U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Quick Reaction Report 

Plans to Migrate Data to the 

New EPA Acquisition System 

Need Improvement 

 Report No. 10-P-0071 

 February 24, 2010 
Abbreviations 

CO Contracting Officer 

CS Contracting Specialist 

EAS EPA Acquisition System 

EPA U.S. Environmental Protection Agency 

FPDS Federal Procurement Data System 

ICMS Integrated Contracts Management System 

NIST National Institute of Standards and Technology 

OAM Office of Acquisition Management 

OMB Office of Management and Budget 
U.S. Environmental Protection Agency 10-P-0071 

February 24, 2010 Office of Inspector General 

At a Glance
 

Catalyst for Improving the Environment 

Why We Did This Review 

The Office of Inspector 

General contracted with 

Williams, Adley & Company,

LLP, to review the U.S. 

Environmental Protection 

Agency’s (EPA’s) plans for 

migrating data from the 

Integrated Contracts

Management System (ICMS) 

to the EPA Acquisition

System (EAS) to determine 

whether planned controls will 

ensure complete and accurate 

data transfer. 

Background 

EPA’s Office of Acquisition 

Management supports the 

procurement needs of 

program offices throughout 

the EPA and utilizes the 

ICMS system to facilitate that 

process. The Office of 

Acquisition Management is in 

the process of replacing the 

in-house-developed ICMS 

system with EAS, a 

commercial off-the-shelf 

acquisition system that will be 

configured and modified to 

meet EPA requirements. As 

part of the implementation 

process, data residing in 

ICMS will be migrated to 

EAS. 

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/ 

20100224-10-P-0071.pdf 

Plans to Migrate Data to the New EPA 

Acquisition System Need Improvement 

 What Williams, Adley & Company, LLP, Found 

EPA’s plans for migrating data from ICMS to EAS lack sufficient incorporation 

of data integrity and quality checks to ensure the complete and accurate transfer 

of procurement data. In particular, verification of overall data accuracy relies 

heavily on Contracting Officers to review their own contract data in EAS after it 

has been migrated from ICMS. However, EPA does not require that Contracting 

Officers attend data migration training. In addition, plans to migrate closed 

contracts do not require verification of the accuracy and completeness of that 

data, which will be utilized for historic reporting purposes in EAS. While EAS 

data validation and edit checks will enforce integrity constraints over userentered data, proper data migration controls are paramount to ensuring that the 

acquisition data transfer accurately and completely from ICMS to EAS. 

Proper data migration controls ensure data intended for migration arrive in the 

new system ready for their intended purpose and that erroneous data are 

identified and corrected prior to release in the new system. By taking steps to 

improve its data migration strategy now, EPA increases its chances of achieving 

effective data clean-up prior to migrating ICMS data to EAS. Likewise, 

incorporation of data integrity checks and manual quality control review of data 

would provide management with assurance that (1) it could rely on the accuracy 

and completeness of the data in the new system, and (2) it could report EPA has 

effective internal controls over financial reporting as required by Office of 

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

Internal Control. 

 What Williams, Adley & Company, LLP, Recommends 

Williams, Adley & Company, LLP, recommends that the Director, Office of 

Acquisition Management, Office of Administration and Resources Management, 

require third-party review of migrated data for active and inactive contracts prior 

to release in EAS, enhance the EAS data migration training requirements and 

ensure all Contracting Officers involved in the process attend the training, and 

develop a plan to ensure closed contract data are reviewed for accuracy. 

The Agency generally agreed with the findings and recommendations. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

February 24, 2010 

MEMORANDUM 

SUBJECT:	 Plans to Migrate Data to the New EPA Acquisition System 

Need Improvement 

 Report No. 10-P-0071 

FROM:	 Rudolph M. Brevard 

Director, Information Resources Management Assessments 

Office of Inspector General 

TO: John Gherardini, Acting Director 

Office of Acquisition Management 

Office of Administration and Resources Management 

This is the report on the subject audit conducted by Williams, Adley & Company, LLP, 

(Williams Adley) on behalf of the Office of Inspector General of the U.S. Environmental 

Protection Agency (EPA). This report contains findings that describe the problems Williams 

Adley identified and corrective actions recommended. This report represents the conclusions of 

Williams Adley and does not necessarily represent the final EPA position. Final determinations 

on matters in this report will be made by EPA managers in accordance with established audit 

resolution procedures. 

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 $130,684. 

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. We have no objections 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 regarding this report, please contact me at (202) 566-0893 

or brevard.rudy@epa.gov, or Harry Kaplan, Project Manager, at (202) 566-0898 or 

kaplan.harry@epa.gov. 
February 24, 2010 

MEMORANDUM 

SUBJECT: Plans to Migrate Data to the New EPA Acquisition System Need Improvement 

FROM: Robert J. Fulkerson 

Senior IT Audit Manager 

Williams, Adley & Company, LLP 

THRU: Rudolph M. Brevard 

Director, Information Resources Management Assessments 

Office of Inspector General 

TO: John Gherardini, Acting Director 

Office of Acquisition Management 

Office of Administration and Resources Management 

This memorandum is to inform the U.S. Environmental Protection Agency (EPA) of Williams, 

Adley, & Company LLP critical findings that require management action regarding the 

migration of data to the new EPA acquisition system. 

If you or your staff have any questions regarding this report, please contact Rudolph Brevard at 

(202) 566-0893 or brevard.rudy@epa.gov; or Harry Kaplan, Project Manager, at (202) 566-0898 

or kaplan.harry@epa.gov. 
Plans to Migrate Data to the New EPA Acquisition 10-P-0071 

System Need Improvement 

Table of Contents 

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

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

Scope and Methodology............................................................................................. 1 

Findings ....................................................................................................................... 2 

Migration Plans Lack Third-party Review of Migrated Data Prior to Release ...... 2 

Migration Plans Lack Mandatory Data Migration Training.................................... 3 

Migration Plans Lack Review of Closed Contract Data Used for Reporting......... 3 

Recommendations...................................................................................................... 4 

Status of Recommendations and Potential Monetary Benefits.............................. 5 

Appendix 

A Distribution ......................................................................................................... 6 
10-P-0071 

Purpose 

The Office of Inspector General contracted with Williams, Adley & Company, LLP, (Williams 

Adley) to review the U.S. Environmental Protection Agency’s (EPA’s) plans for migrating data 

from the Integrated Contracts Management System (ICMS) to the EPA Acquisition System 

(EAS) to determine whether planned controls will ensure complete and accurate data transfer. 

Background 

EPA’s Office of Acquisition Management (OAM) supports the procurement needs of program 

offices throughout EPA and utilizes ICMS to facilitate that process. OAM is in the process of 

replacing the in-house-developed ICMS application with EAS, a commercial off-the-shelf 

acquisition system that will be configured and modified to meet EPA requirements. As part of 

the implementation process, data residing in ICMS will be migrated to EAS. 

According to the EAS Data Migration Scope and Approach document, data migration to EAS 

was scheduled to begin in June 2009. However, EPA has delayed data migration until April 5, 

2010, due to concerns regarding adequate documentation of system requirements, test scripts, 

and testing plans. Like its predecessor ICMS, EAS will provide summary procurement data to 

the General Services Administration’s Federal Procurement Data System – Next Generation 

(FPDS-NG) to support congressional reporting and public access to the data. 

Federal guidance underscores how important it is that EPA ensure the accuracy and 

completeness of data imported into the EAS system from ICMS. The National Institute of 

Standards and Technology (NIST) and Office of Management and Budget (OMB) require EPA 

to consistently apply data entry controls to ensure the integrity of their information technology 

systems and data and to accurately report contractual actions to the Federal Procurement Data 

System (FPDS). Specifically, OMB Circular A-127, Financial Management Systems, states that 

internal controls over data entry and transaction processing shall be applied consistently 

throughout the system to ensure the validity of information. NIST Special Publication 800-30, 

Risk Management Guide for Information Technology Systems, states that system and information 

owners are responsible for ensuring proper controls are in place to address integrity of data they 

own. Small Business Administration publication M-06-28, Reporting Small Business 

Contracting Information, states that each agency and department is responsible for submitting 

accurate data to FPDS and verifying the accuracy of such data. Lastly, Federal Acquisition 

Regulation 4.604(a) holds the Senior Procurement Executive and head of the contracting activity 

responsible for monitoring a process that ensures accurate reporting of contractual actions to 

FPDS. 

Scope and Methodology 

We performed this audit from April through December 2009 at EPA Headquarters in 

Washington, DC. We conducted the audit in accordance with generally accepted government 

auditing standards. 

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These standards require that we plan and perform the audit to obtain sufficient and appropriate 

evidence to provide a reasonable basis for our findings and conclusions based on the audit 

objectives. The evidence obtained from our audit tests and processes provides a reasonable basis 

for our findings and conclusions. 

We assessed the EAS Data Migration process and considered relevant internal controls 

associated with the scope of our review. We reviewed relevant Data Migration documentation, 

such as project and data management plans, migration tool requirements and design documents, 

and sample migration code. We also conducted interviews with the EAS Project Management 

Team and attended a data migration training session to ascertain the adequacy of planned data 

integrity controls. 

Findings 

EPA’s plans for migrating data from ICMS to EAS lack sufficient incorporation of data integrity 

and quality checks to ensure the complete and accurate transfer of procurement data. In 

particular, verification of overall data accuracy relies heavily on Contracting Officers (COs) to 

review their own contract data in EAS after it has been migrated from ICMS. However, EPA 

does not require that COs attend data migration training. In addition, plans to migrate closed 

contracts do not require verification of the accuracy and completeness of that data, which will be 

utilized for historic reporting purposes in EAS. While EAS data validation and edit checks will 

enforce integrity constraints over user-entered data, proper data migration controls are paramount 

to ensuring that the acquisition data transfer accurately and completely from ICMS to EAS. 

Proper data migration controls ensure data intended for migration arrive in the new system ready 

for their intended purpose and that erroneous data are identified and corrected prior to release in 

the new system. By taking steps to improve its data migration strategy now, EPA increases its 

chances of achieving effective data clean-up prior to migrating ICMS data to EAS. Likewise, 

incorporation of data integrity checks and manual quality control review of data would provide 

management with assurances that (1) it could rely on the accuracy and completeness of the data 

in the new system, and (2) it could report EPA has effective internal controls over financial 

reporting as required by OMB Circular A-123, Management’s Responsibility for Internal 

Control. 

Migration Plans Lack Third-party Review of Migrated Data Prior to Release 

Data migration plans include data clean-up efforts that focus on reconciling Vendor and 

Financial Data to the financial system of record prior to data migration. The accuracy of 

remaining procurement data, such as detailed contract terms, relies on verification by the 

CO or Contracting Specialist (CS) once it has been migrated to EAS. Data that have 

been migrated to EAS but have yet to be reviewed and released into the system are 

referred to as “reconstruct” data. The CO or CS will be required to review this 

reconstruct data for accuracy and completeness prior to releasing it into EAS. While 

verification guidance outlined in the EAS Reconstruct Review Steps indicates 

functionality to route the reconstruct to another party such as the CO for additional 

review, this routing has not been explicitly stated as a requirement. Thus, data are 

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currently only required to be validated by the sole CO or CS responsible for migration of 

that contract. 

Relying on a single CO or CS verification is a weak quality control procedure that should 

be enhanced by requiring a third party, such as a CO not responsible for the contractor or 

another outside party, to perform a secondary review of data prior to release into EAS. 

Such a requirement would provide greater assurance regarding the accuracy of migrated 

data. 

Migration Plans Lack Mandatory Data Migration Training 

Williams Adley attended an EAS Migrated Data Review Orientation (data migration 

training) on April 2, 2009, conducted for COs and CSs at the Ronald Reagan Building in 

Washington, DC. The purpose of this training was to instruct COs and CSs on the data 

verification phase of the migration. We noted that appropriate emphasis was placed on 

instructing COs and CSs to verify migrated EAS data against the hardcopy version of the 

procurement documents, which at EPA is the document of record. At the time of the 

training, the procurement document attachment feature of EAS was not functional and 

was thus not addressed in detail. As the revised EAS project rollout plan includes 

migration of attachment documents from ICMS to EAS, training materials must be 

updated to ensure COs and CSs are instructed to verify such attachments against the 

hardcopy versions to ensure the correct attachments were migrated. 

While OAM recommends that all COs and CSs involved in verification of the migrated 

data attend the data migration training, it has not been made a mandatory prerequisite for 

CO and CS participation in the data verification process. Because verification of overall 

data accuracy relies heavily on COs to review their own contract data in EAS once they 

have been migrated from ICMS, it is imperative that these individuals have the 

knowledge and toolset to carry out that responsibility, as well as understand its 

importance. 

Migration Plans Lack Review of Closed Contract Data Used for Reporting 

According to Migration Tool Design Documents, migrated data verification efforts 

performed by the CO and CS will be limited to active contracts imported from ICMS. 

Inactive ICMS contracts will only be reviewed and released into EAS as needed by the 

CO or CS. By design, closed contract data will not be subject to the same data integrity 

checks and verification efforts as active contracts. These closed contracts will be 

migrated to an Ad Hoc Reporting module of EAS as is, where the data will be available 

for reporting purposes. Because EPA’s priority is to verify data needed to carry out work 

on ongoing contracts, significant historical reporting and output data inaccuracies could 

potentially exist, and any inconsistencies in closed contract data will carry forward to the 

new EAS system. This situation could potentially reduce the ability of EPA management 

to rely on EAS data for decision-making purposes. 

In response to the draft report issued on December 18, 2009, we met with the Agency on 

February 2, 2010. The Agency, in general, agreed with the findings and recommendations. The 

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Agency expressed concern about the resources needed to conduct a 100 percent third-party 

review of migrated data. However, the Agency sees the value in conducting such reviews and 

will develop a plan to address our concerns. 

Recommendations 

Williams, Adley & Company, LLP, recommends that the Director, Office of Acquisition 

Management, Office of Administration and Resources Management: 

1.	 Require third-party review of migrated data for active and inactive contracts prior to 

release in EAS. 

2.	 Enhance the EAS Migrated Data Review Orientation and require that all Contracting 

Officers who will be involved in the data migration process attend. 

3.	 Develop a plan to ensure closed contract data are reviewed for accuracy. 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

1 

2 

3 

4 

4 

4 

Require third-party review of migrated data for 

active and inactive contracts prior to release in 

EAS. 

Enhance the EAS Migrated Data Review 

Orientation and require that all Contracting Officers 

who will be involved in the data migration process 

attend. 

Develop a plan to ensure closed contract data are 

reviewed for accuracy. 

O 

O 

O 

Director, Office of Acquisition 

Management, Office of 

Administration and 

Resources Management 

Director, Office of Acquisition 

Management, Office of 

Administration and 

Resources Management 

Director, Office of Acquisition 

Management, Office of 

Administration and 

Resources Management 

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 

5 

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Appendix A 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Administration and Resources Management 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

Acting Director, Office of Acquisition Management, Office of Administration and 

 Resources Management 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Affairs 

Associate Administrator for Public Affairs 

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

Audit Follow-up Coordinator, Office of Acquisition Management, 

Office of Administration and Resources Management 

Acting Inspector General 

6