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EPA Needs to Improve 

STAR Grant Oversight

Report No. 13-P-0361 August 27, 2013

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
Report Contributors: Eileen Collins

Kimberly Crilly

Janet Kasper

Madeline Mullen

Shannon Schofield

LaTanya Scott

Abbreviations

CFR Code of Federal Regulations

EPA U.S. Environmental Protection Agency

FY Fiscal year

IGMS Integrated Grants Management System

NCER National Center for Environmental Research

OARM Office of Administration and Resources Management

OGD Office of Grants and Debarment

OIG Office of Inspector General

ORD Office of Research and Development

STAR Science to Achieve Results

Cover photo: A mass spectrometer in a research laboratory is an example of laboratory

equipment that can be used to analyze samples during STAR grant research

(EPA OIG photo). 

Hotline

To report fraud, waste, or abuse, contact us through one of the following methods:

email:

phone:

fax:

online:

OIG_Hotline@epa.gov

1-888-546-8740

(202) 566-2599

http://www.epa.gov/oig/hotline.htm

write: EPA Inspector General Hotline 

1200 Pennsylvania Avenue, NW

Mailcode 2431T

Washington, DC 20460
13-P-0361

August 27, 2013

Why We Did This Review

The U.S. Environmental 

Protection Agency, Office of 

Inspector General, conducted 

this audit to answer the 

questions: 

1. Is EPA effectively monitoring 

Science to Achieve Results 

grant recipient activities?

2. Does EPA verify that STAR 

grant recipients take action 

to ensure that research 

misconduct is not associated 

with grant activities? 

The STAR competitive grant 

program is the primary vehicle 

through which the EPA funds 

research at universities and 

nonprofit groups. From fiscal 

years 2010 through 2012, the 

EPA funded 220 projects 

totaling $150,043,796 through 

the STAR grant program.

This report addresses the 

following EPA Goal or 

Cross-Cutting Strategy:

Advancing science, research 

and technological innovation.

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391.

The full report is at:

www.epa.gov/oig/reports/2013/ 

20130827-13-P-0361.pdf

EPA Needs to Improve STAR Grant Oversight 

 What We Found

We found that the EPA’s project officers did not monitor STAR grant recipients in 

a manner consistent with the agency’s policy and guidance. For example, project 

officers did not take action when recipients submitted annual reports late, did not 

follow baseline monitoring guidance, and did not routinely follow up when 

disclaimers about EPA’s endorsement were not included in published articles.

By not following policy, project officers increased the risk that issues would not 

be corrected in a timely manner and that projects might not meet specified goals. 

During administrative advanced-monitoring reviews, the EPA did not ensure costs 

were allocable to the grant and did not request certified effort reports. We 

reviewed drawdowns totaling $639,045 and found $53,854 in costs that were not 

allowable. We also found that one grant recipient’s certified effort reports did not 

comply with the recipient’s own internal policies.

Project officers did not actively monitor STAR grant recipients for potential 

research misconduct, or review recipients for compliance with research 

misconduct terms and conditions. When the EPA does not monitor research 

misconduct, the agency puts grant funds at risk.

 Recommendations and Planned Agency Corrective Actions

We recommend that the EPA provide mandatory training to STAR grant project 

officers. The training should include baseline monitoring performance and

instructions to ensure baseline monitoring reports are accurately completed. 

For incrementally funded grants, the EPA should enforce the terms and conditions

that allow withholding of funds for late or missing reports, and amend these 

requirements for all awards so that payment will be withheld when progress 

reports are missing or late. We recommend that the EPA require grant recipients

to submit corrections to publications when acknowledgement of EPA funding and 

disclaimers of EPA endorsement are missing from articles. 

To address unallowable costs, we recommend that the EPA follow up on the 

unallowable costs that we identified and issue guidance to grant specialists for

improving administrative advanced-monitoring reviews. We also recommend that 

the EPA require project officers to verify grant recipients’ awareness of research 

misconduct reporting requirements. The EPA’s completed and planned corrective 

actions address all of the OIG’s recommendations.

 Noteworthy Achievements 

The EPA immediately corrected a website containing outdated terms and 

conditions after we informed the agency about the problem. Grant recipients are 

now directed to the correct website for grant terms and conditions.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance
August 27, 2013 

MEMORANDUM

SUBJECT: EPA Needs to Improve STAR Grant Oversight 

 Report No. 13-P-0361 

FROM: Arthur A. Elkins Jr. 

TO: Lek Kadeli, Principal Deputy Assistant Administrator 

Office of Research and Development 

 Craig Hooks, Assistant Administrator 

Office of Administration and Resources Management 

This is our report on the subject audit conducted by the Office of Inspector General of the 

U.S. Environmental Protection Agency. This report contains findings that describe the 

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

Action Required 

In responding to the draft report, the agency provided a corrective action plan for addressing the 

recommendations with milestone dates. Therefore, a response to the final report is not required. 

The agency should track corrective actions not implemented in the Management Audit Tracking 

System. This report will be available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Richard Eyermann, acting 

assistant inspector general for the Office of Audit, at (202) 566-0565 or eyermann.richard@epa.gov; 

or Janet Kasper, product line director, at (312) 886-3059 or kasper.janet@epa.gov. 

THE INSPECTOR GENERAL

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460
EPA Needs to Improve STAR Grant Oversight 13-P-0361

Table of Contents

Chapters

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

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

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

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

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

2 Project Officers Did Not Follow EPA Guidance.............................................. 4

STAR Grants Must Comply With Federal and EPA Requirements ............. 4

Annual Reports Were Frequently Late ....................................................... 5

Project Officers Did Not Follow Baseline Monitoring Guidance .................. 6

Published Articles Were Missing Required Disclaimers ............................. 7

Recommendations..................................................................................... 8 

Agency Comments and OIG Evaluation..................................................... 8

3 Drawdown Reviews Need Improvement ......................................................... 10

Federal Requirements Define Allowable Costs .......................................... 10

EPA Reimbursed Unallowable Costs ......................................................... 10

Administrative Advanced-Monitoring Review Needs Improvement............. 12

Increased Risk of Reimbursing Unallowable Costs .................................... 12

Recommendations..................................................................................... 13 

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

4 Research Misconduct Terms and Conditions Were Not Monitored.............. 14

EPA’s Terms and Conditions Define Research Misconduct 

 and Reporting Requirements ............................................................. 14

Project Officers Did Not Monitor for Potential Research Misconduct .......... 15

Project Officers Did Not Ask About Research Misconduct.......................... 17

Risk of Research Misconduct Not Addressed ............................................ 17

Recommendation... ................................................................................... 17

Agency Comments and OIG Evaluation..................................................... 18

Status of Recommendations and Potential Monetary Benefits ............................. 19

Appendices

A STAR Grants Reviewed by the EPA OIG......................................................... 20

B Agency’s Response to Draft Report ............................................................... 21

C Distribution ....................................................................................................... 26
13-P-0361 1

Chapter 1

Introduction

Purpose

The U.S. Environmental Protection Agency, Office of Inspector General,

conducted an audit of the Science to Achieve Results grant program to 

answer the questions: 

1. Is EPA effectively monitoring Science to Achieve Results grant recipient 

activities?

2. Does EPA verify that STAR grant recipients take action to ensure that 

research misconduct is not associated with grant activities?

Background

The STAR program began in 1995 and was assigned to the EPA’s National 

Center for Environmental Research and Quality Assurance—currently known as 

the National Center for Environmental Research. The program’s research focus 

was developed specifically to meet the research needs of the EPA. The program 

funds targeted research grants in numerous environmental science and 

engineering disciplines.

The STAR competitive grant program is the primary vehicle through which the 

EPA funds research at universities and nonprofit groups. From fiscal years 2010 

through 2012, the EPA funded 220 projects totaling $150,043,796 through the 

STAR grant program. Research efforts funded by these grants are aligned with the 

EPA’s strategic goals, including the cross-cutting strategic goal of advancing

science and research. The public can access progress reports about these research 

projects by visiting the NCER website at 

http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/search.welcome. 

Although the NCER is responsible for administering the programmatic aspects of 

STAR grants, the Office of Grants and Debarment is responsible for the financial 

management of the STAR program. The NCER and OGD each perform baseline 

and advanced-monitoring reviews of grant recipients. 

The EPA includes terms and conditions in the grants that it awards. The terms and 

conditions cover topics such as financial and program management of the grants, 

timing and content of annual and final reports, and reporting requirements for 

research misconduct. According to the Code of Federal Regulations through 

2 CFR §215.61, grant recipients failing to comply with the terms and conditions 

of an award can have their awards terminated.
13-P-0361 2

Noteworthy Achievements

The EPA ensured that an outdated website was corrected so that the terms and 

conditions included in the awards would no longer direct grant recipients to 

outdated agency-specific information. We found that the EPA’s STAR grant 

agreements did not always include the correct website that contained the 

applicable agency-specific terms and conditions. When we informed EPA staff 

about this, they took immediate action to correct the problem. 

Scope and Methodology

We conducted this performance audit from July 2012 through June 2013, in 

accordance with generally accepted Government Auditing Standards (Yellow 

Book) issued by the Comptroller General of the United States. Those standards 

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

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

our audit objective. We believe that the evidence obtained provides a reasonable 

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

The 12 STAR grants that we reviewed had a total funding amount of 

$10,385,348. The audit team initially made a judgmental selection of two grants 

with a total obligation amount of $4,680,608. After reviewing these two grants to 

gain an understanding of the STAR grant process and documents, the team 

randomly sampled 10 additional grants. We identified 84 STAR grants with 

project start dates after October 1, 2008, and project end dates prior to 

September 30, 2013. The total funding amount for these grants was $49,798,525.

The team generated a random sample of 10 grants with a total obligation amount 

of $5,704,740.

To determine whether there was evidence of monitoring and whether the 

monitoring was conducted in accordance with applicable policies and procedures, 

we obtained annual progress reports from the selected grant recipients’ project 

officers. We reviewed the annual progress reports to determine if the reports were 

submitted on time and whether they indicated progress commensurate with the 

outputs and outcomes identified in the work plan. We also obtained programmatic 

and administrative reports from the EPA’s Integrated Grants Management 

System. The IGMS reports were completed by project officers and grant 

specialists. 

To determine whether grant recipients were complying with the terms and 

conditions of their grants, we obtained the following documents from selected 

grant recipients and from websites where scientific articles are posted. 

Supporting financial documentation for three selected drawdowns for 

each of the five judgmentally selected grant recipients to determine if 

claimed costs were allowable. We selected the five grants based on 
13-P-0361 3

information noted on the grant application indicating the recipient had

received funding for similar grants from EPA or other federal agencies. 

Six published articles to determine whether the articles contained 

an acknowledgment of EPA funding and a disclaimer stating the 

EPA does not endorse the article. At the time of the audit, only six

of the grant recipients had published articles. 

Scientific integrity policies of nine grant recipients to determine whether 

their policies were consistent with EPA requirements for reporting 

research misconduct, as outlined in the agency’s terms and conditions. 

We reviewed the scientific integrity policies for the grant recipients that 

we were also reviewing for financial documentation and published 

articles. We limited our review to nine grant recipients to comply with 

requirements of the Paperwork Reduction Act. 

We interviewed the OGD and Office of Research and Development staff

(including project officers), and discussed their procedures for monitoring grant 

recipients and ensuring scientific integrity. We also interviewed the grant 

recipients to discuss applicable terms and conditions, reporting, and interactions 

with the EPA. The grants reviewed are listed in appendix A.

There were no prior audits impacting the objectives of this assignment. 
13-P-0361 4

Chapter 2

Project Officers Did Not Follow EPA Guidance

Project officers did not monitor STAR grant progress in a manner consistent with 

the EPA’s policy and guidance. Project officers also allowed grant recipients to 

submit annual reports late. STAR grant recipients must comply with numerous 

federal and EPA requirements. The project officers emphasized overall progress 

rather than compliance with specific requirements. This introduced risks that 

could lead to the project officers not detecting issues needing corrective action 

and that might impact the project meeting its goals. In addition, missing 

acknowledgements and disclaimers in published research put the EPA’s 

transparency at risk and could give an appearance of the agency endorsing the 

research.

STAR Grants Must Comply With Federal and EPA Requirements

The EPA’s Assistance Administration Manual (EPA Order 5700) requires agency 

project officers to conduct baseline monitoring of all assistance agreements. 

Monitoring is supposed to include a review of:

Compliance with programmatic terms and conditions.

Drawdowns and budget expenditures.

Recipient progress, including a comparison of funds available to project 

progress or time remaining on the project. 

The EPA’s Policy on Compliance, Review, and Monitoring (EPA Order 5700.6) 

requires project officers to conduct baseline monitoring at least annually, and that 

baseline monitoring should include a review of the grant recipient’s annual report.

Terms and conditions for EPA grants require recipients to submit annual reports 

on grant progress. Depending on when the grant was awarded, the due date for the 

annual report varies.

Table 1: Annual report due date

Terms and conditions 

issuance date1 Annual report due date

July 2008 30 days prior to the end of the reporting period

June 2009 30 days prior to the end of the reporting period

November 2010 90 days after the end of the reporting period

Source: EPA grant terms and conditions.

 

1 Terms and conditions apply to all grants awarded after the date the terms and conditions were issued.
13-P-0361 5

If the recipient does not submit the annual report by the due date, the terms and 

conditions for partially funded grants allow the EPA not to provide further 

funding until the recipient has submitted the required annual progress report.

The EPA encourages independent publication of results from its extramural 

research in appropriate scientific journals. When doing so, the terms and 

conditions require that there be an acknowledgement of EPA funding. The exact 

wording of the acknowledgement depends on when the grant was awarded. The 

FY 2008 terms and conditions required grant recipients to include the following 

statement in all journal articles publishing work funded by an EPA grant:

Although the research described in this article has been funded 

wholly or in part by the United States Environmental Protection 

Agency through grant/cooperative agreement (number) to (name), 

it has not been subjected to the Agency’s required peer and policy 

review and therefore does not necessarily reflect the views of the 

Agency and no official endorsement should be inferred.

The FY 2009 and FY 2010 terms and conditions revised the statement as follows:

This publication was made possible by USEPA grant (number). Its 

contents are solely the responsibility of the grantee and do not 

necessarily represent the official views of the USEPA. Further, 

USEPA does not endorse the purchase of any commercial products 

or services mentioned in the publication.

Annual Reports Were Frequently Late

Of the 12 grants that we reviewed, 10 grant recipients submitted late annual 

reports for 2 years or more during the life of the projects (see table 2):

Table 2: Annual progress reports that were late or not submitted

Grant 

number 2007 2008 2009 2010 2011 2012

83337401 273 109 Not 

submitted

231 Not 

submitted

83409301 Not 

submitted

140 289 Not 

submitted

83389201 98 123 225

83435901 277 237 141

83428501 122 139 135

83428201 123 139 Not 

submitted

83438601 150 211

83459601 322 161

83399002 454 434 168

83337302 144 1

Source: OIG analysis of recipient annual reports for days late. (Shaded cells indicate 

reports were not required that year.)
13-P-0361 6

The EPA’s project officers did not enforce the specific annual reporting time

frames listed in the terms and conditions. In many cases, the project officer did 

not identify the correct annual report due dates in the terms and conditions,

because award documents directed the reader to an outdated website that 

contained incorrect information. Project officers also did not conduct monitoring 

in compliance with EPA Order 5700.6, and one project officer chose to allow a 

grant recipient to submit late annual reports despite the due dates that were 

required by the terms and conditions. The often substantial tardiness of annual 

reports introduced an unnecessary risk that could lead project officers not to 

detect issues needing corrective action and might impact the project not meeting

its goals.

For grants that were awarded in full, there were no consequences for late or 

missing reports. For grants that received incremental funding, the terms and 

conditions gave the EPA the option of not providing further funding until grant 

recipients submitted annual progress reports. Four of the grants we reviewed 

received incremental funding, and three of those four grant recipients consistently 

submitted annual reports late. In fact, further funding had already been provided

for two of the recipients before the first progress report was due, and one recipient 

was fully funded after the first progress report was submitted late. As a result, the 

EPA could not exercise this option.

Project Officers Did Not Follow Baseline Monitoring Guidance

Of the eight EPA project officers that we interviewed, four did not conduct 

monitoring in compliance with EPA Order 5700.6 requirements. Specifically:

Two project officers did not complete programmatic baseline monitoring 

reports for 1 year or more.

One project officer conducted baseline monitoring without reviewing the 

recipient’s annual progress report.

One project officer did not review the project’s progress against the 

timeline in the work plan, because the timeline was missing.

The project officers are supposed to conduct baseline monitoring annually and 

document the monitoring in the IGMS. Baseline monitoring includes a review of 

the grant recipients’ annual progress reports. The 2007 baseline monitoring 

checklist guidance did not require project officers to note whether annual reports 

were late. This introduced a risk that the EPA could not detect issues needing 

corrective action and that projects might not meet their goals. The EPA updated 

that checklist in 2012 to include a specific question concerning whether progress 

reports were submitted as required. When project officers do not follow baseline 

monitoring guidance, the EPA’s oversight of grants is hindered.

The terms and conditions require grant recipients to report expenditures to date,

along with providing a comparison of the percentage of the project completed 
13-P-0361 7

according to the project schedule. However, one project officer did not think that 

a timeline was necessary to review the project progress. Because the grant 

recipient’s work plan did not include a timeline, the project officer was unable to 

monitor sufficient progress within the agreed-upon project period. Subsequently,

he approved a no-cost time extension to perform the work and/or to use the

unexpended funds for additional work. When project officers allow STAR grant 

recipients to rely upon no-cost time extensions to complete work that the 

recipients had agreed to finish in a shorter time period, the integrity of the STAR 

grant award process is called into question.

Published Articles Were Missing Required Disclaimers

Of the six published articles reviewed, three did not contain the disclaimer 

required by grant terms and conditions noting the EPA does not endorse the 

article (see table 3).

Table 3: Published articles reviewed 

Grant 

number Article title

Disclaimer was 

not included

83409301 UV Irradiation and Humic Acid Mediate Aggregation of 

Aqueous Fullerene (nC60) Nanoparticles

X

83428501 Economically Consistent Long-Term Scenarios for Air 

Pollutant Emissions

X

83459601 Exposure to Traffic-related Air Pollution During 

Pregnancy and Term Low Birth Weight: Estimation of 

Causal Associations in a Semiparametric Model

X

Source: EPA OIG analysis of select published articles.

Project officers learned about the inclusion of the required acknowledgment and 

disclaimer in published articles only after the actual publication; therefore, any 

corrective action by the agency was after the fact. Some project officers said they 

checked and found missing information, but only one acknowledged following up 

with the grant recipient. Follow-up was not consistent. During the audit, NCER 

management said actions could be taken to improve compliance with this 

requirement. 

Without the required disclaimer, people may presume that the EPA approves of 

the information presented in the articles. This is especially true when EPA 

funding is acknowledged. Public confidence in the EPA’s mission could be 

diminished if the research is contradicted in the future.
13-P-0361 8

Recommendations

We recommend that the Assistant Administrator for Research and Development:

1. Require all project officers to attend training on how to perform baseline 

monitoring. Include a discussion concerning actions to be taken when 

publications do not include required acknowledgements and disclaimers.

2. Conduct a review of baseline monitoring reports to ensure they are 

accurately completed. 

3. Enforce the terms and conditions that allow funds to be withheld from 

incrementally funded grants, if reports are missing or late.

4. Amend terms and conditions so that all awards are subject to a condition 

that payments will be withheld when reports are missing or late. 

5. Require the grant recipient to submit corrections to publications when 

project officers identify missing acknowledgements and disclaimers.

Require immediate correction for online articles and at the next 

publication date for printed articles.

6. Require grant recipients to submit corrections to publications for the 

articles that the EPA OIG identified as missing acknowledgments and 

disclaimers.

Agency Comments and OIG Evaluation 

The EPA agreed with the recommendations and stated that the ORD will provide 

all STAR grant project officers with training on the performance of baseline 

monitoring. The ORD has drafted standard operating procedures for steps to be 

taken when annual progress reports are not received in a timely manner, including 

when to pursue withholding funds from incrementally funded grants due to failure 

to comply. The ORD is revising its guidance pertaining to annual report reviews, to 

include actions to be taken when publications do not have the required 

acknowledgements and disclaimers. 

The ORD is adding a requirement for grant recipients to ensure that publications 

have EPA acknowledgements and disclaimers. The ORD is also revising its terms 

and conditions to include a condition that payments may be withheld when reports 

are missing or late. This will be applied to all new STAR grants. If 

acknowledgements and disclaimers are identified as missing, principal investigators 

will be instructed to submit corrections. When implemented, the agency’s actions 

should address recommendations 1, 3, 4 and 5. 
13-P-0361 9

The EPA reported that corrective actions for two of the recommendations have 

already been completed. The NCER completed a review of project officer file 

records and modified its multiyear review plan to include an annual review of 

STAR grants, including baseline monitoring reports. Also, the ORD received 

copies of three correction requests that journal editors made to add the required 

disclaimers. The EPA’s corrective actions address recommendations 2 and 6. 
13-P-0361 10

Chapter 3

Drawdown Reviews Need Improvement

During administrative advanced-monitoring reviews, the EPA does not ensure 

that costs are allocable to the grant and does not request certified effort reports. 

We reviewed drawdowns totaling $639,045 and found $53,854 in costs that were 

not allowable because the costs were either unallocable or unsupported. We also 

found that one grant recipient’s certified effort reports did not comply with the 

recipient’s own internal policies. EPA Order 5700.6 states that the purpose of the 

advanced monitoring is to conduct in-depth assessments, including administrative 

and financial progress. Federal regulations state costs are allowable only if they 

are allocable to the grant agreement. The lack of detailed cost reviews increases 

the risk that more unallowable costs will be reimbursed in the future.

Federal Requirements Define Allowable Costs

An allowable cost is defined in 2 CFR Part 220, Appendix A. A cost is allowable 

if it is reasonable, allocable to the sponsored agreements, and given consistent 

treatment. A cost is allocable to a particular cost objective if it is incurred solely 

to advance the work and benefits both the sponsored agreement and other work of 

the institution. 

According to 2 CFR Part 220, Appendix A, grant recipients are also required to 

confirm the activity of personnel who charge time to the grant through what is 

referred to as “certified effort reports.” These signed reports verify the work was 

performed by employees and can be signed by either the employee or a 

responsible official. The effort reports verify that salaries or wages were correctly 

charged against the grant.

EPA Order 5700.6 requires the EPA to evaluate the allowability of costs as a part 

of advanced monitoring. The order states that the purpose of administrative 

advanced monitoring is to conduct in-depth assessments of a recipient’s 

administrative and financial progress. Additional EPA guidance for administrative 

advanced monitoring requires the testing of transactions to determine whether 

claimed costs are allowable, allocable, and reasonable under the assistance 

agreement.

EPA Reimbursed Unallowable Costs

The EPA incorrectly reimbursed a total of $53,854 (see table 4). Of the 

$6,906,269 drawn down by the five grant recipients, we reviewed $639,045. 
13-P-0361 11

The costs were not allowable because they were either not allocable to the grant 

or were not supported. While we only looked at a sample of the drawdowns, the 

sample may be an indicator that other unallowable costs exist.

Table 4: Summary of unallowable costs

Type of cost Unallowable costs Note

Personnel $44,886 1

Travel 426 2

Other 292 3

Indirect costs 8,250 4

Total $53,854

Source: OIG analysis of recipient drawdown records.

Note 1–Personnel Costs 

One grant recipient claimed $44,886 of personnel costs that were not allowable. 

The grant recipient did not provide certified effort reports as required by 2 CFR 

Part 220, Appendix A to confirm that distribution of labor is accurate. 

Recipient effort reports did not always meet federal regulations or the grant 

recipient’s own internal policies. For example, one grant recipient provided 

incorrect effort reports:

Three effort reports were certified by individuals who were not authorized 

to certify effort reports, according to the grant recipient’s own internal 

policy.

Nine effort reports did not identify the certifier by name, as required by

2 CFR Part 220, Appendix A.

Note 2–Travel Costs 

Travel costs totaling $426 were not allowable:

Travel expenses totaling $224 were not allocable.

o The travel expense report showed a $200 expense for a personal 

side trip to a different location. The costs claimed for the return 

flight were not reduced to account for the expense associated with 

the personal side trip.

o Internal audit fees related to two travel expense reports and totaling 

$24 were included in the draw. However, the purpose of the travel 

associated with these expense reports was not entirely related to 

the EPA grant. 
13-P-0361 12

Travel expenses totaling $202 were not supported.

o A $198 hotel expense was not supported with a hotel receipt.

o A $4 local travel expense was not supported because $18 was 

claimed, but only $14 was supported.

Note 3–Other Costs

The grant recipient claimed $292 in other costs that were not allowable:

Computer services costs totaling $211 were not supported.

Communication costs totaling $81 were charged to the STAR grant when 

the cost should have been shared with another non-EPA funded project.

Note 4–Indirect Costs

Because personnel, travel and other costs identified above were not allowable,

associated indirect costs totaling $8,250 were also not allowable. 

Administrative Advanced-Monitoring Review Needs Improvement

One of the grants in our sample had an administrative advanced-monitoring desk 

review, where we found:

The grant specialist traced payroll costs to the payroll register, but not to 

the certified effort reports. According to OGD staff, the grant specialist

does not request effort reports during an administrative advancedmonitoring review.

The grant specialist traced travel costs to the supporting documents, but 

did not determine whether the travel was applicable to the grant. 

According to OGD staff, the grant specialist would not know whether the 

travel was applicable to the grant, because the specialists do not have the 

same technical knowledge about the project as the project officers.

The EPA’s grants staff do not collaborate with program staff on cost reviews. The 

agency’s policy requires grant specialists to review drawdowns as a part of the 

administrative advanced monitoring. However, according to EPA staff, drawdown 

reviews by grant specialists did not include verification or consultation with the 

project officer about cost allocability.

Increased Risk of Reimbursing Unallowable Costs

Federal funds drawn for unallowable costs could have been put to better use. 

When the OGD and project officers do not collaborate on reviewing costs during 

administrative advanced monitoring, there is a risk that unallowable costs will be 
13-P-0361 13

reimbursed. Also, not reviewing effort reports increases the risk that unallowable 

personnel costs will be reimbursed.

Recommendations

We recommend that the Assistant Administrator for Administration and 

Resources Management:

7. Follow up on unallowable costs identified in the finding. If grant 

recipients cannot provide documentation, require repayment of the funds.

8. Issue guidance to grant specialists, and remind them that during 

transaction testing they are required to:

a. Trace costs to source documents, including a review of certified 

effort reports. 

b. Make a determination as to whether costs are related to the 

activities funded by the grant. Where grant specialists cannot 

determine allocability, they should work with the project officer to 

verify costs associated with the grant. 

Agency Comments and OIG Evaluation 

The EPA agreed with the recommendations and stated that the Office of 

Administration and Resources Management will follow up on unallowable costs 

and require repayment as appropriate. When implemented, the agency’s actions

should address recommendation 7. Also, the OARM reminded grant specialists to 

follow advanced-monitoring guidance provisions to trace grant costs to source 

documentation and determine whether costs are related to grant-funded activities. 

If there are allocability questions, grant specialists will work with the project 

officer to verify costs. The agency’s action addresses recommendation 8.
13-P-0361 14

Chapter 4

Research Misconduct Terms and Conditions

Were Not Monitored

Project officers did not actively monitor STAR grants for potential research 

misconduct or assess compliance with research misconduct terms and conditions.

The grant recipients’ scientific integrity policies do not always reflect an 

understanding of this requirement and can conflict with agency policy. EPA Order 

5700.6 requires project officers to conduct baseline monitoring of all assistance 

agreements, including a review of compliance with programmatic terms and 

conditions. The EPA’s terms and conditions require grant recipients to notify the 

agency when the recipients discover research misconduct. 

Project officers assumed grant recipients would report research misconduct. The 

project officers also assumed the grant pre-award peer-review process and the 

published article peer-review process would lessen the likelihood of research 

misconduct. However, grant recipients may not understand the requirements for 

identifying and reporting research misconduct. The pre-award peer-review 

process only searches for one type of research misconduct—a conflict of interest;

while during the publication peer-review process, the NCER does not receive any 

information. In both instances, the lack of monitoring increases the risk that 

federal funds will be misused.

EPA’s Terms and Conditions Define Research Misconduct and 

Reporting Requirements 

The EPA’s terms and conditions for research misconduct state that in accordance 

with 40 CFR 30.51(f), the recipient agrees to notify the EPA project officer in 

writing about research misconduct involving research activities that are supported 

in whole or in part with agency funds. The EPA defines research misconduct as 

fabrication, falsification, or plagiarism in proposing, performing, or reviewing 

research or in reporting research results; or ordering, advising or suggesting that 

subordinates engage in research misconduct. Terms and conditions specified in 

the “EPA Research and Related Agency Specific Requirements” call for STAR

grant recipients to:

(1) immediately notify the EPA Project Officer who will then 

inform the EPA Office of Inspector General (OIG) if, at any 

time, an allegation of research misconduct falls into one of the 

categories listed below: 

A. Public health or safety is at risk. 

B. Agency resources or interests are threatened. 
13-P-0361 15

C. Circumstances where research activities should be 

suspended. 

D. There is a reasonable indication of possible violations of 

civil or criminal law. 

E. Federal action is required to protect the interests of those 

involved in the investigation.

F. The research entity believes that the inquiry or 

investigation may be made public prematurely so that 

appropriate steps can be taken to safeguard evidence and 

protect the rights of those involved. 

G. Circumstances where the research community or public 

should be informed. 

(2) report other allegations to the OIG when they have conducted 

an inquiry and determined that there is sufficient evidence to 

proceed with an investigation.

EPA Order 5700.6 requires project officers to conduct baseline monitoring of all 

assistance agreements, including a review of compliance with programmatic 

terms and conditions. The EPA’s programmatic baseline monitoring template 

includes the following question: Is the recipient complying with all applicable 

programmatic terms and conditions? The 2012 baseline monitoring template 

provides additional guidance and states that the project officer has to confirm that 

all terms and conditions are being met to the maximum extent practicable.

Project Officers Did Not Monitor for Potential Research Misconduct 

Project officers are not monitoring grant recipient compliance with research 

misconduct terms and conditions. Project officers said it is the grant recipient’s

responsibility to report research misconduct, and the officers assume the 

recipients will do so if misconduct occurs. The project officers also did not review 

grant recipients’ scientific integrity policies to determine whether the recipients

understood the EPA’s research misconduct definitions or the agency’s notification 

requirements.

We reviewed scientific integrity policies for nine grant recipients (see table 5) and 

found that the policies did not include:

A complete definition of research misconduct.

A statement that the sponsoring agency would be notified immediately 

upon discovery of research misconduct. 
13-P-0361 16

Table 5: Scientific integrity policies not consistent with terms and conditions

Grant 

number

Missing notification 

requirement

Incomplete definition of 

research misconduct

83337401 X X

83329201 X X

83409301 X X

83438601 X X

83428501 X X

83428201 X X

83459601 X X

83399002 X X

83337302 X

Source: OIG analysis of grant recipients’ scientific integrity policies.

Notification Requirement 

The EPA’s terms and conditions require grant recipients to immediately notify the 

project officer if, at any time, an allegation of research misconduct falls into one 

of seven specified categories. However we found that eight grant recipients’ 

policies contained reporting language that was inconsistent with the terms and 

conditions. For example:

One policy stated that the dean shall take whatever action he or she 

considers appropriate and would provide a copy of the proceedings to the 

EPA when required. There is a risk that all applicable allegations of 

research misconduct would not be reported unless the dean took action on 

the allegations first.

Another policy said the grant recipient would only notify the federal

sponsor within 24 hours if there is a reasonable indication of a possible 

federal criminal and civil violation. It did not state that the sponsor would 

be immediately notified for other conditions and did not include 

circumstances where research activities should be suspended. There is a 

risk that all applicable allegations of research misconduct would not be 

reported.

Definition of Research Misconduct

All of the nine grant recipients’ policies defined research misconduct as 

“fabrication, falsification or plagiarism, in proposing, performing, or reviewing 

research, or in reporting research results,” as included in the EPA’s terms and 

conditions. However, none of the nine grant recipients included “ordering, 

advising or suggesting that subordinates engage in research misconduct” in their 

definition—terms that are found in the EPA’s definition of research misconduct.
13-P-0361 17

Project Officers Did Not Ask About Research Misconduct

The EPA’s guidance does not include specific procedures for project officers to 

follow when monitoring grant recipients for potential research misconduct.

Project officers relied on the grant recipients’ experience and expertise and 

assumed recipients would report research misconduct when it occurred. Project 

officers made the following assumptions:

Grant recipients could be relied on to exercise scientific integrity, and that 

it would not be necessary to review the policies to ensure that grant 

recipients understood the research misconduct reporting requirements in 

the terms and conditions.

The prestige of the universities and the professional reputation of the 

principal investigators lessened the likelihood of research misconduct.

The pre-award process and the peer-review process for articles published 

in reputable journals lessened the likelihood of research misconduct.

Risk of Research Misconduct Not Addressed

Because grant recipients’ policies do not specifically address the reporting of 

research misconduct allegations to the EPA, there is a higher risk that the agency

may not be notified when grant recipients become aware of actual or alleged

research misconduct. An article appearing in Nature, an international journal of 

science, described a survey of scientists early in their career and in mid-career, 

and noted that 33 percent of the scientists admitted to engaging in at least one 

research misconduct activity during the previous 3 years. If the EPA is not 

notified when research misconduct is discovered, this could prevent the EPA from 

taking corrective action or determining whether grant funds were misused. The 

STAR program funds millions of dollars in research each year, and research 

misconduct puts those federal dollars at risk. 

Recommendation

We recommend that the Assistant Administrator for Research and Development:

9. Require that during annual baseline monitoring, project officers verify that 

grant recipients fully understand research misconduct reporting 

requirements.
13-P-0361 18

Agency Comments and OIG Evaluation

The EPA agreed with the recommendation and stated that the NCER will modify 

its terms and conditions for annual progress reports to include an assertion of 

compliance with the research misconduct terms and conditions. When 

implemented, the agency’s action should address recommendation 9.
13-P-0361 19

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 8 Require all project officers to attend training on how 

to perform baseline monitoring. Include a discussion 

concerning actions to be taken when publications 

do not include required acknowledgements and 

disclaimers.

O Assistant Administrator for 

Research and Development

12/31/13

2 8 Conduct a review of baseline monitoring reports to 

ensure they are accurately completed.

C Assistant Administrator for 

Research and Development

7/19/13

3 8 Enforce the terms and conditions that allow funds to 

be withheld from incrementally funded grants, if 

reports are missing or late.

O Assistant Administrator for 

Research and Development

9/30/13

4 8 Amend terms and conditions so that all awards are 

subject to a condition that payments will be withheld 

when reports are missing or late.

O Assistant Administrator for 

Research and Development

9/30/13

5 8 Require the grant recipient to submit corrections to 

publications when project officers identify missing 

acknowledgements and disclaimers. Require 

immediate correction for online articles and at the 

next publication date for print articles.

O Assistant Administrator for 

Research and Development

9/30/13

6 8 Require grant recipients to submit corrections to 

publications for the articles that the EPA OIG 

identified as missing acknowledgements and 

disclaimers

C Assistant Administrator for 

Research and Development

7/19/13

7 13 Follow up on unallowable costs identified in the 

finding. If grant recipients cannot provide 

documentation, require repayment of the funds.

O Assistant Administrator for 

Administration and Resources 

Management

12/31/13 $54 $54

8 13 Issue guidance to grant specialists, and remind 

them that during transaction testing they are 

required to:

a. Trace costs to source documents, including a 

review of certified effort reports.

b. Make a determination as to whether costs are 

related to the activities funded by the grant. 

Where grant specialists cannot determine 

allocability, they should work with the project 

officer to verify costs associated with the 

grant.

C Assistant Administrator for 

Administration and Resources 

Management

08/12/13

9 17 Require that during annual baseline monitoring, 

project officers verify that grant recipients fully 

understand research misconduct reporting 

requirements,

O Assistant Administrator for 

Research and Development

12/31/13

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

C = Recommendation is closed with all agreed-to actions completed.

U = Recommendation is unresolved with resolution efforts in progress.
13-P-0361 20

Appendix A

STAR Grants Reviewed by the EPA OIG

Grant 

number Project title

Grant 

period

EPA 

funding

Grant 

randomly

selected

Principal 

investigators 

interviewed

Scientific 

integrity 

policy 

reviewed

Published 

articles 

reviewed

Drawdown 

support 

reviewed

83337401 Changes in Climate, Pollutant Emissions, 

and United States Air Quality

03/01/07 –

02/28/12

$896,597 X X X X

83329201 Center for Children's Environmental 

Health

11/01/06 -

10/31/13

$3,784,011 X X X X

83389201 Platinum-Containing Nanomaterials: 

Sources, Speciation, and Transformation 

in the Environment

02/01/09 –

01/31/13

$399,406 X

83409301 Natural Organic Matter/C60 Fullerene

Interactions

12/01/08 –

11/30/12

$399,996 X X X X

83428501 Analysis of Co-benefits of GHG 

Abatement

09/01/09 –

08/31/13

$300,000 X X X X

83399002 Novel Markers of Air Pollution Vascular 

Toxicity

11/01/10 –

10/31/12

$432,664 X X X X

83459601 Children's Environmental Health Center 05/07/10 –

05/06/13

$1,091,783 X X X X X

83428201 Effects of Changing Climate on Fires & Air 

Quality

11/01/09-

10/31/13

$599,366 X X X X

83438601 C02 Sequestration Modeling to Protect 

Drinking Water Sources

12/01/09 –

11/30/13

$899,567 X X X X

83337302 Impacts of Global Climate and Emissions 

Changes on U.S. Air Quality Zones

01/04/11 –

04/14/13

$259,778 X X X X

83482401 Comparison of Mice for Allergenicity 

Testing

09/15/10 –

09/14/13

$423,546 X

83435901 Predicting Regional Allergy Hotspots -

Future Climates

09/01/09 –

08/31/13

$898,634 X

Total $10,385,348 10 9 9 7 5

 

 Source: Project officers interviewed, file documents, and annual reports reviewed.
13-P-0361 21

Appendix B

Agency’s Response to Draft Report

July 19, 2013

MEMORANDUM

SUBJECT: Response to the Office of Inspector General Draft Report titled, The EPA Needs 

to Improve STAR Grant Oversight Project No. OA-FY12-0606, Dated June 18, 

2013

FROM: Craig E. Hooks, Assistant Administrator

Office of Administration and Resources Management (OARM)

Lek G. Kadeli, Principal Deputy Assistant Administrator

Office of Research and Development (ORD)

TO: Arthur A. Elkins, Jr., Inspector General 

Office of Inspector General (OIG)

Thank you for the opportunity to respond to the OIG draft report titled, The EPA Needs to 

Improve STAR Grant Oversight. EPA is committed to keeping the Science to Achieve Results 

(STAR) grant program as a highly competitive, rigorously peer-reviewed, well-managed

extramural research grants program. To further the cross-cutting Agency goal of enhancing 

science and research while upholding the integrity of the way in which the Agency utilizes its 

resources, the EPA’s ORD and the OARM will renew our commitment to collaborate closely to 

that end. The STAR grant program helps maximize the Agency’s resources by complementing 

and supplementing the research of our in-house laboratories that otherwise would not benefit 

from the increased interagency collaboration and greater interactions with academic and nonprofit institutions on the forefront of innovative scientific research. 

We appreciate the OIG’s work to assess EPA’s monitoring of STAR grants and proactive efforts 

to ensure that research misconduct is not associated with grant activities. Most notably, your 

team’s efforts to communicate with the Agency on a regular basis about potential findings and 

recommendations have allowed us to take some immediate corrective actions during the course 

of the review. In addition, these communications have provided us an opportunity to clarify 

issues relating to certain findings and recommendations. In short, and as discussed during our 

communications with your team, EPA generally agrees with the OIG’s recommendations 

regarding STAR grants and has provided the corrective actions shown below. 
13-P-0361 22

AGENCY’S RESPONSE TO REPORT RECOMMENDATIONS

No. Recommendation Responsible 

Office

Corrective Action (s) Estimated 

Completion 

Date

1 Require all project officers 

to attend training on how 

to perform baseline 

monitoring. Include a 

discussion concerning 

actions to be taken when 

publications do not include 

required 

acknowledgements

and disclaimers.

ORD ORD will provide training on 

performance of baseline monitoring to 

all STAR grant project officers. In 

addition, we are revising the annual 

report review guidance to include 

information on actions to be taken 

when publications do not include 

required acknowledgements and 

disclaimers.

1

st Quarter FY 

2014

2 Conduct a review of 

baseline monitoring reports 

to ensure they are 

accurately completed.

ORD In January 2013, NCER completed a 

review of official file records of STAR 

grants project officers, which included 

a review of baseline monitoring reports. 

As part of ORD’s FY 2013 Annual 

Assurance Letter, NCER modified its 

2013-2017 Multiyear Review Plan to 

include an annual review of STAR 

grants, including a review of baseline 

monitoring reports. Documentation that 

completes this corrective action has 

been provided to ORD’s Audit Liaison.

Completed

3 Enforce the terms and 

conditions that allow funds 

to be withheld from 

incrementally funded 

grants, if reports are 

missing or late.

ORD ORD has drafted Standard Operating 

Procedures (SOP), which will be 

finalized with assistance from OARM, 

to address steps to be taken when 

annual progress reports for STAR 

grants are not received in a timely 

manner. The SOP includes information 

on when to pursue withholding funds 

from incrementally funded grants due 

to failure to comply with this term and 

condition.

4

th Quarter FY 

2013
13-P-0361 23

No. Recommendation Responsible 

Office

Corrective Action (s) Estimated 

Completion 

Date

4 Amend terms and 

conditions so that all 

awards are subject to a 

condition that payments 

will be withheld when 

reports are missing or late.

ORD ORD is revising the terms and 

conditions for its STAR grant program 

to including a condition that payments 

may be withheld when reports are 

missing or late. The revised terms and 

conditions will apply to all new STAR 

grants.

4

th Quarter FY 

2013

5 Require the grant recipient 

to submit corrections to 

publications when project 

officers identify missing 

acknowledgements and 

disclaimers.

Require immediate 

correction for online 

articles and at the next 

publication date for printed 

articles.

ORD ORD is revising its SOP for STAR 

grants annual progress report review to 

include a requirement that grant 

recipients ensure their publications 

have appropriate EPA 

acknowledgements and disclaimers. If 

acknowledgements and disclaimers are 

identified as missing, the principal 

investigator will be instructed to submit 

corrections to the publications 

requesting corrections.

4

th Quarter FY 

2013

6 Require grant recipients to 

submit corrections to 

publications for the articles 

that the EPA OIG 

identified as missing 

acknowledgments and 

disclaimers.

ORD ORD has received copies of three 

correction requests made of the journal 

editors and determined the fourth 

publication was submitted in error. 

That publication has been removed 

from the grants publication list. 

Documentation that completes this 

corrective action has been provided to 

ORD’s Audit Liaison.

Completed

7 Follow up on unallowable 

costs identified in the 

finding. If grant recipients 

cannot provide 

documentation, require 

repayment of the funds.

OARM OARM will follow up on unallowable 

costs and require repayment of costs as 

appropriate.

1

st Quarter of 

FY 2014.
13-P-0361 24

No. Recommendation Responsible 

Office

Corrective Action (s) Estimated 

Completion 

Date

8 Issue guidance to grant 

specialists, and remind 

them that during 

transaction testing they are 

required to:

a. Trace costs to source 

documents, including a 

review of certified effort 

reports.

b. Make a determination 

as to whether costs are 

related to the activities 

funded by the grant. Where 

grant specialists cannot 

determine allocability, they 

should work with the 

project officer to verify 

costs associated with the 

grant.

OARM a. OARM has guidance that relates to 

this finding which can be found on the 

OARM/OGD G share at 

G:\GIAMD\Advanced Monitoring 

Guidance. For example, the Standard 

Operating Procedures for Grants 

Management Office Desk and Onsite 

Reviews, Section III, Attachment 1 C 

(e), covers the review of supporting 

documentation related to payroll and 

other costs. OARM will remind grant 

specialists to follow the provisions in 

the guidance on tracing grant costs to 

source documentation. 

b. OARM guidance related to this issue 

can be found in the Standard Operating 

Procedures for Grants Management 

Office Desk and Onsite Reviews, 

Section III, Attachment 6. OARM will 

remind grant specialists that during 

transaction testing they are required to 

determine whether costs are related to 

grant funded activities and if there are 

allocability questions, to work with the 

project officer to verify costs.

4

th Quarter FY 

2013

9 Require that during annual 

baseline monitoring, 

project officers verify that 

grant recipients fully 

understand research 

misconduct reporting 

requirements.

ORD NCER will modify the term and 

condition for annual progress reports to 

include an assertion of compliance with 

the research misconduct term and 

condition.

4

th Quarter FY 

2013

Should you or your staff have any questions related to EPA’s Office of Research and 

Development’s responsibilities for recommendations 1-6 and 9, please contact Deborah 

Heckman at (202) 564-7274. For questions related to EPA’s Office of Administration and 

Resources Management responsibilities for recommendations 7 and 8, please contact Jennifer 

Hublar at (202) 564-5294.

cc: Ramona Trovato

Bob Kavlock

Nanci Gelb
13-P-0361 25

Howard Corcoran

Jim Johnson

Bruce Binder

Darrell Winner
13-P-0361 26

Appendix C

Distribution

Office of the Administrator 

Principal Deputy Assistant Administrator, Office of Research and Development

Assistant Administrator, Office of Administration and Resources Management

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator 

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations

Associate Administrator for External Affairs and Environmental Education 

Principal Deputy Assistant Administrator, Office of Administration and Resources Management

Director, Grants and Interagency Agreements Management Division,

 Office of Administration and Resources Management

Director, Office of Policy and Resource Management, 

 Office of Administration and Resources Management

Deputy Director, Office of Policy and Resource Management, 

 Office of Administration and Resources Management

Audit Follow-Up Coordinator, Office of Research and Development

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

Audit Follow-Up Coordinator, Office of Policy and Resource Management, 

 Office of Administration and Resources Management