Office of Inspector General

U.S. Environmental Protection Agency

At a Glance

23-P-0018
May 17, 2023

The CSB Complied with Improper Payments Requirements in Fiscal Year 2022
but Should Improve Internal Controls for Improper Payments Reporting

Why We Did This Audit

To accomplish this objective:

The U.S. Environmental Protection
Agency Office of Inspector General
conducted this audit to determine
whether the U.S. Chemical Safety and
Hazard Investigation Board complied
with the Payment Integrity Information
Act of 2019 in fiscal year 2022.

The Payment Integrity Information Act
aims to improve efforts to identify and
reduce governmentwide improper
payments. The Office of Management
and Budget directs agencies to identify
all programs and activities they
administer that expend more than
$10 million annually and perform a risk
assessment to determine whether they
are susceptible to significant improper
payments. Office of Management and
Budget Circular A-123, Appendix C,
requires each agency to publish payment
integrity information with its annual
financial statements. Agency inspectors
general are to review payment integrity
reporting for compliance and issue an
annual report.

To support this CSB mission-related
effort:

• Creating and maintaining an
engaged, high-performing
workforce.

Effective internal controls reduce
the risk of improper payment
inaccuracies and increase
confidence in the CSB's ability to
achieve its mission.

What We Found

In fiscal year 2022, the CSB complied with the
requirements of the Payment Integrity
Information Act of 2019, or PI I A, and the
applicable Office of Management and Budget
guidance. Because the CSB had less than
$10 million in annual program outlays for
FY 2022, the Board was only required to publish its performance and accountability
report and post the report on its website. Additionally, the CSB performed an improper
payments risk assessment for FY 2022, even though it was not required to do so
because none of its annual program outlays exceeded $10 million.

Despite the CSB's overall compliance with the PI I A, we identified deficiencies in its
processes for determining and recording improper payments. In FY 2022, the CSB made
$1,036 in improper payments related to sales tax and $10,878 in improper payments
related to payroll transactions, for a total of $11,914 in improper payments. The CSB,
however, did not account for the improper payments related to payroll transactions when
determining the total value of its improper payments. It also did not accurately record its
improper payments related to sales tax. Furthermore, the CSB erroneously included
amounts paid pursuant to interagency agreements when determining its program
outlays, and it misidentified the improper payments statute in its payment integrity-related
reporting.

Inadequate controls, including a lack of written guidance, insufficient supervisory
reviews, and no training on PI IA requirements, contributed to these inaccuracies. These
inaccuracies did not impact our conclusion that the CSB is compliant with the PI IA, but
without improvements in internal controls, the CSB may continue to make similar
mistakes. Accurate improper payments reporting is important for the CSB to
demonstrate its commitment to financial integrity and transparency.

Recommendations and Planned CSB Corrective Actions

We recommend that the CSB establish and implement written procedures on the PI IA
and improper payments reporting, including an internal review for errors and a process
for making corrections. Additionally, we recommend that the CSB provide training to
applicable CSB staff about the PI I A, improper payments, and the associated
procedures. The CSB agreed with our recommendations. All recommendations are
resolved with corrective actions pending.

Address inquiries to our public affairs

office at (202) 566-2391 or

OIG WEBCOMMENTS@epa.gov.

List of OIG reports.

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