U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Interim Report 

EPA Travel Program Lacks 

Necessary Controls 

Report No. 10-P-0078 

 March 9, 2010
 
Report Contributors: Bettye Bell-Daniel 

Rae Donaldson 

Johnny Ross 

Bram Hass 

Dwayne E. Crawford 

Eric Lewis 

Abbreviations 

EPA U.S. Environmental Protection Agency 

ES Excepted Service 

FDW Financial Data Warehouse 

OCFO Office of the Chief Financial Officer 

OIG Office of Inspector General 

SES Senior Executive Service 
U.S. Environmental Protection Agency 10-P-0078 

 March 9, 2010 Office of Inspector General 

At a Glance
 

Catalyst for Improving the Environment 

Why We Did This Review 

The Office of Inspector 

General (OIG) conducted 

preliminary research to 

evaluate the U.S. 

Environmental Protection 

Agency’s (EPA’s) management 

controls over the GovTrip 

approval and authorization 

process. 

Background 

EPA travel and delegation 

policies allow EPA Office 

Directors, Laboratory 

Directors, and their equivalents 

to approve their own travel 

authorizations and travel 

payment vouchers. GovTrip 

is the single EPA travel 

management system for 

scheduling, approving, and 

auditing travel authorizations 

and travel payments. The 

General Services 

Administration is the federal 

manager for GovTrip and the 

Office of the Chief Financial 

Officer (OCFO) manages 

GovTrip for EPA. 

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/2010/ 

20100309-10-P-0078.pdf 

EPA Travel Program Lacks Necessary Controls 

What We Found 

The EPA travel program, which comprises EPA policies and GovTrip, lacks 

necessary control procedures to assure all travel authorizations were necessary 

and in the best interest of the government. Additionally, some travelers may 

approve their own travel without mandatory independent review of travel 

authorizations prior to travel. As a result, EPA is unnecessarily vulnerable to 

fraud, waste, and abuse in its travel programs. 

Our preliminary review covered 949 travel documents extracted from the 

Financial Data Warehouse covering the period September 2008 to April 2009. 

Our review of these documents disclosed 199 incidents where travel appeared to 

be self-approved by persons below the intended responsibilities of “Office 

Director” (or equivalent). EPA’s travel policy states that self-approved travel is 

not permitted below the level of Office Directors, Laboratory Directors, and their 

equivalents (presumably Senior Executive Service and Excepted Service 

personnel). The employees associated with the 199 travel records we analyzed 

ranged in grade from GS-12 to GS/GM-15. We will review these records during 

our field work phase for potential violations of the Agency’s travel policy. 

OCFO personnel stated that the data we used from the Financial Data Warehouse 

were unreliable; however, OCFO urges use of this data in support of Agency 

financial transactions and thus the Agency’s financial statements. We intend to 

assess the reliability of the GovTrip data in the Financial Data Warehouse as part 

of our review. 

Poor internal controls also allow personnel to change the routing chain for travel 

approval without notifying their supervisor of record. EPA travel policy requires 

personnel to route travel requests to officials with the authority to authorize their 

travel. However, personnel can circumvent this requirement by requesting a 

routing change to the Agency’s GovTrip helpdesk, or by making the change 

electronically through the GovTrip system. Consequently, through collusion or 

compromise of an approving official’s account, an individual could use 

government funds for unauthorized or personal travel. 

This interim report is for information only and does not represent any final 

conclusions or recommendations by the OIG. However, given the potential 

significance of the areas of vulnerabilities identified, we are providing our 

preliminary findings for information purposes. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

March 9, 2010 

MEMORANDUM 

SUBJECT: EPA Travel Program Lacks Necessary Controls 

 Report No. 10-P-0078 

FROM: Wade T. Najjum 

Assistant Inspector General 

Office of Program Evaluation 

TO: Barbara Bennett 

 Chief Financial Officer 

The Office of the Inspector General (OIG) is providing this interim report on the results of our 

preliminary research regarding the U.S. Environmental Protection Agency’s (EPA’s) 

management controls governing travel authorization and the approval of travel vouchers using 

the GovTrip travel system. OIG managers became aware that an OIG employee acknowledged 

that the employee could authorize his or her own travel despite not meeting the criteria to do so 

under the Agency’s Travel Policy. Subsequently, the OIG conducted preliminary research to 

evaluate EPA’s management controls over the GovTrip approval and authorization process. 

Specifically, we wanted to determine whether these controls are adequate to prevent 

unauthorized and unapproved travel using the GovTrip system. 

We found three potential areas of vulnerability during our preliminary research: 

•	 The EPA travel program, which comprises EPA policies and GovTrip, lacks necessary 

control procedures to assure all travel authorizations were necessary and in the best 

interest of the government. 

•	 Agency implementation of GovTrip allows some individuals authority to authorize their 

own travel. Of 949 travel documents reviewed since GovTrip was implemented in 

September 2008, we noted 199 incidents where travel appeared to be self-approved by 

persons below the intended responsibilities of “Office Director” (or equivalent). 

•	 Poor internal controls also allow personnel to change the routing chain for travel approval 

without notification of their supervisor of record. 
Given the potential significance of the vulnerabilities identified, we are providing the results of 

our preliminary review for information purposes only. The OIG has not completed its overall 

analysis of these issues; therefore, this interim report does not represent any final 

recommendations or conclusions by the OIG. We plan to conduct further analysis during our 

field work phase to evaluate whether the Agency has adequate management controls to ensure 

travel documents are properly routed and authorized through use of the GovTrip system. 

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

applicable daily full cost billing rates in effect and the time – is $548,603. 

If you or your staff have any questions regarding this report, please contact me at 202-566-0832 

or najjum.wade@epa.gov, or Eric Lewis at 202-566-2664 or lewis.eric@epa.gov. 
EPA Travel Program Lacks Necessary Controls 10-P-0078 

Table of Contents 

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

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

Scope and Methodology .................................................................................................. 3 

Results of Preliminary Research..................................................................................... 3 

Conclusion ........................................................................................................................ 7 

Status of Recommendations and Potential Monetary Benefits.................................... 8 

Appendix 

A Distribution ......................................................................................................... 9 
 10-P-0078
 

Purpose 

The Office of the Inspector General (OIG) conducted preliminary research to evaluate the 

U.S. Environmental Protection Agency’s (EPA’s) management controls over the GovTrip 

approval and authorization process. Specifically, we sought to determine whether these 

controls are adequate to prevent unauthorized and unapproved travel using the GovTrip 

system. 

This interim report is for information purposes and does not include any final 

recommendations or conclusions by the OIG. 

Background 

EPA implemented the GovTrip system in September 2008. GovTrip is a large, complex, 

distributed computing system that provides federal travelers with completely automated 

travel planning and reimbursement capabilities. The system allows for the electronic 

submission of travel authorizations and travel vouchers for the approval and 

reimbursement of government travel. 

•	 Travelers and Travel Preparers use GovTrip to arrange all aspects of transportation, 

including to submit a request for and receive reimbursement quickly after travel. 

•	 Approving Officials use GovTrip to monitor and manage all necessary 

authorizations, disbursements, and reimbursements. 

•	 Federal Agency Travel Administrators use GovTrip to set up and maintain data for 

organizations, groups, routing lists, and individual users. 

Common procedures for processing travel authorizations and travel vouchers using the 

GovTrip system are shown in Figure 1. 

Figure 1: Agency Procedures for Processing Travel Documents 

Travel Authorizations Travel Vouchers 

• Traveler/preparer creates the travel 

authorization. 

• The travel authorization is routed to Authorizing 

Official who reviews and stamps the document 

“authorized.” 

• Travel authorization routed to Approver who 

verifies lines of accounting and approves 

document. 

• Traveler/preparer creates the travel 

voucher. 

• The travel voucher is routed to 

Authorizing Official who reviews and 

authorizes the travel voucher. 

• Cincinnati Travel Team reviews the 

travel voucher for payment. 

Source: GovTrip Supplemental Training Packet. 

When a trip is complete, the federal traveler files a voucher that is electronically routed 

for approval and sent to the Agency’s Finance and Accounting Department. An 

electronic funds transfer or a check to the traveler completes the process. 

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EPA Delegations Manual 

EPA 1200 Delegations Manual establishes Agency policy governing the delegation 

process for Agency management officials to act on behalf of the Administrator. 

According to this policy, authority may be re-delegated only when allowed in the specific 

delegation, and re-delegations must be made sequentially from one level to the next 

(e.g., Assistant Administrator to Office Director to Division Director, rather than from the 

Assistant Administrator directly to a Division Director). Further, the policy states that 

the original delegate must keep a written record of all re-delegations of authority to the 

lowest permissible organizational level or individual exercising the authority. However, 

the re-delegation of authority does not exonerate the original delegate or interim levels 

from responsibility or accountability. 

EPA Travel Policy 

EPA’s 1200 Delegations Manual establishes the authority for the authorization and 

approval of both domestic and international travel and certain travel-related activities. 

Chapter 1-17-A (domestic travel), Part 1.n, establishes the authority for the authorization 

and approval of one’s own travel authorizations and travel vouchers. Such authority is 

delegated to the Deputy Administrator, Chief of Staff, Assistant Administrators, Deputy 

Chief of Staff, Chief Financial Officer, General Counsel, Inspector General, and Regional 

Administrators. 

Under Chapter 1-17-A, authority granted under Part 1.n may only be re-delegated to: 

•	 The Deputy Chief of Staff in the Office of the Administrator 

•	 Office Directors (excluding the Office of the Administrator) 

•	 Directors, Office of Administration and Resources Management, Cincinnati and 

Research Triangle Park 

•	 Directors of Laboratories 

•	 Office of Research and Development Laboratory/Center/Office Directors (or 

equivalents) 

According to EPA’s travel policy, further re-delegation by these officials is not permitted. 

Office of Management and Budget Circular A-123 

Office of Management and Budget Circular A-123, Management’s Responsibility for 

Internal Control, states that control activities are the policies and procedures that help 

ensure that management directives are carried out and that management’s assertions in its 

financial reporting are valid. Management’s assertions should include an understanding 

of the control activities applicable at the entity level, such as segregation of duties.1 

1 Office of Management and Budget Circular No. A-123, Section III, Part B.3 – Control Environment, revised 

December 21, 2004. 

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Segregation of duties is a control activity that ensures there are separate personnel with 

authority to authorize a transaction, process the transaction, and review the transaction. 

Scope and Methodology 

We conducted our review in accordance with generally accepted government auditing 

standards. Those standards require that we adequately plan for the audit; properly 

supervise audit staff; obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions; and prepare audit documentation related to the 

planning, conducting, and reporting for each audit. We believe that the evidence 

obtained to date provides a reasonable basis for the information being reported based on 

the purpose of our review. 

We conducted preliminary research from March 2009 through March 2010, during which 

time we analyzed EPA travel data extracted from the Agency’s Financial Data 

Warehouse (FDW) maintained by the Office of the Chief Financial Officer (OCFO). 

These data represented 949 travel documents processed by EPA using the GovTrip 

system. We analyzed travel records that met the following criteria: 

•	 Transactions processed from September 2008 to April 2009. 

•	 Name of authorizer on transaction equaled name of traveler. 

•	 Name of authorizer on transaction equaled name of signer. 

We analyzed travel data, downloaded from the FDW on May 19, 2009, that represented 

travelers who authorized their own travel documents. According to policy, the 

re-delegation of this authority for these records should have been done sequentially and 

to the lowest organizational level of Office Directors, Laboratory Directors, and their 

equivalents. We also analyzed travel data, downloaded on July 22, 2009, to determine 

whether there was any information overlap since May 19, 2009. We determined there 

were no differences in the results of analysis performed between these two periods. 

Results of Preliminary Research 

The results of our preliminary research analysis showed the following: 

•	 The EPA travel program, which comprises EPA policies and GovTrip, lacks 

necessary control procedures to assure all travel authorizations were necessary 

and in the best interest of the government. For instance, EPA’s current domestic 

travel policy allows some travelers the authority to approve their own travel 

without mandatory independent review of travel authorizations or travel vouchers. 

As a result, EPA is unnecessarily vulnerable to fraud, waste, and abuse in its 

travel programs. 

•	 Of the 949 travel documents reviewed, we found 199 incidents where travel 

appeared to be self-approved by persons below the intended responsibilities of 

“Office Director” (or equivalent). EPA’s travel policy states that self-approved 

3
 
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travel is not permitted below the level of Office Directors, Laboratory Directors, 

and their equivalents (presumably grade level of Senior Executive Service (SES) 

or Excepted Service (ES)). The grade level of employees associated with the 199 

incidents ranged from GS-12 to GS/GM-15. 

•	 Poor internal controls also allow personnel to change the routing chain for travel 

approval without notification of their supervisor of record. EPA travel procedures 

require personnel to route travel requests through authorizing officials. However, 

personnel can circumvent this requirement by requesting a change through the 

Agency’s GovTrip helpdesk, or by making the change electronically through the 

GovTrip system. The routing change allows the requestor to “pick” who 

approves the travel authorization. Consequently, through collusion or 

compromise of an approving official’s account, it is possible for an individual to 

use government funds for unauthorized travel. 

Analysis of Delegation of Authority for Travel 

EPA’s travel policy establishes authority for certain Agency officials to approve their 

own travel authorizations and travel vouchers for domestic travel. Such authority is 

delegated to the Deputy Administrator, the Chief of Staff, Assistant Administrators and 

Deputy Chief of Staff, the Chief Financial Officer, the General Counsel, the Inspector 

General, and EPA Regional Administrators. Further re-delegation of this authority is not 

permitted for international travel. 

However, the current domestic travel policy does not include requirements for a 

mandatory independent review of the travel authorizations submitted by the officials 

stated above (presumably employees at the SES and ES level) prior to travel to 

determine whether intended travel is in the best interest of the Agency. Consequently, 

abusive or fraudulent travel and/or travel payments may occur without independent 

Agency review. 

We identified 27 SES/ES employees who approved their own travel authorizations and 

travel vouchers since September 2008. We plan to review travel records corresponding 

to travel taken by these 27 employees to determine what procedures, if any, were 

followed to perform an independent review of their travel justifications and whether the 

travel was in the best interest of the Agency. 

Analysis of Re-delegation Authority for Travel 

EPA’s travel policy states the re-delegation of authority for the self-authorization of 

travel is not permitted below the level of Office Directors, Laboratory Directors, or their 

equivalent. This would indicate that only selected SES/ES personnel are intended to be 

eligible for this authority. We advised OCFO managers that some GS-12/13 personnel 

appeared to have this authority. These OCFO managers responded that the title of Office 

Director varies within individual program and regional offices because the delegation of 

authority is related to position and not grade level. Consequently, various interpretations 

of the Agency’s travel policy may be resulting in situations where persons below the 

4
 
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intended responsibilities of “Office Director” (or equivalent) may be granted the 

authority to authorize their own travel. In our opinion, we do not believe that any 

personnel, including SES/ES personnel, should be allowed to approve their own travel. 

Self-approval results in no segregation of duties over this process as required by Office of 

Management and Budget Circular A-123.2 As a result, EPA’s re-delegation of authority 

allowing individuals self-approval of travel is a control weakness in the Agency’s travel 

process. 

We identified 199 travel documents successfully authorized by EPA employees whose 

grade levels ranged from GS-12 to GS/GM-15. Figures 2 and 3 represent the results of 

our analysis regarding these incidents. 

Figure 2: Incidents by Organization 

Organizational Office 

Number of 

Incidents 

Administrator 1 

Assistant Administrator for International Affairs 1 

Assistant Administrator for Research and Development 20 

Assistant Administrator for Enforcement and Compliance Assurance 49 

Assistant Administrator for Administration and Resources Management 6 

Assistant Administrator for Air and Radiation 18 

Assistant Administrator for Prevention, Pesticides and Toxic Substances 4 

Assistant Administrator for Solid Waste and Emergency Response 7 

Assistant Administrator for Water 12 

Office of Environmental Information 2 

Office of General Counsel 2 

Office of Inspector General 6 

Region 2 New York 1 

Region 3 Philadelphia 9 

Region 4 Atlanta 16 

Region 5 Chicago 18 

Region 6 Dallas 14 

Region 7 Kansas City 2 

Region 10 Seattle 7 

Organization not shown 4 

Total 199 

Source: OIG analysis of Agency travel documents extracted from the Financial Data Warehouse, April 2009. 

2

 Office of Management and Budget Circular A-123, Section III, Assessing Internal Control over Financial 

Reporting discusses the significance of the control environment and control activity on financial reporting. 

Section III, Part 3 identifies segregation of duties as a key control activity for management’s assertions that its 

financial reporting is valid. 

5
 
 10-P-0078 

Figure 3: Incidents by Grade 

Grade Number of Incidents 

GS-12 1 

GS-13 11 

GM/GS-14 80 

GM/GS-15 107 

Total 199 

Source: OIG analysis of Agency travel documents extracted 

 from the Financial Data Warehouse, April 2009. 

We briefed OCFO management in July 2009 regarding these incidents. OCFO managers 

stated that the data we used from the FDW were unreliable; however, OCFO urges the 

OIG to use this data in support of Agency financial transactions and thus the Agency’s 

financial statements. Further, these OCFO managers agreed that the Agency’s policy 

could be revised pending further confirmation of the OIG’s preliminary research results. 

According to these managers, the current travel policy was a collection of several older 

travel manuals, and OCFO had not recently reviewed its overall content. The most recent 

date of the Agency’s Delegation of Authority for domestic travel is July 24, 2008. 

We intend to assess the reliability of the GovTrip data in the FDW as part of our field 

work review. Further, we will review the determining factors used to re-delegate 

authority to individuals to self-authorize and self-approve travel, and determine whether 

these actions adhere to the intent of Agency’s travel policy. 

Analysis of the Routing for Travel Documents 

According to the GovTrip Document Processing Manual,3

 through GovTrip, Federal 

Agency Travel Administrators are able to establish document routing based on 

organization and type of action, and automatically verify compliance with travel policy. 

GovTrip procedures require that travel authorizations and travel vouchers be routed to 

officials with the authority to authorize travel. However, based on tests conducted by the 

OIG, we found that routing changes could be made through the Agency’s GovTrip 

helpdesk or electronically through the GovTrip system without the consent or knowledge 

of the supervisor of record. 

We conducted two tests to determine the effectiveness of management controls over the 

routing of travel documents. One test involved an OIG employee submitting an e-mail to 

the Agency’s GovTrip helpdesk requesting a routing change for the processing of that 

employee’s travel documents. A second test conducted using the GovTrip system 

involved an employee changing the name of the designated authorizing official for the 

routing of the employee’s travel documents. Both tests resulted in successfully changing 

the routing for these individuals’ travel documents to someone other than their designated 

authorizing officials without the consent or notification of their supervisors of record. 

3

 GovTrip Document Processing Manual, Version 3.0, updated March 6, 2009. 

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We were told by an OCFO manager familiar with the Agency’s travel process that it is 

the responsibility of individual program and regional offices to maintain the accuracy of 

their routing chains for travel document processing. This manager stated that it is 

impossible for the GovTrip helpdesk to verify these established routing chains because of 

the frequency with which the names of authorizing officials change. Further, this 

manager stated the Agency has no formal written procedures for this process. Rather, 

most EPA program and regional offices continue to rely on routing chains established 

under the old Travel Manager system. 

These procedures allow personnel to change the routing chain for travel approval without 

notification of the supervisor of record. Consequently, through collusion or compromise 

of an approving official’s account, an individual could use government funds for 

unauthorized or personal travel. We plan to evaluate this issue further during our field 

work phase. 

Conclusion 

•	 The EPA travel program, which comprises EPA policies and GovTrip, lacks 

necessary control procedures to assure all travel authorizations were necessary 

and in the best interest of the government. 

•	 Agency implementation of GovTrip allows some individuals authority to 

authorize their own travel. Of 949 travel documents reviewed since GovTrip was 

implemented in September 2008, we noted 199 incidents where travel appeared to 

be self-approved by persons below the intended responsibilities of “Office 

Director” (or equivalent). 

•	 EPA personnel can change the routing of their travel documents without the 

consent or knowledge of their supervisor of record. 

We make no recommendations in this interim report and no response is necessary. We 

are providing our preliminary findings for information purposes only given the potential 

significance of the areas of vulnerabilities identified. 

We plan to conduct further field work concerning these travel controls to determine 

whether (1) necessary control procedures are in place to help ensure that all travel 

authorizations were necessary and in the best interest of the government, (2) EPA’s travel 

policy governing the re-delegation of authority for self-approval of travel was carried out 

consistently Agency-wide, and (3) program and regional offices had control procedures 

to help ensure that supervisors approved all routing changes. 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. Page Completion Claimed Agreed To 

No. No. Subject Status1 Action Official Date Amount Amount 

No recommendations 

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 

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Appendix A 

Distribution 

Office of the Administrator 

Chief Financial Officer 

Deputy Chief Financial Officer 

Acting Director, Office of Financial Services, Office of the Chief Financial Officer 

Acting Director, Office of Financial Management, Office of the Chief Financial Officer 

Associate Staff Director, Office of Financial Management, Office of the Chief Financial Officer 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Audit Follow-up Coordinator, Office of the Chief Financial Officer 

Acting Inspector General 

9