GAO-04-383R Grants Management 

January 30, 2004 

The Honorable James M. Inhofe 

Chairman, Committee on Environment 

 and Public Works 

United States Senate 

Subject: Grants Management: EPA Actions Taken against Nonprofit Grant 

Recipients in 2002

Dear Mr. Chairman: 

The Environmental Protection Agency (EPA) awards over one-half if its budget, or 

about $4 billion, annually in grants.1 At the end of fiscal year 2002, EPA was 

providing funding to 4,100 grant recipients, with $245.4 million, or nearly 6 percent of 

its awarded grant dollars, going to nonprofit grant recipients. Congressional hearings 

in 1996 and 1999 cited concerns with the grants management capabilities of nonprofit 

grantees. Specifically, the 1996 hearing raised questions about nonprofit grant 

recipients’ use of federal funds for lobbying. The 1999 hearing cited concerns with 

the ability of nonprofit grantees to manage their grants,2

 because, for example, many 

nonprofit organizations do not have staff with accounting backgrounds. Often, their 

grants are too small to be covered under the requirements of the Single Audit Act.3

 In 

response to such concerns, EPA has included lobbying restrictions in grant 

agreements, issued guidance and policies on grantee oversight, and has attempted to 

improve nonprofit grantees’ grants management with a 1-day training course and 

follow-up instructional videotape specifically designed for nonprofit grant recipients. 

 

1

Federal financial assistance includes grants, cooperative agreements, loans, loan guarantees, 

scholarships, and other forms of assistance. For simplicity, we are referring to all financial assistance 

as “grants.” 

2

40 C.F.R. Part 30 contains grant management requirements for recipients including nonprofit 

organizations. 

3

The Single Audit Act Amendments of 1996, Pub. L. No. 104-156, 110 Stat. 1396 (codified at 31 U.S.C. §§ 

7501-7507), requires grantees to have an audit of their financial statements and federal awards or a 

program specific audit if they spend $300,000 or more in federal awards in a fiscal year. The Office of 

Management and Budget (OMB), as authorized by the act, increased this amount to $500,000 in federal 

awards as of June 23, 2003. 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-383R Grants Management 

However, as we reported in August 2003,4 nonprofit grant recipients continue to have 

problems managing their grants.5

 These problems have led EPA to recommend 

actions to correct specific problems, such as maintaining records to track staff time, 

obtaining a required audit, and improving a financial management system. In some 

cases, these problems led EPA to take more significant actions against nonprofit 

grant recipients, such as issuing suspension orders, holding payments, and 

designating grantees as high-risk. 

As a result of continuing concerns about the problems that nonprofit grant recipients 

have had in managing their grants, you asked us to provide supplementary 

information on the grants management performance of nonprofit grantees. 

Specifically, this report discusses (1) grants management problems EPA identified 

with nonprofit recipients in 2002, (2) corrective actions EPA recommended to 

address these problems, and (3) EPA’s more significant actions taken against specific 

nonprofit grant recipients. 

To obtain this information, we relied on the results of our analysis of EPA’s oversight 

of grant recipients conducted in calendar year 2002. As part of this effort, we 

reviewed the records of 1,232 in-depth grantee reviews EPA conducted. EPA 

conducts in-depth reviews to analyze grantees’ compliance with grant regulations and 

specific grant requirements.6

 For each of these in-depth reviews, we developed and 

answered a standard set of questions concerning the grantee and the findings of the 

review.7

 We also obtained and analyzed additional information from EPA on the 

nonprofit grant recipients who received significant actions, including background 

information on the organizations and any results of EPA actions. For each of these 

grant recipients, we summarized EPA’s information on the problems identified, the 

corrective actions recommended, significant actions taken, and the results of EPA’s 

actions, if provided. Enclosure I describes the types of problems EPA identified in its 

1,232 in-depth reviews and provides examples of these problems. Enclosure II 

provides specific details on 15 nonprofit grant recipients that EPA took a significant 

action against in 2002. 

EPA Identified Many Problems with Nonprofit Grant Recipients

According to our analysis of EPA’s calendar year 2002 in-depth reviews, EPA 

identified 276 problems with nonprofit grantees. EPA identified these problems in 

the 245 reviews it conducted of nonprofit grant recipients. These reviews 

 

4

U.S. General Accounting Office, Grants Management: EPA Needs to Strengthen Efforts to Address 

Persistent Challenges, GAO-03-846 (Washington, D.C.: Aug. 29, 2003). 

5

For additional information on nonprofit grantees and EPA’s oversight of them, see, U.S. General 

Accounting Office, Environmental Protection: EPA’s Oversight of Nonprofit Grantees’ Costs Is 

Limited, GAO-01-366 (Washington, D.C.: Apr. 6, 2001). 

6

EPA refers to these in-depth reviews as advanced monitoring. EPA conducts these reviews either at 

the grantee’s location (on-site) or at EPA’s office or another location (off-site). In 2002, EPA also 

contracted with private firms to perform reviews of a limited number of grantees as part of a pilot 

program. 

7

For detailed methodology, see GAO-03-846, app. I. 
Page 3 GAO-04-383R Grants Management 

represented 20 percent of EPA’s 1,232 in-depth reviews.8 The identified problems 

included inadequate accounting systems, failure to obtain approved indirect cost 

rates, and insufficient documentation to support sole-source contracts and other 

expenditures charged to the grants. Table 1 describes the five most frequently 

identified types of problems with nonprofit grant recipients. 

Table 1: Most Frequently Identified Problems with Nonprofit Grant Recipients, 2002 

Problem Number of problems Examples of this type of problem 

Technical issues 49 The grantee was behind in the progress of its work. 

Written procedures 41 The grantee’s written policies or procedures were either missing or 

inadequate. 

Procurement 38 The grantee lacked documentation to support sole-source contracts and 

did not report its efforts to encourage procurement from disadvantaged 

businesses. 

Progress reports 29 The grantee’s progress report was late, or it did not include all the 

necessary information. 

Personnel/payroll 28 The grantee did not track the amount of time its employees spent on 

specific grant activities or did not have appropriate staff resources to 

perform the grant activities. 

Source: GAO’s analysis of EPA’s in-depth reviews. 

EPA identified at least one problem in almost half of its reviews of nonprofit grant 

recipients. Table 2 shows the number of problems identified per in-depth review for 

nonprofit grant recipients. 

Table 2: Number of Problems Per In-depth Review of Nonprofit Grant Recipients, 2002 

Number of problems identified Number of reviews Percentage of reviews 

0 124 51 

1 51 21 

2 34 14 

3 15 6 

4 8 3 

5 6 2 

6 2 1 

7 2 1 

8 3 1 

Total 245 100 

Source: GAO’s analysis of EPA’s in-depth reviews. 

Our analysis of EPA’s 2002 in-depth reviews also identified similar grants 

management problems with other types of recipients including states, native 

American tribes, local governments, universities, and others (see GAO-03-846, app. 

III). 

EPA Recommended Corrective Actions to Resolve More than Half of the 

Problems Identified 

Overall, EPA recommended that nonprofit grant recipients take corrective action in 

response to an identified problem in approximately 66 percent of the in-depth 

reviews we analyzed. For example, EPA found that a nonprofit grant recipient 

needed to have a Single Audit conducted for 2001 and 2002. EPA recommended that 

the recipient immediately arrange to have these audits conducted. For another 

nonprofit grant recipient, EPA found that the recipient received funding from 

multiple sources but did not maintain records to track the staff time that was 

 

8

In 2002, EPA conducted 135 reviews of the nonprofit recipients on-site and 110 off-site. 
Page 4 GAO-04-383R Grants Management 

allocated to each of these grants. EPA recommended that the recipient develop and 

use timekeeping records that meet the standards outlined in the Office of 

Management and Budget’s (OMB) circular.9

 Table 3 shows the number of nonprofit 

grant recipient problems identified by type of problem, compared with the number of 

corrective actions EPA recommended. 

Table 3: Comparison of Nonprofit Grant Recipient Problems with EPA’s Recommended Corrective 

Actions, 2002 

Problem 

Number of 

problemsa 

Number of corrective 

actions 

Percentage of problems with corrective 

action 

Accounting 18 16 89 

Administrative 12 7 58 

Approval of modifications 1 0 0 

Conflict of interest 4 1 25 

Cost sharing 1 0 0 

Financial expenditures 13 10 77 

Indirect costs 7 6 86 

Internal controls 11 10 91 

Lobbying 0 0 N/A 

Missing required audit 2 2 100 

Personnel/payroll 28 20 71 

Procurement 38 29 76 

Program income 1 0 0 

Progress reports 29 16 55 

Property management 3 3 100 

Quality assurance 5 2 40 

Subagreements 1 1 100 

Technical issues 49 17 35 

Terms and conditions of 

work 

8 1 13 

Travel 4 4 100 

Written procedures 41 36 88 

Total 276 181 66 

Source: GAO’s analysis of EPA’s in-depth reviews. 

a

See enclosure I for a description of problems identified in EPA’s in-depth reviews.

Our analysis of EPA’s 2002 in-depth reviews found that for all types of grant 

recipients (nonprofits, states, native American tribes, local governments, universities, 

and others), EPA recommended corrective actions for about half the problems it 

identified (see GAO-03-846, app. III). 

EPA Took Significant Actions against Some Nonprofit Grant Recipients 

We also found that EPA took 32 significant actions against 15 different nonprofit 

grant recipients. These significant actions are shown in table 4. 

 

9

OMB has issued three circulars defining allowable costs for different types of grant recipients: A-21, A87, and A-122. 
Page 5 GAO-04-383R Grants Management 

Table 4: Significant Actions EPA Took Against Nonprofit Grant Recipients, 2002 

Type of significant action Description of significant action 

Number of 

significant 

actions 

Grant termination/annulment or 

novation (or transfer) 

EPA cancels the grant, or transfers it to a different recipient. 1 

Disallowance of costs EPA disallows a recipient’s expenditures when the agency 

determines that the recipient did not spend its grant funds in 

accordance with federal cost principles or its particular grant 

agreement. 

7 

Suspension order EPA requires a recipient to stop work and take action to minimize its 

grant-related expenditures until it resolves EPA’s areas of concern. 

5 

Payment hold EPA decides it will not make any more payments to a recipient until 

the recipient has resolved an area of concern. 

6 

High-risk designation/imposition 

of special grant conditions 

EPA designates the recipient as high risk and places certain 

requirements on further grant work, such as having EPA approve all 

expenditures before the recipient receives a reimbursement. 

5 

Referral for investigation EPA requests that its Inspector General conduct an audit of the 

recipient. 

3 

Threat to take action EPA threatens to take a significant action, such as disallowance of 

costs or a payment hold. 

5 

Total 32 

Source: GAO analysis of EPA documents. 

Note: EPA can also debar a grant recipient by declaring that the particular organization or individual is not eligible to receive 

grants for a specific period of time. We did not find any instances where EPA debarred grant recipients in 2002. 

In addition to taking significant actions against nonprofit grant recipients EPA also 

took actions against state and tribal grant recipients in 2002 (see GAO-03-846, app. 

III). 

Of the 32 significant actions EPA took against nonprofit grant recipients in calendar 

year 2002, 23 resulted from problems identified during in-depth reviews. EPA took 

the other nine significant actions as a result of problems identified during grantee 

oversight other than in-depth reviews and investigations by the EPA Office of 

Inspector General (OIG). Our analysis found that of the 36 nonprofit grant recipients 

that had three or more problems identified during in-depth reviews, EPA took at least 

one significant action in nine cases, or 25 percent of the cases. Nonprofit grant 

recipients that received significant actions were often cited as having multiple 

problems related to their accounting systems, internal controls, or financial 

expenditures. While the problems identified with some of these nonprofit recipients 

have been resolved through corrective and significant actions, information provided 

by EPA indicates that many problems remain unresolved. For example, some 

recipients have improved their financial management systems as a result of 

recommended actions, while in other instances a number of questionable grant 

expenditures are still in the audit resolution process.10 We have enclosed detailed 

information concerning the circumstances surrounding 15 nonprofit grant recipients 

that had significant actions taken against them in 2002 (see encl. II). 

We provided a draft of this report to EPA for comment. In response, we received oral 

comments from EPA officials including the Director of the Grants Administration 

Division. The EPA officials generally agreed with the information presented in our 

report and provided some clarifying comments that we incorporated into this report, 

as appropriate. 

 

10EPA noted that for some of the cases with questionable costs still in the audit resolution process, 

grant recipients have challenged the OIG’s findings under EPA’s grant dispute procedures. 
Page 6 GAO-04-383R Grants Management 

- - - - - - 

We performed our work from December 2003 through January 2004 in accordance 

with generally accepted government auditing standards. As we agreed with your 

office, unless you publicly announce the content of this report earlier, we plan no 

further distribution until 30 days from the report date. At that time, we will be 

sending copies of this report to the congressional committees with jurisdiction over 

EPA and its activities; the Honorable Mike Leavitt, EPA Administrator; and the 

Honorable Joshua B. Bolten, Director, Office of Management and Budget. In 

addition, this report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you have any questions about this report or need additional information, please 

contact me at (202) 512-3841. Key contributors to this report were Andrea Wamstad 

Brown, Christopher Murray, Rebecca Shea, Carol Herrnstadt Shulman, and Amy 

Webbink. 

Sincerely yours, 

John B. Stephenson 

Director, Natural Resources 

 and Environment 
Enclosure I 

Page 7 GAO-04-383R Grants Management 

Description of Problems Identified in EPA’s 1,232 In-depth Reviews

Problem Description of problems included in EPA’s in-depth reviews 

Accounting Any failure of a grantee’s financial management system of shortcomings in the 

procedures it used to ensure the proper accounting of federal funds. For example, EPA 

found cases in which a grantee 

• could not compare budgeted amounts with actual expenditures, 

• did not properly reconcile report balances to the general ledger, or 

• did not separately track funds for different grants. 

Administrative Cases in which a grantee’s record keeping system was inadequate. 

Approval of 

modifications 

Any instance in which a grantee had begun performing tasks outside its original scope of 

work without seeking prior approval from EPA. 

Conflict of interest Cases in which a grantee, using grant funds, entered into a contract with a closely 

affiliated organization. 

Cost sharing Cases in which a grantee failed to appropriately track and document its cost-sharing 

expenditures. 

Financial 

expenditures 

Cases in which a grantee did not sufficiently document expenses to determine the 

eligibility of costs or charged ineligible costs to the grant. 

Indirect costs Cases in which a grantee did not have an approved indirect cost rate or indirect cost 

allocation plan. 

Internal controls Cases in which a grantee did not adequately segregate financial responsibilities. 

Lobbying No instances of lobbying problems. 

Missing required 

audit 

Cases in which a grantee did not have its required audit performed or had not submitted a 

copy of its audit to EPA. 

Personnel/payroll Problems included cases in which a grantee did not track the amount of time its 

employees spent on specific grant activities, or did not have sufficient staff resources to 

perform the grant activities. 

Procurement Cases in which grantees lacked documentation to support sole-source contracts and did 

not report their efforts to encourage procurement from disadvantaged businesses. 

Program income In one case, a grantee generated income through the use of grant funds but did not 

manage the funds in accordance with the grant agreement; and in another, the grant 

agreement did not allow the grantee to generate such income. 

Progress reports Instances in which a grantee’s progress report was missing or late, or did not include all 

the necessary information. 

Property 

management 

Cases in which the grantee did not properly control property, such as equipment. 

Quality assurance Instances in which a grantee needed to revise its quality assurance plan. Quality 

assurance plans are required to ensure the quality of data collected during the grant work. 

Subagreements Cases in which a grantee did not properly monitor subgrantees, or when a subgrantee’s 

files were incomplete. 

Technical issues Cases in which a grantee was behind in the progress of its work. 

Terms and 

conditions 

Cases in which a grantee was not meeting the terms and conditions of a grant agreement. 

Terms and conditions vary, depending on the grant agreement and in some cases overlap 

with the other problem categories. 

Travel Cases in which a grantee lacked documentation to support travel expenditures or did not 

obtain written approval from the appropriate official prior to incurring travel expenses. 

Written procedures Cases in which a grantee’s written policies or procedures were either missing or 

inadequate. 

Source: GAO’s analysis of EPA’s in-depth reviews. 
Enclosure II 

Page 8 GAO-04-383R Grants Management 

Detailed Information on 15 Nonprofit Grant Recipients that Received 

Significant EPA Actions in 2002 

This enclosure provides detailed information on 15 nonprofit grant recipients against 

which the Environmental Protection Agency (EPA) took significant actions in 2002. 

The information provided includes background on the recipient and the grant(s) 

received, descriptions of EPA identified problems and recommended corrective 

actions, EPA’s significant actions, the results of these corrective and significant 

actions, and other information. This information is presented for each grant recipient 

in alphabetical order. We developed this information from our analysis of EPA’s 2002 

in-depth reviews, as well as other information we obtained from EPA during our audit 

work for the August 2003 report on EPA’s grants management.11 Additionally, EPA 

provided specific information on these 15 grant recipients. 

Academy of Natural Sciences 

During the week of October 22, 2001, officials from EPA’s Region 3 conducted an onsite evaluation of the Academy of Natural Sciences (the Academy) and identified 

several concerns with the Academy’s financial management and procurement 

systems. A subsequent review by officials from EPA’s Office of Grants and 

Debarment on February 27, 2002, found that these concerns had been addressed 

through the appropriate corrective actions. However, after evaluating the costs 

charged to the grant, Region 3 disallowed costs in the amount of $51,085 because of a 

conflict of interest and lack of competition of a contract agreement, and lack of 

supporting documentation in accounting records. The Region 3 Administrator 

reversed the decision to disallow these costs on January 22, 2003. 

Background 

The Academy is a nonprofit organization governed by a board of trustees. It was 

founded in 1812 for the purpose of advancing knowledge about the natural world. 

The Academy is based in Philadelphia, Pennsylvania, and is affiliated with the Patrick 

Center for Environmental Research and the Estuarine Research Center. 

Grants Received 

• The Academy received a grant for $500,000 (X-983127-01) in June 1999, for the 

Urban Rivers Awareness Program; a pilot program for scientific research, 

hands-on and virtual educational experiences and exhibit design. The 

recipient received an amendment in June 2000 for an additional $665,000, 

bringing the total award to $1,165,000. This grant was closed in July 2003 after 

Region 3 received all required deliverables. 

• The Academy received a grant for $698,500 (X-983127-02) in August 2001 for 

the Urban Rivers Awareness Program. The objectives of this grant were to 

test watershed education methods and to have a sustainable, effective 

 

11GAO-03-846.
Enclosure II 

Page 9 GAO-04-383R Grants Management 

program. The recipient received an amendment for this grant in August 2003 

and work on the grant is ongoing. 

• The Academy received a grant for $76,569 (CB-983683-01) in August 2002 for 

the Chesapeake Bay Program. The purpose of this grant was to assist in 

characterizing chemical contaminant impacts in tributaries to the Chesapeake 

Bay. Work on this grant is ongoing, and the project is scheduled to last until 

June 2004. 

Description of Problems and Corrective Actions

The reviewers found problems in the following areas with the Academy’s 

management of grant number X-983127-01:12

Conflict of Interest 

• The Academy entered into a contract for work with an entity whose sole 

owner was previously employed by the recipient. More importantly, the scope 

of work for the contract was submitted on August 11, 2000, but the employee 

was not separated from the organization until September 29, 2000, and the 

contract was signed on October 19, 2000. The reviewers determined that this 

was a conflict of interest and that the contract had not been awarded 

competitively, and disallowed the costs of the contract in the amount of 

$44,900. 

Financial Expenditures 

• The Academy could not provide adequate documentation to support a charge 

to the grant in the amount of $6,185. The reviewers disallowed these costs. 

Procurement 

• The Academy’s procurement files did not include documentation of 

competitive awards or cost or price analyses for contracts awarded, although 

its policies and procedures required this documentation. The reviewers 

recommended that the recipient perform a cost or price analysis for the 

remaining contracts awarded under the EPA grant. 

EPA’s Significant Actions

EPA notified the Academy that, based on its evaluation of costs incurred under grant 

number X-983127-01, it was disallowing $51,085 for nonconformance with EPA grants 

management regulations. This amount included the $44,900 from the noncompetitive 

contract the Academy had awarded to a previous employee and $6,185 in costs for 

 

12These problems were those with corrective actions outstanding after the February 2002 review by 

officials from the Office of Grants and Debarment. They do not represent all of the grants 

management deficiencies identified during the Region 3 October 2001 review. 
Enclosure II 

Page 10 GAO-04-383R Grants Management 

which the Academy could not provide adequate supporting documentation. EPA 

requested that a check for this amount be mailed to Region 3 within 30 days. 

Results of Corrective and Significant Actions, and Other Information

In February 2002, officials from EPA’s Office of Grants and Debarment found that the 

Academy had addressed the problems with its financial and procurement systems 

identified by Region 3 officials. However, the Academy appealed the decision to 

disallow $51,085 in costs. The Regional Administrator for Region 3 reversed the 

decision to disallow these costs on January 22, 2003. EPA indicated that this decision 

was made after reviewing additional information and supporting documentation 

submitted by the Academy for the disallowed costs.
Enclosure II 

Page 11 GAO-04-383R Grants Management 

American Public Works Association 

On January 30, 2002, officials from EPA’s Office of Grants and Debarment conducted 

an on-site, in-depth review of a grant with the American Public Works Association 

(the Association). The reviewers found a number of problems including unallowable 

costs related to alcoholic beverages included as part of meal expenses. EPA reported 

that the Association took corrective action before the recipient was formally notified. 

Background

The Association is a nonprofit organization governed by a 17-member board of 

directors. The Association is an international educational and professional 

association of public agencies, private sector companies, and individuals that provide 

goods and services related to public works. It has offices in Kansas City, Missouri 

and Washington, D.C., and is affiliated with the Canadian Public Works Association. 

 Grants Received 

• The Association received a grant for $55,000 (X-82741801-2) in May 1999 to 

inform its members and other interested parties about certain federal 

stormwater regulations. EPA reported that the workshops the Association 

hosted were successful, and the program generated enough income for the 

recipient to complete the work without drawing all of the grant funds 

available. The grant was closed in June 2003. 

Description of Problems and Corrective Actions

The reviewers found problems and recommended corrective actions in the following 

areas: 

Financial Expenditures 

• The Association’s policies allowed alcoholic beverages to be included as part 

of meal expenses that in some cases were paid by the grant. EPA 

recommended that the recipient examine all meal expenses paid for by federal 

funds, and reimburse the appropriate accounts. 

Procurement 

• The Association had not filed reports of its efforts to select disadvantaged 

businesses for grant activities. EPA recommended that the recipient 

implement internal control policies and procedures within 30 days, including 

maintaining documentation, to ensure compliance with the grant’s terms and 

conditions regarding the selection of these businesses. EPA also 

recommended that the recipient begin submitting its required report to EPA 

within 90 days. 
Enclosure II 

Page 12 GAO-04-383R Grants Management 

• The Association was unable to provide documented evidence of a cost or price 

analysis being conducted for advertising services. The Association was 

purchasing space in its own official magazine. However, the reviewers could 

not find documentation supporting or justifying the award of the 

noncompetitive contract for advertising services. EPA recommended that the 

recipient perform and document a cost or price analysis for every 

procurement action using federal funds. EPA also required the recipient to 

construct contract files that include a sole source justification in all 

noncompetitively awarded contracts. 

EPA’s Significant Actions

Following the review, EPA provided the Association with a letter documenting its 

concerns and asking the recipient to provide a corrective action plan within 30 days. 

These corrective actions included examining all meal expenses paid for by federal 

funds, and reimbursing the appropriate accounts. 

Results of Corrective and Significant Actions, and Other Information

EPA noted that the Association began taking action to address its concerns on 

compliance with requirements for selecting disadvantaged businesses and justifying 

noncompetitive contracts. Additionally, the Association’s accounting staff began 

removing alcoholic beverage charges from the grant accounts. EPA reported that the 

recipient took corrective action before it was formally notified.
Enclosure II 

Page 13 GAO-04-383R Grants Management 

Association for Commuter Transportation/Transportation Demand 

Management Institute 

On July 11, 2002, an official from EPA’s Office of Grants and Debarment 

conducted a prereview in preparation for an on-site review of a grant with the 

Transportation Demand Management Institute (the Institute). The reviewer found 

that the Institute actually had no paid employees, but rather employees of Urban 

Trans Consultants, an associated for-profit company, were contracted to work on 

the grant. As a result of the conflicts of interest that were apparent with this 

company, EPA warned the Institute that it was considering whether to issue a 

suspension order unless the recipient responded within 10 days. 

The response provided to EPA did not satisfy all concerns regarding the apparent 

conflicts of interest, and EPA asked for additional information. EPA conducted 

an on-site, in-depth review of the recipient on October 9, 2002. As a result of 

findings identified during the on-site review, EPA decided to novate (i.e., transfer) 

the grant from the Institute to the Association for Commuter Transportation (the 

Association). 

Background

The Association is a nonprofit organization based in Denver, Colorado, and 

governed by an 18-member board of directors. The Association’s purpose is to 

support its members in their efforts to enhance mobility, improve air quality, and 

conserve energy through transportation demand management activities. The 

Institute is a charitable foundation established by the Association to conduct 

research and provide educational opportunities to the membership and public. 

The executive committee of the Association also serves as the board of directors 

for the Institute. 

Grants Received 

• The Institute received a grant for $69,750 (X-82893401-0) in April 2001 to 

redesign and update a Web site that would educate and inform key 

constituencies and stakeholders in the Commuter Choice Initiative. The 

grant has resulted in the Commuter Choice Web site, 

www.commuterchoice.com. The grant was closed in November 2003. 

• The Institute received a grant for $150,000 (X-82964601-0) in March 2002 to 

benefit the public by expanding awareness of transportation choices, 

especially for commuters. The grant resulted in a conference and the 

Commuter Choice Web site; and was transferred to the Association with a 

remaining balance of $12,987. 

Description of Problems and Corrective Actions

During the prereview, reviewers identified the following concerns with the 

Institute’s management of grant number X-82964601-0: 
Enclosure II 

Page 14 GAO-04-383R Grants Management 

Conflict of Interest 

• The reviewer was concerned about the relationship between the Institute 

and Urban Trans Consultants, a for-profit company. In its grant 

application, the Institute gave the impression that it had its own staff and 

budget. However, during his discussion with the Institute’s associate 

director, the reviewer learned that the organization did not actually have 

any paid employees, but rather contracted for the work of staff employed 

by Urban Trans Consultants. Additionally, the executive director of the 

Institute was the president of Urban Trans Consultants. EPA’s primary 

concern was that the affiliate relationships with interlocking officers and 

directors created apparent conflicts of interest, especially when those with 

the apparent conflicts of interest awarded and managed the contracts. 

EPA asked the Institute to provide information on its financial statements, 

how the grant and all contracts paid with grant funds had been 

administered and by whom, its indirect cost rate proposal, and the 

relationships between the Association, the Institute, and Urban Trans 

Consultants. 

EPA’s Significant Actions

Based on its concerns regarding potential conflicts of interest between the 

Institute and Urban Trans Consultants, EPA notified the Institute that it was 

considering whether to impose a suspension order. The suspension order would 

take effect if the Institute did not provide specific information within 10 days. The 

Institute responded to EPA’s concerns, but it did not satisfy the questions that had 

been raised during the prereview, according to EPA. EPA asked the Institute for 

additional information that, if not provided within 10 days, would result in the 

suspension order being imposed. EPA also asked to meet with the recipient. EPA 

conducted an on-site review of the Institute on October 9, 2002. Based on the 

findings identified during the review, EPA transferred the grant to the Association. 

EPA determined that this transfer would allow for a more appropriate structure 

and relationship between Urban Trans Consultants, the Association, and EPA. 

Results of Corrective and Significant Actions, and Other Information

EPA reported that, as of October 2003, the grant is being transferred to the 

Association, with a remaining balance of $12,987.
Enclosure II 

Page 15 GAO-04-383R Grants Management 

Calcasieu League for Environmental Action Now, Inc. 

On May 31, 2002, an official from EPA’s Region 6 conducted an off-site evaluation 

of a grant with the Calcasieu League for Environmental Action Now. The 

reviewer determined that the recipient was not making progress on the grant 

work or meeting the terms and conditions of its grant. The reviewer warned the 

recipient that if it continued to not use its grant funds, EPA would not extend the 

grant. Information provided by EPA indicated that it has found the recipient 

noncompliant with its grant, and it will not be allowed to apply for any future 

grants. 

Background

The Calcasieu League for Environmental Action Now, Inc. is a nonprofit 

community group governed by five board members and five officers. The 

organization is a group of private citizens who are affected by the North Ryan site 

in Lake Charles, Louisiana, that is on the Superfund National Priority List. The 

grantee is affiliated with the Calcasieu Estuary Task Force and the Calcasieu 

Local Emergency Planning Committee. 

Grants Received 

• The recipient received a grant for $50,000 (1-98658201-0) in January 2001 to 

hire independent technical advisors to help interpret and comment on siterelated information generated by the state agency or EPA. The grantee has 

not produced any results, and the grant’s project period is scheduled to end 

in January 2004. 

Description of Problems and Corrective Actions

The reviewer found problems in the following areas: 

Accounting 

• The recipient did not keep budget records. 

Procurement 

• The recipient had not submitted reports documenting compliance with 

disadvantaged business contracting requirements. 

Progress Reports 

• The recipient had not submitted the required progress reports. 

Technical Issues 
Enclosure II 

Page 16 GAO-04-383R Grants Management 

• The recipient had not expended any funds, and the grant work was not on 

schedule. 

Terms and Conditions 

• The recipient had not submitted the required financial status reports. 

EPA’s Significant Actions

EPA documentation indicated that repeated efforts to assist the recipient with its 

grant activities had failed. A Region 6 official warned the organization that at a 

minimum, it needed to submit the required quarterly progress reports and that 

EPA would not extend the grant if the organization continued to not use its funds. 

Results of Corrective and Significant Actions, and Other Information

As a result of EPA’s warnings, the Region 6 reviewer noted that the recipient 

began sending in “no progress” reports the following quarter. According to 

additional EPA documentation, the recipient has not used the grant funds and has 

failed to produce the agreed upon deliverables. EPA has found the organization 

was noncompliant with the grant and informed the recipient that it cannot apply 

for any future grants.
Enclosure II 

Page 17 GAO-04-383R Grants Management 

Central States Air Resource Agencies Association 

In July 2002, EPA’s Office of Inspector General (OIG) issued a draft audit of costs 

claimed under two grants awarded to the Central States Air Resource Agencies 

Association (the Association). The draft audit identified a number of problems 

with the recipient’s management of its funds. The OIG notified Region 6 of the 

findings, at which time EPA warned the Association that it was considering 

whether to impose a suspension order. EPA also designated the recipient as highrisk and imposed special conditions on future grant work. 

Additionally, the EPA Region 6 project officer for these grants conducted a 

number of reviews throughout 2002. On September 5, 2002, the Association’s staff 

visited with EPA to submit corrective documents in response to the OIG audit. 

The EPA reviewer found additional problems and decided to continue the 

recipient’s high-risk status until the audit issues were resolved, as well as 

informing the recipient that new awards would be postponed. EPA reported that 

the Association began to take action in a number of areas. 

In March 2003,13 the OIG published its audit of the costs claimed under these 

grants. The OIG questioned $1,644,618 in recipient claims. As of January 2004, 

the OIG’s findings are in the audit resolution stage. 

Background

The Association is a nonprofit organization governed by an 11-member board of 

directors. The purpose of the organization is to promote interstate collaboration 

on air issues among the states of the central United States through a multistate 

organization. The recipient is affiliated with the Central Regional Air Planning 

Association and is located in Oklahoma City, Oklahoma. 

Grants Received 

• The Association received a grant for $255,000 (X-996940-01) in May 1998 to 

fund a regional multistate organization. The grant was subsequently 

amended to total $2,226,243, and resulted in the establishment of a 

multistate organization to promote the exchange of information on 

controlling air pollution among the states of Arkansas, Iowa, Kansas, 

Louisiana, Minnesota, Missouri, Nebraska, Oklahoma, and Texas, and other 

interested parties. The organization provided a unified regional voice for 

the air quality agencies in the central states. It also provided training and 

performed other activities necessary to support the development of sound 

air pollution control policy. 

 

13EPA Office of Inspector General, Costs Claimed by Central States Air Resource Agencies 

Association Under EPA Assistance Agreement Nos. X996940-01 and X986516-01, Report No. 

2003-1-00087 (Washington, D.C.: Mar. 31, 2003). 
Enclosure II 

Page 18 GAO-04-383R Grants Management 

• The Association received a grant for $420,000 (X-986920-01) in September 

2001 to continue funding the multistate organization for training and to 

provide a forum for interstate ozone issues. The grant resulted in 

maintaining the operations of the multistate organization to promote the 

exchange of information between the states and interested parties in the 

central United States. Training was provided on basic principles and 

practices of air pollution control, inspection, technical writing, and air 

quality modeling. The recipient also provided information and support to 

member states and interested parties on technical and policy issues related 

to sound air pollution control policy. 

• The Association received a grant for $500,000 (X-986516-01) in April 2000 

and an amendment for an additional $500,000 in April 2001 to fund a 

regional planning body for the central states. The grant resulted in 

establishing an infrastructure for a regional planning body, including both 

states and tribes, to address the 1999 Regional Haze Rule. Modeling, 

monitoring, implementation and control strategies, communication, 

emissions inventory and international workgroups were formed with 

representation from states and tribes in the central United States. Training, 

emissions inventory, and modeling activities were initiated to support 

regional haze analyses. 

Description of Problems and Corrective Actions

The OIG and Region 6 reviewer found problems and recommended corrective 

actions in the following areas: 14,15

Accounting 

• The OIG found that the Association had claimed outlays that did not agree 

with the general ledger, which led the OIG to question all $1,644,618 in 

costs claimed under these two grants. 

• The OIG recommended that EPA require the Association modify its 

financial management system to meet federal requirements. Modifications 

were to, among other things, ensure that financial results are current, 

accurate, and complete; include written procedures to determine 

reasonableness, allocability, and allowability of costs; and include 

accounting records that are supported by adequate source documentation. 

• The OIG also recommended that EPA suspend work under the grants and 

make no new awards until the Association could demonstrate that its 

accounting practices were consistent with federal requirements. 

 

14The OIG findings presented represent those identified in its final report for grant numbers X996940-01 and X-986516-01, see EPA Office of Inspector General, Report No. 2003-1-00087. 

15A Region 6 official conducted on-site reviews of this recipient on March 22, April 12, and August 

9, 2002, and an off-site review on September 5, 2002. 
Enclosure II 

Page 19 GAO-04-383R Grants Management 

Financial Expenditures 

• The OIG found that it was unable to evaluate the claimed direct costs 

because the Association improperly charged all indirect costs to one of its 

grants. The OIG recommended that EPA recover all grant funds that could 

not be supported within 180 days. 

Indirect Costs 

• The OIG and Region 6 reviewer found that the Association did not develop 

an indirect cost rate to allocate costs benefiting multiple projects and to 

distinguish between direct and indirect costs. 

Personnel/payroll 

• The OIG found that the Association had an inadequate labor distribution 

system. Specifically, labor claimed under the EPA grants was not based on 

actual hours worked. Employees prepared time sheets but did not identify 

any grant projects or final cost objectives. Also, the organization did not 

use the time sheets to record salary costs in the general ledger, but instead, 

charged all employee salaries, including vacation, holiday, and sick leave to 

one grant. Region 6 officials recommended that the recipient implement an 

adequate labor tracking system as soon as possible. 

• The Region 6 reviewer found that the Association’s staff and facilities were 

not appropriate to handle the grant work. 

Procurement 

• The OIG found that the Association did not competitively procure 

equipment and services and did not perform a cost or price analysis for 

these purchases. The OIG recommended that EPA recover the costs of 

$575,743 for equipment and services unless the organization ensured that 

federal requirements had been met. 

Progress Reports 

• The Region 6 reviewer found that the required progress reports were not 

always being submitted on time and did not always include the required 

financial information. 

Technical Issues 

• The Region 6 reviewer found that grant work was not on schedule. 
Enclosure II 

Page 20 GAO-04-383R Grants Management 

Terms and Conditions 

• The Region 6 reviewer found that the Association had not complied with its 

grants’ terms and conditions. 

Written Procedures 

• The OIG found that the Association did not have written accounting 

procedures regarding the allocation of joint costs. 

EPA’s Significant Actions

Region 6 notified the Association that as a result of the issues identified in the 

draft OIG report it was considering issuing a suspension order unless the 

organization responded appropriately. It also notified the recipient that, in lieu of 

issuing a suspension order before the recipient responded, EPA would designate 

the organization as high risk and impose special conditions on future grant work. 

These special conditions included the following: 

• requiring EPA approval for each request for reimbursement of grant 

expenses, based on clearly defined cost documentation, and 

• postponing additional Clean Air Act awards until resolution of the audit 

issues. 

After the additional issues identified during the Region 6 review, EPA reinforced 

the consequences of noncompliance with statutory and regulatory requirements. 

EPA also informed the Association that its status on the high-risk list would 

continue, as would the postponement of new awards until the audit issues had 

been resolved. 

Results of Corrective and Significant Actions, and Other Information

EPA documentation noted that the Association had begun to take action in a 

number of areas. It had submitted new financial management, labor distribution, 

personnel, procurement, property management, and travel policies for EPA 

approval. Additionally, it had hired a consultant to assist it in developing an 

adequate labor tracking system. EPA indicated that these actions were sufficient 

for the Association to continue its grant activities under the high-risk conditions 

without EPA imposing the threatened suspension order. In its March 2003 report 

on its audit, the OIG noted that the Association did not agree with the OIG’s 

findings, but the OIG continued to question the organization’s claims for 

$1,644,618. As of January 2004, the OIG’s findings are in the audit resolution 

stage. 
Enclosure II 

Page 21 GAO-04-383R Grants Management 

Consumer Federation of America Foundation 

On March 21 and 22, 2002, officials from EPA’s Office of Grants and Debarment 

conducted an on-site, in-depth review of the Consumer Federation of America 

Foundation (the Foundation). The reviewers found a number of problems with 

the Foundation’s grants management, which led EPA to take four significant 

actions against it: issuing a suspension order, issuing a payment hold, identifying 

unallowable costs, and requesting that the OIG audit the Foundation. EPA 

reported that the Foundation was restructured and that EPA imposed special 

terms and conditions on April 25, 2002. The OIG indicated that its audit was 

completed in December 2003, and it is currently awaiting comments from the 

Foundation. It expects to receive these comments in late January 2004, and will 

issue the report soon afterwards. 

Background

The Foundation was established in 1972 as a nonprofit organization to 

complement the work of the Consumer Federation of America (the Federation), a 

lobbying organization. The Foundation, assists state and local organizations, 

provides information to the public on consumer issues, and conducts consumer 

research projects. The Foundation’s State and Local Resource Center provides 

training and technical assistance on governance and resource development. It 

also awards grants for organization development and equipment. The Center 

convenes an annual caucus for state and local leaders and, through a Web site and 

regular mailings, serves as a clearinghouse for information. The Foundation is 

governed by the same 40-member board of directors as its affiliated organization, 

the Federation. The Foundation’s executive director is the executive director of 

the Federation, while its project managers and comptroller are also employed by 

the Federation. The Foundation used Federation employees to run a centralized 

grants management system. 

Grants Received 

• The Foundation received a grant for $1,806,708 (X-825612-01) in July 1997 

to create a national radon public service announcement to increase 

voluntary home radon testing and mitigation. The grant resulted in 

television, radio, and print public service announcements yielding 1,094,237 

broadcasts/advertisements. The grant also resulted in the development of 

materials for National Radon Action Week and strategies to increase 

awareness from consumer studies and research. The grant was closed in 

December 2002. 

• The Foundation received a grant for $1,737,532 (X-825837-01) in October 

1997 to create a national media campaign to reduce childhood exposure to 

environmental tobacco smoke. The grant resulted in a number of 

television, radio, and print public service announcements. It also used 

telephone and e-mail promotions to reach 1,500 media directors and 
Enclosure II 

Page 22 GAO-04-383R Grants Management 

participated in two national press conferences publicizing the Smoke Free 

Home Campaign. The grant is waiting for closeout as of January 2004. 

• The Foundation received a grant for $225,161 (X-828814-01) in February 

2001 to promote the environmental, economic, and health benefits of 

buying energy-efficient products. The grant resulted in, among other 

things, training for 16 states and local affiliates for public outreach 

activities; publishing an article on the benefits of energy efficiency; and 

maintaining and enhancing a Web site (www.buyenergyefficient.org). The 

grant was closed in November 2003. 

• The Foundation received a grant for $359,000 (X-829178-01) in August 2001 

to educate consumers about reducing their risks from radon and other 

indoor air quality issues by promoting testing and mitigation. This grant is 

still active. 

• The Foundation received a grant for $434,928 (XA-831201-01) in September 

2003 to increase public awareness of the environmental, economic, and 

health benefits of energy-efficient products and practices. The grant is still 

active and is expected to result in community outreach to inform 

consumers and to support the Web site. 

Description of Problems and Corrective Actions

The reviewers found problems and recommended corrective actions in the 

following areas: 

Conflict of Interest 

• The Foundation awarded a sole-source contract to the Federation for 

administrative and personnel services. It appeared to the reviewers that 

hundreds of thousands of dollars were flowing between the two entities for 

labor, fringe benefits, and indirect costs without signed or written 

agreements. Additionally, the parent company is a lobbying organization, 

but the reviewers had difficulty separating the two entities. EPA required 

the Foundation to establish written agreements for all services paid for 

with grant funds, provide written justifications for sole-source contracts to 

the parent company, and explain how sole-source contracts did not violate 

the code of ethics. Further, the reviewers recommended that the recipient 

completely separate the two entities. 

Financial Expenditures 

• The Foundation was paying one of its consultants at $600 per hour, 

significantly above the rate allowed by federal regulations—which EPA 

indicated was $498.32 a day or $62.29 per hour. EPA recommended that 

the recipient provide documentation of hourly rates for consultants over 

the allowable limit, and then reimburse the grants for consultant costs that 

were above the limitation. 
Enclosure II 

Page 23 GAO-04-383R Grants Management 

Indirect Costs 

• The Foundation did not have a current indirect cost rate approved by EPA 

as required by the terms and conditions of the grant. The recipient was 

instead operating under an old rate. The reviewers were also concerned 

that the Foundation had no employees. Therefore all of the wages that 

were being charged as indirect costs were actually for contract labor from 

the Federation. EPA recommended that the recipient develop an indirect 

cost rate proposal and reimburse the grants for the mis-charged indirect 

costs. 

Personnel/payroll 

• The Foundation and Federation employees did not fill out a time sheet or 

personnel activity report, and the Foundation allocated labor costs using 

budget estimates. The reviewers determined that this allocation method 

was not allowable for supporting these expenses. EPA recommended that 

the recipient complete personnel activity reports for personnel whose 

compensation was charged to the grants. EPA also stated that any 

personnel charges incurred on EPA grants that could not be supported 

with the appropriate documentation would be disallowed and would have 

to be repaid to the appropriate grant. 

Procurement 

• The reviewers did not find evidence to document that a cost or price 

analysis was being performed for most contracted services. EPA 

recommended that the recipient document a cost or price analysis, 

including a sole-source justification, for procurements using federal funds. 

• The Foundation had not complied with disadvantaged business 

procurement requirements, and had not submitted the required reports 

within 30 days of the end of each federal fiscal year. EPA recommended 

that the recipient, within 30 days, implement procedures to ensure 

compliance with these requirements. EPA also recommended that the 

recipient begin filing the required reports within 90 days. 

Written Procedures 

• The Foundation did not have written travel policies. EPA recommended 

that the recipient either adopt federal travel guidelines or develop its own 

travel policy. EPA also required that all charges in excess of the federal 

per-diem rates be repaid to the appropriate grant. 

EPA’s Significant Actions

As a result of the findings identified during the on-site review, EPA notified the 

Foundation that it was suspending work and temporarily withholding funds for 
Enclosure II 

Page 24 GAO-04-383R Grants Management 

grant numbers X-825612-01, X-825837-01, X-828814-01, and X-829178-01 and would 

notify the Financial Management Center not to make further payments until EPA’s 

concerns with the recipient’s grants management had been resolved. These 

included concerns with potential unallowable costs leading to EPA’s 

recommendations that the Foundation reimburse the grants for the mis-charged 

indirect costs and consultant costs that were above the limitation. EPA informed 

the recipient that the suspension order required it to stop project work and take 

all reasonable steps to minimize costs incurred on the project. The suspension 

order was scheduled to be in effect for 45 days. Additionally, EPA forwarded a 

copy of its on-site report to the OIG and requested that the OIG perform an audit 

of the Foundation. EPA asked that the OIG perform tests on all grant related 

financial transactions to confirm that the grant funds were being used properly 

and noted there appeared to be acquisition versus assistance issues with at least 

one of the grants. 

Results of Corrective and Significant Actions, and Other Information

EPA did not provide specific information regarding the status of a number of the 

corrective actions requested of the Foundation. However, EPA indicated that the 

Foundation provided documentation of hourly rates for consultants over the 

allowable limit, and reimbursed the grants for consultant costs above the limit 

before the suspension order was lifted. EPA also noted that the Foundation was 

restructured, and EPA placed special terms and conditions on the recipient on 

April 25, 2002. Also, the OIG indicated that the audit EPA requested was 

completed in December 2003, and it is currently awaiting comments from the 

recipient. The OIG expects to receive these comments in late January 2004, and 

will issue the report soon afterwards.
Enclosure II 

Page 25 GAO-04-383R Grants Management 

Coordinating Committee for Automotive Repair 

In May 2002, the OIG issued a special report on the Coordinating Committee for 

Automotive Repair’s (the Committee) grants management.16 The OIG identified a 

number of findings, including that the Committee had not accounted for 

$2,026,837 in costs claimed under its three grants, which led EPA to take four 

significant actions against it: issuing a suspension order, issuing a payment hold, 

disallowing costs, and imposing special conditions on the recipient. The 

Committee disputed the suspension order in January 2003. The Grants 

Administration Division and the Office of Enforcement and Compliance 

Assurance are still working with the Committee to try to resolve the issues 

identified in the OIG report. 

Background

The Committee is a nonprofit organization governed by a board of directors with 

approximately 10 members. Also referred to as CCAR-Greenlink, it is one of 10 

compliance assistance centers funded by EPA’s Office of Enforcement and 

Compliance Assurance to provide compliance assistance information to the 

automotive industry via the Internet. This information is designed to assist 

members of the industry to better understand their environmental responsibilities 

and to help them achieve compliance with environmental program requirements. 

Grants Received 

• The Committee received a grant for $1,765,000 (CX82437601) in September 

1995 to, among other things, provide multimedia environmental 

compliance information and pollution prevention ideas that can help shop 

owners comply with environmental requirements. The grant resulted in 

focus groups to identify the best ways to deliver information to participants 

in the industry. The grant also funded baseline surveys to document the 

level of compliance and measure the success of compliance assistance 

efforts and the development of a Web site. 

• The Committee received a grant for $90,000 (CX82573201) in October 1997 

that resulted in the Committee’s working with three states to develop statespecific information relating to auto repair and make this material available 

through the compliance assistance center’s Web site. 

• The Committee received a grant for $333,945 (CX82836601) in September 

2000 to conduct an outreach project to owners and technicians employed 

in the automotive service and collision industry. The grant resulted in 

maintaining and improving the center’s Web site, continuing to conduct 

outreach about the site and applicable environmental regulations, 

developing educational modules, and responding to thousands of industry 

 

16EPA Office of the Inspector General, EPA Cooperative Agreements Awarded to the Coordinating 

Committee for Automotive Repair, Report No. 10960-2002-M-000017 (Washington, D.C.: May 29, 

2002). 
Enclosure II 

Page 26 GAO-04-383R Grants Management 

and public inquiries regarding environmental compliance and pollution 

prevention activities. EPA reported that the Web site has been successful 

and comments from users have been positive. 

Description of Problems and Corrective Actions

The OIG found problems and made recommendations in the following areas: 

Accounting 

• The Committee identified indirect costs in its budget; however, its 

accounting system treated all costs as direct. 

• The Committee did not appropriately distribute costs between federal and 

nonfederal activities. 

• The Committee’s accounting system was deficient because it did not have 

adequate controls to prevent the submission and reimbursement of 

ineligible expenses for travel. 

• The OIG was unable to reconcile the Committee’s total program outlays 

claimed with the recipient’s accounting system. These differences totaled 

$8,580 for the three grants. 

• The OIG recommended that the Committee modify its financial 

management system to meet federal regulations. Modifications were to 

ensure that financial results are current, accurate, and complete; include 

written procedures to determine reasonableness, allocability, and 

allowability of costs; and include accounting records that are supported by 

adequate source documentation. EPA agreed with the OIG’s 

recommendation and noted that it was requiring that the Committee have 

its new financial management system certified by a third-party auditor.

Financial Expenditures 

• The Committee had not accounted for $2,026,837 in costs claimed under its 

three grants. These included $149,509 in ineligible payroll costs, such as a 

reduction in the number of hours for the executive director without a 

similar reduction in salary; expenses paid to the executive director in 

excess of the EPA-imposed ceiling; and holiday pay for the recipient’s 

employees for holidays, which were not authorized in its written personnel 

policy. The remainder of the questioned amount consisted of $1,877,328 in 

unsupported payroll, travel, equipment, printing/postage, rent, telephone, 

outreach, administration, Web/computer, and supply costs. Specifically, 

the OIG identified claims to EPA for alcoholic beverages and trips for 

nonfederal activities on one of the grants. 

• The OIG recommended that the Committee reconstruct the accounting 

records necessary to document its grant expenditures and that EPA 

recover all funds that could not be supported by the Committee’s 

documentation. EPA agreed with this recommendation and asked the 
Enclosure II 

Page 27 GAO-04-383R Grants Management 

recipient to provide documentation to substantiate the $1,877,328 in 

unsupported costs. EPA noted that the recipient did not believe it was 

going to be able to fully reconstruct all of the requested accounting 

records, and responded that the individuals who claimed the unsupported 

costs could submit notarized affidavits. 

• The OIG recommended that EPA recover all ineligible costs that did not 

meet Office of Management and Budget (OMB) requirements. EPA agreed 

with this recommendation and asked the Committee to pay back the 

$149,509 in ineligible costs. 

Indirect Costs 

• The Committee did not prepare indirect cost proposals as required by the 

terms and conditions of its grants. The OIG recommended that the 

recipient submit indirect cost proposals for 1995 to the present. EPA 

agreed with this recommendation. 

Personnel/payroll 

• The Committee did not maintain adequate time records for all three grants. 

The recipient’s employees maintained weekly records of work activity but 

did not usually identify the actual hours spent on the activities. In some 

cases, employees identified nonfederal activities but charged all salary 

costs to the grant. The OIG found that the Committee needed to develop a 

time distribution (or timekeeping) system that met federal regulations. 

EPA agreed with the OIG’s recommendation and noted that it was requiring 

that the recipient have its new time distribution system certified by a thirdparty auditor. 

EPA’s Significant Actions

EPA notified the Committee that, based on the OIG’s findings, it was suspending 

work on grant number CX82836601 and temporarily withholding funds until the 

recipient had resolved EPA’s concerns. The suspension order required the 

Committee to stop project work and to take all reasonable steps to minimize costs 

incurred on the project. The order was scheduled to be in effect for 45 days. 

Additionally, the recipient had to repay the $149,509 in ineligible costs and 

provide documentation for the $1,877,328 in unsupported costs from the three 

grants. 

The OIG also recommended that EPA withhold further funding from the 

Committee until it received confirmation that the recipient had the financial 

management capability to manage its grant funds in accordance with federal 

regulations. EPA did not agree with this recommendation and in fact provided an 

additional funding increment to the recipient. EPA decided this on the basis that 

the Committee had accomplished important and effective work in the past. EPA 

also noted that two of the grants mentioned in the OIG report had been completed 
Enclosure II 

Page 28 GAO-04-383R Grants Management 

and the third was nearing completion. However EPA decided to place special 

conditions on the Committee. These included: 

• requiring the recipient to submit all requests for reimbursement to the 

project officer for approval, based on a detailed justification of the costs, 

and 

• requiring the recipient to have appropriate staff take a grants management 

course within 6 months. 

Results of Corrective and Significant Actions, and Other Information

According to EPA, the Committee disputed the suspension order in January 2003, 

and the Grants Administration Division and the Office of Enforcement and 

Compliance Assurance are still working with the recipient to resolve the issues 

identified in the OIG report. The Committee submitted one of the three required 

indirect cost proposals in June 2002 and met one of the required special 

conditions when personnel attended a grants management course in August 2002. 

The recipient provided EPA with an independent auditor’s report of its financial 

and time management systems. EPA responded in December 2003, requesting 

additional information or adjustments to the Committee’s financial system in 

order to be eligible for federal assistance. EPA expects the Committee to respond 

to this request, in addition to providing information on the status of the OIG’s 

recommendations to reconstruct accounting records and submit indirect cost 

proposals, by the end of January 2004. EPA documentation also indicated it had 

conducted an on-site review for grant number CX82836601, in June 2002. The 

reviewers did not identify further problems with the recipient’s grants 

management but noted that progress of the work was falling behind, largely due 

to efforts to respond to the OIG’s findings and recommendations. 

In August 2002, the OIG issued another report related to the Committee in which 

it described oversight issues identified during its review.17 The OIG found that 

EPA’s lack of oversight contributed to the recipient’s grants management 

problems. The project officer and grants specialist did not provide the necessary 

oversight to ensure the recipient managed its grants in accordance with federal 

regulations. Specifically, the project officer and grants specialist did not work 

together to monitor the Committee or follow recommended procedures in grant 

guidance, and the grants specialist was not responsive to repeated requests from 

the recipient for assistance in developing an indirect cost rate. The OIG reported 

that the project officer was aware that the recipient had not developed an indirect 

cost rate but allowed the grants to continue. The OIG concluded that adequate 

EPA oversight could have prevented reimbursing the Committee for ineligible and 

unsupported costs.

 

17EPA Office of the Inspector General, EPA’s Lack of Oversight Contributed to Coordinating 

Committee for Automotive Repair’s Grant Management Problems, Report No. 10960-2002-M000031 (Washington, D.C.: Aug. 22, 2002). 
Enclosure II 

Page 29 GAO-04-383R Grants Management 

Engineers’ Society of Western Pennsylvania 

On April 8, 2002, EPA used contracted staff to conduct an on-site, in-depth review 

of the Engineers’ Society of Western Pennsylvania (the Society). The reviewers 

found a number of problems, including unallowable costs resulting from 

excessive salary expenses. The reviewers made recommendations to correct 

these problems, and EPA requested that the recipient submit a corrective action 

plan within 30 days. EPA noted that the Society was put on a corrective action 

plan and completed it on July 26, 2002. 

Background

The Society is a nonprofit organization governed by a 12-member board of 

directors, with eight consultants to the board. The organization is a membership 

society with the purpose of advancing the professions of engineering, 

architecture, and applied sciences through technical activities and public service. 

The Society is affiliated with 30 organizations: Association for the Advancement 

of Cost Engineering International; American Concrete Institute; Association for 

Facilities Engineers; American Institute of Chemical Engineers; American 

Institute of Mining, Metallurgy & Petroleum Engineers/Society of Mining; 

American Iron and Steel Institute; Association for Iron and Steel Technology; 

American Society of Civil Engineers; American Society of Heating, Refrigeration & 

Air Conditioning Engineers; American Society for Materials; American Society for 

Mechanical Engineers; American Society for Professional Estimators; American 

Society for Quality; Air & Waste Management Association; Construction 

Specifications Institute; Institute of Electrical & Electronics Engineers; Institute 

of Industrial Engineers; Institute of Packaging Professionals; Instrument Society 

of America; National Association of Corrosion Engineers; Project Management 

Institute; Pennsylvania Society of Professional Engineers; Society for Analytical 

Chemists of Pittsburgh; Society of Automotive Engineers; Society of American 

Military Engineers; Society of Fire Protection Engineers; Society of Plastics 

Engineers; Spectroscopy Society of Pittsburgh; Society of Women Engineers; and 

Tri-State Construction Users. 

Grants Received 

• The Society received a grant for $1,306,584 (827988-01) in September 1999 

to disseminate social, economic, and statistical research. The grant 

resulted in a conference to present Brownfields research. The project has 

expired and is waiting for closeout as of January 2004. 

• The Society received a grant for $600,000 (830661-01) in September 2002 to 

conduct a Brownfields research conference. The grant resulted in a 

conference for the dissemination of technical, engineering, and economic 

and social science research on the issue of contaminated sites. The project 

has expired and is waiting for closeout as of January 2004. 
Enclosure II 

Page 30 GAO-04-383R Grants Management 

Description of Problems and Corrective Actions

The reviewers found problems with the management of grant number 827988-01 

and made recommendations in the following areas: 

Accounting 

• The Society could not document that costs charged to the grant were 

disbursed before it requested reimbursement from EPA. For example, in 

one case the reviewers found a time sheet indicating that time was being 

charged to the grant, but they could not find documentation to support 

payment to the employee in the payroll register or a cancelled check. The 

reviewers recommended that the recipient provide documentation for the 

disbursement and ensure that expenditures for grant activities are 

disbursed before asking EPA for reimbursement. 

• The Society classified costs from one of its contracts for labor as 

personnel. The reviewers recommended that the recipient reclassify these 

costs to the appropriate budget line item and ensure that they were 

allowable. 

• In several instances, budgeted expenditures were exceeded by more than 

10 percent. The reviewers recommended that the Society revise its 

procedures to ensure adherence to the approved budget, and receive 

approval from EPA for deviations greater than 10 percent. 

Financial Expenditures 

• The Society requested reimbursement for salaries at a rate greater than the 

actual salary rate of some of the employees. The reviewers concluded that 

the organization was reimbursed for more than the actual costs incurred 

related to the grant. The reviewers recommended that the recipient 

recalculate salary costs chargeable to all EPA grants based on the actual 

rates paid to employees. The difference between actual costs and the 

amount requested from EPA should be reimbursed. They also 

recommended that the recipient revise its policies to ensure that only the 

actual costs associated with federal grants were charged. 

• The Society hired a professor at an hourly rate of $100 per hour, which was 

higher than the allowable federal rate of $62.29 per hour. The reviewers 

recommended that the recipient evaluate the amount paid to the professor 

and adjust it to more closely reflect a reasonable cost as defined in OMB 

regulations. 

Indirect Costs 

• The Society charged indirect costs to its grant but did not have an officially 

approved indirect cost rate from EPA. The reviewers recommended that 

the recipient develop an indirect cost allocation plan for EPA’s review. 
Enclosure II 

Page 31 GAO-04-383R Grants Management 

Internal Controls 

• The Society’s general manager was responsible for approving all 

expenditures related to the grant, including authorizing his own timesheets 

and approving travel expense reports. The reviewers recommended that 

the recipient develop a policy to ensure that all expenditures receive 

approval from someone other than the person incurring the cost. 

Personnel/payroll 

• The Society’s time sheets contained a number of problems. At least one 

employee failed to sign time sheets for work conducted under the grant; in 

several instances time sheets had no supervisor’s signature, indicating 

approval of the time charged to the grant; several time sheets were missing 

both the employee’s and supervisor’s signatures; and the time sheets of one 

individual were accumulated and submitted at one time for several months 

of activity associated with the grant. The reviewers recommended that the 

recipient implement new policies and procedures to ensure that the payroll 

system and time sheets met the requirements of OMB regulations. 

Procurement 

• The Society entered into several sole-source contracts without having 

adequate justification. In one instance, the recipient did not request 

competing bids for audit services; in another, the recipient contracted with 

a local organization without providing a justification for the contract or 

maintaining evidence that it had conducted a cost or price analysis. The 

reviewers recommended that the recipient ensure compliance and proper 

documentation in accordance with federal regulations for all 

procurements. 

• The Society’s contract with one organization to obtain the services of an 

employee was not documented with a written agreement. The reviewers 

recommended that the recipient execute a written agreement with all 

consultants. 

• The Society had not documented nor submitted the required reports to 

indicate compliance with disadvantaged business requirements. The 

reviewers recommended that the recipient document the steps taken to 

ensure compliance with these requirements and submit the necessary 

reports. 

Subagreements 

• The Society did not require vendors and subcontractors to maintain 

records for the appropriate length of time. The reviewers recommended 

that the recipient ensure the compliance of subgrantees’ policies and 

procedures. 
Enclosure II 

Page 32 GAO-04-383R Grants Management 

Terms and Conditions 

• The Society was delinquent in filing at least one of its required financial 

status reports. The reviewers recommended that the recipient ensure 

compliance with its financial reporting requirements. 

Written Procedures 

• The Society did not maintain a written policies and procedures manual for 

accounting, reporting, record retention, and other functions related to the 

administration of the grant. The reviewers recommended that the recipient 

develop and update policies and procedures to ensure compliance with 

grant requirements. 

EPA’s Significant Actions

EPA requested that the recipient identify the actions it would take to address the 

findings and recommendations in the contractor’s report, and the associated time 

frames of each action, in a corrective action plan provided to EPA within 30 days. 

While not specifically identified in the letter to the recipient, the contract’s report 

stated that these corrective actions should include addressing the unallowable 

costs related to the excess salaries paid to some of the Society’s employees. 

Results of Corrective and Significant Actions, and Other Information

Documentation provided by EPA indicated that the Society repaid the 

unallowable costs as part of its corrective action plan, which was completed on 

July 26, 2002; the grant is awaiting closeout as of January 2004.
Enclosure II 

Page 33 GAO-04-383R Grants Management 

Geothermal Heat Pump Consortium 

On March 7 and 8, 2002, officials from EPA’s Office of Grants and Debarment 

conducted an on-site, in-depth review of the Geothermal Heat Pump Consortium 

(the Consortium). The reviewers stated that there were too many indicators of 

poor grants management and allowable cost issues to complete the review. These 

problems led EPA to take three significant actions against the Consortium: 

issuing a suspension order, issuing a payment hold, and requesting that the OIG 

audit the recipient. The OIG published an audit of the Consortium in September 

2003 in which it questioned $1,153,472 in costs claimed by the recipient.18 The 

project is in the audit resolution process as of January 2004. 

Background

The Consortium is a nonprofit organization, founded in 1994, to implement the 

National Earth Comfort Program. This program is a collaborative effort between 

the Department of Energy, EPA, and private sector organizations interested in 

promoting the growth of energy-efficient, environmentally friendly heating and 

cooling technology. The Consortium has offices in Washington, D.C., and 

Columbia, Maryland, and is governed by a 14-member board of directors. The 

Consortium is a membership organization; its members include electric utilities, 

equipment manufacturers, architects, engineers, contractors, builders, energy 

service companies, and others. Members also include many national 

organizations, such as the Edison Electric Institute, Electric Power Research 

Institute, International Ground Source Heat Pump Association, National Rural 

Electric Cooperative Association, and the Association of Energy Engineers. 

According to EPA, the benefits of membership in the Consortium include, among 

other things, the opportunity to increase the awareness of GeoExchange 

(geothermal heat pump) technology, and member support through a variety of 

services and programs. EPA noted that the Consortium’s Web site advertised the 

lobbying experience of its staff. 

Grants Received 

• The Consortium received a grant for $712,500 (X-828299-01) in June 2000 to 

provide financial support for increasing awareness of GeoExchange 

technology through public outreach and information dissemination. 

Activities under the grant included operation of the GeoExchange 

Information Center, maintenance of the Consortium’s Web site, publication 

of a newsletter, attendance at conferences, and production of a national 

teleconference. The OIG published an audit of this grant in September 

2003. 

 

18EPA Office of the Inspector General, Geothermal Heat Pump Consortium, Inc. Costs Claimed 

Under EPA Assistance Agreement Nos. X828299-01 and X828802-01, Report No. 2003-4-00120 

(Washington, D.C.: Sept. 30, 2003). 
Enclosure II 

Page 34 GAO-04-383R Grants Management 

• The Consortium received a grant for $748,300 (X-82880201-0) in September 

2001 to increase awareness of the benefits of geothermal heat pump 

technology by providing information to the public and conducting outreach 

to the educational sector. The OIG published an audit of this grant in 

September 2003; the project is in the audit resolution process as of January 

2004. 

• The Consortium received a grant for $750,000 (X-83055901-0) in December 

2002 for emission reductions with GeoExchange technology. EPA did not 

provide the results and current status of this grant. 

Description of Problems and Corrective Actions

The reviewers found problems in the following areas: 

Accounting 

• The lack of financial accounts set up to track the flow of funds made it 

impossible to determine the allowability and allocation of many charges. 

Conflict of Interest 

• The Consortium entered into contracts for services paid for by EPA funds 

with companies whose employees sat on the recipient’s board of directors. 

Financial Expenditures 

• A bonus plan was available to all management personnel at the Consortium 

(all of the employees at the time of the review were management). 

Consortium staff earned the bonus by obtaining industry memberships as 

well as other funding (such as federal grants). These bonuses appeared to 

be paid with funds generated from the sale of memberships because the 

income all went to an unrestricted account. This was also the account out 

of which the lobbying tax and lobbying activity charges were paid. The 

reviewers believed that if it were determined that the membership 

revenues were program income, many of the charges to the grant would be 

unallowable. 

Indirect Costs 

• The Consortium did not have an approved indirect cost allocation plan as 

required by the terms and conditions of the grant agreement. Instead, the 

recipient was charging a flat 30 percent of salaries and wages to the grant. 
Enclosure II 

Page 35 GAO-04-383R Grants Management 

Procurement 

• The Consortium’s procurement files did not contain needed documentation 

(such as a cost or price analysis) for all contracts and for contracts with 

companies in which the recipient’s staff had more than a minimal financial 

interest; the recipient needed to document that it had followed a 

competitive process. 

Program Income 

• The reviewers noted that many of the benefits the Consortium offers to its 

members resulted from grant-related activities. Therefore, they were 

concerned that membership dues could be partially considered program 

income. 

EPA’s Significant Actions

As a result of the concerns identified during the on-site review, EPA informed the 

Consortium that it was suspending work on the project and temporarily 

withholding funds. EPA notified the Financial Management Center not to make 

payments until EPA’s concerns with the recipient’s grants management had been 

addressed. The suspension order required the Consortium to stop project work 

and take all reasonable steps to minimize project costs. This order was scheduled 

to be in effect for 45 days. EPA also forwarded a copy of the preliminary report to 

the OIG, requesting an audit of the Consortium. EPA requested that the OIG 

perform tests on all grant-related financial transactions to confirm that the 

recipient was properly using federal funds. 

Results of Corrective and Significant Actions, and Other Information

As requested, the OIG conducted an audit of the Consortium’s management of 

grant numbers X828299-01 and X828802-01, and published its findings on 

September 30, 2003. The OIG questioned $1,153,472 of claimed costs because the 

Consortium did not comply with the federal rules, regulations, and terms of the 

agreements. Specifically, the OIG found that the Consortium’s financial 

management system was inadequate because the Consortium did not separately 

identify the costs for all direct activities, account for program income generated 

by the activities funded by the grants, prepare or negotiate indirect cost rates, 

prepare written procedures for allocating costs to final cost objectives, maintain 

an adequate labor distribution system, provide adequate support for direct cost 

allocations, competitively procure contractual services or perform any of the 

required cost or pricing analyses, and comply with all reporting requirements. 

Regarding the finding that the Consortium’s financial management system did not 

separately identify costs for direct activities, the OIG reported that the 

Consortium operated a membership organization that provided lobbying support 

for its members. The Consortium’s lobbying effort included costs for outside legal 

counsel and legislative consultants, and the salary and expenses for Consortium 
Enclosure II 

Page 36 GAO-04-383R Grants Management 

employees involved in lobbying activities. However, the OIG noted that the 

Consortium’s financial management system was not structured to allow 

membership and lobbying activities to be treated as direct costs. The 

Consortium’s employee time sheets did not include separate categories for either 

membership or lobbying labor, and the general ledger either did not use or include 

all accounts needed to accumulate all expenses related to membership and 

lobbying activities. 

The OIG recommended that EPA evaluate the need for the grants with the 

Consortium, taking into consideration the fact that the recipient had other income 

to support these activities, and if the grants were not necessary, to annul the 

grants. If EPA determined that the grants were necessary, the OIG recommended 

that EPA recover the $1,153,472 in unsupported costs, suspend work under the 

grants, and make no new awards until the Consortium demonstrated that its 

accounting practices were consistent with federal regulations, require the grantee 

to submit an indirect cost rate proposal, require the grantee to provide detailed 

documentation supporting its use of program income, and factor the program 

income into the reimbursement of any costs EPA determined were allowable from 

the two grants. The Consortium did not agree with the OIG’s findings; its 

comments were included in the final report. EPA has indicated that the project is 

in the audit resolution process as of January 2004. Additional documentation 

provided by EPA noted that as a result of the issues identified by the OIG, EPA is 

(1) requiring the Consortium to submit all payment requests for EPA approval, 

and (2) holding additional funding until the audit issues are resolved.
Enclosure II 

Page 37 GAO-04-383R Grants Management 

National Association of Local Government Environmental Professionals 

On September 26, 2002, officials from EPA’s Office of the Administrator met to 

discuss grant progress with an official from the National Association of Local 

Government Environmental Professionals (the Association). The EPA officials 

told the recipient that nonperformance of the activities within the scope of the 

grant and irregular submission of progress reports was unacceptable. EPA 

recommended negotiating new activities and targets and warned the recipient that 

if these activities were not completed and the targets were not met, the Office of 

the Administrator would turn the issue over to EPA’s Grants Administration 

Division for appropriate action. Additional information provided by EPA 

indicates that the grant work has progressed on schedule since this meeting. 

Background

The Association, located in Washington, D.C., is a nonprofit organization governed 

by a 12-member board of directors. The Association represents local government 

personnel responsible for ensuring environmental compliance, and developing 

and implementing environmental policies and programs. The organization is 

affiliated with Spiegel and McDiarmid, Washington, D.C. 

Grants Received 

• The Association received a grant for $610,000 (827183-01) in September 

1998 for the Showcase Community network project. The grant resulted in 

technical assistance and support for the Brownfields ‘Showcase 

Communities’ project. The grant is scheduled to expire in January 2004. 

• The Association received a grant for $160,000 (829111-01) in January 2002 

to support transportation community partnerships for clean air. The grant 

provided for clean air innovation at the community level by supporting 

participants in a clean air transportation partnership program. The grant is 

scheduled to expire in January 2004. 

• The Association received a grant for $200,000 (830592-01) in September 

2002 for a community revitalization initiative. The grant supported 

research for the promotion of new approaches in the cleanup and 

redevelopment of hazardous waste sites. The grant is still active as of 

January 2004. 

• The Association received a grant for $200,000 (831388-01) in September 

2003. Additional funding is expected to bring this grant to a total award of 

$1,400,000. The purpose of the grant is Brownfields training, research, and 

technical assistance. The grant has resulted in the creation of a 

Brownfields communities network providing technical assistance and 

training to local government officials and other key stakeholders. The 

grant is active as of January 2004. 

• The Association received a grant for $75,000 (GX828550-01-0). EPA 

expects work on this grant to be completed by March 2004. 
Enclosure II 

Page 38 GAO-04-383R Grants Management 

Description of Problems and Corrective Actions

The reviewers identified problems with the Association’s management of grant 

number GX828550-01-0 in the following areas: 

Financial Expenditures 

• The Association had spent a large portion of the grant funds in relation to 

the amount of work that it had completed. 

Progress Reports 

• The Association was not submitting progress reports on a timely basis. 

Technical Issues 

• The Association was not on schedule with the progress of its work. 

EPA’s Significant Actions

According to the documentation EPA provided, the reviewers told the Association 

that the September 26, 2002, meeting was a “last warning.” They emphasized that 

the recipient had received several prior warnings, but EPA had not seen an 

improvement in performance. The reviewers said that they would negotiate new 

activities and target dates with the recipient, but if these were not met, the matter 

would be turned over to EPA’s Grants Administration Division for appropriate 

action. 

Results of Corrective and Significant Actions, and Other Information

Additional information provided by EPA indicates that work on this grant has 

progressed on schedule since the September 2002 meeting. However, EPA also 

noted that a contractor performed a review of the Association’s financial 

management system. EPA expects the review to be completed in late January 

2004, and early indications are that the contractor identified problems that will 

require corrective action by the recipient.
Enclosure II 

Page 39 GAO-04-383R Grants Management 

National Environmental Education and Training Foundation 

From January 22 through 25, 2002, EPA contractor staff conducted an on-site, indepth review of the National Environmental Education and Training Foundation 

(the Foundation). The reviewers found a number of problems, including an 

unallowable and duplicate travel expense in the amount of $1,584.24, and made 

recommendations concerning these issues. EPA requested that the Foundation 

submit a corrective action plan within 30 days. A February 26, 2002, on-site 

review conducted by officials from EPA’s Office of Grants and Debarment 

indicated that Foundation was generally in compliance with its administrative 

requirements and terms and conditions. 

Background

Located in Washington, D.C., the Foundation is a nonprofit organization founded 

in 1990 and governed by a board of directors with nine members and six honorary 

members. According to EPA, the Foundation’s mission is to extend the 

contribution of environmental education and training to meet critical 

environmental protection needs. 

Grants Received 

• The Foundation received a grant for $150,000 (828935-01) in April 2001 for 

watershed and television weather reporting. The grant resulted in helping 

the public to understand watersheds and the role they play in the health of 

aquatic ecosystems. The grant is in the closeout phase as of January 2004. 

• The Foundation received a grant for $10,000 (828015-01) in December 1999 

for a resource guide to educate and train journalists and others in public 

education on consumer confidence reports involving drinking water. This 

grant is in the closeout phase as of January 2004. 

• The Foundation received a grant for $1,638,848 (827026-01) in September 

1998 to target pesticides education to health care providers. The grant 

resulted in educating health-care providers and other professionals on 

pesticide related exposures and illnesses. This grant is in the closeout 

phase as of January 2004. 

• The Foundation received a grant for $195,780 (827807-01) in August 1999 

for research and development of resources to advance environmental 

mentoring. The grant resulted in an enhancement of environmental and 

economic performance through linking the expertise of corporate 

environmental leaders. This grant is in the closeout phase as of January 

2004. 

• The Foundation received a grant for $65,000 (826903-01) in September 1998 

for an education backdrop on clean and safe water programs. The grant 

resulted in the development of an initiative to fill existing gaps in 

educational opportunities. This grant is in the closeout phase as of January 

2004. 
Enclosure II 

Page 40 GAO-04-383R Grants Management 

Description of Problems and Corrective Actions

The reviewers found problems and recommended corrective actions in the 

following areas: 

Accounting 

• The Foundation’s "cash on hand end of period" and "cash on hand 

beginning of period," as reported to EPA in the recipient’s Federal Cash 

Transaction Report, did not agree with the general ledger. The Transaction 

Report cited a balance of $0 for both periods, while the general ledger 

noted balances of $18,689 and minus $2,664, respectively. The reviewers 

recommended that the Foundation reconcile its general ledger accounts to 

ensure that its records and reporting amounts were correct within 30 days. 

Financial Expenditures 

• The Foundation incorrectly charged a travel expense of $792.12 to its EPA 

grant. However, while attempting to correct the error, the Foundation 

instead charged the expense twice. The reviewers recommended that EPA 

disallow these expenses and that the recipient refund the amount of 

$1,584.24 to the EPA grant. 

Indirect Costs 

• The Foundation did not have an approved indirect cost allocation plan, as 

required by the terms and conditions of the grant. The reviewers 

recommended that the recipient submit an indirect cost proposal within 60 

days for approval, and negotiate its indirect cost rate with EPA. 

Internal Controls 

• The Foundation did not have proper separation of duties in the payroll, 

personnel, and accounts payable functions. The vice president of finance 

and administration was performing personnel and payroll functions. He 

also had check-signing authority, access to blank checks, and conducted 

bank reconciliations. The reviewers recommended the recipient separate 

these duties by having the president review the payroll each pay period and 

the bank reconciliation each month. 

Progress Reports 

• The progress reports for two out of the six grants were not filed at the 

appropriate times during the previous year. The terms and conditions of 

the grant agreement required quarterly submission of progress reports 

within 30 days of the reporting period. The reviewers recommended that 
Enclosure II 

Page 41 GAO-04-383R Grants Management 

the Foundation establish procedures to ensure timely submission of 

progress reports within 30 days. 

EPA’s Significant Actions

EPA requested that the Foundation provide EPA with a list of corrective actions 

to resolve the problems identified during the review, along with associated time 

frames for each action, within 30 days. As part of these corrective actions, the 

recipient was required to repay the grant $1,584.24 for the amount charged to it in 

error. 

Results of Corrective and Significant Actions, and Other Information

Additional information provided by EPA indicated that the Foundation repaid the 

mis-charged amount and completed its corrective action plan. Also, a February 

26, 2002, on-site review conducted by officials from EPA’s Office of Grants and 

Debarment indicated that the Foundation was generally in compliance with 

administrative requirements and the terms and conditions of its grants.
Enclosure II 

Page 42 GAO-04-383R Grants Management 

National Environmental Policy Institute 

On January 15 and 16, 2002, officials from EPA’s Office of Grants and Debarment 

conducted an on-site, in-depth review of the National Environmental Policy 

Institute (the Institute). The reviewers found a number of problems with the 

Institute’s grants management, which led EPA to take two significant actions 

against it: issuing a payment hold and a suspension order. EPA also learned that 

the Institute was going to cease operations, and due to concerns about the proper 

expenditure of the remaining grant funds and the Institute’s financial instability, 

EPA placed special conditions on the recipient to ensure that remaining grant 

funds were spent in an allowable manner. EPA reported that the Institute has 

ceased operations and that it transferred the remaining funds, amounting to 

$381,353, to another recipient in February 2003. 

Background

The Institute was established as a nonprofit organization in 1993. The Institute’s 

mission was to provide a framework for improving environmental policy and 

management; however, it has ceased operations. 

Grants Received 

• The Institute received a grant for $2,000,000 (828769-01-0) in November 

2000 to develop a telework and emissions trading study. The grant was 

transferred to the Global Environment and Technology Foundation in 

February 2003. 

Description of Problems and Corrective Actions

The reviewers found problems and recommended corrective actions in the 

following areas: 

Accounting 

• The Institute’s accounting records did not identify the source and use of 

funds. EPA recommended that the recipient maintain a system of 

accounting records that adequately identified the source and use of funds 

provided for grant activities. 

• The Institute did not have budget controls in place. EPA recommended 

that the recipient compare actual expenditures or outlays with budgeted 

amounts for each grant or subgrant. 

Financial Expenditures 

• The Institute was unable to provide adequate documentation to determine 

the allocability of a number of costs totaling at least $1,237. For example, 

the reviewers noted one invoice for “Shirazi Dr. Cobb” in the amount of 
Enclosure II 

Page 43 GAO-04-383R Grants Management 

$198.20. The reviewers could not obtain an explanation for the 25 lunches 

charged on this invoice and could not determine if the money was spent for 

a grant purpose. In another instance, the reviewers found an invoice for 

“Shirazi Sheraton Hotels” in the amount of $260.91. However, they found 

no source documentation for this invoice and could not determine if the 

money was spent for a grant purpose. EPA recommended that the 

recipient provide source documentation and explanations for the 

transactions. 

Missing Required Audit 

• The Institute had not obtained its required Single Audit. EPA 

recommended that the recipient obtain this audit. 

Personnel/payroll 

• The Institute received funding from multiple sources, but it did not 

maintain records (such as time sheets) to track the staff time that it 

allocated to its grants. EPA recommended that the recipient develop and 

use timekeeping records that meet the standards outlined in federal 

regulations. 

Procurement 

• The Institute had not filed reports of its efforts to select disadvantaged 

businesses for grant activities. These reports were specifically required as 

a term and condition in the grant agreement. EPA recommended that the 

recipient file its required reports by February 15, 2002. 

Property Management 

• The Institute did not have a fixed asset control system. EPA recommended 

that the recipient implement a fixed asset threshold or adopt the federal 

standard. EPA also recommended that the recipient maintain a fixed asset 

control system (1) providing detailed property records for assets acquired 

under a grant or subgrant, and (2) including procedures to provide 

reasonable assurance that safeguards are present to prevent or detect 

unauthorized use of these assets. 

Written Procedures 

• The Institute did not have written policies or procedures for accounting, 

codes of conduct, procurement, travel, or record retention. EPA 

recommended that the recipient develop written policies and procedures 

that met the standards outlined by federal regulations. 
Enclosure II 

Page 44 GAO-04-383R Grants Management 

EPA also recommended that the Institute require an employee to get training in 

grants management and that it provide additional financial support personnel to 

help ensure that new policies and procedures are enforced. 

EPA’s Significant Actions

As a result of the concerns identified during the on-site review, EPA informed the 

Institute that it was suspending work on the project and temporarily withholding 

funds. EPA indicated that it was notifying the Financial Management Center not 

to make further payments until EPA’s concerns with the recipient’s grants 

management had been addressed and a corrective action plan was in place. The 

suspension order required the Institute to stop project work and take all 

reasonable steps to minimize project costs. This order was scheduled to be in 

effect for 45 days, and EPA requested that the recipient submit a corrective action 

plan identifying the actions to be taken and associated time frames within 30 days. 

EPA learned that the Institute was considering ceasing operations. Based on this 

information, EPA informed the recipient that it was considering the issuance of 

another suspension order and requested a discussion of these concerns. After the 

Institute’s decision to formally cease operations, EPA notified the organization 

that it was concerned about the proper expenditure of the remaining grant funds 

and the Institute’s financial instability. These concerns led EPA to place special 

conditions on the Institute. Specifically, 

• changing the method of payment from advance to reimbursement; 

• requiring the recipient to submit all reimbursement requests for EPA 

approval and including a list of expenditures identifying task, vendors, and 

supporting documentation to show that the costs were authorized by the 

scope of work for the grant; and 

• requesting that the recipient continue to submit Financial Status Reports. 

Results of Corrective and Significant Actions, and Other Information

EPA provided information indicating that the Institute was unable to formulate a 

corrective action plan to resolve the findings from the on-site review and that the 

Institute dissolved shortly after the suspension order was put in place. EPA 

reported that the Institute’s remaining funds, amounting to $381,353, were 

transferred to the Global Environment and Technology Foundation in February 

2003.
Enclosure II 

Page 45 GAO-04-383R Grants Management 

Self Reliance Foundation 

On October 16 and 17, 2002, officials from EPA’s Office of Grants and Debarment 

conducted an on-site, in-depth review of the Self Reliance Foundation (the 

Foundation). The reviewers identified a number of problems with the 

Foundation’s grants management practices, which led EPA to take two significant 

actions against it: issuing a payment hold and classifying the Foundation as a 

high-risk recipient with special conditions on future grant work. EPA reported 

that while the Foundation has taken some corrective actions, it still has not 

complied with several terms and conditions; and as a result, the Grants 

Administration Division sought to terminate grant number X-82851401 as of 

December 31, 2003. 

Background

The Foundation is a nonprofit organization founded in 1979 to help Hispanics take 

advantage of opportunities for personal and community empowerment in the 

areas of health, women’s issues, education, economic opportunities, science, 

environmental protection and access to new technologies. The Foundation 

operates the Hispanic Community Resource Helpline, the only national, 

multiservice, bilingual information and referral service in the United States. The 

organization is headquartered in Washington, D.C., and is governed by a board of 

directors with six members. It is affiliated with the Hispanic Radio Network. 

Grants Received 

• The Foundation received a grant for $75,000 (X-82851401) in September 

2000 to provide outreach and education of pesticide exposure hazards to 

the Spanish-speaking agricultural community including farm workers, their 

families, growers, and the general public. The results of the grant are 

incomplete and EPA is seeking to terminate the agreement. 

• The Foundation received a grant for $50,000 (X-83041801-0) in September 

2002 to create a Spanish language educational mass media and outreach 

program focusing on radon and asthma. The results of the grant are 

incomplete because work was just beginning when EPA imposed sanctions 

on the Foundation. 

• The Foundation received a grant for $21,232 (NE-98364501-0) in June 2002 

to develop a bilingual exhibit to educate children about asthma and its 

environmental causes. EPA is waiting for a final progress report for this 

grant. 

Description of Problems and Corrective Actions

The reviewers found problems and recommended corrective actions in the 

following areas: 
Enclosure II 

Page 46 GAO-04-383R Grants Management 

Accounting 

• The Foundation did not have a system in place to produce required 

financial reports or to reconcile the amount reported as disbursements to 

EPA with the general ledger. EPA recommended that the recipient develop 

a system within 60 days. 

• The Foundation drew budgeted amounts at the beginning of the award 

periods before actually incurring the expenses. EPA recommended that 

the recipient immediately begin following EPA’s guidelines for cash 

advances. 

Internal Controls 

• The Foundation’s operations lacked adequate segregation of duties. 

Specifically, one contractor had control over processing accounting 

transactions, balancing the general ledger, the checking account, the 

payroll log, and other financial and nonfinancial duties. EPA 

recommended that the recipient divide these responsibilities among 

various individuals within 60 days. 

Missing Required Audit 

• The Foundation had not obtained its required Single Audit for 2001 and 

2002. EPA recommended that the recipient immediately arrange to have 

these audits conducted. 

Personnel/payroll 

• The Foundation’s time sheets showed a number of problems: at least one 

employee failed to sign the time sheets related to grant activity; in several 

instances the time sheets did not show supervisory approval; none of the 

time sheets signatures’ were dated; and one employee was paid without a 

time sheet so the reviewers were unable to determine if the employee’s 

time was allocable to the grant. EPA recommended that the recipient 

implement new policies and procedures to ensure that its payroll system 

met the appropriate standards within 60 days. 

Procurement 

• The Foundation did not document its efforts toward the selection of 

disadvantaged businesses for grant activities. EPA recommended that the 

recipient develop a system to ensure adherence to procurement policies 

regarding these vendors (including documentation) within 90 days. 

• The Foundation was using EPA grant funds to make oral contracts and had 

no written contracts, no documentation of preaward review, and no 

contract monitoring system. EPA recommended that the recipient 

implement procedures to ensure adherence to procurement policies, 
Enclosure II 

Page 47 GAO-04-383R Grants Management 

including requests for proposals, and general procurement standards for 

sole-source solicitation within 30 days. 

• The Foundation entered into a sole-source contract without providing an 

adequate written justification or evidence of a cost or price analysis. EPA 

recommended that the recipient immediately begin ensuring it made and 

documented grant procurements in accordance with federal regulations. 

Progress Reports 

• The Foundation did not include required financial information in its 

programmatic reports. EPA recommended that the recipient immediately 

begin including this financial information in its reports. 

Property Management 

• The Foundation’s property management system did not include all fixed 

assets owned, and the reviewers were unable to determine if equipment 

had been purchased with federal funds. EPA recommended that within 120 

days the recipient complete and update its property management system to 

include all of its fixed assets and other information required by EPA. EPA 

also recommended that the recipient take an accurate inventory and 

compare it with the general ledger and other records. 

Written Procedures 

• The Foundation had not developed a formal and comprehensive policies 

and procedures manual. EPA recommended that, within 120 days, the 

recipient develop policies and procedures covering, among other things, 

accounting and reporting, budget, fixed assets, procurement, and a code of 

conduct. 

EPA’s Significant Actions

As a result of these problems, EPA placed a payment hold on the Foundation’s 

account by instructing the Financial Management Center not to make further 

payments until the concerns had been resolved. EPA also classified the 

Foundation as high-risk and placed the following special conditions on it: 

• changing the method of payment from advance to reimbursement; 

• requiring the recipient to submit written procurement and contract 

administration procedures for EPA approval; 

• requiring the recipient to submit the procedures it would follow to ensure 

that professional service contracts are awarded competitively for EPA 

approval; and 

• requiring the recipient to submit a code of conduct and procedures for 

EPA’s approval. 
Enclosure II 

Page 48 GAO-04-383R Grants Management 

The special conditions also included statements that: 

• No contractor or consultant of the recipient may participate in the 

selection, award, or administration of a contract awarded to their firm; 

• The recipient must take steps to make its relationship with all consultants 

or contractors funded by EPA grant money clear to EPA officials involved 

in overseeing the grants; 

• The recipient’s procurement files must contain documentation of a cost or 

price analysis for all contracts awarded with EPA grant funds; 

• The recipient must establish written procedures to ensure that all costs 

being charged to the grants are properly controlled and documented and 

that the procedures must include an independent review of expenses 

incurred by consultants or contractors; and 

• The recipient must comply with the terms and conditions of its grant 

agreements regarding selection of disadvantaged businesses. 

EPA requested that the Foundation submit a corrective action plan and provide 

documentation that it had an adequate financial management system in order for 

the special conditions to be discontinued. 

Results of Corrective and Significant Actions, and Other Information

Documentation provided by EPA noted that in May 2003, the Foundation issued 

accounting and financial management policies and procedures that addressed 

many of the findings identified in the on-site review. However, EPA also reported 

that the Foundation still had not complied with several terms and conditions and 

failed to submit requested items and required reports. Specifically, the 

Foundation had not submitted the following items for approval: the annual 

progress report for grant number X-82851401; contract administration policies and 

procedures; procedures to ensure that all costs are reasonable, allocable, and 

allowable; a utilization report for disadvantaged business activities; a sole-source 

procurement policy requiring that written justification for selections be included 

in the file; procedures to solicit quotes from disadvantaged businesses and 

documentation of their selection; and procedures to ensure timely submission of 

progress reports. EPA reported that as a result of these deficiencies, the Grants 

Administration Division sought to terminate grant number X-82851401 as of 

December 31, 2003.
Enclosure II 

Page 49 GAO-04-383R Grants Management 

Tribal Association on Solid Waste and Emergency Response 

On July 1, 2002, EPA received a report contractor staff who conducted an on-site, 

in-depth review of the Tribal Association on Solid Waste and Emergency 

Response (the Association). The reviewers found a number of problems with the 

Association’s grants management, which led EPA to take three significant actions 

against it: issuing a suspension order, issuing a payment hold, and requesting that 

the OIG audit the Association. The OIG published its audit in September 2003 and 

questioned all costs claimed by the Association as unsupported. 19 EPA reported 

that the grantee has taken measures to correct the deficiencies identified during 

the on-site review and the audit, and it lifted the suspension order. The project is 

in the audit resolution process as of January 2004. 

Background

The Association is a nonprofit organization located in Washington, D.C. Its 

purpose is to preserve and restore the health and environment of Indian and 

Alaskan native communities. The Association also has as its purpose ensuring 

that environmental policies address the needs and values of tribes, with respect to 

solid waste, emergency response, and Superfund issues. The Association is a 

membership organization consisting of over 100 federally recognized tribes and is 

governed by a 12-member board of directors. 

Grants Received 

• The Association received a grant for $3,360,000 (CR82718101-0) in 

September 1998 to research the effects of waste contamination on human 

health and the detection of hazardous substances in tribal communities. 

The Association is still conducting work for this grant. 

Description of Problems and Corrective Actions

The reviewers found problems and recommended corrective actions in the 

following areas: 

Accounting 

• The Association did not have a system in place to produce required 

financial reports or to reconcile the amount reported as disbursements to 

EPA with the general ledger. The reviewers recommended that, within 60 

days, the Association develop a system that includes line items for: annual 

budget, monthly and year-to-date disbursements, and unused or 

overexpended balances. The reviewers further recommended that the 

 

19EPA Office of the Inspector General, Costs Claimed by the Tribal Association on Solid Waste 

and Emergency Response Under EPA Assistance Agreement No. CR827181-01, Report No. 2003-

4-00119 (Washington, D.C.: Sept. 19, 2003). 
Enclosure II 

Page 50 GAO-04-383R Grants Management 

Association use this information to produce the required financial reports 

and make any adjustments necessary to reconcile the general ledger 

amounts. 

• The Association advanced annual budgeted amounts to contractors at the 

beginning of the contract periods. The reviewers recommended that the 

Association limit cash advances to contractors to the minimum amount 

necessary to carry out required activities. 

Internal Controls 

• The Association’s financial operation and other functions lacked adequate 

segregation of duties. Specifically, one employee had control over 

processing, authorizing, and approving accounting transactions. This 

individual also managed procurement and grant activities, maintained the 

general ledger, and performed other duties. The reviewers recommended 

that the Association assign responsibility for approval and authorization of 

accounting transactions to someone other than this employee. 

Additionally, the reviewers recommended that the Association hire other 

personnel to perform certain functions, such as grants management, 

procurement, and financial reporting. 

Personnel/payroll 

• The Association’s personnel files did not include all necessary and updated 

information about its employees. The reviewers recommended that the 

Association maintain personnel files that are complete and updated for 

current and terminated employees. 

Procurement 

• The Association did not have documentation supporting its efforts to select 

disadvantaged businesses. The reviewers recommended that the 

Association implement procedures to document its efforts for selecting 

these vendors within 90 days. 

• The Association awarded a contract for a multiyear research project using 

a sole-source solicitation, without documenting a preaward review. The 

reviewers recommended that the Association implement procedures to 

ensure compliance with procurement policies and EPA requirements 

within 90 days. 

Progress Reports 

• The Association did not prepare or submit in a timely way the various 

reports required by EPA, such as its annual progress report. The reviewers 

recommended that the Association follow EPA’s guidelines in preparing 

and submitting required reports. 
Enclosure II 

Page 51 GAO-04-383R Grants Management 

Property Management 

• The Association’s property management system did not account for all 

fixed assets, nor had it conducted a physical inventory. The reviewers 

recommended that the Association complete and update its property 

management system to account for these deficiencies within 30 days. 

Technical Issues 

• The Association did not properly prepare or submit in a timely way the 

various reports required by EPA, such as the semiannual Federal Cash 

Transaction Reports and quarterly Financial Status Reports. The reviewers 

recommended that the Association follow EPA’s guidelines in preparing 

and submitting required reports. 

Written Procedures 

• The Association did not have a formal and comprehensive policies and 

procedures manual. The reviewers recommended that the Association 

develop a manual within 120 days that included, among other things, 

accounting and reporting policies and procedures, budget policies, fixed 

asset policies, and procurement policies. 

EPA’s Significant Actions

As a result of the findings identified during the on-site review, EPA notified the 

Association that it was suspending work and temporarily withholding funds and 

would notify the Financial Management Center not to make further payments 

until EPA had resolved its concerns with the recipient’s grants management. EPA 

requested that the Association submit a corrective action plan, with associated 

time frames, within 30 days. EPA informed the Association that the suspension 

order required it to stop project work and take all reasonable steps to minimize 

costs incurred on the project. The order was scheduled to be in effect for 45 days. 

Additionally, EPA forwarded a copy of its on-site report to the OIG and requested 

that the OIG audit the Association. EPA asked that the OIG perform tests on all 

grant related financial transactions to confirm that the grant funds were being 

used properly. 

Results of Corrective and Significant Actions, and Other Information

As requested, the OIG conducted an audit of the Association’s management of 

grant number CR827181-01 and published its findings on September 19, 2003. The 

OIG questioned $2,357,376 of claimed costs because the Association did not 

comply with the federal rules, regulations, and terms of the agreement. 

Specifically, the OIG found that among other things, the Association could not or 

did not (1) reconcile claimed costs to its general ledger, (2) support its salaries 

and wages with the appropriate timesheets, and (3) competitively procure 
Enclosure II 

Page 52 GAO-04-383R Grants Management 

contractual services or perform any of the required cost or pricing analyses. 

Regarding the finding that the Association did not competitively procure 

contractual services, the OIG reported that a former Association board member 

was instrumental in soliciting a university for a contract. However, before the 

Association awarded the contract, the former board member was hired by the 

university. 

The OIG recommended that EPA recover the $2,357,376 in unsupported costs, 

suspend work under the grant, make no new awards until the Association 

demonstrated that its accounting practices were consistent with federal 

regulations, and require the Association to modify its financial management 

system to include, among other things, financial reports that are current, accurate, 

complete, and supported by accounting records and an adequate time distribution 

system that could account for total hours worked and identify specific activities. 

The Association did not agree with the OIG’s findings, and its comments were 

included in the final report. EPA reported that the Association has taken 

measures to correct the deficiencies identified during the on-site review and the 

audit, and it has lifted the suspension order. The project is currently in the audit 

resolution process, and the Grants Administration Division is scheduled to 

respond to the OIG in January 2004.
Enclosure II 

Page 53 GAO-04-383R Grants Management 

Washington Heights Environmental Coalition 

In May 2002, Region 6 officials returned a request for reimbursement from the 

Washington Heights Environmental Coalition (the Coalition) in the amount of 

$352 for multiple reasons, including a lack of grant funds remaining in the account 

and an ineligible expenditure. Region 6 officials also conducted an on-site, indepth review of the Coalition on July 9, 2002. The officials found that the project 

was not on schedule. Additional documentation provided by EPA indicated that 

the agency had noted problems with the Coalition, such as late submission of a 

progress report and a lack of grants management skills. EPA found the Coalition 

to be in noncompliance and determined that it must produce deliverables before 

receiving advanced payment funds. Information EPA provided noted that the 

Coalition has not received additional grants. 

Background

The Coalition is a nonprofit group of citizens affected by the Hudson Refinery site 

in Cushing, Oklahoma, that is on the Superfund National Priority List. The 

Coalition is located in Cushing and is governed by a four-member board of 

directors. 

Grants Received 

• The Coalition received a grant for $50,000 (1-98677501-0) in August 2001 to 

hire independent technical advisors to help interpret and comment on siterelated information generated by the state agency or EPA. The grant 

resulted in few analysis documents from the technical adviser; EPA is 

waiting for further deliverables. 

Description of Problems and Corrective Actions

EPA documentation identified problems in the following areas: 

Financial Expenditures 

• A Coalition request for reimbursement was denied for three reasons: (1) 

the amount of the request was $352, but the recipient had only $346 

remaining in its checking account, (2) $2.70 of this $352 was ineligible for 

repayment because the claimed cost was incurred on April 28, 2001, which 

was before the grant was awarded, and (3) the remaining $3.30 over the 

$346 was too small a request for EPA to process. 

Personnel/payroll 

• The Coalition did not have staff with the skills necessary to manage its 

grant and prepare required reports or forms correctly. EPA requested a 

special training session with the recipient to assist it in managing its grant. 
Enclosure II 

Page 54 GAO-04-383R Grants Management 

Progress Reports 

• The Coalition had been late in submitting a progress report. 

Technical Issues 

• The Coalition was behind in hiring its technical advisor, which affected the 

submission of analysis documents. The reviewers noted that a major 

barrier to accomplishing the work was the recipient’s lack of 

administrative skills. 

EPA’s Significant Actions

EPA did not process the Coalition’s ineligible expenditure. 

Results of Corrective and Significant Actions, and Other Information

Additional information provided by EPA indicated that the Coalition has produced 

few of its analysis documents. EPA found the recipient to be in noncompliance 

and determined that it must produce deliverables before drawing further funds. 

EPA noted that it has not awarded any more grants to the Coalition. 

(360422) 
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