
questions from OIG employees who may seek advice involving ethics.

The OC also coordinates and processes the OIG's responses to the Freedom of Information Act,
Privacy Act of 1974, and other legal requests or demands for OIG documents. The Freedom of
Information Act provides authority for the public to obtain access to federal Agency records,
except to the extent that such records are protected from public disclosure by one of nine
exemptions. The Privacy Act mandates how federal agencies maintain records about individuals.
The law strives to balance the government's needs to maintain these records with the individual's

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right to be protected from unwarranted invasions of personal privacy. In recent years, the OIG
has received increasing numbers of Freedom of Information Act requests, topping 130 in
FY 2018 and 113 requests for FY 2019.

The OC also houses the OIG Whistleblower Protection Coordinator. The Whistleblower
Protection Enhancement Act of 2012 and the Whistleblower Protection Coordination Act of
2018 amended the Inspector General Act to require Inspectors General to designate a
Whistleblower Protection Coordinator. The EPA OIG Whistleblower Protection Coordinator is
available to educate Agency employees (as well as employees of EPA contractors,
subcontractors, grantees, subgrantees, or personal services contractors) who have made, or are
contemplating making, a protected disclosure about rights and remedies against retaliation for
protected disclosures—including the means by which employees may seek review of any
allegation of reprisal, and the roles of the OIG, the Office of Special Counsel, the Merit Systems
Protection Board, and other relevant entities. Further, the EPA OIG Whistleblower Protection
Coordinator assists the Inspector General in promoting the timely and appropriate handling and
consideration of protected disclosures and allegations of reprisal. The EPA OIG Whistleblower
Protection Coordinator cannot act as a legal representative, agent, or advocate of an employee or
former employee. The EPA OIG's Whistleblower Protection Coordinator can be contacted at
whistleblower protection@epa.gov or by phone at (202) 566-1513. More information can be
found on the OIG's website.

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The Plan: Office of Management FY 2020
Focus

The OM serves as the corporate focal point for the Immediate Office of the Inspector General
and is responsible for promoting the most efficient use and accountability of OIG resources, and
helps the OIG effectively achieve its mission and goals. The OM has three directorates that form
the cornerstone of the OIG's management services:

•	Business Analysis and Results Directorate. Provides budget planning, formulation,
execution, analysis, and reporting support; acquisition liaison and management; strategic
and operational planning, policy, and procedure management; performance management
and reporting; internal reviews; GAO liaison activities; and management and oversight of
the OIG enterprise risk management program.

•	Human Resources Directorate. Provides operational support for activities such as
recruitment, staffing, classification, retirement, and benefits liaison activities; employee
training and professional development; performance management; employee relations;
workforce planning; executive resources; and facilities and space management.

•	Information Technology Directorate. Provides the OIG with a range of products and
services in the areas of software development, data analysis, and survey support;
infrastructure and technical support services; information security; and records and
property management. Additionally, the directorate performs all Information
Management Officer functions including, but not limited to, overseeing IT purchases and
acquisitions as well as providing mobile device support.

The matrix of the OIG OM Plan is a compilation of the goals and measurements captured in the
OIG Strategic Plan and the IT Strategic Plan. The OM plan maintains alignment with the EPA's
and the CSB's respective missions and new strategic goals, along with the OIG's unique duties,
roles, authorities, and responsibilities as defined by the Inspector General Act; and the OIG's
specific management values and vision for inspiring the greatest level of OIG success in
performing our mission. These goals and objectives reflect our responsibility to detect and
prevent fraud, waste, abuse, mismanagement, and misconduct in the EPA's and the CSB's
programs and operations. The OIG Strategic Plan provides a unified direction with clear
expectations.

The matrix of the OIG OM Plan charts the course of the OM and outlines how we will service
our customers' human resource needs, provide tools and technologies to support collaboration,
and provide fiscally sound budget advice. The following are OM's priorities for FY 2020:

•	Maximize the customer experience by providing results-oriented IT solutions.

•	Optimize tools and technology to foster collaboration among stakeholders.

•	Continuously improve delivery of OIG systems and services.

•	Recruit, develop, and retain a high-quality workforce.

•	Implement the internal review of OIG practices and programs.

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•	Establish the OIG's enterprise risk management governance.

•	Expand data analytics capability.

Point of Contact: Stephanie L. Wright, Acting Deputy Assistant Inspector General for
Management, (202)-566-2698

The matrix of the OIG OM Plan communicates our vision, mission, and future direction to our
customers and team members so that we can reinforce and expand collaborative efforts to
accomplish our three goals. The following are the strategic measures the OM will endeavor to
progress toward in FY 2020:

Strategic
Measure
#

Strategic Measure Description

1.2.3

By September 30, 2023, the OIG will have refined its performance metrics to better align with mission
objectives, improve our ability to "tell the OIG story" of our influence and impact on our contribution
to the elimination of environmental risks and challenges, and confirm that we maintain relevance with
current goals and objectives.

3.2.1

By September 30, 2023, the OIG will implement at least ten best practices across the OIG, aimed at
increasing our efficiency in our human resources, IT, and budgetary missions.

3.2.2

By September 30, 2023, the OIG will have implemented an enterprise risk management system whose
governance and cycle of accountability will increase our organization's effectiveness.

3.2.3

By September 30, 2023, the OIG will identify high-risk and high-vulnerability OIG activities, implement
appropriate review for activities that are considered high-risk, and minimize them to an appropriate
degree. The OIG will implement at least one mitigation plan.

3.3.1

By September 30, 2023, the OIG will match or improve on federal government retention rates and will
continue to develop programs to attract and retain high-talent staff.

3.3.2

By September 30, 2023, the OIG's Federal Employee Viewpoint Survey scores in at least three of the
five Office of Personnel Management embedded indexes (Employee Engagement, Global Satisfaction,
Effective Communications, New Inclusion Quotient, and Human Capital Assessment and
Accountability Framework) and will increase by at least 10 percent from each index's 2018 average.

3.3.3

By September 30, 2023, due to various programs that we put into place, the OIG will work to increase
its "Best Places to Work" score for an Agency subcomponent (as administered by the Partnership for
Public Service) by at least one quartile from FY 2018 levels.

The following are OM's specific plans for FY 2020 matrixed to goals of both the OIG IT
Strategic Plan as well as the OIG Strategic Plan FY 2019-2023:

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OIG IT Strategic Plan
FY2018—2021

OIG Strategic Plan
2019-2023



Planned FY 2020 OM Projects

Maximize the

customer
experience by
providing
results-
oriented IT
solutions

Optimize
tools and
technology

to foster
collaboration

among
stakeholders

Continuously
improve
delivery of
OIG systems
and services

Contribute to
improved EPA

and CSB
programs and
operations
protecting
human health

and the
environment,
and enhancing
safety

Conduct audits,
evaluations,

and
investigations
that enable the

EPA and the
CSB to improve

business
practices and
accountability

Improve OIG
processes,
resource
allocation,
and
accountability

to meet
stakeholder
needs

Project time
frame

Information Technology Directorate















IGEMS ColdFusion 2016 upgrade

Y

Y

Y





Y

Complete
in FY 2020

Move Primary Data Centerto Research Triangle Park

Y

Y

Y





Y

Complete
in FY 2020

Move disaster recovery site to Region 8 in support of COOP
initiatives

Y

Y

Y





Y

Complete
in FY 2021

Windows Server 2008 end of life software upgrade initiative

Y

Y

Y





Y

Complete
in FY 2020

Data back-up storage system upgrade project

Y

Y

Y





Y

Complete
in FY 2020

Continuous monitoring assessments





Y





Y

Ongoing

Business Analysis and Results Directorate















Establish OM Internal Review Program











Y

Initiated
in FY
2019,
then
ongoing

Conduct Internal Review of the OIG time and attendance
procedures











Y

Complete
in FY 2020

Conduct Internal Review of the OIG Employee Wellness
Program











Y

Complete
in FY 2020

Establish governance for enterprise risk management











Y

Complete
in FY 2020

Restructure OIG Performance Management and Analysis
Program 1











Y

Complete
in FY 2020

Execute FY 2019 Carryover Management











Y

Complete
in FY 2020

Manage OIG FY 2020 Operations Plan











Y

Ongoing

Complete FY 2021 Congressional Justification











Y

Complete
in FY 2020

Establish FY 2022 OIG Budget Planning











Y

Complete
in FY 2020

Human Resources Directorate















Develop and Implement FY 2020 Recruitment Strategy











Y

Complete
in FY 2020

Establish new performance management system











Y

Complete
in FY 2020

Implement OM continuous improvement initiatives











Y

Initiate in
FY 2020,

then
ongoing.

Reduce OIG HQfootprint pursuant to the FY 2020 EPA Space
Consolidation











Y

Complete
in FY 2020

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Appendix A: Overview of the OIG Strategic Plan 2019-2023

VISION

Be the premier oversight organization trusted to speak the truth,
promote good governance, and contribute to improved human health
and the environment.

MISSION

Conduct independent audits, evaluations, and investigations; make evidence based
recommendations to promote economy, efficiency, and effectiveness; and prevent and
detect fraud, waste, abuse, mismanagement, and misconduct for the EPA and the CSB.

Contribute to improved EPA and CSB
programs and operations protecting
human health and the environment,
and enhancing safety.

GOALS

h. *

Conduct audits, evaluations, and
investigations that enable the EPA
and the CSB to improve business
practices and accountability.

Improve OIG processes, resource
allocation, and accountability to
meet stakeholder needs.

r • Influence actions and
change that contribute to
improved human health,
safety, and environmental
quality.

• Produce results that
contribute to the
identification, reduction, or
elimination of
environmental risks and
challenges.

OBJECTIVES

•	Protect the integrity of programs
and operations through criminal,
civil, and administrative
investigations.

•	Influence actions and identify
best practices to improve
efficiency and accountability,
and achieve monetary benefits.

•	Reduce risk of loss by detecting
and achieving monetary
benefits.

•	Reduce risk of loss by detecting
and preventing fraud, waste,
abuse, mismanagement, and
misconduct.

r • Ensure that our products and
services are timely, responsive,
and relevant, and maximize
protection of human health and
the environment and return on
investment.

•	Ensure that our processes and
actions are efficient and
effective through continuous
improvement.

•	Recruit, develop, and retain an
innovative, high performing and
diverse workforce that is
valued, appreciated, and
respected.

•	Enhance constructive
relationships and foster

^ collaborative solutions.

Core Value: Be the best in public service

Customer Service

Integrity

Accountability

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Appendix B: OIG Strategic Measures 2019-2023





Objective 1.1: Influence actions and change that contribute to improved human
health, safety, and environmental quality.

Strategic Measure 1.1.1—By September 30, 2023, the OIG will have conducted audits and
evaluations resulting in recommendations in specific areas geared toward improvement in
EPA policies, procedures, and practices contributing to improved human health, safety, or
environmental quality in each of its major offices and sub-offices. Further, the OIG will
continue to work with the Agency to track implementation of OIG recommendations.

Objective 1.2: Produce results that contribute to the identification, reduction, or
elimination of environmental risks and challenges.

Strategic Measure 1.2.1—By September 30, 2023, the OIG will be able to show
quantitative measures supporting the OIG's contribution to the reduction or elimination of
environmental risks and challenges by conducting audits, evaluations, or investigations.
We will conduct at least one audit, evaluation, or investigation addressing an emerging
environmental risk or challenge.

Strategic Measure 1.2.2—By September 30, 2023, the OIG will have contributed to the
reduction and elimination of environmental risks and challenges by conducting at least one
audit or evaluation in each of the EPA's six priority goal areas rendering impactful
recommendations.

Strategic Measure 1.2.3—By September 30, 2023, the OIG will have refined its
performance metrics to better align with mission objectives, improve our ability to "tell the
OIG story" of our influence and impact on our contribution to the elimination of
environmental risks and challenges, and confirm that we maintain relevance with current
goals and objectives.

Objective 2.1: Protect the integrity of programs and operations through criminal,
civil, and administrative investigations.

Strategic Measure 2.1.1—By September 30, 2023, the OIG will have conducted
investigations geared toward protecting the integrity of programs and operations within
the EPA's six priority goals.

Strategic Measure 2.1.2—By September 30, 2023, the OIG will have conducted
investigations for the prevention of cyber-related attacks. These investigations will
result in increased protective measures codified in policy and procedure.



J

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~\

Objective 2.2: Influence actions and identify best practices to improve efficiency
and accountability and achieve monetary benefits.

Strategic Measure 2.2.1—By September 30, 2023, the OIG will perform audits and
evaluations in each EPA priority area, resulting in documented, data-supported
improvements in efficiency and accountability across the Agency.

Objective 2.3: Reduce risk of loss by detecting monetary benefits.

Strategic Measure 2.3.1—By September 30, 2023, the OIG will have reduced risk of loss
by detecting monetary benefits through audits and evaluations targeting initiatives within the
EPA's six priority goals.

Objective 2.4: Reduce risk of loss by detecting and preventing fraud, waste,
abuse, mismanagement, and misconduct.

Strategic Measure 2.4.1—By September 30, 2023, the OIG will have increased its
capacity for case management of investigations involving mismanagement and
misconduct that result in fraud, waste, or abuse.

Strategic Measure 2.4.2—By September 30, 2023, the OIG will have increased the
effectiveness of audits and evaluations using quantifiable impact in implemented
recommendations as our measure.

Strategic Measure 2.4.3—By September 30, 2023, the OIG will increase its return on
investment to a minimum ratio of 12 to 1 as an average from 2019 to 2023.

Objective 3.1: Ensure that our products and services are timely, responsive, and
relevant, and maximize protection of human health and the environment and
return on investment.

Strategic Measure 3.1.1—By September 30, 2023, the OIG will implement new timeliness
measures and goals on products and services provided to our stakeholders and to the
Agency.

Objective 3.2: Ensure that our processes and actions are efficient and effective
through continuous improvement.

Strategic Measure 3.2.1—By September 30, 2023, the OIG will implement at least ten
best practices across the OIG, aimed at increasing our efficiency in our human
resources, IT, and budgetary missions.

Strategic Measure 3.2.2—By September 30, 2023, the OIG will have implemented an
enterprise risk management system whose governance and cycle of accountability will
increase our organization's effectiveness.



J

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Strategic Measure 3.2.3—By September 30, 2023, the OIG will identify high-risk and
high-vulnerability OIG activities, implement appropriate review for activities that are
considered high risk, and minimize them to an appropriate degree. The OIG will
implement at least one mitigation plan.

Objective 3.3: Recruit, develop, and retain an innovative, high-performing, and
diverse workforce that is valued, appreciated, and respected.

Strategic Measure 3.3.1—By September 30, 2023, the OIG will match or improve on
federal government retention rates and will continue to develop programs to attract and
retain high-talent staff.

Strategic Measure 3.3.2—By September 30, 2023, the OIG's Federal Employee
Viewpoint Survey scores in at least three of the five Office of Personnel Management
embedded indexes (Employee Engagement, Global Satisfaction, Effective
Communications, New Inclusion Quotient, and Human Capital Assessment and
Accountability Framework) and will increase by at least 10 percent from each index's
2018 average.

Strategic Measure 3.3.3—By September 30, 2023, due to various programs that we put
into place, the OIG will increase its "Best Places to Work" score for an Agency
subcomponent (as administered by the Partnership for Public Service) by
at least one quartile from FY 2018 levels.

Objective 3.4: Enhance constructive relationships and foster collaborative
solutions.

Strategic Measure 3.4.1—By September 30, 2023, the OIG will be a recognized and active
participant in leader forums with sister agencies and with stakeholders as appropriate (e.g.,
interactions with the Office of Management and Budget, the Office of Personnel
Management, the EPA's Criminal Investigative Division, and CIGIE).



y

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