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Costs of $1.2 Million for 

Brownfields Cooperative 

Agreement to Pioneer Valley 

Planning Commission in 

Massachusetts Questioned

Report No. 15-4-0072 February 2, 2015

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Financial Management 
Report Contributors: Janet Kasper

Doug LaTessa

Patrick McIntyre

Mary Anne Strasser

Abbreviations

Agreement Cooperative Agreement BF97119201

CFR Code of Federal Regulations

EPA U.S. Environmental Protection Agency

PVPC Pioneer Valley Planning Commission

RLF Revolving Loan Fund

Cover photos: From left to right: The partially occupied City of Springfield Asylum Project

and the South Main Street School Brownfields Revolving Loan Fund site, 

Town of Monson, Massachusetts. (EPA OIG photos) 

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15-4-0072

February 2, 2015

Why We Did This Review

The U.S. Environmental 

Protection Agency (EPA), 

Office of Inspector General 

(OIG), conducted this 

examination to determine 

whether the costs claimed 

under a Brownfields Revolving 

Loan Fund Cooperative 

Agreement BF97119201 

(the agreement), awarded to 

the Pioneer Valley Planning 

Commission (PVPC), are 

reasonable, allowable and 

allocable in accordance with 

the applicable laws, regulations 

and agreement conditions. The 

OIG also sought to determine 

whether the objectives of the 

award were met. 

PVPC is the regional planning 

body for the Pioneer Valley 

Region, which encompasses 

43 cities and towns in the

Hampden and Hampshire 

county areas of Massachusetts.

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Cleaning up communities 

and advancing sustainable 

development.

Send all inquiries to our public 

affairs office at (202) 566 2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2015/ 

20150202-15-4-0072.pdf

 

Costs of $1.2 Million for Brownfields Cooperative

Agreement to Pioneer Valley Planning

Commission in Massachusetts Questioned

 

 What We Found

PVPC did not follow federal requirements when 

administering the agreement. Also, PVPC’s 

accounting system cannot provide an accurate, 

current and complete disclosure of the financial 

results. Of the $1,261,665 in funds drawn, 

PVPC acknowledged that $94,891 involved 

duplicate invoices, unverified costs, costs associated with another federal 

assistance agreement, and ineligible indirect costs, and agreed to repay $94,891. 

We consider the remaining $1,166,774 to also be questionable due to the other 

accounting deficiencies. PVPC’s accounting reports for the agreement do not 

reconcile, PVPC did not implement a corrective action from a previous Single 

Audit report, and PVPC is applying the wrong administrative requirements in its 

internal policies and procedures because those procedures apply to non-profit 

organizations and not governmental units such as PVPC.

PVPC achieved the intent of the agreement in that four brownfields were 

remediated. Two of the four sites were also reused, while the other two sites 

remained vacant due to market conditions and other factors.

 Recommendations and Planned Corrective Actions

We recommend that the Regional Administrator, EPA Region 1:

 Place PVPC on a reimbursement basis for all EPA grants and agreements.

 Issue a stop work order for this agreement until PVPC is able to provide 

accurate information on costs incurred for the agreement.

 Require PVPC to transfer $19,277 program income back to the Revolving 

Loan Fund.

 Verify that PVPC has a financial management system that meets federal 

standards prior to any future awards.

 Question and recover $1,261,665 of federal funds drawn at the time we 

began our review.

EPA Region 1 agreed to all recommendations and provided corrective actions 

and completion dates that meet the intent of the recommendations. Further, 

PVPC has already agreed to repay $94,891 in questioned costs and transfer 

$19,277 back to the Revolving Loan Fund.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

We found all of the 

$1,261,665 drawn by PVPC to 

be questionable, and PVPC 

has already agreed to repay 

$94,891 of that amount.
February 2, 2015

MEMORANDUM

SUBJECT: Costs of $1.2 Million for Brownfields Cooperative Agreement to 

Pioneer Valley Planning Commission in Massachusetts Questioned 

Report No. 15-4-0072

FROM: Arthur A. Elkins Jr.

TO: Curt Spalding, Regional Administrator

Region 1

This is our report on the subject examination conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems 

the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of 

the OIG and does not necessarily represent the final EPA position. EPA managers, in accordance with 

established audit resolution procedures, will make final determinations on matters in this report. 

The purpose of our examination was to determine whether the amounts drawn by the Pioneer Valley 

Planning Commission under Cooperative Agreement BF97119201 were reasonable, allowable and 

allocable in accordance with federal requirements and terms and conditions for Brownfields Assessment 

and Cleanup Cooperative Agreements and whether the results of the agreement were achieved.

Action Required

In responding to the draft report, Region 1 provided a corrective action plan, with milestone dates, for 

addressing the recommendations. However, since the report requires resolution of more than $250,000 

in questioned costs, EPA Manual 2750 requires Region 1 to submit a proposed management decision 

within 120 days. To expedite the resolution process, please email an electronic version of your proposed 

management decision to kasper.janet@epa.gov.

Your response will be posted on the OIG’s public website, along with our memorandum commenting on 

your response. Your response should be provided as an Adobe PDF file that complies with the 

accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final 

response should not contain data that you do not want to be released to the public. If your response 

contains such data, you should identify the data for redaction or removal. 

This report will be available at http://www.epa.gov/oig.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
Costs of $1.2 Million for Brownfields Cooperative Agreement to 15-4-0072

Pioneer Valley Planning Commission in Massachusetts Questioned

Table of Contents

Chapters

1 Introduction ...................................................................................................... 1

Purpose ..................................................................................................... 1

Background................................................................................................ 1

2 Independent Accountant’s Report .................................................................. 4

3 PVPC Did Not Comply With Federal Requirements ....................................... 6

PVPC Requested Reimbursement for Unallowable Costs.......................... 6

PVPC’s Financial System Does Not Provide Accurate Disclosure of 

 Financial Results.............................................................................. 7

PVPC Policy Refers to the Wrong Administrative Requirements................ 8

Recommendations..................................................................................... 9

EPA and Recipient Comments and OIG Evaluation................................... 9

4 Properties Have Been Remediated and Some Reused.................................. 12

Act Designed to Promote Cleanup and Reuse of Brownfields.................... 12

Remediation Costs of $1.3 Million Incurred, and Two of Four 

 Properties Reused ............................................................................. 12

Market Conditions and Other Factors Prevented Reuse of Two Sites........ 13

Status of Recommendations and Potential Monetary Benefits ............................. 14

Appendices

A PVPC Response to Draft Report...................................................................... 15

B Region 1 Response to Draft Report ................................................................ 47

C Distribution ....................................................................................................... 51
15-4-0072 1

Chapter 1

Introduction

Purpose

The purpose of this examination was to determine whether the Pioneer Valley 

Planning Commission (PVPC, or the recipient):

 Reported costs that are reasonable, allowable and allocable in accordance 

with the applicable laws, regulations, and terms and conditions of 

Cooperative Agreement BF97119201 (the agreement).

 Achieved the intended results of the agreement.

Background

The Small Business Liability Relief and Brownfields Revitalization Act1

authorized grants to eligible entities to capitalize a Revolving Loan Fund (RLF)

that provides loans and grants for the remediation of brownfield sites.2 Through 

these awards, the U.S. Environmental Protection Agency (EPA) seeks to 

strengthen the marketplace and encourage stakeholders to leverage the resources 

needed to clean up and redevelop brownfields. 

According to the Small Business Liability Relief and Brownfields Revitalization 

Act: “The term brownfield site means real property, the expansion, 

redevelopment, or reuse of which may be complicated by the presence or 

potential presence of a hazardous substance, pollutant, or contaminant.” 

When loans are repaid, the loan amount is returned into the fund and re-lent to 

other borrowers, providing an ongoing source of capital within a community.

Since 1962, PVPC has been the designated regional planning body for the 

Pioneer Valley region, which encompasses 43 cities and towns in the Hampden 

and Hampshire County areas in Massachusetts, as shown in Figure 1.

 

1 Public Law 107-118.

2 The Small Business Liability Relief and Brownfields Revitalization Act amended Sections 101 and 104 of the 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980.
15-4-0072 2

Figure 1: Map of PVPC’s designated planning area

Source: PVPC.

According to its Schedule of Expenditures of Federal Awards identified in the 

Single Audit for the period ending June 30, 2012, PVPC administered numerous 

awards from several federal agencies. The EPA Region 1 awarded PVPC the 

agreement on April 17, 2008, with a total approved project cost of $1,621,244. 

As of March 12, 2014, PVPC had drawn $1,261,665 of those funds. 

The purpose of the assistance agreement was to provide funding to PVPC to 

develop a RLF and clean up brownfield sites in Springfield, Chicopee, Holyoke, 

and Westfield, Massachusetts. Under the agreement, the EPA is to contribute 

80 percent of all approved budget costs incurred, up to and not exceeding total 

federal funding of $1,351,037, while PVPC is to pay a cost share of at least 

20 percent of total federal funds awarded. 
15-4-0072 3

Prior Audit Reports

Table 1 identifies the three Single Audits we reviewed pursuant to our audit 

objectives.

Table 1: Prior audit reports reviewed by auditors

Date of Single 

Audit report Significant findings

March 15, 2011  Improve controls over journal entries.

 Improve general grant management and accounting.

 Request reimbursement in accordance with grant 

provisions and maintain support for expenses reported.

July 12, 2012  Improve indirect cost rate management and accounting.

 Improve controls over journal entries.

 Improve general grant management and accounting.

 Maintain support for expenses reported – Brownfields 

Revolving Loan Program.

March 11, 2013 None. The audit report stated that findings from the previous 

year were satisfactorily resolved. However, there were no 

disbursements from the Brownfields Revolving Loan Fund 

during the audit period.

Source: OIG analysis of Single Audits.
15-4-0072 4

Chapter 2

Independent Accountant’s Report

As part of our oversight of assistance agreement awards made by the EPA, the 

EPA’s Office of Inspector General (OIG) examined the costs claimed under 

Cooperative Agreement BF-97119201 awarded to PVPC. The OIG conducted the 

examination to determine whether the costs claimed under the agreement were 

reasonable, allowable and allocable in accordance with the Code of Federal 

Regulations (CFR) under 40 CFR Part 31, Uniform Administrative Requirements 

for Grants and Cooperative Agreements to State and Local Governments; 2 CFR 

Part 225, Cost Principles for State, Local, and Indian Tribal Governments; and 

the terms and conditions of the agreement. We examined costs claimed by the 

recipient of $1,261,665 covering the period from April 17, 2008, to March 12, 

2014. We also reviewed PVPC’s accomplishment of the agreement’s objectives.

In accepting the award, PVPC is responsible for complying with the requirements

listed above. Our responsibility is to express an opinion on PVPC’s compliance 

and costs claimed based on our examination.

Our examination was conducted in accordance with the Government Auditing 

Standards issued by the Comptroller General of the United States, and the 

attestation standards established by the American Institute of Certified Public 

Accountants. We examined, on a test basis, evidence supporting the amount 

claimed under the agreement and performed other procedures we considered 

necessary under the circumstances. We believe our examination provides a 

reasonable basis for our opinion.

We conducted our examination from March 12 to September 23, 2014. We 

performed the following steps:

 Reviewed and analyzed EPA project files, grant files and data systems.

 Interviewed the recipient to obtain an understanding of the recipient’s 

internal controls, accounting system and project management.

 Interviewed the EPA’s Office of Brownfields and Land Revitalization, and 

EPA Region 1’s grants and project managers for the agreement, to obtain 

an understanding of the recipient’s history.

 Reviewed Single Audit information from 2010 to 2012 for unresolved 

audit findings.

 Verified deposits of EPA payments to the recipient’s bank statements.
15-4-0072 5

 Reviewed costs claimed by the recipient to obtain reasonable assurance 

that the costs complied with the applicable federal laws and regulations 

and the terms and conditions of the agreement.

 Determined whether the recipient met its cost share match.

 Conducted project site visits to determine whether the work specified in 

the agreement was accomplished.

PVPC is responsible for establishing and maintaining effective internal control 

over compliance with the requirements of 40 CFR Part 31, 2 CFR Part 225, and 

the terms and conditions of the agreement. We considered PVPC’s internal 

controls over compliance with the requirements listed above as a basis for 

designing our examination procedures, but not for the purpose of expressing an 

opinion on the effectiveness of internal control over compliance. Our 

consideration of internal controls would not necessarily disclose all internal 

control matters that might be material weaknesses. 

Our examination disclosed the following significant deficiencies in internal 

controls over compliance with the requirements of 40 CFR Part 31, 2 CFR 

Part 225, and the terms and conditions of the agreement:

 Unallowable costs were charged to the agreement.

 Errors, such as drawing funds for the same invoice multiple times, were 

not identified and corrected by PVPC.

 PVPC’s accounting records cannot provide reliable information on the 

financial results of the agreement.

As a result, we questioned total costs claimed under the agreement as of March 12, 

2014, of $1,261,665, and recommend that the EPA recover that amount. 

In our opinion, the costs claimed do not meet, in all material respects, the 

requirements of 40 CFR Part 31, 2 CFR Part 225, and the terms and conditions of 

the agreement for the project period ending December 31, 2014. 

Janet Kasper

Director for Contracts and Assistance Agreement Audits

September 23, 2014
15-4-0072 6

Chapter 3

PVPC Did Not Comply With Federal Requirements

PVPC did not adhere to federal requirements when administering the agreement. 

PVPC charged costs to the agreement that were unallowable, were incurred for 

another EPA award, and were prohibited by the agreement’s terms and 

conditions. PVPC’s accounting system cannot produce accurate reports on the 

costs incurred under the agreement. PVPC did not maintain required 

documentation, and referred to the wrong administrative requirements in its 

internal procedures. Federal regulations require costs charged to federal awards to 

be reasonable, allowable and allocable; and require accurate and complete 

disclosure of the financial results of financially assisted activities. Due to the 

numerous errors we identified and our inability to reconcile PVPC’s accounting 

reports, we are questioning the $1,261,665 claimed under the agreement at the 

time of our review. PVPC has agreed to repay $94,891 of that amount.

PVPC Requested Reimbursement for Unallowable Costs

PVPC requested reimbursement for the same invoices as part of two separate 

draw requests. The total value of the duplicate invoices was $71,709, as shown in 

Table 2. Cost Principles for State, Local, and Indian Tribal Governments - 2 CFR 

Part 225 - establishes principles and standards for determining costs for federal 

awards. Appendix A to Part 225 at Section C(1) sets out the factors affecting the 

allowability of costs.

Table 2: Summary of duplicate draws

Draw dates Amount of draw duplicated

2/17/2010 1/26/2010 $65,360

10/6/2010 9/20/2010 6,349

Total $71,709

Source: OIG analysis of PVPC data.

PVPC requested reimbursement for two invoices that were not allocable to the 

agreement. The invoices were for services rendered by PVPC on behalf of the 

town of Monson for a contract signed in November 2005, pursuant to EPA 

assistance agreement BF97131101. The value of those two invoices was $6,053

as shown in Table 3. Cost Principles for State, Local, and Indian Tribal 

Governments - 2 CFR Part 225 - establishes principles and standards for 

determining costs for federal awards. Appendix A to Part 225 at Section C(3) 

defines allocable costs. Per that section, costs incurred by PVPC for services 

performed pursuant to another federal assistance agreements are not allocable to 

the agreement.
15-4-0072 7

Table 3: Invoices incurred for services rendered for EPA award BF97131101

Draw date Amount of invoice

9/22/2009 $5,783

9/20/2010 270

Total $6,053

Source: OIG analysis of PVPC data.

PVPC requested and received reimbursement for indirect costs for at least 18 of 

the 32 draws of federal funds we examined. The value of ineligible indirect costs 

was $19,589. Both the approved budget and the terms and conditions of the 

agreement prohibit indirect costs. PVPC self-identified that it was not in full 

compliance with the charging of ineligible indirect costs. PVPC stopped 

requesting reimbursement for indirect costs once it realized this violated the 

agreement’s terms and conditions. According to our analysis, the last draw for 

which PVPC requested reimbursement for indirect costs occurred in September 

2010.

PVPC also transferred $19,277 of program income from the RLF to its general 

checking account for unidentified and unspecified administrative expenses. The 

agreement’s terms and conditions do not allow program income to be used for 

administrative expenses. PVPC self-identified that it was not in full compliance 

with the charging of program income. PVPC stopped transferring program 

income once it realized this violated the agreement’s terms and conditions. The 

last transfer of program income occurred in February 2011. In responding to the 

draft report, PVPC stated it would return the program income to the RLF. 

PVPC’s Financial System Does Not Provide Accurate Disclosure of 

Financial Results

PVPC’s accounting system cannot provide an accurate, current and complete 

disclosure of the financial results of the agreement. We asked PVPC to provide a 

transaction report identifying all revenues and expenditures for the agreement. 

PVPC provided two reports: (1) Revenue and Expenses Report by Project; and 

(2) Project/Element Charge Listing. In comparing these two reports, we noted 

differences between the reports for several line items. For example:

 PVPC recorded 89 percent of the RLF expenses to the “revolving loans”

account. The amount of this account varied by $154,321 between the two 

reports. PVPC did not include details on how the funds were used in its

accounting system. Detailed information on how the funds were used was 

contained in a separate manual ledger. As a result, PVPC’s accounting 

system cannot be relied upon to produce accurate financial reports.

 The loan repayments/recapture account had a $203,798 difference 

between the reports. PVPC’s accountant stated that loan repayments may 

not have been recorded. As a result, it is unclear whether all loan 
15-4-0072 8

repayments were returned to the RLF as required by the terms and 

conditions of the agreement.

We noted other accounts with differences between the two accounting reports, as 

shown in Table 4. The differences indicate that PVPC’s accounting system cannot 

be relied upon to provide information on the cost incurred for RLF projects.

Table 4: PVPC accounting report variances

Revenue & expenditure 

report by project

Project/element 

charge listing report Variance 

Interest Income $58,402 $31,701 $26,701

Travel-Gas/Mileage/Parking 846 804 42

Conferences 3,194 2,655 539

Subcontractors 15,054 2,726 12,328

Due to Other PVPC Grant 22,310 0 22,310

Source: OIG Analysis of PVPC data.

Standards for financial management systems - 40 CFR 31.20(b)(1) and (b)(2) -

require recipients to have a financial management system that provides for 

accurate, current and complete disclosure of the financial results of financially 

assisted activities; and requires recipients to maintain records which adequately 

identify the source and application of funds. Based on the variances between the 

two reports, PVPC’s accounting system cannot provide an accurate, current and 

complete disclosure of the financial results of the agreement. Because PVPC has 

not reconciled the brownfields accounts, PVPC cannot provide accurate 

information on the costs incurred under the agreement. Therefore, we are 

questioning the $1,261,665 drawn as of March 12, 2014.

The Single Audit report for the period ending June 30, 2010, reported significant 

deficiencies in internal control over major programs. Specifically, the report 

stated that PVPC did not retain any documentation to support either the amounts 

claimed for reimbursement or the amounts reported on the quarterly progress 

reports filed with the EPA for salaries and indirect costs. In its corrective action 

plan, PVPC stated that it would be “reconciling all support documentation for the 

Brownfields RLF Program....” This corrective action was never implemented. 

Office of Management and Budget Circular A-133, Subpart C §300(f), states that 

auditees shall follow up and take corrective action on audit findings. 

PVPC Policy Refers to the Wrong Administrative Requirements

PVPC is applying the wrong administrative requirements as it refers to Uniform 

Administrative Requirements for Grants and Agreements with Institutions of 

Higher Education, Hospitals, and other Non-Profit Organizations throughout its 

Financial Control Policy and Procedures. These requirements are not applicable to 

governmental units such as PVPC. Title 2 CFR Part 225, Appendix A, Section 

B.16 defines a local government as a “county, municipality, city, town, township, 

local public authority, school district, special district, intrastate district, council of 
15-4-0072 9

governments (whether or not incorporated as a nonprofit corporation under state 

law), any other regional or interstate government entity, or any agency or 

instrumentality of a local government.” PVPC’s Operations Manual states that 

PVPC is a public sector agency, and PVPC’s Executive Director told auditors that 

PVPC is a governmental unit, not a non-profit. As a result of our review, PVPC 

modified its Financial Control Policy and Procedures, although these have not yet 

been adopted by PVPC’s Executive Committee.

Recommendations

We recommend that the Regional Administrator, EPA Region 1:

1. Place PVPC on a reimbursement basis for all EPA grants and agreements.

2. Issue a stop work order for this agreement until PVPC is able to provide 

accurate information on costs incurred for the agreement.

3. Require PVPC to transfer $19,277 of program income back to the RLF.

4. Verify that PVPC has a financial management system that meets federal 

standards established under 40 CFR § 31 prior to any future awards.

5. Question and recover the $1,261,665 of federal funds drawn as of 

March 12, 2014.

EPA and Recipient Comments and OIG Evaluation

PVPC and EPA Region 1 both provided written responses to the draft report

(Appendices A and B, respectively). We held an exit conference with EPA 

Region 1 and PVPC to discuss the draft report comments and their impact on our 

final report. PVPC generally agreed with our findings regarding the unallowable 

costs that it claimed, but disagreed that its financial system did not provide accurate 

disclosure of financial results. EPA Region 1 provided comments and a corrective 

action plan. Where we agreed with the comments, we made changes to the report. 

Their responses are summarized below, as well as our evaluation of their responses. 

In response to Recommendation 1, EPA Region 1 placed PVPC on a 

reimbursement basis for its grants starting September 18, 2014. EPA Region 1’s 

actions addressed the recommendation.

For Recommendation 2, the OIG proposed issuing a stop work order for the 

brownfields revolving loan agreement. The project period ended on December 31, 

2014. Rather than issuing a stop work order, Region 1 staff stated that they did not 

renew the agreement. EPA Region 1’s action will addresses the intent of the 

recommendation.
15-4-0072 10

In regard to Recommendation 3, PVPC agreed that the program income needs to be 

moved back into the RLF and proposed to Region 1 that it would repay the funds 

by the 2nd quarter of FY 2015. Region 1 will confirm the amount is accurate. PVPC 

and Region 1’s action, when implemented, will address the recommendation. 

In regard to Recommendation 4, PVPC stated in its response that the accounting 

system allows PVPC to track all contracts—including federal awards—separately 

and independently. While the system may allow PVPC to track the costs associated 

with the award, the reports from PVPC’s accounting system that it provided during 

the review were not accurate or complete. For example, the accounting system did 

not include detailed information on how funds were used. Also, the accountant was 

not sure whether all loan repayments had been recorded in the system.

The records PVPC provided in response to the audit report did not match up with 

the data in EPA’s accounting system. In response to the draft report, PVPC 

provided a spreadsheet—not from its Grants Management System accounting 

system—showing total funds drawn of $1,257,551.54. The EPA accounting system 

records show PVPC received $1,261,665.44 of funds paid to PVPC under the 

agreement. PVPC did not explain the difference in the response to the draft report.

During the audit, PVPC could not provide accurate information on the financial 

results of the agreement. In responding to the draft report, PVPC provided a 

spreadsheet from outside its accounting system that it says represents the total 

funds drawn but does not reconcile to EPA accounting system records. In 

responding to the draft report, PVPC has not provided the information necessary to 

show that its financial management system meets the federal standards under 

40 CFR Part 31. 

In responding to Recommendation 4, Region 1 stated that it will meet with PVPC 

and verify that it has a financial system that meets federal standards. PVPC 

proposed to EPA Region 1 a completion date of the 4th quarter of FY 2015. 

Region 1’s planned action, when implemented, will address the recommendation.

In responding to Recommendation 5, PVPC agreed that it was responsible for 

repaying to the EPA $94,890.63. Details are in Table 5.

Table 5: Amounts PCPC agreed to repay

Item Amount

Duplicate invoices $71,709.00

Unverified costs (identified by PVPC in response to draft report) 539.72

Cost associated with another federal assistance agreement 6,053.00

Ineligible indirect costs 16,588.91

Total to be repaid $94,890.63

Source: PVPC
15-4-0072 11

Because PVPC cannot provide accurate information on the costs incurred under the 

agreement, the remaining $1,166,774 remains questioned. The OIG continues to 

recommend that these funds be recovered. In responding to the draft report, EPA 

Region 1 stated that it will meet with PVPC to review the supporting 

documentation for the eligible agreement expenses. PVPC proposed to Region 1 a 

completion date of the 4th quarter of FY 2015. The region’s proposed action, when 

implemented, will address the recommendation. Since more than $250,000 in costs 

were questioned, EPA Region 1 will need to provide the OIG with a proposed 

management decision on the questioned costs before issuing the final decision to 

PVPC.
15-4-0072 12

Chapter 4

Properties Have Been Remediated 

and Some Reused

PVPC achieved the intended results of the agreement, as four properties were

remediated. Two of the four properties were also reused, which the Small 

Business Liability Relief and Brownfields Revitalization Act is designed to 

promote. The Act authorized grants to eligible entities to capitalize an RLF to

provide financial assistance for the remediation and revitalization of brownfield 

sites. Original plans for redevelopment of the other two properties have not been 

achieved due to market conditions and other factors. 

Act Designed to Promote Cleanup and Reuse of Brownfields

The Act promotes the cleanup and reuse of brownfields by establishing a program 

to provide grants to eligible entities to be used for capitalization of an RLF for 

brownfields remediation. RLF recipients provide loans and grants to carry out 

remediation activities at brownfield sites. The EPA’s Brownfields program is 

designed to empower states, communities and other stakeholders in economic 

redevelopment to work together in a timely manner to prevent, assess, safely 

clean up, and sustainably reuse brownfields. Through these grants, the EPA seeks 

to strengthen the marketplace and encourage stakeholders to leverage the 

resources needed to clean up and redevelop brownfields.

Remediation Costs of $1.3 Million Incurred, and Two of Four 

Properties Reused

The agreement provided funding to PVPC to develop a revolving loan fund and to 

clean up brownfield sites. PVPC achieved the intended results of the agreement,

as its RLF was used to remediate the following four Massachusetts properties:

1. Town of Ware.

2. Town of Monson.

3. Springfield Redevelopment Authority Chapman Valve.

4. City of Springfield Asylum Project.

In addition, two of the four properties have been reused. Original plans for the 

Town of Monson, Springfield Redevelopment Authority Chapman Valve, and 

City of Springfield Asylum Project called for the space to be used as housing, a 

light-industrial park with pad-ready sites, and office space for the Springfield 

Parking Authority, respectively. Two of the projects (Town of Monson and 

Springfield Redevelopment Authority Chapman Valve) are now remediated 

vacant lots available for reuse. The City of Springfield Asylum Project in 

downtown Springfield is partially occupied. The Town of Ware project completed 
15-4-0072 13

the removal of contaminated soils from a former landfill and farm equipment 

facility, and is now reused as a fire station.

Table 6: Remediation cost of properties paid for by the agreement

Recipient RLF cost

Loan 

amount

Subgrant 

amount

Town of Ware $50,000 $40,000 $10,000

Town of Monson 205,276 123,166 82,110

Springfield Redevelopment Authority Chapman Valve 740,781 444,468 296,313

City of Springfield Asylum Project 345,550 207,330 138,220

Total $1,341,607 $814,964 $526,643

Source: PVPC data.

Market Conditions and Other Factors Prevented Reuse of Two Sites

The original redevelopment plans for two projects have not been achieved for the 

following reasons:

 Original plans for the Town of Monson project called for the building to be 

rehabilitated for use as housing, but the collapse of the housing market and 

structural deterioration of the building forced the town to raze the building.

 Redevelopment plans for the Springfield Redevelopment Authority

Chapman Valve project were put on hold indefinitely due to unexpected 

levels of contamination at a key adjacent property.

Top row, from left: The Town of Ware project that is now a fire station and the Town of 

Monson vacant lot. Bottom row, from left: The Springfield Redevelopment Authority 

Chapman Valve vacant lot and the partially occupied City of Springfield Asylum Project.
15-4-0072 14

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed

Amount

Agreed-To 

Amount

1 9 Place PVPC on a reimbursement basis for all EPA 

grants and agreements.

C Regional Administrator, 

EPA Region 1

9/18/14

2 9 Issue a stop work order for this agreement until 

PVPC is able to provide accurate information on 

costs incurred for the agreement.

C Regional Administrator, 

EPA Region 1

12/30/14

3 9 Require PVPC to transfer $19,277 of program 

income back to the RLF.

O Regional Administrator, 

EPA Region 1

3/31/15 $19.2 $19.2

4 9 Verify that PVPC has a financial management 

system that meets federal standards established 

under 40 CFR § 31 prior to any future awards.

O Regional Administrator, 

EPA Region 1

9/30/15

5 9 Question and recover the $1,261,665 of federal 

funds drawn as of March 12, 2014.

U Regional Administrator, 

EPA Region 1

$1,261.7 $94.9

1 O = Recommendation is open with agreed-to corrective actions pending.

C = Recommendation is closed with all agreed-to actions completed.

U = Recommendation is unresolved with resolution efforts in progress.
15-4-0072 15

Appendix A

PVPC Response to Draft Report

Pioneer Valley Planning Commission

Response to U.S. Environmental Protection Agency

Office of Inspector General Report on Examination of Costs

Cooperative Agreement BF97119201

Project No. OA-FY14-0170 November 7, 2014

Fire Department Headquarters, Ware, Massachusetts (formerly Ware Farm Equipment)

 

1600 Main International Biergarten, Springfield, Massachusetts (formerly the Asylum Club)
15-4-0072 16

Pioneer Valley Planning Commission

Response to U.S. Environmental Protection Agency

Office of Inspector General Report on Examination of Costs

Cooperative Agreement BF97119201

Project No. OA-FY14-0170 November 7, 2014

In calendar year 2014, the U.S. Environmental Protection Agency (EPA), Office of the Inspector General 

(OIG) conducted an examination of costs for Cooperative Agreement BF97119201 (Agreement) awarded 

to the Pioneer Valley Planning Commission (PVPC). During the course of the EPA OIG's site visits and 

subsequent verbal and electronic communication, the PVPC provided exhaustive records, information and 

explanations concerning the OIG's requests. 

As part of this examination, the EPA OIG made the following findings:

 Federal Requirements were not followed when administering the Agreement.

 PVPC's accounting system cannot provide an accurate, current, and complete disclosure of 

accounting results.

 Reimbursement was requested for ineligible indirect costs.

 Program income was used for administrative expenses.

 Duplicate invoices (drawdowns) were submitted by the PVPC.

 PVPC's accounting reports do not reconcile.

 Davis-Bacon Act documentation not maintained.

 Corrective action from previous audit report not implemented.

 The wrong administrative requirements in PVPC's internal policies and procedures are referenced.

 Although the PVPC met the intent of the Agreement concerning remediation, not all sites were 

developed and reused.

This formal response provides further detail on the PVPC's efforts to clarify statements made by the EPA 

OIG. As there is overlap in some of the issues raised and subsequent explanation, the PVPC is categorizing 

its response according to general comments, financial issues, accounting software, administrative issues 

and project concerns.

General Comments

The PVPC feels that the title of the EPA OIG's report is very misleading and derogatory and is not an 

accurate portrayal of the review by the OIG. Furthermore the inference that the remediated sites were not 

re-used should be removed. The perception shown is inaccurate, misleading and doesn't focus on the 

accomplishments of the PVPC, which could not have been accomplished if funds were misused. The OIG 

report cover and general statement that $1.2 million in grant costs are "questioned" is inaccurate as the 

PVPC has provided documentation for its expenses and has tracked over $1.257 million in draws. The 

PVPC feels that its costs were reasonable, allocable, and allowable but for those limited exceptions detailed 

later in this response. Based on the information provided to the OIG, the PVPC feels that this report does 

not reflect accurately the results of the audit. The OIG failed to acknowledge the support documentation 

provided or the corrective actions taken to address any issues. Furthermore, the PVPC is confident that it 

has a strong financial accounting system in place. The PVPC looks forward to continuing to be able to do 

good work in the future. The OIG's report, as written, unfairly impedes that ability, despite the fact that 
15-4-0072 17

we've undeniably made a concerted, good faith effort to address and correct all known deficiencies in a 

satisfactory manner..

Financial Issues

 Federal requirements were not followed when administering the Agreement.

 Reimbursement was requested for ineligible indirect costs.

 Program income was used for administrative expenses.

 Duplicate invoices were submitted by the PVPC.

 PVPC's accounting reports do not reconcile.

1. Federal requirements, ineligible indirect costs, program income. Although the PVPC did follow 

federal requirements pursuant to the administration and implementation of the Agreement, it recognizes 

that it unknowingly did not fully adhere to all requirements pertaining to administrative indirect costs and 

the use of program income for administrative costs at the time that those costs were incurred. Previous 

PVPC assigned Brownfields staff, through discussions with EPA, interpreted the use of a flat rate inclusive 

of total cost as compliance with the administrative cost prohibition. In addition, program staff at the time 

were not fully cognizant of the change in regulations pertaining to the use of program income for 

administrative expenses until significant charges had been made. 

PVPC self-identified that it was not in full compliance with the charging of ineligible indirect and use of 

program income and the practice immediately stopped. Further, the PVPC engaged the services of a 

contractor to audit it's records to determine the outstanding amount due back to the EPA. As a draft audit 

was not complete until July 2013, the PVPC opted to wait until the OIG's examination was complete so as 

to comply with the amount to be transferred back into the appropriate accounts. This was fully disclosed 

to the EPA OIG at the time of the examination, including estimated monetary amounts expected to be 

transferred. 

The PVPC generally concurs with the $22,237 of indirect costs identified by the OIG as drawn during the 

period of 5/31/08 through 8/31/10. (Note: The OIG rounded the indirect rate to the nearest whole number. 

The actual indirect as fully calculated is $22,458.43) However, the fringe portion of this amount is an 

eligible expense under EPA's Regulations. Pursuant to OMB Circular A-87 and PVPC's approved terms 

and conditions, "fringe" is an allowable expense under the terms of the agreement and is outlined in the 

PVPC approved work plan and budget. PVPC's indirect rate is established annually through its independent 

audit with the actual fringe benefit rate and indirect cost rate within the approved indirect cost pool being 

set by a U.S. EPA Rate Negotiator in its Financial Analysis and Oversight Service Center. See Attachment 

A.

The actual ineligible indirect costs totals $16,588.91, as shown below. This is based on the $22,458.43 of 

indirect less the $5,869.52 of eligible fringe.

Draw Period Direct Labor 

Amount

Indirect 

Rate

Indirect ($) Eligible Fringe* 

(%)

Eligible 

Fringe ($)

5/31/08-6/30/08 $735.95 110.8% $815.43 34.86 $256.55

7/1/08-6/30/09 $8,524.95 110.8% $9,445.64 33.66 $2,869.49

7/1/09-6/30/10 $10,185.61 118.3% $12,049.58 26.61 $2,710.39

7/1/10-6/30/11 $124.92 118.3% $147.78 26.49 $33.09

Total $19,571.43 NA $22,458.43 NA $5,869.52

* See Attachment A for OMB Circular A-87 Cognizant Agency Negotiation Agreements.
15-4-0072 18

OIG Response 1.

We agree with PVPC that fringe benefits are an eligible expense. After our exit conference, 

PVPC provided support for the $19,571.43 in direct labor identified in the table above, and we 

were able to verify the calculation of eligible fringe benefit. We agree with PVPC’s 

calculation of ineligible indirect costs of $16,588.91.

In addition, the PVPC has calculated the transferred program income amount for the period of 7/2008 

through 2/2011 to be $24,704.41 and not the lesser $19,277 as identified by the OIG. 

Complete records of these draws, transfers and expenses are on file and available for review at the PVPC. 

The following table details the transferred administrative program income payments that PVPC between 

July 2008 and February 2011.

Date Check # Principal Interest Bank Interest Disbursement

07/08/08 1010 $2,152.19 $3,200.00 $75.23 $5,427.42

02/26/09 1013 $1,774.77 $1,685.73 $85.49 $3,545.99

02/07/09 1016 $2,195.24 $2,769.56 $33.24 $4,998.04

02/12/10 1021 $1,810.59 $1,327.51 $66.81 $3,204.91

07/08/10 1026 $2,239.14 $2,330.51 $57.07 $4,626.72

02/28/11 1042 $1,847.14 $962.05 $92.14 $2,901.33

Total $24,704.41

OIG Response 2.

The difference between the OIG-calculated amount of transferred program income ($19,277) 

and the amount reported by PVPC ($24,704.41) is $5,427.41—or the amount equal to the draw 

on July 8, 2008 (rounded). The difference was discussed at the exit conference and PVPC 

agreed that the amount was associated with another EPA cooperative agreement. PVPC agreed 

with the OIG original calculation of $19,277 of program income.

Finally, the PVPC also recognizes that it incorrectly drew funds for administrative activities for another EPA 

funded activity. These monies totaled $6,053.

PVPC Corrective Action: The PVPC is well aware that it must transfer monies back into the program income 

account and that it is required to absorb the cost of the identified ineligible indirect. The PVPC has 

repeatedly communicated to EPA officials that it has always fully intended to do so once the amount due 

was clearly and concisely identified. The PVPC will transfer all ineligible indirect and program income, plus 

all applicable interest back into the appropriate accounts. This will result in $16,588.91 being paid back to 

the grant and $24,704.41 being transferred from the PVPC general operating account to the RLF program 

income account. 

In addition, the PVPC will reimburse the grant $6,053 for the EPA administrative funds used on a related, 

but separately funded contract.

2. Duplicate invoices (drawdowns) were submitted by the PVPC. Upon compiling a spreadsheet for 

the EPA OIG's office showing a detailed listing of drawdowns and associated expenses for the PVPC RLF 

Program, it was determined that 2 duplicate draws occurred in the winter and fall of 2010 totaling $71,709. 

These funds were deposited in the PVPC general fund and not expensed to the RLF Program. 

The PVPC hired a new Accounting Manager in February 2009 due to retirement of the previous accounting 

manager. After an acceptable first year of performance, the actions and abilities of the Accounting Manager 

deteriorated due to a combination of not fully understanding governmental finances, inability to learn the 

agency's financial software program and steadily deteriorating health. Actions in 2010 including failure to 
15-4-0072 19

keep proper back-up records, failure to enter regular journal entries, missed deadlines and other serious 

concerns led to a very poor annual evaluation with clear benchmarks for improvement, changes in internal 

procedures for monitoring, an Action Plan for Employment ("last chance agreement") and eventually, formal 

termination in December 2011, effective in January 2012. The behavior of the Accounting Manager which 

resulted in such poor performance and inappropriate actions such as the EPA duplicate draws were directly 

related to his severely deteriorating health, and at that time, no accounting staff assistance. In mid-to-late 

2011, temporary accounting assistance was put in place as well as procedures to monitor overall 

accounting activity. These are reflected in the FY10 and FY11 PVPC Audit Management Responses (see 

elsewhere in this response). The health of the Accounting Manger had declined to such a degree where 

he was relieved of many of his duties prior to his termination or had most of his work reviewed by 

management. Unfortunately he died shortly after being notified of his termination but while officially still in 

the employ of the PVPC.

PVPC Corrective Action: With the hiring of a new Accountant in late January 2012, the formal establishment 

of an Accounting Assistant position, the implementation of a number of financial checks and balances 

including oversight by the Deputy Director of Operations of all financial activity, the PVPC has the protocols 

in place to prevent similar duplication activity from occurring. The PVPC fully recognizes the draw error, is 

in agreement that this amount totals approximately $71,709, and will transfer these funds from the PVPC 

general operating account back into the RLF Grant.

3. PVPC Accounting Records Do Not Reconcile. Independently and as accurately maintained, the 

PVPC accounting records do reconcile. The circumstance concerning the PVPC RLF account was 

impacted by actions as described above concerning the PVPC's previous Accounting Manager. In addition, 

the poor decision to combine the old RLF account, PI account and new RLF account over multiple fiscal 

years and varying indirect rates resulted in the inability to use the PVPC's main financial software program 

to solely identify the sources and uses. However, as expenditures were paid out of and tracked in a 

separately maintained account within the Agency's Community Development Section, the drawdowns and 

expenditures can and have been tracked. Using the latter, according to PVPC records, the total amount of 

funds drawn from 6/30/08 through 3/12/14 totals $1,257,551.54, which varies by $4,113.90 from the 

$1,261,665.44 noted by the EPA OIG. This difference directly related to the circumstances described in #2 

above. The $1,257,551.54 amount documented by the PVPC includes the duplicate draws ($71,709) 

detailed in #2 above and $539.72 in unverifiable direct costs. This totals $76,362.62 in documented costs 

that the PVPC is responsible for paying back to the grant. Records of these draws and expenditures are 

on file and available for review at the PVPC. A spreadsheet summary is provided as Attachment B.3 

PVPC Corrective Action: The PVPC recognizes the cost discrepancy and will transfer these funds plus all 

applicable interest back into the RLF Grant. This totals $76,362.62 which includes the duplicate draws and 

unverified costs.

OIG Response 3

The records PVPC provided in response to the audit report did not match up with the data in 

EPA’s accounting system. In response to the draft report, PVPC provided a spreadsheet, not 

from its accounting system, showing total funds drawn of $1,257,551.54. EPA accounting 

system records show PVPC received $1,261,665.44 of funds paid to PVPC under the 

cooperative agreement.

 

3 Attachment B not include in OIG final report because it was not readable. 
15-4-0072 20

Accounting Software

 PVPC's accounting system cannot provide an accurate, current, and complete disclosure of 

accounting results.

1. PVPC Accounting System. The EPA OIG has claimed that the PVPC accounting system cannot 

provide accurate, current, and complete disclosures and therefore cannot be relied upon to produce 

accurate financial reports. As noted above in Financial Issues, very unique circumstances including human 

error, human health and poor record-keeping led to the inability to provide specifically what the OIG wanted 

using solely the PVPC financial software program. This is the extreme exception and not the norm. The 

extraction of information for comparison purposes shown as Table 4 in the EPA OIG report is not clear to 

the PVPC. It is not known what the intent of shown values, the period of performance nor the accuracy of 

the comparison. Without more specificity, the PVPC cannot comment on the purpose of the Table 4 

presentation. Apart from the circumstances described above, once a contract or agreement is entered into 

the financial software system, it clearly tracks all expenditures and revenues. Further it can provide detailed 

vendor payment history by month as well as timesheet charges and reimbursements. This accounting 

system allows PVPC to track all contracts, including all federal awards, separately and independently.

The PVPC has engaged the use of this software program due to the program's ability to handle multiple 

contracts and budgets. The current Accountant, unlike the previous Accounting Managers, has purchased 

additional modules for the software, which even further enhances the PVPC's financial tracking and 

reporting abilities. 

PVPC's GMS Accounting Software is designed to handle activity accounting. It is specifically designed to 

account, report, and monitor budgets for multiple grants, contracts and activities. It is an integrated 

accounting system that performs all accounting activities such as; General Ledger, Cash Receipts, General 

Journal, Budget Preparation, Cost Allocation, Accounts Receivable & Payable, Payroll, Timesheet 

Accounting, Financial Reporting, & Security. It is capable of cost allocation for common costs, general and 

administrative costs, indirect costs, fringe benefits, leave costs, and various specialized cost pools. It 

complies with all state and federal requirements, audit standards, and reporting required for the Board of 

Directors and management team, and GASB 34 (the Governmental Accounting Standard Board 

requirement as state and local government follow). The GMS Accounting Software program is used by 

hundreds of comparable agencies to the PVPC which exist across the country, many of whom are EPA 

recipients. This includes four regional planning agencies in Massachusetts who receive a variety of state 

and federal funding similar to that of the PVPC.

As previously noted, every contract/project is assigned a project code and a revenue and expenses budget 

is entered into GMS. Staff time is charged to the project code and entered into Payroll. All direct expenses 

are entered into Expense reimbursements (travel/mileage) and Accounts Payable. These amounts are 

tracked and reported on Timesheet Charges by Activity and Project Expense/Element Charge Listing

reports. These amounts follow through onto the Revenue/Expense Report which represents the total 

summary of the project. The Revenue/Expenses reports identifies total revenue received, total salaries, 

indirect cost, and all direct expenses. It shows the original budget and the total amount spent in each 

budget category and what is unspent. All activity is reflected on this report. Sample GMS financial software 

reports are provided in Attachment C.

PVPC Corrective Action: No further action required.

OIG Response 4

During the audit, PVPC could not provide accurate information on the financial results of the 

agreement. In responding to the draft report, PVPC provided a spreadsheet from outside its 

accounting system that it says represents the total funds drawn but does not reconcile to EPA 

accounting system records. In responding to the draft report, PVPC has not provided the 

information necessary to show that its financial management system meets the federal 

standards under 40 CFR Part 31.
15-4-0072 21

Administrative Issues

 The wrong administrative requirements in PVPC's internal policies and procedures are referenced.

 Corrective action from previous audit report not implemented.

1. PVPC Internal Policies and Procedures. As a result of recommendations from PVPC's auditor, the 

PVPC revised its Operations Manual as it pertained to certain financial controls and operations. These 

documents and revisions were sent to U.S. EPA Region I for review and comment. Working directly and 

cooperatively with Region I in July/August 2013, the PVPC incorporated very specific language pertaining 

to federal compliance including accounting guidance, cost allocation, and charging of costs to federal 

awards. A clear miscommunication between PVPC and EPA Region I resulted in the use of CFR references 

as it pertains to Non-Profit Organizations as opposed to State and Local Governments. The PVPC is 

recognized as a form of local government as a "political subdivision of the Commonwealth of 

Massachusetts" and has always operated in that manner including financial compliance. 

PVPC Corrective Action: The PVPC has reviewed the 9-page Section III Financial Control Policies and 

Procedures of its Operations Manual and has corrected the twelve incorrectly cited OMB Circular and CFR 

references within Section. These will be formally adopted at an upcoming PVPC Executive Committee 

meeting. See Attachment D for modified policies.

2. Corrective Action From Previous Audit Report Not Implemented. The EPA OIG Reports states the 

following:

"The Single Audit Report for the period ending June 30, 2010 reported significant deficiencies in internal 

control over major programs. In its corrective action plan, the PVPC stated that it would be reconciling all 

support documentation for the Brownfields RLF Program. This corrective action was never implemented".

This corrective action, was, in fact, implemented. Due to the issues detailed in Financial Issues above, the 

ability to initiate the corrective action was significantly delayed. PVPC Single Audits prior to FY2010 were 

exceptional with no findings or significant deficiencies. PVPC's FY13 Single Audit, that being the first audit 

under the PVPC Accountant hired in January 2012, also resulted in no findings or significant deficiencies 

with only minor recommendations (ie enhance inventory records, change passwords more often, obtain 

additional software licenses, etc.). The PVPC Single Audits for FY2010, 2011, and 2012 were subject to 

the financial actions of the previous PVPC Accounting Manager who was put on notice and ultimately 

terminated due to poor job performance including adherence to PVPC financial policy as it related to recordkeeping, attention to details, retention of records, etc. as well as inadequate annual audit preparation. As 

a result of the latter, the PVPC's Single audits were substantially delayed each fiscal year such that by the 

time a fiscal year audit was completed, the entirety of the subsequent fiscal year had already passed, 

rendering it impossible to correct the prior year identified issues in that subsequent fiscal year. This was 

further complicated by the circumstances previously described concerning the PVPC's previous Accounting 

Manager due to health-related performance issues as much of the corrective actions required was the 

responsibility of the Accounting Manager. See timeline for audits below.

 Single Audit FY10 (7/1/09 - 6/30/10) - completed late Spring 2011 (90% of FY11 passed)

 Single Audit FY11 (7/1/10 - 6/30/11) - completed late June 2012 (100% of FY12 passed)

The PVPC's FY10 management response to the Single Audit was made after the entirety of FY11 had 

passed. Thus, although the response and intent was to correct the identified issues for FY11, it was not 

feasible to do so. These issues carried over to FY11 and were further complicated by the health and 

performance issues of the previous Accounting Manager.

The PVPC has, in fact, put into place numerous changes as a result of the FY10 and FY11 Single Audit 

concerns and these changes have been discussed and shared with the EPA Region I office prior to the 

EPA OIG site visit(s). This includes:
15-4-0072 22

 Hiring of a new Accountant w/public sector and financial software experience.

 Hiring a 30-hr per week Accounting Assistant.

 Adopting new Financial Control Policies and Procedures.

 Adopting new checks and balances for oversight, disbursement of checks, and related financial 

activity which involves direct interaction and approval from the Deputy Director of Operations.

 Hiring a contractor to review all Brownfields Programs to identify any discrepancies, required 

adjustments, and reconciliations.

The above actions were all developed and implemented prior to the EPA OIG site visit(s). As noted 

previously, the contractor report concerning this audit was in draft form on mid 2013 and not completed 

until early 2014. As a result, the PVPC opted to wait until the OIG's examination was complete so as to 

confer with any amounts that may have been required to be transferred back into the appropriate accounts. 

This was fully disclosed to the EPA OIG at the time of the examination, including estimated monetary 

amounts expected to be transferred. 

PVPC Corrective Action: The PVPC has fully addressed all issues which were identified in its FY10 and 

FY11 Single Audits. 

OIG Response 5

We disagree that the corrective action was implemented at the time of our review. The fiscal 

year 2010 Single Audit’s corrective action plan stated, “The Commission will also back-up all 

payment reimbursement and quarterly reports to EPA with proper support documentation 

reflecting all allowable costs.” Instead, vendor invoices and timesheets were maintained in 

different locations and invoices did not reconcile to individual payment requests.

Project Concerns

 Davis-Bacon Act documentation not maintained.

 Although the PVPC met the intent of the Agreement concerning remediation, not all sites were 

developed and reused.

1. Davis-Bacon Compliance. The EPA OIG states in its report that the PVPC bid not obtain payroll 

documentation for demolitions services provided by a subcontractor for the Town of Monson, South Main 

Street Project as "sampled by an invoice from the subcontractor". The PVPC has a designated "payroll 

compliance officer" who works with project staff to review certified payrolls and identify any issues that need 

to be resolved. Payroll compliance records are maintained in separate lose-leaf notebooks for each project 

and includes the state and federal wage rates (as applicable), wage interviews, certified payrolls, 

correspondence, and a summary sheet of actions. The South Main Street Project Bid Document contained 

the applicable federal wage rates. A notebook was maintained for this project throughout its entirety 

including the submitted certified payrolls. The payroll compliance notebook was in off-site storage at the 

time of the EPA OIG site visit and therefore not available for its review. The OIG requested payroll 

information from staff who was not in the employ of the PVPC when the Monson South Main Street Project 

took place and therefore that staff person was not aware that these records were transferred to off-site 

storage. The OIG made no requests for such records to PVPC management staff or other project staff who 

were present when the Monson project occurred. Based upon a review of the five 

contractors/subcontractors involved in this project, it appears that all were paid according to federal wage 

requirements. Complete records are on file and available for review at the PVPC. A sample payroll and 

compliance review is provided as Attachment E.

PVPC Corrective Action: No further action required.
15-4-0072 23

OIG Response 6

We reviewed the documentation provided to us in PVPC’s response, and conclude that it 

shows compliance with the Davis-Bacon Act. We therefore removed this finding from the 

report.

2. Site Developement and Reuse. The EPA OIG states in its report that although the intended results of 

the Agreement were met as four properties were remediated, three of these have not been reused. PVPC's 

Agreement with the EPA does not mandate it as the responsibly party to insure actual site redevelopment. 

The four properties listed by the OIG include those in the Town of Ware, Town of Monson, and two in the 

City of Springfield. The actual status of these sites is as follows:

Ware - The Ware site was remediated and now serves as the site for town's new fire station. (See cover 

photo).

Monson - Due to the rapidly deteriorating condition of the building originally slated for asbestos and related 

clean-up, the original plan to rehabilitate the existing structure was deemed infeasible. As a result, the 

building was abated, and a portion of the site contained through asphalt encapsulation. A RAO-P closure 

was filed under the MA DEP Clean-up Program. Due to the site's proximity to an abutting stream and small 

size of the remaining developable land, redevelopment options are extremely limited. The Town of 

Monson's efforts to market this property were sidetracked in June 2011 due to the occurrence of a tornado 

through its downtown which severely impacted or destroyed numerous businesses and private homes. The 

town's municipal office building was also severely affected and deemed unsafe with a new facility currently 

being built. At the present time, the site is being used by the town for temporary storage. When the town 

has fully recovered from the effects of the tornado and when the market conditions improve, the PVPC 

stands ready to assist the Town in accordance with the requests of its chief elected officials to advance the 

redevelopment of this property. 

Springfield (Asylum property) - The Asylum property has been fully remediated and redeveloped. The 

building on the site was fully rehabilitated with most of the first floor serving as a restaurant/banquet facility 

operated in partnership with one of the city's most popular restaurants. Since its conversion, this site has 

hosted regular and numerous downtown events. A smaller portion of the 1st floor remains unoccupied with 

the intended reuse being a smaller food establishment. There remains limited development options on the 

partial and very small second floor. The property owner is considering housing as a possible option for that 

space. The remaining portion of the site is a fully paved parking lot for the building users and occupants 

and adjacent restaurant. This parking lot is also available to serve as space for a farmer's market during 

the late spring - early fall months. (See cover photo).

Springfield (Chapman Valve) - This site contains multiple parcels of which only one was assisted using EPA 

RLF funds. Collectively these parcels were to serve as the basis for a larger urban redevelopment plan. 

Based on recent discussions with a developer interested in installing solar panels throughout the former 

Chapman property , the City of Springfield is currently finalizing an RFP for sale and redevelopment of this 

site. But for the use of EPA RLF monies, this redevelopment RFP for reuse of this site would not be moving 

forward.

PVPC Corrective Action: No further action required. 
15-4-0072 24

PVPC Comment on EPA OIG Report Recommendations

and Potential Monetary Benefits

Rec. 

No.

Page 

No.

Subject Claimed 

Amount

Comment

1 7 Place PVPC on a reimbursement 

basis for all EPA grants.

NA The PVPC has contacted 

EPA Region I and is 

submitting all pay 

requisitions to Region I 

for advance approval. 

Once approval is 

obtained, a draw can be 

made, funds received 

and payment made in 

the exact amount 

authorized.

2 7 Issue a stop work order for this CA 

until PVPC reconciles its accounting 

records and is able to provide 

accurate information on costs 

incurred for the grant.

NA

The PVPC has active 

loans and sub grants in 

process as discussed 

with Region I. The 

PVPC has 

documentation for costs 

incurred with exception 

to that detailed in 

PVPC's response to the 

OIG.

3 7 Require PVPC to transfer program 

income back to the RLF.

$19,000 PVPC concurs to 

transfer the agreed 

amount of program 

income back to the RLF 

account.

4 7 Verify that PVPC has a financial 

management system that meets 

federal standards established under 

40 CFR s31 prior to any future 

awards.

NA

PVPC's financial 

management system 

complies with all state 

and federal 

requirements. This 

accounting system 

allows PVPC to track all 

contracts, including all 

federal awards, 

separately and 

independently.

5 7 Question and recover the $1,261,665 

of federal funds drawn at the time we 

began our review.

$1.261 

million

PVPC recognizes that 

there is a total of 

$76,362.62 in

unverifiable costs 

(duplicate draws, 

incorrect charge); $6,053 

in charges to a separate 

contract; and $16,588.91 

of ineligible indirect 

expense that will be paid 

back to the RLF grant.
15-4-0072 25

Closing

The Pioneer Valley Planning Commission takes its role as a public agency working with local, state and 

federal governments very seriously and strives to insure that public funds are spent properly and in a 

manner which truly serves the best interests of the public. Although we clearly recognize that to some 

degree, much in part due to reasons not readily controllable, we did not fully achieve that with our 

Agreement with the U.S. EPA. We have identified those practices and areas needing modifications and 

have put all the necessary protocols in place to address identified issues and to insure that replication does 

not occur.

I sincerely trust that this response comprehensively and satisfactorily addresses the issues outlined in the 

EPA OIG's report. If you have further questions, please do not hesitate to contact me. Thank you for your 

ongoing guidance and support.

Sincerely,

Timothy W. Brennan, Executive Director

Attachments

Attachment A: OMB Circular A-87 Cognizant Agency Negotiation Agreements

Attachment B: Spreadsheet Summary of PVPC Drawdowns and Associated Expenses4

Attachment C: Sample GMS Financial Software Reports

Attachment D: PVPC Financial Control Policies and Procedures (as modified)

Attachment E: Sample Payroll Compliance Review and Monitoring5

 

4 Not included in OIG final report because the information was not readable.

5 Not included in OIG final report because it included confidential business information.
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Attachment A: OMB Circular A-87

Cognizant Agency Negotiation Agreements
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Attachment C: Sample GMS Financial Software Reports
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Attachment D: PVPC Financial Control Policies

and Procedures (as modified)

S. III. PVPC FINANCIAL CONTROL POLICIES AND PROCEDURES

GENERAL

1. The Executive Director formulates financial policies, delegates administration of the 

financial policies and daily oversight to the Deputy Director for Operations, and reviews 

operations and activities.

2. Financial duties and responsibilities are separated so that no one employee has sole 

control over cash receipts; disbursements; payroll; reconciliation of bank accounts; etc.

3. The Financial Section consists of the Accountant, Accounting Assistant and Payroll 

Coordinator as overseen by the Deputy Director and who report to the Executive Director.

4. Contracts in the amount of $5,000 or more require approval from the PVPC Executive 

Committee authorizing the Executive Director to negotiate and execute.

Project Oversight

1. Project staff shall meet with the PVPC Accountant and/or reconcile financial records 

on a quarterly basis, or more if required, to insure that financial records correspond 

between project records and the Accountant’s financial records.

2. Financial notebooks shall be created by project managers for all major contracts and/or 

multi-year contracts and contracts and will contain contracts, amendments, extensions, 

budget information, work plans and scope, subcontracts, and all other relevant 

information that can assist with project oversight and budget management. The 

Accountant will keep his/her own project folder on the same.

3. Contracts involving cash matches and/or restrictions on eligible expenses shall require 

separate documentation by project staff including relevant support documentation, as 

appropriate and/or required. The Accountant makes any necessary journal entries to a 

project in the financial software system and maintains evidence of Executive Committee 

approval and vote of a cash match.

4. Monthly reviews of the Revenue and Expenditure Reports of all open PVPC project 

contracts will be conducted by the Accountant and Deputy Director for Operations to 

identify any potential concerns, unusual spending trends, cost overruns or required 

reallocations.

Cash Receipts

1. The Agency Receptionist/Administrative Assistant opens all checks received in the 

mail and records on a log sheet all relevant check information including payment from, 

amount, date, check number and to whom the check goes. All checks are immediately 

brought to the Accountant or if a program check, to the respective Financial Coordinator.
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2. All receipts will be deposited intact. No disbursements will be made from cash or 

check receipts prior to deposit.

3. The Accountant or Accounting Assistant will record each cash payment received. 

Checks and cash shall be locked in a secure location until taken to the bank.

4. Checks are scanned upon receipt and deposited electronically. Paper checks are held 

in a secure location for 60-90 days and then shredded.

5. Both the Executive Director and Deputy Director receive a copy of account history 

(deposits, checks issued, payments made) for review.

Cash/Check Disbursements

1. All satisfactory invoices/check requests will be approved (indicated by 

initialing/signature) by the appropriate Project or Section Manager, with an appropriate 

project number.

Only original invoices should be submitted for payment. Sales tax will be deducted from 

the amount to be reimbursed. No reimbursement for alcohol or tobacco is allowed. 

Proper procurement procedures must be followed in order for a check or reimbursement 

to be issued. See Section V.

2. All approved invoices will be forwarded to the Deputy Director who will review all 

invoices for mathematical accuracy, validity, conformity to the budget and compliance 

with contract requirements.

3. Approved invoices will be assigned a General Ledger (GL) code by the Accounting 

Assistant as reviewed and approved or modified by the Deputy Director.

4. Upon completion of Steps 1-3 above, final approval of the Executive Director is 

required for all invoices.

5. Approved invoices will be entered into the PVPC financial software program in 

Accounts Payable.

6. All entered outstanding invoices will appear on an Accounts Payable listing. Check 

disbursement and actual release of payment is determined by the Deputy Director.

7. The Accountant will prepare checks on a bi-weekly basis or as otherwise required and 

issue payment as authorized.

8. After the checks are printed, individual voucher labels listing the vendor name, voucher

#, amount of check, invoice # and check date are also printed and are affixed on the 

corresponding A/P invoice and filed.
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9. Authorized check signers include the PVPC Executive Director, Executive Committee 

Chair, Executive Committee Vice-Chair, Executive Committee Treasurer, and Executive 

Committee Assistant Treasurer.

10. Checks in the amount of $5,000 or more require a two-party signature.

11. In no event will:

a) invoices be paid unless approved by an authorized signer.

b) blank checks (checks without a date or payee designated) be signed in 

advance.

c) checks be made out to “cash” or “bearer,” etc.

d) checks be prepared on verbal authorization, unless approved by the Executive 

 Director.

12. Blank checks are locked in a fireproof cabinet in the Accountant’s office. 

13. Subsequent check #’s are always verified by confirming with the check register book.

Bank Reconciliations

1. The Accounting Assistant will reconcile the bank statements monthly. 

2. The PVPC Executive Committee will receive statements of checks issued on a regular 

 basis.

3. The Deputy Director shall verify the reconciliation of the bank accounts on at least a

 quarterly basis.

4. On all checks outstanding over 120 days, the Accountant will take appropriate action.

Petty Cash

1. Petty Cash is maintained and tracked by the Administrative Support Section and 

reconciled regularly by the Accounting Assistant. Petty Cash Requests and Petty Cash 

Reimbursement Forms must be used to receive funds in advance or for reimbursement 

of a purchase made. These forms require Section Manager authorization, a project code 

designation and a strict accounting of the funds used/requested. See Section IV –

Miscellaneous Practices and Guidelines.

Accounts Receivables

1. The Accountant prepares invoices monthly, quarterly or as deemed necessary. 

2. Invoice amounts are reconciled with the financial software program’s Revenue and 

Expenditure Reports.
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3. Generated invoices are issued to the respective client with copies given to the 

appropriate PVPC Project Manager and the Accounting Assistant. Upon receipt, the 

Accounting Assistant enters the invoice information into Accounts Receivable module of 

the financial software program.

Files

1. Financial records are maintained in the PVPC Accountant’s office for 2 years upon 

project close-out and thereafter placed in off-site storage. Stored files shall be maintained 

for a period of seven (7) years from the date of Program Close-out, or if such records 

become the subject of audit findings, they shall be retained until such findings have been 

resolved, whichever is later. 

FEDERAL COMPLIANCE

Accounting Guidance

The following are procedural and compliance guidelines to be followed by the PVPC 

financial and accounting personnel in the administration on federal funds:

 Identify source and application of funds

 Maintain controls and accountability of funds and property

 Compare outlays with budgeted amounts

 Minimize time between receiving fed funds and issuing payments

 Adhere to procedures to insure reasonableness, allocability and allowability of 

costs

 Insure that records are supported by source documents

 Do not exceed SES4 level for payment of consultants for EPA grants

 Cash advances should be limited to amount needed (31.21)

 Payments should be made within 5 business days of grant draws - 31 CFR 205 

(Dept of Treasury applies)

 Must be able to account for the receipt, obligation and expenditure of funds

 Maintain advances in interest bearing accounts

 Cost sharing shall be verifiable (40 CFR 31.24)

 Volunteer services can be used (at their regular rate or comparable rate in 

grantees organization) along with fringes, no indirect costs though

 Volunteer services shall be documented in same manner as grantees employees

 Program income should be added to project funds, used to finance the non Fed 

share or deducted from the total project cost (40 CFR 31.25)

 Budgets developed in accordance with 40 CFR 31.20
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 Grantees are required to report budget deviations. Grantees to get prior approval 

for certain conditions

 Annual A133 audits must be done when receiving >$500,000 of Fed funds (40 

CFR 31.26)

 Grant participation for individual consultant charges follows MGL C30B

 Record retention per 40 CFR 31.42. At a minimum, keep documents for 3 years 

after final pay.

 Federally funded equipment with a useful life of more than one year and with an 

acquisition cost of $5,000 or more per unit will be identified in the PVPC's 

Inventory Log. 

 A physical inventory of PVPC equipment with a remaining useful life value 

(excluding furnishings) shall be conducted on a biennial basis.

Cost Allocation

Direct Costs

Costs that can be identified specifically with a particular funding source or grant are 

directly charged.

Shared costs are prorated individually as direct costs to each award, contract, or funding 

activity using a base appropriate to the cost being prorated. A spreadsheet is developed 

that lists the basis and calculates a fair distribution of shared cost. 

Examples of types of shared costs are:

 general administration expenses of the organization, such as salaries and 

expenses of executive officers, personnel administration, and accounting;

 costs of operating and maintaining facilities (for buildings shared by more than 

one program or by administrative staff and program staff), such as utilities, 

janitorial; and

 costs of shared program staff and equipment.

Program Costs

Program costs include, but are not limited to:

(1) Personnel and non-personnel costs directly related to the provision of program 

services, training, and transportation for staff, parents and volunteers.

(2) Costs of functions directly associated with the delivery of program services through 

the direction, coordination or implementation of a specific program area.

(3) Costs of the salaries of program specialists and managers, program staff, janitorial 

and transportation staff involved in program efforts, and the costs associated with 

parent involvement and volunteers.
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(4) Expenses related to program staff functions, such as the allowable costs of fringe 

benefits, travel, per diem and transportation, training, food, center/classroom supplies 

and equipment, parent activities funds, insurance, and the occupation, operation and 

maintenance of program component space, including utilities.

Dual benefit costs

Some costs benefit the programs as well as the development and administrative functions 

within the Pioneer Valley Planning Commission. In such cases:

(1) The Pioneer Valley Planning Commission must identify and allocate appropriately the 

portion of the costs that are for development and administration.

(2) Dual benefit costs include, but are not limited to, salaries, benefits and other costs 

(such as travel, per diem, and training costs) of staff that perform both program and 

development and administrative functions. The Pioneer Valley Planning Commission 

must determine and allocate appropriately the part of these costs dedicated to 

development, program and administration.

(3) Space costs and costs related to space, such as utilities, are frequently multiple 

benefit costs. The Pioneer Valley Planning Commission must determine and allocate 

appropriately the percentage of space dedicated to development and administration 

and program.

Charging of Costs to Federal Awards

Overview

It is the policy of the Pioneer Valley Planning Commission that only costs that are 

reasonable, allowable and allocable to a Federal award shall be charged to that award 

directly or indirectly. All unallowable costs shall be appropriately segregated from 

allowable costs in the general ledger in order to assure that unallowable costs are not 

charged to Federal awards.

Segregating Unallowable From Allowable Costs

The following steps shall be taken to identify and segregate costs that are allowable and

unallowable with respect to each federal award:

1. The budget and grant or contract for each award shall be reviewed for costs 

specifically allowable or unallowable. 

2. Accounting personnel shall be familiar with the allowability of costs provisions of

OMB Circular A-87, "Cost Principles for State and Local Governments", 

particularly:

a. The list of specifically unallowable costs found in Attachment B (Selected 

Items of Cost), such as alcoholic beverages, bad debts, contributions, fines 

and penalties, lobbying, etc.
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b. Those costs requiring advance approval from Federal agencies in order to 

be allowable in accordance with Attachment B, such as foreign travel, 

equipment purchases, etc.

3. No costs shall be charged directly to any Federal award until the cost has been 

determined to be allowable under the terms of the award and/or OMB Circular A87.

4. All items of miscellaneous income or credits, including the subsequent write-offs 

of uncashed checks, rebates, refunds, and similar items, shall be reflected for grant 

accounting purposes as reductions in allowable expenditures if the credit relates 

to charges that were originally charged to a Federal award or to activity associated 

with a Federal award. The reduction in expenditures shall be reflected in the year 

in which the credit is received (i.e. if the purchase that results in the credit took 

place in a prior period, the prior period shall not be amended for the credit.)

Criteria for Allowability

It is the policy of the Pioneer Valley Planning Commission that all costs must meet the 

following criteria in order to be treated as allowable direct or indirect costs under a Federal 

award:

1. The cost must be “reasonable” for the performance of the award, considering the 

following factors:

a. Whether the cost is of a type that is generally considered as being 

necessary for the operation of the organization or the performance of the 

award;

b. Restraints imposed by such factors as generally accepted sound business 

practices, arm’s length bargaining, Federal and state laws and regulations, 

and the terms and conditions of the award;

c. Whether the individuals concerned acted with prudence in the 

circumstances;

d. Consistency with established policies and procedures of the Organization, 

deviations from which could unjustifiably increase the costs of the award.

2. The cost must be “allocable” to an award by meeting one of the following criteria:

a. The cost is incurred specifically for a Federal award;

b. The cost benefits both the Federal award and other work, and can be 

distributed in reasonable proportion to the benefits received; or

c. The cost is necessary to the overall operation of the Organization, but, 

where a direct relationship to any particular program or group of programs 

cannot be demonstrated.

3. The cost must conform to any limitations or exclusions of OMB Circular A-87 or 

the Federal award itself.
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4. Treatment of costs must be consistent with policies and procedures that apply to 

both federally financed activities and other activities of the Organization.

5. Costs must be consistently treated over time.

6. The cost must be determined in accordance with generally accepted accounting 

principles.

7. Costs may not be included as a cost of any other federally financed program in the 

current or prior periods.

8. The cost must be adequately documented.

Cost Sharing and Matching

It is the policy of the Pioneer Valley Planning Commission to value contributed services 

and property that are to be used to meet a cost sharing or matching requirement at their 

fair market values at the time of contribution, unless award documents or Federal agency 

regulations identify specific values to be used. 

The Pioneer Valley Planning Commission shall claim contributions as meeting a cost 

sharing or matching requirement of a Federal award only if all of the following criteria are 

met:

1. They are verifiable from records.

2. They are not included as contributions for any other federally assisted project or 

program.

3. They are necessary and reasonable for proper and efficient accomplishment of 

project or program objectives.

4. They are allowable under OMB Circular A-87.

5. They are not paid by the Federal government under another award, except where 

authorized by Federal statute to be used for cost sharing or matching.

6. They are provided for in the approved budget when required by the Federalawarding agency.

7. They conform to all provisions of OMB Circular A-102.

8. In the case of donated space, the space is subject to an independent appraisal or 

market survey to establish its value.

Contributed services used for cost sharing or matching purposes shall be valued at rates 

consistent with those rates paid for similar work in the Commission (match up experience 

and skill level), including an estimate of reasonable fringe benefits. In cases in which the 

required skills are not found in the Commission, rates used shall be consistent with those 

paid for similar work in the labor market in which competes.

It is the policy of the Pioneer Valley Planning Commission to require volunteers, when 

necessary, to document and account for their contributed time.
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Appendix B

Region 1 Response to Draft Report

FROM: Michael Kenyon, EPA Region 1, Assistant Regional Administrator

TO: Arthur A. Elkins, Jr. Inspector General 

DATE: November 7, 2014

OIG Project Number: OA-FY14-0171

SUBJECT: Pioneer Valley Planning Commission Needs to Improve Its Compliance with 

Federal Requirements, as $1.2 Million in Grant Costs Are Questioned 

Below please find Region 1’s comments concerning the above referenced IG draft report. 

General Comments:

The AFC coordinated with the Program Office and the Grants Management Office to gather the 

Agency’s comments regarding the Inspector General’s draft report for the review of Pioneer 

Valley Planning Commission (PVPC. The Region has worked with this Cooperative Agreement 

recipient (CAR) for a long time and does feel that this CAR has made significant 

accomplishments in reducing human health risks in New England with the work they have 

supported and completed. 

Specific Comments on Draft Report Sections:

 Title Page:

 R1 Comment: There should be consistency with the titles used on IG reports. 

The majority of other Audits/Reviews conducted by the IG for reviewing 

Assistance Agreements are titled “Examination of costs claimed under EPA

Grants ...”. The IG should consider changing the title to be consistent with other 

Attestation reviews conducted for grantees to “Examination of costs claimed 

under EPA Brownfields Grant 97119201”.
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 At a Glance -What We Found 

 Brownfields Program Comment: The last sentence in this section states that the 

goal of the EPA’s Brownfields program is not achieved when remediated sites are 

not redeveloped and reused. The Regional Brownfields program does not agree 

with this statement made by the IG because the grantee achieved the goals of the 

Brownfields program by getting contaminated land ready for reuse. This is 

explained further in the comments to Chapter 4 below. 

 Chapter 3- PVPC did not comply with Federal requirements

 PVPC Requested Reimbursement for Unallowable Costs- R1 Comment: The 

Draft IG report does not identify that PVPC had identified some of the 

unallowable costs prior to the commencement of this review and had indicated to 

the Region that PVPC had hired a financial consultant to reconcile and balance 

the EPA RLF financial through 6/30/2012. PVPC had also indicated that a final 

report with recommendations of actions would be forthcoming prior to the IG’s 

review.

 PVPC did not maintain required documentation: The Draft IG report states 

that PVPC did not obtain payroll documents showing contractor’s compliance 

with the Davis-Bacon Act for demolition services provided by a subcontractor for 

the Town of Monson, South Main Street School project. 

Brownfields Program comment: Region 1 received the following comment 

form the National Brownfields program *1, which the Regional Brownfields 

program also supports: 

“EPA is aware of the challenges of adhering to Davis-Bacon wage rate 

requirements. This often comes up as an issue among our RLF grantee 

community, so we have covered Davis Bacon compliance requirements on 

two webinars in the past year in an effort to address these concerns and bring 

about a more consistent approach to complying with Davis Bacon.

Additionally, this topic has been discussed in sessions with RLF grantees at 

the past several Brownfields Training Conferences, as well as a Davis-Bacon 

one-pager that was developed in 2009 to assist RLF grantees.”

 4- Properties have been remediated, but not reused

 Goal of the Brownfields Program is to cleanup and reuse: Brownfields 

Program comment: Region 1 received the following comment form the National 

Brownfields Program *2, which the Regional Brownfields program also supports: 

“There is an entire chapter (p9) dedicated to the statement first seen in the 

summary that “the goal of the EPA’s Brownfields program is not achieved 

when remediated sites are not redeveloped and reused.” The Brownfields 

Program does not set a goal to reuse sites – we say our goal is to empower 

communities with tools and information to reuse sites. The comment implies 

that we have control over what the market wants to do with a brownfield site 

when we do not. The RLF funds cleanups, not redevelopments, and the 

Pioneer Valley Planning Commission RLF funded four cleanups, so from the 
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program’s perspective the grantee achieved the goals of our program by 

getting contaminated land ready for reuse.”

(Footnotes*1 and *2 – Both of these comments were submitted by Megan Quinn the National 

Brownfields RLF Coordinator.) 

 Status of Recommendation and Potential Monetary Benefits

The Agency is submitting Attachment A, the high-level intended corrective actions and 

estimated completion dates, for review and concurrence by the IG.

Please contact Valerie Marshall, the Region 1 Audit Follow-up Coordinator, of my staff at 617-

918-1674, if you have any questions concerning this memorandum.

cc: Janet Kasper, US EPA Office of Inspector General

 Mary Anne Strasser, US EPA Office of Inspector General 

 Mega Quinn, US EPA National Brownfields RLF Coordinator

 Frank Gardner. US EPA Region 1 Brownfields Program

 Cheryl Scott, US EPA Region 1 Grants Management Officer
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ATTACHMENT A

O = Recommendation is open with agreed-to corrective actions pending. 

C = Recommendation is closed with all agreed-to actions completed. 

U = Recommendation is unresolved with resolution efforts in progress.

No. Recommendation Status Comments Planned Completion 

Date

Claimed 

Amount

Agreed 

to 

Amount

1 Place PVPC on a 

reimbursement basis 

for all EPA grants. 

C All active EPA Assistance 

Agreements (4) are now on 

reimbursement. 

September 18, 2014.

2 Issue a stop work 

order for this CA until 

PVPC reconciles its 

accounting records 

and is able to provide 

accurate information 

on costs incurred for 

the grant.

O The CAR has agreed that it 

will work with Region 1 to 

provide the necessary support 

documentation to reconcile 

PVPC’s accounting records 

for this grant award.

The CAR has 

proposed a completion 

date for 3rd quarter 

FY2015.

3 Require PVPC to 

transfer program 

income back to the 

RLF.

O The CAR has proposed that 

the agreed amount for 

program income to be repaid 

should be $24,704.41. Once 

the Region has reviewed the 

necessary back up 

documentation, it will 

determine if this amount is 

accurate. 

The CAR has 

proposed to repay the 

amount agreed to by 

the 2nd quarter 

FY2015.

$19,000

4 Verify that PVPC has 

a financial 

management system 

that meets federal 

standards established 

under 40 CFR § 31 

prior to any future 

awards.

U The Region will need to meet 

with the CAR and verify that 

PVPC has a financial system 

that meets federal standards.

The CAR has 

proposed a completion 

date for 4th quarter 

FY2015.

5 Question and recover 

the $1,261,665 of 

federal funds drawn at 

the time we began our 

review.

U The Region will need to meet 

with the CAR to review the 

support documentation and 

identify what costs the CAR is 

able to reconcile and verify as 

eligible grant expenses under 

this grant award. 

The CAR has 

proposed a completion 

date for 4th quarter 

FY2015.

$1,261,665
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Appendix C

Distribution

Regional Administrator, Region 1

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator

Deputy Regional Administrator, Region 1

Director, Grants and Interagency Agreements Management Division,

Office of Administration and Resources Management

Audit Follow-Up Coordinator, Region 1

Public Affairs Officer, Region 1

Executive Director, Pioneer Valley Planning Commission