4% \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I * WASHINGTON, D.C. 20460
^ PRO^fc
OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE
may - 9 2019
NOW THE
OFFICE OF LAND AND
EMERGENCY MANAGEMENT
OLEM Directive #9275.1-38
MEMORANDUM
SUBJECT: Superfund Special Accounts Management Strategy for 2019 - 2021
FROM: James E. Woolford, Director .
Office of Superfund Remediation and Technology Innovation
Office of Land and Emergency Management
TO: Superfund National Program Managers, Regions 1-10
Assistant Regional Administrators, Regions 1-10
Regional Counsels, Regions 1-10
On behalf of the U.S. Environmental Protection Agency's Special Accounts Senior Management
Committee, this updated Superfund Special Accounts Management Strategy ("Strategy") sets
forth EPA's plan for ensuring that special accounts are successfully used nationwide to support
cleanup at contaminated sites being addressed under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA). The goal of the Strategy is to continually
improve the use, management and monitoring of special accounts. This Strategy serv es as a
roadmap for EPA Regional and Headquarters personnel who are responsible for the oversight
and management of special accounts. EPA has updated a workplan to undertake the activities
outlined in this Strategy (see Attachment 1) and will evaluate and revise the Strategy after three
years.
Through the development and implementation of this Strategy, EPA intends to achieve the
following objectives:
¦ Continue to implement a nationally consistent approach to managing and monitoring
special accounts;
¦ Maximize the use of special accounts to support site cleanups;
¦ Ensure the proper tools are available to maximize the use of special account funds;
and,
¦ Improve coordination and transparency on the use of special accounts.
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The Superfund Special Accounts Senior Management Committee ("Committee") serves as the
oversight body for the Agency's management and use of special accounts.1 The Committee,
comprised of senior managers from the Office of Superfund Remediation and Technology
Innovation (OSRTI), Office of Site Remediation Enforcement (OSRE), Office of the Chief
Financial Officer (OCFO), and lead Regions for both Superfund and Management, oversees the
implementation of this Strategy.
I. Background and Purpose
Special accounts are site-specific, interest bearing sub-accounts within the Superfund Trust Fund
established through settlements and used to fund site-specific work. The Agency's goal for the
establishment and use of special accounts is to provide cleanup dollars collected under
agreements with parties for sites where future response work remains. Use of special account
resources helps to achieve cleanup without relying solely on EPA's annual Superfund
appropriations, thus preserving annually appropriated resources for sites without viable parties.
Special accounts have been established and used in the Superfund program for over two decades.
To date, EPA has collected more than $7.0 billion in settlement funds, earned over $548 million
in interest, and used more than $4.2 billion for the cleanup of hundreds of Superfund sites.2
While some special accounts have a large balance available, the vast majority (73%) of open
special accounts have less than $1 million available.3
The Agency has been successful at collecting settlement funds to be placed in special accounts
and directing these funds towards future response actions. Through its enforcement efforts
negotiating settlements for past costs and future response costs, the Agency continues to receive
site-specific settlement funds that are placed in special accounts each year, so the extent of
progress on actual obligation and disbursement of funds may not be apparent upon review solely
of the cumulative available balance. Annual obligations and expenditures from current special
account balances are offset by new deposits for future response work.
The Agency's success in collecting funds from parties for future response work and placing
those funds in special accounts has called for a greater focus on managing and using those funds.
Through implementation of this Strategy, the Agency can manage special accounts to ensure
that:
1) Available special account funds that are needed for future site cleanup work are being
used as expeditiously as possible;
2) Special account funds, rather than annually appropriated resources, are used for
response work as appropriate;
3) Special account funds are reclassified or transferred to the general portion of the
Superfund Trust Fund when they are no longer needed for future cleanup work at a
particular site;
1 More information on the Superfund Special Accounts Senior Management Committee can be found at:
https://www.epa.gov/enforcement/superfund-special-accounts.
2 As of October 1, 2018, 1,424 special accounts have been established for 1,117 sites. The $4.2 billion used for
cleanup includes $3.77 billion disbursed and $456.9M obligated but not yet disbursed for cleanup work.
3 Based on data from Compass Business Objects Reporting as of October 1, 2018.
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4) Special accounts are closed when funds are no longer required for work at the site and
no future deposits are expected; and,
5) Data continue to be collected to allow for the effective monitoring of planned and
actual uses for special account funds.
II. Special Accounts Management Strategy
The establishment, planning, and use of special accounts requires extensive coordination among
the Regions and Headquarters. EPA has implemented many management practices to help ensure
that the funds in special accounts are managed effectively to support cleanup at Superfund sites.
To improve upon these practices, EPA's management strategy focuses on four main areas: 1)
Coordination and Transparency; 2) Planning and Use of Special Accounts; 3) Monitoring Special
Accounts; and 4) Regional Support, Guidance and Training.
1. Coordination and Transparency
Intra-agency Coordination
EPA has focused attention on improving coordination among the offices responsible for
managing special accounts: the three Headquarters offices (OSRTI, OSRE, and OCFO) and the
Regions (Regional program, counsel, and finance offices). These EPA offices have collaborated
closely on improvements to data systems, oversight and tracking, financial management
procedures, and responding to inquiries from external parties. These offices have further
reinforced management initiatives through activities such as training events, regular meetings,
and monthly conference calls.
OSRTI, OSRE, and OCFO Office Directors, along with the appropriate Division Directors for
the Lead Region for Superfund and the Lead Region for Management, participate on the
Committee. The Committee meets at least semi-annually to discuss the current status of the
program and elevates issues, as appropriate, to the appropriate senior level official(s) at the
Assistant Administrator level or above for resolution. OSRTI, as the Chair of the Committee,
convenes and organizes the meetings.
OSRTI, OSRE, OCFO, and Regions will continue the following activities to coordinate special
account activities:
• Attend and participate in Superfund's semi-annual Superfund Division Director meetings,
Regional Counsel Branch Chief meetings, and other national meetings.
• Attend and participate in regular intra-agency meetings, such as at OSRE/OSRTI bi-
weekly meetings.
• Attend and participate in semi-annual Committee meetings.
• Continue to hold monthly conference calls, as necessary, to discuss and coordinate
special account activities and issues among the offices as they arise.
• Participate on national quarterly conference calls with Regional program, counsel,
enforcement, and financial staff to discuss special account activities and issues.
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Responding to External Inquiries
EPA receives inquiries about special accounts from a host of entities, including the Office of
Inspector General (OIG), the Office of Management and Budget (OMB), the Government
Accountability Office (GAO), Congress, the public, and the media. EPA's goal in responding to
these inquiries is to be timely, informative, and accurately answer the questions posed.
OSRTI will coordinate responses to broad special account related inquiries from external parties,
such as GAO, OIG, and the media, as appropriate. OCFO will continue to be the lead office to
coordinate responses to inquiries from OMB, the Congressional Budget Office (CBO),
Congressional appropriations committees, or other external entities as appropriate.
EPA will continue its practice of responding to requests in a timely and efficient manner and will
coordinate responses across offices. We recognize that external parties can provide insights into
needed changes that improve the program. Each request will be thoroughly reviewed and
responded to as warranted. If action is required, the relevant EPA office(s) will implement the
action as appropriate.
Making Special Account Information Available to the Public
Publicly reporting information on special accounts allows external parties to understand the
importance and benefits of special accounts to the Superfund program and promotes
understanding of how these funds are spent. EPA will continue to report special accounts
financial and planning information in the annual Performance Plan and Congressional
Justification that is submitted to Congress. This information is reported publicly on EPA's
internet to provide more transparency about EPA's use of special accounts without undermining
enforcement efforts at particular Superfund sites.
OSRTI and OSRE will update the special accounts internet page at least annually with
cumulative special account data, such as amounts collected, used, and available in all special
accounts.4 Fact sheets on EPA's special accounts program have been developed to assist the
public in understanding what special accounts are and how they may be used. OSRE will
maintain the special accounts internet page, in coordination with OSRTI, and staff in OSRTI,
OSRE, and the OCFO offices will routinely review and update the information available. The
Committee will continue to explore options for placing additional, pertinent information on the
EPA's internet sites.
Cumulative special account information is reported on the monthly Superfund Trust Fund
financial statements by the Department of Treasury.5 OCFO will monitor these reports monthly,
and work with the Bureau of Fiscal Services to fix any discrepancies.
4 Special Accounts Internet content is available at http://www.epa.gov/enforcement/superfund-special-accounts.
5 Department of Treasury's Trust Funds Program Monthly Reports for the Hazardous Substance Superfund are
available at http://www.treasurvdirect.gov/govt/reports/tfmp/hazfund/hazfund.htm. Reporting of the receipt account
began with the September 2015 monthly report.
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OSRTI has developed a document that provides the key data points often used in
communications specifically for special accounts. The goal of this document is to ensure
consistent messaging across the Agency when discussing special accounts. The document also
identifies the success and benefits of using special accounts. OSRTI will annually update this
document with end of fiscal year data.
Availability of Information on the Intranet
The intranet serves as an important resource for Agency staff working on special accounts.6
OSRE and some Regional offices currently maintain intranet pages specific to special accounts.
OSRE has coordinated the Agency's special account content on the intranet, and the pages
include communication tools and tools for practitioners, such as sample memos for Regions to
use when notifying Headquarters of planned special account actions. Also housed on the OSRE
special accounts intranet page is an annotated bibliography of special account guidance and
frequently asked questions specific for special accounts. These interactive tools provide specific
information on special accounts topics with links to relevant guidance, models, and memos.
2. Planning and Use of Special Accounts
By developing and monitoring plans for using available special account funds, OSRTI, OSRE,
and the Regions will be able to analyze the use of special accounts and ensure special account
funds are considered as site response actions are planned. Through these efforts, the Agency will
be able to better plan and use special account resources on a site level, as well as identify trends
at the Regional and national levels.
Special Account Utilization
The use of special account funds enables the Superfund program to increase its capacity to
conduct response work at more sites than if it had to rely solely on annually appropriated funds.
While special account funds provide a readily available resource for EPA to conduct site
response work, it may take years for response work to be initiated and completed at some
Superfund sites with special account funds available due to other extenuating circumstances,
including the specific requirements for fund use set forth in the settlement agreement, the stage
of site cleanup, the viability of other responsible parties to conduct site cleanup, and the nature of
the site contamination, among other things.
Special account resources should generally be used before annually appropriated resources for
site response activities. On an annual basis, OSRTI will work with Regional offices to review
recent expenditures of annually appropriated funds for sites with open special accounts to
evaluate if special account funds could be used for those response costs rather than appropriated
funds.
As part of efforts to make special account funds available earlier in the fiscal year for obligation
and disbursement, OCFO's Office of Budget (OB) began a pilot in FY 2017 for the automatic
6 OSRE's Special Accounts Intranet content is available at
http://intranet.epa.gov/oeca/osre/work-team/workgroup/sa/index.html.
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rollover of unused reimbursable authority for special account funds at the beginning of the fiscal
year. OB will continue to monitor this process to identify improvements in the utilization of
requested reimbursable authority for special account funds. OB will evaluate the pilot's results in
the beginning of FY 2021.
Through the Superfund Task Force, EPA is working to ensure that contaminated sites across the
country are remediated to protect human health and the environment and returned to beneficial
use as expeditiously as possible. The Committee will continue to work on actions to implement
the Superfund Task Force recommendation to maximize the use of special accounts to facilitate
site cleanup and/or redevelopment.
Enabling Effective Regional Planning in SEMS
The special accounts management screen in the Superfund Enterprise Management System
(SEMS) enables Regions to see planning data and enter additions or changes for the use of
special account funds in conjunction with response activities for individual sites. Available
balances for special accounts are imported into SEMS nightly from information maintained by
OCFO, which allows the Regions to monitor their account balances and plan the use of resources
for ongoing and future site-specific response activities.
Regions are expected to plan appropriately for available funds in each special account, and
Regions will update special account planning data on a continual basis, as warranted by site
activity.7 The planning data should be updated at least twice a year during the work planning and
mid-year review process, but also more frequently when a milestone is reached (e.g., an account
is established, funds are received, new planning information is available).
OSRTI and OSRE will periodically review the utility of the special account planning fields in
SEMS to determine if appropriate data have been captured to manage the accounts and assess
and report on the value of special accounts to the Superfund program. OSRTI and OSRE also
will work with the Regions to ensure the fields in SEMS meet Regional needs for planning site
actions and planned utilization of special account resources.
Quality Control / Quality Assurance
It is crucial to the successful management of special accounts that SEMS planning data are not
only current, but also entered completely and accurately. This data must be entered consistently
across Regions to reflect accurately the true nature of how special account funds will be used to
support site work. Consistent with all plans for site-specific response actions, the use of special
account funds should be discussed with Regional program management to ensure they are fully
aware of the spending plans for each site.8 Through review and analysis of this data, EPA can
7 See the September 28, 2010, "Guidance on the Planning and Use of Special Accounts" [OSWER Directive#
9275.1-20] at https://www.epa.gov/sites/production/files/2013-10/documents/plan-use-specacct.pdf.
8 See the September 28, 2010, "Guidance on the Planning and Use of Special Accounts" [OSWER Directive#
9275.1-20] at https://www.epa.gov/sites/production/files/2013-10/documents/plan-use-specacct.pdf.
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ensure that the funds are used to their fullest potential, as well as report to internal and external
stakeholders, as appropriate. Data monitoring is discussed below.
OSRTI maintains and updates a SEMS User Guide that outlines how Regions should enter
planning information in the data and comment fields.9 Regional staff also are able to clarify
procedures by participating in national quarterly special account conference calls, bi-weekly
Superfund Information Management Coordinator/Budget Coordinator (IMC/BC) calls, or
through consultation with a Headquarters special accounts contact.
3. Monitoring Special Accounts
Monitoring special accounts will achieve the following goals:
1) Ensure appropriate use of the SEMS planning fields to maintain data quality;
2) Ensure funds are planned to the fullest extent possible and in accordance with
guidance;
3) Maximize the use of funds in special accounts; and,
4) Ensure both annually appropriated and special account resources are planned for and
used appropriately.
Data Monitoring Plan
OSRTI and OSRE have developed a special account data monitoring plan that outlines the
process for reviewing SEMS special account planning data and determining areas of OSRTI and
OSRE focus for improving the management of special accounts. The plan helps to inform work
planning and mid-year reviews, reporting to management, and topics for additional training
and/or guidance. OSRTI and OSRE update the plan as necessary to reflect current priorities and
activities.
Monthly Reviews of Accounts with Negative Balances
On a monthly basis, the Cincinnati Finance Center will monitor accounts with negative funds
available and coordinate with the Regions to correct the appropriate transactions within those
accounts. Regions should make corrections to address the negative funds issue, generally within
30 days, or provide a status to CFC of why a correction cannot be made.
Requests for Special Account Transactions
OSRTI, OSRE, and OCFO will work closely with the Regions on reclassifications, transfers to
the Superfund Trust Fund, and special account closures to ensure national policies are
implemented consistently. During work planning and mid-year sessions, as well as through the
notification process for these actions, Headquarters will discuss with the Regions the Region's
9 The Instruction Guide is available at:
http://intranet.epa.gov/oerrinet/rmd/imb/sems/SEMS SpecialAccount UserGuide 2014.pdf.
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intentions to reclassify or transfer resources to the general portion of the Superfund Trust Fund
prior to such actions taking place.
OSRTI, OSRE, and OCFO are working with the Regions to centralize the process for requesting
the movement of funds among special accounts for the same site, reclassifications, transfers to
the Trust Fund, and account closures with the goals of streamlining the process and improving
transparency of the status of requested actions. By centralizing these requests and streamlining
the process to request actions, EPA will have better internal controls to ensure requested actions
are completed or, if they are not completed, appropriate follow up action can be taken.
Monitoring Reports
OCFO has created reports in Compass Business Objects Reporting (CBOR) for Regions to
monitor special account financial transactions. OCFO and the Regions evaluate on an ongoing
basis whether existing reports in CBOR need to be modified or new reports developed for
Regions and Headquarters to monitor special account activity.
OSRTI, OSRE, and the Regions will develop new reports and/or modify existing reports to
effectively monitor SEMS planning data and the use of special accounts as needed.
Regional Superfund Division Directors will annually review open accounts with more than $1
million available, accounts with $0 obligated or disbursed in the past 5 years, and accounts with
less than $25 thousand available; this review ensures effective utilization of funds available in
these accounts and timely closure of accounts to decrease management and oversight. OSRTI
will provide a list of accounts that should be reviewed as part of the annual work planning
special account data review.10
OSRTI will continue to provide quarterly reports to the Superfund Division Directors and the
Committee on the status of planned reclassifications, transfers to the Superfund Trust Fund, and
overall utilization of special accounts.
Regional Work Planning and Mid-Year Reviews
During the annual work planning and mid-year review processes, OSRTI and OSRE will pull
SEMS data using developed monitoring reports to serve as the basis for work planning and mid-
year discussions with the Regions. The work planning data pull will take place at the beginning
of the fiscal year to establish a baseline for planning data for the coming fiscal year and to allow
EPA to report on special account multi-year plans. OSRTI and OSRE may conduct other SEMS
data pulls for use during mid-year reviews, and, on an ad hoc basis, may initiate other queries of
the data and conduct additional reviews.
During work planning as well as throughout the fiscal year, OSRTI, OSRE and the Regions will
use existing data to discuss how special account existing balances are being used to achieve site
progress, and whether opportunities exist to use additional funds for response actions at a site or
10 See the "Effective Utilization of Superfund Special Accounts" memorandum issued April 2, 2012 at
https://semspub.epa.gov/work/HO/175865.pdf.
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to reclassify or transfer resources to the general portion of the Superfund Trust Fund. OSRTI and
OSRE staff will review the planning data entered into SEMS in accordance with the priorities
outlined in the special account data monitoring plan and provide reports to the Committee about
how special account funds are planned for use in SEMS. OSRTI and OSRE also will put special
emphasis on ensuring special account funds are planned and used in accordance with appropriate
guidance.
Ad-hoc Reviews of Special Account Planning and Utilization Data
OSRTI, OSRE, and OCFO may conduct ad-hoc reviews of special account planning and/or
utilization data using data from SEMS and CBOR. These reviews may be done to support
Federal Managers Financial Integrity Act (FMFIA) requirements or to support activities to
improve the management and use of special accounts.
4. Regional Support Guidance and Training
Guidance and Training
The Agency has developed support documents relevant to the establishment, use, and
management of special accounts and has issued guidance and documents clarifying roles and
responsibilities of staff. In addition, requirements documents, fact sheets, and program status
reports have been made available to assist in the understanding and management of special
accounts. Special account planning and utilization data will be evaluated to identify areas where
additional training, guidance, and/or reference materials may be needed. Guidance and training
materials also will be developed at the direction of the Committee to ensure effective utilization
and proper management of special accounts.
OSRTI, OSRE, and OCFO will continue to conduct national and Region-specific special account
training. For example, special account training has been provided via webinars and has been
discussed at Superfund Branch Chief meetings and Superfund Division Director meetings. These
dialogues may lead to the determination that further guidance or input is required on an issue.
Special account planning and use data also will be used to identify areas where additional
training, guidance, and/or reference materials may be needed. OSRTI, OSRE, and the Regions
will explore other opportunities to engage on special account issues, such as during Regional
visits.
III. Designation of Points of Contact
OSRTI, OSRE, and OCFO have dedicated at least one person in each office who will be a
primary point of contact for the Regions and who will monitor special account use, planning
data, and general special account issues. In addition, each Region has designated at least one
person as a primary special account contact who coordinates across the Region on special
account management issues.
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IV. Strategy Implementation
Through implementation of the activities outlined in this Strategy, EPA will make additional
improvements in the management of special accounts. OSRTI, OSRE, and OCFO have updated a
workplan (Attachment 1) to undertake the activities outlined in this Strategy. The workplan is
dynamic to allow for activities to change as information and priorities regarding special accounts
may change. Implementation of this Strategy will be discussed at semi-annual meetings of the
Committee, as well as with Regions at national meetings. OSRTI, OSRE, and OCFO will
evaluate and update this Strategy after three years.
If you have any questions regarding this Strategy, please contact Tracey Stewart in OSRTI at
703-603-8791 or stewart.tracev@epa.gov.
Attachment
cc: Special Accounts Senior Management Committee
Superfund Special Account Contacts, Regions 1-10
Superfund Regional Branch Chiefs, Regions 1-10
Regional Comptrollers, Regions 1-10
Peter Wright, AO
Barry Breen, OLEM
Steven Cook, OLEM
Susan Bodine, OECA
Larry Starfield, OECA
Holly Greaves, OCFO
David Bloom, OCFO
Reggie Cheatham, OLEM/OEM
Gregory Gervais, OLEM/FFRRO
Nigel Simon, OLEM/OPM
Tracey Stewart, OLEM/OSRTI
Manuel Ronquillo, OECA/OSRE
Laura Ripley, OCFO/OB
Gregory Luebbering, OCFO/OC
Randy Sargent, OCFO/OC
Elizabeth McGuffey, OCFO/OC
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Attachment 1 Special Accounts Management Strategy Implementation Work Plan
Strategy
Priority
Activity
Sub-Activity
Due Date
Coordination
&
Transparency
Availability of Information on
EPA's Intranet
Maintaining and updating
special account information
available on the Intranet
Ongoing
Coordination
&
Transparency
Making Special Account
Information Available to the
Public
Maintaining and updating
special account information
available on the Internet
At least
annually
Coordination
&
Transparency
Making Special Account
Information Available to the
Public
EPA's Annual Performance
Plan and Congressional
Justification
1 st Monday
in February
each year
Coordination
&
Transparency
Making Special Account
Information Available to the
Public
Monitor receipt account in
monthly Superfund Trust Fund
financial statements
Ongoing
Coordination
&
Transparency
Making Special Account
Information Available to the
Public
Review and update key data
points for national Superfund
special accounts
communications
Annually
Coordination
&
Transparency
Intra-agency Coordination
Special Accounts Senior
Management Committee
(SASMC) semi-annual
meetings
Semi-annual
Coordination
&
Transparency
Respond to External Inquiries
Coordinate and respond to
OIG, GAO, Congressional,
public, and press inquiries
As inquiries
occur
Coordination
&
Transparency
Intra-agency Coordination
Update Special Accounts
Management Strategy
Every 3 years
Coordination
&
Transparency
Intra-agency Coordination
Update SASMC Charter
Every 2 years
Coordination
&
Transparency
Intra-agency Coordination
Report on annual activities of
the SASMC
1 st quarter
each FY
SA Planning
& Use Efforts
Quality Assurance/Quality
Control
Update/maintain SEMS
special account management
screen user guide
Ongoing
SA Planning
& Use Efforts
Enable Effective Regional
Planning in SEMS
Update/maintain SEMS
special account management
screens
Ongoing
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Strategy
Priority
Activity
Sub-Activity
Due Date
SA Planning
& Use Efforts
Enable Effective Regional
Planning in SEMS
Regions review and update
special account planning data
in SEMS
At least twice
a year
SA Planning
& Use Efforts
Special Account Utilization
Review on annual basis recent
expenditures of annually
appropriated funds for sites
with an open special account
Annual
SA Planning
& Use Efforts
Special Account Utilization
Implement pilot to carryover
special account reimbursable
authority at the beginning of
the fiscal year
Through
beginning of
FY 2021
S A Use &
Planning
Efforts
Special Account Utilization
Implement Superfund Task
Force recommendations
specific to special accounts
FY 2019
Monitoring
SAs
Monitoring Reports
Develop new reports and/or
modify existing reports to
effectively monitor SEMS
planning data
Ongoing
Monitoring
SAs
Monitoring Reports
Provide special account
management reports on a
quarterly basis to Superfund
Division Directors and the
SASMC
Ongoing
Monitoring
SAs
Monitoring Reports
Develop new reports and/or
modify existing reports in
CBOR to effectively monitor
special account financial
activity
Ongoing
Monitoring
SAs
Monitoring Reports
Regional Superfund Division
Directors annual review of
select special accounts
Annual
Monitoring
SAs
Special Accounts Data
Monitoring Plan
Implement and update data
monitoring plan as needed
Ongoing
Monitoring
SAs
Regional Work Planning and
Mid-Year Reviews
OSRTI and OSRE staff review
planning data entered in SEMS
Twice a year
Monitoring
SAs
Regional Work Planning and
Mid-Year Reviews
Provide to the SASMC an
analysis of the planning data
entered in SEMS
Twice a year
Monitoring
SAs
Regional Work Planning and
Mid-Year Reviews
Per OIG recommendation,
regularly analyze accounts 10
years old or more
At least twice
a year
Monitoring
SAs
Regional Work Planning and
Mid-Year Reviews
Per OIG recommendation,
evaluate $88.4M held (as of
At least twice
a year
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Strategy
Priority
Activity
Sub-Activity
Due Date
OIG 2009 Report) for potential
future use
Monitoring
SAs
Ad-hoc Reviews of Special
Accounts
FMFIA Reviews
As needed or
requested
Monitoring
SAs
Requests for Special Account
Transactions
Headquarters review of
regional reclassification,
transfer to the Trust Fund, and
closure memos
As memos
are received
Monitoring
SAs
Requests for Special Account
Transactions
Centralize process for
requesting special account
transactions (movement of
receipts, reclassifications,
transfers to the Trust Fund,
and account closures)
FY 2020
Monitoring
SAs
Monthly Reviews of Accounts
with Negative Balances
Identify and monitor monthly
accounts with negative fund
code and account available
balances
Monthly
Regional
Support,
Guidance &
Training
Guidance and Training
Conduct national and region-
specific special account
training
As needed or
requested
Regional
Support,
Guidance &
Training
Guidance and Training
Identify guidance or reference
documents for development
Ongoing
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