U.S. Department of Energy

Office of Inspector General

Office of Audit Services

Audit Report

Accounting and Reporting for the 

American Recovery and 

Reinvestment Act by the Department 

of Energy's Funding Recipients

OAS-RA-10-06 April 2010
Department of Energy 

Washington, DC 20585 

April 1, 2010

MEMORANDUM FOR THE SECRETARY 

FROM: Gregory H. Friedman 

 Inspector General 

SUBJECT: INFORMATION: Audit Report on "Accounting and Reporting for the 

 American Recovery and Reinvestment Act by the Department of 

 Energy's Funding Recipients" 

BACKGROUND

The American Recovery and Reinvestment Act of 2009 (Recovery Act) was established to 

jumpstart the U.S. economy, create or save millions of jobs, and invest in the Nation's energy 

future. The Department of Energy received approximately $37 billion through the Recovery Act 

to support a variety of science, energy and environmental initiatives. The Office of Management 

and Budget (OMB) issued guidance for carrying out stimulus-related activities which requires, 

among other things, that recipients ensure funds provided by the Recovery Act are clearly 

distinguishable from non-Recovery Act funds in all reporting systems and that recipients' actions 

are transparent to the public. To meet these requirements, the Department's recipients (prime 

contractors, grantees and other financial assistance awardees) must clearly and accurately track 

and report on 18 separate data elements. In addition, the Department was to develop and 

implement a process to ensure that recipient information reported to the public was free from 

material omissions and significant reporting errors. 

Our recent report on the Department of Energy's Quality Assurance Process for Prime 

Recipients' Reporting for the American Recovery and Reinvestment Act of 2009 (OAS-RA-10-

01, October 2009) noted that the Department had developed a quality assurance process to 

facilitate the quarterly reviews of recipient data and planned to test it during the first quarterly 

reporting cycle. To determine whether the Department's quality assurance process over data 

reported by all recipients was effective, we examined information reported by recipients of 

Departmental funding as of September 30, 2009. We also sought to determine whether the 

Department's prime contractors were prepared to track and report on Recovery Act activities. 

RESULTS OF AUDIT

The Department had taken a number of actions designed to ensure the accuracy and transparency 

of reported Recovery Act results. For instance, the Department developed and implemented a 

data quality assurance process to examine select data elements (4 of 18) for all recipients of 

Recovery Act funds. This process identified potential anomalies with information reported by 

1,113 of 2,038, or 55 percent of recipients. We view the Department's data quality assurance 

efforts as both timely and significant. As noted by our audit testing, however, opportunities exist 

to strengthen the process, thus reducing the risk of material errors and improving the 

transparency of publicly reported Recovery Act information. In particular: 

Site officials did not always ensure that anomalies, once identified during the quality 

assurance process, were actually resolved. For example, the Department's process 
2

identified that about 740 of the approximately 10,000 jobs reported in the first quarter of 

Fiscal Year 2010 as created/retained were for projects reported as having no funds spent. 

Although these problems were referred to site officials for follow-up and/or correction, the 

information was never actually changed; 

The Department did not always utilize the correct basis when evaluating the accuracy of 

"funds provided" data submitted by grant recipients. For example, in its analysis process, 

the Department used data reflecting "funds obligated" rather than the correct amount of 

"total grant awards". This generated a number of potential false positives; and, 

Duplicate reports by certain recipients, resulting in overstatements of as much as $137 

million of the more than $18 billion obligated, were not corrected. 

We observed that the Department had taken prompt action to ensure that its prime facility 

management contractors could properly report Recovery Act information. Notably, the seven 

contractors in this category included in our review had modified their accounting systems, as 

necessary, to ensure that they could accurately track and report on Recovery Act activities. The 

systems at each of these entities had been restructured so that they: (i) could separate Recovery 

Act and non-Recovery Act funds; and, (ii) had adequate processing capacity to handle the 

projected increase in transactions. 

We recognize the challenge of balancing the need to reduce the risk that material errors or 

misstatements exist in reported Recovery Act information and the cost of quickly reviewing 

large amounts of data and resolving resulting anomalies. As such, we found the Department's 

decision to limit its reviews to the four elements that it considered to be critical (award amount, 

invoiced amount, jobs created/retained, and project status) to be reasonable. We concluded, 

however, that as demonstrated by our test results, other elements or dependent relationships 

should not be completely excluded from review. Even in cases where the Department views data 

elements as "non-critical," introducing random comparisons on a rotating or cyclical basis could 

enhance review efforts and increase the likelihood that Recovery Act information is free of 

material errors. 

Beyond its initial development and implementation of its quality assurance process, the 

Department had taken steps to improve its ability to ensure that Recovery Act information was 

both accurate and transparent to the public. Specifically, officials changed the quality assurance 

plan based on initial data reviews. Department officials also informed us that they are in the 

process of updating their quality assurance process to meet new OMB requirements. For 

example, recent guidance directed agencies to focus on certain data elements, such as award 

number and recipient name, during their quality assurance reviews. In addition, subsequent to 

our review, the Department added two more data elements and comparisons to its quarterly 

assurance process, including an analysis of costs/expenditures and a comparison of the recipient 

reported project status to the Department's data contained in its financial system. 

OTHER MATTERS

While not directly related to data quality, during the course of our audit work we observed that 

none of the seven prime contractors reported the number of subcontractor jobs created or 
3

retained in conjunction with funds provided under the Recovery Act. To be clear, OMB did not 

require such data to be reported. Interestingly, as reported externally, we found that the number 

of jobs created by subcontractors was almost double that of jobs created by prime contractors. At 

the seven prime contractors reviewed, over 1,100 prime contractor jobs were reported as being 

created or retained. However, data gathered by prime contractors indicated that more than 2,000 

subcontractor jobs were also created or retained over the same period. The following chart 

represents the variance between prime contractor and subcontractor jobs as of September 30, 

2009.

Contractor Location*

Prime 

Contractor 

Jobs Created

or Retained

Subcontractor 

Jobs Created

or Retained Total

CH2M Hill Plateau Remediation Company Hanford 621 1,404 2,025

Washington Closure Hanford Company Hanford 36 39 75

Washington River Protection Solutions Hanford 200 87 287

Battelle Memorial Institute PNNL 27 114 141

UT-Battelle ORNL 41 161 202

Bechtel Jacobs Company ETTP 93 7 100

B&W Y-12 Y-12 129 202 331

1,147 2,014 3,161

* Locations more fully described in Appendix 1. 

We do not question the basis or rationale leading to the decision to exclude subcontractor job 

creation or retention from reporting. However, as a practical matter, it tends to alter the visibility 

of jobs creation related to execution of the Recovery Act in the Department of Energy. The 

Department's core structure for many of its activities relies heavily on prime and subcontractor 

relationships. 

MANAGEMENT REACTION

Management concurred with each of the report's recommendations and indicated that it had taken 

action to address the recommendations. Management's comments are included in their entirety 

in Appendix 3. 

Attachment 

cc: Deputy Secretary 

 Under Secretary of Energy 

Under Secretary for Science 

 Administrator, National Nuclear Security Administration 

 Chief Financial Officer 

 Chief of Staff 
ACCOUNTING AND REPORTING FOR THE AMERICAN 

RECOVERY AND REINVESTMENT ACT BY THE DEPARTMENT 

OF ENERGY'S FUNDING RECIPIENTS 

TABLE OF 

CONTENTS 

Accounting and Reporting for the American Recovery and Reinvestment Act

Details of Finding ................................................................................................................1

Recommendations and Comments .......................................................................................5

 

Appendices

1. Objective, Scope, and Methodology ............................................................................6

2. Prior Reports .................................................................................................................8

3. Management and Auditor Comments ...........................................................................9
ACCOUNTING AND REPORTING FOR THE AMERICAN RECOVERY 

AND REINVESTMENT ACT 

___________________________________________________________________ 

Page 1 Details of Finding 

The Department's As previously noted in our report on the Department of

Quality Assurance Energy's Quality Assurance Process for Prime Recipients'

Process and Prime Reporting for the American Recovery and Reinvestment Act

Contractor Accounting of 2009 (OAS-RA-10-01, October 2009), the Department of 

Systems Energy (Department) had developed a quality assurance 

process to identify material omissions and significant reporting 

errors. The Department applied its quality assurance process to 

the first round of American Recovery and Reinvestment Act of 

2009 (Recovery Act) reporting and identified a significant 

number of anomalies. However, our analysis of the same 

September 30, 2009, data reported by all recipients, including 

certain prime contractors, identified anomalies where recipients 

may have reported erroneous information that resulted in 

potentially inaccurate reporting to FederalReporting.gov and 

the ultimate publication of such information on Recovery.gov. 

Based on our testing, we concluded that the Department's 

quality assurance process could be further strengthened to help 

ensure that information reported by recipients was not 

materially inaccurate. Our review also disclosed that seven of 

the Department's prime contractors that received Recovery Act 

funding for various projects and initiatives appeared to have 

adequate information systems and processes in place for 

tracking and reporting on Recovery Act activities. 

Recipient Reporting and Quality Assurance

The Department's quality assurance process was designed to 

analyze information provided by all of the Department's 

Recovery Act recipients and focused on 4 of 18 reporting 

elements required by the Office of Management and Budget 

(OMB): award amount, invoiced amount, jobs 

created/retained, and project status. These recipient-reported 

data elements were compared to information maintained in the 

Department's financial systems, such as the Standard 

Accounting and Reporting System. Department officials noted 

that they focused their attention on these four elements because 

they believed that they were the highest risk areas and testing 

the data would detect material omissions and significant 

reporting errors. In fact, the Department's quality assurance 

process identified potential anomalies with 1,113 of 2,038 (55 

percent) recipients reviewed. The potential errors included 308 

recipients that did not report approximately $323 million of 

Recovery Act funding to FederalReporting.gov as of 

September 30, 2009. While the Department's quality assurance 

process identified numerous anomalies, we noted that some 
___________________________________________________________________ 

Page 2 Details of Finding 

were never corrected and additional potential reporting errors 

existed. Specifically, during our review of recipient reported 

data, we found: 

Site officials did not always ensure that needed changes 

identified during the quality assurance process were made. 

OMB guidance requires the Department to evaluate 

recipients' data submissions and direct changes as 

necessary. In addition, a Department official stated that the 

site officials were responsible for a follow-through review. 

Although discrepancies were identified during the quality 

assurance process, we found recipients for 102 projects 

reported to FederalReporting.gov that 744 jobs had been 

created or retained even though no funds had been spent on 

these projects; 

The Department did not always utilize the correct amount 

when evaluating the accuracy of data reported by grant 

recipients to FederalReporting.gov. Specifically, at the 

time of our review, the Department utilized the amount of 

funding provided to the recipients to date rather than the 

total amount of the award reported by the recipients. For 

example, an Office of Fossil Energy grantee reported that it 

was awarded approximately $308 million for a project. 

However, in its quality assurance analysis, the Department 

incorrectly compared the award amount on 

FederalReporting.gov to the amount of funding provided to 

date, as indicated in the Department's financial system, and 

flagged that as a potential error of approximately $258 

million. Errors such as this resulted in site officials 

identifying and addressing more discrepancies than 

necessary, reducing the efficiency of the quality assurance 

process; 

13 recipients reported in duplicate to FederalReporting.gov, 

potentially overstating the amount of Recovery Act awards 

by $137 million. For instance, we noted that one State 

Energy Program grantee reported duplicate information, 

resulting in an overstatement of Recovery Act spending of 

more than $25 million. Although inaccuracies such as 

these were detected during the quality assurance process, 

the duplicate awards were not removed by the recipients 

from FederalReporting.gov; and, 
___________________________________________________________________ 

Page 3 Details of Finding 

The quality assurance process also did not detect anomalies 

when the recipients reported no award amount. 

Specifically, we found several instances where the 

recipients were awarded Recovery Act funding, but noted 

in their data submission that there was no award amount. 

After we brought this matter to its attention, the 

Department told us that it had evaluated the issue and 

determined that a programming error caused the problem 

we discovered. Responsible officials indicated that they 

would take action to address the issue. 

Prime Contractor Accounting and Reporting Systems

To support agency efforts, OMB issued guidance for carrying 

out activities enacted in the Recovery Act which required, 

among other things, that agencies ensure all funds provided in 

the Recovery Act were distinguishable from non-Recovery Act 

funds in their financial and business reporting systems. To 

meet these requirements, the Department's prime contractors 

were required to clearly and accurately report Recovery Act 

data in a timely manner. During our review, we conducted test 

work at seven of the Department's prime contractors that 

received Recovery Act funding for various projects and 

initiatives to determine whether contractor systems were 

capable of meeting these new reporting challenges. 

Based on our evaluations, we concluded that the contractors' 

information systems we examined appeared to be adequate for 

tracking and reporting Recovery Act activities. Specifically, 

all seven of the prime contractors reviewed had existing 

information systems and processes in place that had been 

modified to handle and process the additional Recovery Act 

transactions. For example, officials at one national laboratory 

noted that their financial system was easily modified and 

allowed for projects to be allocated funding from multiple 

sources, including Recovery Act and non-Recovery Act 

funding. Similar changes were made to systems at the other 

sites reviewed. We also found that systems at each of the sites 

reviewed contained adequate processing capacity to handle the 

additional transactions resulting from Recovery Act activities. 

Quality Assurance The Department had taken a risk-based approach when

Process and implementing its quality assurance process. This approach was 

Training designed to analyze data reported by all recipients in an 

expedited manner. However, we noted that the quality 

assurance process did not focus on all relevant recipient 
___________________________________________________________________ 

Page 4 Details of Finding 

information. In addition, officials responsible for carrying out 

the quality assurance process were not always trained in how to 

address potential recipient errors. 

 

The quality assurance process utilized by the Department 

detected more than 1,100 anomalies during the initial reporting 

cycle using an approach that was designed to identify the most 

likely errors and material omissions. During its first quarterly 

quality assurance review, the Department analyzed four data 

elements reported by recipients: award amount, invoiced 

amount, jobs created/retained, and project status. Officials 

believed that reviewing these particular elements would detect 

significant errors and material omissions in recipient reported 

data. While we agree that the four elements evaluated were 

critical, other data fields such as recipient name and 

congressional district could also assist the public in its efforts 

to determine the economic impact – jobs created/retained and 

funding provided – to its geographical region. Furthermore, 

enhancements to the Department's quality assurance process, 

including reviews of various elements through random 

comparison on a rotating basis, may assist the Department in 

its efforts to identify and remediate issues similar to those 

noted in our report. 

The Department developed a training program for officials 

responsible for reviewing recipient data submissions that 

included detailed steps and procedures for cognizant officials 

to follow when reviewing recipient quarterly data for 

significant reporting errors and material omissions. 

Department officials indicated that they had conducted training 

at six locations; however, officials at a number of additional 

sites still needed to receive training. 

Transparency and The Department placed a great deal of emphasis on its initial 

Accuracy of quality assurance process. And, arguably, it was successful in 

Recipient Reported that it identified an anomaly rate of nearly 50 percent. Further, 

Data the Department had initiated changes to the quality assurance 

plan based on initial data reviews. However, our findings 

indicate that additional refinements to the quality assurance 

process could help to ensure that Recovery Act information is 

free of material errors, transparent, and ready for public 

consumption. Of greatest importance, such data should 

accurately reflect whether the Department's Recovery Act 

efforts are ultimately successful, especially in terms of job
___________________________________________________________________ 

Page 5 Recommendations and Comments 

creation and economic stimulation. This process could be 

enhanced by ensuring that all officials charged with resolving 

reporting errors are adequately trained, providing additional 

assurance that information ultimately published on 

Recovery.gov is not materially misstated. 

RECOMMENDATIONS To help enhance the effectiveness of the Recovery Act data 

quality assurance process, we recommend that the Chief 

Financial Officer work with program officials to: 

1. Adjust the quality assurance process, as necessary, to 

include adding comparisons of other data elements to 

increase the likelihood that material omissions and 

significant reporting errors are detected; and, 

2. Ensure that all officials with oversight responsibility for 

Recovery Act recipient reporting are adequately 

trained. 

MANAGEMENT Management concurred with the recommendations made in the 

REACTION report and indicated that action had been taken or was currently 

underway to address many of the issues identified during our 

review. In particular, management commented that it recently 

made enhancements to the quality assurance process to 

increase the likelihood that material omissions and significant 

reporting errors are detected. In addition, management noted 

that it was providing additional training on the Department's 

quality assurance process to agency reviewers in the field. 

Management's comments are included in their entirety in 

Appendix 3. 

AUDITOR Management's comments are responsive to our 

COMMENTS recommendations. 
Appendix 1 

___________________________________________________________________ 

Page 6 Objective, Scope, and Methodology 

OBJECTIVE To determine whether the Department of Energy's 

(Department) quality assurance process over data reported by 

all recipients was effective, we examined information reported 

by recipients of Departmental funding as of September 30, 

2009. We also sought to determine whether the Department's 

prime contractors were prepared to track and report on 

Recovery Act activities. 

SCOPE The audit was performed between September 2009 and March 

2010 at Department Headquarters in Washington, D.C., the 

Oak Ridge Office, Oak Ridge National Laboratory, East 

Tennessee Technology Park, and Y-12 National Security 

Complex, Oak Ridge, Tennessee; the Richland Operations 

Office, Hanford Site; and, Pacific Northwest National 

Laboratory, Richland, Washington. 

METHODOLOGY To accomplish the audit objective, we: 

Obtained and reviewed the Department's policy and 

procedures for reviewing quarterly recipient of the 

American Recovery and Reinvestment Act of 2009 

(Recovery Act) data pursuant to Office of 

Management and Budget Memorandum 09-21; 

Obtained the Department's quality assurance process 

results and reviewed the data for any material 

omissions, significant errors, and reporting anomalies; 

Compared the quality assurance process results to the 

recipients' reported data from Recovery.gov for any 

reporting anomalies that were not identified by the 

process and discussed the anomalies with cognizant 

site officials; 

Determined what changes prime contractors made to 

their information systems to enable Recovery Act 

funds and number of jobs created/retained to be 

appropriately tracked and reported; 

Determined the prime contractors' system controls in 

place to prohibit co-mingling of Recovery Act and 

non-Recovery Act funds; and,

Determined the prime contractors' processes for 

reporting Recovery Act information to 

FederalReporting.gov
Appendix 1 (continued) 

___________________________________________________________________ 

Page 7 Objective, Scope, and Methodology 

We conducted this performance audit in accordance with 

generally accepted Government auditing standards. 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 objectives. 

We believe the evidence obtained provides a reasonable basis 

for our findings and conclusions based on our audit objectives. 

The audit included tests of internal controls and compliance 

with laws and regulations to the extent necessary to satisfy the 

audit objective. Because our review was limited, it would not 

necessarily have disclosed all internal control deficiencies that 

may have existed at the time of our audit. We also assessed 

performance measures in accordance with the Government 

Performance and Results Act of 1993 relevant to the Recovery 

Act. We found that none of the seven sites reviewed had 

developed measures directly related to our audit. We 

addressed the reliability of computer-processed data which we 

considered to be critical to satisfying our audit objective. 

Management waived an exit conference. 
Appendix 2 

___________________________________________________________________ 

Page 8 Prior Reports 

PRIOR REPORTS

The Department of Energy's Quality Assurance Process for Prime Recipients' Reporting 

for the American Recovery and Reinvestment Act of 2009 (OAS-RA-10-01, October 

2009). This report identified that the Department of Energy (Department) had developed 

a quality assurance process to facilitate the quarterly reviews of recipient data. The 

process included procedures to compare existing information from the Department's 

financial information systems with that reported to FederalReporting.gov by recipients. 

In addition, plans were in place to notify recipients of anomalies or errors exposed by the 

quality assurance process. While the Department has made a good deal of progress in 

this area, the report did identify several issues which could, if not addressed, impact the 

effectiveness of the quality assurance process.

Department of Energy's Efforts to Meet Accountability and Performance Reporting 

Objectives of the American Recovery and Reinvestment Act (OAS-RA-09-04, September 

2009). This audit revealed that the Department's efforts to develop, refine, and apply 

control structure needed to ensure, timely, and reliable reporting to be both proactive and 

positive. However, there were certain issues relating to American Recovery and 

Reinvestment Act of 2009 (Recovery Act) performance management, accounting and 

reporting accuracy, and timeliness that needed to be addressed and resolved. In 

particular, at the time of the review, no determination was made whether or not prime and 

sub recipients could properly segregate and report both accounting and performance 

measures.

The American Recovery and Reinvestment Act at the Department of Energy (OAS-RA09-01, March 2009). This report informed the Department leadership of the risks that it 

should consider as stimulus activities progress. Specifically, the report identified specific 

risks discovered during past reviews and investigations in areas such as fund 

accountability and reporting, grant and cooperative agreement execution, contract 

management, and the management of loan guarantee efforts. The report also provides the 

Department with "lessons learned" and suggests approaches for reducing the risks 

associated with the Recovery Act funding. Suggested actions are included that should be 

considered during Recovery Act planning and program execution to help reduce the 

likelihood that historical problems will recur. The report also describes the Department's 

initial efforts to identify risks and to develop strategies to help ensure that the Recovery 

Act goals and objectives are satisfied.
1

March 26, 2010

MEMORANDUM FOR: Rickey R. Hass

 Deputy Inspector General

 For Audit Service 

FROM STEVE ISAKOWIITZ (NO SIGNATURE 508 VERSION)

 CHIEF FINANCIAL OFFICER

SUBJECT: Comments to Draft Report – “Accounting and Reporting for the American 

Recovery and Reinvestment Act by the Department of Energy’s Funding 

Recipients”

Thank you for the opportunity to review your draft report on Recovery Act recipient reporting. As noted by 

your report, the quality assurance program developed by the Office of the Chief Financial Officer for the period 

reviewed by the draft report (third quarter 2009) was a success. Subsequent to the period reviewed by the 

Office of Inspector General, recipient reporting has improved substantially. For the fourth quarter 2009 

reporting period, a greater percentage of the Department's recipients reported and a higher percentage of their 

reports were reviewed by the Department. 

The Office of the Chief Financial Officer is committed to continuously improving the reporting process for 

Recovery Act recipients and has initiated several efforts to further enhance the reporting process. These 

initiatives include:

• Training to over 300 agency reviewers on the Department’s quality assurance process at five DOE sites; 

• Multiple webinars on the quality assurance process;

• Outreach campaign to agency reviewers to encourage them to ensure timely recipient reporting and error 

correction; and

• Continued enhancements to the processes for identifying questionable data reporting. 

The Department concurs with both IG recommendations, which have already been implemented. Please see the 

attached for detailed responses to the draft report’s recommendations. 
2

Response to Inspector General Draft Report

A10RA049- Draft Report “Accounting and Reporting for the American Recovery and Reinvestment Act

(ARRA) by the Department of Energy’s Funding Recipients”

To help enhance the effectiveness of the Recovery Act data quality assurance process, we recommend that the 

Chief Financial Officer work with the program officials to:

Recommendation 1

Adjust the quality assurance process, as necessary, to include adding comparisons of other data elements to 

increase the likelihood that material omissions and significant reporting errors are detected; and,

Management Decision

Concur. The Office of the Chief Financial Officer has already implemented this recommendation. The quality 

assurance process is continuously adjusted to account for changes in reporting guidance and, more importantly, 

to improve the Department’s quality assurance review of recipient data. Recent enhancements include 

additional comparisons for payments, final reports, and award types and updated logic used for assessing the

award amount, thus increasing the likelihood that material omissions and significant reporting errors are 

detected. The Office of the CFO will continue to adjust its quality assurance process as necessary to address 

any issues identified in future reporting periods. 

Estimated Completion Date: Completed. 

Recommendation 2

Ensure that all officials with oversight responsibility for Recovery Act recipient reporting are adequately 

trained. 

Management Decision

Concur. The Office of the CFO has completed numerous training initiatives to ensure that all officials with 

oversight responsibility have the opportunity to be trained on Recovery Act recipient reporting and oversight 

responsibilities. These initiatives include:

• Training to over 300 agency reviewers on the Department’s quality assurance process at five DOE sites; 

• Multiple webinars on the quality assurance process; 

• Outreach campaign to agency reviewers to encourage them to ensure timely recipient reporting and error 

correction; and 

Additionally, the Office of the CFO has developed draft guidance on how the Department will review recipient 

data submitted to OMB for the reporting period covering the first quarter of 2010. The broad concepts of the 

document have been shared with the Field Offices and some select individuals at Headquarters. When the 

OMB guidance is finalized the Office of the CFO will provide agency reviewers 24/7 access to a recorded 

webinar they can review at their convenience. 

Estimated Completion Date: Completed. 
IG Report No. OAS-RA-10-06

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