September 2008
Revised April 2009
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# Ti U.S. ENVIRONMENTAL PROTECTION AGENCY
I ^142 I OFFICE OF INSPECTOR GENERAL
% PRO^
Catalyst for Improving the Environment
FY 2009 Annual Plan with Strategic Plan Update and
Draft Plans for Oversight of the American Recovery and Reinvestment Act of2009
Based Upon the Enterprise Risk Management Integrated Framework Model
Developed by the Committee of Sponsoring Organizations of the Treadway Commission
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Environmental Protection Agency Office of Inspector General Strategic Plan FY 2009 Update
Goals:
1. Contribute to Improved Human Health and Environmental Quality
2. Contribute to Improved Business Practices and Accountability
3. Continuously Improve Office of Inspector General (OIG) Products and Services
Objectives: (linked to OIG's Government Performance and Results Act Budget Measures and Targets on Page 22)
Influence Programmatic and Business Actions, Savings and Risk Reduction for Improved Operational Efficiency,
Accountability, Environmental Quality, and Public Health.
Identify Recommendations, Risks, Weaknesses, Best Practices, and Opportunities for Operational and Environmental
Improvements and Resource Savings.
Leverage a Positive Dollar Return in Savings and Recoveries from Funds Invested in the OIG.
Improve Operational and Program Integrity, Reduce Loss of Resources, and Promote Public Confidence in EPA through
Detection and Prevention of Fraud, Waste, and Abuse.
Strategy: (linked to the assignments listed in this plan)
Create an organizational structure and culture which maximizes the application of resources, information, measurement,
technology, empowerment, teamwork, creativity, and communication for mutual accountability and efficient productivity.
Plan assignments that fulfill all statutory and regulatory requirements, meet the needs of EPA's stakeholders, address
EPA's most significant risks, and are outcome-oriented to influence actable changes, savings, and long-term
improvements.
Implemented through Offices of Audit, Program Evaluation, Mission Systems, and Investigations, based upon the
Enterprise Risk Management Integrated Framework Model {shown on the cover) and focusing on the following Themes:
o Agency Research
o Follow-up
o Grants and Contracts
o Homeland Security
o Internal Controls Risk Assessment
o Manpower Assessment
o Enforcement/Regulation Review
o Oversight of Recovery Act Funds (added March 2009)
o Program Management Data Verification
o Project Management
o Effective Resource Management Accountability
o Siiperfund
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The OIG mission is to conduct and supervise audits, evaluations, inspections, and investigations relating to the programs and operations
of the Agency; provide leadership and coordination and recommend policies for activities designed to promote economy, efficiency, and
effectiveness in the administration of Agency programs and operations, and to prevent and detect fraud and abuse in such programs and
operations; and keep the Administrator and the Congress fully and currently informed about problems and deficiencies relating to the
administration of such programs and operations and the necessity for and progress of corrective action.
This OIG Annual Plan identifies mandated and selected assignment topics continuing from Fiscal Year (FY) 2008, and those scheduled
to be started through the second half of FY 2009, providing for unforeseen work in the latter part of the year which may be directed by a
new Inspector General, and requests from new Agency leadership and Congress. Because this is a "living," flexible document subject to
change, the reader is encouraged to consult our Web page for the most current listing of recently issued reports at www.epa.gov/oig.
Appendix B (page 25) has been added to include the EPA OIG's Draft Plans in response to its oversight responsibilities in support of the
American Recovery and Reinvestment Act of 2009 (ARRA or Recovery Act).
Implementation of this Plan is carried out through audits, evaluations, investigations, and public liaison reviews in compliance with the
Inspector General Act, the applicable Professional Standards of the U.S. Comptroller General, and the Quality Standards for Federal
Offices of Inspector General of the President's Council on Integrity and Efficiency.
Primary sources of input for the assignments listed in this plan included a Risk Assessment across the Agency programs and operations
based upon prior OIG work, Government Accountability Office (GAO) high-risk assessments, congressional interest, Office of
Management and Budget (OMB) priorities, Agency Program Assessment Rating Tool reviews, Agency vulnerability assessments under
OMB Circular A-123 and the Federal Managers' Financial Integrity Act (FMFIA), and identification of key Agency challenges and
strategic planning priorities. Our current planning also reflects a direct outreach and solicitation of topics and assignment suggestions
with EPA's leadership during FYs 2006, 2007, and 2008. As a result, a significant number of new assignments listed in this Plan are
responsive to the immediate concerns or requests of our clients. Other assignments are required or are self-initiated based upon our
themes where we believe we can provide the greatest value and risk reduction to the Agency and the public interest. We want to thank
each of the Assistant Administrators, Regional Administrators, and the Deputy Administrator for their participation in this process, and
look forward to continuing an open dialogue for receiving their ideas, suggestions, and feedback.
We welcome input into our planning process, and feedback on the quality and value of OIG products and services from all customers,
clients, stakeholders, and the public through our Website: webcomments.oig@epa.gov.
Bill A. Roderick
Acting Inspector General
in
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Table of Contents
1 Identifying the Risks
1 Top EPA Management Challenges
2 OIG Identified - EPA Internal Control Risks and Deficiencies
2 GAO Identified - EPA High-Risk Areas
3 EPA Identified Management Challenges, Risks, Priorities, Issues
5 The Strategy
5 Risk and Customer-Driven Themes for Greater Performance and Efficiency
8 Making Choices - A Customer-Driven Process
9 The Plan - Continuing and New Assignments
9 Audit Plan
10 Assistance Agreements and Contracts
11 Forensic Audits
12 Financial Audits
12 Risk Assessment and Program Performance
13 Office of Mission Systems
Evaluations and Special Reviews Plan
15 Air and Research
16 Water and Enforcement
Land and Superfund
17 Cross Media
Special Reviews (new assignments planned for FY 2009)
18 Special Reviews (carryover assignments from FY 2008)
19 Follow-up Reviews, Coordination, and Reporting
Regulatory and Policy Analysis and Review
20 Investigation Plan
22 Performance Measures and Targets
23 Appendix A- Limitations on Advisory Services
25 Appendix B - Oversight of Recovery Act Funds
The OIG Annual Plan is produced by the
OIG Office of Congressional, Public Affairs
and Management in conjunction with the
OIG Deputy Inspector General and Assistant
Inspectors General, with inputfi'om the EPA
Administrator, Deputy Administrator,
Assistant Administrators, and Regional
Administrators, as well as congressional
stakeholders and OMB.
This Plan is available in hard copy from the:
Office of Inspector General
US Environmental Protection Agency
MC 2491 T
1200 Pennsylvania Avenue, NW
Washington, DC 20460
by calling (202) 566-2391, or
via the Internet at: www.epa.gov/oig
To report fraud, waste, or abuse,
contact the OIG Hotline at:
OIG Hotline@epa.gov
or
1-888-546-8740
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EPA Office of Inspector General Annual Plan: Identifying the Risks
The Criteria for Developing and Selecting Assignments
The OIG reviewed the major risks, challenges, and planning priorities across EPA as well as those solicited from Agency Leadership to
obtain their first-hand input in helping us identify and select OIG products and topics that would be of greatest benefit to them and the
American public that they serve. This section summarizes and applies the key Agency-wide risks, issues, and management challenges,
as the basis for the types of work assignments requested, developed, and selected for this FY 2009 plan.
Top EPA Management Challenges - Reported by the OIG* (as required by the Consolidated Reports Act of2000)
Threat and Risk Assessments: The Agency does not comprehensively assess threats to human health and the environment across
media to ensure EPA's actions are planned, coordinated, designed, and budgeted to most efficiently and effectively address
environmental risks. The fragmentary nature of EPA's approach continues because environmental laws often focus on single media or
threats. As a result, Agency goals and units are designed to implement separate legislative mandates and available solutions to address
specific pollutant sources.
EPA's Organization and Infrastructure: EPA maintains 204 offices and laboratories in 144 locations with over 18,000 staff members.
With diminishing resources, the autonomous nature of regional and local offices, and the growing pressure to expand its role globally,
EPA will be challenged to assess the efficiency and effectiveness of its current structure to identify opportunities for consolidating and
reducing operating costs.
Performance Measurement: EPA must focus on the logic and design of its measures for success and efficiency, along with data
standards and consistent definitions, to ensure that accurate, timely, and meaningful information is used to evaluate and manage EPA
programs, operations, processes, and results.
Water and Wastewater Infrastructure: Drinking water and wastewater treatment systems are wearing out, and it will take huge
investments to replace, repair, and construct facilities.
Meeting Homeland Security Requirements: EPA needs to implement a strategy to effectively coordinate and address threats,
including developing a scenario to identify resource needs, internal and external coordination points, and responsible and accountable
entities.
Oversight of Delegations to States: Implementing EPA's programs, enforcement of laws and regulations, and reporting on program
performance has largely been delegated to States and tribes, with EPA retaining oversight responsibility. However, inconsistent capacity
and interpretation of responsibility among State, local, and tribal entities limit accountability for and compliance with environmental
programs and laws.
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Chesapeake Bay Program: After 20 years of effort by federal, State, and local governments, Bay waters remain degraded and required
nutrient and sediment reductions will not be met by the 2010 target. EPA needs to institute management controls ensuring that actions to
manage land development, agricultural runoff, nutrient reduction technology, and air emissions are implemented, and that consistent
sources of funding are identified by EPA partners.
Voluntary Programs - Update: EPA must ensure that applying voluntary approaches and innovative or alternative practices to provide
flexible, collaborative, and market-driven solutions for measurable results are managed using standards, consistent processes, and
verifiable data, to ensure that programs are efficiently and effectively providing intended and claimed environmental benefits.
OIG Identified - EPA Internal Control Risks and Deficiencies
Information Technology Systems Development and Implementation
Program Evaluation
Superfund Cost Recovery
Superfund Site Deletions
Efficient Use of Available Funds
Audit Follow-up
Tribal Environmental Capacity Building
Data Quality and Standards
Privacy Program
Workforce Planning
GAO Identified - EPA High-Risk Areas
Environmental Information
Human Capital Management
Chemical Regulation
Risk Assessment
Financial Management Practices
Management of Leaking Underground Storage Tanks
Enforcement and Compliance Activities
Strategies for Managing Watersheds
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EPA Identified Management Challenges, Risks, Priorities, Issues
The following information identifies cross-cutting risks that the OIG identified through outreach solicitations and
meetings with EPA Leadership.
1. Emergency Preparedness/Homeland Security
Preparedness for emergencies (natural or manmade disasters).
Protection of drinking water (Water Sentry program).
Waste management.
Data security and protection controls.
Clarification of roles and responsibilities (within EPA, between federal agencies and States).
2. Stove-Piped Organizational Planning
EPA operates by implementing original authorizing legislation of specific media - instead of holistically
30 federal agencies with an environmental mission need better coordination in planning and implementation.
Lack of direct lines of authority (coordination) among and between Assistant Administrators and Regions.
Plans, resources, data, authority, and measures are not aligned with risks and priorities across EPA.
Better collaboration internally and with stakeholders needed to align processes, leverage resources, implement controls, reduce duplication, and
align resources with priorities.
3. Data Quality & Systems/Security/Availability/Consistency of Reporting
Information drives the decision making process, but there are gaps and inconsistencies.
Questions exist as to whether EPA is collecting the right data, of sufficient quality, and making that data available.
EPA's information systems are not aligned for efficiency, consistency, accessibility, and security.
Control of laboratory data, personally identifiable information, and confidential business information outside of EPA, especially related to
registration and re-registration of pesticides and other formulas regulated by the Toxic Substances Control Act.
Agency programs need a consistent approach for determining relative risk and demonstrating outcome results.
4. Performance Measurement/Funding
Agency programs need a consistent approach for determining relative risk and demonstrating outcome results.
Need a clear linkage between goals, resources, processes, actions taken, and outcomes within EPA and by its partners.
No standards or agreement among stakeholders upon which to base measures of environmental risk and outcomes (States vs. national).
Program efficiency, progress, and results are not measured meaningfully.
EPA does not know what things cost and what efficiency measures are needed.
Who will pay for needed infrastructure investment?
How can EPA use creative financing and leverage funding through public-private partnerships?
What role can the OIG perform to help with Agency program assessments?
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5. Compliance/Enforcement - Federal/State/Tribal Responsibilities/Capacity
Differences exist in the ways environmental laws are monitored and enforced within EPA and between States/tribes.
Federal vs. State roles and economic compliance incentives vs. enforcement.
Monitoring requirements are under funded.
6. Grant Management/Monitoring/Grantee Capacity
Half of the Agency's budget is for assistance agreements to grantees - fund management and accountability is generally beyond EPA's control
once the funds are distributed.
Highest risk in the grants management process is at the point that funds are spent - by grantees - sometimes commingled with a variety of
other sources of grant funds.
Grantees have limited capacity or incentives to account for funds or performance.
EPA lacks resources to adequately monitor grants, and lack uniform reporting and accountability conditions.
EPA needs to execute and manage grants for measurable success with their intended goals.
7. Human Capital Management - Skill gaps/alignment with functions
EPA needs workforce analysis and to implement its Human Capital Strategy to identify and fill skill gaps.
Redirect recruitment approach and development to close identified competency gaps.
8. Financial Management/Contracting (accounting for cost of performance)
Agency needs to manage it resources and the performance of contractors to optimize their value added.
Operational controls are needed to protect and account for costs, assets, information, and performance.
EPA's FMFIA and OMB Circular A-123 process needs stronger implementation.
Working Capital Fund does not have the transparency or accountability to prove its efficiency.
Agency management needs a greater understanding of, and accountability for, taking agreed-to actions on OIG recommendations.
OIG recommendations need to be specific, and OIG should only accept specific, responsive, and measurable proposed Agency actions.
9. Policy and Regulation Setting, Review, and Implementation
The Agency's regulatory process is extremely complex and needs streamlining without reducing its required integrity.
There may be risks of overlap gaps and conflicts from competing interests of stakeholders and regulated community.
Many policies are out of date or based upon outdated science and technology.
10. Risk Measurement, Characterization, Innovation, and Communication
EPA needs to use a consistent approach to evaluate actual and relative environmental and operational risk and program effectiveness, assign
resource priorities, make regulatory decisions, take enforcement actions, and inform its stakeholders.
Ensure the integrity of laboratory data, results, and scientific research; and that the timely transfer of knowledge and innovative technology is
applied in the regulatory and policy process.
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EPA Office of Inspector General Annual Plan: The Strategy
Based on prior work, cross Agency risk assessment, Agency challenges, future priorities, and customer input, we have chosen the
following themes to develop and prioritize our FY 2009 work. These themes were chosen to address cross Agency weaknesses,
vulnerabilities, and opportunities for significant Agency improvement through opportunities for greater savings, efficiency, and risk
reduction.
Results measurement has been expanded to include all aspects of measurements under the category of Program Management and Data
Verification, including availability, quality, accuracy, validity, and management. This has been a major management challenge in EPA in
past years. Overhead and manpower assessment are interrelated as factors of efficiency as EPA needs to consider how many people and
fixed resources it needs to administer its programs. EPA needs to be better at recognizing and assessing its own program and operational
strengths and weaknesses through evaluations and internal control reviews. Each theme is briefly described below.
Risk and Customer-Driven Themes for Greater Performance and Efficiency
Agency Research
EPA spends a significant amount of resources on, and depends on the work of, the Office of Research and Development (ORD) to provide
the science and research that is the foundation of much of EPA's policy, regulations, and enforcement actions. The OIG has performed
little prior review of ORD's costs, performance, and data quality.
Follow-up
The OIG issues hundreds of recommendations for Agency improvement each year and the Agency self-certifies that agreed-to actions are
completed. Without verification and reporting of recommendations that remain outstanding, the OIG and Agency management cannot be
sure that appropriate actions have been taken to resolve problems or improve conditions.
Grants and Contracts
Half of the Agency's budget is dedicated to assistance agreements for States, tribes, universities, and nonprofit organizations. The highest
risk in the grants management process occurs at the point where the funds are spent, yet many grantees have limited capacity or incentives
to account for funds or performance. The Agency is highly dependent on contracts with about a fifth of its annual budget used to acquire
contract goods and services. With dwindling resources, the Agency must manage these funds and contractor performance to optimize
their value added.
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Homeland Security
Within challenges for national homeland security, EPA is responsible for, among other issues, protecting drinking water. As an
organization with a unique human resource pool and contractual resources to handle wastes of all kinds that result from natural or
manmade disasters, an expectation exists that the Agency is prepared to provide the expected support. However, such an expectation may
require more than the Agency can currently provide.
Internal Controls/Risk Assessment
Managing and ensuring the integrity of the Agency's resources is of critical importance. Because each office and region is responsible for
ensuring proper management, this delegation increases the chance of differential applications of internal controls over processes and assets.
The risk of resource waste or loss, environmental danger to the public, or failure to accomplish mission objectives due to a lack of controls
or fraud is increased as monitoring and accountability is diminished internally as well as by contractors and grantees.
Elements of Internal Control with Which to Assess Potential Program Impacts/Vulnerabilities/Risks
Planning: Without system-wide goal setting based upon consistent criteria, operations and efforts are fragmented and competing.
Organization: Without coordination and collaboration, the risk exists of duplication, conflicting forces, inconsistencies, and gaps
across organizational units.
Policies and procedures: Without effective policies or procedures, no basis exists for consistency, criteria, or control to guide
actions within or across EPA.
Performance measurement: Without clear and consistent measurement, priorities cannot be recognized, nor can progress or
accountability be assessed.
Monitoring: Without oversight, there is no way to identify and correct deviations from the plan.
Accountability: Without accountability, no commitment, obligation, recourse, or enforceability exists.
Manpower Assessment
The nature of the work being done by the Agency continues to evolve as more of the programs are delegated and have integrated
relationships. As the work changes and the roles of the Agency change in relation to its partners, laws, and goals, EPA needs to accurately
assess workforce allocation within its organizational structure to determine the correct number and location of staff and skills necessary.
Enforcement/Regulation Review
The Agency's regulatory process is extremely complex, and opportunities may exist to streamline the effort without reducing its required
integrity. Enforcement of environmental laws and regulation is often fragmented and inconsistent as it is carried out differently among the
various federal, State, tribal, and local government entities. Jurisdictional, interpretation, and coordination questions can undermine
program effectiveness.
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Oversight of American Recovery and Reinvestment Act Funds (added March 2009)
The American Recovery and Reinvestment Act of 2009, signed by President Obama on February 17, 2009, provides the EPA Office of
Inspector General $20 million for oversight activities available through September 30, 2012. The Office of Inspector General will conduct
audits, investigations, and other reviews to ensure economy and efficiency and to prevent and detect fraud, waste, and abuse in how EPA
uses the $7.2 billion it has received under the Act. See Appendix A, Page 25, for the general plan and assignment/activity areas.
Program Management/Data Verification
Agency programs need to be able to determine relative risk and demonstrate outcome results in terms of environmental conditions and
human health for the funds that are spent. This requires valid and reliable data linked to the resources applied, the processes used, and the
actions taken within EPA and by its federal, State, and grantee partners. This is a difficult challenge, as no standards or universal
agreements exist amongst the stakeholders upon which to base consistent measures of environmental risk and outcomes. Data are used
without independent verification of their accuracy, making them vulnerable to manipulation or misuse to influence decisions.
Project Management
EPA spends significant amounts of funds either directly or through its delegated programs on highly complex projects without adequately
applying tools of process planning and feedback to control costs and performance.
Spending Effectively/Financial/Overhead/Effective Resource Management
As budgets are reduced and environmental issues become more complex and costly, EPA will need to find ways of improving its
operational efficiency by reducing the cost of operations, eliminating unnecessary spending, collecting receivables, and leveraging
resources to apply a greater percentage of available funds to directly solving the greatest environmental problems.
Superfund
EPA needs to ensure safe and appropriate reuse and revitalization of brownfields, underground storage tank fields, Superfund sites,
Resource Conservation and Recovery Act sites, Base Realignment and Closure sites, and other federal properties through effective long-
term monitoring strategies, incentives and compliance and enforcement tools.
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Making Choices - A Customer-Driven Process
Audits, evaluations, inspections, and investigations are chosen by the OIG based on several criteria, in order of priority. The objective is to
develop a "portfolio" of OIG assignments that represents the best possible return on investment in monetary value and responsiveness in
addressing the needs, risks, challenges, priorities, and opportunities of OIG customers, clients, and stakeholders. To do this, we
1) conducted considerable research on environmental and management risks, challenges, and opportunities previously identified by EPA
leaders, staff, independent interest organizations, Congress, OMB, States, tribes, and earlier OIG work to develop a comprehensive,
indexed compendium of those items by topical area*; and 2) conducted direct outreach planning meetings individually with members of
EPA's headquarters and regional leadership to obtain their input and validate our research.
Criteria Considered in Identifying and Selecting Assignments
> Was it requested by senior leaders of the Agency or members of Congress?
> Is it within the mission of the OIG?
> Does it have Agency cost implications?
> Can it be done in a timely and cost effective way?
> Does it have environmental risk or improvement implications?
> Does it improve public confidence and accountability in administering Agency operations?
> Are adequate business control systems in place?
> Is it a program, operation, expense, or technology that has not been previously reviewed?
> Are there indications of environmental/business integrity risk?
> Are there prior audit or evaluation results upon which to follow up?
> Are there opportunities to leverage results with partners?
> What is the availability of OIG resources?
> What is the federal investment or regulatory authority?
> Is there an opportunity to improve process or cost efficiency?
*Full versions of the Compendium of Environmental and EPA Management Priorities, Risks, Challenges, and Opportunities Identified by EPA Leadership and
Stakeholders, OIG Risk Assessment, and Top Management Challenges are available from the OIG by contacting (202)-566-2617.
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The Plan: Continuing and New Assignments
EPA Office of Inspector General FY 2009 Annual Plan: Audit Plan
The Office of Audit: Office of Inspector General audit work focuses on four areas: assistance agreements and contracts; financial
audits, risk assessment and program performance, and forensic audits. Taken together, funds awarded for assistance agreements and
contracts account for approximately two-thirds of EPA's budget. Producing timely financial statements remains a priority across the
Federal Government. Equally important is the need to gather and use the financial and program performance information to improve
EPA's programs by reducing risks and maximizing results.
Planned work will emphasize:
direct testing for fraud in grants, contracts, and operational activities;
cost savings resulting from audits of grantee and contractor claims;
continued improvements in assistance agreement and contract administration;
EPA's preparation of timely, informative financial statements;
EPA's use of financial and program performance information, including efficiency measures, to identify cost savings, reduce risks,
and maximize results achieved from its environmental programs; and
review of EPA's risk assessment processes, and allocation/application of human resources.
Audits are conducted through four product lines. Specific assignment titles are listed on the following pages under each product line.
Assistance Agreements and Contracts
Forensic Audits
Financial Audits
Risk Assessment and Program Performance
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Assistance Agreements and Contracts
Is EPA using assistance agreements and contracts to efficiently and effectively accomplish its mission?
Is EPA effectively managing contracts to ensure services and products are received from qualified contractors at a reasonable price in a timely manner?
Contact: Janet Kasper (312
886-3059
OIG Themes Covered
Grants and Contracts
Spending Effectively
Internal Controls/Risk
Assessment
Follow-up
ARRA (see page 25)
Carryover Assignments from FY 2008
Desk review of the FY 2004 Single Audit for Worthington, WV
Independent government cost estimates for EPA contracts
Financial audits of grants to the National Tribal Environmental Council
Review of contractor invoices
State Revolving Fund reserves
Follow-up on the 2006 Audit of EPA's Critical Infrastructure and Key Resources Protection Plan
Hotline allegation involving property purchased under Homeland Security Presidential Directive 12
New Assignments Planned for FY 2009
Financial audits of EPA's assistance agreement recipients
EPA planning for acquisitions needed during national emergencies
Follow-up on Defense Contract Audit Agency reports
Unused Special Appropriation Project Act Funds
Single Audit Program
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Forensic Audits
Is EPA sufficiently protected against the risk of fraud, waste, and abuse in its grants, contacts, and internal operations?
Robert Adachi (415)947-4537
Contact:
OIG Themes Covered
Grants and Contracts
Internal Controls/
Risk Assessment
Superfund
Carryover Assignments from FY 2008
Alaska Native Tribal Health Consortium
SAAP grant awarded to Blackfoot, ID
SAAP grant awarded to Miami-Dade Water and Sewer Department
SAAP grant awarded to Wheeling, WV
Fraud, waste, and abuse at contractors
New Assignments Planned for FY 2009
Fraud, waste, and abuse at SAAP grantees
Fraud, waste, and abuse at not-for-profit grantees
Fraud, waste, and abuse at contractors
Controls over purchase card transactions
Superfund claims
Hotline complaints involving grantees and contractors
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Financial Audits
Does EPA have the people, processes, and systems needed to efficiently provide timely, accurate, complete, and useful financial information for
decision making, including resource management and accountability?
Paul Curtis (202) 566-2523
contact:
OIG Themes Covered
New Assignments Planned for FY 2009
Audits of:
Resource Management
Agreed-upon procedures - EPA's Quarterly FY 2009 Financial Statements
Follow-up
Unliquidated obligations in federal Special Accounts
Superfund
Unliquidated obligations in Superfund Cooperative Agreements (selected States)
Grants and Contracts
Billing and collection of fines and penalties
Internal Controls/
FY 2009 EPA financial statements
Risk Assessment
FY 2008 financial statements: Pesticides Reregistration and Expedited Processing Fund (FIFRA)
ARRA (see page 25)
US Chemical Safety and Hazard Investigation Board FY 2009 Financial Statements
Risk Assessment and Program Performance
Does EPA have the control systems in place to identify and prevent the misuse of resources, assess its human capital needs, and determine if its
program processes are efficient and goals are being achieved?
Patrick Gilbride (303) 312-6969
contact:
OIG Themes Covered
Manpower Assessment
Grants and Contracts
Internal Controls/
Risk Assessment
Program Management/
Data Verification
New Assignments Planned for FY 2009
Controls over EPA's manpower activities
2009 internal control weaknesses and management challenges
FMFIA review of ORD labs/centers/offices
Office of Research and Development internal controls 2009
Chemical Safety and Hazard Investigation Board - Action taken to address OIG and GAO recommendations
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Office of Mission Systems
With increasing visibility of data management, quality, and availability, information resource management has become an increasingly important area
of work for the Agency. Over the years, the OIG has reported management challenges in a number of key information resource management areas.
Information Collection and Quality: Do EPA's data collection methods ensure the appropriate type, quantity, and quality of data is collected for the
intended purpose?
Information Technology Investment Management: Has EPA implemented well-structured and effective processes to ensure investments in
information technology recourses achieve the desired result?
Information Security and Privacy: Are EPA's computer security and privacy programs comprehensive and actively implemented throughout the
Agency to balance risk and mission requirements?
Rudy Brevard (202) 566-0893
Contact;
OIG Themes Covered
Resource Management
Internal Controls
Follow-up
Grants and Contracts
Project Management
Manpower Assessment
Homeland Security
Enforcement
ARRA (see page 25)
Carryover Assignments from FY 2008
Data quality audit of Enforcement and Compliance History Online (ECHO) System (contracted)
Data quality audit of Integrated Contracts Management System (ICMS) (contracted)
Quality of self-reported data in EPA's Information Security Weakness and Remediation System
EPA's efforts to remediate identified information security weaknesses (follow-up)
Quality of data in EPA's Air Quality System (AQS) (contracted)
Quality of data in EPA's Resource Conservation and Recovery Act Information (RCRA Info) System (contracted)
New Assignments Planned for FY 2009
EPA's use of the Exchange Network for Environmental Information Reporting Phase II
Follow-up on EPA's use of the Exchange Network for Environmental Information Reporting Phase I
Audit of EPA's System Development Activities
FY 2009 FISMA Audit
IT audit support to the Fiscal 2009 Financial Statement Audit
US Chemical Safety and Hazard Investigation Board - FY 2009 FISMA Audit (contracted)
Review of Computer Technology Systems (CTS) project implementation
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EPA Office of Inspector General Annual Plan: Evaluations and Special Reviews Plan
Program Evaluations and Special Reviews Conducted by the Office of Program Evaluation
Program evaluations and special reviews assess and answer specific questions about how well a program is working. They are performed
at EPA OIG by a staff with diverse backgrounds, including accounting, economics, environmental management, and the sciences; and
comply with the rigorous Government Auditing Standards. They can assess: 1) strategic planning and process implementation to
determine if a program is designed and operating as intended, 2) the extent to which a program is achieving its outcome objectives,
3) the extent to which the program outcomes are affecting impacts, and 4) the benefits of program results compared to the costs. The
objective of OIG program evaluations is to examine root causes, effects, and opportunities leading to conclusions and recommendations
that influence systemic changes and promote improved delivery of the Agency's mission.
Evaluations for FY 2009
EPA is facing greater-then-ever challenges of delivering a vital program of environmental protection on issues that are more complex and
costly than ever at a time when federal program budgets are diminishing as a matter of competing demands and the economic
environment. For this reason, the OIG program evaluations will concentrate on reviewing the ways the program is using and controlling
its physical, fiscal, human, and informational resources. They will also review the way programs are structured to carry out the
regulatory process, and how EPA ensures the integrity of the data it uses to assess environmental performance, develop policies and
regulations, and make significant enforcement and management decisions. Program evaluations will specifically attempt to identify
ways that the Agency can best leverage its resources, reduce duplication and costly practices and processes, as well as improve the
integrity and value of program results.
Assignments concentrate on themes of Research, Enforcement, Homeland Security, Superfund, Data Verification, and Internal Controls,
reflecting our attention to the Agency's mission, operational, and systemic risks. The evaluation staff is flexible, producing effective
analyses in any assigned area. Evaluation topics and priorities in our FY 2009 Plan are driven by our assessment of organizational risk
input from EPA's leadership, the Congress, and stakeholders in relation to available resources. Program evaluations are conducted
through five product lines. Specific assignment titles are listed on the following pages under each product line.
Air and Research
Water and Enforcement
Land and Superfund
Cross Media
Special Reviews
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Air and Research
Research: Is EPA effectively and efficiently planning, managing, conducting, and overseeing research and its by-products to address the Agency's
current and future needs and safeguarding the public from hazardous risks?
Air Toxics: Is EPA obtaining sufficient data that are both valid and reliable to measure performance, guide decision-making, and assessing and
managing risks provide reasonable assurance of progress towards goals and provide adequate protection to the public?
Clean Air Partnerships: Are partnerships, voluntary programs, and other non-regulatory initiatives achieving clean air goals efficiently and
effectively?
RickBeusse (919) 541-5747
Contact:
OIG Themes Covered
Project Management
Data Verification
Internal Controls
Follow-up
Resource Management
Research & Development
(R&D)
Carryover Assignments from FY 2008
Independent evaluation of Continuous Emissions Monitoring System calibration
Evaluation of the use of remote sensing data to assess environmental contamination at selected Superfund sites
Assessment of EPA's Certification Program to Certify Radon Test
EPA peer review panels
New Assignments Planned for FY 2009
R&D - Assessment of ORD's Performance Management System for Achieving Selected Research Goals
R&D - EPA efforts to monitor, assess, and act on threats from the production, use, and disposal of nanomaterials
Air Toxics - EPA's progress in achieving urban air toxics strategy goals
Clean Air Partnerships - Use of emerging and voluntary emission reduction measures in SIPs
Clean Air Partnerships - Oversight of Clean Air Settlement Agreements
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Water and Enforcement
Protecting Water Quality: How well is EPA protecting water quality through core water programs?
Health of Aquatic Systems: How can EPA effectively protect and restore sustainable healthy aquatic communities and ensure waters that are
protective of human health?
Enforcement: How well is EPA carrying out its enforcement program in terms of accuracy and consistency?
DanEngelberg (202) 566-0830
Contact:
OIG Themes Covered
Resource Management
Data Verification
Project Management
Internal Controls
Enforcement, Regulation
Review
Carryover Assignment from FY 2008
EPA's role ensuring compliance with wetlands requirements
New Assignments Planned for FY 2009
High-priority violations
Nutrients: EPA's identification of violations under Section 404 of the Clean Water Act
Resource Conservation and Recovery Act corrective action universe
Gulf of Mexico hypoxia
Land and Superfund
Hazardous Waste Clean-up (Superfund): Is EPA ensuring that requirements are met and guidance is followed in conducting and overseeing
Superfund cleanups, recovering the government's costs to clean up Superfund sites, and ensure their long-term safety?
Carolyn Copper (202) 566-0829 All Assignments Cover Superfund Program Activity
Contact:
OIG Themes Covered
Follow-up
Superfund
Enforcement
Regulation Review
Internal Controls
Resource Management
New Assignments Planned for FY 2009
EPA efforts to address vapor intrusion at Superfund and Brownfield sites
Ensuring long-term safety at federal facility Superfund sites
Independent site sampling
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Cross Media
Partnership/Voluntary Programs: Are EPA voluntary programs effectively achieving their environmental goals?
Management and Performance: How does the program management and organizational structure of EPA's community-based initiatives impact
program outcomes?
Homeland Security: How effectively can EPA perform its mission during a pandemic?
Jeffrey Harris (202) 566-0831
Contact:
Carryover Assignments from FY 2008
Testing of Energy Star products
Evaluation of EPA's Continuity of Operations Plan
New Assignments Planned for FY 2009
Evaluation of U.S. Great Lakes areas of concern
Evaluation of EPA's process for detecting and preventing un-registered pesticides from re-entering the
U.S. food supply on imported foods
Evaluation of EPA procedures to review and oversee chemicals regulated under the Toxic Substances Control Act
Follow-up on the 2004 evaluation of the Office of Children's Health Protection
Hotline complaint: EPA's Antimicrobial Testing Program
Special Reviews
Special Reviews - Evaluation of Hotline Complaints
Contact: Eric Lewis (202) 566-2664
OIG Themes Covered
New Assignments Planned for FY 2009
Internal Controls
Hotline reviews
Resource Management
Congressional or management requests and inquiries
Enforcement, Regulation
Review
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OIG Themes Covered
Resource Management
Internal Controls
Research/Development
Project Management
Follow-up
Manpower Assessment
Data Verification
Homeland Security
Enforcement/Regulation
Review
ARRA (see page 25)
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Office of Congressional, Public Affairs and Management
The Office of Congressional, Public Affairs and Management (OCPM) serves as the bridge between the EPA OIG and Congress, the public,
and the media. Some staff provide liaison with Congress and the media, and editorial support to the OIG. OCPM receives complaints through
the OIG hotline and, if appropriate, the OIG conducts reviews and publishes reports of findings and recommendations. OCPM fulfills the
requirements of the Inspector General Act by coordinating the review of existing and proposed legislation, regulations, and policy. OCPM
also implements requirements of the Inspector General Act, OMB Circular A-50, and the Generally Accepted Government Auditing Standards
by coordinating and reviewing Agency performance in taking agreed-to corrective actions on OIG recommendations, and coordinates OIG's
internal FMFIA program. Additionally, OCPM coordinates OIG annual and strategic planning as well as human resources, budgeting,
financial management, controllership, and contracting functions.
Special Reviews: Congressional, public, and EPA concerns about all environmental goal areas and management issues
Special Reviews (New Special Review Assignments in FY 2009 will be performed by the Office of Program Evaluation)
Contact: Eric Lewis (202) 566-2664
OIG Themes Covered
~ Internal Controls
~ Superfund
~ Follow-up
~ Spending Effectively
~ Project Management
~ Enforcement, Regulation
Review
~ Manpower Assessment
~ Program Assessment Rating
Tool/Data Validation
~ Research and Development
Carryover Assignments from FY 2008
Perchlorate technical review
Review of applications of science in a sample EPA regulation
Review of Office of Administration and Resources Management Reorganization - information technology issues
Scientific uncertainty about perchlorate
Unaccredited colleges and universities
Office of Solid Waste and Emergency Response regional public liaison
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Follow-up Reviews, Coordination, and Reporting
To what degree is the Agency taking the agreed-to actions on OIG recommendations?
Michael Binder (202) 566-2617
Contact:
Regulatory and Policy Analysis and Review
How can the OIG promote economy, efficiency, and effectiveness through the review of existing and proposed legislation, regulations, and policies?
Gary Greening (202) 566-1504
Contact:
OIG Themes Covered
Internal Controls
Superfund
Follow-up
Spending Effectively
Enforcement, Regulation
Review
Manpower Assessment
Program Assessment Rating
Tool/Data Validation
Research/Development
Grants and Contracts
Homeland Security
ARRA (see page 25)
Carryover Assignment from FY 2008
OIG Followup Coordination and Semiannual Compendium Report on Unimplemented Actions on OIG Recommendations
New Assignments Planned for FY 2009
Policy coordination, external policy, exposure draft, regulation review
Revision of EPA Manual 2750
OIG Follow-up Coordination and Semiannual Compendium Report on Unimplemented Actions on
OIG Recommendations
Analysis of OIG close-out and Agency follow-up management processes
OIG Annual Performance Report
OIG Annual Internal FMFIA Report
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EPA Office of Inspector General Annual Plan: Investigation Plan
The Office of Investigations (OI). 01 primarily employs Special Agents, as well as computer specialists, chemists, and support staff.
01 maintains a presence in each of the EPA regions as well as at selected EPA laboratories, other facilities, and in Headquarters.
The majority of investigative work is reactive in nature. 01 receives hundreds of allegations of criminal activity and serious misconduct
in EPA programs and operations that may undermine the integrity of or confidence in programs and create imminent environmental risks.
In prioritizing our work, we evaluate the allegations to determine which investigations may have the greatest impact on Agency funds,
the integrity of EPA programs and operations, and produce the greatest deterrent effect. 01 assists EPA in meeting its strategic goals by
ensuring that the Agency's scarce resources are not pilfered by unscrupulous individuals or companies. 01 has identified the following
major areas on which to focus: financial fraud (contracts, assistance agreements), computer crimes, infrastructure/terrorist threat,
program integrity, and theft of intellectual or sensitive data.
Investigations:
OIG focuses on the prevention, detection, and investigation of fraud, waste, and abuse in programs and operations administered or financed by the
EPA. In this role, the OIG conducts criminal, civil, and administrative investigations into allegations of fraud and serious misconduct that could
create imminent environmental risks or undermine the integrity of EPA or the public's confidence in its key environmental work.
Stephen J. Nesbitt (202) 566-0819
Contact:
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OIG Themes Covered
Data Verification
Enforcement/Regulation
'In'ternal Controls
Grants and Contracts
Superfund
Homeland Security
Follow-up
ARRA funds (see page 25)
Investigations begun prior to FY 2009 and new investigations will examine:
Criminal activities in the awarding, performance, and payment of funds under EPA contracts, grants, and other assistance
agreements to individuals, companies, and organizations, with an emphasis on entities receiving ARRA funds.
Criminal activity or serious misconduct affecting EPA programs which could undermine or erode the public trust.
Contract laboratory fraud relating to water quality and Superfund data, and payments made by EPA for erroneous
environmental testing data and results that could undermine the bases for EPA decision-making, regulatory compliance, and
enforcement actions.
Intrusions into and attacks against EPA's network, as well as incidents of computer misuse and theft of intellectual property
or other sensitive data and release of or unauthorized access to sensitive or proprietary information.
Investigative support to EPA and new initiatives:
Continue providing key EPA officials and entities receiving ARRA funds training for increased awareness of contract and
grant fraud to identify funds at risk, and cyber threat issues and indicators to identify conditions at risk and vulnerabilities.
Form an Emergency Response Team (ERT) to respond to national or regional disasters. The ERT will proactively address
high-risk financial resources and provide generalized law enforcement support to critical EPA assets and activities. This
proactive approach will ensure a quick assessment of the possible threat that might impair EPA's ability to execute its critical
safety response mission.
Further enhance our knowledge, skills, and abilities to ferret out financial crimes targeting EPA financial resources.
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EPA Office of Inspector General Annual Plan: Performance Measures and Targets
The Government Performance and Results Act (GPRA) requires federal agencies to develop goal-based budgets supported by Annual
Performance Plans that link the organization's Mission and Strategic Goals to its Annual Performance Goals (APGs). The APGs,
presented as quantifiable targets, are supported by measures and indicators that represent the expected results in terms of outputs and
outcomes. Actual results, compared to targets, are reported through the Agency's annual Performance Accountability Report as a means of
informing OMB, Congress, and the public about what value they are receiving for funds invested and how well goals are being achieved.
This Annual Plan presents the means by which the OIG will convert its resources into results through required and priority assignments.
Since outcome results from OIG work are a reflection of measurable actions and impacts, there is typically a time lag between the
completion of OIG work and recognition of such results. Therefore, OIG results are recorded in the year recognized regardless of when the
work was performed. OIG targets and measures represent the promotion of economy, efficiency, and effectiveness; and prevention and
detection of fraud, waste, and abuse through both current-year outputs and long-term outcomes.
The FY 2009 President's Budget for the OIG is $52.5 million, including Superfund work and $0.3 million for work supporting the
Chemical Safety and Hazard Investigation Board. The following are the OIG Annual Performance Goals/Targets that this plan is designed
to achieve, pending final budget agreements.
Annual Performance Measures
Supporting Indicators
FY 09 Targets*
Environmental and Business Actions Taken for
Improved Performance and Reduction of Risk
from or influenced by OIG work
o Policy, process, practice, or control changes implemented
o Environmental or operational risks reduced or eliminated
o Critical congressional or public concerns resolved
o Certifications, verification, or analysis for decision or assurance
318
Environmental and Business
Recommendations or Risks Identified for
Corrective Action by OIG Work
o Recommendations or best practices identified for implementation
o Risks or new management challenges identified for action
o Critical congressional/public actions addressed or referred for action
903
Potential Monetary Return on Investment in
the OIG, as a Percentage of the OIG Budget
o Recommended questioned costs
o Recommended cost efficiencies and savings
o Fines, penalties, settlements, restitutions
*f§S/o8«ti₯ion)
Criminal, Civil, Administrative, and Fraud
Prevention Actions Taken from OIG Work
o Criminal convictions
o Indictments/Informations
o Civil judgments
o Administrative actions (staff actions and suspension or debarments)
80
*Fincil budget levels and targets are subject to change through congj'essional and Administration action.
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Appendix A - Limitations on Advisory Services
The OIG provides certain advisory services to the Agency as part of the value it adds in promoting economy, efficiency, and effectiveness.
However, to protect Inspector General independence, the Inspector General Act explicitly restricts the Inspector General from making or
deciding on Agency policies. The Generally Accepted Government Auditing Standards provide specific criteria limiting what Advisory
Services, defined as non-audit services, OIG staff can perform, and what constitutes a personal or organizational impairment of
independence in fact or appearance. Several of the limitations by the Standards are cited below and serve as an explanation of why the
OIG may not be able to assist the Agency in ways that may be requested.
Overarching Independence Principles When Performing Non-audit Services
The following two overarching principles apply to auditor independence when assessing the impact of performing a non-audit service for
audited entities:
audit organizations must not provide non-audit services that involve performing management functions or making management
decisions, and
audit organizations must not audit their own work or provide non-audit services in situations where the non-audit services are
significant/material to the subject matter of audits.
In considering whether audits performed by the audit organization can be significantly or materially affected by the non-audit service, audit
organizations should evaluate (1) ongoing audits; (2) planned audits; (3) requirements and commitments for providing audits, which
include laws, regulations, rules, contracts, and other agreements; and (4) policies placing responsibilities on the audit organization for
providing audit services. If requested to perform non-audit services that would impair the audit organization's ability to meet either or both
of the overarching independence principles for certain types of audit work, the audit organization should inform the requestor and the
audited entity that performing the non-audit service would impair the auditor's independence with regard to subsequent audit or attestation
engagements.
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Non-audit Services That Impair Independence
By their nature, certain non-audit services directly support the entity's operations and impair the audit organization's ability to meet either or
both of the overarching independence principles for certain types of audit work. Examples of the types of services under this category include
the following:
> Maintaining or preparing the audited entity's basic accounting records or maintaining or taking responsibility for basic financial or other
records that the audit organization will audit.
> Designing, developing, installing, or operating the entity's accounting system or other information system that is material or significant to
the subject matter of the audit.
> Recommending a single individual for a specific position that is key to the entity or program under audit, or otherwise ranking or
influencing management's selection of the candidate; or conducting an executive search or a recruiting program for the audited entity.
> Developing an entity's performance measurement system when that system is material or significant to the subject matter of the audit.
> Performing the entity's internal control self-assessment process or developing the internal control system.
> Developing an entity's policies, procedures, and internal controls.
> Providing services used as management's primary basis for making decisions that are significant to the subject matter under audit.
> Internal audit functions, when performed by external auditors.
> Serving as voting members of an entity's management committee or board of directors, making policy decisions that affect future direction
and operation of an entity's programs, supervising entity employees, developing programmatic policy, authorizing an entity's transactions,
or maintaining custody of an entity's assets.
> Planning, conducting, or reviewing audit work of the subject matter of the non-audit by the same person providing the non-audit services
under the overarching independence principle that auditors must not audit their own work.
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Appendix B - Oversight of Recovery Act Funds
OIG Objectives Regarding Recovery Act Oversight FY 2009 - 2012 (andpossibly beyond as needed)
The American Recovery and Reinvestment Act (Recovery Act) of 2009 provides the EPA OIG $20 million through September 30, 2012, for oversight
and review. The OIG will assess whether EPA is using the $7.2 billion of Recovery Act funds in accordance with its requirements and is meeting the
accountability objectives as defined by the Office of Management Budget. The objectives include whether:
Funds are awarded and distributed in a prompt, fair, and reasonable manner.
The recipients and uses of all funds are transparent to the public, and the public benefits of these funds are reported clearly, accurately, and in a
timely manner.
Funds are used for authorized purposes and instances of fraud, waste, error, and abuse are mitigated.
Projects funded under this Act avoid unnecessary delays and cost overruns.
Program goals are achieved, including specific program outcomes and improved results on broader economic indicators.
OIG Actions to Help the Agency Reduce Risk
As EPA prepares to award Recovery Act funds, the OIG is taking a number of actions to alert Agency managers of risks and recommend cost-effective
controls to help prevent fraud, waste, and abuse; and ensure program goals are achieved and stimulus funds are accurately tracked and reported. As our
auditors and evaluators identify risks, they will provide Agency managers with flash reports with recommendations for ways to mitigate these risks.
Our investigators are developing an outreach strategy to educate EPA employees, contractors, grant recipients, the law enforcement community, and the
general public of grant and contract fraud schemes and how to report suspected fraud. Our work is being closely coordinated with the Recovery
Accountability and Transparency Board, as well as other audit and law enforcement organizations at the federal, State, and local levels.
OIG Review Activities
After EPA awards the Recovery Act funds, the OIG will focus on auditing and investigating EPA's management of the Recovery Act programs, how
the funds are being used, and the accuracy of the information being reported. The OIG will continue to take proactive actions to prevent fraud, waste,
abuse, and mismanagement of funds. Listed below are some of the areas we plan to audit and investigate.
Performance Audit Objectives
Evaluate the process for awarding funds, particularly competitive awards.
Determine whether funds are being awarded and spent timely.
Determine whether the Agency has sufficient staff with the skills and knowledge needed to manage the grants and contracts awarded with
Recovery Act funds.
Evaluate how the Agency is monitoring the use of the funds.
Assess how performance is being measured and the process used for computing jobs saved and created.
Review the quality of data systems and information EPA uses for reporting the Recovery Act's requirements.
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Financial Audits
Conduct interim and final financial audits of Recovery Act fund recipients to determine whether:
Costs incurred met federal requirements;
Funds were used as intended; and
Funds were free of fraud, waste, abuse, and mismanagement.
Work with EPA to update the Single Audit Compliance Supplements for the Clean Water and Drinking Water State Revolving Funds.
Review Single Audit reports on Recovery Act funds and ensure that corrective action is taken.
As part of the annual audit of EPA's overall consolidated financial statements:
Assess internal controls over the financial reporting of Recovery Act funds;
Examine transactions to determine whether they are properly authorized, recorded, and reported;
Examine compliance with Recovery Act provisions that could have a material or direct effect on the financial statements; and
Assess the ability or effectiveness of capturing data for external reporting.
Investigations
Investigate allegations raised by the public and others of fraud, waste, and abuse committed against EPA involving Recovery Act funds.
Contact State recipients to facilitate ongoing communications regarding EPA Recovery Act funds distributed to local authorities.
Through the review of EPA and State audits and evaluations, identify fraud indicators, program weaknesses, and potential problems.
Gather information on potential instances of fraud being perpetrated with EPA Recovery Act funds from law enforcement officials, auditors,
contractors, suppliers, and vendors at the federal, State, and local levels.
New Assignments Planned for FY 2009
Audits and Evaluations
State selection process for State Revolving Fund (SRF)-funded projects.
Evaluation and use of contractor performance information.
Management of contract costs and schedule.
Responsibility determinations for Recovery Act interagency agreements.
Data quality review of Recovery Act reporting systems.
Oversight validation and quality assessment of EPA and grantee performance data, measures, and reporting.
Investigations and Advisory Services
Form Fraud Investigative Teams (FIT) with the Office of Program Evaluation to train EPA regional SRF staff, starting with the top 10 States
receiving Recovery Act SRFs.
Develop educational and outreach materials which identify known fraud indicators associated with contract and grant fraud.
Develop and implement an outreach program to EPA resources, and State and local recipients of Recovery Act funds.
Develop data collection methodologies to allow for determining activities to identify high-risk targets.
Provide advisory services on Agency and Government-wide risk assessment and performance measurement methodology.
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OIG Recovery Act Oversight Performance Measures and Reporting
OIG will continue using its standard GPRA measures to separately report the results of its work in providing Recovery Act oversight, as collected
through its internal databases. The OIG will also collect and report results based on specific measures described in the Recovery Act relating to
Whistleblower Reprisal complaints and allegations. Additionally, the OIG will report monthly on actual and planned activities through the Council of
Inspectors General on Integrity and Efficiency (CIGIE), and the Recovery Accountability and Transparency (RAT) Board.
Existing Annual Measures
Environmental/management improvement or risk reduction actions taken as a result of OIG work (policies, practices, controls
changed/implemented; risks reduced/eliminated; decisions made).
Environmental/management improvement recommendations or risks identified by OIG work (policies, practices, controls; risks challenges,
public concerns addressed awareness briefings).
Potential monetary return from questioned costs, cost efficiencies, fines, settlements, recoveries.
Criminal, civil, and administrative actions taken to prevent or detect fraud, and promote program integrity.
New Monthly Measures Reported through the CIGIE and the RAT Board
Whistleblower reprisal reviews initiated, closed, declined, and with extensions requested.
Major actions taken to date and planned (bulleted list).
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