EPA’s Financial Oversight of 

Superfund State Contracts

Needs Improvement

Report No. 16-P-0217 June 27, 2016

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Financial Management
Report Contributors: Paul Curtis

Arthur Budelier

Carol Kwok

Kevin Ross

Wendy Swan

Abbreviations

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFC Cincinnati Finance Center

CFR Code of Federal Regulations

EPA U.S. Environmental Protection Agency

OIG Office of Inspector General

OLEM Office of Land and Emergency Management

SSC Superfund State Contract

Cover photo: A warning sign at a Superfund site. (EPA photo)

Are you aware of fraud, waste or abuse in an

EPA program?

EPA Inspector General Hotline 

1200 Pennsylvania Avenue, NW (2431T)

Washington, DC 20460

(888) 546-8740

(202) 566-2599 (fax)

OIG_Hotline@epa.gov

Learn more about our OIG Hotline.

EPA Office of Inspector General

1200 Pennsylvania Avenue, NW (2410T)

Washington, DC 20460

(202) 566-2391

www.epa.gov/oig

Subscribe to our Email Updates

Follow us on Twitter @EPAoig

Send us your Project Suggestions
 

 16-P-0217

June 27, 2016

Why We Did This 

Review

The U.S. Environmental 

Protection Agency (EPA), 

Office of Inspector 

General (OIG), performed 

this audit to determine 

whether the EPA: 

(1) effectively oversees 

the Superfund State 

Contract (SSC) process 

for remedial activities,

(2) bills and collects 

appropriate SSC costs 

from the states, and

(3) properly approves and 

applies SSC credits and 

in-kind payments to 

Superfund sites.

An SSC is an agreement

between the EPA and a

state to conduct remedial 

action at a site. The SSC 

clarifies the EPA’s and the 

state’s financial and other 

responsibilities to

complete the remedial 

action, and documents 

state assurances before 

the remedial action 

occurs.

This document 

addresses the following 

EPA goal or 

cross-agency strategy:

 

 Embracing EPA as a 

high-performing 

organization.

Send all inquiries to our 

public affairs office at 

(202) 566-2391 or visit 

www.epa.gov/oig. 

Listing of OIG reports.

 

EPA’s Financial Oversight of Superfund

State Contracts Needs Improvement

 What We Found

The EPA almost always billed and collected 

appropriate SSC costs and properly approved 

and applied SSC credits to SSCs. However, we 

found areas where improvements are needed. 

Specifically, we found that the EPA:

 Incurred total SSC obligations and expenditures in excess of the authorized SSC 

cost ceiling for 51 of the 504 active and closed SSCs.

 Did not perform timely or complete and accurate financial closings for 20 SSCs

to ensure that both the EPA and the state had satisfied their cost share 

requirement.

 Did not have all the up-to-date information needed for an accurate SSC accrual 

calculation.

In addition, the EPA did not effectively oversee the SSC process in some areas 

because some EPA regions did not:

 Effectively monitor SSC obligations and expenses.

 Make financial closings a priority or have closing procedures.

 Provide all the information needed for the accrual calculation.

Without effective oversight, excess SSC obligations and expenditures may constitute 

breaches of the SSCs. The accrual calculation may not be accurate and may misstate 

the financial statements and SSC financial status. SSC financial closings not 

performed timely or completely may delay the availability of appropriated funds. We 

identified SSCs with available reimbursable funds with the potential to increase these 

appropriated funds by $2.3 million.

 Recommendations and Planned Agency Corrective Actions

We recommend that the Office of Land and Emergency Management emphasize to 

the regions the importance of monitoring total SSC costs and develop uniform SSC 

cost monitoring and financial closeout procedures. We also recommend that the Chief 

Financial Officer develop guidance for the regions to provide information for a more 

accurate SSC accrual calculation and make certain accrual adjustments for more 

accuracy.

The agency concurred with and provided acceptable corrective actions and estimated 

completion dates for all recommendations. The agency completed corrective actions 

for three recommendations. The remaining recommendations, for the Assistant 

Administrator for Land and Emergency Management to emphasize the importance of 

monitoring SSC costs and to develop uniform SSC financial closeout procedures for

the regions, are open with agreed-to corrective actions scheduled to be completed by 

the end of the year.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

With improved financial oversight, 

the EPA may manage SSCs more 

effectively, report results more 

accurately, and increase the 

availability of funds for cleanups

protecting public health.
June 27, 2016

MEMORANDUM

SUBJECT: EPA’s Financial Oversight of Superfund State Contracts Needs Improvement

Report No. 16-P-0217

FROM: Arthur A. Elkins Jr.

TO: Mathy Stanislaus, Assistant Administrator

Office of Land and Emergency Management

David Bloom, Deputy Chief Financial Officer

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

U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY15-0054. 

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. Final determinations on matters in this report will be made by EPA managers in 

accordance with established audit resolution procedures.

The offices with primary jurisdiction over the issues in this report are the Office of Superfund 

Remediation and Technology Innovation within the Office of Land and Emergency Management, and the 

Office of the Controller and Office of Budget within the Office of the Chief Financial Officer.

Action Required

In accordance with EPA Manual 2750, your offices provided acceptable corrective actions and 

milestone dates in response to OIG recommendations. All recommendations are resolved and no final 

response to this report is required.

We will post this report to our website at www.epa.gov/oig. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
EPA’s Financial Oversight of Superfund 16-P-0217

State Contracts Needs Improvement

Table of Contents

Chapters

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

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

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

Responsible Offices ................................................................................... 4

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

2 EPA Should Improve Its Financial Oversight of 

Superfund State Contracts .............................................................................. 5

SSC Expenditures Exceeded SSC Estimated Project Costs ...................... 6 

Regions Did Not Perform Timely or Complete and Accurate

Financial Closings ............................................................................... 8

CFC Did Not Have All Information Needed to Accurately

Calculate SSC Revenue....................................................................... 10

Conclusion................................................................................................. 13

Recent Agency Actions Prompted by OIG Work ........................................ 14

Recommendations..................................................................................... 14

Agency Comments and OIG Evaluation..................................................... 15

Status of Recommendations and Potential Monetary Benefits ............................. 16

Appendices

A Details on Scope and Methodology ................................................................ 17

B SSCs With Available Reimbursable Funds..................................................... 19

C Agency Response to Draft Report................................................................... 20

D Distribution ....................................................................................................... 25
16-P-0217 1

Chapter 1

Introduction

Purpose

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

(OIG), performed this audit to evaluate the EPA’s oversight of Superfund State 

Contracts (SSCs) for remedial activities. With the current focus on reducing the 

federal budget deficit, the OIG wanted to determine whether the EPA was 

collecting the appropriate state cost shares. The objectives of our audit were to 

determine whether the EPA:

 Effectively oversees the SSC process for remedial activities.

 Bills and collects appropriate SSC costs from the states.

 Properly approves and applies SSC credits and in-kind payments to 

Superfund sites.

Background

An SSC is an agreement between the EPA and a state under which the EPA takes 

the lead in cleaning up a site located in that state. The SSC is a joint, legally 

binding agreement that clarifies the EPA’s and state’s responsibilities to complete 

the remedial action. It also documents other requirements and state assurances 

before the remedial action occurs. One important assurance is the state’s 

commitment to share costs. The agreement is reached before the cleanup starts 

and calls for the state to share in the cost of the cleanup based on an agreed-upon 

percentage, as defined in the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980 (CERCLA).

From the program’s beginning in 1980 through 

December 31, 2014, the EPA has entered into more 

than 500 SSCs totaling $8.8 billion in estimated 

project costs, with a state cost share of $889 million. 

The EPA has spent more than $7 billion in project 

costs, and collected $550 million in cash from the 

states. The EPA also approved $104 million for the 

states in credits, which are state site-specific 

expenses that the EPA determines to be reasonable, 

documented, direct, out-of-pocket expenditures of nonfederal funds for remedial 

action.

The regional offices negotiate and execute the SSC agreements with the states. 

Regional office responsibilities may vary depending upon how a region is 

organized and operates. The regional offices forward the signed SSC 

The EPA has entered 

into more than 

500 SSCs totaling 

$8.8 billion in 

estimated project costs, 

with a state cost share 

of $889 million.
16-P-0217 2

documentation to the Office of the Chief Financial Officer’s Cincinnati Finance 

Center (CFC). The CFC records the SSC billings and collections in the Compass 

accounting system for the EPA’s 10 regions. The CFC prepares a quarterly 

spreadsheet to calculate the earned revenue and unearned revenue from the SSCs 

to properly reflect the financial statements. Unearned revenue represents the 

EPA’s liability for advance collections from the states for which the EPA has not 

yet incurred costs on the SSC. As required by proper accounting policy, the EPA 

recognizes earned revenue as it incurs costs on an SSC.

SSC collections from a state to cover a state’s cost share are designated as 

reimbursable resources. The EPA spends those funds on the remedial action 

designated in the SSC, and pays the EPA’s cost share from the Superfund 

appropriation. The Superfund appropriation expenditures generally represent 

90 percent of the remedial action costs, and the reimbursable expenditures 

generally represent 10 percent, reflecting the SSC cost share percentages. 

Credits are state site-specific expenses for remedial action approved by the EPA 

and used by the states to reduce all or part of their cost share requirement. EPA 

regulations also permit states to pay their cost share through in-kind services, 

which are non-cash contributions of goods or services directly benefitting the 

remedial action.

Statutory Authority and Guidance

CERCLA, as amended, authorized SSCs. CERCLA Section 101 defines a 

remedial action as

... those actions consistent with a permanent remedy taken instead 

of or in addition to removal actions in the event of a release or 

threatened release of a hazardous substance into the environment, 

to prevent or minimize the release of hazardous substances so that 

they do not migrate to cause substantial danger to present or future 

public health or welfare or the environment.

CERCLA Section 104 requires the state to provide 10 percent of the remedial 

action’s cost at privately owned or operated facilities, and requires 50 percent 

(or such greater amount as determined by the agency) of the remedial action’s 

cost at a facility that is operated by the state.

The Code of Federal Regulations (CFR), in 40 CFR Part 35, Subpart O, provides 

the requirements for administering an SSC. Subpart O, Section 35.6800, requires 

an SSC with a state “before EPA can obligate or expend funds for a remedial 

action at a site within the State and before EPA or a political subdivision can 

conduct the remedial action.” Section 35.6815 states that the state may pay for its 

share of the costs of the response activities in cash or credit. The state may pay for 

its cost share using in-kind services only if the state has entered into a support 
16-P-0217 3

agency cooperative agreement with the EPA. To conclude the SSC, Section 

35.6820 requires, among other things, that the signatories produce a final 

accounting of all project costs.

Office of Land and Emergency Management (OLEM)

1 Directive 9200.3-15-IG-Y,

Superfund Program Implementation Manual Fiscal Year 2015, provides 

overarching program management priorities, procedures and practices for the

Superfund programs. The manual states at Chapter III.I.2 that the EPA may not 

obligate funds for a fund-financed remedial action without having a signed SSC in 

place. The SSC must contain an estimated value of the remedy that the EPA will 

implement using fund resources and the state’s 

share, the amount of cost share that the state is 

assuring to provide, and a cost share payment 

schedule. The EPA may not spend remedial action 

resources in excess of the estimated value of the 

remedy determined in the SSC. If there are 

increases to the cost of the remedial action, the 

SSC must be amended to reflect the change and 

document that the state has increased share of the cost. Chapter III.I.4 states that 

SSC collections from state cost share payments are designated as reimbursable 

resources.

OLEM Directive 9375.7-01, Ensuring the Adequacy of Cost Share Provisions in 

Superfund State Contracts, dated March 29, 1993, advised the EPA’s regional 

offices that once all funds identified in an SSC are expended, the “EPA must not 

obligate more funds until the SSC is amended.” OLEM Directive 9375.7-02, 

Obligation of Funds Under Superfund State Contracts, dated August 5, 1993, 

states that Subpart O reconciliation clauses are to be used only at the time of 

project closeout and must not be used as a substitute for amending an SSC when 

cost increases become apparent far in advance of the end of the project. The 

reconciliation provisions are intended to allow the EPA and the state to adjust 

actual cost share amounts to a level of precision possible only after all project 

costs are fully known.

The EPA’s Resource Management Directive System No. 2550D-09-P1, Financial 

Management of Superfund Program - State Cost Share Provisions for Superfund 

State Contracts and Remedial Cooperative Agreements, August 2, 2012, describes 

the EPA’s process for managing the financial aspects of Superfund program 

remedial state cost share provisions in state contracts and remedial cooperative 

agreements. Regional program offices are responsible for the overall management 

of SSCs. The regional program offices, in conjunction with regional finance 

office and the Office of Regional Counsel, are responsible for financial closeout 

of SSCs.

 

1 On December 15, 2015, the EPA’s Office of Solid Waste and Emergency Response, or OSWER, changed its name 

to the Office of Land and Emergency Management, or OLEM. Hereafter, we will always refer to OLEM.

The EPA may not spend 

remedial action 

resources in excess of 

the estimated value of 

the remedy determined 

in the SSC.
16-P-0217 4

Responsible Offices

The offices we identified with primary jurisdiction over the audit issues and the 

responsibility for taking corrective action on our recommendations are the Office 

of Superfund Remediation and Technology Innovation within OLEM, and the 

Office of the Controller and Office of Budget within the Office of the Chief 

Financial Officer. Regional Superfund program offices are responsible for the 

overall management of SSCs in the regions, and regional financial management 

offices handle the financial management.

Scope and Methodology

We conducted this audit from January 2015 to May 2015, and January 2016 

through March 2016, 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 based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit 

objectives.

Appendix A contains additional details concerning our scope and methodology, 

including details on prior reports reviewed.
16-P-0217 5

Chapter 2

EPA Should Improve Its Financial Oversight of

Superfund State Contracts

The EPA almost always billed and collected appropriate SSC costs and properly 

applied SSC credits to SSCs. However, the EPA could improve financial 

oversight in some areas. We found that:

 The EPA incurred total SSC obligations and expenditures that exceeded the 

authorized SSC-estimated project costs on 51 out of the 504 SSCs.

 EPA regions did not perform timely or complete and accurate financial 

closings for 20 SSCs.

 CFC did not have all the up-to-date SSC information needed to maximize 

the accuracy of the SSC accrual spreadsheet that supports the EPA’s 

financial statements.

CERCLA requires the EPA to enter into an SSC with a state before spending 

funds for remedial action. Title 40 CFR Part 35, Subpart O, provides the 

requirements for administering an SSC, including cost share conditions. However, 

the EPA’s oversight problems occurred because:

 The regions did not have uniform guidance for monitoring SSC

obligations and expenses, and monitoring procedures varied by region.

 Some regions did not provide the CFC with all the up-to-date information 

needed to maximize the accuracy of the SSC accrual spreadsheet, despite 

the CFC providing the regions quarterly instructions to do so.

 Some regions did not make financial SSC closings a priority or did not 

have financial closing procedures.

 EPA guidance did not specifically require the regions to report in-kind 

payment information to the CFC, and the CFC did not include in-kind 

payments in the SSC accrual calculation.

Without effective oversight, excess SSC obligations 

and expenditures may constitute breaches of the SSCs.

The accrual calculation may not be accurate, and 

could misstate the financial statements and financial 

status of the SSCs. In addition, SSCs not closed timely 

where state cost share funds remain available after 

completion of the activities identified in the SSC may 

delay the availability of appropriated funds that could 

be used for other sites. We identified SSCs with available reimbursable funds 

with the potential to increase appropriated funds by $2.3 million. Appendix B lists 

the details of the $2.3 million in available reimbursable funds. Figure 1 illustrates 

the areas where the EPA should improve its financial oversight of SSCs.

Without effective 

oversight, excess SSC 

obligations and 

expenditures may breach 

the SSCs and violate 

OLEM directives.
16-P-0217 6

Figure 1

Source: OIG-generated.

SSC Expenditures Exceeded SSC Estimated Project Costs

The EPA incurred total SSC obligations and expenditures that exceeded the 

authorized estimated project costs on 51 of the 504 active and closed SSCs. 

CERCLA prohibits the EPA from providing any fund-financed remedial actions 

unless the state first enters into a contract with the agency in which the state 

makes certain, specified assurances. OLEM Directive 9200.3-15-IG-Y, the EPA’s 

Superfund Program Implementation Manual Fiscal Year 2015, states that the cost 

of the remedial actions shall not exceed the SSC-estimated cost unless the 

contract is amended. Some regions did not adequately monitor the total SSC costs 

to ensure they did not exceed the SSC-estimated project costs. The regions did not 

have uniform guidance for monitoring SSC obligations and expenses, and 

monitoring procedures varied by region. EPA expenditures that exceed the SSC 

cost estimates violate EPA policy and could lead to disputes with states that may 

prevent the EPA from continuing a remedial action at a site.

CERCLA Section 104 (c) (3) prohibits the EPA from providing any fundfinanced remedial actions unless the state first enters into a contract or 

cooperative agreement (in which the state makes certain, specified assurances) 

with the agency. Title 40 CFR Part 35, Subpart O, Section 35.6800, further 

clarifies that an SSC is required before the EPA can obligate or transfer funds for 

an EPA-lead remedial action.

OLEM Directive 9200.3-15-IG-Y, Superfund Program Implementation Manual 

Fiscal Year 2015, states that the EPA may not spend remedial action resources in 

excess of the estimated value of the remedy determined in the SSC. If there are 

increases to the cost of the remedial action, the SSC must be amended to reflect 

the change and document the state’s increased share of the cost.

EPA should 

improve its 

financial 

oversight of 

superfund state 

contracts

SSC expenditures 

exceeded SSC 

estimated project 

costs

CFC did not have all 

information needed to 

accurately calcuate 

SSC revenue

Regions did not 

perform timely or 

complete and accurate 

financial closings
16-P-0217 7

OLEM Directive 9375.7-02, Obligation of Funds under Superfund State 

Contracts, states that Subpart O reconciliation clauses—which ensure that both 

the EPA and the state have satisfied their cost share requirement—are to be used 

only at the time of project closeout. The final reconciliation of project costs must 

not be used as a substitute for amending an SSC when cost increases become 

apparent far in advance of the end of the project.

Nine of the 45 randomly selected SSCs that we initially reviewed incurred total 

expenditures exceeding the authorized estimated project costs. We also examined 

the other 459 SSCs on the CFC’s accrual spreadsheet for excess expenditures, and 

determined that an additional 42 exceeded the authorized project costs. The 

combined total of 51 of the 504 SSCs exceeding the authorized costs had excess 

costs totaling $135,498,443. Table 1 lists the SSCs with excess expenditures.

 

Table 1: SSCs with expenditures exceeding the authorized project costs

Region Site numbers Excess $

1 01C4, 01N9 $1,251,893

2 0255, 0286, 0237 3,111,334

3 03T6, 031M, 032S, 03Q6, 03W9, A301 3,097,316

4 0444, 04B7, 04G2, 0442 7,207,586

5 0525, B58Y, 050WRA01, 05BW, 05C3, 05D3, 05D5 16,015,473

6 0611, 0635 39,719

7

07CS OU2, 07EF OU1, 07EF OU2, 07GE OU1, 07XL, 0706, 

0701, 071T OU1 14,539,201

8 0813R, 0801, 0841, 085G, 087T, 08K5-081Y 27,806,021

9 09H2, 093Y, 094R, 09R6 6,650,777

10 1014, 104K, 10G8, 10P9, 10W2, 1022, 1027, 1091, 103N 55,779,123

 Total $135,498,443

Source: OIG analysis of EPA data.

The remedial action expenditures for some SSCs exceeded estimated project costs 

because the regions did not adequately monitor the total SSC costs. For example:

 Region 1 tracked the reimbursable expenses but not the appropriated funds 

or the total expenses against the estimated project cost.

 Region 7 tracked total costs for billing purposes but not costs against the 

estimated project cost.

 Region 9 tracked reimbursable costs and total costs for billing purposes 

but not total costs against the estimated project cost.

 Region 10 did not track total costs against the estimated project cost and 

relied on CFC’s SSC accrual spreadsheet to track and monitor SSC costs.

 The other regions described various methods of tracking total SSC costs, 

but their tracking methods were not completely effective because we 

identified SSCs in all regions that exceeded the estimated project costs.
16-P-0217 8

We determined that the EPA currently monitors reimbursable funds effectively

because only four SSCs out of 504 had reimbursable obligations in excess of 

collections. In October 2014, the Office of the Chief Financial Officer developed 

an available balances report for all regions that compares SSC collections 

(reimbursable authority) to SSC obligations of reimbursable funds and highlights

SSCs with negative balances (obligations in excess of collections). The report is 

available to all regions for monitoring reimbursable funds. The January 22, 2015,

negative balance summary report showed four SSCs with negative balances

totaling $198,105. The EPA worked to correct the negative balances, and as of 

July 28, 2015, the EPA had four SSCs with negative balances totaling $11,177. 

We consider the negative balances to be an acceptable level in relation to the 

$4.2 million obligations for those SSCs as of July 28, 2015.

According to OLEM’s Directive 9375.7-01, Ensuring the Adequacy of Cost Share 

Provisions in Superfund State Contracts, dated March 29, 1993, without effective 

oversight, excess SSC expenditures may constitute breaches of the SSCs. Without 

having an adequate cost-share provision in the SSC, the EPA may have to 

interrupt an ongoing cleanup, thereby delaying the environmental cleanup and 

public health protection until the SSC is amended. 

The EPA may also be in violation of CERCLA for conducting remedial action 

without having a valid SSC. Any expenditure by the EPA in excess of the 

estimated project cost would be beyond the terms of the SSC, and the state may 

not be contractually bound to share in paying the additional cost.

Regions Did Not Perform Timely or Complete and Accurate 

Financial Closings

The regions did not perform timely or complete and accurate financial closings 

for several SSCs. Although the EPA does not have a standard for timely closing, 

we believe the amount of elapsed time for closing some SSCs (4 to 28 years) was 

excessive. Some regions did not make financial closings a priority or did not have 

financial closing procedures. SSCs not closed timely may delay the issuance of a 

final bill or refund to the state. They may also delay the reclassification of 

appropriated and reimbursable funds, which may affect the availability of 

appropriated funds. We identified SSCs with available reimbursable funds with 

the potential to increase appropriated funds by $2.3 million. Appendix B lists the 

details of the $2.3 million in available reimbursable funds.

Title 40 CFR Part 35, Subpart O, Section 35.6805, states that

...the SSC remains in effect until the financial settlement of 

project costs and final reconciliation of response costs 

(including all change orders, claims, overmatch of cost 

share, reimbursements, etc.) ensures that both the EPA and 
16-P-0217 9

the state have satisfied the cost share requirement in 

Section 104 of CERCLA, as amended.

The EPA’s Resource Management Directive System 2550D-09-P1 directs the 

regional program office to conduct the SSC financial closeout process, which 

includes the reconciliation of the state’s final cost share and reclassification of 

disbursements when applicable. The guidance further states that the SSC accrual 

calculation for a financially closed SSC should be reviewed and adjusted, if 

needed, to reflect a zero accrual balance.

We identified 20 SSCs out of 56 we reviewed where the regions did not perform 

timely or complete and accurate financial closings. Table 2 lists 10 SSCs that the 

EPA did not financially close, with the number of years that have elapsed since 

the EPA completed the SSC remedial action. Table 3 lists 10 SSCs where the 

EPA provided termination agreements or other documentation to indicate they 

had closed the SSC, but we determined that the EPA did not perform the closing 

completely and accurately or report accurate closeout data for the accrual 

calculation. 

The EPA records did not provide a remedial action completion date for some of 

the SSCs we reviewed. When the remedial action completion date was not 

available, we used the date when the EPA completed remedial action 

expenditures to determine financial closing timeliness. Although the EPA does 

not have a standard for timely closing, we believe the amount of elapsed time for 

closing these SSCs—4 to 28 years after completing the remedial activity—was 

excessive.

Table 2: SSCs not financially closed timely

Site

number

Year remedial

activity complete

Financial 

closing status

Elapsed time

(rounded to nearest year)2

0230 2002 Not closed 13

0444 1996 Not closed 19

0502 2011 Not closed 4

0655 1996 Not closed 19

077M OU1 2000 Not closed 15

0928 1988 Not closed 27

0939 1987 Not closed 28

0944 2000 Not closed 15

09H2 2009 Not closed 6

09Y1 2004 Not closed 11

Source: OIG analysis of EPA data.

Table 3 lists the 10 SSCs that the EPA attempted to close but the closing was not 

complete and accurate or the closeout data for the accrual calculation was not 

 

2 We calculated the elapsed time from the year remedial activity was completed to the year 2015. 
16-P-0217 10

accurate. The EPA did not financially close these SSCs completely and accurately 

because the regions did not:

 Properly reclassify disbursements from the appropriated funds to the

reimbursable funds to take advantage of available reimbursable funds.

 Report accurate closeout data and transfer of SSC credits to the CFC to 

support an accurate SSC revenue accrual.

Table 3: SSCs not financially closed completely and accurately

Site

number Reason not closed completely and accurately

0104 Did not report accurate closeout data and transfer of credits for the accrual. 

0204 Disbursement reclassifications not complete. 

0289 Disbursement reclassifications not complete.

0312 Did not include all remedial action costs in the final reconciliation.

0316 Did not report accurate closeout data for the accrual.

03T6 Disbursement reclassifications not complete and did not report accurate 

closeout data for the accrual.

0525 Disbursement reclassifications not complete.

05L3 Disbursement reclassifications not complete.

0813R Did not report accurate closeout data for the accrual.

1056 Disbursement reclassifications not complete and did not report accurate 

closeout data for the accrual.

Source: OIG analysis of EPA data.

We found various reasons for the lengthy or incomplete financial closings. Some 

regions did not make financial SSC closings a priority or did not have financial 

closing procedures. Other reasons included determining how to correct a negative 

balance SSC and resolving a discrepancy in interagency agreement costs. 

SSCs not closed timely may:

 Delay the issuance of any final bill or refund to the state.

 Delay the reclassification of appropriated and reimbursable funds, which 

affects the availability of appropriated funds.

 Misstate the accrual calculation, the financial statements, and the SSC 

financial status.

CFC Did Not Have All Information Needed to Accurately Calculate

SSC Revenue

The CFC did not have all the current SSC information needed to accurately 

calculate SSC revenue. EPA guidance directs the regions to provide the CFC 

information to support the preparation of the revenue accrual. The CFC provided 

the regions with quarterly instructions for verifying certain SSC information, 

adding any new information and financially closing the accounts for closed SSCs. 
16-P-0217 11

We found that the regions did not always provide all the needed information. 

Without complete information, the SSC revenue calculation was not as accurate 

as it could have been and may have misstated the financial statements and the 

financial status of the SSCs.

The EPA’s Resource Management Directive System 2550D-09-P1 directs the 

regional financial management offices and program offices to provide the CFC 

with information on a quarterly basis with respect to new and/or amended SSCs, 

credits, and other information to support the calculation of SSC revenue. Figure 2 

summarizes the reasons why the CFC did not have all information needed to 

accurately calculate SSC revenue.

Figure 2

Source: OIG-generated.

Regions Did Not Provide All Information Needed

The CFC’s quarterly correspondence with the regions instructed them to provide 

quarterly updated SSC information, including the estimated cost amount, state cost 

share percentage, and SSC credit additions for the quarter. The CFC also asked the 

regions to financially close accounts listed as “closed” on the spreadsheet.

We determined that the regions did not provide the CFC with the information 

needed in 15 of the 45 SSCs we reviewed. For example, the regions did not always:

 Update the SSC-estimated project cost amount after it made an amendment.

 Separate a site with multiple SSCs onto multiple lines of the accrual 

spreadsheet to provide more accurate accrual calculations.

 Notify CFC whether SSC expenses are allocated to the proper line on the 

accrual spreadsheet.

 Notify CFC whether a site credit needs to be allocated to multiple lines of 

the accrual spreadsheet, as appropriate.

 Report cost share payments made with in-kind contributions.

 Provide SSC financial closeout information, such as final billing and 

collections, SSC final project cost amount, appropriated disbursements,

and reimbursable disbursements.

CFC did not have all information needed to accurately calculate SSC revenue

Regions did not provide all 

information needed

SSC calculation should 

separately identify 

financially closed SSCs

Regions did not properly 

use in-kind payments in 

calculating SSC revenue 
16-P-0217 12

For a more accurate quarterly SSC accrual, we believe the CFC should also 

instruct the regions to:

 Separate a site with multiple SSCs or allocate a credit for multiple SSCs to 

multiple lines on the accrual spreadsheet.

 Report cost share payments received with in-kind contributions, which are 

needed to calculate an accurate accrued receivable for unbilled costs.

Without complete and up-to-date SSC information, the CFC revenue calculation 

was not as accurate as it could have been and may have misstated the financial 

statements and the financial status of the SSCs. We found errors in the fiscal year 

2015 first quarter SSC accrual spreadsheet for some regions due to:

 Misstatements of SSC-estimated cost amounts (three regions).

 Omission of in-kind contributions, which overstated the accrued 

receivable for unbilled costs (two regions).

 Financial closing information not properly entered (eight regions).

 Misstatements of earned and unearned revenue (four regions).

SSC Calculation Should Separately Identify Financially Closed SSCs

The SSC accrual spreadsheet separated some of the SSCs into “active” and 

“administratively closed” categories but did not separately disclose “financially 

closed” SSCs. According to regional personnel, an SSC that is administratively 

closed has completed the remedial action and the state has provided all 

assurances. According to the EPA’s financial policy, an SSC financial closeout is 

complete when the EPA:

 Completes all billings, collections, credits, refunds and transfers.

 Records all disbursements in the agency’s financial system of record.

 Reclassifies appropriated and reimbursable disbursements when 

applicable.

 Adjusts advances in the agency’s financial system of record to equal zero.

 Completes a final amendment to the SSC or closeout agreement that all 

appropriate parties have signed.

Some regions had differing definitions of “administratively closed” and “financially 

closed,” and other regions stated that the two terms had the same meaning. Due to 

the differing definitions, the SSCs in the “administratively closed” section of the 

spreadsheet may not be financially closed. Therefore, we believe the SSC accrual 

spreadsheet should separately identify the financially closed SSCs. The CFC could 

then determine if the spreadsheet had all the final information and the appropriate 

columns equal zero as they should for a financially closed SSC. When a region

financially closes an SSC, it may make additional appropriated funds available.
16-P-0217 13

Regions Did Not Properly Use In-Kind Payments in Calculating

SSC Revenue

The regions did not properly apply in-kind payments to the SSC revenue 

calculations. If the state and EPA enter into a support agency cooperative 

agreement, 40 CFR Part 35, Subpart O, Section 35.6815, allows a state to pay for 

its cost share with in-kind services. EPA guidance directs the regions to provide 

the CFC information on new or amended SSCs, credits and other information to 

support the preparation of the SSC revenue estimate. However, EPA guidance did 

not specifically require the regions to report in-kind payment information to the 

CFC, and the CFC did not include in-kind payments in the SSC accrual 

calculation. We identified in-kind payments totaling $5,379,477. By not reporting 

in-kind payments, the CFC overstated the estimate for unbilled SSC costs and 

may have misstated the financial statements and the financial status of the SSCs.

Conclusion

The EPA should improve its financial oversight of SSCs to increase monitoring and 

prevent SSC expenses from exceeding the estimated project costs. With improved 

monitoring, the EPA could reduce the risk of: interrupting an ongoing cleanup, 

delaying the environmental cleanup and public health protection, or making 

expenditures for which the state is not contractually bound to share in paying. In 

addition, the EPA should prepare a more accurate SSC revenue estimate and 

financial status to financially close SSCs more timely and to improve the potential 

availability of appropriated funds. With a more accurate revenue estimate, the EPA 

can prepare more accurate financial statements and provide the regions with more 

precise information to help improve their oversight of SSCs. Figure 3 highlights the 

benefits of improved financial oversight.

Figure 3

Source: OIG-generated

We believe the EPA could improve its oversight of SSCs by developing additional 

guidance for the regions to provide quarterly SSC information. Timelier financial 

closing of SSCs may improve the availability 

of appropriated funds needed to improve the 

environment and protect human health. We 

identified SSCs with available reimbursable 

funds with the potential to increase 

appropriated funds by $2.3 million.

Improved financial 

oversight

Timelier financial closing 

of SSCs

Improve availability of 

appropriated funds

We identified SSCs with available 

reimbursable funds with the 

potential to increase appropriated 

funds by $2.3 million.
16-P-0217 14

Recent Agency Actions Prompted by OIG Work

In response to our discussion document, the CFC in February 2016, provided us 

its additional quarterly guidance to the regions to provide the CFC in-kind 

contributions by SSC and identify financially closed SSCs.

During the course of our audit, in November 2015, the Office of Superfund 

Remediation and Technology Innovation issued new national model provisions 

for use in SSCs. The new model language addressed the issue raised during our 

audit that SSC expenditures should not exceed the estimated project cost. The 

new model states that the EPA may not expend appropriated funds in excess of 

the cost estimate, and any increase in the cost estimate requires an amendment to 

the SSC. We believe this provision in the new model reinforces the EPA’s policy 

that the SSC cost estimate represents a spending ceiling; an SSC amendment is 

required to increase the ceiling before the EPA can continue to fund-finance a 

remedial action. Although the new model addresses this issue, we believe that the 

EPA needs to emphasize to the regions the importance of monitoring SSC costs to 

ensure they do not exceed the SSC cost estimate.

Recommendations

We recommend that the Assistant Administrator for Land and Emergency 

Management:

1. Emphasize to the regions the importance of monitoring total SSC costs to 

ensure they do not exceed the SSC cost estimate.

2. Develop and implement uniform regional guidance for monitoring 

obligations and expenditures of SSC costs.

3. Develop uniform SSC financial closeout procedures for the regions.

We recommend that the Chief Financial Officer:

4. Develop and implement additional quarterly accrual guidance for the 

regions to provide the CFC:

 The in-kind contributions by SSC needed for an accurate SSC 

accrual calculation.

 The financially closed SSCs for the CFC to list in a separate 

section on the accrual spreadsheet.

 The amounts of final appropriated disbursements and reimbursable 

disbursements upon completion of the SSC final closeout and 

reclassification of appropriated and reimbursable disbursements, as 

needed.
16-P-0217 15

5. Direct the CFC to change the SSC accrual spreadsheet by separating a site 

with multiple SSCs onto multiple lines of the spreadsheet, allocating 

expenses to the proper SSC line on the spreadsheet, and adding a column 

to track in-kind contributions.

Agency Comments and OIG Evaluation

The agency generally agreed with the OIG’s review conclusions and supported 

the need to emphasize the importance of SSC financial management in the 

Superfund remedial program. The agency agreed with all our findings and 

recommendations, and provided acceptable high-level intended corrective actions 

and estimated completion dates that meet the intent of the recommendations. 

The corrective actions include issuing new model SSC provisions regarding the 

monitoring of SSC costs, conducting outreach to EPA regions and states to ensure 

knowledge of the provisions, and developing tools to assist regions with SSC 

closeout procedures. Corrective actions also include making various 

improvements to the SSC quarterly guidance and accrual calculation. The EPA 

stated that it reviewed the SSCs from all 10 regions and initiated work to update 

the model provisions prior to the OIG’s audit. However, the EPA’s memorandum 

of January 16, 2015, reporting the results of its review, did not include the issue of 

SSC expenditures exceeding the estimated project cost. 

We agree the agency has completed acceptable corrective actions for 

Recommendations 2, 4 and 5, and those recommendations are closed with all 

agreed-to actions completed. Recommendations 1 and 3 are open with agreed-to 

actions pending.

The agency’s response to the draft report is in Appendix C.
16-P-0217 16

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 14 Emphasize to the regions the importance of 

monitoring total SSC costs to ensure they do not 

exceed the SSC cost estimate.

O Assistant Administrator for 

Land and Emergency 

Management

9/30/16

2 14 Develop and implement uniform regional guidance 

for monitoring obligations and expenditures of SSC 

costs.

C Assistant Administrator for 

Land and Emergency 

Management

12/31/15

3 14 Develop uniform SSC financial closeout 

procedures for the regions.

O Assistant Administrator for 

Land and Emergency 

Management

12/31/16 $2,271 $2,271

4 14 Develop and implement additional quarterly accrual 

guidance for the regions to provide the CFC: 

 The in-kind contributions by SSC needed for 

an accurate SSC accrual calculation.

 The financially closed SSCs for the CFC to list 

in a separate section on the accrual 

spreadsheet.

 The amounts of final appropriated 

disbursements and reimbursable 

disbursements upon completion of the SSC 

final closeout and reclassification of 

appropriated and reimbursable

disbursements, as needed.

C Chief Financial Officer 3/31/16

5 15 Direct the CFC to change the SSC accrual 

spreadsheet by separating a site with multiple 

SSCs onto multiple lines of the spreadsheet,

allocating expenses to the proper SSC line on the 

spreadsheet, and adding a column to track in-kind 

contributions.

C Chief Financial Officer 3/31/16

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

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

U = Recommendation is unresolved with resolution efforts in progress.
16-P-0217 17

Appendix A

Details on Scope and Methodology

To gain an understanding of the EPA’s processes for the financial management of SSCs, we:

 Reviewed applicable laws, regulations, policies, guidance and relevant prior audit reports.

 Reviewed the EPA’s procedures for managing SSCs.

 Interviewed personnel involved with SSCs in the Office of the Chief Financial Officer, 

including in the CFC; the Office of Superfund Remediation and Technology Innovation 

within OLEM; and regional finance offices and regional Superfund program offices.

 Reviewed the EPA’s fiscal year 2014 management integrity assurance letters from the 

regions, program offices and finance centers for reported internal control weaknesses 

related to SSCs.

We tested the effectiveness of the EPA’s internal controls designed to comply with SSC 

regulations and guidance, including the cost share agreement terms, SSC billings, collections, 

credits and in-kind payments, allocation of appropriated and reimbursable funds, and financial 

closings. We performed an extensive review of 45 randomly sampled SSCs with total estimated 

costs of $656,257,148 from a universe of 504 SSCs with total estimated costs of $8,775,378,724. 

Each region was represented in our 45 samples, which included from one to nine sample SSCs 

per region. Since the 45 samples included only four SSCs with state credits totaling $4,759,041, 

we randomly sampled and tested an additional 11 SSCs with state credits totaling $10,966,376, 

to determine whether the EPA properly approved and applied the credits to the SSCs and the 

accrual calculation. The EPA entered into the sampled contracts from 1982 through 2013.

We also reviewed CFC’s accrual spreadsheet for anomalies and errors, such as:

 SSCs with remedial action expenditures exceeding the approved contract cost ceiling.

 Total estimated project cost on the accrual spreadsheet not agreeing with the SSC, most 

recent SSC amendment, or termination amendment.

 SSCs listed as financially closed without reclassifying the appropriated and reimbursable 

expenditures to the proper amounts.

We accessed billing, collection, obligation and disbursement information in Compass Financials, 

the agency’s accounting system. This data materially affected our findings, conclusions, and 

recommendations. We did not review the internal controls over Compass Financials from which 

we obtained financial data, but relied on the review conducted during the audit of the EPA’s 

fiscal year 2014 financial statements. We did not assess the reliability of data in any other 

information systems because using the data did not materially affect our findings, conclusions or 

recommendations.

Prior Reports Reviewed

We researched prior EPA OIG and U.S. Government Accountability Office reports related to 

SSCs. We did not identify any U.S. Government Accountability Office reports with information 
16-P-0217 18

directly related to our review. We did review eight prior EPA 

OIG reports, listed in Table A-1. These eight reports, of the 

EPA’s annual consolidated financial statement audits,

disclosed SSC-related findings regarding the inaccurate 

recording and reconciliation of SSC entries in the general 

ledger and data errors in the SSC accrual spreadsheets. The 

fiscal year 2009 report noted SSCs as a material weakness 

because the EPA did not properly review the calculations used 

to reconcile unearned revenue. Although the EPA’s corrective actions in fiscal year 2010 

reduced the material weakness to a significant deficiency, the EPA needed to make further 

improvements in reviewing the calculations. The agency agreed with each report’s findings and 

recommendations and completed corrective actions for all 18 recommendations. 

Table A-1: Prior reports reviewed

Report title Report no. Date

Audit of EPA’s Fiscal 2013 and 2012 

Consolidated Financial Statements EPA OIG 14-1-0039 December 16, 2013

Audit of EPA’s Fiscal 2010 and 2009 

Consolidated Financial Statements EPA OIG 11-1-0015 November 15, 2010

Audit of EPA’s Fiscal 2009 and 2008 

(Restated) Consolidated Financial Statements EPA OIG 10-1-0029 November 16, 2009

Audit of EPA’s Fiscal 2008 and 2007 

Consolidated Financial Statements EPA OIG 09-1-0026 November 14, 2008

Audit of EPA’s Fiscal 2005 and 2004 

Consolidated Financial Statements EPA OIG 2006-1-00015 November 14, 2005

Audit of EPA’s Fiscal 2004 and 2003 

Consolidated Financial Statements EPA OIG 2005-1-00021 November 15, 2004

Audit of EPA’s Fiscal 2003 and 2002 

Consolidated Financial Statements EPA OIG 2004-1-00021 November 21, 2003

Audit of EPA’s Fiscal 2002 and 2001 

Consolidated Financial Statements EPA OIG 2003-1-00045 January 29, 2003

Source: OIG analysis.

Prior reports disclosed 

that inaccurate recording 

and reconciliation of SSC 

entries has been a 

continuing problem since 

2002.
16-P-0217 19

Appendix B

SSCs With Available Reimbursable Funds

Site number Available reimbursable funds

0204 $6,231

0289 113,813

0525 21,740

0534 824,164

0554 19,768

05DK 245,153

05GU 135,070

05H5 98,629

05L3 28,846

05N1 101,553

05T2 293,132

05W2 63,286

05W6 6,021

0611 100

067E 55,774

06DB 1,832

06DF 6,704

06E5 23,009

0944 166,408

09H2 59,297

$2,270,530

Source: OIG analysis of EPA data.
16-P-0217 20

Appendix C

Agency Response to Draft Report

(Received May 6, 2016)

MEMORANDUM

SUBJECT: Response to Office of Inspector General Draft Report No. OA-FY15-0054

“EPA’s Financial Oversight of Superfund State Contracts Needs Improvement,” 

April 1, 2016

FROM: Mathy Stanislaus, Assistant Administrator /s/

Office of Land and Emergency Management

David A. Bloom, Deputy Chief Financial Officer /s/

Office of the Chief Financial Officer

TO: Arthur A. Elkins, Jr.

Inspector General

Thank you for the opportunity to respond to the issues and recommendations in the subject audit 

report. Following is a summary of the agency’s overall position, along with its position on each 

of the report recommendations. For those report recommendations with which the agency agrees, 

we have provided high-level intended corrective actions and estimated completion dates to the 

extent we can. For your consideration, we have included a Technical Comments Attachment to 

supplement this response.

AGENCY’S OVERALL POSITION

The agency generally agrees with the OIG’s review, and supports the need to emphasize the 

importance of Superfund State Contract financial management in the Superfund remedial 

program. The agency appreciates the OIG recognition of the 2015 Model Provisions for SSCs in 

the Recent Agency Actions Prompted by OIG Work section of the draft report. However, the 

agency would like to clarify that the work to update the model provisions was initiated prior to 

the OIG’s audit. In 2014, OLEM’s Office of Superfund Remediation and Technology Innovation 

reviewed SSCs from all ten regions, and found a need to revise the twenty-five year old model 

provisions to better protect both EPA and state interests. OLEM convened a workgroup of EPA 

and state representatives to update the model SSC provisions, and to clarify some of the issues 

noted during the 2014 SSC review (see Memorandum: Results of OSRTI Review of SSCs and 

Amendments and Next Steps, January 16, 2015). The agency is using training opportunities, as 

well as regular national meetings with our state co-regulators, to ensure awareness of the model 

provisions and national program expectations for their usage. 
16-P-0217 21

The agency believes the 2015 SSC Model Provisions address the important issues raised in the 

OIG’s draft report. Recommendation 1, related to ensuring SSC costs do not exceed cost 

estimates, is dealt with in two separate provisions in the 2015 Model. First, Provision 28 - SSC 

Amendments states “Amendments are required when... project costs exceed the remedial action 

cost estimate.” A clear statement like this was not included in the original 1990 model. In 

addition, Provision 17D - Periodic Financial Review was added to ensure regular 

communication between the region and the state related to the cost of the remedy. The provision 

states: 

“Once expenditures incurred are [“$[amount]” or “[number]% of the estimate”], the 

parties agree to consult on the necessity to amend the cost estimate. Failure to consult 

does not preclude amendments to this Contract to amend the cost estimate.” 

Recommendation 2 highlights the need for monitoring obligations and expenditures of SSC 

costs. The EPA and the states agreed this was an important issue, and added Provision 17D 

Periodic Financial Review to the national model. During the model provision workgroup, states 

and regions noted that remedial actions at each site are incredibly different, making it hard to 

specify a uniform timeframe for cost monitoring. Therefore, the provision text below enables the 

region and state to determine the appropriate frequency for financial monitoring and 

consultation: 

“EPA and the State are both responsible for reviewing cumulative expenditures for the 

work provided under this SSC on a [specify time frequency] basis. Such a review may 

also include a review of credits and in-kind services, use of contingency funds, cost share 

payments, and SSC cost estimates. Once expenditures incurred are [“$[amount]” or 

“[number]% of the estimate”], the parties agree to consult on the necessity to amend the 

cost estimate.”

Recommendation 3 deals with creating closeout procedures for SSCs. One issue unaddressed in 

the OIG’s draft report is that some regions have left SSCs open beyond the end of remedial 

action to keep valid the state’s assurance to provide for the operation and maintenance of 

implemented remedial actions for the expected life of such actions. Through the model provision 

workgroup process, there is a pathway to enable the region and the state to come to final terms 

with the implementation and cost of the remedy while keeping the SSC active with respect to 

O&M implementation. 

There are two components associated with the closure of an SSC in the model provisions: 

Administrative Closure and Final SSC Conclusion. Administrative Closure refers to most 

activities associated with implementation of the SSC. These include satisfactory completion of 

the response activities under the SSC, final financial reconciliation, transfer of property, and 

assumption of responsibility for all future O&M by the state. Administrative Closure must be 

documented through an amendment to the SSC.

Under the model provisions, the SSC remains in effect until O&M is no longer required at the 

site, a potentially responsible party has taken over the O&M, or the SSC is terminated for other 
16-P-0217 22

reasons. At this point, Final SSC Conclusion may take place, which must also be documented by 

a final amendment to the SSC.

The agency feels that it may be helpful to develop additional tools to assist regions as they 

prepare for Administrative Closure and Final Conclusion of SSCs. Therefore, the agency will 

work to develop tools to help regions complete all steps necessary to ensure SSCs are closed in a 

timely and accurate way.

AGENCY’S RESPONSE TO REPORT RECOMMENDATIONS

Agreements

No. Recommendation High-Level Intended 

Corrective Action(s)

Estimated Completion by 

Quarter and FY

1 Emphasize to the regions 

the importance of 

monitoring total SSC 

costs to ensure they do 

not exceed the SSC cost 

estimate.

1.1 Issue new model 

provisions to require SSC 

amendments when costs 

exceed SSC amendment.

Complete, 1st quarter 

FY2016

1.2 Conduct outreach to 

EPA regions and states to 

ensure knowledge of new 

model provisions, including 

the provision requiring 

amendment for cost 

increases.

SSC Presentation at National 

Association of Remedial 

Project Managers, 3rd quarter 

FY2016

SSC Presentation at 

Association of State and 

Territorial Solid Waste 

Management Officials 

Superfund and Brownfields 

Symposium, 4th quarter 

FY2016 

2 Develop and implement 

uniform regional 

guidance for monitoring 

obligations and 

expenditures of SSC 

costs.

1.1 Issue new model 

provisions requiring 

periodic financial review of 

SSCs.

Complete, 1st quarter 

FY2016

3 Develop uniform SSC 

financial closeout 

procedures for the 

regions.

1.1 Issue new model 

provisions to address 

expectations for final 

financial reconciliation, 

administrative closure and 

final conclusion of SSCs.

Complete, 1st quarter 

FY2016

1.2 Develop tools to assist 

regions with steps needed to 

achieve final financial 

reconciliation, 

administrative closure and 

final conclusion.

1

st quarter, FY2017
16-P-0217 23

4 Develop and implement 

additional quarterly 

accrual guidance for the 

regions to provide the 

CFC:

4.1 The in-kind 

contributions by SSC 

needed for an accurate 

SSC accrual calculation.

4.2 The financially closed 

SSCs for the CFC to list 

in a separate section on 

the accrual spreadsheet.

4.3 The amounts of final 

appropriated 

disbursements and 

reimbursable 

disbursements upon 

completion of the SSC 

final closeout and 

reclassification of 

appropriated and 

reimbursable 

disbursements, as needed.

4.1 Request regional update 

of in-kind contributions in 

accrual spreadsheet.

4.2 Add closed SSCs to 

separate section of accrual 

spreadsheet.

4.3 Adjust quarterly 

correspondence to ensure 

the regions are 

appropriately categorizing 

SSC sites. 

Complete, 2nd quarter 

FY2016

Complete, 2nd quarter 

FY2016

Complete, 2nd quarter 

FY2016

5 Direct the CFC to change 

the SSC accrual 

spreadsheet by separating 

a site with multiple SSCs 

onto multiple lines of the 

spreadsheet, allocating 

expenses to the proper 

SSC line on the 

spreadsheet, and adding a 

column to track in-kind 

contributions.

Update accrual spreadsheet 

to separate sites with 

multiple SSCs, and add a 

column to track in-kind 

contributions.

Complete, 2nd quarter 

FY2016

If you have any questions regarding this response, please contact Ellyn Fine, in OLEM’s Office 

of Superfund Remediation and Technology Innovation, at (703) 603-8714 or Nic Grzegozewski, 

OCFO Audit Follow-up Coordinator, at (202) 564-2292. 

Attachments:

1. Technical Comments

2. Memorandum: Results of OSRTI Review of SSCs and Amendments and Next Steps, January 

16, 2015
16-P-0217 24

cc: Barry Breen, OLEM

 Nitin Natarajan, OLEM 

James Woolford, OLEM

Jennifer Wilbur, OLEM

Kecia Thornton, OLEM

Art Flaks, OLEM

Ellyn Fine, OLEM

Howard Osborne, OCFO 

Stefan Silzer, OCFO 

Jeanne Conklin, OCFO 

Meshell Jones-Peeler, OCFO 

Richard Gray, OCFO

Leo Gueriguian, OCFO

Carol Terris, OCFO

Nic Grzegozewski, OCFO

Greg Luebbering, OCFO

Judi Doucette, Region 1

Jennifer Chernowski, Region 2

Susan Janowiak, Region 3

David Keefer, Region 4

Tom Short, Region 5

Susan Jenkins, Region 6

John Phillips, Region 7

Russell Leclerc, Region 8

David Wood, Region 9

Carrie Williams, Region 10

Regional Audit Follow-Up Coordinators, Regions 1–10
16-P-0217 25

Appendix D

Distribution

Office of the Administrator 

Chief Financial Officer 

Assistant Administrator for Land and Emergency Management

Regional Administrators, Regions 1–10

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Associate Chief Financial Officer 

Principal Deputy Assistant Administrator for Land and Emergency Management 

Controller, Office of the Controller, Office of the Chief Financial Officer 

Deputy Controller, Office of the Controller, Office of the Chief Financial Officer 

Director, Office of Budget, Office of the Chief Financial Officer

Director, Financial Services Division, Office of the Controller, Office of the Chief Financial

Officer

Director, Cincinnati Finance Center, Office of the Chief Financial Officer

Director, Office of Superfund Remediation and Technology Innovation, Office of Land and 

Emergency Management

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

Audit Follow-Up Coordinator, Office of Land and Emergency Management

Audit Follow-Up Coordinators, Regions 1–10