U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 

 Audit Report 

EPA’s Contracts and Grants 

Workforce May Face Future 

Workload Issues 

 Report No. 11-R-0005 

 October 25, 2010

 
Report Contributors: Janet Kasper 

 Michael Petscavage 

 Matthew Simber 

 Shannon Schofield 

 Wendy Swan 

 Richard Valliere 

 Nancy Dao 

Abbreviations 

EPA U.S. Environmental Protection Agency 

FMFIA Federal Managers’ Financial Integrity Act 

FTE Full-Time Equivalent 

FY Fiscal Year 

OAM Office of Acquisition Management 

OCFO Office of the Chief Financial Officer 

OGD Office of Grants and Debarment 

OIG Office of Inspector General 

OMB Office of Management and Budget 

RATB Recovery Accountability and Transparency Board 

Cover photo: Recovery Act sign in Massachusetts. (EPA OIG photo)
 

11-R-0005 

 October 25, 2010

Catalyst for Improving the Environment

Why We Did This Review

We conducted this audit to 

determine whether the U.S. 

Environmental Protection 

Agency (EPA) has sufficient 

qualified contracts and grants 

staff to handle American 

Recovery and Reinvestment 

Act of 2009 work and 

non-Recovery Act work. 

Background

EPA received $7.2 billion 

from the Recovery Act. The 

Recovery Act also established 

the Recovery Accountability 

and Transparency Board. 

Among its responsibilities, the 

board determines whether 

there are sufficient qualified 

contract and grant personnel 

overseeing funds. EPA 

retained $81.5 million of 

Recovery Act funds for 

management and oversight. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2011/

20101025-11-R-0005.pdf

EPA’s Contracts and Grants Workforce 

May Face Future Workload Issues 

 What We Found

EPA should ensure that it has sufficient contracts and grants staff to perform both 

the Recovery Act and non-Recovery Act activities. EPA emphasized Recovery 

Act activities, resulting in non-Recovery Act activities being delayed or not 

completed. The Office of Management and Budget’s Recovery Act 

implementation guidance states that each agency is responsible for initiating risk 

mitigation actions, including evaluating workforce needs. The management and 

oversight resource allocations of the Office of Acquisition Management (OAM) 

and the Office of Grants and Debarment (OGD) were not always based on 

workforce analyses of the actual resources needed to accomplish Recovery Act 

activities. Factors such as the funding limitations set forth in the Recovery Act 

heavily influenced how Recovery Act management and oversight funds were 

distributed. As a result, non-Recovery Act resources were devoted to Recovery 

Act activities, leaving less time for staff to focus on non-Recovery Act 

administration, monitoring, and oversight. 

Unlike OGD, OAM does not have Agency-wide performance measures, thereby 

making it difficult to assess the impact of the Recovery Act on its staff and 

workload. The Government Performance and Results Act of 1993 requires the 

Federal Government to establish performance measures. In response to a prior 

Office of Inspector General audit recommendation, OAM developed performance 

measures for employee job standards that tied in to its strategic goals. However, it 

did not develop Agency-wide performance measures for contract functions. 

Without Agency-wide performance measures, OAM does not have valuable 

information it could use to effectively and efficiently manage its workforce and 

workload, and quickly address emerging issues such as impacts from Recovery 

Act work. 

 What We Recommend

We recommend that the Assistant Administrator for Administration and Resources 

Management direct OAM and OGD to review the September 30, 2010, metrics and 

prepare action plans for any measure that did not meet its goal in 2010. At the exit 

conference, EPA stated that if we allowed flexibility for the Agency to determine 

what delays would reveal a control weakness, it would agree with the 

recommendation. EPA stated that it agreed with the recommendation as it was 

revised in the final report. We also recommend that OAM develop and implement 

organization-wide performance measures to better manage its activities. OAM 

agreed to implement this recommendation. 

U.S. Environmental Protection Agency 

Office of Inspector General 

At a Glance
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL

October 25, 2010 

MEMORANDUM

SUBJECT: EPA’s Contracts and Grants Workforce May Face 

 Future Workload Issues 

 Report No. 11-R-0005 

FROM: Arthur A. Elkins, Jr. Mark Bialek for

Inspector General 

TO: Craig E. Hooks 

 Assistant Administrator for Administration and Resources Management 

This is the Office of Inspector General’s (OIG) report on the U.S. Environmental Protection 

Agency’s (EPA’s) contracts and grants workforce. This report contains findings that describe 

problems the OIG has identified and corrective actions the OIG recommends. This report 

represents the position of the OIG and does not necessarily represent the final EPA position. 

Final determinations on matters in the report will be made by EPA managers. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $393,447. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. You should include a corrective actions plan for agreed-upon 

actions, including milestone dates. 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. We have no objection to the further release of this report to the 

public. This report will be available at http://www.epa.gov/oig.
If you or your staff have any questions, please contact Melissa Heist, Assistant Inspector General 

for Audit, at 202-566-0899 or heist.melissa@epa.gov; or Janet Kasper, Product Line Director, at 

312-886-3059 or kasper.janet@epa.gov. 
EPA’s Contracts and Grants Workforce 11-R-0005

May Face Future Workload Issues 

 

Table of Contents 

Chapters 

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

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

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

 Noteworthy Achievements........................................................................... 2 

 Scope and Methodology.............................................................................. 2 

 

2 Potential Future Workload Issues .................................................................... 5 

OMB Implementation Guidance Requires Sufficient Qualified Staff............ 5 

 Guidance Identifies Assessing Workforce Needs and Skill Gaps ............... 6 

Indicators of Future Workload Problems ..................................................... 6 

 Performance Measurement Information Indicates Potential Staffing 

 Shortfalls for Grants............................................................................ 10 

 OAM Did Not Use Workforce Analysis to Establish Staffing Levels............ 11 

 Grant Resource Allocation Not Based on Workload Study ......................... 12 

 Potential Diminished Efforts in Monitoring and Oversight Reviews............. 12 

 Recommendation ........................................................................................ 13 

 Agency Comments and OIG Evaluation...................................................... 13 

3 OAM Needs Agency-Wide Performance Measures......................................... 15 

Performance Measurement Is Required by Law ......................................... 15 

OAM Does Not Have Performance Measures............................................. 15 

Past Implementation of Performance Measures Not Effective.................... 16 

Recommendation ........................................................................................ 16 

Agency Comments and OIG Evaluation...................................................... 17 

Status of Recommendations and Potential Monetary Benefits.............................. 18 

Appendices 

A Agency Response to Draft Report.................................................................... 19 

B Distribution ......................................................................................................... 24 

 
 11-R-0005 

Chapter 1 

Introduction 

Purpose 

The U.S. Environmental Protection Agency (EPA) Office of Inspector General 

(OIG) conducted this audit to determine whether EPA has sufficient qualified 

staff to administer its contracts and grants1 for both American Recovery and 

Reinvestment Act of 2009 (Recovery Act) (Pub. L. 111-5) and non-Recovery Act 

activities. We performed this audit in conjunction with the Recovery 

Accountability and Transparency Board’s (RATB’s) survey request for Agency 

workforce information. 

Background 

EPA received $7.2 billion from the Recovery Act. EPA distributed Recovery Act 

funds through the Clean Water State Revolving Fund, Drinking Water State 

Revolving Fund, Brownfields, Leaking Underground Storage Tanks, Diesel 

Emission Reductions, and Superfund Remedial programs. The Recovery Act 

provided EPA 1 to 4 percent of appropriated funds for program management and 

oversight purposes. EPA retained $81.5 million for Recovery Act management 

and oversight, which can be used for payroll, travel, awards, overtime, and 

compensatory time through Fiscal Year (FY) 2011. 

Section 1521 of the Recovery Act established the RATB to coordinate and 

conduct oversight of covered funds to prevent fraud, waste, and abuse. Section 

1523 of the Recovery Act directs the RATB to determine whether there are 

sufficient qualified contract and grant personnel overseeing funds. At the 

RATB’s request, OIGs from a number of agencies distributed surveys to their 

respective agencies to obtain information on current and projected staffing levels 

and qualifications of staff supporting Recovery Act activities. 

On behalf of the RATB, the U.S. Department of Commerce OIG presented the 

findings from the OIG surveys in its report, Review of Contracts and Grants 

Workforce Staffing and Qualifications in Agencies Overseeing Recovery Act 

Funds, issued in March 2010. The report states that the additional workload from 

the Recovery Act has put a strain on a significant portion of the contracts and 

grants workforce. It also reported on the impact of the additional workload from 

the Recovery Act on both Recovery Act and non-Recovery Act work, which 

included (1) award delays, (2) decreased postaward monitoring, (3) increased staff 

hours, and (4) increased use of supplemental staff. To ensure timely completion 

 

1

 The term “grant” also refers to cooperative agreements and interagency agreements. 

1 
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of the Recovery Act activities, the report found that agencies gave priority to their 

Recovery Act workload and devoted more full-time equivalents (FTEs) to 

Recovery Act contracts and grants. EPA’s response to the RATB survey is 

discussed on page 7. 

Noteworthy Achievements 

In signing the Recovery Act, the President expected agencies to make additional 

contract and grant awards as quickly as possible while adhering to regulations and 

procedures that would ensure a fair and competitive process. EPA assigned 

resources to emphasize Recovery Act actions. Specifically: 

 The Agency shifted experienced grant administration staff to handle the 

Recovery Act workload. Contract administration staff had other work 

priorities adjusted so that they were dedicated to Recovery Act work. 

 The Office of Grants and Debarment (OGD) assumed the responsibility 

from the regions for its advanced monitoring program for grant recipients 

for FY 2009. This allowed the regions to focus on the priority of 

awarding Recovery Act funds. 

The additional emphasis on Recovery Act activities resulted in EPA awarding 

grants quickly, which was one of the goals of the Recovery Act. The President 

signed the Recovery Act in February 2009 and, by September 30, 2009, EPA had 

awarded $6,483,386,620 in grants and $302,428,540 in contracts. 

To ensure effective internal controls, EPA developed a stewardship plan that sets 

out the Agency’s Recovery Act risk assessment, internal controls, and monitoring 

activities for Recovery Act funds. The EPA stewardship plan incorporates U.S. 

Government Accountability Office Internal Control Standards: control 

environment, risk assessment, control activities, information and communication, 

and monitoring. EPA monitors the risk assessment, mitigation, and oversight for 

its stewardship plan and prepares a quarterly report identifying any issues that 

arise from these monitoring reviews.

Scope and Methodology 

We conducted this audit from July 2009 to May 2010 in accordance with 

generally accepted government auditing standards issued by the Comptroller 

General of the United States. Those standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objective. After reviewing 

the results from preliminary research, we limited our audit to the Agency’s 

contracts and grants workforce, and did not include the program office support 

for contract and grant functions. We believe the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit objective. 

2 
 11-R-0005 

Our audit included interviewing Agency managers responsible for preparing the 

proposals on resources needed for Recovery Act activities for the Office of 

Acquisition Management (OAM), OGD, Office of the Chief Financial Officer 

(OCFO), and the various program offices receiving Recovery Act funds: Office 

of Solid Waste and Emergency Response (Superfund, Brownfields, and Leaking 

Underground Storage Tanks); Office of Air and Radiation (Diesel Emissions 

Reduction); and Office of Water (Clean Water and Drinking Water State 

Revolving Funds). We interviewed OAM and OGD managers regarding their 

efforts to determine the FTEs needed to manage grants and contracts and any 

studies that they had performed. 

We reviewed Agency performance measurement data and reports and the 

Agency’s response to the RATB survey. We also reviewed documentation and 

spoke with budget managers to obtain support for the decisions made in 

distributing management and oversight funds. Based on this information, we 

selected six regional offices with which to further discuss the impact the Recovery 

Act is having on their respective contract and grant workloads. Specifically, we 

spoke with management, contracting officers, and grant specialists in Regions 1, 

3, 4, 5, 8, and 9. We selected these regions based on a risk assessment formulated 

from information gathered during preliminary research, which included RATB 

survey results and interviews with various EPA managers. 

 Prior Audit Coverage 

We reviewed prior OIG reports for recommendations related to our audit 

objective. We made similar recommendations in Report No. 2005-P-00006, 

Office of Acquisition Management Can Strengthen Its Organizational Systems, 

issued February 17, 2005. The report recommended that the OAM Director 

develop an action plan with milestone dates to: 

 Establish measures for, and a means of measuring progress against, OAM 

strategic goals. 

 Complete its workload analysis and perform a workforce analysis. 

 Capture data needed to measure, analyze, and improve short- and longterm program performance in achieving its vision and goals, including: 

 cost and quality of its contract services 

 the extent to which OAM contracting offices are the preferred 

business partner for EPA offices 

 environmental and other benefits received from EPA contracts. 

Per the Management Audit Tracking System, all the recommendations have been 

completed and closed out. However, there continue to be weaknesses in the 

performance measurement system as discussed in Chapter 3. 

3 
 11-R-0005 

 Internal Control Structure 

In planning and performing our audit, we reviewed management controls related 

to our objective. Specifically, the Office of Management and Budget’s (OMB’s) 

Recovery Act implementation guidance (M-09-10 and M-09-15) instructed 

agencies to develop an overall agency plan for the Recovery Act. Such plans 

should describe processes in place for senior managers to regularly review the 

progress and performance of major programs, including identifying areas of risk. 

The OMB guidance instructed EPA to prepare individual program plans that were 

to address, among other things, barriers to effective implementation such as 

personnel skill gaps. EPA finalized its plans on May 15, 2009, and updated its 

plans June 1, 2010. We reviewed these plans to identify actions the Agency 

planned to take regarding staffing. 

We reviewed the Agency’s Recovery Act Stewardship Plan as it related to our 

audit objective. In its stewardship plan, the Agency identified additional steps 

and procedures it would follow to mitigate the risks identified for each of the 

programs receiving Recovery Act funds. 

We reviewed documents EPA completed in compliance with the Federal 

Managers’ Financial Integrity Act (FMFIA) for weaknesses related to staffing or 

workforce needs. We reviewed each of the region’s FY 2009 FMFIA assurance 

letters and the letters for the Office of Water, Office of Air and Radiation, Office 

of Administration and Resources Management, Office of Solid Waste and 

Emergency Response, and OCFO. 

4 
 11-R-0005 

Chapter 2 

Potential Future Workload Issues 

EPA should ensure that it has sufficient contracts and grants staff to perform both 

Recovery Act and non-Recovery Act activities. EPA emphasized Recovery Act 

activities, resulting in non-Recovery Act activities being delayed or not 

completed. OMB’s Recovery Act implementation guidance states that each 

agency is responsible for initiating risk mitigation actions, which include 

evaluating workforce needs. OAM and OGD management and oversight resource 

allocations were not always based on workforce analyses of the actual resources 

needed to accomplish the Recovery Act. Factors such as the funding limitations 

set forth in the Recovery Act heavily influenced how Recovery Act management 

and oversight funds were distributed. As a result, EPA’s current contract and 

grant staffing levels may not be sufficient to meet current and future nonRecovery Act contract and grant workload demands. 

OMB Implementation Guidance Requires Sufficient Qualified Staff 

OMB’s Recovery Act implementation guidance discusses the Agency’s 

responsibilities for initiating risk mitigation actions.2 These include: 

 Evaluating workforce needs to appoint qualified contracting officers, 

contracting officer technical representatives, and program managers with 

certification levels appropriate to the complexity of Recovery Act projects. 

 Paying special attention to ensuring that sufficient qualified acquisition 

personnel are available to perform contract administration and mitigate the 

government’s risk when using other than firm-fixed-price contracts. 

According to EPA’s Contract Management Manual, firm-fixed-price 

contracts place maximum risk and full responsibility for all costs on 

contractors. Cost-reimbursement contracts place the risk on the 

government and require extensive oversight. 

 Identifying mission-critical human capital needs for Recovery Act 

implementation and assessing the gap between the current workforce and 

Recovery Act human capital requirements. 

The OMB guidance states that agencies were to take certain actions, beyond 

standard practice, when planning to award contracts and grants. The guidance 

states that because of the critical importance of the Recovery Act, heightened 

attention to acquisition planning is needed to ensure, among other things, that the 

 

2

 OMB issued the original guidance on February 19, 2009 (M-09-10), and updated it on April 3, 2009 (M-09-15). 

5 
 11-R-0005 

Agency uses a sufficient, adequately trained workforce to award and monitor 

contracts. In planning for Recovery Act grants, the guidance states that the 

Agency should work with managers and staff at all levels to secure the resources 

needed to implement the Recovery Act. 

Guidance Identifies Assessing Workforce Needs and Skill Gaps 

 

In September 2005, the Office of Personnel Management developed a workforce 

planning model that included a five-step process3 for identifying and addressing 

the skill gaps of today and the human capital needs of tomorrow. According to 

the model, effective workforce planning enables the organization to develop a 

comprehensive picture of where gaps exist between current workforce 

competencies and future competency requirements, identify and implement gap 

reduction strategies, make decisions about how to best structure the organization 

and deploy the workforce, and identify and overcome internal and external 

barriers to accomplishing strategic workforce goals. 

OMB memorandum, Acquisition Workforce Development Strategic Plan for 

Civilian Agencies FY 2010-2014, dated October 27, 2009, provides a structured 

approach to improve the capacity and capability of the acquisition workforce. 

According to the memorandum, the demands on the critical federal acquisition 

workforce have grown substantially, while growth in the workforce has not kept 

pace. This increased workload leaves less time for effective planning and 

contract administration, which can lead to diminished acquisition outcomes. 

Advanced planning is necessary to develop clear requirements and performance 

measures that are used in the preaward phase to determine competition and 

negotiation strategies. Clear requirements and performance measures are also 

needed in the postaward phase to manage the contract and make appropriate 

award and incentive fee decisions. 

Indicators of Future Workload Problems 

The Agency has made the Recovery Act a top priority by shifting its existing 

contract and grant administration staff to Recovery Act activities at the expense of 

non-Recovery Act activities. In FY 2009, EPA awarded 576 Recovery Act grants 

and issued 139 Recovery Act grant amendments, for a total of 715 actions. EPA 

processed 162 Recovery Act contract actions, which included contract awards, 

modifications, delivery orders, and task orders. To give some perspective, in 

FY 2009, EPA processed a total of 8,130 contract actions and 10,014 grants 

actions. 

While Recovery Act actions represented only 2 percent of contract activity and 

7 percent of grant activity, we identified indicators that EPA’s current contract 

 

3

 The five steps of the workforce model are (1) set strategic direction; (2) analyze workforce, identify skill gaps, and 

conduct workforce analysis; (3) develop action plan; (4) implement action plan; and (5) monitor, evaluate, and 

revise. 

6 
 11-R-0005 

and grant staffing levels may not be sufficient to meet current and future nonRecovery Act contract and grant workload demands. Our conclusion is based on 

statements from EPA managers and staff contained in EPA’s response to the 

RATB survey, the FY 2009 FMFIA assurance letters, interviews, OAM’s 

Acquisition Human Capital Plan, and performance measurement information.

Workload Issues Highlighted in Response to the RATB Survey

The RATB provided EPA a survey to benchmark the contract and grant 

workforce communities. Each EPA program office, contract division, and region 

responded to the survey by identifying the number of staff for each position and 

the impact of the Recovery Act on their respective workloads. Overall, EPA 

responded that it had sufficient resources to manage Recovery Act grants and 

contracts. The individual survey responses provided examples of the impact 

Recovery Act activities were having, or may have, on non-Recovery Act contract 

and grant a tivities. c

Contracts.  Seven regions and one contract division responded that Recovery Act 

activities will have some impact on non-Recovery Act activities. For example, 

Region 1 responded that its workload tripled from what it had projected, and there 

was unanticipated workload for tracking, reporting, and stewardship. As a result, 

work was being delayed, sent elsewhere, or not completed. Region 7 stated that 

Recovery Act activities may potentially impact non-Recovery Act acquisitions 

through potential delays in reviewing non-Recovery Act progress reports, 

inability to review non-Recovery Act invoices for accuracy, and the potential 

inability to quickly resolve non-Recovery Act issues. 

 

Grants. Eight regions and one program office responded that Recovery Act 

activities will have some impact on non-Recovery Act activities. For example, 

Region 3 noted that there will be some delay in reviewing applications and 

making awards, reduced baseline monitoring efforts, and reduced follow-up to 

close out completed grants. Region 3 also stated that it would reduce the number 

of meetings with the program offices. Region 10 indicated it was deferring or 

cancelling postaward monitoring activities. The Region’s customer service level 

had dropped because the processing time for non-Recovery Act awards has 

increased. Region 10 also indicated that the additional workload may lead to 

employee stress and errors. 

EPA indicated concerns throughout the survey that the regions’ monitoring 

activities performed for Recovery Act and non-Recovery Act contracts and grants 

may be delayed. These monitoring activities were put into place to reduce risk to 

the government and to ensure that the government is getting what it paid for. In 

the cover letter for the RATB survey, dated September 4, 2009, EPA’s Senior 

Accountable Official for the Recovery Act wrote: 

 

7 
 11-R-0005 

The Survey results also show that in making Recovery Act 

implementation our top priority, we have had to disinvest in some 

of our non-Recovery Act grant and contract work. This includes, 

among other things, delays in non-Recovery Act awards and 

closeouts, less frequent post-award monitoring and extending 

milestones under our Grants Management Plan. The Agency will 

continue to carefully assess the level of disinvestment over the next 

two years to ensure it does not jeopardize our internal controls for 

effective grants and contracts management. 

We asked OAM and OGD how they were continuing to assess the level of 

disinvestment to ensure the disinvestment does not jeopardize internal controls for 

effective management in the grants and contracts areas. According to OAM 

managers, OAM divisions were not noticeably affected by the workloads created 

by the Recovery Act. Regional contract officer supervisors identified some nonRecovery Act disinvestments, but they were temporary and were discussed with 

program offices well in advance. The OGD director stated that the office is 

monitoring Recovery Act and non-Recovery Act activities and that while strategic 

disinvestments were made, he did not believe the disinvestments were 

jeopardizing EPA internal controls for grants management. 

EPA Identified Staffing Levels as a Management Challenge or 

Emerging Weakness 

 

Some EPA regions identified staffing levels as a management challenge or 

emerging weakness in regional FY 2009 FMFIA annual assurance letters. 

Region 1’s assurance letter listed staffing as a management challenge and stated, 

“Workload has increased at a higher pace than staffing and the current staffing 

level continues to be inadequate to address the Region’s needs.” Region 7 

identified staffing issues as a management challenge and as a new or emerging 

issue. Region 7 indicated that the Recovery Act required higher levels of EPA 

oversight, State reporting, and accountability than the grants funded by regular 

appropriations. This higher level of grant oversight for Recovery Act grants will 

be a strain on existing staffing resources, as these programs will also be managing 

grants and programs funded by the annual appropriations. Region 9 stated that 

the monitoring workload is expected to be much higher than normal due to the 

additional requirements under the Recovery Act and extraordinary oversight. 

Interviews with EPA Managers and Staff Indicated Staffing 

Concerns Exist 

Managers in the regional contracts and grants offices identified Recovery Act 

impacts on non-Recovery Act activities. 

Contracts. Region 1’s contract manager explained that the current contract 

staffing level cannot perform both Recovery Act and non-Recovery Act activities. 

8 
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Further, after our discussions about the lack of staff, the manager of contracts and 

procurement learned that an experienced contract officer was leaving the Agency. 

In an e-mail dated January 8, 2010, the manager wrote, “Since another CO has 

been unofficially detailed out of the office for other duties it is more than 

impossible (is that possible?) for us to do our jobs. The hiring process is too long, 

though we are requesting detail help from HQ or another region. We’ll see what 

happens.” 

The Region 5 contract manager indicated that the office was down many people 

prior to the Recovery Act and that some work had been delayed. She stated that if 

things are falling behind, it is because of the lack of staff and not the increased 

work due to the Recovery Act. However, lack of staff still means that work is not 

done, and if Recovery Act work is a priority, then non-Recovery work would be 

the work that slips. 

Grants. Region 3 managers indicated that baseline monitoring for non-Recovery 

Act activities may slip as a result of the additional work created by the Recovery 

Act. They also explained that their past practice of regularly meeting with the 

program offices is not being maintained. Region 5 grant personnel indicated that 

grant closeouts are being delayed. 

Although the number of Recovery Act grant and contract actions has been small 

(7 and 2 percent, respectively, of all actions taken in FY 2009), Recovery Act 

activities have resulted in non-Recovery Act work being delayed or not 

completed. 

OAM’s Acquisition Human Capital Plan Identified Staff Shortfall 

EPA submitted an Acquisition Human Capital Plan to the Office of Federal 

Procurement Policy on April 1, 2010. Per Office of Federal Procurement Policy 

instructions, EPA used a tool kit provided by the Federal Acquisition Institute to 

project its workforce requirements. EPA projected that it needed 351 contracting 

officers, contract specialists, and procurement analysts. OAM’s submission 

identified its current workforce at 324 contracting officers, contract specialists, 

and procurement analysts – a shortage of 27. Based on OAM’s projection for FY 

2010, the acquisition staffing level is to remain the same, at about 324. The plan 

did not include any specifics as to how OAM would address the shortfall in 

staffing. The staffing shortfall is especially critical since OAM used existing 

cost-reimbursement contracts for Recovery Act rather than the preferred fixed 

price contracts. While using the existing cost-reimbursement contracts saved time 

at the outset, they require extensive oversight, thereby creating an additional 

burden to the existing staff and lessening the time available for non-Recovery Act 

contract activities in the longer term. 

9 
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Performance Measurement Information Indicates Potential Staffing 

Shortfalls for Grants 

Performance measurement information, while limited, indicates that there may be 

difficulty managing the grant workload. The increase in Recovery Act activities 

has impacted non-Recovery Act work. The total percentage of grants closed out 

decreased from 95.5 percent in FY 2008 to 93.4 percent in FY 2009 (Table 2-1). 

Table 2-1: Grants Closure Rates, FY 2008 and 2009 

 9/30/2008 9/30/2009 

Grants Ended in Period 3,511 3,403 

Total Grants Closed 3,352 3,177 

Percent Closed 95.5 93.4 

 Source: OGD FY 2008 and FY 2009 Fourth Quarter Performance Measure Reviews.

Although the overall decrease in grants closed is not yet significant, it illustrates a 

possible trend that could continue at an increasing rate if not addressed. The total 

grants remaining to be closed increased approximately 35 percent, from 221 at the 

end of FY 2008 to 299 at the end of FY 2009 (Table 2-2). Nine regions showed 

increases in grants remaining to be closed. 

Table 2-2: Grants Remaining to Be Closed, FY 2008 and 2009

Region 9/30/20081 9/30/20092 Difference % Change 

HQ 107 97 (10) (9) 

1 1 20 19 1900 

2 13 15 2 15 

3 4 13 9 225 

4 6 9 3 50 

5 21 57 36 171 

6 12 25 13 108 

7 0 0 0 0 

8 27 30 3 11 

9 29 28 (1) (3)

10 1 5 4 400 

Totals 221 299 78 35 

Source: OGD FY 2008 and FY 2009 Fourth Quarter Performance Measure Reviews.

1 Includes all grants ending in FY 2002 through FY 2007. 

2 Includes all grants ending in FY 2002 through FY 2008. 

The increase in the number of grants to be closed shown in the Table 2-2 was 

corroborated by interview and survey responses from Regions 1, 3, 5, 6, and 10. 

Regions 1 and 6 responded in their RATB survey that closeouts may be delayed, 

which is evident in the increase in total grants remaining to be closed. During our 

meetings with grant managers in Regions 3 and 5, they indicated that their nonRecovery Act work is slipping. Region 5 said resources were heavily invested in 

implementing the Recovery Act, thereby reducing the number of grant closeouts 

for FY 2009. Region 3 further indicated in its response to the RATB survey that 

follow-up on grants closeouts would be reduced. Region 10 responded in its 

10 
 11-R-0005 

RATB survey that Recovery Act work was prioritized at the expense of routine 

non-Recovery Act work. 

In EPA’s Stewardship Plan Quarterly Status Report, dated June 4, 2010, OGD 

identified baseline monitoring reviews for Recovery Act grants that were 

considered overdue as of April 29, 2010. According to the report, administrative 

baseline reviews showed the Agency above its target of 90 percent. However, the 

reviews also showed that 24 of 590 Recovery Act administrative baseline reviews 

(4.1 percent) were overdue. This report does not include statistics on nonRecovery Act work nor does it identify impacts to non-Recovery Act grants 

resulting from overdue baseline monitoring reports. 

OAM Did Not Use Workforce Analysis to Establish Staffing Levels 

OAM distributed Recovery Act resources to the regional offices it believed would 

be most impacted by the Recovery Act. However, this distribution was not based 

on a workforce analysis, which would have identified regions and divisions that 

were over- or understaffed. For example, OAM did not perform an analysis of 

each region and division to determine whether contract offices were short staffed 

prior to the Recovery Act and the subsequent implications that Recovery Act 

would have on their workloads. Because EPA was using existing contracts for the 

Recovery Act, Region 8, which was taking the lead for contract resource 

distribution, believed most of the additional activities would be related to 

monitoring and reporting requirements of the Recovery Act. Regions that were 

already understaffed would have more difficulty handling both Recovery and nonRecovery Act work. 

OAM’s workforce analysis, prepared in FY 2007 in response to a prior OIG audit 

report, was not Agency-wide in scope and did not specifically identify the 

organization’s skill gaps. The analysis simply allocated the workload at the time to 

the existing workforce. Further, when managers met to discuss the analysis, they 

could not agree on the staff allocations. Therefore, OAM took no further actions to 

implement the workload model. When the Recovery Act was passed, the lack of a 

workforce analysis placed OAM at a disadvantage, since it did not have statistical 

information on the number of staff needed to effectively carry out the contracting 

activity. Without a detailed analysis of the workforce/workload ratio, it is difficult 

to assess the overall impact that additional work created by the Recovery Act is 

having or whether there is sufficient staff to handle the additional work. 

In response to an OMB 2009 request on acquisition workforce planning, EPA 

submitted its Acquisition Human Capital Plan, dated April 1, 2010, which 

identified strategies and goals for increasing the capacity and capability of the 

workforce. The plan specifically provided an overall view of staffing and staff 

capabilities for OAM as a whole. OAM used data from a formal competency 

survey conducted in 2007 and updated its information via an informal poll of 

current mid-level managers to determine contract workers’ strengths and areas for 

11 
 11-R-0005 

improvement. Using the updated survey information, OAM determined the 

highest-ranked and lowest-ranked competencies of its contracting workforce and 

will consider the results to develop training plans for 2011. This strategy in part 

follows the Office of Personnel Management’s workforce planning model for 

identifying skill gaps, particularly for determining the current workforce resources 

and how they will evolve over time through turnover and other means, and 

determining existing gaps between the current and projected workforce needs. 

The plan identifies an overall summary of projected workforce needed for future 

contracting activities within EPA. The plan does not identify which regions, 

divisions, or laboratories need additional contracting staff. While the plan 

identified a 27 FTE gap in the contracting workforce, it did not identify whether 

contracting specialists or contracting officers were needed. The Office of 

Personnel Management’s workforce planning guide suggests developing 

specifications for the numbers, skill levels, and location of workers and managers 

needed to accomplish the Agency’s strategic requirements. Without the additional 

details, EPA cannot determine staffing shortfalls or skill gaps at the local level. 

Grant Resource Allocation Not Based on Workload Study 

While OGD had a study on workload, the final decision on allocation of resources 

for the Recovery Act was not based on the study.4 In anticipation of the 

Recovery Act’s passage, the Agency established workgroups consisting of 

regional and program representatives to prepare program requests for funds 

through FY 2012, which was the timeframe in the early drafts of the Recovery 

Act legislation. For its initial assessment of resources needed for the Recovery 

Act, EPA estimated its workload using factors provided by program and regiona

offices. Each of the offices had the opportunity to justify its request for 

management and oversight funds. However, in the final legislation, the Reco

Act was only funded through FY 2011. Because the timeframe for use of the 

funds was reduced and the program requests exceeded the amount of funds 

provided in the law, OCFO revised program and regional allocation requests to, in

their view, best distribute the available resources. After receiving feedback from 

the offices, OCFO made the final allocation adjustments of the managem

l 

very 

ent and 

oversight funds. 

Potential Diminished Efforts in Monitoring and Oversight Reviews 

 

Increasing employee workloads to focus on Recovery Act work reduces time

spent on other important activities, such as monitoring and oversight of nonRecovery Act related work. Contract officers and grant specialists are concerned

that they will be giving less attention to postaward monitoring and oversight for 

4 Management of Assistance Agreements at the Environmental Protection Agency, April 2005 (commonly referred to 

as the LMI study). 

12 
 11-R-0005 

non-Recovery Act work. Diminished monitoring and oversight of contract and 

grant vehicles leaves the Agency susceptible to errors. 

When management and oversight funds expire in 2011, the Agency will ha

perform monitoring and oversight of Recovery and non-Recovery grants and 

contracts with base program resources. According to a February 2, 2009, 

Congressional Budget Office cost estimate, money historically appropriated t

State Revolving Funds is spent slowly, with about half being spent after the first 

3 years. As of August 2010, EPA disbursed about 42.4 percent of the Clean 

Water State Revolving Fund Recovery Act money and 47.2 percent of Drinki

Water State Revolving Fund Recovery Act money. Because 

ve to 

o 

ng 

Recovery Act grants 

nd contracts may not be completed in 2011, the Agency will be required to 

resource needs and plan for future contingencies.

Recommen

 

e recommend that the Assistant Administrator for Administration and 

2-1 

ue 

e. 

ue to resource limitations, OAM and OGD 

should work with OCFO to reexamine the distribution of Recovery Act 

Agency Co

Our draft report contained two recommendations for this chapter. The 

t already have been 

identified, such as completion of grant closeouts and administrative 

to 

. 

lays indicate that a weakness in internal 

a

reevaluate 

dation

W

Resources Management: 

Direct OAM and OGD to establish procedures to review the metrics for 

Recovery Act and non-Recovery Act contract and grant activities with 

senior managers for the period ending September 30, 2010, and quarterly 

thereafter. For any metrics that do not meet performance goals, senior 

managers should examine the reasons the goals were not met, and where a 

control weakness is revealed, develop a plan with corrective actions, d

dates, and responsible offices to ensure that the goals are met in the futur

If goals are not attained d

management resources. 

mments and OIG Evaluation 

recommendations were: 

 Develop action plans to address the delays tha

monitoring reviews for Recovery Act grants. 

 Direct OAM and OGD to regularly review, with senior managers, 

performance information such as performance measures, FMFIA reports,

contract office quality assurance plans, and stewardship plan updates, 

detect delays in Recovery Act and non-Recovery Act grant and contract

management activities and develop appropriate written action plans

Written action plans should be developed when performance measures

will not be met or when de

13 
 11-R-0005 

controls may exist. Existing workforce information should be used to 

develop the action plans. 

The Agency did not agree that it should develop action plans to address current 

delays. OAM responded that action plans for contract-related delays are 

unnecessary at this time because there are no specific actions that have not been 

awarded or unduly delayed. While OGD acknowledges that delays hav

in non-Recovery Act activities, it does not believe these impacts warrant 

development of an action plan at this time. OGD provided baseline monitoring

data through August 31, indicating that its administrative baseline and 

programmatic baseline reviews are at 85.3 percent and 77.1 percent, respectively,

for non-Recovery Act awards. OGD believes that both the administrative an

programmatic baseline reviews will approach the 90 percent goal by year end. 

Both OAM and OGD contend that action plans should not be developed until an 

issue becomes an internal weakness. Both did agree to review performance 

information on a regular basis and develop written action plans, using availab

workforce information, where the review identifies an internal control we

OAM and OGD agreed to meet with senior resource officials and the OCFO in 

the first qua

e occurred 

d 

le 

akness. 

rter of FY 2011 to determine whether the Agency has the proper 

rategy in place for managing the Recovery Act and non-Recovery Act 

e in 

es rise 

tors we reported and those contained in 

e response to the draft report show that EPA contracts and grants may have 

e 

sts 

the 

rol weakness, he would 

agree with the recommendation. In responding to the final report, the Office of 

Administration and Resources Management should provide a corrective actions 

plan for implementing the revised recommendation. 

st

procurement and assistance workload. OAM and OGD would brief the OIG on 

the results. 

The OIG’s recommendations in the draft report were intended to be proactiv

nature in an attempt to address potential issues and problems before the issu

to the level of an internal control weakness. The OIG believes that waiting until 

an issue becomes an internal control weakness is too late, and that by being 

proactive, the Agency can prevent some internal control weaknesses from

occurring. We still believe that the indica

th

future workload issues and that these issues should be addressed prior to 

becoming an internal control weakness. 

Many of the functions in which delays are occurring are critical functions. 

For example, programmatic baseline monitoring reviews provide important 

information, such as whether expended and remaining funds are reasonable, 

whether all programmatic terms and conditions are being met, and whether 

project milestones are being met. Based on EPA’s response, we combined th

previous two recommendations into one, and the new recommendation reque

that EPA use the September 30, 2010, performance data to determine whether 

Agency should take additional actions. At the exit conference, the Director, 

Office of Grants and Debarment, stated that if we allowed flexibility for the 

Agency to determine what delays would reveal a cont

14 
 11-R-0005 

Chapter 3 

OAM Needs Agency-Wide Performance Measures 

OAM does not have Agency-wide performance measures, thereby making it 

difficult to assess the impact of the Recovery Act on its staff and workload. The 

Government Performance and Results Act of 1993 (GPRA) (P.L. 103-62) requires 

the Federal Government to establish performance measures. In response to a 

prior OIG audit recommendation, OAM developed performance measures for 

employee job standards that tied in to its strategic goals. However, OAM did not 

develop Agency-wide performance measures for contract functions. Without 

performance measures, OAM does not have valuable information it could use to 

effectively and efficiently manage its workforce and workload, and quickly 

address emerging issues such as impacts from Recovery Act work. 

Performance Measurement Is Required by Law 

The Government Performance and Results Act of 1993 provides criteria for 

management’s obligation to maintain performance measurement data. The law 

requires an annual performance plan that is to include: 

 Performance goals to define the level of performance to be achieved. 

 Goals expressed in an objective, quantifiable, and measurable form. 

 A description of the operational processes, skills, and technology, and the 

human capital, information, or other resources required to meet the 

performance goals. 

 Performance indicators to be used in measuring or assessing the relevant 

outputs, service levels, and outcomes of each program activity. 

 A basis for comparing actual program results with the established 

performance goals. 

 A description of the means to be used to verify and validate measures. 

 

OAM Does Not Have Performance Measures 

OAM does not have Agency-wide performance measures to assess relevant 

changes in outputs, service levels, and outcomes of contracting activity. Some 

regional and procurement offices do track contract closeout activity. OAM does 

collect some Agency-wide information on activities that could be used to develop 

performance measures. For example, according to OAM’s FY 2009 activity 

report, it processed 8,130 contract awards, modifications, delivery orders, and 

task orders, including 162 Recovery Act actions. In response to the RATB 

survey, OAM stated that it had 121 contracting officers; that number would 

equate to about 67 contracting actions per contracting officer. While each 

15 
 11-R-0005 

contracting action may require different levels of resources, OAM could use the 

information to identify trends in processing contracting actions that may need to 

be investigated further. 

Without consistent performance measures, OAM cannot determine the impact that 

Recovery Act activities have had on contract work Agency-wide or whether 

required contract tasks are completed efficiently and effectively. Unlike OGD, 

which has established annual performance measures and goals such as number of 

grant closeouts and average time to award grants and amendments, OAM does not 

track such performance measures Agency-wide. These performance measures 

assist OGD in better assessing the impact that Recovery Act work has on the 

overall grant workload. 

 

Past Implementation of Performance Measures Not Effective

OAM developed performance measures in response to OIG Report No. 

2005-P-00006, Office of Acquisition Management Can Strengthen Its 

Organizational System, issued February 17, 2005. This report made 

recommendations to OAM to develop an action plan with milestone dates for 

establishing performance measures and a means of measuring progress against its 

strategic goals. In response to this recommendation, OAM developed OAM-wide 

performance measures for employee job standards. These measures included 

providing courteous customer service, leading change, and optimizing business 

practices. 

The measures OAM developed in response to the prior report cannot be used to 

measure outputs, service levels, or outcomes of contracting activities, and cannot 

be used as a basis for comparing results with performance goals. Tracking 

progress against organization-wide measures can be helpful in determining how 

processes can be more efficient. For example, comparing fiscal year activity from 

1 year to the next could indicate which regions or procurement offices may be 

having difficulty completing certain tasks and provide a basis for asking why 

actions are not completed. Tracking progress could also indicate which regions or 

procurement offices are performing well. The region or procurement office may 

have its own internal best practices that may be useful to the organization as a 

whole. 

Recommendation

We recommend that the Assistant Administrator for Administration and 

Resources Management: 

3-1 Direct OAM to develop and implement organization-wide performance 

measures to better manage its activities. 

16 
 11-R-0005 

Agency Comments and OIG Evaluation 

EPA agreed with our recommendation and will implement the recommendation 

through a Balanced Scorecard Management Plan and a Balanced Scorecard 

Performance Measurement System that will track progress in implementing the 

plan. EPA intends to have the plan in place by March 2011 and the system in 

place by September 30, 2011. 

17 
 11-R-0005 

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 

2-1 13 Direct OAM and OGD to establish procedures to 

review the metrics for Recovery Act and nonRecovery Act contract and grant activities with 

senior managers for the period ending September 

30, 2010, and quarterly thereafter. For any metrics 

that do not meet performance goals, senior 

managers should examine the reasons the goals 

were not met, and where a control weakness is 

revealed, develop a plan with corrective actions, 

due dates, and responsible offices to ensure that 

the goals are met in the future. If goals are not 

attained due to resource limitations, OAM and 

OGD should work with OCFO to reexamine the 

distribution of Recovery Act management 

resources. 

U Assistant Administrator for 

Administration and 

Resources Management 

 

3-1 16 Direct OAM to develop and implement 

organization-wide performance measures to better 

manage its activities. 

O Assistant Administrator for 

Administration and 

Resources Management 

9/30/2011 

 

 

 

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

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

18 
 11-R-0005 

Appendix A 

Agency Response to Draft Report 

September 13, 2010 

MEMORANDUM

SUBJECT: Draft Office of Inspector General (OIG) Audit Report: 

 EPA’s Contracts and Grants Workforce 

May Face Future Workload Issues 

 (Project No. OA-FY09-0924, August 12, 2010) 

FROM: Craig E. Hooks 

 Assistant Administrator 

TO: Melissa M. Heist 

 Assistant Inspector General for Audit 

 Thank you for the opportunity to comment on the subject draft audit report (report). 

 I am pleased that the report recognizes the Agency’s noteworthy achievements in 

implementing the Recovery Act. As described in the report, these include the award of over $6 

billion in grants and $300 million in contracts and the development of a stewardship plan that 

fully incorporates Government Accountability Office internal control standards. These 

achievements are a tribute to EPA’s acquisition and grants workforce, which did an exceptional 

job of workload management and prioritization in the face of the extremely challenging 

objectives, expectations and new administrative and reporting requirements resulting from the 

Recovery Act. 

 The report examines EPA’s contracts and grants staffing for both Recovery Act and nonRecovery Act activities and finds that current staffing levels may be insufficient to meet present 

and future workload demands. It also finds that the Office of Acquisition Management (OAM) 

has not developed Agency-wide performance measures for contract functions. To address these 

findings, the OIG recommends that I direct OAM and the Office of Grants and Debarment 

(OGD) to take certain actions. My response to the recommendations is as follows. 

19 
 11-R-0005 

Chapter 2 Recommendations

Recommendation 2-1: Develop action plans to address the delays that already have been 

identified, such as the completion of grant closeouts and administrative monitoring reviews for 

Recovery Act grants. 

Response: In coordination with the OA Division Directors and the Regional Contracting Officer 

(RCO) Supervisors, OAM has determined that action plans for contract-related delays are 

unnecessary at this time as there are no specific actions that have not been awarded or that have 

been unduly delayed as a result of prioritizing Recovery Act work. However, if we determine, 

based on new information, that such delays have occurred or may potentially occur, OAM will 

coordinate with the OAM Division Directors and RCO Supervisors and develop action plans as 

appropriate. 

In the grants areas, as demonstrated by information from OGD’s performance measure reports, 

the Recovery Act workload has delayed non-Recovery Act activities. As described below, 

however, none of these impacts warrants development of an action plan at this time. 

Advanced Programmatic Monitoring 

To ensure adequate advance programmatic monitoring for Recovery Act awards, OGD 

temporarily reduced the required level of advance programmatic monitoring for Regional and 

Office of Air and Radiation non-Recovery Act awards from 10% of active recipients to 7% of 

active recipients. OGD has not identified any significant adverse effects from this reduction. At 

the 7% level, the Agency is still obtaining the information needed to identify grants management 

risk areas. 

Advanced Administrative Monitoring

The Agency primarily performs advanced administrative monitoring via contract. As of July 28, 

2010, we have completed 56 of the 60 Recovery Act contract reviews and will finish the 

remaining 4 reviews by the end of the fiscal year. Making Recovery Act advanced 

administrative monitoring a priority has slowed the pace of our non-Recovery Act advanced 

administrative monitoring reviews. As of July 28, 2010, we have completed only 3% of these 

reviews, but are on track to complete the remaining 97% by the end of the calendar year as 

required by EPA Order 5700.6A2 CHG2, Policy on Compliance, Review and Monitoring.

Baseline Monitoring 

In 2010, OGD implemented a new post-award Baseline Monitoring tool that tracks real-time 

compliance with baseline monitoring requirements. As of August 31, 2010, the following chart 

measures Agency progress in meeting a Grants Management Plan (GMP) compliance target of 

90%. 

20 
 11-R-0005 

All Awards ARRA Awards Only Non-ARRA Awards 

Administrative 

Baseline 

86% 91.3% 85.3% 

Programmatic 

Baseline 

77% 75% 77.1% 

The data show that, to date, administrative baseline monitoring exceeds the 90% target for 

Recovery Act awards and is near the target for non-Recovery Act awards. While the comparable 

numbers for programmatic baseline monitoring are not as high, we expect that the level of 

monitoring will approach 90% by the end of the calendar year. 

Grants Management Plan Disinvestments 

The Recovery Act workload did lead to the deferral of certain activities under the Agency’s 

GMP. This has principally involved moving scheduled completion dates for selected milestones 

into FY 2011 under the GMP Goals 1-3. Activities affected include enhancements to guidance 

on environmental results and roles and responsibilities as well as the development of a new 

grants policy vision. OGD believes that the existing controls in these areas (e.g., the 

Environmental Results order, the Roles and Responsibilities Matrix, and relying on the Grants 

Customer Relations Council as a key mechanism for policy feedback) have been sufficient to 

mitigate any adverse effects of the deferral. 

Closeouts 

Although the report suggests that grants closeouts could become a problem, existing data show 

that as of August 31, 2010, EPA was at the 86.7% and 99.3% levels towards achieving the 90%-

99% GMP closeout goals. These percentages are on par with the August 31 numbers for 2009 

(86.7% and 99.4) and 2008 (86.8% and 99.3). As is typically the case, OGD expects there will 

be significant closeout activity through the remainder of the fiscal year to allow EPA to meet, 

from an overall Agency standpoint, the 90%-99% goals. 

In short, the delays in non-Recovery Act grant work caused by the Recovery Act workload do 

not rise to the level of a material or agency weakness requiring preparation of an action plan at 

this time. The internal controls in the GMP are currently sufficient to address the risks posed by 

the delays, and OGD anticipates that the Agency will return to pre-Recovery Act performance 

levels in FY 2011. At the same time, and as described more fully in the response to 

Recommendation 2-2, OGD will continue to monitor the situation through its performance 

measurement reports and, if circumstances change, take appropriated corrective action. 

Recommendation 2-2: Direct OAM and OGD to regularly review with senior managers 

performance information such as performance measures, FMFIA reports, contract office quality 

assurance plans, and stewardship plan updates, to detect delays in Recovery Act and nonRecovery Act grant and contract management activities and develop appropriate written action 

plans. Written action plans should be developed when performance measures will not be met or 

when delays indicate that a weakness in internal controls may exist. Existing workforce 

21 
 11-R-0005 

information should be used to develop the action plans. 

Response: I agree with the recommendation to review performance information on a regular 

basis and develop written action plans, using available workforce information, where the review 

identifies an internal control weakness. Consistent with this recommendation, OAM and OGD 

will be meeting with Senior Resource Officials and the Office of the Chief Financial Officer in 

the first quarter of FY 2011 to determine whether the Agency has the proper strategy in place for 

managing the Recovery Act and non-Recovery Act procurement and assistance workload. OAM 

and OGD will brief you on the results of the meeting. 

I disagree, however, with the recommendation to prepare written action plans whenever a 

performance measure is not met. Instead, similar to the case for delays in Recovery Act and 

non-Recovery Act activities, written action plans for performance measure shortfalls should be 

required only where a shortfall reveals an internal control weakness. The OIG’s formulation 

would limit OAM’s and OGD’s discretion to strike an appropriated balance between recovery 

Act and non-Recovery Act activities by mandating action plans for deviations from performance 

measures that are de minimus or otherwise not material. I am therefore requesting that the OIG 

modify Recommendation 2-2 to apply the internal weakness standard to both contract/grant 

delays and performance measure shortfalls. 

Chapter 3 Recommendation

Recommendation 3-1: Direct OAM to develop and implement organization-wide performance 

measures to better manage its activities. 

Response: I agree with this recommendation and OAM will address it through a Balanced 

Scorecard. This will consist of two components - a Balance Scorecard Management Plan (Plan), 

and a Balanced Scorecard Performance Measurement and Management System (System) that 

will track progress in implementing the Plan. The Balanced Scorecard will establish a 

comprehensive framework for performance management of the Agency’s acquisition programs, 

incorporating objectives, core measures and targets that focus on meeting EPA, OARM and 

OAM strategic goals. It will also allow OARM to identify opportunities to strengthen EPA’s 

Acquisition Workforce Strategic Human Capital Plan, thereby ensuring that the Agency has the 

best qualified acquisition staff to support its mission. 

I am confident that the Balance Scorecard will enable EPA to achieve consistency, uniformity, 

and continuous improvement in its acquisition programs. OAM anticipates having the Plan in 

place by the end of March 2011 and the System in place by the end of September 2011. 

Thank you again for the opportunity to comment on the report. If you have any questions, please 

contact me, John Bashista, Director, OAM, at (202) 564-4310, or Howard Corcoran, Director, 

OGD, at (202) 564-1903. 

cc: Nanci Gelb 

 Renee Wynn 

 Jerry Kurtzweg 

22 
 11-R-0005 

 Sheila Frace 

 Maryann Froehlich 

 David Bloom 

 Stefan Silzer 

 Janet Kasper 

 Deputy Regional Administrators 

 Assistant Regional Administrators 

 John Bashista 

 Chuck Gherardini 

 Lisa Mass 

 Joan Wooley 

 John Oliver 

 OAM Division Directors 

 Regional Contracting Officer Supervisors 

 Denise Simons 

 Catherine Vass 

 Francis Roth 

 Don Flattery 

 Marian Cooper 

 Grants Management Officers 

 Junior Resource Officials 

 Howard Corcoran 

 

 

 

23 
 11-R-0005 

24 

Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator for Administration and Resources Management 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Director, Office of Acquisition Management, Office of Administration and 

Resources Management 

Director, Office of Grants and Debarment, Office of Administration and 

Resources Management 

Director, Grants and Interagency Agreements Management Division, Office of 

Administration and Resources Management 

Director, Office of Regional Operations 

Audit Follow-up Coordinator, Office of Administration and Resources Management 

Audit Follow-up Coordinator, Office of Acquisition Management, Office of Administration and 

Resources Management 

Audit Follow-up Coordinator, Office of Grants and Debarment, Office of Administration and 

Resources Management 

Inspector General