U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Improved Contract 

Administration Needed for 

the Customer Technology 

Solutions Contract 

Report No. 13-P-0398 September 16, 2013 

Scan this mobile 

code to learn more 

about the EPA OIG. 
 

 

Report Contributors:	 Michael D. Davis 

 Teren Crawford 

 Nancy Dao 

 Kevin Haas 

 Debra Coffel 

Abbreviations 

CO Contracting Officer 

COTR Contracting Officer Technical Representative 

CPARS Contractor Performance Assessment Reporting System 

CSIRC Computer Security Incident Response Capability 

CTS Customer Technology Solutions 

EPA U.S. Environmental Protection Agency 

EPAAR Environmental Protection Agency Acquisition Regulations 

FAR Federal Acquisition Regulations 

ISO Information Security Officer 

NIH-CPS National Institutes of Health’s Contractor Performance System 

OAM Office of Acquisition Management 

OARM Office of Administration and Resources Management 

OIG Office of Inspector General 

OMB Office of Management and Budget 

OTOP Office of Technology Operations and Planning 

PO Project Officer 

PPIRS Past Performance Information Retrieval System 

QAM Quality Assurance Manager 

QASP Quality Assurance Surveillance Plan 

SP Service Provider 

SRI Service Request Interface 

WCF Working Capital Fund 

Hotline 

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

email: OIG_Hotline@epa.gov write: EPA Inspector General Hotline 

phone: 

fax: 

1-888-546-8740 

202-566-2599 

1200 Pennsylvania Avenue, NW 

Mail code 2431T 

online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460 
 

U.S. Environmental Protection Agency 13-P-0398 

September 16, 2013 Office of Inspector General 

At a Glance 

Why We Did This Review 

The U.S. Environmental Protection 

Agency Office of Inspector 

General conducted this audit to 

determine whether the EPA 

implemented effective contract 

administration for its Working 

Capital Fund contract EPW08034. 

The Office of Administration and 

Resources Management’s Office 

of Acquisition Management and 

the Office of Environmental 

Information’s Office of Technology 

Operations and Planning perform 

contract administration activities 

with contracting officers, project 

officers and quality assurance 

managers for the Customer 

Technology Solutions contract 

EPW08034. Contract 

administration involves those 

activities performed by 

government officials after a 

contract has been awarded to 

determine how well the 

government and the contractor 

performed to meet the contract 

requirements. Contract 

administration assists the 

government in assuring it receives 

the goods and services for which it 

paid. 

This report addresses the 

following EPA theme: 

	 Embracing EPA as a high 

performing organization.
 

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/ 

20130916-13-P-0398.pdf 

Improved Contract Administration Needed for the 

Customer Technology Solutions Contract 

What We Found 

Based on our review of the WCF contract EPW08034, which ended 

September 2012, the EPA needs to improve its contract administration to 

assist in managing other similar type contracts. The EPA did not, as stated by 

Office of Management and Budget, Federal Acquisition Regulations and 

agency guidelines: 

 Use performance standards to measure cost outcomes. 

 Complete any of the required contractor performance evaluation reports. 

 Maintain required contract administration documents. 

The EPA did not have policies in place that would require performance metrics 

and standards to be linked to cost outcomes and procedures to ensure 

contract administrators maintain sufficient documents in the official contract 

files. The EPA did not complete contractor performance reports because of 

insufficient guidance and inadequate communications during contractor 

performance system changes and personnel reassignments. The EPA’s 

contractor performance systems include the National Institutes of Health’s 

Contractor Performance System and subsequently the Contractor 

Performance Assessment Reporting System, which transmits information into 

the Past Performance Information Retrieval System. The EPA’s ineffective 

contract administration may have hindered the ability of EPA staff to ensure 

that the contractor successfully met agency needs, as well as its ability to 

determine whether the EPA achieved the best value for the $85 million 

expended on the WCF contract. 

 Recommendations and Planned Agency Corrective Actions 

We recommend that the OARM assistant administrator update its policies and 

procedures to ensure that contract performance metrics and standards link to 

cost outcomes. We also made recommendations involving updating internal 

programs to provide oversight and accountability for linking metrics to cost 

outcomes and the review and submission of contractor performance 

evaluation reports for the contract reviewed. Further, we recommend that 

OARM develop contract administration procedures related to the transfer of 

documents when reassigning contract administrative staff. 

OARM concurred with four of the six recommendations and did not concur 

with recommendations 1 and 2. The OARM’s corrective actions for 

recommendations 3 through 6 do not contain milestones nor completely 

address the recommendations and are unresolved.

 Noteworthy Achievements 

The Office of Acquisition Management implemented the Balanced Scorecard 

program in fiscal year 2011 for the EPA Acquisition Systems to provide the 

necessary checks and balances to ensure procurement documents are of the 

highest quality and comply with applicable laws, regulations and policies. 
 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

September 16, 2013 

MEMORANDUM 

SUBJECT:	 Improved Contract Administration Needed for the 

Customer Technology Solutions Contract 

Report No. 13-P-0398 

FROM:	 Arthur A. Elkins Jr. 

TO:	 Craig E. Hooks, Assistant Administrator 

 Office of Administration and Resources Management 

Renee P. Wynn, Acting Assistant Administrator and Chief Information Officer 

 Office of Environmental Information 

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. This report represents the opinion of the 

OIG and does not necessarily represent the final EPA position. 

Action Required 

The agency agreed with four of the six recommendations in this report. However, all six 

recommendations are considered unresolved pending our receipt of EPA’s corrective action plan and 

estimated completion dates that correspond with the specific recommended actions. Therefore, for all 

recommendations, you are required to provide a corrective action plan with planned completion dates within 

60 days of report issuance. 

We will post this report to our website 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 Mike Davis, director for Efficiency Audits, at (513) 487-2363 or davis.michaeld@epa.gov. 
 

 

 

 

 

 

 

 

 

 

 

Improved Contract Administration Needed for the 13-P-0398 

Customer Technology Solutions Contract 

Table of Contents 

Chapters 

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

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

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

 Noteworthy Achievements ........................................................................... 3 

 Scope and Methodology .............................................................................. 4 

2 Ineffective Administration of Contractor Performance .................................. 6 

OMB, FAR and EPAAR Provide Guidance for Managing Contractors ........ 6 

Performance Metrics and Standards Not Linked to Cost Outcomes ........... 7 

Contractor Performance Evaluation Reports Not Completed ...................... 9 

Conclusion................................................................................................... 11 

 Recommendations ..................................................................................... 11 

Agency Comments and OIG Evaluation ...................................................... 12 

3 Inadequate Contract Records Management .................................................... 13 

Federal and Agency Guidance on Records Management ........................... 13 

Agency Official Contract Files Missing Required Documents ..................... 14 

Conclusion................................................................................................... 16 

 Recommendations ..................................................................................... 16 

Agency Comments and OIG Evaluation ...................................................... 16 

Status of Recommendations and Potential Monetary Benefits.............................. 17
 

Appendices 

A Contract Performance Requirements Summary ............................................. 18 

B PO, CO and QAM Reassignments on CTS Contract ....................................... 22 

C Relevant Recordkeeping Criteria...................................................................... 23 

D Agency Comments on Draft Report ................................................................. 25
 

E Distribution ......................................................................................................... 32 
 

 

 

Chapter 1

Introduction 

Purpose 

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

conducted this audit to determine whether the EPA implemented effective 

contract administration for its Working Capital Fund contract EPW08034. 

Even though the contract ended on September 30, 2012, the EPA awarded 

subsequent contracts for the same services. In addition, the EPA can apply 

lessons learned from this audit to improve its contract administration that will 

assist in managing other similar types of contracts (see chapters 2 and 3). 

Background 

Contract administration involves government activities performed after an agency 

awards a contract to determine whether the contractor met contract requirements. 

Contract administration activities include controlling costs, monitoring, 

measuring and reporting contractor performance, and maintaining records in the 

official contract files. Contract administration constitutes that primary part of the 

procurement process that assures the government gets what it pays for. 

The WCF is a revolving fund authorized by law to finance a cycle of operations in 

which federal agencies can charge the costs for goods or services provided to its 

customers. WCF customers include the EPA’s program offices and regions. The 

role of the WCF is to provide a centralized source of administrative and support 

services for the EPA. The WCF strives to reduce the costs of services in the 

agency through improved efficiencies gained by achieving economies of scale, 

greater consumer bargaining power, and reduction in overhead. 

The Office of Administration and Resources Management’s Office of Acquisition 

Management and the Office of Environmental Information’s Office of 

Technology Operations and Planning provide contract administration on the WCF 

contract EPW08034. OTOP personnel manage the work performed under the 

contract, which is with Customer Technology Solutions. CTS, a WCF data 

processing service, provides and coordinates all information technology end-user 

support and services for the EPA’s headquarters and field offices. Critical 

participants in the contract administration of the WCF contract include: 

 OAM’s contracting officers, who have overall responsibility for the contract. 

 OTOP’s project officers, quality assurance managers and quality assurance 

evaluators, who monitor contractor performance and customer satisfaction. 

13-P-0398 1 
 

 

 

Even though the Office of the Chief Financial Officer manages the WCF, 

including reviews and processing of invoices, OAM and OTOP provide contract 

administration functions. 

In April 2008, the EPA awarded an indefinite delivery/indefinite quantity hybrid 

contract. This hybrid contract also contained provisions for performance-based 

award fees and fixed hourly rates and material costs for a time and materials 

contract. This contract required the contractor to provide technology services to 

approximately 12,000 program office users scattered throughout 16 states and the 

District of Columbia. The total potential value of the contract was over 

$200 million and covered the contract base period of June 1, 2008, to 

September 30, 2012, and an option period available through December 31, 2016. 

The EPA decided not to exercise the option period because the contractor had not 

met the required performance metrics. Figure 1 summarizes the WCF’s top five 

data processing service contracts obligated as of May 2012. 

Figure 1: Top Five WCF obligations as of May 20121 

Source: OIG analysis of EPA data. 

The agency identified approximately $72 million of funds obligated for the CTS 

contract EPW08034 as of May 2012. By October 2012, the EPA’s Compass 

Financial2

 system reported that the agency’s expenditures for this CTS contract 

increased to approximately $85 million. 

1

 OTOP’s WCF coordinator provided this information on May 11, 2012, in the form of an email. 

2

 Compass is the EPA’s official financial database. 

13-P-0398 2 
 

 

 

The Federal Acquisition Regulation, Subsection 37.601(b), requires that: 

Performance-based contracts for services shall include--(1) A 

performance work statement (PWS); (2) Measurable performance 

standards (i.e., in terms of quality, timeliness and quantity, etc.) and 

the method of assessing contractor performance against performance 

standards; and (3) Performance incentives where appropriate. 

The FAR Subsection 37.603(a) requires that performance standards establish the 

performance level required by the government to meet the contract requirements. 

In addition, this same FAR Subsection requires the performance standards to be 

measurable and structured to permit an assessment of the contractor’s 

performance. The EPA Contracts Management Manual [CMM], Section 11.1.5.7, 

“Developing a Performance Based Service Contract Quality Assurance 

Surveillance Plan,” states that a: 

The quality assurance surveillance plan (QASP) defines what the 

Government must do to ensure that the contractor has performed 

in accordance with the PWS performance standards. 

The QASP objective is to assess the ability of the contractor to achieve the 

defined performance standards and fulfill contractual obligations. According to 

the CTS contract, the EPA defined the performance standards in the contract’s 

Technical Exhibit under the title “Performance Requirement Summary.” 

This CTS performance-based contract has a performance work statement, 

measurable performance standards, performance incentives and a QASP. The 

Performance Requirement Summary identified 44 performance metrics and 

standards. According to the QAM, the EPA used no other performance metric or 

standard to measure contractor performance. In addition, the EPA performed 

weekly and monthly evaluations based on the 44 performance metrics to monitor 

contractor performance per the FAR. According to the contract’s award fee plan, 

the EPA also used the 44 performance metrics and standards to determine whether 

the EPA would provide an award fee to the contractor. The 44 performance 

metrics identified categories that relate to quality and technical performance 

(a degree of excellence), timeliness and scheduling (meeting milestones), and 

business relations (customer satisfaction). Details are in appendix A. 

Noteworthy Achievements 

OAM implemented the Balanced Scorecard Program in fiscal year 2011 for the 

EPA Acquisition Systems. The internal control program works in conjunction 

with the Balanced Scorecard Program to provide the necessary checks and 

balances to ensure that procurement documents are of the highest quality and in 

compliance with applicable laws, regulations and policies. The Balanced 

Scorecard Program also seeks to include measures of quality, cost, timeliness, 

customer service and employee alignment with skills, to provide an in-depth, 

13-P-0398 3 
 

 

predictive performance management system. Even though the EPA implemented 

specific measures in the Balance Scorecard Program to ensure that past 

performance information is timely and included in the Contractor Performance 

Assessment Reporting System, the specific measures did not start until the end of 

fiscal year 2012. 

Scope and Methodology 

We conducted this performance audit in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions. We believe that the evidence obtained provides 

a reasonable basis for our findings and conclusions based on our audit objectives. 

We conducted the audit from May 2012 to June 2013 at OTOP, OAM and the 

Office of the Chief Financial Officer’s Research Triangle Park Finance Center. 

During the audit, we obtained the top five WCF data processing service contracts 

and reviewed the contract with the highest reported obligated amount to 

determine whether the EPA was effectively managing WCF contracts. We limited 

our review to auditing the EPA’s contract administration for the CTS EPW08034 

contract because it accounted for approximately $72 million (60 percent) of the 

approximately $120 million in the EPA WCF contracts (see figure 1). 

We reviewed memoranda, regulations, guides and other documents to gain an 

understanding of the requirements and processes used to provide effective 

contract administration. The specific documents reviewed included: 

 Office of Management and Budget memoranda. 

 Office of Federal Procurement Policy Memoranda, and Guides. 

 FAR Parts 1, 4, 16, 32, 37, 42 and 46. 

 Environmental Protection Agency Acquisition Regulations Sections 

1509.170 and 1542.15 

 The EPA CMM. 

Appendix C includes relevant recordkeeping criteria. 

We looked at OMB, FAR, agency polices and guidance for contract and contract 

administration requirements. We discussed with OAM, OTOP and Research Triangle 

Park Finance Center staff their procedures used to manage contractor performance, 

invoices, monthly progress reports and other needed contract administration 

functions used for effective internal controls. We also discussed other background 

information that pertains to WCF procedures and associated key players. The WCF 

background information obtained involved the systems used, documents managed 

and other WCF funding procedures used. Other WCF key players included OTOP’s 

Director of Customer Business Support Staff, who oversees WCF workload, 

collections, billings and reports. The director also interacts with WCF customers who 

13-P-0398 4 
 

 

 

provide feedback on service quality. We reviewed contract invoices, checklists, 

monthly progress reports, QASPs, prior audit reports, award fee determination 

reports, as well as other supporting documentation, to determine whether the EPA 

conducted effective contract administration. 

Prior Agency OIG Reports 

The EPA OIG issued the following reports with findings related to CTS contract 

administration: 

Report No. 10-P-0194, EPA Needs to Improve Management Practices to 

Ensure a Successful Customer Technology Solutions Project, August 23, 2010. 

The agency’s lack of acquisition planning led to questions involving: 

 The quality of the helpdesk supporting the project. 

 A quality management program that was not finalized. 

 Key business processes to support ongoing operations not being defined. 

 Vacant leadership positions needed to facilitate communication and 

coordination with customers about CTS equipment deployments. 

We did not follow up on the contractor providing helpdesk support on the project 

because the EPA cancelled the contract. We did follow up on areas that affected 

contract administration. We found the following: 

 The EPA finalized the QASP. 

 The EPA ensured the contractor defined key business process documents. 

 The EPA filled vacant leadership positions. 

Report No. 11-P-0705, EPA Contract Oversight and Controls Over Personal 

Computers Need Improvement, September 26, 2011. The EPA paid the CTS 

contractor a total of $489,734 over an 11-month period for 3,343 seats. A standard 

seat includes a leased computer with accessories and technical support, which was 

not ordered by the agency during the aforementioned period. We recommended that 

the EPA should improve controls for updating data in the fixed assets database, and 

should retain property acquisition documentation in accordance with retention 

requirements. In addition, we recommended that the agency should have a 

separation of duties in its property staff positions and consider assigning permanent 

property positions. We did not follow up on this condition because the EPA 

decided not to exercise the contract option award terms because the contractor had 

not met the required performance metrics. However, during this review, we found 

similar internal control issues in terms of updating databases, including: 

 Retaining appropriate documentation. 

 Maintaining permanent contract positions (see the following chapters).
 

13-P-0398 5 
 

 

 

Chapter 2

Ineffective Administration of Contractor Performance 

OAM did not effectively evaluate cost outcomes and report any of the four 

required annual contractor performance evaluation reports in the Past 

Performance Information Retrieval System between September 2009 and 

March 2013. OMB and FAR require agencies to assess cost outcomes, while the 

FAR and EPAAR require agencies to report on contractor performance 

information in the PPIRS. Deficiencies occurred because of insufficient guidance 

and inadequate communications during contractor performance system changes 

and personnel reassignments. Consequently, the EPA did not effectively monitor 

costs to ensure that the contract, with expenses at approximately $85 million, 

achieved the best possible cost outcomes and value. In addition, the EPA did not 

provide other federal acquisition community users with contractor past 

performance data so that other federal government agencies can make effective 

management decisions on whether to conduct business with the same contractor. 

OMB, FAR and EPAAR Provide Guidance for Managing Contractors 

OMB and the FAR established requirements for evaluating contractor 

performance for cost outcomes. OMB policies state that evaluation factors be 

directly linked to cost performance results.3 Another OMB policy4 addresses the 

evaluating of cost controls based on the contractor’s: 

 Ability to perform within or below budget.
 

 Use of cost efficiencies. 

 Relationship of negotiated costs to actual costs. 

 Submission of reasonably priced change proposals. 

 Providing current, accurate and complete billing in a timely manner. 

This policy addressed the assessing of the contractor’s effectiveness in 

forecasting, managing and controlling contract cost. This policy also stated cost 

controls are needed for fixed price contracts. The FAR5

 requires that, for incentive 

fee type and time and materials contracts, evaluating factors be linked to cost 

performance results and cost controls, respectively. 

The FAR and EPAAR regulations establish requirements for reporting contractor 

performance information. Specifically, the FAR6

 requires that agencies prepare an 

annual evaluation of contractor performance that closely parallels the award fee 

3

 OMB memorandum Appropriate Use of Incentive Contracts, December 4, 2007; and OMB memorandum, 

Improving Government Acquisition, dated July 29, 2009, 4

 OMB policy Best Practices for Collecting and Using Current and Past Performance Information, May 2000. 5

 FAR Subsections 16.401(e)(2), 16.402-1(a) and 16.601(c)(1).
 6 FAR Subpart 42.1500, Subsections 42.1503(b), and 42.1503(c).
 

13-P-0398 6 
 

 

 

determinations and submit past performance information electronically to the 

PPIRS in accordance with agency procedures. The agency’s acquisition 

regulations7

 require the agency to use the National Institutes of Health’s 

Contractor Performance System, subsequently replaced by CPARS, to record 

contractor performance information. The systems collect and transmit information 

into the PPIRS. 

Performance Metrics and Standards Not Linked to Cost Outcomes 

The EPA’s 44 performance metrics and standards identified in the Performance 

Requirements Summary for the EPW08034 CTS contract did not include cost 

outcomes as required by the FAR and addressed in OMB guidance. The EPA used 

the 44 performance metrics and standards to evaluate contractor performance on 

the CTS contract and determine whether the contractor would receive an award 

fee. The QASP identifies the procedures used by the QAM and quality assurance 

evaluator to review contractor performance based on the Performance 

Requirement Summary and its 44 performance metrics and standards. The QAM 

assembled biannual reports that identified and rated each of the 44 performance 

metrics and standards used to determine whether the contractor would be granted 

an award fee. Appendix A identifies the 44 metrics and standards that relate to 

quality, schedule and customer satisfaction outcomes. The EPA did not include 

any metrics and standards relating to cost outcomes as required by the FAR. The 

44 performance metrics and standards did not include the OMB-identified 

definitions for cost controls that cover: 

 The contractor’s ability to perform within or under budget. 

 Use of cost efficiencies. 

 Relationship of negotiated costs to actual costs. 

 Submission of reasonably priced change proposals. 

 The contractor providing current, accurate and complete billing in a 

timely manner. 

Also, the CTS contract performance work statement identified a requirement for 

the contractor to analyze potential cost savings from new technologies and 

business process changes. FAR Subsection 37.602(b) (3) requires agencies to 

“rely on the use of measurable performance standards and financial incentives in a 

competitive environment to encourage competitors to develop and institute 

innovative and cost-effective methods of performing the work.” The EPA did not 

use the 44 performance metrics and standards or incentives to encourage 

competitors to develop and institute innovative and cost-effective methods of 

performing the work per FAR requirements. 

As part of the EPA Balanced Scorecard Program approach, OAM identified 

measures for cost control in contractor performance evaluations as principles 

7

 EPAAR Subpart 1542.1503(a) (CPARS), which replaced 1509.170-3(c) and 5(c) (NIH-CPS). 

13-P-0398 7 
 

 

 

needed to improve its acquisition process. However, the EPAAR and CMM did 

not require that for incentive fee and time and material type contracts the 

performance evaluation factors include cost outcomes. In accordance with the 

December 2007 OMB memorandum, chief acquisition officers and senior 

procurement executives review agency’s acquisition policies to ensure that incentive 

fees are linked to acquisition outcomes such as cost, schedule, and performance 

results. Current EPA policy does not address this requirement. Even though this 

contract has ended, having this requirement will ensure that existing and future 

contracts will contain the required cost outcome metrics and standards. 

By not linking the award fee to cost outcomes as required, the EPA did not 

effectively hold the contractor accountable for cost inefficiencies and 

inaccuracies. We found examples where the contractor billed for services that 

were not rendered. For example, Table 1 identifies examples of 13 invoices 

totaling nearly $1 million that the agency suspended for inaccurate billings. 

Suspended contractor invoice payments due to inaccurate billings indicate 

potential problems exist with contract cost. 

Table 1: Invoices suspended 

Suspended 

Invoice amounts Bill date Reason for suspension 

1 $2,734.41 07/20/10	 Units not deployed. Invoice is inaccurate 

(data does not support the billable amount 

for the time period). 

2 3,125.04 

3 117,775.00 08/13/09 Dispute over number of printers installed. 

4 4,330.57 08/21/09 Fifteen student/intern seats deployed on a 

Saturday. User cannot accept deployment on 

Saturday. Need to count these seats next 

month. 

10/26/10 Units not deployed. 

5 281,050.00 10/13/09 Dispute over printers installed. 

6 391,650.00 11/20/09 Dispute over printers installed. 

7 3,767.62 08/12/10 Units not deployed. 

8 53,082.25 02/27/12 Work not completed 

9 15,961.82 11/13/12 Typo error on prior payment. 

10 This invoice indicates a double billing for the 29,784.47 05/21/12 same service. 

11 9,674.35 08/12/10 Units not deployed. 

12 130.21 10/22/10 Units not deployed. 

13 27,433.72 07/06/12 Questioned billing method of rounding. 

Total $940,499.46 

Source: OIG data analysis. 

In addition, since FAR requires cost outcomes from past contractor performance 

be inputted into PPIRS, the EPA should have evaluated the cost outcome based on 

contractor performance standards. As a result, the EPA cannot sufficiently inform 

other federal agencies about the contractor’s cost performance. 

Even though the agency did not award the contractor an award fee, there could 

have been additional corrective actions implemented by having cost outcomes tied 

13-P-0398 8 
 

 

 

 

 

 

to contractor performance standards. This would have provided additional 

enforcement measures to prevent recurring or escalating problems. According to 

the QASP, the QAM has the responsibility to monitor the contractor’s 

performance to control cost and take corrective actions. The performance work 

statement requires the contractor to look for cost savings through enhanced 

technology. The EPA did not tie the requirement to performance standards so the 

EPA did not use this requirement for determining an award fee. Including cost 

outcomes could have driven the overall ratings up if the contractor identified 

savings and could have driven the overall ratings further down if the contractor 

did not identify savings. Such actions would facilitate a determination as to 

whether the contractor is performing to meet the overall contract needs and 

providing the most value for the government. 

Contractor Performance Evaluation Reports Not Completed 

The EPA did not complete the four required annual contractor past performance 

evaluation reports. The EPA completes contractor past performance evaluations 

when an agency official enters the finalized reports in CPARS. Prior OIG reports 

identified similar issues where the EPA did not complete the evaluations or report 

past performance information into required systems in a timely fashion.8 Both the 

FAR and EPAAR require the agency to conduct and report the evaluations in the 

past performance system after the end of each 12-month contractor performance 

period. The initial EPAAR Subpart 1509.170, dated 2002, required the EPA to 

use the NIH-CPS to report past performance information within 90 business days 

from the date the contracting officer initiates the evaluation. As of September 

2010, the new EPAAR Subsection 1542.1502 replaced Subpart 1509.170, and 

requires the use of the Department of Defense’s CPARS [see prior Footnote 7]. 

CPARS requires reporting of past performance information within 120 days. 

Table 2 identifies the specific contractor past performance data not timely entered 

into the system. 

Table 2: Timeliness of Contractor Performance Evaluations for EPW08034 

Evaluation period 

Reporting 

system * 

Evaluation 

Date due 

Interim/final 

evaluations 

# Calendar Days 

Past Evaluation 

Due Date 

(04/01/2013=OIG 

cut-off date) 

10/01/08–09/30/09 NIH-CPS 02/11/10 (1) Not prepared 1145 

10/01/09–09/30/10 CPARS 02/11/11 (1) Not prepared 780 

10/01/10–09/30/11 CPARS 02/10/12 (1) Not prepared 416 

10/01/11–09/30/12 CPARS 01/28/13 (2) Not prepared 63 

*Past performance information in NIH-CPS/CPARS is automatically transmitted to the PPIRS. 

(1) 95 business days allowed for years 1-3's evaluation process. (2) 120 calendar days allowed for 

evaluation process for year 4 per new EPAAR Subsection 1542.1502. 

8 Report No. 10-R-0113, EPA Should Improve Its Contractor Performance Evaluation Process for Contractors 

Receiving Recovery Act Funds, issued April 26, 2010; and Report No. 12-P-0417, Weaknesses in EPA’s 

Management of the Radiation Network System Demand Attention, issued April 19, 2012. 

13-P-0398 9 
 

 

 

 

Source: OIG analysis of contractor performance evaluations as of 04/01/2013. 

The 44 performance metrics and standards (see appendix A) identify the 

performance categories quality, timeliness and business relations. Quality 

assurance evaluators review contractor performance based on the metrics and 

standards and submit semiannual reports that contain needed information to input 

into the CPS or CPARS, but the EPA did not use such information to complete 

contractor past performance evaluation reports in the systems. 

The EPA did not have the contractor performance information in PPIRS because 

of inadequate communication during the NIH-CPS and CPARS transitions and 

personnel reassignments. NIH-CPS and CPARS are the official systems used by 

the agency to download past performance information into PPIRS. Even though 

the FAR required contractor performance information to be entered into PPIRS, 

the EPA did not provide clear guidance to enforce the reporting of contractor 

information for existing contracts. The OAM intranet website stated that the 

CPARS would be used for new solicitations issued on October 3, 2011, or later. 

In addition, OAM’s Intranet also emphasized EPAAR changes for new 

solicitations but did not require the EPA to input contractor performance 

information into CPARS for existing contracts. The Interim Policy Notice 10-03 

issued by OAM in March 2010 also emphasizes that solicitations issued, contracts 

awarded and options exercised after May 14, 2010, are to follow the EPAAR 

deviations to report contractor performance information in CPARS. The EPAAR 

deviations did not require existing contracts to report contractor performance 

information. Since the CTS contract, awarded in 2008, was an active contract at 

the time and EPA did not provide clear guidance on existing contracts, the EPA 

did not report on four contractor performance evaluation periods (see table 2 

above). 

In addition, when the EPA’s OAM and OTOP reassigned staff, these offices did 

not communicate adequate procedures to ensure reporting of contractor 

performance information. The initial QAM stated she asked the CO about putting 

information into NIH-CPS, but the CO said that, since the EPA changed systems, 

they should do nothing. One PO, assigned to the contract for a few months, did 

not fully understand the CPARS assessment process and did not have access to 

the CPARS. One CO stated that she transitioned out before the end of the 12-

month evaluation period. Another CO said she requested the PO to assess the 

contractor performance but received no response from the PO. With many 

personnel reassignments (see appendix B), the EPA has no effective procedure to 

communicate what CPARS evaluations have or have not been done. The 

Department of Defense CPARS policy guide9

 states an interim evaluation in 

CPARS is required upon a significant change within the agency provided 6 

months of performance has occurred. The changes include change in program or 

9

 The PPIRS website, www.ppirs.gov, and OMB memorandum, Improving Contractor Past Performance 

Assessments: Summary of the Office of Federal Procurement Policy’s Review, and Strategies for Improvement, 

dated January 2011, acknowledges the DOD policy as guidance for federal agencies on contractor performance 

information. The DOD policy was subsequently revised in June. 

13-P-0398 10 
 

 

project management responsibility and transfer of a contract to a different 

contracting activity. It also states that an interim evaluation in CPARS shall be 

started prior to transfer of assessing official duties from one individual to another, 

to ensure continuity. 

If COs did not report the contractor performance information in the past 

performance systems for all contract performance periods, performance reports 

are not available to inform the EPA and other federal agencies about the 

contractor’s performance. According to the OMB memorandum identified in the 

footnote 9, this information is used in the source selection process to assist other 

agencies in assessing past performance when making future acquisitions. Without 

timely availability of contractor past performance information that includes 

information on contract cost, the EPA and other federal agencies may 

inadvertently award contracts to contractors that have a history of poor 

performance on current or past government contracts. Since the EPA did not 

provide an award fee throughout the entire life of this 4-year performance-based 

contract, there may be concerns with the contractor performance that should be 

reflected and available for consideration by other agency offices and government 

agencies. An OMB memorandum, Clarifying Chief Acquisition Officer Roles and 

Responsibilities, dated October 2012, states that chief acquisition officers “. . . 

should lead efforts to, among other things, improve the value of contractor past 

performance assessments and increase the transparency of contractor business 

integrity data so that the Federal Government only does business with reputable 

firms.” 

Conclusion 

Cost controls and contractor performance information have been the focus of 

OMB memoranda and the Balanced Scorecard Program addressed in chapters 1 

and 2 above. The EPA did not evaluate cost outcomes and report on any required 

contractor performance information as required. Having effective cost controls 

and past contractor performance information for this contract valued at 

approximately $85 million will help the EPA assure that the government gets 

what it paid for. It will also provide transparency so that other federal government 

agencies can make effective management decisions on whether to conduct 

business with the same contractor. 

Recommendations 

We recommend that the assistant administrator, Office of Administration and 

Resources Management: 

1.	 Update the policies to include procedures that would ensure that, for all 

incentive and time and material contracts, contract performance metrics 

and standards include cost outcomes. 

13-P-0398 11 
 

 

2.	 Update internal programs that provide oversight and accountability to 

ensure that, for all incentive type and time and material contracts, the EPA 

performance metrics and standards link to cost outcomes. 

3.	 Require OTOP, in conjunction with OAM, to review contractor 

performance reports generated per the QASP. Require OTOP to 

coordinate all actions taken with the COs and POs and require the COs to 

input contractor performance information into CPARS. 

4.	 Require COs to input interim reports into CPARS prior to their 

reassignments. 

Agency Comments and OIG Evaluations 

OARM did not concur with recommendations 1 and 2, but concurred with 

recommendations 3 and 4. However, recommendations 3 and 4 are unresolved 

pending receipt of corrective actions that correspond with the causes and 

recommendations. 

OARM disagreed with recommendations 1 and 2. OARM stated EPA does not have 

to control cost or manage the contract-based cost incentives for this WCF contract 

because the contract has fixed rates so it is a fixed unit price contract. FAR 

Subsections 16.202-1 and 203-1(b) requirements state that for fixed price contracts, 

the award fee or incentive is based solely on factors other than costs; however, this 

contract’s requirements and data indicated a contract type other than a fixed price 

contract. FAR Subsection 16.201(b) states “time and material contracts and labor 

hour contracts are not fixed price contracts.” The EPA’s Acquisition System and the 

Federal Procurement Data System identified this contract to be a time and materials 

contract. The contract also identified changes to fixed hourly rate and negotiated 

hours throughout the contract 4-year time period and identified fixed rate and other 

elements that is consistent with FAR Subpart 16.6 for time and materials contracts. 

Recommendations 1 and 2 also reflect on the performance standards having cost 

outcomes and the decision to award a fee based on cost outcomes. FAR Subsection 

1.102-2 states that performance standards satisfy the customer in terms of cost, 

quality and timeliness of delivered product or service, so performance standards as 

well as the decision to award a fee should link to cost outcomes. 

OARM stated during the exit conference that issues found and addressed under 

recommendations 3 and 4 relate to inadequate management oversight. Based on the 

causes addressed above, we found no EPA procedures in place to direct the actions 

of inputting interim performance information into CPARS when there are staff 

reassignments. This detailed direction would assist management in providing the 

oversight to ensure the contractor performance information is input into CPARS. In 

addition, this is a recurring issue because prior audits recommended improvements 

to management oversight that the agency agreed to yet the conditions still exist (see 

footnote 8). As a result, we concluded that this further direction is needed. 

13-P-0398 12 
 

 

Chapter 3

Inadequate Contract Records Management 

The official contract files maintained by COs, POs and the QAM were missing 

required official documents. These missing documents were: 

 Thirty-four of 48 monthly progress reports. 

 A post award conference meeting document. 

 Three of four CO annual contract invoice reviews. 

 A financial monitoring review report and the CO’s applicable responses. 

 Initial or finalized QASPs. 

 Six of eight letters sent to the contractor providing its performance ratings. 

FAR Subsection 4.802 and agency policies require that contract files be 

maintained under central control to ensure effective documentation, safeguarding 

and efficient retrieval. These required documents were missing due to ineffective 

oversight of the policies and procedures in place to ensure the easy retrieval of 

official documents during the many staff reassignments. Because the EPA did not 

maintain adequate files on an approximately $85 million contract, the agency 

could not provide assurance that the EPA made informed business decisions to 

ensure contractors met contract requirements and the EPA complied with criteria. 

As a result, the EPA cannot also provide assurance that the government 

effectively got what it paid for. 

Federal and Agency Guidance on Records Management 

FAR Subsection 4.801, General, states documentation in the files shall be 

sufficient for purpose of providing a complete background for informed decisions 

and furnishing essential facts in the event of litigations or congressional inquiries. 

FAR Subsection 4.802, Contract Files, paragraphs (c) and (d), states: 

Files must be maintained at organizational levels that ensure: 

(1) Effective documentation of contract actions; (2) Ready 

accessibility to principal users; (3) Minimal establishment of 

duplicate and working files; (4) The safeguarding of classified 

documents; and (5) Conformance with agency regulations for file 

location and maintenance. If the contract files or file segments are 

decentralized (e.g., by type or function) to various organizational 

elements or to other outside offices, responsibility for their 

maintenance must be assigned. A central control and, if needed, a 

locator system should be established to ensure the ability to locate 

promptly any contract files. 

13-P-0398 13 
 

 

The EPA policies and procedures emphasize the need for creating and managing 

the records necessary to document the agency’s official activities and actions. The 

following agency policies are applicable. 

	 EPA Classification No. CIO 2155, EPA Records Management Policy, 

requires that all agency employees are responsible for creating, managing 

and filing records for safe storage and efficient retrieval. 

	 The EPA Records Management Manual maintains that agency staff must 

capture records by filing, storing or otherwise systematically maintaining 

them in a recordkeeping system to ensure information is accessible to all 

authorized staff, including related records stored on special media or in 

different locations. 

	 EPA Record Series, Schedule 202, NARA Disposition No. N1-412-06-

6/5, calls for COs and contracting officer representatives to work together 

to determine who is responsible for maintaining specific documents to 

minimize duplication while still providing an adequate audit trail (see 

appendix C for more criteria). 

Agency Official Contract Files Missing Required Documents 

OAM COs and OTOP POs had inadequate records management based on FAR, 

EPAAR and the EPA policy. The official contract file and files maintained by 

each CO and PO were missing the following: 

 Thirty-four of 48 monthly progress reports. 

 A post award conference meeting document. 

 Three of four CO annual contract invoice reviews. 

 A financial monitoring review report and the CO’s applicable responses. 

 Initial or finalized QASPs. 

 Six of eight letters sent to the contractor providing its performance ratings. 

In addition, the EPA did not centrally control the documents that did exist, as 

required by the FAR Subsection 4.802(d), as stated above. EPA’s OAM 

procedures did not establish a requirement for a central repository. The EPA’s 

various COs, POs and QAMs individually maintained selected documents. For 

example, the COs did not maintain the finalized QASP in the official contract file. 

The PO maintained the finalized QASP separately in their office computer. Of the 

14 monthly progress reports received, the current CO provided only 11, one PO 

provided two, and another PO provided one. These monthly progress reports 

assist in determining whether the contractor met contract requirements. We asked 

the current CO for contractor performance evaluations, but he could not provide 

any. Two different COs provided six award fee evaluation reports. The evaluation 

reports assist in determining whether EPA complied with FAR and EPAAR 

requirements for measuring contractor performance. 

13-P-0398 14 
 

 

The OIG has noted this problem with the agency’s administration of its contracts 

during multiple audits. The EPA’s OAM Balanced Scorecard Program also 

identified similar issues. Table 3 lists the OIG reports and the OAM document. 

Table 3: Related audit reports 

Report Finding 

EPA OIG 11-P-0705, EPA Contract 

Oversight and Controls Over Personal 

Computers Need Improvement 

We found similar internal control issues in 

terms of updating databases, retaining 

appropriate documentation, and 

maintaining permanent contract positions. 

EPA OIG draft report, Improvements 

Needed in EPA’s Smartcard Program to 

Ensure Consistent Physical Access 

Procedures and Cost Reasonableness 

Staff did not assure adequate data 

maintenance and that incomplete contract 

files resulted from issues within both the 

project management and contract 

management offices. 

OAM Balanced Scorecard An internal audit identified contract 

documentation issues. 

Source: OIG analysis. 

The agency’s inadequate record management persists because OAM and OTOP 

did not have adequate oversight of policies and procedures in place to ensure the 

easy retrieval of official documents during the many staff reassignments (see 

appendix B). OAM and OTOP procedures did not hold responsible personnel 

accountable for adequate records management during CO and PO personnel 

reassignments. The CO and PO did not perform an inventory of required 

documents to ensure the prior CO and PO maintained documentation. In addition, 

OAM and OTOP did not implement procedures to require the transference and 

maintenance of data in a centralized location or key locator system to identify 

where documents are located during CO and PO personnel changes. The FAR 

Subsection 4.802(d) states: “A central control and, if needed, a locator system 

should be established to ensure the ability to locate promptly any contract files.” 

As a result of ineffective records management, files cannot be readily accessible 

to principal users who are required to facilitate and ensure the effective 

accomplishment of contract requirements and contract closeout. An overall 

analysis of all documented monthly progress reports and annual invoice reviews 

would have provided a better indication of the contractor achieving contract 

requirements. In addition, the EPA may be unable to make effective management 

decisions and provide reasonable assurance that the agency complied with 

applicable regulations. If the CO centrally maintained all contractor performance 

evaluations, the CO would have had past performance information readily 

available to ensure compliance with FAR and EPAAR (see chapter 2). 

Consequently, the EPA cannot reasonably make informed decisions based on 

missing documents and ensure the government got what it paid for. 

13-P-0398 15 
 

 

 

Conclusion 

Without complete and organized contract files, the EPA is unable to make 

effective management decisions and provide reasonable assurance that the 

contractor met contract requirements and the EPA complied with applicable 

regulations. Although the contract has ended, the EPA needs to maintain adequate 

records to make effective and informed decisions on contractor past performance 

for contract closeout purposes and in the event of litigation or congressional 

inquiries. Since the agency continues to acquire those same services, records 

would provide needed lessons learned to improve management of the new 

contracts. 

Recommendations 

We recommend that the assistant administrator, Office of Administration and 

Resources Management: 

5.	 Develop OAM procedures to require that, before there are personnel 

reassignments, COs, POs and QAMs perform an inventory of required 

documents in their possession or in the official contract file to ensure 

maintenance of accurate and complete records. 

6.	 Update internal procedures and programs to include a process to transfer 

all required documents to the newly appointed COs and POs or establish a 

key locator system identifying the location of required contracting 

documents. 

Agency Comments and OIG Evaluations 

OARM concurred with recommendations 5 and 6, but the recommendations are 

unresolved pending receipt of corrective actions that correspond with the causes 

and recommendations. 

OARM stated during the exit conference that issues found and addressed under 

recommendations 5 and 6 should relate to a management oversight issue, yet we 

found no EPA procedures in place to direct the actions of record management 

when there are staff reassignments or new appointments. The criteria addressed in 

appendix C does not address the local procedures when there are CO, PO and 

QAM reassignments and new appointments. In addition, this is a recurring issue 

because prior audits recommended improvements in records management that the 

agency agreed to yet the conditions still exist (see table 3 above). As a result, we 

concluded that this further direction is needed. 

13-P-0398 16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

1 

Page 

No.

11 

 Subject 

Update the policies to include procedures that 

would ensure that, for all incentive and time and 

material contracts, contract performance metrics 

and standards include cost outcomes. 

Status1 

U 

Action Official 

Assistant Administrator, 

Office of Administration and 

Resources Management 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

2 

3 

4 

5 

6 

12 

12 

12 

16 

16 

Update internal programs that provide oversight 

and accountability to ensure that, for all incentive 

type and time and material contracts, the EPA 

performance metrics and standards link to cost 

outcomes. 

Require OTOP, in conjunction with OAM, to review 

contractor performance reports generated per the 

QASP. Require OTOP to coordinate all actions 

taken with the COs and POs and require the COs 

to input contractor performance information into 

CPARS. 

Require COs to input interim reports into CPARS 

prior to their reassignments. 

Develop OAM procedures to require that, before 

there are personnel reassignments, COs, POs and 

QAMs perform an inventory of required documents 

in their possession or in the official contract file to 

ensure maintenance of accurate and complete 

records. 

Update internal procedures and programs to 

include a process to transfer all required 

documents to the newly appointed COs and POs or 

establish a key locator system identifying the 

location of required contracting documents. 

U 

U 

U 

U 

U 

Assistant Administrator, 

Office of Administration and 

Resources Management 

Assistant Administrator, 

Office of Administration and 

Resources Management 

Assistant Administrator, 

Office of Administration and 

Resources Management 

Assistant Administrator, 

Office of Administration and 

Resources Management 

Assistant Administrator, 

Office of Administration and 

Resources Management 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is unresolved with resolution efforts in progress 

13-P-0398 17 

1 
 

 

 

 

 

Appendix A 

Contract Performance Requirements Summary 

(Performance Metrics and Standards) 

Applicable 

performance work 

statement 

sections/section # ID Metric 

Performance 

standard Surveillance method 

Frequency of 

surveillance 

1 Percentage of all requests 

responded to and routed within 

90% Monitoring monthly data As needed 

15 minutes of submission to the 

Service Request Interface during 

core hours 

2 Percentage of all requests 99% Monitoring monthly data As needed 

responded to and routed within 

60 minutes of submission to the 

SRI during core hours 

Service request 

interface 

(Section 2.1.1) 

3 Percentage of tickets correctly 

routed or escalated on initial 

attempt 

75% Monitoring monthly data 

and Customer Support 

Representative input 

Monthly 

4 Percentage of tickets correctly 95% (months Monitoring monthly data Monthly 

routed or escalated on second 

attempt 

05-28)

 98% (months 

and Customer Support 

Representative input 

29-100) 

5 Percentage of end-user requests 

(requiring more than 1 business 

98% Monitoring monthly 

sample 

As needed 

day to resolve) receiving daily 

updates 

6 Percentage of assets accurately 98% Planned sample: cross Periodic 

identified in tracking system reference random sample 

of assets with tracking 

system; cross reference 

random sample of 

tracking system with 

assets 

7 Percentage of unaccounted assets 99% Planned sample: audit Periodic 

accurately accounted for and 

recorded in tracking system or 

sampling of missing 

assets records with 

Asset management 

(Section 2.1.2) 

identified as missing within 30 

days of previous surveillance 

check 

information in the 

Remedy system and 

Ebusiness 

8 Percentage of accurate updates 

made in tracking system within 

90% Evaluate moves, adds, 

and changes crossMonthly 

1 business day of change being referenced against date 

made of update made to the 

asset tracking system 

9 Percentage of accurate updates 99% Evaluate moves, adds Monthly 

made in tracking system within 

2 business days of change being 

and changes crossreferenced against date 

made of update made to the 

asset tracking system 

10 Percentage of accounts in 90% Monitoring of monthly Monthly 

compliance with the EPA policy 

and standards 

data provided by Service 

Provider 

Account access 

and management 

(Section 2.1.2.3) 

11 Percentage of accounts 99% 

Monitor monthly Bind 

view reports 

Monitoring of monthly Monthly 

established or routed to proper data provided by Service 

authority within 4 hours Provider 

13-P-0398 18 
 

 

 

 

 

 

 

Applicable 

performance work 

statement 

sections/section # ID Metric 

Performance 

standard Surveillance method 

Frequency of 

surveillance 

12 Percentage of systems that are 

patched and have latest virus 

definition files by CSIRC required 

date 

90% Monthly inspection of 

data 

Monthly 

13 Percentage of systems that are 

patched have latest virus definition 

files within 10 business days of 

CSIRC required date 

99% Monthly inspection of 

data 

Monthly 

14 Percentage of incidents that are 

reported to ISO and contracting 

officer technical representative 

within 4 hours of incident 

90% Random sampling Monthly 

Security 

(Section 2.1.3) 

15 Percentage of incidents that are 

reported to ISO, CSIRC and 

COTR within 2 days of incident 

99% Random sampling Periodic 

16 Percentage of incidents of 

personally identifiable information 

loss that are reported to ISO, 

CSIRC and COTR within 1 hour of 

90% Random sampling Periodic 

incident 

17 Percentage of incidents of 

personally identifiable information 

loss that are reported to ISO, 

CSIRC and COTR within 4 hours 

99% Random sampling Periodic 

of incident 

18 Percentage of contractor staff who 

complete required training on time 

95% Random Monitoring Once a year 

19 Percentage of hardware installs 

scheduled within 4 hours of 

80% Review monthly data 

from SP and validation 

Monthly 

submission of approved request to 

the SRI for standard 

through analysis of data 

from various sources 

desktops/laptops or upon receipt 

of other hardware 

Hardware 

provisioning 

(Section 2.2.1.1) 

20 Percentage of hardware installs 

scheduled within 2 business days 

of submission of approved request 

to the SRI for standard desktops/ 

laptops or upon receipt of other 

hardware 

99% Review monthly data 

from SP and validation 

through analysis of data 

from various sources 

Monthly 

21 Percentage of hardware installed 90% Review monthly data Monthly 

by the scheduled install date and from SP and validation 

time; includes loaner hardware through analysis of data 

from various sources 

22 Percentage of hardware installed 99% Review monthly data Monthly 

within 1 business day of schedule from SP and validation 

date and time; includes loaner through analysis of data 

hardware from various sources 

13-P-0398 19 
 

 

 

 

 

 

 

 

 

 

 

Applicable 

performance work 

statement 

sections/section # ID Metric 

Performance 

standard Surveillance method 

Frequency of 

surveillance 

23 Percentage of software installs 

scheduled within 4 hours of 

80% Review monthly data 

from SP and validation 

Monthly 

submission of approved request to through analysis of data 

the SRI for standard software or from various sources 

upon receipt of other software 

24 Percentage of software installs 

scheduled within 2 business days 

99% Review monthly data 

from SP and validation 

Monthly 

Software 

provisioning 

(Section 2.2.1.2) 25 

of submission of approved request 

to the SRI for standard software or 

upon receipt of other software 

Percentage of software installed 

by the scheduled install date and 

90%

through analysis of data 

from various sources 

 Review monthly data 

from SP and validation 

Monthly 

time through analysis of data 

from various sources 

26 Percentage of software installed 99% Review monthly data Monthly 

within 1 business day of schedule from SP and validation 

date and time through analysis of data 

from various sources 

27 Percentage hardware collected 

and removed from desk within 1 

90% Review monthly data 

from SP and validation 

Monthly 

business day of submission of 

approved request to the SRI 

through analysis of data 

from various sources 

Deprovisioning 

(Section 2.3) 

28 Percentage hardware collected 

and removed from desk within 2 

business days of submission of 

approved request to the SRI 

99% Review monthly data 

from SP and validation 

through analysis of data 

from various sources 

Monthly 

29 Percentage of accounts 

deactivated/disabled on scheduled 

99% Review monthly data 

from SP and validation 

Monthly 

date through analysis of data 

from various sources 

Operations 

(Section 2.4) 

30 

31 

Percentage of systems in 

compliance with the EPA policy 

and standards 

Percentage of network printers 

fully operational 

95%(months 

05-16) 

98%(months 

17-100) 

98% 

Compare sample of 

selected CTS desktop 

configurations to the EPA 

standard configuration to 

ensure compliance 

Sampling of printer data 

Monthly 

Monthly 

32 Percentage of preventative 90% Inspection of reports Periodic 

maintenance schedules met 

33 Percentage of password resets 

completed within 15 minutes after 

90% Sampling monthly data 

from remedy 

Periodic 

notification of request 

34 Percentage of password resets 

completed within 60 minutes after 

99% Sampling monthly data 

from remedy 

Periodic 

notification of request 

User support 

(Section 2.4.3) 

35 Percentage of hardware and 

software issues resolved or 

reprovisioned within 4 hours of 

submission of request for service 

to the SRI 

90% Review monthly data 

from SP and validation 

through analysis of data 

from various sources 

Monthly 

36 Percentage of hardware and 

software issues resolved or 

99% Review monthly data 

from SP and validation 

Monthly 

reprovisioned within 2 business through analysis of data 

days of submission of request for 

service to the SRI 

from various sources 

13-P-0398 20 
 

 

 

 

 

Applicable 

performance work 

statement 

sections/section # ID Metric 

Performance 

standard Surveillance method 

Frequency of 

surveillance 

37 Percentage of moves, changes, 90% Review monthly data Monthly 

and upgrades completed within from SP and validation 

4 hours of scheduled time through analysis of data Moves, changes, from various sources 

and upgrades 38 Percentage of moves, changes, 99% Review monthly data Monthly (Section 2.4.3.3) and upgrades completed within from SP and validation 

2 business days of scheduled time through analysis of data 

from various sources 

39 Percentage of reports delivered in 90% Monitoring submission Monthly 

accordance with reporting dates and quality of 

Reporting schedule reports 

(Section 3.5) 40 Percentage of reports delivered 99% Monitoring submission Monthly 

within 5 business days of due date dates and quality of 

reports 

41 Percentage of customer 95% Review sampling of Monthly 

satisfaction surveys rated at an surveys 

average overall score of 4.0 or 

higher (scale of 0 - 5 with 5 being 

highest) 

42 Percentage of IT training class 95% Review sampling of Monthly 

evaluations rated at an average surveys 

overall score of 4.0 or higher Customer (scale of 0 - 5 with 5 being highest) satisfaction 

43 Percentage of requests properly 95% Monitoring of monthly Monthly 

completed at first attempt	 data sample and 

Customer Support 

Representative input 

44 Percentage of requests properly 99% Monitoring of monthly Monthly 

completed at second attempt	 data sample and 

Customer Support 

Representative input 

* Note: All 44 metrics relate to quality; Metrics 1, 2, 5, 7-9, 11, 13-29, 32-40 relate to timeliness; and Metrics 41 - 44 

relate to business relations. 

Source: CTS Contract Modification 6. 

13-P-0398 21 
PO, CO and QAM Reassignments on CTS Contract 

MA J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N 

PO 1 5/1/08 ‐ 10/8/08

2

10/8/08 ‐ 3/11/09

3

3/11/09 ‐ 12/23/09

4

12/23/09 ‐ 6/21/11

MA J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N 

C 1 2

3

O 4/1/08 ‐ 3/11/09 3/11/09 ‐ 6/2/10 6/2/10 ‐ 11/14/11 

MA J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N 

Q

A

M

vacant

1

9/1/08 ‐

3/31/11

2

7/3/11 ‐ 10/31/11 vacant

4

2008 2009 2010 201

*This CO is the same person but serviced during a different period of time. 

Source: OIG analysis.

13-P-0398 
 

 

Appendix C 

Relevant Recordkeeping Criteria 

The following table illustrates the criteria for government contract records. 

Regulation/policy/ 

instruction/guidance 

Requirement/suggestion/recommendation 

FAR Subsection 46.104 (c) Maintain, as part of the performance records of the contract, suitable 

records reflecting (1) the nature of government contract quality 

assurance actions, including, when appropriate, the number of 

observations made and the number and type of defects; and (2) 

decisions regarding the acceptability of the products, the processes, and 

the requirements, as well as action to correct defects. 

EPAAR Subsection 

1542.1503 (f) 

Copies of the evaluation, contractor response, and review comments 

(if any) shall be retained as part of the evaluation, and hard copies shall 

be contained in contract files. 

EPA Classification No. CIO “All agency employees are responsible for (1) creating and managing 

2155, EPA Records the records necessary to document the agency's official activities and 

Management Policy, actions, including those records generated by the EPA contractors and 

paragraph 8(h)(2)(i)1&3 grantees, in accordance with the EPA recordkeeping requirements;.... 

(3) filing records for safe storage and efficient retrieval and maintaining 

personal papers and non-record materials separately from official 

agency records.” 

EPA Records Management After creating or receiving a record, the EPA staff must capture it by 

Manual, Chapter 3 filing, storing or otherwise systematically maintaining it in a 

recordkeeping system. The EPA offices must capture records in a 

recordkeeping system that facilitates maintenance and use of the 

records in an efficient and cost-effective manner. 

EPA CMM, paragraph 

7.3.5.5(E) 

Contract files must document the contractor's performance to assist the 

agency in future procurements. 

EPA CMM, Section 11.2, A properly documented file should be kept by both the PO/Delivery 

NOTE (11) Order PO and work assignment manager, along with copies of invoices 

reviewed and approval documents. Relevant work assignment manager 

issues should also be communicated and filed in the PO file. The CO 

should file formal correspondence in the contract file. 

EPA CMM, Section 11.2, The Research Triangle Park Finance Center maintains the official file 

NOTE (15) documenting invoice payments. The PO/Delivery Order PO and CO 

maintain secondary files which generally include added data supporting 

payment decisions, suspensions and disallowances. 

EPA CMM, Section 11.2, (1) POs should update their financial records to reflect information 

paragraph 11.2.5.2 (E) - concerning the invoice, the amount paid, and the account used; and 

Filing/Recordkeeping (2) both the PO and work assignment manager should maintain files of 

approved invoices and all associated documentation. These files will 

eventually be sent to the CO at the completion of the contract. The PO 

should consolidate PO/work assignment manager invoice files before 

they are sent to the CO. 

13-P-0398 23 
 

 

 

Regulation/policy/ 

instruction/guidance 

Requirement/suggestion/recommendation 

EPA CMM, Appendix 42.1, Set-up a file system containing all relevant documentation including the 

(4) COR Work plan (a) basic contract, list of contracting officer representatives under the 

contract, all correspondence and meetings related to the contract, 

technical direction, contract deliverables received and reviewed, 

payment file and other items that will provide an audit trail of the 

contract-level contracting officer representative’s actions under the 

contract. Maintain files in accordance with agency National Records 

Management Program policy. Guidance on maintaining the EPA Series 

202, Contract Management Records, is available on the Intranet at 

http://www.epa.gov/records/policy/schedule/sched/202.htm. 

EPA Record Series, 

Schedule 202, NARA 

Disposition No. N1-412-06-

6/5, Contract Management 

Records 

COs and contracting officer representatives should work together to 

determine who is responsible for maintaining specific documents to 

minimize duplication while still providing an adequate audit trail. 

Source: OIG analysis of EPA data. 

13-P-0398 24 
 

 

 

Appendix D 

Agency Comments on Draft Report 

The Office of Administration and Resources Management and the Office of Environmental 

Information have reviewed the draft OIG audit report OA-FY12-0494 and provide the following 

comments and corrective actions in response to subject audit findings and recommendations. 

13-P-0398 25 
 

 

 

 

 

General Comments on Report 

Page 2 - The OIG writes, “In April 2008, the EPA awarded an indefinite delivery/indefinite 

quantity hybrid contract. This hybrid contract also contained provisions for performance-based 

incentive fees and fixed hourly rates and material costs for a time and materials contract. This 

contract required the contractor to provide technology services to approximately 12,000 program 

office users scattered throughout 16 states and the District of Columbia.” 

Contract EP-W-08-034 was a “Seat Service” contract which refers to all the desktop hardware 

and software required for EPA employees to perform work responsibilities. In the contract, the 

EPA estimated the maximum number of seats that may be required by the agency was 12,000, 

and the contractor proposed a monthly fixed price of $169.75 per seat to ensure all EPA 

employees – up to 12,000 - were provided with desktop hardware and software. Ninety percent 

of contract spend used this pricing methodology – the Government both ordered and agreed to 

pay a fixed amount per seat per month, thus accepting the pricing risk in the event the estimated 

12,000 seat calculation was understated, and the contractor accepted the pricing risk in the event 

the 12,000 seat calculation was overstated. The remaining 10% of the contract price was for 

labor categories proposed by the contractor to support various potential contract tasks, such as 

Disaster Recovery and Emergency Response Support and Specialized Projects relating to the 

PWS, and other ancillary services that the EPA required in support of seat service. These 

additional services were procured via task orders, under which the EPA and the contractor 

negotiated the hours needed to perform the required work using the labor categories and fixed 

rates set forth in contract. For this effort, the hours were negotiated but the Government agreed to 

pay the fixed hourly rates. Given the above-described contract terms and conditions, the OIG’s 

characterization of the contract as “provide technology services to approximately 12,000 

program office users” is a misleading description of a contracting and pricing arrangement. 

OIG Evaluation. This report included statements obtained from and supported by the audited 

contract. EPA awarded an Indefinite Delivery/ Indefinite Quantity contract that issued task orders for 

supplies and services with time and materials provisions that the fixed rates include wages, overhead, 

general and administrative expenses and profit. According to the FAR Subsection 16.600, time and 

materials contracts are not fixed price contracts and Subsection 16.601 states fixed hourly rates are 

supposed to be specified. Based on our review of this contract, modifications (mods) indicated 

changes to the rates, hours and user requirements, so the possibility that fixed rates were used and 

the overall cost would not change appear to be misleading. Below shows changes to rates per seat: 

Year 1 Year 2 Year 3 Year 4 

Contract $169.75 $139.27 $139.43 $140.13 

Task Order 2 $175.00 (mod 4) $147.28 (mod 8) $146.70 (mod 15) $147.28 (mod 23). 

If the overall cost is determined based on the changing fixed rate multiplied by the seats, the costs will 

reflect upward and downward revisions to the stated overall contract price. With these changes, this 

contract is not a firm fixed price contract and cost controls are needed. FAR Subsection16.601 states 

that for a time and materials contract, appropriate government surveillance of contractor performance 

is required to give reasonable assurance that efficient methods and effective cost controls are being 

used. 

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Page 8: The OIG writes “By not linking award fee to cost outcomes as required, the EPA did not 

effectively hold the contractor accountable for cost inefficiencies and inaccuracies...Even though 

the agency did not award the contractor an incentive fee, there could have been additional 

corrective actions implemented by having cost outcomes tied to contracting activity.” Pursuant to 

the contract terms and conditions, contractor performance was evaluated against contract 

performance metrics, and the contractor was held accountable when performance against those 

metrics did not meet the level required for payment of incentive fees. Under the afore-mentioned 

contract terms and conditions, performance was incentivized and the contractor was not awarded 

an incentive fee when performance did not meet contract metrics. Accordingly, contract 

incentives worked exactly as designed and intended in accordance with contract terms and 

conditions. Under a fixed price arrangement, controlling costs is inherent in this contract type 

and is therefore, not incentivized. The contractor has to deliver the services at the fixed rate in 

the contract or absorb any additional costs associated with the services. 

OIG Evaluation. According to the FAR Subsection 16.202, a firm fixed price contract provides for a 

price that is not subject to any adjustment on the basis of the contractor’s cost experience in 

performing the contract. A firm fixed price contract type places upon the contractor maximum 

incentive for the contractor to control costs and can use award fee or incentives based on factors 

other than costs. There is nothing in the audited contract that states this is a fixed price contract. EPA 

awarded an Indefinite Delivery/ Indefinite Quantity contract that issued task orders for supplies and 

services with time and materials provisions that the fixed rates include wages, overhead, general, 

and administrative expenses, and profit. FAR Subsection 16.601 states that a time and materials 

contract provides no positive incentive to the contractor for cost control or labor efficiency. Therefore, 

appropriate government surveillance of contractor performance is required to give reasonable 

assurance that efficient methods and effective cost controls are being used. Since this contract has 

an award fee plan, FAR Subsection 16.401 9(e)(2) states award shall not be earned if the overall 

cost, schedule and technical performance is not at a satisfactory level. 

Responses to the Recommendations 

Recommendation 1: Update the policies and procedures to include controls that would ensure 

contract performance metrics and standards include cost outcomes for all incentive and time and 

materials contracts. 

Recommendation 2: Update internal programs that provide oversight and accountability to 

ensure that, for all incentive type and time and materials contract, the EPA performance metrics 

link to cost outcomes. 

OAM Response: 

OAM disagrees with these recommendations and disagrees with the OIG’s recommendation that 

cost is an appropriate incentive for all incentive and time and materials contracts. EPA’s CTS 

Contract EP-W-08-034 is an Indefinite Delivery/Indefinite Quantity type contract with time and 

materials pricing, under which the contractor may earn an incentive fee for performance that 

exceeds metrics set forth in the contract. 

Attachment 11 of the contract contains contract pricing. Under the Attachment 11 Base Period, 

90% of the contract price is for standard seat service, “Seat Service” refers to all the desktop 

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hardware and software required for EPA employees to perform work responsibilities. In the 

contract, EPA estimated the maximum number of seats that may be required by the agency was 

12,000, and the contractor proposed a monthly fixed price of $169.75 to ensure all EPA 

employees – up to 12,000 - are provided with desktop hardware and software. Again 90% of 

contract pricing used this methodology. The other pricing under Attachment 11 Base Period, 

which totals 10% of the contract price, is for labor categories proposed by the contractor to 

support various potential contract tasks, such as Disaster Recovery and Emergency Response 

Support and Specialized Projects relating to the PWS, that the EPA may require in support of 

seat service. These additional services were procured via task orders, under which EPA and the 

contractor negotiated the hours needed to perform the required work using the labor categories 

and fixed rates set forth in Attachment 11. For this effort, the hours were negotiated but the rates 

were fixed. 

Attachment 6 of the contract sets forth performance standards/metrics for seat service and other 

tasks against which contractor performance is measured for the purpose of determining the 

award fee. The performance standards/metrics identified are specifically tied to Performance 

Work Statement tasks the contractor is performing to ensure all EPA employees have the 

necessary desktop hardware and software to perform their work responsibilities. As such, the 

criteria set forth in Attachment 6 of the contract is designed to measure critical contract 

performance – timeliness, responsiveness, system security, user support, and customer 

satisfaction. 

Attachment 12 of the contract prescribes how the contractor will be paid an incentive fee for 

elevated levels of performance, for example, if the performance metric is met at 100%, the 

vendor receives 100% of the incentive fee, if met at 75%, the vendor receives 75%, etc. The final 

fee is calculated against the Attachment 6 metrics, and paid against the Attachment 11 pricing. 

OAM believes that writing a policy that “includes cost outcomes for all incentive and time and 

materials contracts” is not necessary. Additionally, FAR Subpart 16.1 states selecting the 

contract type is a matter for negotiation and requires the exercise of sound judgement. Factors 

that should be considered in this negotiation are risk, complexity of the requirement, expected 

price competition, urgency of the requirement, period of performance of the requirement (the 

longer the more risk), and the contractor’s technical capability and financial responsibility. The 

FAR also states that the objective is to negotiate a contract type and price that will result in 

reasonable contractor risk and provide the contractor with the greatest incentive for efficient and 

economical performance. In the above pricing arrangement, the number of seats was controlled 

by the Government, and the price per seat was fixed, so the only risk to the Government was 

with contractor performance. FAR Subsection 16.402 states that performance incentives may be 

considered in connection with specific product characteristics (e.g., a missile range, an aircraft 

speed, an engine thrust, or vehicle maneuverability) or other specific elements of the contractor’s 

performance. These incentives should be designed to relate profit or fee to results achieved by 

the contractor, compared with specified targets. OAM incentivized contractor performance 

characteristics in the areas of timeliness, responsiveness, system security, user support, and 

customer satisfaction, and fee was awarded based upon the contractor’s performance against 

metrics set forth in these areas. Regardless of the amount of fee awarded against these metrics, 

the vendor was entitled to collect the fixed price per seat set forth in the contract. Under the 

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above pricing structure, OAM properly assessed contract risk and established incentive fee 

metrics to mitigate and shift the burden of that risk to the contractor. OAM does not agree with 

writing a policy requiring cost be an incentive for all incentive and time and materials contracts. 

OIG Evaluation. The OAM response does not sufficiently address recommendations 1 and 2. 

OAM states OIG is recommending cost as an appropriate incentive, yet we are emphasizing FAR 

Subsections 16.401, 16.402, and 16.601, and OMB requirements that, for incentive (contracts with an 

award fee) and time and material contracts, agencies link cost outcomes to performance standards 

and metrics. Also, OAM’s response is stating they have the right to determine contract type when the 

issue is with the FAR additional requirements for the contract types already selected. To ensure the 

EPA is complying with FAR and OMB requirements addressed above, the EPA policies/procedures 

should require that for incentive (contracts with an award fee) and time and material contracts 

performance standards and metrics are linked to cost outcomes. In addition for recommendation 2, 

per OMB Circular A 123, agencies are responsible for establishing internal controls (policies and 

procedures) to achieve compliance with applicable laws and regulations and should design 

management structures that help ensure accountability for results. 

Recommendation 3: Require OTOP, in conjunction with OAM, to review contractor 

performance reports generated per the QASP. Require OTOP to coordinate all actions taken with 

the COs and PO’s and require the CO’s to input contractor performance information into 

CPARS. 

Recommendation 4: Require CO’s to input interim reports into CPARS prior to their 

reassignments. 

OAM Response: 

OAM agrees with these recommendations. With regard to the CTS contract, OAM has been 

working with the program office to complete the required past performance evaluation(s). The 

contract was registered and interim reports initiated in CPARS on Feb 1, 2013. Evaluation 

narratives were drafted by OAM based on information obtained from the award-fee assessments; 

and finalization of these reports is pending upon additional input from the program office (OEI). 

With regard to overall past performance reporting, OAM believes adequate policy already exists 

in the FAR and EPAAR with regard to reporting requirements. As part of the OAM Balanced 

Scorecard Performance Measurement and Management Peer Review and Oversight Process, 

OAM reviews individual office's procedures for monitoring Contractor Performance Assessment 

Reporting System and evaluates whether the office has an effective oversight program. 

Furthermore, in March 2013, OFPP began monitoring CPARS compliance and required all 

federal agencies to establish compliance goals to be monitored both internally and externally. In 

order to monitor and oversee both internal and external past reporting initiatives, OAM 

designated a CPARS lead to monitor agencywide past performance reporting compliance on a 

monthly basis. The lead ensures compliance by comparing PPIRS reports with the CPARS 

database and disseminates the results to all agency CPARS focal points and their managers. 

Beginning in February 2013, the CPARS representative is requiring Agency focal points report 

status on any incomplete CPARS. Under the above described internal OAM compliance 

program, OAM has already improved compliance by 15% and anticipates continual 

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improvement over the next few months. Additionally, as of June 2013, OAM appears to be on 

target to meet our Agency CPARS compliance goal of 75 percent by the end of FY 2013. 

Based upon EPA/OAM’s established, aggressive and continuous CPARS compliance oversight 

and monitoring toward achieving and reporting against external goals, and given CPARS 

monitoring is a recognized ongoing effort satisfies recommendation 4 and OARM considers this 

recommendation closed. 

OIG Evaluation. Even though the agency agreed to recommendations 3 and 4, the comments are 

not completely responsive to the recommendations. The comments should address requiring that 

COs put interim reports into CPARS prior to their reassignments. This additional procedure will assist 

the agency to ensure that the contractor performance reports are entered into CPARS. The response 

did not address how or when OARM would implement the agreed-to recommendation to require COs 

input interim evaluation prior to reassignments in CPARS. This should be addressed as part of the 

60-day response to the final report. According to EPA Manual 2750, if the OIG determines that the 

agency’s intended corrective actions meet the intent of the recommendations, the OIG reports 

recommendations as resolved in the OIG's audit tracking system. 

Recommendation 5: Develop OAM procedures to require that before there are personnel 

reassignments, CO’s, PO’s, and QAM’s perform an inventory of required documents in their 

possession or in the official contract file to ensure maintenance of accurate and complete records. 

Recommendation 6: Update internal procedures and programs to include a process to transfer 

all required documents to the newly appointed CO’s and PO’s or establish a key locator system 

indentifying the location of required contracting documents. 

OAM Response: 

OAM agrees with these recommendations although regarding the need for policy updates with 

regard to adequate file documentation, OAM believes sufficient internal and external policy and 

procedures with regard to contract documentation requirements already exists in the FAR, the 

Contract Management Manual, and the Acquisition Handbook. OAM also believes that 

meaningful oversight and review processes are necessary to ensure compliance with the 

applicable statutes, regulations, policies and procedures. Accordingly, OAM’s Balanced 

Scorecard Performance Measurement and Management Program consists of self-assessment and 

peer review oversight components that utilize a significant file review component to assess 

compliance with statues, regulations, policies, and procedures as documented in the contract. 

Under this approach, contract file documentation adequacy is internally reviewed by each 

division, and also independently by an independent team of senior level contracting 

professionals. 

Since program implementation in FY 2012, OAM has been assessing the quality and compliance 

of EPA’s acquisition system agency-wide, and using review results to identify acquisition system 

weaknesses, and correct problems areas through training and/or implementation of policy and 

process guidance. In peer reviews to date, the need for improved contract file documentation has 

been identified as a systems issue finding, and as a result, individual organizations have 

developed corrective action plans and OAM has been including documentation requirements 

under various comprehensive new acquisition policies on Acquisition Planning and the CPARS. 

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In addition, Acquisition Handbook, Section 4.1, is being updated to prescribe requirements for 

streamlined internal controls (e.g., higher-level transactional reviews), to ensure the sufficiency 

and quality of file documentation in support of support contracting officer decisions and actions 

and an updated standardized checklist for contract file documentation. Under the BSC PMMP 

program, all OAM staff are accountable for the quality and health of the EPA acquisition system. 

Information on OAM’s BSC PMMP Program may be found on the OAM intranet under the 

“Balanced Scorecard” tab on the left. 

Based upon EPA/OAM’s established and aggressive BSC PMMP compliance oversight and 

monitoring program, OAM requests the above described ongoing actions be considered and 

these recommendations be closed. 

OIG Evaluation. The agency agreed with the recommendations 5 and 6. However, the agency’s 

comments are not completely responsive to the recommendations. The recommendations discussed 

procedures as opposed to policy and OAM procedures are necessary to provide details on what 

should be done to ensure maintenance of accurate and complete contract records. The policies 

OAM mentioned do not address procedures needed when there are CO, PO and QAM 

reassignments and new appointments. Procedures to perform an inventory of the required contract 

documents would assist in ensuring maintenance of accurate and complete records. In addition, 

procedures are needed to include a process to transfer all required documents to the newly 

appointed COs and POs or establish a key locator system indentifying the location of required 

contracting documents. According to EPA Manual 2750, if the OIG determines that the agency’s 

intended corrective actions meet the intent of the recommendations, the OIG reports 

recommendations as resolved in the OIG's audit tracking system. 

Should you have any questions regarding the OEI issues, please contact Scott Dockum at (202) 

566-1914; any questions regarding OAM’s responses can be directed to Rebecca Snipe at (202) 

564-8346. 

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Appendix E 

Distribution 

Office of the Administrator 

Assistant Administrator for Administration and Resources Management 

Assistant Administrator for Environmental Information and Chief Information Officer 

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 

Director, Office of Acquisition Management, Office of Administration and 

Resources Management 

Director, Office of Technology Operations and Planning, Office of Environmental Information 

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

Audit Follow-Up Coordinator, Office of Environmental Information 

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