OFFICE OF INSPECTOR GENERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
St
CUSTOMER SERVICE ~ INTEGRITY ~ ACCOUNTABILITY
FISCAL YEAR 2021
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* VISION
Be a premier oversight organization trusted to speak the truth, promote good governance,
and contribute to improved human health and environment.
* MISSION
Conduct independent audits, evaluations, and investigations; make evidence-based
recommendations to promote economy, efficiency, and effectiveness; and prevent and
detect fraud, waste, abuse, mismanagement, and misconduct for the
U.S. Environmental Protection Agency and the
U.S. Chemical Safety and Hazard Investigation Board.
Cover page: EPA OIG imagery
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INSPECTOR GENERAL
U.S. Environmental Protection Agency
March 26, 2021
I am pleased to present the U.S. Environmental Protection Agency's Office of
Inspector General Fiscal Year 2021 Oversight Plan. When determining which audits
and evaluations to include in our Oversight Plan, we independently considered the
top management and performance challenges facing the EPA and the U.S Chemical
Safety and Hazard Investigation Board; work conducted by the EPA, the CSB, and
the U.S. Government Accountability Office; and input from Congress.
Previously, we published an OIG Anmal Plan to guide our work each fiscal year.
This fiscal year, we present an Oversight Plan to categorize, by top management
challenge for the Agency, our planned and ongoing oversight projects. The plan, as
presented, guides us in fulfilling our critically important mission to detect and deter
waste, fraud, and abuse in EPA and CSB programs and operations; improve the
efficiency and effectiveness of the EPA and the CSB; help ensure ethical conduct
throughout the EPA and the CSB; and keep the EPA, the CSB, Congress, and the American people fully and
currently informed of problems and deficiencies.
In Report No. 20-N-0231. EPA's FYs 2020 2021 Top Management Challenges, we identify what we consider
to be the EPA's top eight challenges in accomplishing its mission for fiscal years 2020 through 2021:
1. Maintaining operations during pandemic and natural disaster responses.
2. Complying with key internal control requirements.
3. Overseeing states, territories, and tribes responsible for implementing EPA programs.
4. Improving workforce/workload analyses to accomplish the EPA's mission efficiently and effectively
5. Enhancing information technology security to combat cyberthreats.
6. Communicating risks to allow the public to make informed decisions about its health and the environment.
7. Fulfilling mandated reporting requirements.
8. Integrating and leading environmental justice across the Agency and government.
Though we have mandatory and discretionary assignments for the CSB, we focus on the EPA in this Oversight
Plan, as the majority of our resources are dedicated to oversight of the EPA. We do address our CSB oversight
projects in a separate section in this plan. It is also important to note that our plan is not static, and the projects
included herein may be modified throughout the year as new challenges and risks for the EPA emerge.
This Oversight Plan reflects the priority work that the OIG believes is necessary to keep the EPA, the CSB, and
Congress fully informed about problems and deficiencies relating to the administration of Agency programs and
operations. We look forward to meeting our goals and fulfilling our mission. For those interested in our planning
process, we welcome feedback on the quality and value of our products and services.
Sincerely,
S&A.
Sean W. O'Donnell
Sean W. O'Donnell
Inspector General
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Fiscal Year 2021 Oversight Plan
Introduction 1
Challenge 1: Maintaining Operations During Pandemic and Natural
Disaster Responses 4
PLANNED PROJECTS 4
ONGOING PROJECTS 5
Challenge 2: Complying with Key Internal Control Requirements 7
PLANNED PROJECTS 7
ONGOING PROJECTS 8
Challenge 3: Overseeing States, Territories, and Tribes Responsible for
Implementing EPA Programs 11
PLANNED PROJECTS 11
ONGOING PROJECTS 12
Challenge 4: Improving Workforce/Workload Analyses to Accomplish EPA's
Mission Efficiently and Effectively 14
ONGOING PROJECTS 14
Challenge 5: Enhancing Information Technology Security to Combat Cyberthreats 15
PLANNED PROJECTS 15
ONGOING PROJECTS 15
Challenge 6: Communicating Risks to Allow the Public to Make Informed Decisions
About Its Health and the Environment 16
ONGOING PROJECTS 16
Challenge 7: Fulfilling Mandated Reporting Requirements 17
PLANNED PROJECTS 17
ONGOING PROJECTS 18
Challenge 8: Integrating and Leading Environmental Justice Across the Agency
and Government 19
PLANNED PROJECTS 19
ONGOING PROJECTS 19
Overseeing High-Priority Unimplemented Recommendations 20
U.S. Chemical Safety and Hazard Investigation Board 21
PLANNED PROJECTS 22
FY 2021 Reports Issued as of the Date of This Publication 23
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Introduction
The U.S. Environmental Protection Agency's Office of Inspector General, established by the
Inspector General Act of 1978, as amended, 5 U.S.C. app., is an independent office of the EPA that
detects and prevents fraud, waste, and abuse to help the Agency protect human health and the
environment more efficiently and effectively. The EPA inspector general also serves as the
inspector general for the U.S. Chemical Safety and Hazard Investigation Board.
Our Fiscal Year 2021 Oversight Plan describes the oversight projects we intend to conduct this fiscal
year, as well as our ongoing and completed audits and evaluations as of March 2021. Our plan may
change as we remain nimble to identify additional discretionary projects, such as whether and how
the EPA is addressing emerging environmental threats to human health and the environment.
In FY 2020, the inspector general established an Engagement Board to improve the planning and
coordination of our oversight efforts and to increase communication and awareness of our audits
and evaluations. The Engagement Board ensures that we initiate high-value and relevant projects
and serves as a forum to discuss emerging topics and specific requests from Congress and other
stakeholders. Additionally, it fosters cross-disciplinary collaboration, allowing us to ensure that
each project we undertake helps address a top management challenge facing the EPA. In OIG Report
No. 20-N-0231. EPA's FYs 2020-2021 Top Management Challenges, we identify what we consider to
be the EPA's eight most significant challenges in accomplishing its mission:
1. Maintaining Operations During Pandemic and Natural Disaster Responses. The EPA
needs to maintain human health and environmental protections, business operations, and
employee safety during the coronavirus pandemic and future disasters.
2. Complying with Key Internal Control Requirements. The EPA faces the following
overarching challenges in implementing and operating internal controls that establish and
maintain an effective work environment:
o Developing internal control risk assessments.
o Ensuring quality data.
o Creating effective operational policies and procedures.
3. Overseeing States, Territories, and Tribes Responsible for Implementing EPA
Programs. The EPA faces a challenge in improving its oversight of and the results received
from state, territory, and tribal environmental programs.
4. Improving Workforce/Workload Analyses to Accomplish the EPA's Mission Efficiently
and Effectively. The EPA needs ongoing and comprehensive workload analyses to
adequately respond to and prepare for future staffing gaps and shortages in essential
positions. This includes staffing gaps related to determining the safety of chemicals. The
U.S. Government Accountability Office has identified workforce analysis as a
governmentwide concern in GAO-19-181. Key Talent Management Strategies for Agencies to
Better Meet Their Missions, issued March 2019.
Office of Inspector General FY 2021 Oversight Plan | I
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5. Enhancing Information Technology Security to Combat Cyberthreats. Without
enhanced information technology security, the EPA remains vulnerable to existing and
emerging cyberthreats. The Government Accountability Office has identified cybersecurity
as a governmentwide concern.
6. Communicating Risks to Allow the Public to Make Informed Decisions About Its
Health and the Environment. The EPA needs to provide individuals and communities with
sufficient information to make informed decisions to protect their health and the
environment.
7. Fulfilling Mandated Reporting Requirements. The EPA must meet its congressionally
mandated report requirements.
8. Integrating and Leading Environmental Justice Across the Agency and Government.
The EPA needs to enhance its consideration of environmental justice across programs and
regions and provide leadership in this area.
In OIG ReportNo. 20-N-0218. Fiscal Year 2020 U.S. Chemical Safety and Hazard Investigation Board
Management Challenges, issued July 6, 2020, we also identify what we consider to be the top three
management challenges for the CSB. We focus on the EPA in this Oversight Plan, but we detail the
CSB management challenges and our related oversight work in the "U.S. Chemical Safety and
Hazard Investigation Board" section of this plan.
In addition to considering the top management challenges when planning our EPA and CSB
oversight projects, we review and consider our own research and previous oversight work; key
strategic documents, such as the CSB and EPA strategic plans and the EPA's FY 2021 budget;
oversight work from other organizations, including the Government Accountability Office;
congressional hearings; legislation; feedback from members of Congress; and the Top Management
and Performance Challenges Facing Multiple Federal Agencies issued in February 2021 by the
Council of the Inspectors General on Integrity and Efficiency, or CIGIE. When considered
collectively, these resources help ensure that we undertake audits and evaluations to address the
EPA's and the CSB's most pressing challenges. For example, CIGIE's Top Management and
Performance Challenges report reflects the depth and breadth of the work across the federal OIG
community. This document helps the OIG community, the new administration, and other
stakeholders identify governmentwide challenges, including:
• Information technology security and management.
• Human capital management.
• Financial management
• Homeland security, disaster preparedness, and the coronavirus pandemic.
• Procurement management.
• Grant management.
• Performance management and accountability.
2 | Office of Inspector General FY 2021 Oversight Plan
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In similar fashion to CIGIE's report, our Oversight Plan organizes our projects by the top eight
management challenges we have identified for the EPA. Each chapter in this plan contains a brief
description of an identified challenge, followed by a list of the planned and ongoing oversight
projects for this fiscal year that directly align with that challenge. This is a living document,
however; as our oversight planning is an ongoing process, we routinely reassess it, adding new
projects and removing others when necessary.
In addition to the planned and ongoing oversight work outlined in this document, we conduct other
oversight activities that aim to improve EPA program efficiency and effectiveness; detect and deter
waste, fraud, and abuse; and ensure ethical conduct. These activities include statutory and
regulatory responsibilities for criminal investigations; the OIG Hotline; senior official misconduct
and whistleblower reprisal investigations; fraud awareness briefings; whistleblower reprisal
protection education; EPA policy development; and critical ancillary functions, such as
management, information technology, human resources, counsel, and chief of staff support. Due to
the nature of these activities, however, they are not identified in this document
Through this Oversight Plan, our Engagement Board, and our project processes, we aim to fully,
dynamically, and holistically plan our oversight projects. Planning the right audit and evaluation
projects at the right time is critically important to our effectiveness and the EPA's and CSB's
success. We must ensure that each project is relevant, meaningful, timely, and responsive to the
strategic environment in which the EPA and the CSB operate.
Office of Inspector General FY 2021 Oversight Plan | 3
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Challenge 1: Maintaining Operations
During Pandemic and Natural
Disaster Responses
The EPA must adapt to protect human health and
the environment amid both the coronavirus
pandemic—that is, the SARS-CoV-2 virus and
resultant COVID-19 disease—and natural disasters,
such as wildfires and hurricanes. The Agency's
responsibilities for implementing federal
environmental laws continue, even as its resources
and support capabilities shift to respond to these
overlapping events.
(Centers for Disease Control and Prevention image)
PLANNED PROJECTS ^
EPA Actions to Implement Safety and Health Measures Upon
Reopening of Facilities Following the Coronavirus Pandemic
Determine whether the Agency implemented measures to protect its employees' health and
safety upon returning to the workplace, in accordance with government policy from the
Centers for Disease Control and Prevention, the National Institute for Occupational Safety
and Health, and the Occupational Safety and Health Administration, among others.
Left to right: EPA office door. Employees gathered outside an EPA headquarters building entrance.
(EPA photos)
Follow-Up of Prior OIG Report on Improving Continuity
of Operations Planning
Determine whether (1) the EPA implemented recommendations issued in OIG Report
No. KKP-0017. EPA Needs to Improve Continuity of Operations Planning, dated
4 | Office of Inspector General FY 2021 Oversight Plan
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October 7, 2009; and (2) any additional improvements in continuity of operations planing
are needed based on the response to the coronavirus pandemic.
Impact ofEPA's Enforcement Discretionary Policy During the
Coronavirus Pandemic for the Clean Water Act Program
Determine whether the EPA implemented its Enforcement Discretion Policy in a clear and
consistent manner for the Clean Water Act program during the coronavirus pandemic,
specifically (1) what policies and procedures the EPA used to assess regulated entities'
claims that the coronavirus pandemic caused or contributed to given instances of
noncompliance, (2) how the EPA oversaw states' decision-making related to enforcement
discretion during the coronavirus pandemic, and (3) what impacted enforcement discretion
during the coronavirus pandemic.
Coronavirus Pandemic Impact on EPA's Ability to Conduct
Laboratory Testing and Assure Compliance with Mobile Source
Emissions Standards
Determine how the coronavirus pandemic has impacted (1) laboratory operations and
testing at the EPA's Office of Transportation and Air Quality's National Vehicle and Fuel
Emissions Laboratory in Ann Arbor, Michigan, and (2) Office of Transportation and Air
Quality compliance programs designed to minimize the potential for emissions in excess of
standards or for noncompliance with regulations in heavy-duty, light-duty, and nonroad
vehicles, engines, and equipment.
EPA's Controls Over Grantee Flexibilities Due to the
Coronavirus Pandemic
Determine the extent to which the EPA has implemented pandemic-related grant flexibilities
permitted by the Office of Management and Budget Specifically, determine the extent to which
the EPA has:
• Modified work plans, adjusted budgets, and extended periods of performance for grants
due to the coronavirus pandemic.
• Granted administrative relief or continued to compensate grant recipients whose work
was interrupted due to the coronavirus pandemic.
• Provided regulatory exceptions on a case-by-case basis.
ONGOING PROJECTS
Office of Inspector General FY 2021 Oversight Plan | 5
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Impact of the Coronavirus Pandemic on State and Local Compliance
Monitoring Services
Assess the impacts of the coronavirus pandemic on the number and type of compliance
monitoring activities taken by state and local agencies at facilities that are large emitters of
air pollution. Determine what guidance the EPA has provided to state and local agencies to
target or prioritize compliance monitoring activities at facilities. Determine how state and
local agencies are targeting or prioritizing compliance monitoring activities at facilities.
Impact of the Coronavirus Pandemic on Authorized State Resource
Conservation and Recovery Act Programs
Evaluate the readiness of authorized state Resource Conservation and Recovery Act
programs to continue operations during the pandemic.
Impact of the Coronavirus Pandemic on Long-Term Cleanups
Determine the impact of the coronavirus pandemic on long-term cleanups at Superfund
National Priority List sites, based on a survey of remedial project managers and interviews
with senior management from the Office of Land and Emergency Management and the
Office of Enforcement and Compliance Assurance.
6 | Office of Inspector General FY 2021 Oversight Plan
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Challenge 2: Complying with Key
Internal Control Requirements ^ internal
CONTROLS^
Effective internal controls are needed for the EPA to efficiently
implement the hundreds of programs, projects, and laws in place
to accomplish its mission and goals. Agencies are expected to
comply with the comptroller general's Standards for Internal Control in the Federal Government.
These standards establish five components that provide the overall framework for establishing and
maintaining an effective internal control system. The EPA's programs lack key elements in three out
of the five key internal controls: risk assessment,
control activities, and information and
communication. Without these key components,
the EPA risks falling short of achieving Agency and
program goals.
Source: Government Accountability Office.
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PLANNED PROJECTS ^
Renewable Identification Numbers for the Renewable Fuel
Standard Program
Determine whether EPA oversight provides reasonable assurance that the generation and
exchange of Renewable Identification Numbers comply with EPA regulations and guidance.
Resource Conservation and Recovery Act Inspections Follow-Up
Verify the status of corrective actions implemented in response to OIG recommendations in
Report No. 16-P-0104. EPA Has Not Met Statutory Requirements for Hazardous Waste
Treatment, Storage and Disposal Facility Inspections¦, but Inspection Rates Are High, issued
March 11, 2016. Confirm that the EPA implemented management controls to conduct the
required risk management inspections. If not all inspections are being conducted, evaluate
how the EPA considers environmental justice to determine which inspections to conduct.
Follow-Up on Need for Electronic Invoicing and Stronger Payment
Process Controls
Determine whether the (1) EPA implemented the corrective actions for the
recommendations included in Report No. 18-P-0231. Without E-Invoicing and Stronger
Payment Process Controls; EPA Is Placing $1.2 Billion at Risk Annually, issued August 16, 2018;
(2) corrective actions were effective in addressing the deficiencies identified in the prior
audit report; and (3) Agency's plans for electronic invoicing are on schedule or complete.
Office of Inspector General FY 2021 Oversight Plan | 7
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Land Use Controls at Resource Conservation and Recovery Act
Corrective Action Sites
Evaluate the EPA's internal controls over the long-term effectiveness of Resource
Conservation and Recoveiy Act corrective action sites in preventing human exposure and
groundwater contamination, including in environmental justice communities.
In accordance with the Single Audit Act and the Office of Management and Budget's Uniform
Guidance, nonfederal entities exceeding annual federal expenditure thresholds are required
to undergo what is referred to as a "single audit" each year. These audits are typically
performed by certified public accounting firms and state audit organizations. The OIG's
Single Audit Tearn reviews the reporting packages submitted to the Federal Audit
Clearinghouse by the nonfederal entity to assure the quality of the single audit, as well as to
inform the Agency of findings—such as internal controls weakness and deficiencies,
questioned costs, or compliance issues—for any necessary follow-up or management
action.
Follow-Up on Religious Compensatory Time
Determine whether the Agency's corrective actions addressed the findings identified in OIG
Report No. 16-P-0333. Enhanced Controls Needed to Prevent Further Abuse of Religious
Compensatory Time, issued September 27, 2016.
Follow-Up on Brownfields Revolving Loan Fund Program
Determine whether the EPA's corrective actions have effectively addressed reported
program deficiencies identified in OIG Report No. 17-P-0368. Improved Management of the
Brownfields Revolving Loan Fund Program Is Required to Maximize Cleanups, issued
August 23, 2017.
Office of the Chief Financial Officer's Oversight Monitoring and
Compliance with Agencywide Internal Control Requirements
Determine whether the Office of the Chief Financial Officer is conducting agencywide entity-
level risk assessments and implementing internal controls for annual and supplemental
appropriations that comply with federal and Agency requirements.
ONGOING PROJECTS
FY 2021 Single Audit Program
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Agency Use of Blanket Purchase Agreements
Determine whether (1) the Agency's use of blanket purchase agreements complies with
applicable laws, regulations, contract provisions, and other requirements; (2) the Agency is
maximizing use of current blanket purchase agreements to achieve savings; and (3) other
blanket purchase agreement opportunities exist
Status of Clean Air Act State Implementation Plan Submittals
and Approvals
Determine (1) the number of Clean Air Act state implementation plans awaiting EPA
approval, (2) factors causing delays in the approval of state implementation plans, (3) the
extent to which states have not submitted the required state implementation plans to the
EPA, (4) the potential impact of delays in state-implementation-plan processing on
achieving air quality standards, and (5) what steps the EPA is taking to address delays in
state-implementation-plan processing.
Use of Travel Cards
Evaluate the EPA's internal controls over travel cards, and determine the risk of illegal,
improper, or erroneous use of travel cards.
EPA's Implementation of Endocrine Disruption Screening Program
Determine the Office of Pesticide Program's progress in implementing the requirements of
the Food Quality Protection Act, specifically (1) Section 408(p)(3)(A) requirements to test
all active pesticides for endocrine disruption activity and (2) Section 408(p)(6)
requirements to take action—for example, conduct an endocrine disruption risk
assessment—if testing shows that the pesticide disrupts the human endocrine system.
EPA's Working Capital Fund Operations Expenditures
and Rate Establishment
Determine whether (1) the EPA's Working Capital Fund is operating efficiently by keeping
expenditures low; (2) the basis of rates established for various services is properly
supported; and (3) allocations of costs are reasonable, allowable, and proper.
Purchase Card and Convenience Check Audit
Determine whether the EPA has implemented corrective actions to reduce the potential for
illegal, improper, or erroneous use of purchase cards and convenience checks.
Office of Inspector General FY 2021 Oversight Plan | 9
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Reviewing and Updating Soil Sampling and Analysis Techniques in
EPA's Superfund Program
Determine how effectively the EPA's Superfund program is reviewing and updating soil
sampling and analysis techniques.
EPA Rules for Action Development Process Adherence
Determine whether specific rulemakings adhered to the EPA's Action Development Process,
and identify any causes for nonadherence and impacts of deviations.
EPA Improper Payments Reporting for FY2020
Determine the EPA's compliance with the Improper Payments Elimination and Recovery Act
of 2010, and evaluate the accuracy and completeness of the Agency's reporting.
EPA's Actions on the Long-Chain PerfluoroalkyI Carboxylate and
PerfluoroalkyI Sulfonate Chemical Substances Chemicals Significant
New Use Rule
Determine whether the EPA's actions in finalizing the Significant New Use Rule for the
subject chemicals were consistent with applicable requirements, including rulemaking
requirements pertaining to interagency review, publication, and record keeping.
Performance Measures for Eliminated EPA Programs Later Funded
by Congressional Appropriation
Determine the processes the Office of the Chief Financial Officer has in place to ensure that
EPA programs eliminated in the President's Budget but later funded by congressional
appropriation have the required performance measures.
10 | Office of Inspector General FY 2021 Oversight Plan
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Challenge 3: Overseeing
States, Territories, and
Tribes Responsible for
Implementing EPA Programs
States, territories, and
tribes have assumed
of the delegable
environmental
authorities under
. federal law. .
States, territories, and tribes are key partners in
executing the EPA's mission to protect human health
and the environment. The EPA authorizes states and certain other entities like territories and tribal
governments to implement many environmental laws—such as the Clean Air Act, Clean Water Act,
Safe Drinking Water Act, and the Resource Conservation and
Recovery Act—if they show that they have the capacity to
operate programs consistent with national standards. According
to the EPA, states have assumed more than 96 percent of the
delegable authorities under federal law. When the EPA delegates
authority for a program to a state, the Agency retains oversight
and enforcement responsibility to provide reasonable assurance
that states continue to protect human health and the
environment, as well as meet minimum federal standards.
EPA headquarters and regional staff perform a variety of formal
and informal oversight activities; however, there have been
disparities in the effectiveness of delegated programs.
Source: EPA OIG graphic.
PLANNED PROJECTS ^
Impact of EPA's Startup, Shutdown, and Malfunction
Exemption Actions
Determine the extent and impacts of startup, shutdown, and malfunction emissions, as well
as the EPA's actions regarding its startup, shutdown, and malfunction policy.
Efficiency and Effectiveness of the Great Lakes Restoration Initiative
Determine whether the EPA's Great Lakes National Program Office is (1) using Great Lakes
Restoration Initiative funds efficiently to accomplish its goals and (2) effectively protecting
and restoring the Great Lakes in the Great Lakes Restoration Initiative Action Plan's focus
areas.
EPA's Implementation of Safe Drinking Water Act Section 1431
Determine how the EPA has implemented its updated guidance and emergency authority
under Section 1431 of the Safe Drinking Water Act.
Office of Inspector General FY 2021 Oversight Plan | I I
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ONGOING PROJECTS flj
EPA's School Air Quality Programs
Determine how the EPA is measuring the success of its programs, such as the Clean Green
and Healthy Schools Initiative and School Air Toxics Initiative, to improve children's health
by addressing indoor and outdoor air quality in and around schools.
EPA's Preparedness for Providing Remote Access Services
Determine whether the EPA planned, developed, and implemented a long-term solution to
address remote access concerns when transitioning to the U.S. General Services
Administration's Enterprise Infrastructure Solutions Contract
National Pollutant Discharge Elimination System Permits
Determine whether the EPA followed appropriate Clean Water Act and National Pollutant
Discharge Elimination System regulations to review the PolyMet permit approved by
Minnesota and issued in 2018.
EPA Oversight of Synthetic Minor Sources
Determine whether the EPA and state and local agencies are providing sufficient oversight
to assure that synthetic minor sources of air emissions comply with the emission or
operational limits in their air permits.
EPA's National Enforcement Trends for 2006-2018
Identify the trends in enforcement results from FYs 2006 through 2018 for EPA-led
enforcement actions. Determine key factors explaining enforcement result trends over time,
as well as differences in enforcement result trends among EPA regions and environmental
statutes.
EPAs Process for Awarding and Overseeing Loans Made Under the
Water Infrastructure Finance and Innovation Act
Determine whether the EPA's loan award process and oversight and monitoring activities
comply with program requirements, as defined by the Water Infrastructure Finance and
Innovation Act statute, regulations, and EPA policy.
12 | Office of Inspector General FY 2021 Oversight Plan
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Follow-Up on Delayed Response
to Flint Water Crisis
Determine whether (1) the EPA implemented
agreed-to corrective actions in response to
recommendations in OIG Report No. 18-P-0221.
Management Weaknesses Delayed Response to
Flint Water Crisis, issued July 19, 2018; and
(2) those actions were effective in addressing
the prior findings.
Follow-Up on Cybersecurity Issues
Flint Water Plant tower in Flint, Michigan.
(EPA OIG photo)
Determine whether the EPA took corrective actions to effectively resolve the cybersecurity
issues identified in related OIG reports issued from FYs 2017 through 2020.
Office of Inspector General FY 2021 Oversight Plan | 13
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Challenge 4: Improving
Workforce/Workload Analyses
to Accomplish EPA's Mission
Efficiently and Effectively
According to the Government Accountability Office, workforce analysis is a governmentwide
concern. Workforce planning requirements are issued by the U.S. Office of Personnel Management
and defined in 5 C.F.R. Part 250, Subpart B, Strategic Human Capital Management, effective
April 11, 2017. Workforce planning affects the EPA's capability to achieve strategic goals and
objectives, but the EPA has not yet executed the required workforce analysis to ensure that it is
well-staffed to achieve its mission of protecting human health and the environment.
EPA's Response to Audits, Inspections, and Investigations Related to
Its National Enforcement Investigations Center
Determine whether the Office of Criminal Enforcement, Forensics, and Training and the
National Enforcement Investigations Center are addressing findings and implementing
corrective actions from audits, inspections, and documented concerns related to the
National Enforcement Investigations Center.
ONGOING PROJECTS
14 | Office of Inspector General FY 2021 Oversight Plan
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IDENTIFY
Challenge 5: Enhancing Information
Technology Security to Combat
Cyberthreats
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According to the Government Accountability Office, cybersecurity is a governmentwide concern.
The Federal Information Security Modernization Act of 2014 governs cybersecurity for federal
government information technology systems. Securing networks that connect to the internet is
increasingly more challenging with sophisticated attacks taking place that affect all interconnected
parties. To reduce these risks for EPA information systems, the EPA needs to be vigilant in
monitoring establishing, and developing ways to mitigate long-range emerging threats; however,
the EPA has not fully implemented information security. The EPA must achieve a strong baseline of
protection for its network and focus on how to manage evolving threats, increasing volumes of data,
and remote access technologies. The EPA's Office of Mission Support is primarily responsible for
information technology management.
EPA's Compliance with the Federal Information Security
Modernization Act for Fiscal Year 2021
Determine whether the EPA implemented an information security management program
that is compliant with the Federal Information Security Modernization Act of 2014.
EPA's Compliance with the Federal Information Security
Modernization Act for Fiscal Year 2020
Assess the EPA's compliance with the FY 2020 inspector general reporting instructions for
the Federal Information Security Modernization Act of 2014.
Follow-Up Audit on Prior OIG Cybersecurity Audit Recommendations
To determine whether EPA took corrective actions to effectively resolve the cyber
security issues identified in OIG reports issued from FYs 2017 through 2020.
PLANNED PROJECTS £$2
ONGOING PROJECTS
Office of Inspector General FY 2021 Oversight Plan | 15
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Challenge 6: Communicating
Risks to Allow the Public to
Make Informed Decisions
About Its Health and the
Environment
Risk communication is a vital component of the EPA's mission to protect public health and the
environment. Citizens count on the EPA for timely and accurate risk communication messages—
from risks of exposure to ethylene oxide, to unsafe drinking water in Flint, to working near
pesticides. When the EPA learns that people are at risk of exposure to harmful pollutants, it is
essential that the risks are communicated to
the public while they are being remediated.
The EPA's mission includes work to ensure
that all "parts of society—communities,
individuals, businesses, and state, local and
tribal governments—have access to accurate
information sufficient to effectively
participate in managing human health and
environmental risks." However, the EPA has
not established strategic goals or objectives
directly addressing risk communication,
ONGOING PROJECTS
EPA's Use of Clean Water Act and Safe Drinking Water Act
Authorities to Protect Against Harmful Algal Blooms
Determine whether the EPA is using its authorities under the Clean Water Act and the Safe
Drinking Water Act to protect human health and the environment from harmful algal blooms.
EPA's Compliance with Federal Requirements to Make Information
Accessible Through Its Public Websites and Digital Services
Determine whether the EPA's public websites and digital services comply with relevant
federal laws and policies, as outlined in Office of Management and Budget
Memorandum M-17-06, Policies for Federal Agency Public Websites and Digital Services.
Dicamba New Use Registrations
Determine whether EPA policies and procedures were effective in addressing stakeholder
risks in the EPA's Dicamba pesticide registration decisions in 2016 and 2018.
EPA-authorized sign warning the public of human health
dangers. (EPA photo)
16 | Office of Inspector General FY 2021 Oversight Plan
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Challenge 7: Fulfilling Mandated
Reporting Requirements
Complying with mandatory reporting requirements is essential to {o}
providing accountability and information about EPA programs to
Congress and the public. The EPA is responsible for submitting reports to Congress under several
environmental statutes. The EPA is also required to produce annual financial statements, which the
OIG is required to audit. However, the EPA has not issued multiple required congressional reports,
as evident in specific OIG recommendations to fulfill legal reporting requirements.
PLANNED PROJECTS ^
FY 2021 EPA Financial Statements
Determine whether (1) the EPA's consolidated financial statements were fairly stated in all
material respects, (2) the EPA's internal controls over financial reporting were in place, and
(3) EPA management complied with applicable laws and regulations.
FY 2020 Financial Statements: Hazardous Waste Electronic Manifest
System Fund
Determine whether (1) the financial statements were fairly presented in all material
respects, (2) the EPA's internal controls over financial reporting were in place, and (3) EPA
management complied with applicable laws and regulations.
FY 2020 Financial Statements: Toxic Substances Control Act Service
Fee Fund
Determine whether (1) the financial statements were fairly presented in all material
respects, (2) the EPA's internal controls over financial reporting were in place, and (3) EPA
management complied with applicable laws and regulations.
FY2020 Financial Statements: Pesticides Registration Fund
Render an opinion on the Agency's Pesticides Registration Fund financial statements and
determine (1) compliance with laws and regulations, (2) effectiveness of internal controls,
and (3) accuracy of reported performance information.
Office of Inspector General FY 2021 Oversight Plan | 17
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ONGOING PROJECTS fMJ
FY2021 EPA's Reporting in Accordance with the DATA Act
Assess the completeness, timeliness, quality, and accuracy of FY 2021 data submitted for
publication on USASpending.gov by the Office of the Chief Financial Officer. Assess the EPA's
implementation and use of the governmentwide financial data standards established by the
Office of Management and Budget and the U.S. Treasury.
FY 2019 Financial Statements: Toxic Substances Control Act Service
Fee Fund
Determine whether (1) the financial statements were fairly stated in all material respects,
(2) the EPA's internal controls over financial reporting were in place, and (3) EPA
management complied with laws and regulations.
18 | Office of Inspector General FY 2021 Oversight Plan
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Challenge 8: Integrating and Leading
Environmental Justice Across the Agency
and Government
Across the country, low-income communities and communities predominantly comprising people
of color are often adjacent to heavily polluted industries or "hot spots" of chemical pollution. As
such, these "environmental justice communities" bear a disproportionate burden of environmental
hazards. In 1994, President Bill Clinton signed Executive Order 12898, which requires federal
agencies to "make achieving environmental justice part of its mission by identifying and addressing,
as appropriate, disproportionately high and adverse human health or environmental effects of its
programs, policies, and activities on minority populations and low-income populations." The order
requires that environmental justice be considered but does not necessarily require a change in an
EPA decision if, for example, an environmental justice community faces new or continued exposure
to pollutants or cumulative exposure to several pollutants.
PLANNED PROJECTS So
Benzene Fenceline Monitoring
Determine whether the EPA's oversight of the benzene fenceline monitoring program is
sufficient to assure that refineries take corrective actions and lower benzene levels, as
required, when measured concentrations exceed the action level.
ONGOING PROJECTS
Residual Risk and Technology Review
Determine whether the EPA's residual risk and technology review process has sufficiently
identified and addressed any elevated cancer risks from air toxics emitted by facilities.
Congressional Request: Use of EPA Data to Prevent Disproportionate
Burden of Exposure
Determine how the EPA's Superfund and Resource Conservation and Recovery Act programs
are using EPA data to prevent disproportionate burden of exposure to any community.
EPA's Oversight of Tribal Drinking Water Systems
Determine to what extent the EPA has implemented compliance assistance and
enforcement activities to help public water systems in Indian Country provide safe drinking
water to customers.
Office of Inspector General FY 2021 Oversight Plan | 19
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Overseeing High-Priority Unimplemented
Recommendations
The OIG develops and maintains a compendium of recommendations with corrective actions
pending by the Agency. Overall, the Agency has implemented approximately 40 percent of all
recommendations the OIG has issued to date, while 60 percent remain unimplemented. In FY 2021,
the OIG developed a mini-compendium, included below, of high-priority recommendations which, if
they remain with corrective actions pending, would either leave the Agency highly vulnerable
financially or have a significantly negative impact on one of its programs.
Date
Report No.
Report Title
5/16/19
19-P-0155
Actions Needed to Strengthen Controls over the EPA Administrator's and Associated Staffs
Travel
10/29/19
20-P-0012
Tribal Pesticide Enforcement Comes Close to Achieving EPA Goals, but "Circuit Rider" Inspector
Guidance Needed
1/3/20
20-P-0066
EPA Can Improve Incident Readiness with Better Management of Homeland Security and
Emergency Response Equipment
3/31/20
20-N-0128
Management Alert - Prompt Action Needed to Infonn Residents Living Near Ethylene Oxide-
Emitting Facilities About Health Concerns and Actions to Address Those Concerns
9/28/20
20-E-0333
Improved EPA Oversight of Funding Recipients' Title VI Programs Could Prevent
Discrimination
20 | Office of Inspector General FY 2021 Oversight Plan
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U.S. Chemical Safety and Hazard
Investigation Board
The CSB's mission is to drive chemical safety change
through independent investigations to protect people
and the environment. The CSB investigates industrial
chemical accidents at facilities, reports on the root
causes to the public, and recommends measures to
prevent future occurrences. In FY 2004, Congress
designated the EPA inspector general to serve as the
inspector general for the CSB.
In OIG Report No. 20-N-0218. Fiscal Year 2020
U.S. Chemical Safety and Hazard Investigation Board
Management Challenges, issued July 6, 2020, we identify what we consider to be the top three
management challenges for the CSB:
• Accomplishment of CSB Mission Is Impaired Until New
Board Members Are Selected. As of March 2020, the CSB
chair was the only board member in an organization
designed for five members. Members typically share the
workload and deploy to accident sites to lead
investigations. The chair also manages the organization.
• CSB Has Not Developed Policy on Board Member
Responsibilities. The CSB needs to define board member
responsibilities to ensure that members do not engage in
inappropriate activities, such as the premature disclosure
of report findings.
• CSB Must Continue Operations During the
Coronavirus Pandemic. The CSB workforce is hampered by the coronavirus pandemic, but
it has a mission to respond to chemical accidents to discover their root cause.
OIG Notes on CSB Management Challenges and Engagement Planning
With respect to the first two challenges, which reference the impact of vacant board seats and lack
of Board policy governing board member responsibilities, the OIG has no ongoing or mandatory
oversight engagements. The CSB's board members are appointed by the president and confirmed
by the U.S. Senate, and the CSB has agreed to "finalize board member roles and responsibilities in an
official policy," per page 7 of OIG Report No. 20-N-0218. Similarly, the OIG has no ongoing or
mandatoiy oversight engagements for the CSB's third management challenge regarding operations
during the coronavirus pandemic. We anticipate that all three challenges may or could be resolved
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Office of Inspector General FY 2021 Oversight Plan | 21
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without inspector general intervention during FY 2021. We will continue to monitor the impacts of
these challenges through our regular oversight duties, and we will initiate engagements, if deemed
necessary.
PLANNED PROJECTS
CSB Compliance with the Federal Information Security
Modernization Act for FY2021 (Contracted)
Determine whether the CSB implemented an information security management program
that is compliant with the Federal Information Security Modernization Act of 2014.
CSB Financial Statements for FY2021 (Contracted)
Determine whether (1) CSB financial statements were fairly stated in all material respects,
(2) internal controls over financial reporting were in place, and (3) CSB management
complied with applicable laws and regulations.
CSB Purchase Card Risk Assessment for FY2021
Perform a risk assessment of CSB purchase card usage, as required by the Government
Charge Card Abuse Prevention Act of 2012.
CSB Reporting in Accordance with the DATA Act for FY2021
Assess the (1) completeness, timeliness, quality, and accuracy of FY 2021 data submitted for
publication on USASpending.gov and (2) CSB's implementation and use of the
governmentwide financial data standards established by the Office of Management and
Budget and the U.S. Treasury.
22 | Office of Inspector General FY 2021 Oversight Plan
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FY 2021 Reports Issued as of the
Date of This Publication
Date Issued
Report No.
Report Title
3/10/21
21-P-0094
EPA Improperly Awarded and Managed Information Technology Contracts
2/8/21
21-P-0070
EPA Mostly Adheres to Regulations When Assessing Risks of New Pesticides but Should Improve
Internal Controls
1/6/21
21-N-0052
Office of Research and Development Initiatives to Address Threats and Risks to Public Health and the
Environment fi'om Plastic Pollution Within the Waters of the United States
1/5/21
21-F-0045
EPA's Fiscal Years 2019 and 2018 Hazardous Waste Electronic Manifest System Fund Financial
Statements
2/23/21
21-E-0084
U.S. Chemical Safety and Hazard Investigation Board's Compliance in Fiscal Year 2020 with Improper
Payments Legislation and Guidance
2/10/21
21-E-0072
EPA Is at Risk of Not Achieving Special Local Needs Program Goals for Pesticides
2/9/21
21-E-0071
CSB's Information Security Program Is Not Consistently Implemented; Improvements Are Needed to
Address Four Weaknesses
12/29/20
21-E-0044
Evaluation of EPA's Compliance with the Executive Order 13950 on Combating Race and Sex
Stereotyping
12/29/20
21-E-0043
Evaluation of CSB's Compliance with Executive Order 13950 on Combating Race and Sex Stereotyping
12/28/20
21-P-0042
EPA Needs to Substantially Improve Oversight of Its Militaiy Leave Processes to Prevent Improper
Payments
12/7/20
21-E-0033
EPA Needs to Improve Its Planning and Management of Laboratoiy Consolidation Efforts
12/3/20
21-P-0032
Region 2's Hunicanes Irma and Maria Response Efforts in Puerto Rico and U.S. Virgin Islands Show
the Need for Improved Planning, Communications, and Assistance for Small Blinking Water Systems
12/1/20
21-E-0031
EPA Needs to Improve Oversight of Invoice Reviews and Contractor Performance Evaluation
11/30/20
21-E-0030
EPA's Initial Plans for Returning to the Office Incorporate CDC Guidance but Differ by Location
11/18/20
21-E-0016
CSB Discontinued Information Recoveiy Testing and Off-Site Backup Storage During the Coronavinis
Pandemic
11/16/20
21-F-0015
Audit of the U.S. Chemical Safety and Hazard Investigation Board's Fiscal Years 2020 and 2019
Financial Statements
11/16/20
21-F-0014
EPA's Fiscal Years2020 and2019 (Restated] Consolidated Financial Statements
November 2020
EPA-350-R-20-002
Semiannual Report to Congress: April 1,2020 to September 30,2020
Office of Inspector General FY 2021 Oversight Plan | 23
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WHISTLE
Whistleblower Protection
U.S. Environmental Protection Agency
The Whistleblower Protection Coordinator's role is to educate Agency employees about
prohibitions on retaliation and employees' rights and remedies in cases of reprisal, For more
information, please visit the Whistleblower Protection Coordinator's webpaae.
For more information about EPA OIG reports or activities,
please contact us:
Congressional Liaison: 202.566.2391
|j] Media Contact: 202.566.2391
[line) EPA OIG Hotline: OIG_Hotline@epa.gov
-emr) Web: epa.gov/oig
Follow us:
Twitter: @epaoig
Linkedln: linkedin.com/company/epa-oig
YouTube: voutube.com/epaoig
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CUSTOMER SERVICE * INTEGRITY * ACCOUNTABILITY
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