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Improvements Needed by 

EPA to Reduce Risk in 

Employee Hiring Process

Report No. 15-P-0253 August 3, 2015

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Spending Taxpayer Dollars
Report Contributors: Jean Bloom

Kevin Collins

Abbreviations

Bulletin EPA Human Resource Bulletin 08-007B, Quality Assurance in the Hiring Process

EPA U.S. Environmental Protection Agency

GS General Schedule

HR Human Resources

OARM Office of Administration and Resources Management

OHR Office of Human Resources

OIG Office of Inspector General

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 15-P-0253

August 3, 2015

Why We Did This Audit

On August 27, 2013, 

Congress requested that the 

U.S. Environmental Protection 

Agency (EPA), Office of 

Inspector General (OIG),

initiate work in connection with 

a fraud committed by John C. 

Beale, a former Senior Policy 

Advisor with the EPA’s Office of 

Air and Radiation. In particular, 

Congress requested the OIG to 

determine EPA policies and 

processes that “facilitated” 

Beale’s fraud. In connection 

with this request, we initiated

an audit on the EPA’s 

employee vetting process.

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Embracing EPA as a highperforming organization.

Send all inquiries to our public

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2015/ 

20150803-15-P-0253.pdf

Improvements Needed by EPA to 

Reduce Risk in Employee Hiring Process

 What We Found

The EPA has a multi-step hiring process and written 

procedures to ensure quality in the hiring process, 

and performs some verification of an applicant’s 

assertions during the pre-employment hiring process. 

However, our audit found that during the 

pre-employment phase, the EPA does not confirm 

applicants’ assertions of prior employment or 

awards/professional certifications, nor does it 

document any reference checks. The EPA does 

verify the academic credentials for jobs with a 

positive education requirement.

We reviewed 25 new hire candidate files and found no documentation that the 

selecting official verified prior employment or references. The EPA advises

selecting officials about the importance of reference checks in verifying an 

applicant’s statements, as it can be helpful in authenticating information provided 

by the applicant. Without verification of employment, reference checks and 

awards/professional certifications, the EPA is at risk of hiring an applicant based 

on false information and may not hire the best-qualified candidate.

 Recommendation and Planned Corrective Actions

We recommend that the Assistant Administrator for Administration and 

Resources Management review and revise EPA Human Resource Bulletin

08-007B, Quality Assurance in the Hiring Process, to enhance internal controls 

for vetting prior employment, verifying awards/professional certifications and 

contacting references. The agency concurred with the recommendation and 

provided acceptable corrective actions with a planned completion date. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

Without verification of 

prior employment or 

references, the 

potential exists that the 

EPA will not hire the 

best possible staff, or 

will hire an employee 

based on false 

statements.
August 3, 2015

MEMORANDUM

SUBJECT: Improvements Needed by EPA to Reduce Risk in Employee Hiring Process

Report No. 15-P-0253

FROM: Arthur A. Elkins Jr.

TO: Karl Brooks, Acting Assistant Administrator 

Office of Administration and Resources Management

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

U.S. Environmental Protection Agency (EPA). This report contains findings that describe 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. In accordance with established auditresolution procedures, EPA managers will make final determinations on matters in this report.

Action Required

In response to our discussion document, the agency provided preliminary corrective actions that address 

the recommendation and establish a planned completion date. Therefore, a written response to the final 

report is not required. The OIG may make periodic inquiries on your progress in implementing these 

corrective actions. Please update the EPA’s Management Audit Tracking System as you complete 

planned corrective actions. Should you choose to provide a final response, we will post your response on 

the OIG’s public website, along with our memorandum commenting on your response. Your response 

should be provided as an Adobe PDF file that complies with the accessibility requirements of 

Section 508 of the Rehabilitation Act of 1973, as amended. The final response should not contain data 

that you do not want to be released to the public; if your response contains such data, you should 

identify the data for redaction or removal along with corresponding justification.

We will post this report on our website at http://www.epa.gov/oig. 

THE INSPECTOR GENERAL

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460
Improvements Needed by EPA to 15-P-0253

Reduce Risk in Employee Hiring Process

Table of Contents

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

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

Reference Checks/Pre-Employment Inquiries .................................................... 2

Verification of Academic Credentials .................................................................. 3

Responsible Office.................................................................................................... 3

Other OIG Audit......................................................................................................... 3

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

Results of Audit......................................................................................................... 6

No Verification of Prior Employment ................................................................... 6

Academic Credentials and Awards/Professional Certifications Verified .............. 7

Recommendation...................................................................................................... 7

Agency Comments and OIG Evaluation .................................................................. 7

Status of Recommendations and Potential Monetary Benefits ............................. 9

Appendices

A Agency Response to Discussion Document .................................................. 10

B Distribution ....................................................................................................... 12
15-P-0253 1

Purpose

As part of our work on internal controls in response to a request from Congress, 

we initiated an audit on the U.S. Environmental Protection Agency’s (EPA’s)

vetting process for new employees to determine whether the EPA confirms 

previous employment, education and awards/professional certifications claimed 

by the applicant.

Background

On August 27, 2013, Congress requested that the Office of Inspector General 

(OIG) initiate work in connection with a fraud committed by John C. Beale, a 

former Senior Policy Advisor with the EPA’s Office of Air and Radiation. In 

particular, Congress asked the OIG to determine EPA policies and processes that 

“facilitated” Beale’s fraud. As part of the assignment, we initiated an audit of the 

EPA’s employee vetting process. For purposes of our audit, we defined vetting as 

the process of verifying an applicant’s assertions made during the hiring process.

It is the objective of the EPA to select the “best and brightest” individuals for its 

workforce to maintain a talented, dedicated and highly motivated staff of 

employees. The EPA’s servicing human resources (HR) office has a variety of 

pre- and post-appointment actions to help provide confidence and credibility in the 

EPA’s recruitment efforts and contributes toward the selection of quality hires. The 

actions are outlined in EPA Human Resource Bulletin 08-007B, Quality Assurance 

in the Hiring Process (the Bulletin), dated September 29, 2008.

The Bulletin highlights the legal and regulatory procedures that servicing HR

offices must follow in the hiring process and the procedures that managers and 

supervisors should use to ensure quality. The EPA’s pre- and post-appointment 

actions associated with hiring are included in the Bulletin. Pre-appointment actions 

are actions, reviews or procedures that take place before a candidate enters on duty 

and measure whether the candidate meets the legal and regulatory requirements for 

the position and is suitable for employment in the federal service. Post-appointment 

actions and procedures occur and/or affect an individual while employed at the 

EPA.

The pre- and post-appointments procedures are shown in Table 1. The two shaded 

areas (items 3 and 5) are the two procedures that we reviewed and tested.
15-P-0253 2

Table 1: Pre- and post-appointment procedures 

Item no. Pre-appointment procedures

1. Screen for minimum qualifications/selective factors.

2. Applicant assessment, rating and ranking.

3. Reference checks/pre-employment inquires.

4. Records check for current federal employees.

5. Verification of academic credentials.

6. Verification of selective services, proof of veterans’ status and U.S. citizenship, or 

documentation that applicant is legally authorized to work in the United States. 

7. Pre-employment security.

8. Completion of declaration for federal employment.

9. Offer of employment.

Post-appointment procedures

1. Suitability.

2. Employment Eligibility Verification Program (E-Verify).

3. Probationary periods.

Source: EPA Human Resource Bulletin 08-007B, Quality Assurance in the Hiring Process.

The vetting of an applicant’s assertions regarding previous employment, 

education and awards/professional certifications are primarily done during the 

reference check/pre-employment inquiries and verification of academic 

credentials stage.

Reference Checks/Pre-Employment Inquiries

The Bulletin, Section I.a.3, Reference Checks/Pre-employment inquiries, states:

Reference checks or pre-employment inquiries can be a valuable 

tool when selecting applicants for employment. They not only can 

be helpful in authenticating information provided in the 

resume/application, but also in obtaining additional information 

about an applicant’s work performance and habits, and other 

information not provided in the resume but relevant to the job 

opening. Servicing HR Offices will advise selecting officials 

about the importance of reference checks in verifying 

applicants’ statements on their resumes or applications and/or 

during the interview for assessing personal effectiveness traits 

that have an impact on an employee’s ability to perform in a 

quality manner (OIG emphasis added). Supervisors should also 

be advised to obtain references from former employers or school 

officials, rather than solely relying on personal references or other 

references submitted with the application or resume.
15-P-0253 3

Because a current supervisor may have other motives for giving a 

current employee either a glowing recommendation or an 

unsatisfactory one, at least two other reference checks should be 

made with other reliable individuals who are knowledgeable of the 

candidate’s skills, abilities and other work-related characteristics.

Verification of Academic Credentials

The Bulletin, Section I.a.5, Verification of Academic Credentials, states:

When a college degree is required for a positon according to the 

Qualification Standards for General Schedule Positions, it must be 

from an accredited college or university. In order to prevent an 

applicant from gaining favorable consideration during the hiring 

process based on bogus degrees or degrees obtained from 

unaccredited institutions, the HR specialist must verify the 

legitimacy of the degree.

The servicing HR office must obtain an official, notarized college 

transcript to verify the degree of a recent college graduate before 

an employee enters on duty.

Selecting officials have a key role in selecting quality staff for the EPA. In 

accordance with the Bulletin, Section II.b, Interviews and Selection:

Selecting officials should select the best candidate for their 

position(s) based on information obtained from the employment 

application, reference checks, interviews, performance appraisals, 

work samples, etc.

Responsible Office

The Office of Human Resources (OHR) within the EPA’s Office of 

Administration and Resources Management (OARM) is responsible for 

developing, promoting and implementing improved principles, standards, 

policies, procedures, services and systems governing the overall organization and 

workforce of the agency. According to the EPA Organization Function, “OHR is 

responsible for policies, procedures, program development, and implementation 

of the full spectrum of EPA’s human resources functions and programs, and 

employee services.”

Other OIG Audit

The OIG issued Report No. 15-B-0076, Improvement Needed by EPA OIG to 

Reduce Risk in Employee Hiring Process,

1

on February 4, 2015. The audit was 

 

1 http://www.epa.gov/oig/reports/2015/20150205-15-B-0076.pdf. 
15-P-0253 4

conducted to evaluate the OIG’s own vetting process and determine whether 

proper verification of applicant assertions was conducted. The audit disclosed 

weaknesses in the OIG’s current system and made two recommendations. We 

recommended that the Deputy Inspector General require selecting officials to 

verify prior employment and references prior to making final selections and retain 

documentation as outlined in the OIG guidance and procedures. In addition, we 

recommended that the OIG establish policies to enhance internal controls for 

employee vetting. The Deputy Inspector General agreed with our 

recommendations and provided corrective actions and completion dates to address 

all recommendations. The two recommendations remain open pending full 

completion of the corrective actions. 

Scope and Methodology

We conducted our audit from December 9, 2013, through May 4, 2015, in 

accordance with the generally accepted government auditing standards issued by 

the Comptroller General of the United States. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate evidence to provide a 

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

We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

To determine the EPA’s employee hiring process and whether applicants’ assertions 

made during the hiring process are validated, we performed the following steps:

 Met with representatives from OHR to obtain an understanding of the 

EPA’s employee hiring process and to identify and discuss applicable 

EPA policies and procedures.

 Obtained and reviewed criteria identified by OHR that is associated with 

employee hiring to obtain an understanding of the requirements. 

Specifically, we obtained and reviewed EPA HR Bulletin 08-007B, 

Quality Assurance in the Hiring Process. 

 Met with OHR Shared Service Centers to obtain an understanding of the 

information available in a job candidate’s file and where it should be 

located.

To determine whether reference checks are conducted and whether applicants’ 

assertions made during the hiring process are validated, we performed the 

following steps:

 Obtained from OHR a listing of full-time career-conditional new employees

for fiscal year 2013 (October 1, 2012 – September 30, 2013) to determine 

the number of employees hired by the EPA and the type of appointment.

Based on the information provided, the EPA hired 291 new hires.
15-P-0253 5

 Analyzed the information provided and selected the General Schedule 

(GS)-level appointments for our universe of testing. We focused on 

GS-level hiring since Mr. Beale was hired as a GS employee. We stratified 

the GS-level appointments by grade level and assessed the risk based on 

the grade level. We assigned the highest risk level to the highest GS grade 

as more work experience would be required and the risk would be greater 

by not verifying prior employment, education and awards/certifications. 

We presented our sampling methodology to OHR and the office took 

no exception. Our original sample universe consisted of 43 GS new hires, 

but was reduced to 41 because we deleted the two OIG GS-15 new hires

who were part of the prior report covering the OIG employee vetting 

process.

 Performed selected testing of GS new hires’ candidate files to determine 

whether reference checks were performed to confirm previous employment. 

We tested 25 of the 41 sample items. The remaining 16 candidate files were 

either not contained in the EZ file system based on the hiring designation or 

were not readily available. We determined the reduction to the 25 sampletested items would provide a representative sample for our testing and OHR 

agreed that the 25 items would be representative. A breakdown of the 

sample is in Table 2.

Table 2: EPA new hires by government pay plan and OIG sample plan

Pay plan and 

grade level hired

Universe of 

employees hired

Test 

percentage

Sample 

size

Items 

Tested

GS-8 and below 23 10% 2 0

GS-9 29 10% 2 1

GS-11 20 10% 2 1

GS-12 19 25% 4 3

GS-13 31 30% 10 7

GS-14 22 50% 11 7

GS-15 12 100% 12 6

Subtotal GS 156 43 25

 Less: OIG Hires (2)

Non-GS Hires 135 0% 0

Total Hires 291 41

Source: OHR new hires from October 1, 2012 – September 30, 2013.

 Reviewed the candidate files to determine whether the EPA verified the 

applicants’ claimed education for hiring actions that had a positive 

education requirement.
15-P-0253 6

 Reviewed the candidate files to determine whether the EPA verified 

applicants’ claimed awards/professional certifications.

On March 16, 2015, we met with the EPA’s OHR Director and provided the 

results of testing. The Director took no exception to our sampling methodology 

and results. 

Results of Audit

The EPA has a multi-step hiring process and written procedures to ensure quality 

in the hiring process, and performs some verification of an applicant’s assertions 

during the pre-employment hiring process. However, we found that the EPA does

not confirm applicants’ assertions of prior employment or verify 

awards/professional certifications claimed during the pre-employment phase. 

The EPA does verify the academic credentials for jobs with a positive education 

requirement.

No Verification of Prior Employment 

We found no documentation in candidates’ files that the EPA confirmed 

applicants’ assertions of prior employment during the pre-employment phase. 

We reviewed 25 new-hire-candidate files maintained by OHR Shared Service 

Centers to determine whether applicants’ assertions of prior employment were 

verified by the EPA. None of the 25 tested candidate files contained 

documentation that prior employment or references were verified.

The EPA’s HR Bulletin does not require HR or the selection official to perform 

reference checks or a verification of statements on an applicant’s resume. Instead, 

Procedures Section I.a.3 of the Bulletin requires that servicing HR offices advise

(OIG emphasis added) selection officials about the importance of verifying 

applicants’ statements or resumes, and includes a sample reference-check 

template with questions. The Bulletin also does not provide information on how 

and where documentation of reference checks or verification of applicants’

assertions should be retained. Without a requirement, there is no assurance that a 

verification of prior employment or references for perspective job candidates is 

conducted or consistently performed. In addition, without the verification, the 

EPA may not hire the best-qualified candidate, and is at risk of hiring an applicant 

based on false information. We consider the verification of prior employment and 

references during the pre-employment phase to be a best practice and recommend 

that it should be conducted for all recruiting actions.

The EPA does not have any review procedures in effect that would detect false 

statements during the normal course of operations. Although, the EPA has the 

ability to release the new hire from employment during the probationary period 

for poor performance and can release the employee for making any false 
15-P-0253 7

statements on their application and resume, it results in unnecessary expenses to 

hire, train and dismiss the employee. 

Academic Credentials and Awards/Professional Certifications Verified

We reviewed 25 new-hire-candidate files maintained by OHR Shared Service 

Centers to determine whether the EPA verified the academic credentials as

required in Procedures Section I.a.5 of the Bulletin. Of the 25 candidate files 

reviewed, only nine were for a job classification that required a positive 

educational requirement. All nine candidate files reviewed had documentation

indicating the appropriate educational requirements were met and verified as

required by the EPA’s HR Bulletin.

We also reviewed the candidate files to determine whether the EPA verified 

awards/professional certifications claimed by applicants. We found no evidence 

that awards/professional certifications were verified. The EPA’s HR Bulletin does 

not require verification of awards or professional certification claimed by the 

applicant. 

Recommendation

We recommend that the Assistant Administrator for Administration and 

Resources Management:

1. Review and revise EPA Human Resource Bulletin 08-007B, Quality 

Assurance in the Hiring Process, to enhance internal controls for vetting 

prior employment, verifying awards/professional certifications and 

contacting references by:

a. Establishing a requirement that an applicant’s prior employment, 

awards/professional certifications and references be verified.

b. Establishing a requirement that the selecting official or delegated 

authority document that they verified prior employment, 

awards/professional certifications and references of prospective 

new hires, or explain the reasons why they did not verify. Retain 

documentation in a permanent file for the time period required in 

the applicable EPA Record Schedule.

Agency Comments and OIG Evaluation

A discussion document was provided to the agency for comment on May 4, 2015. 

The agency provided an initial response on May 22, 2015, and we held a final exit 

conference on June 10, 2015. The agency modified its corrective actions and 

provided an updated response on June 22, 2015. The agency concurred with our 
15-P-0253 8

recommendation and provided acceptable corrective actions with a planned 

completion date. The agency’s full response to our discussion draft is in 

Appendix A of this report.

 
15-P-0253 9

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 7 Review and revise EPA Human Resource Bulletin 

08-007B, Quality Assurance in the Hiring Process,

to enhance internal controls for vetting prior 

employment, verifying awards/professional 

certifications and contacting references by:

a. Establishing a requirement that an 

applicant’s prior employment, 

awards/professional certifications and 

references be verified.

b. Establishing a requirement that the selecting 

official or delegated authority document that

they verified prior employment, 

awards/professional certifications and 

references of prospective new hires, or 

explain the reasons why they did not verify. 

Retain documentation in a permanent file for 

the time period required in the applicable 

EPA Record Schedule.

O Assistant Administrator for 

Administration and 

Resources Management

9/30/15

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.
15-P-0253 10

Appendix A

Agency Response to Discussion Document

UNITED STATES ENVIRONMENTAL PROTECTION

AGENCY

WASHINGTON, D.C. 20460

OFFICE OF 

ADMINISTRATION

AND RESOURCES

MANAGEMENT

MEMORANDUM

SUBJECT: Response to OIG Discussion Document: Improvements Needed by EPA to 

Reduce Risk in Employee Hiring Process, Project No. OA-FY13-0396 

FROM:

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

Office of Inspector General

The purpose of this memorandum is to provide the Office of Administration and Resources 

Management’s response to the above subject discussion document issued by your office on May 

4, 2015. The discussion document identified one OARM recommendation with two 

requirements. OARM concurs with the recommendation and has provided its preliminary 

corrective actions below:

Recommendation: Review and revise EPA Human Resource Bulletin 08-007B, 

Quality Assurance in the Hiring Process, to enhance internal controls for vetting prior 

employment, verifying awards/professional certifications, and contacting references 

by: 

a. Establishing a requirement that an applicant’s prior employment, 

awards/professional certifications and references be verified. 

b. Establishing a requirement that the selecting official or delegated authority 

document that they verified prior employment, awards/professional certifications 

and references of prospective new hires, or explain the reasons why they did not 

verify. Retain documentation in a permanent file for the time period required in the 

applicable EPA Record Schedule.

JUNE 22, 2015
15-P-0253 11

OARM agrees to:

o Revise the guidance contained in EPA Human Resource Bulletin 08-007B, Quality 

Assurance in the Hiring Process to enhance internal controls by:

 requiring selecting official or delegated authority to:

- conduct three professional reference checks (or three academic references 

in the case of students or recent graduates without professional 

references);

- verify prior three years of employment;

- verify a sampling of professional certifications and awards referenced by 

the applicant that is relevant and pertains to the position being filled as 

determined by the selecting official or delegated authority; and

- maintain all vetting documentation in accordance with the appropriate 

EPA records management schedule.

 requiring the selecting official to certify completion of the vetting process directly 

on the “certificate of eligibles” returned to the OARM Shared Service Center 

before the official job offer is made.

The agency plans to revise and institutionalize the HR Bulletin by September 30, 2015.

Thank you and your staff for their efforts to help us address this concern. If you or your staff 

have any additional questions, please contact Susan A. Kantrowitz, director, Office of Human 

Resources, at (202) 564-4606.

cc: John Showman

 Sandy Womack

 Susan Kantrowitz

 Angela Freeman

 Peter Johnson

 Rick Carter
15-P-0253 12

Appendix B

Distribution 

Office of the Administrator 

Deputy Administrator 

Chief of Staff 

Assistant Administrator for Administration and Resources Management 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Principal Deputy Assistant Administrator for Administration and Resources Management 

Director, Office of Policy and Resource Management, Office of Administration and 

Resources Management 

Deputy Director, Office of Policy and Resource Management, Office of Administration and 

Resources Management 

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