U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Audit Report 

Improved Data Integrity Needed 

for the Integrated Contracts 

Management System 

 Report No. 10-P-0144 

 June 14, 2010 
 

 

 

 

 

 

 

 

Abbreviations 

COTS Commercial Off-the-Shelf 

EAS EPA Acquisition System 

EPA U.S. Environmental Protection Agency 

FAR Federal Acquisition Regulation 

FARA Federal Acquisition Reform Act 

FASA Federal Acquisition Streamlining Act 

FPDS-NG Federal Procurement Data System – Next Generation 

GAO U.S. Government Accountability Office 

GSA General Services Administration 

ICMS Integrated Contracts Management System 

NIST National Institute of Standards and Technology 

OAM	 Office of Acquisition Management 

OAM-ITSC Office of Acquisition Management – Information Technology 

Service Center 

OIG Office of Inspector General 

OMB Office of Management and Budget 
 

 

 

 

U.S. Environmental Protection Agency 10-P-0144 

June 14, 2010 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

The Office of Inspector 

General contracted with 

Williams, Adley & Company,

LLP, to conduct a data 

integrity audit of the 

Integrated Contracts

Management System (ICMS). 

We sought to determine 

whether data within the ICMS 

complied with the system edit 

and validation checks 

designed to control data entry 

and quality. 

Background 

The U.S. Environmental 

Protection Agency’s (EPA’s) 

Office of Acquisition 

Management (OAM) supports 

the procurement needs of 

program offices throughout 

EPA and utilizes the ICMS to 

facilitate that process. The 

ICMS generates documents 

critical to the procurement 

process and recorded contract 

values totaling approximately 

$15 billion for Fiscal Year 

2007 and $17.5 billion for 

Fiscal Year 2008. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2010/ 

20100614-10-P-0144.pdf 

Improved Data Integrity Needed for the 

Integrated Contracts Management System 

 What Williams, Adley & Company, LLP, Found 

EPA needs to strengthen ICMS data integrity controls to increase the reliability of 

the data for management reporting. In particular, ICMS data contain exceptions 

to data quality rules defined in the ICMS data dictionary and OAM-defined 

system checks. ICMS data also contain anomalies that cast suspicion over the 

validity of processed transactions. These anomalies include transactions 

processed on nonstandard workdays and dollar values that are unusually high. 

Furthermore, discrepancies noted between OAM-defined system edit and 

validation checks and the ICMS data dictionary call into question what actual 

information should be entered into the ICMS for certain fields. The above 

conditions are caused by a breakdown in controlling data entry or in maintaining 

data and associated system documentation. 

As noted during our field work, EPA is replacing the ICMS with a new 

acquisition system called the EPA Acquisition System (EAS). While it may not 

be practical for EPA to address these weaknesses within the ICMS, EPA should 

take proactive steps to strengthen its data integrity processes so these similar 

weaknesses do not exist in the EAS. 

 What Williams, Adley & Company, LLP, Recommends 

Williams, Adley & Company, LLP, recommends that the Director, OAM: 

•	 Take immediate action to implement recommendations to strengthen 

plans for migrating data from the ICMS to the EAS as outlined in OIG 

Report No. 10-P-0071, Plans to Migrate Data to the New EPA 

Acquisition System Need Improvement. 

•	 Conduct and document a review of the EAS data quality controls to 

ensure all required edit checks are identified and recorded in the EAS 

system documentation and implemented in the system. 

•	 Conduct and document a review of the EAS system development and 

program change control procedures to ensure that the EAS data 

dictionary is updated as database fields, and corresponding edit and 

validation checks are added or modified within the system. Implement 

all needed changes to the procedures. 

The Agency generally agreed with the findings and recommendations. 
 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

June 14, 2010 

MEMORANDUM 

SUBJECT:	 Improved Data Integrity Needed for the Integrated Contracts 

Management System

 Report No. 10-P-0144 

FROM:	 Rudolph M. Brevard 

Director, Information Resources Management Assessments 

Office of Inspector General 

TO: John Gherardini, Deputy Director 

Office of Acquisition Management 

Office of Administration and Resources Management 

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

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

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

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

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

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

resolution procedures. 

The estimated cost of this report, which includes contract costs and OIG contract management 

oversight, is $424,969. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. You should include a corrective actions plan for agreed-upon 

actions, including milestone dates. We have no objections to the further release of this report to 

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

If you or your staff have any questions regarding this report, please contact me at (202) 566-0893 

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

kaplan.harry@epa.gov. 
June 14, 2010 

MEMORANDUM 

SUBJECT: Improved Data Integrity Needed for the Integrated Contracts 

Management System 

FROM: Robert J. Fulkerson 

Senior IT Audit Manager 

Williams, Adley & Company, LLP 

THRU:	 Rudolph M. Brevard 

Director, Information Resources Management Assessments 

Office of Inspector General 

TO: John Gherardini, Deputy Director 

Office of Acquisition Management 

Office of Administration and Resources Management 

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

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

improved data integrity needed for the Integrated Contracts Management System. 

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

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

or kaplan.harry@epa.gov. 
 

 

 

 

 

 

 

 

 

 

Improved Data Integrity Needed for the 10-P-0144 

Integrated Contracts Management System 

Table of Contents 

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

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

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

Findings ....................................................................................................................... 3 

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

Agency Comments and OIG Evaluation ................................................................... 4 

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

Appendices 

A Exceptions to Data Dictionary Defined Edit & Validation Checks.............. 6 

B Exceptions to OAM Information Technology Service Center 

Defined Edit & Validation Checks.................................................................. 8 

C Data Anomalies ............................................................................................... 10 

D Edit & Validation Checks that Require Updating in Data Dictionary.......... 12 

E Agency Response ........................................................................................... 16 

F Distribution ...................................................................................................... 18 
 10-P-0144 

Purpose 

We sought to determine whether data within the Integrated Contracts Management System 

(ICMS) complied with the system edit and validation checks designed to control data entry and 

quality. 

Background 

The U.S. Environmental Protection Agency’s (EPA’s) Office of Inspector General (OIG) 

contracted with Williams, Adley & Company, LLP (Williams Adley), to conduct this audit. 

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

offices throughout EPA and utilizes the ICMS to facilitate that process. The ICMS generates 

documents critical to the procurement process and recorded contract values totaling 

approximately $15 billion for fiscal year 2007 and $17.5 billion for fiscal year 2008. The system 

also provides data to the General Services Administration’s Federal Procurement Data System – 

Next Generation (FPDS-NG) to support congressional reporting and public access to acquisition 

data. The ICMS populates the OAM Data Mart which provides reporting acquisition activities, 

and can assist in managing procurement operations, and assists Program Offices in complying 

with set-aside requirements. Data edit and validation checks have been built into the ICMS to 

help ensure the accuracy of data that users enter into the system. 

Federal guidance, including the National Institute of Standards and Technology (NIST) and the 

Office of Management and Budget (OMB), requires EPA to consistently apply data entry 

controls to ensure the integrity of their information technology systems and data, and to 

accurately report contractual actions to the FPDS. Specifically, OMB Circular A-127, Financial 

Management Systems, states that internal controls over data entry and transaction processing 

shall be applied consistently throughout the system to ensure the validity of information. NIST 

Special Publication 800-30, Risk Management Guide for Information Technology Systems, states 

that system and information owners are responsible for ensuring that proper controls are in place 

to address integrity of data they own. OMB M-06-28, Reporting Small Business Contracting 

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

to FPDS and verifying the accuracy of such data. Lastly, Federal Acquisition Regulation (FAR) 

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

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

The EPA Office of Acquisition Management, Information Technology Service Center (ITSC) is 

responsible for supporting the ICMS application, associated edit and validation checks, and 

system documentation. OAM-ITSC is based in Washington, DC, with a smaller number of staff 

residing in Research Triangle Park, North Carolina, and is in the process of replacing ICMS with 

the EPA Acquisition System (EAS), a commercial off-the-shelf (COTS) acquisition system. As 

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

Scope and Methodology 

We conducted our review in accordance with generally accepted government auditing standards. 

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

1 
 

 

10-P-0144 

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

objectives. Additionally, we used the guidance contained in Government Accountability Office 

(GAO) Guidance for Assessing the Reliability of Computer-Processed Data for evaluating the 

database processes. The evidence obtained from our audit tests and processes provides a 

reasonable basis for our findings and conclusions. 

From the 1,552 ICMS database fields, we identified 207 fields that are considered critical highrisk fields within the ICMS database. The fields were chosen due to their Financial, Compliance 

or Operational significance. This listing was further refined to identify 79 Financial and 

Compliance fields, for purposes of testing. Williams Adley defined critical high-risk fields 

utilizing the following criteria: 

•	 Financial - Data that are critical to the accurate recording of monetary amounts for 

contract solicitations, awards, contract documents, contract modifications, and task 

orders/delivery orders. 

•	 Compliance - Data that are critical to program office compliance with federal laws and 

regulations, Federal Acquisition Regulations (FAR), the Federal Acquisition 

Streamlining Act (FASA), the Federal Acquisition Reform Act (FARA), and the Office 

of Federal Procurement Policy Act as amended Competition in Contracting Act of 1984 

(41 USC); and EPA procurement and acquisition policies and procedures, including setasides for small business and socio-economic classes. 

Williams Adley obtained a data extract from the ICMS database in September 2008 and 

imported all records for the 79 Financial and Compliance fields into a computer-assisted auditing 

tool to prepare for testing. Edit and validation checks for each of the 79 fields were identified 

from the current ICMS data dictionary dated February 28, 2005, and an Oracle field attributes 

document OAM provided. Williams Adley performed testing to evaluate record compliance 

with the data dictionary and database defined edit and validation checks for each of the 79 fields. 

Testing included, but was not limited to, evaluation of the following: 

•	 Maximum number of characters •	 Null values (mandatory vs. nonmandatory fields) •	 Data Type (alpha numeric, character, numeric, date) •	 Evaluation of positive, negative, and zero entries •	 Evaluation of Max values, variance, and standard deviation 

Williams Adley inquired with OAM-ITSC to obtain clarification and assurance to our 

understanding of the edit and validation checks contained in the data dictionary. This resulted in 

requesting OAM-ITSC to provide updated edit and validation checks for the 79 subject fields. 

We performed tests of the data contained in each field to evaluate record compliance with the 

OAM-ITSC defined checks for each of the 79 fields. Williams Adley then performed a 

comparison between OAM-ITSC provided checks and the data dictionary to identify variances 

between the data dictionary and current checks. Lastly, we reviewed the data statistics to 

identify anomalous records. 

2 
 

 

10-P-0144 

Findings 

The ICMS data contains exceptions to data quality rules defined in the ICMS data dictionary or 

OAM-defined system checks. ICMS data also contain anomalies that cast suspicion over the 

validity of processed transactions. These anomalies include transactions processed on 

nonstandard workdays and dollar values with unusually high values. Furthermore, discrepancies 

noted between ITSC-defined system edit and validation checks and the ICMS data dictionary 

call into question what actual information should be entered into ICMS for certain fields. Data 

integrity within the ICMS needs strengthening to increase its (1) reliability for management 

reporting and (2) accuracy before suspected errors are transferred into EPA’s new acquisition 

system. 

These weaknesses exist in part due to: 

•	 A breakdown in the process for controlling data entry, which are necessary to control 

data input; 

•	 Lack of identifying and implementing edit and validation checks during system
 

implementation; and 

•	 Inconsistent documenting of edit and validation checks in the ICMS data dictionary as 

data requirements change. 

Sixty-four percent 

(50 of 79) of the 

ICMS fields passed 

all four data integrity 

tests. The remaining 

data fields failed at 

least one or more 

tests. The noted 

graph depicts the 

breakdown of ICMS 

data field errors by 

the number of tests 

failed. Appendices 

A through D provide 

the details for each 

test performed and 

the listing of fields 

which failed the 

ICMS Data Errors By Number of 

Tests Failed 

15 13 

1 

50 

0 

10 

20 

30 

40 

50 

60 

Failed 1 

Tests 

Failed 2 

Tests 

Failed 3 

Tests 

No Errors 

particular test. 

These conditions have the potential of reducing EPA management’s ability to rely on ICMS data 

for decision making purposes, due to possible inaccuracies in reporting and output data. As a 

critical application used to support acquisition activities for all program offices of EPA, as well 

for reporting to the General Service Administration’s (GSA’s) FPDS-NG management emphasis 

is needed to address these data integrity issues in a comprehensive manner. 

3 
 10-P-0144 

As noted during our fieldwork, EPA is replacing ICMS with a new acquisition system called the 

EPA Acquisition System (EAS). While it may not be practical for EPA to address these 

weaknesses within ICMS, EPA management should take proactive steps to strengthen its data 

integrity processes so these similar weaknesses do not exist in the EAS. 

Recommendations 

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

Management, within the Office of Administration and Resources Management: 

1.	 Take immediate action to implement recommendations to strengthen plans for migrating 

data from the ICMS to the EAS as outlined in Office of Inspector General Quick 

Reaction Report No. 10-P-0071, Plans to Migrate Data to the New EPA Acquisition 

System Need Improvement. 

2.	 Conduct and document a review of the EAS application’s data quality controls to ensure 

all required edit checks are identified and recorded in the EAS system documentation and 

implemented in the system. 

3.	 Conduct and document a review of EAS system development and program change 

control procedures to ensure the EAS data dictionary is updated as database fields, and 

corresponding edit and validation checks are added or modified within the system. 

Implement all needed changes to the procedures. 

Agency Comments and OIG Evaluation 

In general, EPA agreed with our findings and recommendations. However, EPA felt that the 

report did not accurately reflect the Agency's responsibilities for maintaining the system 

documentation, since the new acquisition is built from a commercial-off-the-shelf product. While 

we agree that EPA has limited responsibility for maintaining the manufacturer's portion of the 

system software, EPA has taken significant steps to either configure the software to meet its 

needs or build interfaces so the software could work with existing EPA applications. Therefore, 

to the extent that EPA engages in these activities, it is incumbent upon management to ensure it 

has effective control processes in place to capture and document these changes in the EAS 

system documentation. 

4 
 

 

 

 

 

 

 

 

1 

10-P-0144 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

1 

2 

3 

4 

4 

4 

Take immediate action to implement 

recommendations to strengthen plans for migrating 

data from the ICMS to the EAS as outlined in Office 

of Inspector General Quick Reaction Report No. 

10-P-0071, Plans to Migrate Data to the New EPA 

Acquisition System Need Improvement. 

Conduct and document a review of the EAS data 

quality controls to ensure all required edit checks 

are identified and recorded in the EAS system 

documentation and implemented in the system. 

Conduct and document a review of EAS system 

development and program change control 

procedures to ensure the EAS data dictionary is 

updated as database fields, and corresponding edit 

and validation checks are added or modified within 

the system. Implement all needed changes to the 

procedures. 

O 

O 

O 

Director, Office of Acquisition 

Management, within the 

Office of Administration and 

Resources Management 

Director, Office of Acquisition 

Management, within the 

Office of Administration and 

Resources Management 

Director, Office of Acquisition 

Management, within the 

Office of Administration and 

Resources Management 

11/15/2010 

10/01/2010 

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

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

U = recommendation is undecided with resolution efforts in progress 

5 
 

 

10-P-0144 

Appendix A 

Exceptions to Data Dictionary Defined 

Edit & Validation Checks 

Our testing of the 79 sampled critical fields, which contain varying total records, revealed a total 

of 9 data fields with records in non-compliance with data dictionary-defined edit and validation 

checks. Both Financial and Compliance related fields were included in these exceptions. These 

errors as presented below indicate that exceptions exist throughout the ICMS database. 

However, the listing of the discrepancies does not indicate potential or actual risk. The total 

number of records is also not an indicator of risk or importance of the field. Testing was 

performed only to identify the discrepancy existence. These exceptions are listed as noted 

exceptions from the sample selected. Testing did not measure the level of impact caused by 

these exceptions and thus each field must be weighted equally in impact to overall operations of 

the system. As noted in the table, these failures were due to one or more of the following 

conditions: 

• Duplicate records 

• Non-existent reference table 

• Zero values 

• Non-text character 

• Gaps in sequential values 

• Non-permissible numerical values 

Field error rates were calculated based on the total exceptions and total record count per field 

tested. The error rates ranged from 0.002 percent to 100 percent. 

Table Field Full Field Name 

Edit / 

Validation 

Check 

Nature of 

Exceptions 

Number of 

Exceptions 

Total 

Record 

Count 

Error Rate 

Percentage 

TGPF GPF_EST_CST Government 

Property Facilities 

Estimated Cost 

Reference 

table 

No existing 

reference 

116 116 100% 

TC SDB_PREF_PRG 

RM_CD 

Contract Small 

Disadvantaged 

Business Program 

Code 

Unique key 

and sequential 

Multiple gaps 

in sequence 

and duplicates 

4,324 4,324 100% 

TCLST CLST_ID_CD Close-Out 

Identification 

Code 

Unique 

sequential key 

Multiple gaps 

in sequence 

and duplicates 

3,487 3,601 96.83% 

6 
 10-P-0144 

Table Field Full Field Name 

Edit / 

Validation 

Check 

Nature of 

Exceptions 

Number of 

Exceptions 

Total 

Record 

Count 

Error Rate 

Percentage 

TASG FULL_INCR_CD Full/ 

IncrementallyFunded 

Assignment Type 

No zero values 

permissible, 

nulls (blanks) 

are allowed. 

Zero values 

found. 

16,334 46,964 34.78% 

TCEA CEA_ID_NBR Cost Element 

Account 

Identification 

Number 

Unique key 

and sequential. 

Multiple gaps 

in sequence 

and duplicates. 

16,440 60,757 27.06% 

TOBL OBL_ID_NBR Obligation 

Identification 

Number 

Unique 

sequential key. 

Multiple gaps 

in sequence 

and duplicates. 

35,674 196,718 18.13% 

TCAB CAB_ID_NBR Cost Aggregate 

Budget 

Identification 

Number 

Unique key 

and sequential. 

Multiple gaps 

in sequence 

and duplicates. 

4,000 58,149 6.88% 

TASG FAIR_OPTNTY_ 

CD 

Multiple Award 

Contract Fair 

Opportunity Code 

Range values 

between 1 to 5. 

Values of 6 

and 7 found. 

468 46,964 1.00% 

TCEA CEA_NAME Cost Element 

Account Name 

All text 

characters. 

Nontext 

character. 

1 60,757 0.002% 

7 
 

 

 

 

 

10-P-0144 

Appendix B 

Exceptions to OAM Information Technology 

Service Center Defined Edit & Validation Checks
 

Our testing of the 79 sampled critical fields revealed 5 fields in noncompliance with current edit 

and validation checks provided by OAM-ITSC during audit fieldwork. Current edit and 

validation checks were requested of OAM-ITSC during fieldwork, since the data dictionary had 

not been updated since February 28, 2005. As noted in the below table, these failures were due 

to one or more of the following conditions: 

• Null values (i.e., blanks) 

• State codes in a ZIP Code-defined field 

• Incorrect OAM-defined resource values 

Actual error rates for these exceptions, most close to one hundred percent, were less definable 

due to the nature of their causes, and thus were replaced with a description of the condition. It 

was noted that both Financial and Compliance related fields were included in the listing of 

exceptions. 

Edit / 

Validation Nature of Description of Rule Violation 

Table Field Full Field Name Check Exceptions Conditions 

TSF_1442 SF_1442_SBA_STATE Standard Form Valid State All values are OAM provided the edit check 

1442 Small 

Business 

Administration 

State 

code. null. rule that the set is based on 

ZIP Codes. Testing showed 

that no ZIP Codes exist in the 

data field; therefore the edit 

check rule does not 

appropriately define the field. 

Testing for ZIP Code 

provides a 100% error rate for 

all entries in all tables. 

TPA_ORG_A ADDR_ST Procurement Valid ZIP All data entries OAM provided the edit check 

DDR_ASS Activity 

Organization 

Code. are State codes 

and one zero 

rule that the set is based on 

ZIP Codes. Testing showed 

Address 

Association State 

value entry. that no ZIP Codes exist in the 

data field; therefore the edit 

check rule does not 

appropriately define the field. 

Testing for ZIP Code 

provides a 100% error rate for 

all entries in all tables. 

TASG ASG_LOE Assignment Level 

of Effort 

Reference to 

other fields. 

OAM-defined 

field resource 

values did not 

OAM provided the edit check 

rule that if this is a deliver 

order or task order, then value 

match 

ASG_LOE 

field values. 

must be ≤ to 

99,999,999,999.99, and value 

must be ≤ the sum of all. 

8 
 

 

 

10-P-0144 

Table Field Full Field Name 

Edit / 

Validation 

Check 

Nature of 

Exceptions 

Description of Rule Violation 

Conditions 

Allocated Delivery Order 

(DO)/Task Order (TO) totals 

(CAB_AMT) for this order. 

Testing found inconsistencies 

in multiple table entries for 

CAB_AMT sums. OAM 

explained these sums are 

user- entered. Error rates 

differed depending on the 

table tested for entry. All 

table fields contained errors. 

TCAB CAB_AMT Cost Aggregate 

Budget Amount 

Reference to 

other fields. 

OAM-defined 

field resource 

values did not 

match 

CAB_AMT 

field values. 

OAM provided the edit check 

that the field must be ≤ to the 

parent cost category's amount 

(CAD_CST_AMT). In 

testing, many records were 

found exceeding these 

defined values (the number of 

entries differed depending on 

the table tested; multiple 

tables exist for this field). All 

tables with the parent field 

showed multiple values 

exceeding the edit check rule. 

All table fields contained 

errors. 

TCEB CEB_AMT Cost Element 

Budget Amount 

Reference to 

other fields. 

OAM-defined 

field resource 

values did not 

match 

CEB_AMT 

field values. 

OAM provided the edit check 

rule that the field must be ≤ to 

the parent line item's amount 

(CEA_AMT). The parent 

exists in multiple tables and 

some errors were found in 

tests. All table fields 

contained errors. 

9 
 

 

10-P-0144 

Appendix C 

Data Anomalies 

Our testing of the 79 fields included identifying data outside the expected value range. For 

numerical fields, that included evaluating maximum values noted in the record set. Date fields 

were analyzed for the feasibility of the day of the week the dates were entered. In follow-up 

interviews on these anomalies, OAM program management could not explain these 

inconsistencies. 

These rationality tests identified 13 fields with anomalous records, which fell into one of the 

following categories: 

• Date entered as a Sunday 

• Unusually large monetary amount 

It was noted that both Financial and Compliance related fields were included in this listing of 

exceptions. 

Table Field Full Field Name Nature of Exceptions OAM-Summarized Response 

TASG ASG_FNL_PYM_DT Assignment Final 

Payment Date 

22 Sunday dates The user enters dates and would 

need to verify them. 

TASG ASG_LOE Assignment Level Of 

Effort 

The maximum value for 

one of the entries was 

1,129,905,413.44. 

The user enters values and would 

need to verify them. 

TCAD CAD_OPTL_AMT Contract Aggregate Data 

Optional Amount 

The maximum value for 

one of the entries was 

9,000,000,000.00. 

This is expressing an essentially 

infinite cost ceiling on a GSA 

Schedule contract (GS-02F0211R). The contracting officer 

that entered this was probably 

trying to make sure there was no 

cap on the ceiling that could be 

used on orders against this 

schedule contract. 

TCEA CEA_AMT Cost Element Account 

Amount 

The maximum value for 

one of the entries was 

999,999,999. 

The user enters values and would 

need to verify them. 

TC C_EST_AMT Contract Estimated 

Amount 

The maximum value for 

one of the entries was 

50,000,000,000.00. 

The user enters values and would 

need to verify them. 

10 
 

 

10-P-0144 

Table Field Full Field Name Nature of Exceptions OAM-Summarized Response 

TEFWA EFWA_CNTRCR_CST EPA Work Assignment 

Form Proposed 

Contractor Cost 

 The maximum value 

for one of the entries 

was 3,385,794,743.00. 

The user enters values and would 

need to verify them. 

TMDFCN MDFCN_MAX_PTNTL_ 

VAL_CHNG 

Modification Maximum 

Potential Value Change 

 The maximum value 

for one of the entries 

was 400,000,000.00. 

This is the sum of user-entered 

values, and would need to be 

verified by the user who entered 

them. 

TPOP POP_MAX_AMT Period of Performance 

Maximum Amount 

The maximum value for 

one of the entries was 

999999999.00. 

The user enters values and would 

need to verify them. 

TPOP POP_MIN_AMT Period of Performance 

Minimum Amount 

The maximum value for 

one of the entries was 

50676590.00. 

The user enters values and would 

need to verify them. 

TSYNPS SYNPS_CST_AMT Synopsis Cost Amount The maximum value for 

one of the entries was 

699337192.00. 

This is the sum of user-entered 

values, and would need to be 

verified by the user who entered 

them. 

TVPR VPR_EST_AMT Vendor Procurement 

Role Estimated Amount 

The maximum value for 

one of the entries was 

18263072.00. 

The user enters values and would 

need to verify them. 

TVPR VPR_MAX_AMT Vendor Procurement 

Role Maximum Amount 

The maximum value for 

one of the entries was 

51443860.00. 

The user enters values and would 

need to verify them. 

TCEA CEA_MAX Cost Element Account 

Maximum 

The maximum value for 

one of the entries was 

999999999.00. 

The user enters values and would 

need to verify them. 

11 
 

 

 

 

 

 

10-P-0144 

Appendix D 

Edit & Validation Checks that 

Require Updating in Data Dictionary
 

Gap analysis performed between data dictionary-defined edit and validation checks and 

OAM-provided edit and validation checks revealed 17 fields with discrepancies, representing a 

divide between edit and validation checks verified by OAM to be in place versus what is actually 

documented in the data dictionary. 

It was noted that both Financial and Compliance related fields were included in this listing of 

exceptions. 

Table Field 

Full Field 

Name 

OAM-defined Edit / 

Validation Check 

Data Dictionary 

parameters 

Description of 

Discrepancy 

TC SDB_PREF_PRGRM_CD Contract Small 

Disadvantaged 

Business 

Program Code 

Drop-down list selection; 

this field is no longer 

actively used by the 

application. 

A system generated 

unique sequential 

number 

Data dictionary 

has no statement 

about disabling 

the field, 

inactivity, or 

non-use 

TVO VO_CIS_SML_SFX Vendor Office 

CIS Small 

Business 

Suffix 

No longer used by ICMS. It 

was part of an interface 

with an EPA information 

system that was retired in 

2002. 

Any valid CIS 

Code 

Data dictionary 

has no statement 

about disabling 

the field, 

inactivity, or 

non-use 

TVPR SMLBS_SZE_CD Small Business 

Size Code 

This is a nonmandatory 

field that has evidently 

never been used. 

Positive integer. Data dictionary 

has no statement 

about disabling 

the field, 

inactivity, or 

non-use 

TCAB CAB_ID_NBR Cost Aggregate 

Budget 

Identification 

Number 

This column alone is not a 

primary key, rather it is part 

of a composite key 

(C_ID_CD, ASG_ID_NBR, 

CAB_ID_NBR). Its value 

is system-generated by an 

Oracle sequence object 

(number generator). There 

should be gaps in the 

numbers. Duplicates are 

acceptable, and are caused 

because 13 original ICMS 

databases were merged into 

the current production 

database. 

Sequential number 

that uniquely 

identifies a specific 

cost aggregate 

budget item within 

an assignment. 

Physically derived 

for performance 

enhancement 

purposes. 

Duplication 

errors and 

differences on 

data source. 

12 
 

 

 

 

 

 

10-P-0144 

Table Field 

Full Field 

Name 

OAM-defined Edit / 

Validation Check 

Data Dictionary 

parameters 

Description of 

Discrepancy 

TCEA CEA_ID_NBR Cost Element 

Account 

Identification 

Number 

This column alone is not a 

primary key, rather it is part 

of a composite key 

(C_ID_CD, POP_ID_NBR, 

CEA_ID_NBR). Its value is 

system generated by an 

Oracle sequence object 

(number generator). There 

should be gaps in the 

numbers. Duplicates are 

acceptable, and are caused 

because 13 original ICMS 

databases were merged into 

the current production 

database. 

Sequential number 

that uniquely 

identifies a specific 

cost element 

account within a 

period of 

performance for a 

procurement. 

Duplication 

errors and 

differences on 

data source. 

TCLST CLST_ID_CD Close-Out 

Identification 

Code 

This column alone is not a 

primary key, rather it is part 

of a composite key 

(C_ID_CD, POP_ID_NBR, 

CEA_ID_NBR). Its value 

is system generated by an 

Oracle sequence object 

(number generator). There 

should be gaps in the 

numbers. Duplicates are 

acceptable, and are caused 

because 13 original ICMS 

databases were merged into 

the current production 

database. 

Unique number 

assigned to close 

out records. 

Duplication 

errors and 

differences on 

data source. 

TGPF GPF_EST_CST Government 

Property 

Facilities 

Estimated Cost 

The text "Foreign key to 

Government Property 

Facilities Type reference 

table TGPF_TP_REF" in 

the data dictionary is 

incorrect and should be 

removed. The source of 

this information is a userentered number with no edit 

checks. 

Any valid dollar 

amount. Foreign 

key to Government 

Property Facilities 

Type reference 

table 

TGPF_TP_REF. 

Field sources 

different. 

13 
 

 

 

10-P-0144 

Table Field 

Full Field 

Name 

OAM defined Edit / 

Validation Check 

Data Dictionary 

parameters 

Description of 

Discrepancy 

TASG FAIR_OPTNTY_CD Multiple 

Award 

Contract Fair 

Opportunity 

Code 

Additional choices have 

been added to 

TFAIR_OPTNTY_REF. 

Valid values are null or 1-7. 

The code 

representing the 

Multiple Award 

Contract Fair 

Opportunity Code. 

Corresponds to 

TFAIR_OPTNTY_ 

REF.ID_CD. Valid 

codes are 1 through 

5. The 

TFAIR_OPTNTY_ 

REF.DSCR values 

that correspond to 

codes 1 through 5 

are: Fair 

Opportunity 

Process, Urgency, 

One/Unique 

Source, Follow On 

Order, or Minimum 

Guarantee. 

Additional 

codes 6 and 7 

added and not 

documented. 

TC SDB_PREF_PRGRM_CD Contract Small 

Disadvantaged 

Business 

Program Code 

This is a foreign key to 

TSDB_PREF_PRGRM_RE 

F.ID_CD. There should not 

be any zero values. Values 

should repeat. Some values 

should be null. 

Foreign key to 

TSDB_PREF_PRG 

RM_REF.ID_CD. 

Unique sequential 

number. 

Not allowing 

zero values is 

not documented 

in the data 

dictionary. 

TASG FULL_INCR_CD Full/Increment 

ally Funded 

Assignment 

Type 

There should not be any 

zero values. 

Any permissible 

numeric code value 

contained in the 

ID_CD field of the 

TFULL_INCR_RE 

F table. 

Not allowing 

zero values is 

not documented 

in the data 

dictionary. 

TMDFCN MDFCN_MAX_PTNTL_ 

VAL_CHNG 

Modification 

Maximum 

Potential Value 

Change 

This is the sum of userentered values. Any valid number. Not specifically 

defined as userentered or a sum 

in the data 

dictionary 

TOBL OBL_ID_NBR Obligation 

Identification 

Number 

The composite of 

C_ID_CD, ASG_ID_NBR, 

and MDFCN_ID_NBR 

make this field unique. The 

field is not a unique key. 

Unique in 

combination with 

PR_CD and 

COM_ID_NBR. 

Differences 

include no 

uniqueness and 

the wrong fields 

listed. 

TSF_1442 SF_1442_SBA_STATE Standard Form 

1442 Small 

Business 

Administration 

State 

Valid State code. Any valid US state 

abbreviation. 

No mention of 

entering ZIP 

Codes to receive 

the valid US 

state 

abbreviations 

14 
 10-P-0144 

Table Field 

Full Field 

Name 

OAM defined Edit / 

Validation Check 

Data Dictionary 

parameters 

Description of 

Discrepancy 

TPA_OR 

G_ADDR 

_ASS 

ADDR_ST Standard Form 

1449 

Administered 

By Standard 

Address 

Indicator 

Valid ZIP Code. Any valid two 

character US State 

abbreviation. 

Neither OAM 

nor the data 

dictionary 

mention the 

existence of zero 

values 

TASG ASG_LOE Assignment 

Level Of Effort 

If this is a DO or TO, then 

value must be less than or 

equal to 99,999,999,999.99, 

and value must be ≤l to the 

sum of all allocated DO/TO 

totals (CAB_AMT) for this 

order. 

Any valid number. OAM provides 

more specificity 

than exists in the 

data dictionary. 

TCAB CAB_AMT Cost Aggregate 

Budget 

Amount 

Field must be ≤ to the 

parent cost category's 

amount 

(CAD_CST_AMT). 

Any valid number. OAM provides 

more specificity 

than exists in the 

data dictionary. 

TCEB CEB_AMT Cost Element 

Budget 

Amount 

Field must be ≤ to the 

parent line item's amount 

(CEA_AMT). 

Any valid number. OAM provides 

more specificity 

than exists in the 

data dictionary. 

15 
 

 

 

 

 

10-P-0144 

Appendix E 

Agency Response 

April 16, 2010 

MEMORANDUM 

SUBJECT: Response to Office of Inspector General (OIG) Draft Report: Improved Data 

Integrity Needed for the Integrated Contracts Management System (ICMS) 

FROM: John C. Gherardini III, Acting Director 

Office of Acquisition Management 

TO: Rudolph M. Brevard, Director 

 Information Resources Management Assessments 

Office of Inspector General 

Thank you for the opportunity to comment on the draft report entitled “Improved Data 

Integrity Needed for the Integrated Contracts Management System (ICMS),” dated 

February 26, 2010. We are in general agreement with the findings and recommendations and 

will ensure all corrective actions are completed as required. 

General Comments 

The Office of Acquisition Management (OAM) agrees that ICMS has identified data 

integrity issues. The U.S. Environmental Protection Agency (EPA) Acquisition System (EAS) is 

being implemented to increase data integrity associated with Agency acquisitions and to ensure 

that similar weaknesses do not exist in the new system. Due to the implementation of EAS and 

the unavailability of the specific record details associated with the errors identified in Appendix 

A, B, C & D of the report, a review of all the data discrepancies to ensure full agreement of all 

the errors found would be very difficult. 

Comments on Recommendations: 

Recommendation 1: Take immediate actions to strengthen plans for migrating data from 

ICMS to EAS as in outlined Office of Inspector General Quick Reaction report, “Plans to 

Migrate Data to the New EPA Acquisition System Need Improvement.” 

Response: In reference to the Quick Reaction reports recommendations to strengthen plans for 

migrating data from ICMS to EAS, OAM has taken active steps to ensure that data migration 

from ICMS to EAS is effective by: 

- Ensuring the continuation of the two tier review for migrated data for active and inactive 

contracts. 

16 
 10-P-0144 

- Ensuring that appropriate individuals participate in the EAS Migrated Data Review 

Orientations. Several meetings and training sessions have already taken place in 

headquarters and the regions. 

- Developing a plan to ensure that closed contracts are reviewed for accuracy. OAM will 

use the existing verification and validation annual exercise to review and ensure closed 

contract dates are accurate in the system. This task will be completed by 11/15/2010. 

Recommendation 2: Conduct and document a review of the EAS data quality controls to 

ensure all required edit checks are identified and recorded in the EAS system 

documentation and implemented in the system. 

Response: This process was completed through EAS Requirements, Testing and Deployment 

Planning. Our concern with the report, as written, appears to reveal a lack of understanding 

associated with the Agency’s ability to easily modify documentation and/or codes associated 

with a Commercial-Off-The-Shelf (COTS) package. The Office of Management and Budget has 

encouraged agencies to limit customization in an effort to minimize costs to the federal 

government. PRISM, which is the COTS package associated with EAS, is used in acquisition 

offices across the federal government. Modifications such as edit checks and controls have been 

designed into the system based on feedback not only from EPA but other federal agencies as 

well. Documentation associated with PRISM is the responsibility of the PRISM vendor. As 

changes are made to the system, the vendor is responsible and does provide updated 

documentation. 

Recommendation 3: Conduct and document a review of EAS system development and 

program change control procedures to ensure the EAS data dictionary is updated as 

database fields, and corresponding edit and validation checks, are added or modified 

within the system. Implement all needed changes to the procedures. 

Response: System development and program change control procedures as it relates to the 

PRISM software as well as PRISM data dictionary are out of EPA’s control and are the 

responsibility of the vendor. OAM will conduct and document a review of the EAS system 

development and program change control procedures as it relates to any customizations applied 

for EPA. We will ensure that change control procedures clearly identify where EPA 

documentation should be updated and ensure those updates are completed. This would be done 

within the EAS functional configuration documentation. We have change control procedures in 

place but will review them by 10/01/2010 to ensure documentation updates are included. 

Should you have any questions regarding this response, please contact me at 

(202) 564-4310 or Margaret Lynch, Service Center Manager, Information Technology Service 

Center at (202) 564-4605. 

17 
 10-P-0144 

Appendix F 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Administration and Resources Management 

Agency Follow-up Official (the Chief Financial Officer) 

Agency Follow-up Coordinator 

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

 Resources Management 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Affairs 

Associate Administrator for Public Affairs 

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

Audit Follow-up Coordinator, Office of Acquisition Management, 

Office of Administration and Resources Management 

Acting Inspector General 

18