Operating efficiently and effectively
The EPA's Fiscal
Years 2021 and 2020
(Restated) Hazardous
Waste Electronic Manifest
System Fund Financial
Statements
Report No. 22-F-0062
September 30, 2022
IDENTIFY
COUNT
NOTIFY
MANAGE TRANSPORT
RECYCLE
TREAT
DISPOSE
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Report Contributors: Safiya Chambers
Robert Evans
Damon Jackson
Carol Kwok
Mairim Lopez
Sheila May
Ryan Watren
Abbreviations: C.F.R. Code of Federal Regulations
e-Manifest Hazardous Waste Electronic Manifest
EPA U.S. Environmental Protection Agency
FY Fiscal Year
OIG Office of Inspector General
U.S.C. United States Code
Cover Image: Basic steps for complying with hazardous waste regulations: (1) identify
hazardous waste; (2) count the total weight of all hazardous waste;
(3) notify the EPA or state agency of the hazardous waste activities;
(4) manage the hazardous waste according to associated regulations;
(5) transport hazardous waste off-site and have the required manifest
tracked through the Hazardous Waste Electronic Manifest system;
(6) recycle, treat, or dispose of hazardous waste according to applicable
regulations. (EPA image)
Are you aware of fraud, waste, or abuse in an
EPA program?
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Washington, D.C. 20460
(888) 546-8740
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OIG Hotline@epa.gov
Learn more about our OIG Hotline.
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Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
22-F-0062
September 30, 2022
Why We Did This Audit
We performed this audit pursuant
to the Hazardous Waste
Electronic Manifest
Establishment Act. The Act
requires the U.S. Environmental
Protection Agency to prepare
and the Office of Inspector
General to audit the
accompanying financial
statements of the EPA's
Hazardous Waste Electronic
Manifest System Fund. Our
primary objectives were to
determine whether:
The fund's financial
statements were fairly stated
in all material respects.
The EPA's internal controls
over financial reporting were
in place.
EPA management complied
with applicable laws,
regulations, contracts, and
grant agreements.
The Act also requires the OIG to
analyze the fees collected and
disbursed, fee structure, level of
use of the system, and success
of the system in operating on a
self-sustaining basis.
This audit supports an EPA
mission-related effort:
Operating efficiently and
effectively.
This audit addresses a top EPA
management challenge:
Managing infrastructure funding
and business operations.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
The EPA's Fiscal Years 2021 and 2020
(Restated) Hazardous Waste Electronic
Manifest System Fund Financial Statements
We found the fund's
financial statements,
except for accounts
receivable and earned
revenue, to be fairly
presented.
The EPA Receives a Qualified Opinion
We rendered a qualified opinion on the EPA's fiscal
years 2021 and 2020 (restated) Hazardous Waste
Electronic Manifest System Fund, known as the
e-Manifest Fund, financial statements, meaning that,
except for material errors in accounts receivable and
earned revenue, the fiscal year 2021 financial
statements were fairly presented.
Material Weakness Noted
We noted the following recurrent material weakness: the EPA needs to
continue improving its internal controls over accounts receivable and earned
revenue.
Compliance with Applicable Laws, Regulations, Contracts, and
Grant Agreements
We did not identify any instances of noncompliance that would result in a
material misstatement to the audited financial statements.
Other Governmental Reporting Requirements
During our user fee analysis, we identified various errors and discrepancies in
EPA-provided billing data that limited our ability to perform certain audit
requirements of the Hazardous Waste Electronic Manifest Establishment Act.
Specifically, we were unable to determine the level of use of the e-Manifest
system or whether the EPA was collecting fees sufficient to cover the full cost of
the program.
Recommendations and Agency Corrective Actions Taken
We recommend that the chief financial officer correct the accounts receivable
and earned revenue balances. We also recommend that the chief financial
officer, in coordination with the assistant administrator for Land and Emergency
Management, assess the EPA's procedures for recording e-Manifest delinquent
amounts and implement controls to prevent accounts receivable and earned
revenue duplication. The EPA completed all corrective actions in response to
both recommendations. In response to Recommendation 1, the EPA made
corrections to the accounts receivable and earned revenue balances. However,
as part of the corrections, the EPA made material errors that overstated the
accounts receivable and earned revenue balances. As a result,
Recommendation 1 is unresolved with resolution efforts in progress.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
September 30, 2022
MEMORANDUM
SUBJECT: The EPA's Fiscal Years 2021 and 2020 (Restated) Hazardous Waste Electronic Manifest
System Fund Financial Statements
Report No. 22-F-0062
FROM: Damon Jackson, Director Qm0f( Ja&£g0f(
Financial Directorate
Office of Audit
TO: Faisal Amin, Chief Financial Officer
This is our report on the subject audit conducted by the U.S. Environmental Protection Agency Office of
Inspector General. The project number for this audit was QA-FY22-0064. This report contains findings
that describe the problems the OIG has identified and corrective actions the OIG recommends. Final
determination on matters in this report will be made by EPA managers in accordance with established
audit resolution procedures.
The Office of the Chief Financial Officer is responsible for the issues discussed in the report.
In accordance with EPA Manual 2750, your office completed all corrective actions for Recommendation 2.
This recommendation is resolved. A final response pertaining to this recommendation is not required.
Action Required
Recommendation 1 is unresolved. EPA Manual 2750 requires that recommendations be resolved
promptly. Therefore, we request that the EPA provide us within 60 days its responses concerning specific
actions in process or alternative corrective action proposed on the recommendation. Your response will
be posted on the OIG's website, along with our memorandum commenting on your response. Your
response should be provided as an Adobe PDF file that complies with the accessibility requirements of
Section 508 of the Rehabilitation Act of 1973, as amended. The final response should not contain data
that you do not want to be released to the public; if your response contains such data, you should identify
the data for redaction or removal along with corresponding justification. The Inspector General Act of
1978, as amended, requires that we report in our semiannual reports to Congress on each audit or
evaluation report for which we receive no Agency response within 60 calendar days.
Barry Breen, Acting Assistant Administrator
Office of Land and Emergency Management
We will post this report to our website at www.epa.gov/oig.
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The EPA's Fiscal Years 2021 and 2020 (Restated)
Hazardous Waste Electronic Manifest
System Fund Financial Statements
22-F-0062
Table of C
Inspector General's Report on the EPA's Fiscal
Years 2021 and 2020 (Restated) Hazardous Waste
Electronic Manifest System Fund
Financial Statements
Report on the Financial Statements 1
Report on Internal Control over Financial Reporting 2
Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements 4
Other Governmental Reporting Requirements 4
Management's Discussion and Analysis 6
Prior Audit Coverage 6
Attachments
1. Material Weakness 7
The EPA Needs to Continue Improving Its Internal Control Over Accounts Receivable and
Earned Revenue 8
2. Status of Prior Audit Report Recommendations 11
3. Status of Recommendations and Potential Monetary Benefits 13
Appendixes
A For the Fiscal Years Ending September 30, 2021 and 2020 Hazardous Waste Electronic
Manifest System Fund (e-Manifest) Financial Statements (With Restatements) 14
B Agency Response to Draft Report 39
C Distribution 41
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Inspector General's Report on the EPA's Fiscal
Years 2021 and 2020 (Restated) Hazardous Waste
Electronic Manifest System Fund
Financial Statements
The Administrator
U.S. Environmental Protection Agency
Report on the Financial Statements
We have audited the accompanying financial statements of the U.S. Environmental Protection Agency's
Hazardous Waste Electronic Manifest System Fund, known as the e-Manifest Fund. These statements
comprise the balance sheets as of September 30, 2021, and September 30, 2020 (restated); the related
statements of net cost and changes in net position; the statement of budgetary resources for the years
then ended; and the related notes to the financial statements.
Management's Responsibility for the Financial Statements
Management is responsible for the preparation and fair presentation of these financial statements in
accordance with accounting principles generally accepted in the United States of America.1 This includes
the design, implementation, and maintenance of internal control relevant to the preparation and fair
presentation of financial statements that are free from material misstatement, whether due to fraud or
error.
Auditor's Responsibility
Our responsibility is to express an opinion on these financial statements based on our audit. We
conducted our audit in accordance with auditing standards generally accepted in the United States of
America; the standards applicable to financial statements contained in Government Auditing Standards,
issued by the comptroller general of the United States of America; and Office of Management and
Budget Bulletin 21-04, Audit Requirements for Federal Financial Statements. These standards require
that we plan and perform the audit to obtain reasonable assurance about whether the financial
statements are free from material misstatement.
An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in
the financial statements. The procedures selected depend on the auditor's judgment, including the
assessment of the risks of material misstatement of the financial statements, whether due to fraud or
error. In making those risk assessments, the auditor considers internal control relevant to the entity's
preparation and fair presentation of the financial statements in order to design audit procedures that
are appropriate in the circumstances. An audit also includes evaluating the appropriateness of
accounting policies used and the reasonableness of significant accounting estimates made by
management, as well as evaluating the overall presentation of the financial statements.
1 Management, as used throughout this report, refers to the EPA's management.
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We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for
our audit opinion.
Basis for Qualified Opinion
As discussed in Note 16, the EPA restated its FY 2020 Accounts Receivable and Earned Revenue financial
statement line items. The EPA adjusted these line items to correct errors attributed to timing and
duplicate billings. The net adjustments included a correction for approximately $1,912 million, but we
found that the correction was mistakenly accounted for twice, which resulted in an overstatement of
the balances. After further analysis of the restatement, the EPA also identified an error that had
understated the balances by approximately $1,338 million. Consequently, accounts receivable and
earned revenue are overstated by approximately $574,000 as of and for the year ended September 30,
2021.
Qualified Opinion
In our opinion, except for the effects on the FY 2021 financial statements of the matter described in the
Basis for Qualified Opinion paragraph, the financial statements and accompanying notes referred to
above present fairly, in all material respects, the assets, liabilities, net position, net cost, changes in net
position, and budgetary resources of the EPA's e-Manifest Fund as of and for the years ended
September 30, 2021 and 2020 (restated), in accordance with accounting principles generally accepted in
the United States of America.
Report on Internal Control over Financial Reporting
Opinion on Internal Control. In planning and performing our audit of the financial statements of the
e-Manifest Fund as of and for the year ended September 30, 2021, in accordance with auditing
standards generally accepted in the United States of America, we considered the fund's internal control
over financial reporting as a basis for designing our audit procedures that are appropriate in the
circumstances for the purpose of expressing an opinion on the financial statements and to comply with
the Office of Management and Budget's audit guidance, but not to express an opinion on the
effectiveness of the fund's internal control. Accordingly, we do not express an opinion on the
effectiveness of the fund's internal control over financial reporting.
Material Weaknesses and Significant Deficiencies. Our consideration of the internal control was for the
limited purpose of expressing an opinion on the fund's financial statements and was not designed to
identify all deficiencies in internal control that might be material weaknesses or significant deficiencies;
therefore, such deficiencies in internal control may exist that were not identified during the course of
our audit. A deficiency in internal control over financial reporting exists when the design or operation of
a control does not allow management or employees, in the normal course of performing their assigned
functions, to prevent or detect and correct misstatements on a timely basis. A material weakness is a
deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there
is a reasonable possibility that a material misstatement of the entity's financial statements will not be
prevented or detected and corrected on a timely basis. A significant deficiency is a deficiency, or a
combination of deficiencies, in internal control over financial reporting that is less severe than a material
weakness yet important enough to merit attention by those charged with governance.
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Because of inherent limitations in internal control, misstatements, losses, or noncompliance may
nevertheless occur and not be detected. We noted one matter, which we discuss below, involving the
internal control and its operation that we consider to be a recurrent material weakness. This issue is
summarized below and detailed in Attachment 1.
Material Weakness
The EPA Needs to Continue Improving Its Internal Controls Over Accounts Receivable
and Earned Revenue
We found that the EPA made material errors of approximately $3.5 million in its accounts receivable and
earned revenue financial statement line items by:
Recording September 2020 billings totaling approximately $1,912 million in FY 2021 that should
have been recorded in FY 2020.
Including prior months' outstanding amounts and unpaid late fees of approximately
$1.47 million in the billings from October 2020 to February 2021, overstating FY 2021 accounts
receivable and revenue.
Duplicating delinquent accounts receivable and related earned revenue totaling $118,055.
These misstatements occurred due to inadequate internal control, such as a lack of integrated billing
and financial systems, reliance on manual workarounds, and ineffective management review and
analysis. The e-Manifest billing system was not integrated with the EPA's financial system used for
financial reporting. Federal standards require a system of internal control to ensure accurate recording
of transactions and events. Without adequate controls over recording billings in Compass Financials, the
EPA's financial system, the EPA misstated its accounts receivable and earned revenue.
Attachment 2 contains the status of issues reported in prior years' reports on the fund's financial
statements. The issues included in Attachment 2 should be considered among the material weaknesses
for FY 2021. We reported less significant internal control matters to the Agency during the audit. We will
not issue a separate management letter.
Comparison of the EPA's Federal Managers' Financial Integrity Act Report with
Our Evaluation of Internal Control
Office of Management and Budget Bulletin 21-04 requires us to compare material weaknesses disclosed
during the audit with those material weaknesses reported in the Agency's Federal Managers' Financial
Integrity Act report that relate to the financial statements. We are also required to identify material
weaknesses disclosed by the audit that were not reported in the Agency's report. The Agency's report is
prepared and submitted at the consolidated level, of which the e-Manifest Fund is a component.
Accordingly, there are no findings to report at the e-Manifest Fund level.
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Report on Compliance with Laws, Regulations, Contracts, and
Grant Agreements
EPA management is responsible for complying with laws, regulations, contracts, and grant agreements
applicable to the Agency and the fund. As part of obtaining reasonable assurance about whether the
fund's financial statements are free of material misstatement, we performed tests of the Agency's
compliance with certain provisions of laws, including those governing the use of budgetary authority,
regulations, contracts, and grant agreements that have a direct effect on the determination of material
amounts and disclosures in the fund's financial statements.
Opinion on Compliance with Laws, Regulations, Contracts, and
Grant Agreements
Providing an opinion on compliance with certain provisions of laws, regulations, contracts, and grant
agreements was not an objective of our audit and, accordingly, we do not express such an opinion.
We did not identify any instances of noncompliance that would result in a material misstatement to the
audited financial statements.
Other Governmental Reporting Requirements
Specific Audit Requirements of the Hazardous Waste Electronic Manifest
Establishment Act
The Hazardous Waste Electronic Manifest Establishment Act, known as the e-Manifest Act, 42 U.S.C.
§ 6939g, requires the Office of Inspector General to perform an analysis of (1) the fees collected and
disbursed, (2) the reasonableness of the fee structure in place as of the date of the audit to meet
current and projected costs of the system, (3) the level of use of the system by users, and (4) the success
to date of the system in operating on a self-sustaining basis and improving the efficiency of tracking
waste shipments and transmitting waste shipment data. The results of our analyses follow.
Fees Collected and Disbursed
The EPA began collecting e-Manifest user fees in August 2018. As the e-Manifest Act requires, the EPA
deposited fee collections into the e-Manifest Fund. The EPA received approximately $25.5 million in fee
collections in FY 2021. The Consolidated Appropriations Act, 2021, requires the EPA to reduce by the
amount of offsetting collections the sum Congress appropriated for necessary expenses to carry out the
e-Manifest system. The Agency reimbursed the U.S. Department of the Treasury $8 million in FY 2021
from e-Manifest fee collections to cover the amount Congress had previously appropriated.
Reasonableness of the Fee Structure to Meet Current and Projected Costs
The EPA established fees for each manifest type (fully electronic, hybrid, data plus image upload,
scanned image upload, and mailed paper) based on a fee model that focuses on the marginal labor cost
of processing each manifest type. Additionally, the EPA made a management decision to adjust the raw
output of this formula to distribute the costs across manifest types. Pursuant to 40 C.F.R. § 264.1313(a),
the EPA is required to revise the e-Manifest user fees at two-year intervals by utilizing the applicable fee
calculation formula, the most recent program cost, and manifest usage numbers. The EPA is also
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required to publish the revised fee schedules through the e-Manifest program website by July 1 of each
odd-numbered calendar year. Table 1 describes the fees per manifest that were effective during FY 2021
and FY 2020.
Table 1: FY 2021 and FY 2020 fees by manifest type
1 Manifest type
1 FY 2021 and FY 2020 fee per manifest I
Fully electronic and hybrid
$8.00
Data plus image upload
14.00
Scanned image upload
20.00
Mailed paper
$25.00
Source: FY 2021 and FY 2020 fee rates published on the EPA's website. (EPA OIG table)
Beginning June 30, 2021, the EPA no longer accepted mailed paper manifests.
During our previous audits, we identified a material weakness in the EPA's internal control over
accounts receivable and earned revenue. Attachment 2 provides further details. The misstatements we
identified misrepresented the billing data that included the total number of manifests billed during the
fiscal year and the related earned revenue. The EPA was working on implementing its corrective actions
to address this material weakness, and we identified similar findings in our audit of the FY 2021 financial
statements, as detailed in Attachment 1. As a result, we could not rely on the EPA-provided billing data
to analyze the reasonableness of the fee structure.
Level of Use of the System
When the e-Manifest system was launched on June 30, 2018, the EPA estimated that it would receive
approximately 3 million manifests annually. According to the EPA, actual data on manifest usage were
unavailable because, prior to the launch of the e-Manifest system, there was no national collection of
manifests. The Agency relied on manifest usage estimates from industry and other data sources. For
FY 2021, the EPA estimated receiving approximately 2 million manifests.
As mentioned in the previous subsection and detailed in Attachment 2, we identified a material
weakness in the EPA's internal control over accounts receivable and earned revenue during our previous
audits, the corrective actions for which the Agency had not completed before this audit. We identified
similar findings in our audit of the FY 2021 financial statements, as detailed in Attachment 1. As a result,
we could not rely on the EPA-provided billing data, including the total number of manifests billed during
the fiscal year, to analyze the level of use of the e-Manifest system.
Success to Date of the System in Operating on a Self-Sustaining Basis and Improving
the Efficiency of Tracking Waste Shipments and Transmitting Waste Shipment Data
The e-Manifest Act requires the EPA to recover the full cost of providing system-related services. Based
on FY 2021 financial data, the EPA incurred $17.5 million in program costs. Because of a material
weakness identified in our previous audits and a similar finding in our audit of the FY 2021 financial
statements, as discussed in the previous two subsections, we could not rely on the EPA's billing data to
determine the success of the e-Manifest system in operating on a self-sustaining basis and improving
the efficiency of tracking waste shipments and transmitting waste shipment data. In particular, the
misstatements we identified misrepresented billing data that included the total revenue earned during
the fiscal year, which is necessary for such analysis.
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Management's Discussion and Analysis
Our audit was conducted for the purpose of forming an opinion on the e-Manifest financial statements
as a whole. The Management's Discussion and Analysis section is presented for the purpose of providing
additional analysis and is not a required part of the basic financial statements. Such information is
management's responsibility. We obtained information from the fund's management about its methods
for preparing the Management's Discussion and Analysis section, and we reviewed this information for
consistency with the financial statements.
Our audit was not designed to express an opinion and, accordingly, we do not express an opinion on the
Management's Discussion and Analysis section.
We did not identify any material inconsistencies between the information presented in the fund's financial
statements and the information presented in the Management's Discussion and Analysis section.
Prior Audit Coverage
During our prior year e-Manifest Fund financial statement auditReport No. 22-F-0015. EPA's Fiscal
Years 2020 and 2019 Hazardous Waste Electronic Manifest System Fund Financial Statements, issued
December 29, 2021we reported two material weaknesses:
The EPA continued to make errors in its financial statement preparation process.
The EPA did not have adequate internal control over accounts receivable and earned revenue.
We also reported a significant deficiency related to the EPA misstating its appropriated balances.
The Agency agreed with our material weakness findings and related recommendations. On June 22,
2022, the EPA certified completion of all corrective actions related to the errors made in the financial
statement preparation process and to the improper recording of receivables and earned revenue.
During our audit of the FY 2021 financial statements, we noted that the EPA had made progress in the
preparation and review of its financial statements and adjustments and in the recording of receivables and
earned revenue. Although the EPA has made improvements in these areas, we identified material
misstatements that impacted the FY 2021 financial statements as detailed in Attachment 1.
The Agency also agreed with our significant deficiency finding and two related recommendations issued in
Report No. 22-F-0015. The Agency completed corrective actions in response to one recommendation prior
to that report's issuance. On August 15, 2022, the EPA certified completion of all corrective actions in
response to the remaining recommendation.
Attachment 2 provides further details on our prior audit report recommendations. We will evaluate the
effectiveness of the EPA's corrective actions during our audit of the FY 2022 e-Manifest financial statements.
Damon ftf. Ja&ixoK
Damon Jackson
Certified Public Accountant
Director, Financial Directorate
Office of Audit
Office of Inspector General
U.S. Environmental Protection Agency
August 25, 2022
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Attachment 1
Material Weakness
Table of Contents
1 The EPA Needs to Continue Improving Its Internal Control Over Accounts
Receivable and Earned Revenue 8
22-F-0062 7
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1 - The EPA Needs to Continue Improving
Its Internal Control Over Accounts Receivable
and Earned Revenue
We found that the EPA made material errors of approximately $3.5 million in its accounts receivable and
earned revenue financial statement line items by:
Recording September 2020 billings totaling approximately $1,912 million in FY 2021 that should
have been recorded in FY 2020.
Including prior months' outstanding amounts and unpaid late fees of approximately
$1.47 million in the billings from October 2020 to February 2021, overstating FY 2021 accounts
receivable and revenue.
Duplicating delinquent accounts receivable and related earned revenue totaling $118,055.
These misstatements occurred due to inadequate internal control, such as a lack of integrated billing
and financial systems, reliance on manual workarounds, and ineffective management review and
analysis. The e-Manifest billing system was not integrated with the EPA's financial system used for
financial reporting. Federal standards require a system of internal control to ensure accurate recording
of transactions and events. Without adequate controls over recording billings in Compass Financials,
EPA's financial system, the EPA misstated its accounts receivable and earned revenue.
The U.S. Government Accountability Office's Standards for Internal Control in the Federal Government
defines the five components of internal control in government. Per the standard for control activities,
"management designs control activities so that all transactions are completely and accurately recorded."
It also states:
Management performs ongoing monitoring of the design and operating effectiveness
of the internal control system as part of the normal course of operations. Ongoing
monitoring includes regular management and supervisory activities, comparisons,
reconciliations, and other routine actions.
Statement of Federal Financial Accounting Standards 1, Accounting for Selected Assets and Liabilities,
states:
A receivable should be recognized when a federal entity establishes a claim to cash
or other assets against other entities, either based on legal provisions, such as a
payment due date, (e.g., taxes not received by the date they are due), or goods or
services provided. If the exact amount is unknown, a reasonable estimate should be
made.
EPA's Resource Management Directive System 2540-09-P2, Non-Federal Delinquent Debt, requires the
Office of the Chief Financial Officer, or OCFO, to record debt and accounts receivable transactions into
the EPA's financial management system of record no later than three business days after receipt of the
document establishing the debt or accounts receivable.
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The e-Manifest system was not integrated with Compass Financials. To facilitate recording e-Manifest
billings in its Compass Financials, the EPA has implemented a manual journal-entry process. The Office
of Land and Emergency Management, or OLEM, compiles monthly aggregate billings on a manually
prepared spreadsheet to summarize monthly billings. OLEM then provides the billing summary to the
OCFO to post to Compass Financials through monthly standard vouchers. OLEM bills those facilities with
an active account status based on total manifests processed through the e-Manifest system during the
month prior to the billings. Such bills include current fees owed; outstanding fees; and late fees, if any.
OLEM refers any delinquent invoices to the OCFO for debt collection efforts when the EPA has not
received payment within 120 days from the invoice date. The OCFO establishes individual accounts
receivable for each facility to track the debts throughout the collection procedures. The OCFO records
these individual accounts receivable for the delinquent amounts in addition to the monthly standard
vouchers described above.
During our audit work, we found the following material errors:
Improper recording. The EPA improperly recorded approximately $1,912 million in FY 2021 that
should have been recorded in FY 2020. The EPA did not detect the misstatement during its
review process.
Compounded billing. The EPA compounded its monthly billings from October 2020 to
February 2021 by approximately $1.47 million. The EPA recorded entire invoice amounts, which
included prior months' outstanding fees, instead of recording only current fees owed. OLEM
provided billing summary spreadsheets that included current and prior months' outstanding
fees to the OCFO for recording the accounts receivable journal entries. It did not reconcile the
billings to determine the appropriate amount to record in its accounts receivable and earned
revenue. Recording the entire invoice amount on the bills each month overstated FY 2021
accounts receivable and earned revenue. Based on our recommendations during previous
audits, starting March 2021, OLEM began providing the billing summary spreadsheet in a
different format and informed the OCFO to record only current fees.
Duplicated accounts. The EPA duplicated accounts receivable and earned revenue totaling
$118,055. From FY 2019 through FY 2021, the EPA recorded individual accounts receivable for
each facility with delinquent invoices. However, the EPA had already recorded the related
accounts receivable and earned revenue through its monthly standard vouchers before the
invoices were categorized as delinquent. As a result, the EPA double-counted the delinquent
amounts. The EPA did not analyze the impact that the recording of e-Manifest delinquent
receivables could have on the accounts receivable and earned revenue account balances.
Furthermore, the EPA did not detect the overstatement or adjust its accounts receivable and
earned revenue to ensure that the balances were accurate.
Without adequate controls over recording (1) billings in the appropriate fiscal year, (2) correct billing
amounts from October 2020 to February 2021, and (3) e-Manifest delinquent amounts, the EPA
misstated its accounts receivable and earned revenue. Inadequate internal control over financial
reporting could decrease reliability in the financial statements.
We reported the findings about accounts receivable recorded in the inappropriate fiscal year and
inaccurate billings in OIG Report No. 22-F-0015. EPA's Fiscal Years 2020 and 2019 Hazardous Waste
Electronic Manifest System Fund Financial Statements, dated December 29, 2021, and OIG Report
No. 21-F-0045, EPA's Fiscal Years 2019 and 2018 Hazardous Waste Electronic Manifest System Fund
22-F-0062
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Financial Statements, dated January 5, 2021. In OIG Report No. 21-F-0045. we recommended that the
chief financial officer record accounts receivable and earned revenue in the appropriate fiscal year.
We also recommended that the chief financial officer, in coordination with the assistant administrator
for Land and Emergency Management, analyze the billings so that the accounts receivable and earned
revenue were recorded accurately. The EPA concurred with our recommendations and on June 22,
2022, certified completion of all corrective actions. Part of the EPA's corrective action plan included an
integration of the e-Manifest billing system and Compass Financials. The EPA indicated that the
integration of these systems was completed in April 2022. We will evaluate the effectiveness of the
Agency's corrective actions during our audit of the FY 2022 financial statements.
Recommendations
We recommend that the chief financial officer:
1. Correct the accounts receivable and earned revenue balances.
We recommend that the chief financial officer, in coordination with the assistant administrator for Land
and Emergency Management:
2. Assess the EPA's procedures for recording Hazardous Waste Electronic Manifest System Fund
delinquent amounts and implement controls to prevent accounts receivable and earned
revenue duplication.
Agency Response and OIG Assessment
The Agency concurred with our recommendations and completed all corrective actions. In response to
Recommendation 1, the EPA made corrections to the accounts receivable and earned revenue balances.
However, we found that as part of the corrections, the EPA restated the FY 2020 accounts receivable
and earned revenue balances and made a material error that overstated the balances by approximately
$1,912 million. Also, after further analysis of the restatement, the EPA identified an error that had
understated the balances by approximately $1,338 million. Consequently, accounts receivable and
earned revenue are overstated by approximately $574,000. As a result, Recommendation 1 is
unresolved with resolution efforts in progress. We will evaluate the effectiveness of the EPA's corrective
actions in response to Recommendation 2 during our audit of the FY 2022 financial statements.
The Agency's response to our draft report is in Appendix B.
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Attachment 2
Status of Prior Audit Report Recommendations
We identified material weaknesses and a significant deficiency in our financial statement audits that
remain outstanding as described in Tables 2-1 and 2-2.
Table 2-1: Prior recommendations related to material weaknesses resolved with corrective actions
reported as completed
The EPA Made Errors in Its Financial Statement Preparation Process
During our FY 2019 audit, we found multiple instances in which the EPA had major misstatements of its financial
transactions and financial statements.
We recommended that the chief financial officer (1) strengthen and improve the preparation and management
review of the financial statements so that errors and misstatements are detected and corrected and (2) analyze
adjustments and corrections to the financial statements so that such adjustments are appropriate, accurate, and
properly supported by documentation. The EPA agreed with our findings and recommendations and on June 22,
2022, certified completion of all corrective actions.
We continued to find material errors in the EPA's financial statement preparation process during our FY 2020 audit.
Because the EPA was working on completing its corrective actions, we did not issue additional recommendations
during the FY 2020 audit. During our FY 2021 audit, we noted that the EPA has made progress in the preparation
and review of its financial statements. However, we identified material misstatements that impacted the financial
statements as detailed in Attachment 1.
The EPA Improperly Recorded Accounts Receivable and Earned Revenue
During our FY 2019 audit, we found that the Agency made two material errors in recording accounts receivable and
earned revenue. The Agency improperly recorded $1,187 million in billings during FY 2019. We also found that the
Agency did not record $1,338 million of September 2019 billings until October 2019. The Agency recorded accounts
receivable and earned revenue without analyzing the e-Manifest bills, erroneously compounding its monthly billings.
Also, the Agency believed that the September 2019 billings represented FY 2020 accounts receivable and earned
revenue. While the two errors offset to only approximately $151,000, the compounding effect of the errors, if left
undetected, could materially distort e-Manifest accounts receivable and earned revenue, as well as decrease
confidence in the quality of the fund's financial statements.
We recommended that the chief financial officer record accounts receivable and earned revenue in the appropriate
fiscal year. We also recommended that the chief financial officer, in coordination with the assistant administrator for
Land and Emergency Management, analyze e-Manifest billings so that accounts receivable and earned revenue
are recorded accurately. The EPA agreed with our findings and recommendations and on June 22, 2022, certified
completion of all corrective actions.
We continued to find material errors in the EPA's recording of accounts receivable and earned revenue during our
FY 2020 audit. Because the EPA was working on completing its corrective actions, we did not issue additional
recommendations during the FY 2020 audit. Although we noted that the EPA has made progress, we continued to
find material errors in the EPA's recording of accounts receivable and earned revenue during our FY 2021 audit.
Attachment 1 contains further details on our findings. We will evaluate the effectiveness of the EPA's corrective
actions in our audit of the FY 2022 financial statements.
Source: OIG analysis of prior year recommendations, findings, and Agency corrective actions. (EPA OIG table)
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Table 2-2: Prior recommendation related to significant deficiency resolved with corrective action
reported as completed
The EPA Misstated Its Appropriated Balances
During our FY 2020 audit, we found that the Agency recorded expenses totaling $390,842 that misstated its
appropriations balance. The EPA attempted to correct these expenses by recording an adjustment that created an
abnormal balancea negative balance that we would not expect to be negativein the Appropriations Used
financial statement line item.
We recommended that the chief financial officer, in coordination with the assistant administrator for Land and
Emergency Management, enhance internal controls over accounting for expenses recorded under fund codes so
that appropriation balances are accurate. Specifically, the EPA needs to implement preventative controls, so fund
expenses are properly coded when processed, and implement detective controls at the fund level to ensure
fee-based expenses and appropriations-based expenses are properly segregated, reconciled, and recorded in the
general ledger.
The EPA agreed with our findings and recommendations. On August 15, 2022, the EPA certified completion of all
corrective actions. We will evaluate the effectiveness of the EPA's corrective actions during our audit of the
FY 2022 financial statements.
Source: OIG analysis of prior year recommendations, findings, and Agency corrective actions. (EPA OIG table)
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Attachment 3
Status of Recommendations
and Potential Monetary Benefits
RECOMMENDATIONS
Potential
Planned
Monetary
Rec.
Page
Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
10 Correct the accounts receivable and earned revenue balances.
10 In coordination with the assistant administrator for Land and
Emergency Management, assess the EPA's procedures for
recording Hazardous Waste Electronic Manifest System Fund
delinquent amounts and implement controls to prevent accounts
receivable and earned revenue duplication.
Chief Financial Officer
Chief Financial Officer
$3,500
5/31/22
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
22-F-0062
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Appendix A
For the Fiscal Years Ending September 30, 2021
and 2020 Hazardous Waste Electronic
Manifest System Fund (e-Manifest) Financial
Statements (With Restatements)
22-F-0062
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For the Fiscal Years Ending September 30, 2021 and 2020
Hazardous Waste Electronic Manifest System Fund (e-Manifest)
Financial Statements (With Restatements)
sjSk)
%
PRO"f^C
Produced by the U.S. Environmental Protection Agency
Office of the Chief Financial Officer
Office of the Controller
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Table of Contents
Management Discussion and Analysis ,1
Principal Financial Statements ,6
Balance Sheet 6
Statement of Net Cost 7
Statement of Changes in Net Position 8
Statement of Budgetary Resources 9
Notes to Financial Statements. 10
Note 1. Summary of Significant Accounting Policies 10
A. Reporting Entity. 10
B. Basis of Presentation 10
C. Budgets and Budgetary Accounting 10
D. Basis of Accounting. 10
E. Revenues and Other Financing Sources 11
F. Funds with the Treasury 11
G. General Property, Plant, and Equipment 11
H. Liabilities 11
I. Accmed Unfunded Annual Leave 11
J. Retirement Plan 12
K. Use of Estimates 12
L. Reclassification and Comparative Figures 12
Note 2. Fund Balance with Treasury (FBWT) 13
Note 3. Accounts Receivable, Net (Restated) 13
Note 4. Accounts Payable 14
Note 5. General Property, Plant and Equipment, Net 14
Note 6. Federal Employee Benefits Payable 16
Note 7. Other Liabilities 16
Note 8. Recoveries and Resources Not Available, Statement of Budgetary Resources 17
Note 9. Unobligated Balances Available 18
Note 10. Undelivered Orders at the End of the Period 18
Note 11. Other Adjustments, Statement of Changes in Net Position 18
Note 12. Income and Expenses from Other Appropriations 19
Note 13. Exchange Revenues, Statement of Net Cost 19
Note 14. Intragovemmental Costs and Exchange Revenue (Restated) 19
Note 15. Reconciliation of Net Costs to Net Outlays (Restated) 20
Note 16. Restatements 22
22-F-0062 16
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Management's Discussion and Analysis
Introduction
The Hazardous Waste Electronic Manifest System Fund (e-Manifest) was established as a result of the
Hazardous Waste Manifest Establishment Act (Public Law 112-195, October 5, 2012). The e-Manifest Act
requires the United States Environmental Protection Agency ('EPA' or 'the Agency') to establish and own a
hazardous waste electronic manifest program information technology ('IT') system that will enable electronic
manifesting as a means to augment or replace the use of paper manifests for tracking hazardous waste
shipments. The e-Manifest Act requires that the e-Manifest system:
1. Meets the needs of the user community.
2. Attracts sufficient user participation and service revenues to ensure the viability of the system (the e-
Manifest Act authorizes EPA to collect reasonable user fees).
3. Decreases the administrative burden on the user community.
Current EPA RCRA Manifest Program
The EPA Office of Land and Emergency Management (OLEM) provides policy, guidance and direction for
the Agency's emergency response and waste programs. The Office of Resource Conservation and Recovery
(ORCR) within OLEM works to protect human health and the environment by ensuring responsible national
management of hazardous and nonhazardous waste. Working with delegated state waste programs, ORCR
implements the 1976 Resource Conservation and Recovery Act (RCRA), and ensures that the resource
conservation, recovery and waste management goals of RCRA are met. All states with the exception of Iowa
and Alaska have been delegated RCRA authority, meaning that states implement many if not all aspects of
RCRA policy.
The manifest program as implemented by EPA and the states ensures that hazardous waste shipments are
consistently tracked, and that hazardous wastes in fact arrive at permitted waste management facilities. The
manifest program is based on both RCRA and Department of Transportation (DOT) hazardous materials law
(The Hazardous Materials Transportation Act (HMTA)). These laws together require uniformity in the
content and use of the hazardous waste manifest form.
Launched at the end of June of 2018, e-Manifest now receives about 5,000 hazardous waste manifests a day
and generates more than $1 million in fees each month to support the system. EPA estimates that e-Manifest
will save state and industry users, on average, $50 million annually, once electronic manifests are widely
adopted. In FY 2021, EPA received 1.8 million manifests.
e-Manifest System Planning Activities
Discussion of the e-Manifest system itself has taken place over many years; beginning back in the 1990's
when the concept of an electronic manifest system was first taking shape. Further activities continued over
the years to envision the e-Manifest system through various stakeholder discussions and pilots. For more
information on EPA's efforts prior to the passage of the e-Manifest Act in 2012, please visit
http://www.epa.gov/osw/hazard/transportation/manifest/e-man-pastmeetings.htm.
In early calendar year (CY) 2013, EPA conducted various stakeholder requirements meetings to reengage
with the user community. The purpose of these meetings was to build on past e-Manifest work to determine
high level system functional requirements. Following this, a system alternatives analysis was conducted to
look at various system implementation approaches, all assuming a full electronic mobile workflow. The
alternatives analysis recommended that EPA leverage cloud hosting for initial system development and
system launch, and for long term operations and maintenance (O&M), consider re-negotiating the cloud
contract model or potentially migrate to an on-premise hosting model to keep costs down.
EPA's FY 2021 e-Manifest Financial Statements
1.
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Also as a part of the planning work, a system Concept of Operations (CONOPS) was completed that, at a
high level, outlines both what the current manifest process entails for highway and rail transporters as well as
what the future system may look like. The CONOPS document provides a process and conceptual model for
how data will flow from stakeholder to stakeholder and through the system during the manifest workflow.
The technical architecture for e-Manifest was completed in FY 2015. This architecture includes the specific
components and data flows as currently defined to illustrate a technical solution for the e-Manifest system. In
doing so, it defines the specific boundaries of the e-Manifest system and how the different parts of the system
work together to provide the required services based on current requirements. For example, areas such as
system Cross-Media Electronic Reporting Regulation (CROMERR) integration, paper manifest processing
and manifest data quality assurance (QA) were analyzed as a part of this effort.
As a part of this technical architecture planning work, EPA conducted targeted meetings with states and
industry separately in order to further flesh out current processes as well as expectations for the above areas.
The meetings were more detailed than previous discussions and provided critical information to inform
system requirements.
The technical architecture work completed in FY 2015 serves as baseline for the current manifest program
and provides very strong foundation for future system buildout. It meets user needs and provides flexibility
for future iterations of the system.
Building on FY 2015, in FY 2016 the e-Manifest program realized significant progress while leveraging
existing ORCR software applications. EPA initially conceived e-Manifest as a standalone system and
allowed the system architects to consider a broad range of approaches without inherent constraints from an
existing system design. However, as designs matured, it was recognized that the e-Manifest technical
solution aligned closely with RCRAInfo in terms of end user functionality, data integration, and required
technical infrastructure. These factors led to the decision to implement e-Manifest as a unique module of
RCRAInfo.
Many of the new capabilities of e-Manifest can be implemented in RCRAInfo using the existing modular
architecture present in RCRAInfo. In addition, some of the more innovative design aspects of e-Manifest
could also be incorporated into RCRAInfo, improving both systems.
Furthermore, by leveraging e-Manifest and RCRAInfo modules, opportunities for reuse of existing
technology investments were present, reducing the burden of e-Manifest implementation.
These factors led to the decision to develop e-Manifest and RCRAInfo modules as distinct, but interrelated
entities which will meet the current and future needs of Industry, Government and the Public.
Acquisition Strategy Change
The EPA's system development work is focused on ensuring user needs are met from day one of national
system deployment. To accomplish this, the agency is conducting user-centered design and development, and
is utilizing agile software development methodologies. This approach embodies continuous improvement
through pilots and testing, using iterative processes, and continued regular engagement with users and
stakeholders throughout the process to provide on-going opportunities for input.
EPA's FY 2021 e-Manifest Financial Statements
2.
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Instead of locking in on one source, the new e-Manifest Program services contract (multi-vendor indefinite
delivery/indefinite quantity (IDIQ)) will utilize a variety of vehicles for the following segments of the system:
Project management including integration services.
Paper manifest processing.
User help desk and user training.
Quality assurance for manifest data amongst industry, states, and the EPA.
Services to calculate, collect, and support reporting of user fees for paper and electronic manifest
processing.
Support for stakeholder communication, including outreach and meeting support.
Research has shown that using this type of lean start-up methodology, with agile techniques, lowers the cost
of system development by addressing uncertainties promptly, and by ensuring that the work being completed
brings real value to users.
The agency will continue to work closely with users, add more functionality in an incremental manner and
provide continuous improvement for the lifetime of the system. By taking this iterative approach the EPA
will refine remaining uncertainties from its architecture planning work in the most cost-effective manner.
e-Manifest System Development
As a follow-on to the completed technical and conceptual architecture, e-Manifest embarked on a pilot to
create initial system functionality with the General Service Administration's (GSA) 18F consulting shop.
18F provided the IT expertise to create the foundation of e-Manifest and also provided agile project
management support. Specifically, 18F:
Introduced user-centered design/development, which engages industry/state users in the early phases of
development.
Created the development platform and hosting environment for e-Manifest.
Leveraged open source technologies (Trello, GitHub, biweekly online meetings showcasing recent
system updates) to allow users and other stakeholders to follow and participate in system development.
In September 2015, as part of the agile development focus, EPA, in partnership with 18F, completed an
initial system demonstration. This focused on a key aspect of the system: the transaction at the end of the
chain-of-custody when the hazardous waste arrives at the designated waste management facility, and that
facility signs the electronic manifest to verify that all the hazardous waste types and quantities were received.
Getting the system to properly electronically execute this all-important manifest transaction was a critical
first step. EPA worked with several industry users to complete this initial system functionality.
Although not as straightforward as standard government IT development projects, this course correction from
traditional lifecycle system development ("waterfall") methodology to agile will ultimately deliver a better
system in a quicker, more value-added method going forward.
EPA's FY 2021 e-Manifest Financial Statements
3.
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Starting with this initial system, EPA has been adding more functionality in an incremental manner. Research
has shown that using this type of lean start-up methodology with agile techniques lowers the cost of current
and future system development by addressing uncertainties sooner rather than later. Therefore, EPA has been
conducting user-centered design and development, starting with the small-scale demonstration phase. Open
source code and project engages industry and state users in the early phases of development, creation of
development platform, and hosting environment. EPA will expand engagement efforts to all users over time
(e.g., states with no systems, large and small generators, etc.).
The agile software development methodology embodies continuous improvement through iterative
development and delivers software in sprints. Agile embraces change, continuous and regular feedback and
improvement, value-driven delivery, full-team collaboration, and learning through discovery. Agile
techniques cannot eliminate the challenges intrinsic to high-discovery software development, but by focusing
on continuous delivery of incremental value and shorter feedback cycles, they expose challenges as early as
possible to allow for immediate correction.
EPA has adopted the lean start-up product development strategies with agile, user-centered software
design/development methodologies and has implemented the following:
Conducting two-week sprint intervals.
Using modular development practices, relying heavily on available off-the-shelf software modules, by
building individual working pieces of the system and integrating them into the whole.
Addressing uncertainties that arose during the initial architecture planning work, and engaging early with
users and stakeholders.
Bringing down the cost of current and future development by addressing risk upfront and ensuring that
the work being completed brings actual value to stakeholders and users.
Continuously improving, using iterative processes, and engaging regularly with users and stakeholders
throughout the life of the program.
EPA has made every effort to involve industry users in the development process to build the strongest
possible system. During the system development phase, the e-Manifest team is working alongside industry,
states, and other stakeholders, focusing on issues raised and addressing the issues, including the following:
How the national e-Manifest system will connect with state and industry systems.
User testing of the web application.
Addressing state data access needs.
The e-Manifest team communicates regularly with states, industry, and related stakeholders about ongoing
developments (i.e., continued release and testing of system iterations), updates on e-Manifest related rules
(i.e., user fees for the e-Manifest system and amendments to manifest regulations), and the national launch of
the e-Manifest system.
EPA's FY 2021 e-Manifest Financial Statements
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Our primary methods of communication include the following:
The e-Manifest website
User testing
Conferences
Site visits
Regional implementation working groups
Listserv (general interest and development-focused)
Public webinars
Blog posts
GitHub - code repository and project management
FACA Meetings
Meetings with stakeholders
e-Manifest will follow this path of milestones to system launch and beyond in 2021:
September 2015- initial system functionality completed
Spring 2016 - minimal viable product development
Spring through fall 2016 - early full-scale development
Fall 2016 through winter 2018 - rolling iterative releases/testing of system
Winter 2018 - finalize user fee rule
June 30, 2018 System Launch
Continued development, enhancements and user outreach
Summer 2019 - update user fees
Winter 2020 - deployed updated electronic signature approach
Summer 2021 - update user fees
Fall 2021 - engage stakeholders on enhancing electronic adoption
EPA's FY 2021 e-Manifest Financial Statements
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Principal Financial Statements
U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Balance Sheet
As of September 30, 2021 and 2020 (Restated)
(Dollars in Thousands)
ASSETS
Intragovernmental:
Fund Balance With Treasury (Note 2)
Advances and Prepayments
Total Intragovernmental
2021
19,312
1
19,313
Restated
2020
10.790
11
10,801
Accounts Receivable, Net (Restated) (Notes 3, 16)
General Property, Plant and Equipment, Net (Note 5)
Total Assets
4,785
2.243
26.341
6,683
3.624
21.108
LIABILITIES
Intragovernmental:
Accounts Payable (Note 4) S 97 $ 57
Other (Note 7) - 9
Total Intragovernmental 97 66
With the Public:
Accounts Payable (Note 4) 760 1,229
Federal Employee Benefits Payable (Note 6) 143 118
Other (Note 7)' " L392 1,919
Total Liabilities $ 2.392 $ 3.332
NET POSITION
Unexpended Appropriations - Funds from Dedicated Collections S 24 $ 94
Cumulative Results of Operations - Funds from Dedicated Collections 23.925 17.682
Total Net Position 23.949 17.776
Total Liabilities and Net Position S 26.341 S 21.108
The accompanying notes are an integral part of these financial statements
EPA's FY 2021 e-Manifest Financial Statements
22-F-0062 22
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Statement of Net Cost
For the Fiscal Years Ended September 30, 2021 and 2020 (Restated)
(Dollars in Thousands)
2021
Restated
2020
COSTS
Gross Costs
Expenses from Other Appropriations (Note 12)
Less: Earned Revenue (Restated, Note 16)
17,603
3,162
23.589
25,818
4,379
29.896
NET COST OF OPERATIONS (Notes 14 and 15)
(2.824) $_
301
The accompanying notes are an integral part of these financial statements
EPA's FY 2021 e-Manifest Financial Statements
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Statement of Changes in Net Position
For the Fiscal Years Ended September 30, 2021 and 2020 (Restated)
(Dollars in Thousands)
Cumulative Results of Operations:
Net Position - Beginning of Period
Correction of errors (Note 16)
Net Position - Beginning of Period, as Adjusted
Budgetary Financing Sources:
Appropriations Used
Transfers In/Out
Income from Other Appropriations (Note 12)
Total Budgetary Financing Sources
Other Financing Sources (Non-Exchange)
Imputed Financing Sources
Total Other Financing Sources
Net Cost of Operations (Restated) (Note 16)
Net Change
Cumulative Results of Operations
Unexpended Appropriations:
Beginning Balance
Budgetary Financing Sources:
Other Adjustments (Note 11)
Appropriations Used
Total Budgetary Financing Sources
Total Unexpended Appropriations
TOTAL NET POSITION
2021
Restated
2020
17,682
13,292
-
(6)
; 17,682 S
13,286
92
-
23
3.162
4.379
3,162
4,494
257
203
257
203
I 2,824 S
(301)
6.243
4.396
; 23.925 $
17.682
; 94 S
186
(70)
_
-
(92)
(70)
(92)
24
94
23.949 $
17.776
The accompanying notes are an integral part of these financial statements
EPA's FY 2021 e-Manifest Financial Statements
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Statement of Budgetary Resources
For the Fiscal Years Ended September 30, 2021 and 2020
(Dollars in Thousands)
2021
2020
BUDGETARY RESOURCES
Unobligated Balance From Prior Year Budget Authority, Net (discretionary and
mandatory) (Note 8)
S
6,166
S
2,104
Spending Authority from Offsetting Collections (discretionary and mandatory)
25.462
24.551
Total Budgetary Resources
$
31.628
S
26.655
STATUS OF BUDGETARY RESOURCES
New Obligations and Upward adjustments (total)
s
21.652
s
20,465
Unobligated Balance, End of Year:
Apportioned, Unexpired Accounts
9.765
5,909
Expired Unobligated Balance. End of Year
211
281
Unobligated Balance, End of Year (total): (Note 9)
9.976
6.190
Total Status of Budgetary Resources
$
31.628
$
26.655
OUTLAYS, NET
Outlays, Net (total) (discretionary and mandatory)
s
(8.593)
s
(2.761)
Agency Outlays, Net (discretionary and mandatory)
s
(8.593)
s
(2.761)
The accompanying notes are an integral part of these financial statements
EPA's FY 2021 e-Manifest Financial Statements
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 1. Summary of Significant Accounting Policies
A. Reporting Entity
The EPA was created in 1970 by executive reorganization from various components of other federal agencies
to better marshal and coordinate federal pollution control efforts. The Agency is generally organized around
the media and substances it regulates - air. water, waste, pesticides, and toxic substances.
The Hazardous Waste Electronic Manifest System Fund (e-Manifest) was authorized by the establishment of
the Hazardous Waste Electronic Manifest System Act. The act mandates that the Agency, within three years,
establish a hazardous waste electronic manifest system that can be accessed by any user. The act authorized
the administrator to impose user fees to pay the costs incurred in developing, operating, maintaining, and
upgrading the system, including any costs incurred in collecting and processing data from paper manifests
submitted to the system after the date on which the system enters operations.
The e-Manifest fund charges some administrative costs directly to the fund, and charges the remainder of the
indirect administrative costs to Agency-wide appropriations. These amounts are included as "Income from
Other Appropriations" on the Statement of Changes in Net Position and as "Expenses from Other
Appropriations" on the Statement of Net Cost.
B. Basis of Presentation
These financial statements have been prepared to report the financial position and results of operations of the
EPA for the e-Manifest Fund in accordance with the Chief Financial Officers Act of 1990 and the
Government Management Reform Act of 1994. The reports have been prepared from the books and records
of the EPA in accordance with Office of Management and Budget (OMB) Circular A-136 Financial
Reporting Requirements, and the EPA's accounting policies which are summarized in this note. These
statements are therefore different from the financial reports also prepared by the EPA pursuant to the OMB
directives that are used to monitor and control the EPA's use of budgetary resources.
C. Budgets and Budgetary Accounting
For fiscal year 2021, the e-Manifest fund was funded through offsetting collections. For fiscal year 2020 the
e-Manifest fund was funded through both appropriations and offsetting collections.
D. Basis of Accounting
Generally Accepted Accounting Principles (GAAP) for federal entities is the standard prescribed by the
Federal Accounting Standards Advisory Board (FASAB), which is the official standard-setting body for the
Federal Government and the American Institute of Certified Public Accountants (AICPA). The financial
statements are prepared in accordance with GAAP for federal entities.
Transactions are recorded on an accrual accounting basis and a budgetary basis. Under the accrual method,
revenues are recognized when earned and expenses are recognized when liabilities are incurred, without
regard to receipt or payment of cash. Budgetary accounting facilitates compliance with legal constraints and
controls over the use of federal funds posted in accordance with OMB directives and the U.S. Treasury
regulations.
EPA's FY 2021 e-Manifest Financial Statements
10.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
E. Revenues and Other Financing Sources
For fiscal years 2021 and 2020, EPA received funding from fees collected and recognized revenues from
collections to the extent that expenses were incurred during the fiscal year.
F. Funds with the Treasury
The e-Manifest fund deposits receipts and processes disbursements through its operating account maintained
at the U.S. Department of Treasury.
G. General Property, Plant, and Equipment
General property, plant and equipment for e-Manifest consists of software in development. Internal use
software includes purchased commercial off-the-shelf software, contractor developed software and software
that was internally developed by Agency employees. In fiscal year 2017, EPA reviewed its capitalization
threshold levels for PP&E. The Agency performed an analysis of the values of software assets and increased
capitalization threshold from S250 thousand to $5 million to better align with major software acquisition
investments. The $5 million threshold will be applied prospectively to software acquisitions and
modifications/enhancements placed into service after September 30, 2016. Software assets placed into
service prior to October 1, 2016 were capitalized at the S250 thousand threshold. Internal use software is
capitalized at full cost (direct and indirect) and amortized using the straight-line method over its useful life,
not exceeding five years. The Hazardous Waste Electronic Manifest System was placed into production
August 23, 2018.
H. Liabilities
Liabilities represent the amount of monies or other resources that are more likely than not to be paid by the
Agency as the result of an Agency transaction or event that has already occurred and can be reasonably
estimated. However, no liability can be paid by the Agency without an appropriation or other collections
authorized for retention. Liabilities for which an appropriation has not been enacted are classified as
unfunded liabilities and there is no certainty that the appropriations will be enacted. Liabilities of the Agency
arising from other than contracts can be abrogated by the Government acting in its sovereign capacity.
I. Accrued Unfunded Annual Leave
Annual, sick and other leave is expensed as taken during the fiscal year. Annual leave earned but not taken at
the end of the fiscal year is accrued as an unfunded liability. Accrued unfunded annual leave is included in
the Balance Sheet as a component of "Payroll and Benefits Payable." Sick leave earned but not taken is not
accrued as a liability; it is expensed as it is used.
EPA's FY 2021 e-Manifest Financial Statements
11.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
J. Retirement Plan
There are two primary retirement systems for federal employees. Employees hired prior to January 1, 1987,
may participate in the Civil Service Retirement System (CSRS). On January 1, 1987, the Federal Employees
Retirement System (FERS) went into effect pursuant to Public Law 99-335. Most employees hired after
December 31, 1986, are automatically covered by FERS and Social Security. Employees hired prior to
January 1, 1987, elected to either join FERS and Social Security or remain in CSRS. A primary feature of
FERS is that it offers a savings plan to which the Agency automatically contributes one percent of pay and
matches any employee contributions up to an additional four percent of pay. The Agency also contributes the
employer's matching share for Social Security.
With the issuance of SFFAS No. 5, Accounting for Liabilities of the Federal Government, accounting and
reporting standards were established for liabilities relating to the federal employee benefit programs
(Retirement, Health Benefits, and Life Insurance). SFFAS No. 5 requires that the employing agencies
recognize the cost of pensions and other retirement benefits during their employees' active years of service.
SFFAS No. 5 requires that the Office of Personnel Management (OPM), as administrator of the CSRS and
FERS, the Federal Employees Health Benefits Program, and the Federal Employees Group Life Insurance
Program, provide federal agencies with the actuarial cost factors to compute the liability for each program.
K. Use of Estimates
The preparation of financial statements requires management to make certain estimates and assumptions that
affect the reported amounts of assets and liabilities, including environmental and grant liabilities, and the
reported amounts of revenue and expenses during the reporting period. Actual results could differ from those
estimates.
L. Reclassifications and Comparative Figures
Certain reclassifications have been made to the prior year's financial statements to enhance comparability
with the current year's financial statements in accordance with Office of Management and Budget (OMB)
Circular No. A-136, Financial Reporting Requirements revised August 20, 2021. As a result, the form and
content of the Balance Sheet has changed to conform with OMB Circular No. A-136.
EPA's FY 2021 e-Manifest Financial Statements
12.
22-F-0062
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 2. Fund Balance With Treasury (FBWT)
Fund Balance with Treasury as of September 30, 2021 and 2020, consists of the following:
2021 2020
Entity Non-Entity
Assets Assets
Total
Entity
Assets
Non-Entity
Assets
Total
Revolving Funds:
E-Manifest $ 19.312 S
$ 19.312 !
S 10.790
$
S 10.790
Total $ 19,312 $
$ 19.312 !
S 10.790
$
$ 10.790
Status of Fund Balances:
2021
2020
Unobligated Amounts in Fund Balance:
Available for Obligation
Unavailable for Obligation
Obligated Balance not yet Disbursed
Total
s
$
9.765
211
9.336
19.312
S 6,452
4.338
S 10.790
Note 3. Accounts Receivable, Net (Restated)
Accounts Receivable as of September 30, 2021 and 2020, consist of the following:
2021
(Restated)
2020
Non-Federal:
Accounts & Interest Receivable
Less: Allowance for Uncollectible
Total
s
$
4.794
(9)
4.785
S 6,687
(4)
$ 6.683
The Allowance for Uncollectible Accounts is determined both on a specific identification basis, as a result of
a case-by-case review of receivables, and on a percentage basis for receivables not specifically identified.
EPA's FY 2021 e-Manifest Financial Statements
13.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 4. Accounts Payable
Accounts Payable are current liabilities and consist of the following amounts as of September 30, 2021 and
2020:
2021 2020
Intragovernmental:
Accrued Liabilities
S 97
$
57
Total
S 97
S
57
2021
2020
Non-Federal:
Accounts Payable
$ 760
s
1.229
Total
S 760
$
1.229
Note 5. General Property, Plant and Equipment, Net
As of September 30, 2021, General PP&E Cost consisted of the following:
2021
EPA-
Held
Equipment
Software
(production)
Software
(development)
Contractor
Held
Equipment
Land
and
Buildings
Capital
Leases
Total
Balance,
Beginning of
Year
S
S 6.907
S
$
$
$ - $
6.907
Balance, End
of Year
s
S 6,907
S
$
$
$ - S
6,907
As of September 30, 2021, General PP&E Accumulated Depreciation consisted of the following:
2021
EPA-
Held
Equipment
Software
(production)
Software
(development)
Contractor
Held
Equipment
Land
and
Buildinss
Capital
Leases
Total
Balance,
Beginning of
Year
Depreciation
Expense
$
$ 3,283
1.381
$
$
$
$ - $
3,283
1.381
Balance, End
of Year
S
$ 4.664
$
$
$
$ - S
4.664
EPA's FY 2021 e-Manifest Financial Statements
14.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
As of September 30, 2021, General PP&E, Net consisted of the following:
2021
EPA- Contractor Land
Held Software Software Held and
Equipment (production) (development) Equipment Buildings
Capital
Leases
Total
Balance, End
of Year, Net S - S 2,243 S $ - $
$ - $
2,243
As of September 30, 2020, General PP&E Cost consisted of the following:
2020
EPA- Contractor Land
Held Software Software Held and
Equipment (production) (development) Equipment Buildings
Capital
Leases
Total
Balance,
Beginning of
Year $ - $ 6.907 $ - $ - $ -
$ - $
6.907
Balance, End
ofYear $ - S 6.907 S - $ - S
$ - $
6.907
As of September 30, 2020, General PP&E Accumulated Depreciation consisted of the following:
2020
EPA- Contractor Land
Held Software Software Held and
Equipment (production) (development) Equipment Buildings
Capital
Leases
Total
Balance,
Beginning of
Year $ - $ 1,899 $ - $ - $ -
Depreciation
Expense - 1.384
$ - $
1,899
1.384
Balance, End
ofYear S - S 3.283 $ - $ - $ -
$ - S
3.283
EPA's FY 2021 e-Manifest Financial Statements
15.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
As of September 30, 2020, General PP&E, Net consisted of the following:
2020
EPA-
Contractor
Land
Held
Software
Software
Held
and
Capital
Equipment
(production)
(development)
Equipment
Buildings
Leases
Total
Balance, End
of Year, Net
s
S 3,624
s
$
$
$ -
$ 3,624
Note 6. Federal Employee Benefits Payable
Payroll and benefits payable to the EPA employees for the years September 30, 2021, and 2020, consist of
the following:
Covered by
Budgetary
Resources
Not Covered
by Budgetary
Resources
Total
FY 2021 Payroll and Benefits Payable
Accrued Unfunded Annual Leave
$
S 143
s
143
Total - Current
$
$ 143
s
143
Covered by
Budgetary
Resources
Not Covered
by Budgetary
Resources
Total
FY 2020 Payroll and Benefits Payable
Employer Contributions Payable - Thrift Savings Plan
Accrued LTnfiinded Annual Leave
S 2
s
116
s
2
116
Total - Current
$ 2
S 116
s
118
Note 7. Other Liabilities
Other Liabilities consist of the following as of September 30, 2021:
Covered by
Budgetary
Resources
Not Covered
by
Budgetary
Resources
Total
Other Liabilities - Non-Federal
Current
Accrued Funded Payroll and Benefits
Other
S 102
1.290
s
s
102
1.290
Total Non-Federal
S 1.392
s
s
1.392
EPA's FY 2021 e-Manifest Financial Statements
16.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Other Liabilities consist of the following as of September 30, 2020:
Not Covered
Covered by by
Budgetary Budgetary
Resources Resources Total
Current
Employer Contributions & Payroll Taxes $ 9 $ - S 9
Non-Current
Total Intragovernmental $ 9 $ - $ 9
Other Liabilities - Non-Federal
Current
Accrued Funded Payroll and Benefits S 200 S S 200
Other ' 1.719 - 1.719
Total Non-Federal £ 1.919 S S 1.919
Note 8. Recoveries and Resources Not Available, Statement of Budgetary Resources
Recoveries of Prior Year Obligations, Temporarily Not Available, and Permanently Not Available on the
Statement of Budgetary Resources consist of the following amounts for September 30, 2021, and 2020:
2021 2020
Unobligated Balance Brought Forward, Oct 1.
Adjustments to Budgetary Resources Made During the Current Year
Downward Adjustments of Prior Year Undelivered Orders
Cancelled Authority
Other Adjustments
Total
Unobligated Balance from Prior Year Budget Authority, Net
(discretionary and mandatory)
s
6.190 S
2.026
13
78
(70)
-
33
-
$
(24) $
78
6.166
2.104
EPA's FY 2021 e-Manifest Financial Statements
17.
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33
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 9. Unobligated Balances Available
Unobligated balances are a combination of two lines on the Statement of Budgetary Resources: Apportioned,
and Expired Unobligated Balances. Unapportioned, unexpired balances are available to be apportioned by the
OMB for new obligations at the beginning of the following fiscal year. The expired unobligated balances are
only available for upward adjustments of existing obligations.
The unobligated balances available consist of the following as
of September 30, 2021 and 2020:
2021
2020
Apportioned, Unexpired Accounts
S 9,765 S
5,909
Expired Unobligated Balance, End of Year
211
281
Total
$ 9,976 $
6.190
Note 10. Undelivered Orders at the End of the Period
Budgetary resources obligated for undelivered orders as of September 30, 2021 and 2020:
Intragovernmental:
Unpaid Undelivered Orders
Paid Undelivered Orders
With the Public:
Unpaid Undelivered Orders
Total
2021 2020
S 1,572 S 1,517
1 10
5.516 (42)
$ 7.089 $ 1.485
Note 11. Other Adjustments, Statement of Changes in Net Position
The Other Adjustments in Budgetary Financing Sources on the Statement of Changes in Net Position consist
of cancellation of funds that expired 5 years earlier. These amounts affect Unexpended Appropriations. As of
September 30, 2021, the amount of cancelled general authority was $70 thousand.
EPA's FY 2021 e-Manifest Financial Statements
18.
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34
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 12. Income and Expenses from Other Appropriations
The Statement of Net Cost reports the program costs that include the full cost of the program outputs and
consist of the direct costs and all other costs that can be directly traced, assigned on a cause-and-effect basis,
or reasonably allocated to program outputs.
During FYs 2021 and 2020, the indirect rate was 17.96% and 17.00%, respectively.
As illustrated below there is no impact on e-Manifest's Statement of Changes in Net Position.
2021 2020
Income from Other Appropriations
s
3,162 S
4,379
Expenses from Other Appropriations
3.162
4.379
Net Effect
s
$
-
Note 13. Exchange Revenues, Statement of Net Cost
For FYs 2021 and 2020, the exchange revenues reported on the Statement of Net Cost include both Federal
and Non-Federal amounts.
Note 14. Intragovenimental Costs and Exchange Revenue (Restated)
(Restated)
2021 2020
Costs:
Intragovenimental
S 2,558 S 1,970
With the Public
15,045 23,848
Expenses from Other Appropriations
3.162 4.379
Total Costs
S 20.765 $ 30.197
Revenue:
With the Public
23.589 29.896
Total Revenue
23,589 29,896
Net Cost of Operations:
S (2.824) S 301
Intragovenimental costs relate to the source of the goods or services not the classification of the related
revenue.
EPA's FY 2021 e-Manifest Financial Statements
19.
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35
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 15. Reconciliation of Net Costs to Net Outlays (Restated)
For the Fiscal Year Ended September 30, 2021:
Intra-
governmental
With the
Public
Total 2021
NET COST
S
5,720 a
> (8,544)
$ (2,824)
Components of Net Cost That Are Not Part of Net Outlays:
Property, Plant and Equipment Depreciation
Expenses from Other Appropriations
-
(1.381)
(3,162)
(1.381)
(3,162)
Increase/(Decrease) in Assets:
Accounts Receivable
Other Assets
(10)
(1,898)
(1.898)
(10)
(Increase)/Decrease in Liabilities:
Accounts Payable and Accrued Liabilities
Payroll and Benefits Payable
Other Liabilities
(32)
9
469
(27)
525
437
(27)
534
Other Financing Sources:
Other Imputed Financing
(257)
(257)
Total Components of Net Cost That Are Not Part of Net
Outlays
(290)
(5,474)
(5,764)
Other Temporary Timing Differences
-
(5)
(5)
NET OUTLAYS
s
5.430 3
> (14.023)
$ (8.593)
EPA's FY 2021 e-Manifest Financial Statements
20.
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
For the Fiscal Year Ended September 30, 2020 (Restated):
Intra-
governmental
With the
Public
Total 2020
NET COST (Restated) $
Components of Net Cost That Are Not Part of Net Outlays:
Property, Plant and Equipment Depreciation
Expenses from Other Appropriations
1,971 $
(1,670) $
(1.384)
(4,379)
301
(1.384)
(4,379)
Increase/(Decrease) in Assets:
Accounts Receivable (Restated)
Other Assets
(45)
5,496
5,496
(45)
(Increase)/Decrease in Liabilities:
Accounts Payable and Accrued Liabilities
Payroll and Benefits Payable
Other Liabilities
(7)
(2.380)
(261)
(2,380)
(261)
(7)
Other Financing Sources:
Transfer Out (In) Without Reimbursement
Other Imputed Financing
23
203
-
23
203
Total Components of Net Cost That Are Not Part of Net
Outlays
2,145
(4,578)
(2,433)
Other Temporary Timing Differences
-
(328)
(328)
NET OUTLAYS $
2,145 S
(4,906) S
(2,761)
Budgetary and financial accounting information differ. Budgetary accounting is used for planning and control
purposes and relates to both the receipt mid use of cash, as well as reporting the federal deficit. Financial
accounting is intended to provide a picture of the government's financial operations and financial position, so
it presents information on an accrual basis. The accrual basis includes information about costs arising from
the consumption of assets and the incurrence of liabilities. The reconciliation of net outlays, presented on a
budgetary basis, and the net cost, presented on an accrual basis, provides an explanation of the relationship
between budgetary and financial accounting information. The reconciliation serves not only to identify costs
paid for in the past and those that will be paid in the future, but also to assure integrity between budgetary
and financial accounting. The reconciliation explains the relationship between the net cost of operations and
net outlays by presenting components of net cost that are not part of net outlays (e.g. depreciation and
amortization expenses of assets previously capitalized, change in asset/liabilities), components of net outlays
that are not part of net cost (e.g. acquisition of capital assets), other temporary timing difference (e.g. prior
period adjustments due to correction of errors). The analysis above illustrates this reconciliation by listing the
key differences between net cost and net outlays.
EPA's FY 2021 e-Manifest Financial Statements
21.
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37
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U.S. Environmental Protection Agency
Hazardous Waste Electronic Manifest System Fund
Notes to the Financial Statements
Fiscal Years Ended September 30, 2021 and September 30, 2020
(Dollars in Thousands)
Note 16. Restatements
The FY 2020 financial statements were restated because of errors in accounts receivable and revenue due to
timing and duplicate billings. Six thousand dollars of the restated amount relates to duplicate billings in fiscal
year 2019. The agency implemented an integrated billing system in fiscal year 2022 which will eliminate the
timing and duplicate billing issues.
For the Year Ended September 30, 2020
Previously Restatement Restated
Reported Amount
Accounts Receivable, Net
S
6,167
516
S
6,683
Earned Revenue
s
29,374
522
S
29,896
Net Cost of Operations
s
(823)
522
s
(301)
Cumulative Results of Operations
s
17.166
516
s
17,682
EPA's FY 2021 e-Manifest Financial Statements
22.
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38
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Appendix B
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
use. $ WASHINGTON. D C 20460
%, r\-°
PRCVV
September 14, 2022
OFFICE OF THE
CHIEF FINANCIAL OFFICER
MEMORANDUM
SUBJECT: Response to the Office of Inspector General Draft Report. Project No. OA-FY22-0064,
"EPA's Fiscal Years 2021 and 2020 Hazardous Waste Electronic Manifest System Fund
Financial Statements," dated August 15, 2022
FROM: Faisal Arnin. Chief Financial Officer Am in,
Office of the Chief Financial Officer Faisal
TO: Damon Jackson. Director
Financial Directorate
Office of Audit
Digitally signed by
Amin, Faisal
Date: 2022.09.14
13:43:41 -04W
Thank you for the opportunity to respond to the issues and recommendations in the subject
draft report. The following is a summary of the U.S. Environmental Protection Agency's
overall position along with its position on the report's recommendations. This response has
been coordinated with and agreed upon by the Office of Land and Emergency Management.
AGENCY'S OVERALL POSITION
The draft report contains two recommendations for the Office of the Chief Financi al Officer.
The agency agrees with both recommendations and has completed corrective actions to
address them.
AGENCY RESPONSE TO DRAFT REPORT RECOMMENDATIONS
No.
Recommendation
High-Level Corrective Action(s)
Estimated
Completion
Date
1
Correct the accounts receivable
and earned revenue balances.
Concur. The balances have been
corrected and controls in the new
e-Manifest system have been
designed to prevent these types of
issues in the future.
Completed
8/26/2022
22-F-0062
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In coordination with the assistant
administrator for Land and
Emergency Management, assess
EPA's procedures for recording e-
Manifest delinquent amounts and
implement controls to prevent
accounts receivable and earned
revenue duplication.
Concur. An interface between the
e-Manifest system and Compass
was implemented in April 2022
which properly records the
accounts receivable and earned
revenue in the accounting month
in which they are earned. Controls
were implemented in the new
system to properly record
delinquent amounts and prevent
duplicate reporting.
Completed
5/31/2022
CONTACT INFORMATION
If you have any questions regarding this response, please contact the OCFO's Audit Follow-
up Coordinator, Andrew LeBlanc, at leblanc.andrew@epa.gov or (202) 564-1761.
cc: Barry Breen
Carlton Waterhouse
David Bloom
Lek Kadeli
Meshell Jones-Peeler
Michael Clanton
Derek David
Carolyn Hoskinson
Richard Gray
Wanda Arlington
OCFO-OC-MANAGERS
Mairim Lopez
Robert Evans
Sheila May
Andrew LeBlanc
Jose Kercado
Kecia Thornton
22-F-0062
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Appendix C
Distribution
The Administrator
Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff, Office of the Administrator
Chief Financial Officer
Assistant Administrator for Land and Emergency Management
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Deputy Assistant Administrator for Land and Emergency Management
Deputy Chief Financial Officer
Associate Chief Financial Officer
Controller
Deputy Controller
Director, Policy, Training and Accountability Division, Office of the Controller
Director, Accounting and Cost Analysis Division, Office of the Controller
Deputy Director, Accounting and Cost Analysis Division, Office of the Controller
Director, Cincinnati Finance Center, Office of the Chief Financial Officer
Director, Research Triangle Park Finance Center, Office of the Chief Financial Officer
Chief, Management, Integrity and Accountability Branch, Policy, Training and Accountability Division,
Office of the Controller
Chief, Fees and Collections Branch, Office of the Chief Financial Officer
Chief, General Ledger Analysis and Reporting Branch, Accounting and Cost Analysis Division, Office of
the Chief Financial Officer
Director, Office of Program Management, Office of Land and Emergency Management
Director, Office of Resource Conservation and Recovery, Office of Land and Emergency Management
Director, Program Management, Communications, and Analysis Office, Office of Resource Conservation
and Recovery, Office of Land and Emergency Management
Director, Program Implementation and Information Division, Office of Resource Conservation and
Recovery, Office of Land and Emergency Management
Branch Chief, Information Collection and Analysis Branch, Office of Resource Conservation and
Recovery, Office of Land and Emergency Management
Branch Chief, Resource Management Staff, Office of Resource Conservation and Recovery, Office of
Land and Emergency Management
Associate Branch Chief, Information Collection and Analysis Branch, Office of Resource Conservation and
Recovery, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Liaison, Office of Resource Conservation and Recovery, Office of Land and Emergency
Management
22-F-0062
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