Catalyst for Improving the Environment 

Special Report 

Assistance Agreement and 

Contract Recipients with 

Open Audit Recommendations 

May Affect Recovery Act Activities 

 Report No. 09-X-0196 

 July 14, 2009

 

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL 
Report Contributors: Janet Kasper 

 Matthew Simber 

 Leah Nikaidoh 

 Michael Petscavage 

 Nancy Dao 

 Lisa McCowan 

 Wendy Swan 

Abbreviations 

CFR Code of Federal Regulations 

DCAA Defense Contract Audit Agency 

EPA U.S. Environmental Protection Agency 

FAOSC Financial Analysis and Oversight Service Center 

FY Fiscal Year 

GIAMD Grants and Interagency Agreements Management Division 

OAM Office of Acquisition Management 

OIG Office of Inspector General 

OMB Office of Management and Budget 
 

 09-X-0196 

July 14, 2009

Catalyst for Improving the Environment

Why We Did This Review

We reviewed open 

recommendations from prior 

Office of Inspector General 

(OIG) audit reports that 

focused on assistance 

agreement and contract 

recipients that could impact 

the U.S. Environmental 

Protection Agency’s (EPA’s) 

American Recovery and 

Reinvestment Act (Recovery 

Act) activities. Recent Office 

of Management and Budget 

guidance requires the 

expediting of actions on open 

recommendations to preclude 

continuing weaknesses or 

deficiencies that can impact 

Recovery Act funding. 

Background

Open recommendations are 

those for which EPA or the 

recipient of an EPA assistance 

agreement or contract has not 

completed corrective actions. 

As of June 30, 2009, 

67 reports had open 

recommendations that could 

impact EPA’s Recovery Act 

activities. 

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/2009/

20090714-09-X-0196.pdf

 

Assistance Agreement and Contract 

Recipients with Open Audit Recommendations 

May Affect Recovery Act Activities

 What We Found

As of June 30, 2009, EPA used Recovery Act funding to award one assistance 

agreement and one contract to recipients with open recommendations. 

Providing funding to recipients with known weaknesses and open 

recommendations increases the risks of fraud, waste, abuse, and mismanagement 

of Recovery Act funds. 

We reviewed open audit reports for four audit areas for which the findings and 

recommendations primarily addressed questioned costs and internal control 

weaknesses: 

• Financial audits of assistance agreement recipients (9 reports) 

• Forensic audits of assistance agreement and contract recipients (4 reports)

• Single audits (27 reports) 

• Defense Contract Audit Agency audits (27 reports) 

In addition to the two recipients already receiving Recovery Act funding, at least 

a portion of the remainder may also receive such funds through assistance 

agreements and contracts. EPA should consider known concerns, including open 

recommendations, when making future awards.

 What We Recommend

We recommend that EPA verify whether assistance agreement and contract 

recipients have corrected weaknesses identified in OIG reports prior to awarding 

new funds, and expedite corrective action for open recommendations pertaining 

to Recovery Act funding recipients. 

U.S. Environmental Protection Agency 

Office of Inspector General 

At a Glance 
1 

July 14, 2009 

MEMORANDUM

SUBJECT: Assistance Agreement and Contract Recipients with Open Audit 

Recommendations May Affect Recovery Act Activities 

Report No. 09-X-0196 

 

FROM: Melissa M. Heist 

 Assistant Inspector General for Audit 

TO: Craig Hooks, Acting Assistant Administrator 

 Office of Administration and Resources Management 

The Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) has 

completed a review of open recommendations from prior financial audit reports that could 

impact EPA’s American Recovery and Reinvestment Act (Recovery Act) activities. 1 This 

review was not an audit conducted in accordance with Government Auditing Standards. 

We reviewed and included in this special report all EPA OIG reports with open 

recommendations as of June 30, 2009. Open recommendations are those for which EPA or the 

recipient of an EPA assistance agreement or contract has not completed corrective action. In 

accordance with Executive Office of the President, Office of Management and Budget (OMB)

Recovery Act Implementation Guidance, dated April 3, 2009, if final action on report 

recommendations has not been taken, EPA should (1) expedite such action to preclude the 

continuance of weaknesses or deficiencies in the administration of Recovery Act-funded 

programs, or (2) provide an explanation of why such corrective actions cannot or should not be 

taken in the administration of Recovery Act-funded programs. The OMB guidance instructs 

OIGs to determine whether safeguards exist to ensure recipients and sub-recipients use funds for 

their intended purposes.2

 

1

 A report on open recommendations from performance audit reports, Open Audit Recommendations Affecting 

Recovery Act Activities (Report No. 09-X-0136), was issued on April 9, 2009. 2

 OMB Memorandum M-09-15, Updated Implementing Guidance for the American Recovery and Reinvestment Act 

of 2009.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460

OFFICE OF 

INSPECTOR GENERAL
09-X-0196 

2 

This special report identifies open recommendations from 67 OIG audit reports in four different 

audit areas that could impact EPA’s Recovery Act activities because the findings and 

recommendations addressed questioned costs and internal control weaknesses: 

• Financial audits of assistance agreement recipients (9 reports) 

• Forensic audits of assistance agreement and contract recipients (4 reports) 

• Single audits (27 reports) 

• Defense Contract Audit Agency reviews (27 reports) 

A quick reference table listing all 67 reports is included as Attachment 1. Attachment 2 contains 

details on each of the reports based on audit area. 

While not all the organizations in the 67 reports with open recommendations will receive 

Recovery Act funds, EPA continues to make assistance agreement and contract award decisions. 

These open recommendations demonstrate instances where recipient internal controls did not 

safeguard federal funds or follow federal regulations. EPA must ensure that recipients are able 

to effectively administer and manage Recovery Act-funded projects. Assistance agreement and 

contract recipients with internal control weaknesses may unknowingly or knowingly violate 

federal regulations. One of the crucial accountability objectives listed in the OMB guidance is to 

ensure “funds are used for authorized purposes and potential for fraud, waste, error, and abuse 

are mitigated.” If EPA provides funding to recipients that have not implemented the identified 

corrective actions, the Agency increases the risks of fraud, waste, abuse, and mismanagement of 

Recovery Act funds. 

On March 9, 2009, EPA issued its Initial Recovery Act Grant Award Guidance. This Guidance 

directed EPA Program and Grants Management Offices to resolve OIG audit, single audit, or 

EPA review open findings for Recovery Act funding applicants prior to award. When the open 

recommendations cannot be resolved prior to award and the finding does not call into question 

the recipient’s ability to manage Recovery Act funds, the Office may proceed with the award. 

The award must contain a special term and condition requiring the recipient to take necessary 

corrective actions within a specified period. EPA made a Recovery Act Clean Water State 

Revolving Fund award to the State of New York and did not include the required special term 

and condition. The OIG recognizes that EPA included resolving open recommendations from 

prior reviews in its Recovery Act assistance award process. However, for Recovery Act grant 

recipients, we are recommending the Regional Senior Resource Official to verify that assistance 

agreement recipients have corrected weaknesses or have a plan to timely correct weaknesses 

identified in OIG, single audit, or EPA reviews prior to awarding funds and document the 

verification in the assistance agreement file. EPA’s Office of Acquisition Management (OAM) 

also issued guidance; however, it did not address reviewing audit reports with open findings 

pertaining to contractors that may receive Recovery Act funds. 
09-X-0196 

3 

As of June 30, 2009, EPA had awarded Recovery Act funding to 2 of the 67 recipients with open 

recommendations (see Table 1). 

Table 1: Recipients of Recovery Act Funds with Open Recommendations 

Action Official Recipient Report No. Recovery Act Program 

Region 2 New York, State of 2007-3-00139 Clean Water State Revolving Fund 

OAM Contractor 08-4-0207 Superfund 

Source: OIG analysis 

We are making several recommendations to the Office of Administration and Resources 

Management, which oversees the administration of assistance agreements and contracts, to 

ensure that open recommendations are appropriately addressed in relation to Recovery Act funds. 

We will monitor EPA’s implementing of this report’s recommendations as part of our ongoing 

Recovery Act work.

Recommendations

We recommend that the Assistant Administrator for Administration and Resources Management: 

1. Require Regional Senior Resource Officials; Director, Grants and Interagency 

Agreements Management Division; and/or OAM Procurement Operation Division 

Directors to verify that assistance agreement and contract recipients have corrected 

weaknesses or have a plan to timely correct weaknesses identified in OIG reports prior to 

awarding funds, and document these actions in the assistance agreement or contract file. 

2. For Defense Contract Audit Agency audit reports received by OAM since January 1, 

2009, verify that contract recipients have corrected weaknesses or plan to timely correct 

weaknesses identified in these reports prior to awarding funds.3 Document this review in 

the contract file. Implement the actions identified in Recommendation 3 for the 

contractor that received Recovery Act funding. 

We recommend that the Assistant Administrator for Administration and Resources Management 

and the Regional Administrator, Region 2: 

3. Expedite 

4. corrective actions to address open recommendations for recipients that have received 

Recovery Act funding. Review assistance agreement and contract terms and conditions 

and amend them, as necessary, to adequately protect the government’s interests. 

Document these actions in the assistance agreement or contract file, along with the 

approval of the actions by the Regional Senior Resource Official and the OAM 

Procurement Operation Division Director. 

 

3

 As of January 1, 2009, EPA began administering the interagency agreement with the Defense Contract Audit 

Agency. 
09-X-0196 

4 

Action Required 

Please provide a response within 30 days describing the actions EPA is taking, or has taken, to 

address these recommendations. Specifically, we ask you to describe what EPA is doing to 

address the open recommendations pertaining to the two Recovery Act fund recipients. 

If you or your staff has any questions regarding this report, please contact me at 

(202) 566-0899 or heist.melissa@epa.gov; or Janet Kasper, Director for Contracts and 

Assistance Agreement Audits, at (312) 886-3059 or kasper.janet@epa.gov. 
09-X-0196 

5 

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 3 Require Regional Senior Resource Officials; 

Director, Grants and Interagency Agreements 

Management Division; and/or OAM Procurement 

Operation Division Directors to verify that 

assistance agreement and contract recipients have 

corrected weaknesses or have a plan to timely 

correct weaknesses identified in OIG reports prior 

to awarding funds, and document these actions in 

the assistance agreement or contract file. 

O Assistant Administrator 

for Administration and 

Resources Management 

 

2 3 For Defense Contract Audit Agency audit reports 

received by OAM since January 1, 2009, verify that 

contract recipients have corrected weaknesses or 

plan to timely correct weaknesses identified in 

these reports prior to awarding funds. Document 

this review in the contract file. Implement the 

actions identified in Recommendation 3 for the 

contractor that received Recovery Act funding. 

O Assistant Administrator 

for Administration and 

Resources Management 

 

3 3 Expedite corrective actions to address open 

recommendations for recipients that have received 

Recovery Act funding. Review assistance 

agreement and contract terms and conditions and 

amend them, as necessary, to adequately protect 

the government’s interests. Document these 

actions in the assistance agreement or contract file, 

along with the approval of the actions by the 

Regional Senior Resource Official and the OAM 

Procurement Operation Division Director. 

O Assistant Administrator 

for Administration and 

Resources Management 

and 

Regional Administrator, 

Region 2 

 

1 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 
09-X-0196 

6 

Attachment 1 

Quick Reference Table for OIG Reports 

with Open Findings and Recommendations 

We have developed the following reference table of reports with open recommendations, listing 

the EPA action official and the page number on which the report description is located. The 

table lists reports open as of June 30, 2009. The Grants and Interagency Agreements 

Management Division (GIAMD) and the Office of Acquisition Management/Financial Analysis 

and Oversight Service Center (OAM/FAOSC) both are within EPA’s Office of Administration 

and Resources Management. The recipients with open recommendations that have already 

received Recovery Act funds are highlighted in yellow. 

Table 1-1: OIG Report Quick Reference Table 

Action 

Official 

OIG Report 

Number 

Report 

Date Report Title Page 

GIAMD 2002-2-00008 01/29/2002 Procurement Practices Under Grant No. 

X825532-01 Awarded to MBI International 

14 

GIAMD 2003-S-00001 05/29/2002 EPA Cooperative Agreements Awarded to the 

Coordinating Committee for Automotive Repair 

(Region 7 Proactive) 

13 

GIAMD 2003-4-00120 09/30/2003 Geothermal Heat Pump Consortium, Inc., Costs 

Claimed Under EPA Assistance Agreement 

Nos. X828299-01 and X828802-01 

12 

GIAMD 2005-3-00036 12/30/2004 National Indian Health Board, Fiscal Year (FY) 

2002 

17 

GIAMD 2006-3-00006 10/13/2005 Alfred University, FY 2004 17 

GIAMD 2007-3-00037 12/11/2006 Alfred University, FY 2005 19 

GIAMD 2006-4-00122 07/31/2006 Association of State and Interstate Water 

Pollution Control Administrators Incurred Costs 

for Seven EPA Assistance Agreements 

11 

GIAMD 2006-3-00199 09/07/2006 Howard University, FY 2005 18 

GIAMD 2007-4-00026 11/28/2006 International City/County Management 

Association Reported Outlays Under Seven 

Selected Cooperative Agreements 

11 

GIAMD 2007-4-00027 11/30/2006 Examination of Financial Management Practices 

of National Rural Water Association, Duncan, 

Oklahoma 

10 

GIAMD 08-1-0277 09/25/2008 National Caucus and Center on Black Aged, 

Inc., Incurred Cost Audit of Eight EPA 

Cooperative Agreements 

9 

GIAMD 09-3-0038 11/21/2008 Water Environment Federation, FY 2006 22 

GIAMD 09-3-0073 01/06/2009 Environmental Council of the States and 

Affiliates, FY 2006 

23 

GIAMD 09-3-0062 01/07/2009 Missouri, University of, FY 2006 23 

Region 1 2006-3-00203 09/18/2006 Indian Township Tribal Government, FY 2002 18 

Region 1 2006-3-00204 09/18/2006 Indian Township Tribal Government, FY 2003 18 

Region 1 2006-3-00205 09/19/2006 Indian Township Tribal Government, FY 2004 19 

Region 1 08-3-0250 09/05/2008 Indian Township Tribal Government, FY 2006 20 

Region 1 09-3-0024 11/12/2008 Indian Township Tribal Government, FY 2007 22 

Region 2 2007-3-00139 07/26/2007 New York, State of, FY 2006 20 
09-X-0196 

7 

Action 

Official 

OIG Report 

Number 

Report 

Date Report Title Page 

Region 2 09-3-0050 12/08/2008 St. Regis Mohawk Tribe, FY 2007 22 

Region 2 09-3-0063 12/18/2008 Cayuga County Soil and Conservation District, 

FY 2006 

23 

Region 3 08-4-0156 05/19/2008 Canaan Valley Institute, Inc., Incurred Cost 

Audit of Five EPA Cooperative Agreements 

9 

Region 3 09-3-0126 03/23/2009 Alliance for the Chesapeake Bay, FY 2007 26 

Region 3 09-4-0135 04/03/2009 Contractor 15 

Region 5 09-4-0112 03/09/2009 ML Wastewater Management, Inc. – 

Procurement, Financial Management, and 

Lobbying Issues Under EPA Grant Number 

XP97572201 

15 

Region 5 09-4-0133 04/03/2009 Contractor 16 

Region 6 09-3-0093 02/11/2009 Seminole Nation of Oklahoma, FY 2006 24 

Region 6 09-3-0108 03/03/2009 Seminole Nation of Oklahoma, FY 2007 26 

Region 8 2007-4-00078 09/24/2007 Cheyenne River Sioux Tribe Outlays Reported 

Under Five EPA Assistance Agreements 

10 

Region 8 08-3-0247 09/04/2008 North Dakota, State of, FY 2006 20 

Region 8 08-3-0307 09/30/2008 Oglala Sioux Tribe, FY 2004 21 

Region 8 09-3-0102 02/24/2009 Northern Cheyenne Tribe, FY 2006 25 

Region 8 09-3-0103 02/25/2009 The City of Hill City, FY 2006 25 

Region 8 09-3-0140 04/20/2009 Anaconda-Deer Lodge County, FY 2007 26 

Region 9 09-3-0075 01/08/2009 Lone Pine Paiute-Shoshone Reservation, 

FY 2006 

24 

Region 9 09-3-0077 01/08/2009 La Jolla Band of Luiseno Indians, FY 2006 24 

Region10 09-3-0104 02/25/2009 Snoqualmie Tribe, FY 2006 25 

Region10 09-3-0109 03/03/2009 Nooksack Indian Tribe, FY 2006 26 

Region10 09-2-0078 01/12/2009 Costs Claimed under EPA Grant XP98011401 

Awarded to the City of Rupert, Idaho 

15 

OAM/FAOSC 08-1-0130 04/15/2008 Contractor 31 

OAM/FAOSC 2007-1-00090 08/29/2007 Contractor 30 

OAM/FAOSC 08-1-0131 04/15/2008 Contractor 30 

OAM/FAOSC 2004-1-00099 09/14/2005 Contractor 28 

OAM/FAOSC 2007-1-00016 11/13/2006 Contractor 29 

OAM/FAOSC 2007-1-00097 09/20/2007 Contractor 30 

OAM/FAOSC 08-1-0114 03/24/2008 Contractor 31 

OAM/FAOSC 2007-4-00038 01/08/2007 Contractor 29 

OAM/FAOSC 2007-4-00079 09/25/2007 Contractor 30 

OAM/FAOSC 2007-1-00061 04/09/2007 Contractor 29 

OAM/FAOSC 2007-1-00079 07/18/2007 Contractor 29 

OAM/FAOSC 08-4-0157 05/20/2008 Contractor 31 

OAM/FAOSC 08-4-0002 10/02/2007 Contractor 30 

OAM/FAOSC 2006-4-00120 07/20/2006 Contractor 28 

OAM/FAOSC 2007-4-00080 09/26/2007 Contractor 30 

OAM/FAOSC 2006-4-00165 09/27/2006 Contractor 28 

OAM/FAOSC 2006-4-00169 09/29/2006 Contractor 28 

OAM/FAOSC 2007-1-00059 04/05/2007 Contractor 29 

OAM/FAOSC 2007-4-00058 04/30/2007 Contractor 29 

OAM/FAOSC 08-1-0129 04/10/2008 Contractor 30 

OAM/FAOSC 2007-1-00080 08/30/2007 Contractor 29 

OAM/FAOSC 08-4-0259 09/12/2008 Contractor 32 

OAM/FAOSC 08-4-0207 07/24/2008 Contractor 31 

OAM/FAOSC 09-1-0034 11/24/2008 Contractor 32 
09-X-0196 

8 

Action 

Official 

OIG Report 

Number 

Report 

Date Report Title Page 

OAM/FAOSC 08-4-0308 09/30/2008 Contractor 31 

OAM/FAOSC 09-4-0018 11/05/2008 Contractor 32 

OAM/FAOSC 08-4-0208 07/24/2008 Contractor 31 

Source: OIG analysis 
09-X-0196 

9 

Attachment 2 

Details on OIG Reports with 

Open Findings and Recommendations 

Financial Audits of Assistance Agreement Recipients 

The OIG performs financial audits of EPA assistance agreements to determine whether recipients 

claimed amounts that were reasonable, allocable, and allowable according to federal cost 

principles. These audits evaluate whether recipients maintained adequate financial management 

systems, complied with applicable laws and federal regulations, and achieved the intended 

purposes of the grants. We identified nine reports with open recommendations related to EPA 

assistance agreement recipients as of June 30, 2009. Details of the findings and 

recommendations for each report follow. 

Report: National Caucus and Center on Black Aged, Inc., Incurred Cost Audit of Eight EPA 

Cooperative Agreements (08-1-0277), September 25, 2008 

The recipient-reported outlays in its quarterly Financial Status Reports as of September 30, 2007, 

presented fairly, in all material respects, the allowable outlays incurred in accordance with the 

terms and conditions of the agreements and applicable laws and regulations. However, the 

recipient did not clearly disclose its allocation methods in its indirect cost proposals. The 

recipient also charged employee leave costs to grants disproportionately to the amount of time 

employees spent on each assistance agreement. 

Recommendations: We recommended that EPA’s GIAMD require the recipient to: (1) revise its 

indirect cost proposals to clearly explain the process used to allocate costs to its agreements; 

(2) have the revised proposals approved by its cognizant federal agency; (3) use a more equitable 

method for allocating employee paid absences to agreements; and (4) revise its accounting 

manual to include procedures to ensure that final accounting of administrative costs occur timely. 

Report: Canaan Valley Institute, Inc., Incurred Cost Audit of Five EPA Cooperative 

Agreements (08-4-0156), May 19, 2008 

We questioned $3,235,927 of the $6,686,424 in reported net outlays because the recipient 

reported unallowable outlays for indirect, contractual, and in-kind costs. Specifically, the 

recipient: (1) claimed indirect costs without approved indirect rates; (2) did not credit back to 

the agreements all program income; (3) did not demonstrate that it performed cost analysis of 

contracts; (4) reported costs for services outside of the scope of one agreement; (5) did not 

comply with terms and conditions of contracts; and (6) used EPA funds to match another 

federally-funded cooperative agreement. Also, the recipient could improve its sub-recipient 

monitoring program. 
09-X-0196 

10 

Recommendations: We recommended that EPA Region 3 recover questioned outlays of 

$3,218,661 unless the recipient provides sufficient documentation to support the related reported 

costs in accordance with federal regulations. EPA Region 3 should require the recipient to 

prepare and submit its indirect cost rate proposals for negotiation using the accrual method, and 

disclose the direct allocation methodology. The recipient should credit $17,266 in program 

income to the agreements and ensure that cost and pricing are performed and documented as part 

of its contract procurement process. We also recommended EPA Region 3 direct the recipient to 

revise its sub-recipient monitoring program to require technical reports from its sub-recipients 

and time its sub-recipient payments to ensure the funds are expended timely by its sub-recipients.

Report: Cheyenne River Sioux Tribe Outlays Reported Under Five EPA Assistance 

Agreements (2007-4-00078), September 24, 2007 

The Tribe did not comply with the financial and program management standards under Title 40, 

Code of Federal Regulations (CFR), Parts 31 and 35; and OMB Circular A-87. We questioned 

$3,101,827 of the $3,736,560 outlays reported. The Tribe's internal controls were not sufficient 

to ensure that outlays reported complied with federal cost principles, regulations, and grant 

conditions. In some instances, the Tribe also was not able to demonstrate that it has completed 

all work under the agreements and has achieved the intended results of the agreements. 

Recommendations: We recommended that the EPA Region 8 Regional Administrator disallow 

and recover the federal share of ineligible costs of $64,765. The Region should require the Tribe 

to provide sufficient documentation for the remaining $3,037,062 questioned, and disallow and 

recover the federal share of any outlays the Tribe cannot support. The Region should also 

require the Tribe to adjust its indirect costs claimed. The Region should provide training to the 

Tribe on federal regulations and grant requirements, and review the Tribe’s solicitations and 

contracts under EPA agreements until the Tribe has adequate procedures in place. The Region 

should confirm that all work under the agreements was satisfactorily completed prior to 

agreement closeout. The Region should maintain the Tribe’s “high risk” designation until all 

audit issues have been resolved. 

Report: Examination of Financial Management Practices of National Rural Water 

Association, Duncan, Oklahoma (2007-4-00027), November 30, 2006 

The Association’s method of allocating indirect costs over total direct costs is contrary to the 

requirements of OMB Circular A-122. Currently, the Association does not exclude subcontracts 

or sub-awards from its indirect cost allocation base. As a result, EPA grants are bearing a 

disproportionate amount of indirect costs. For the period March 1, 1999, to February 29, 2004, 

EPA grants may have been over-allocated by $2,021,821 in indirect costs. The exact amount of 

the indirect over-allocation will be determined during negotiation of the indirect cost rate. 

Association practices did not comply with OMB Circular A-122 in the following instances: 

• Procedures did not identify all unallowable costs and the Association did not have written 

procedures for reviewing costs. 

• Costs were charged based on budgets and the Association did not consistently record 

costs based on actual activity. 
09-X-0196 

11 

• Direct and indirect costs may have included unallowable costs. 

• Drawdowns were based on budget amounts and not actual expenditures. 

Recommendations: We recommended that the Director of the Grants Administration Division 

(1) obtain final negotiated indirect cost rates for the Association; and (2) require the Association 

to develop written procedures to (a) identify unallowable costs in accordance with OMB Circular 

A-122, and (b) develop written procedures for the preparation of cash draws. 

Report: International City/County Management Association Reported Outlays Under Seven 

Selected Cooperative Agreements (2007-4-00026), November 28, 2006 

We questioned $1,007,858 of the $9,871,025 in reported outlays because the recipient claimed 

unallowable outlays for contractual services, sub-grant costs, indirect labor costs, and in-kind 

costs. Specifically, the recipient did not: 

• compete contracts, justify a sole-source procurement, or perform contract cost analysis; 

• oversee or maintain documentation for sub-grants; and 

• maintain adequate documentation for in-kind costs used as recipient match. 

We also questioned indirect costs the recipient claimed that were prohibited by law. For 

Brownfields grants, recipients are prohibited by law from claiming administrative costs, which 

EPA has determined to include indirect costs. However, EPA included in the grant a special 

condition to allow the recipient to claim some indirect costs as direct costs under the grant. The 

special condition conflicts with OMB regulations regarding direct and indirect costs. Therefore, 

we questioned indirect costs claimed under the award.

Recommendations: We recommended that EPA’s GIAMD: (1) disallow the questioned outlays 

of $78,298 prohibited by law; (2) obtain sufficient documentation to support the remaining 

questioned outlays of $929,560 in accordance with EPA regulations or disallow the costs from 

federal grant participation; and (3) direct the recipient to establish procedures to address issues 

related to procuring contracts, managing sub-recipients, and documenting in-kind costs. 

Report: Association of State and Interstate Water Pollution Control Administrators Incurred 

Costs for Seven EPA Assistance Agreements (2006-4-00122), July 31, 2006 

The Association did not comply with financial and program management standards and 

procurement standards promulgated in Title 40 CFR, Subchapter B, Part 30. The Association: 

(1) could not provide support for any of its general journal entries; (2) included duplicate 

recorded costs in its accounting system; (3) could not always trace grant draws to the accounting 

records; (4) could not always support labor charged to the EPA grants; (5) could not support the 

recorded indirect costs; (6) did not record all of its program income; (7) did not have adequate 

written procedures for determining reasonable, allocable, and allowable costs; (8) drew EPA 

grant funds in excess of the funds needed; and (9) did not complete the required single audits for 

fiscal years ended June 30, 2004, and June 30, 2005. Also, the Association’s procurement 

system did not comply with procurement standards. The Association awarded contracts to the 
09-X-0196 

12 

America’s Clean Water Foundation, a related organization, without competition or a cost 

analysis, contrary to the requirements of Title 40 CFR 30.42 and 30.45. 

Recommendations: We recommended that EPA’s GIAMD: (1) recover $1,883,590 unless the 

Association is able to reconstruct its accounting records to meet the minimum financial 

management standards required in Title 40 CFR 30.21; (2) disallow contract costs procured in 

violation of Title 40 CFR 30.42 and 30.45; (3) rescind provisional indirect cost rates for the fiscal 

years ended June 30, 2005, and June 30, 2006; (4) stop work on all active grants and refrain from 

awarding any new grants until EPA has assurances that the Association meets minimum financial 

management requirements; (5) keep the Association on the reimbursement payment method until 

the Association meets minimum financial management requirements, settles current federal 

liabilities, and repays all disallowed costs; and (6) require the Association to comply with single 

audit requirements for fiscal years ended June 30, 2004, and June 30, 2005. 

Report: Geothermal Heat Pump Consortium, Inc., Costs Claimed Under EPA Assistance 

Agreement Nos. X828299-01 and X828802-01 (2003-4-00120), September 30, 2003 

We questioned $1,153,472 due to material financial management deficiencies. The 

Consortium’s financial management system was inadequate in that the Consortium did not: 

(1) separately identify and accumulate the costs for all direct activities, such as membership 

support and lobbying; (2) account for program income generated by the activities funded by the 

EPA agreements; (3) prepare or negotiate indirect cost rates; (4) prepare written procedures for

allocating costs to final cost objectives; (5) maintain an adequate labor distribution system; and 

(6) provide adequate support for direct cost allocations. In addition to the financial management 

system deficiencies, the Consortium did not: (1) competitively procure contractual services or 

perform any of the required cost or pricing analyses; and (2) comply with all reporting 

requirements. 

Recommendations: We recommended that EPA’s GIAMD: 

 

1) Evaluate the need and scope of the assistance agreements considering that there were other 

sources of income to support the activities; i.e., membership dues and agreements with other 

federal agencies. If EPA determines that there was not a need for the assistance, take action 

to annul the assistance agreement(s). 

If EPA decides to allow agreements, we recommended that EPA: 

2) Recover the $1,153,472 of unsupported costs. 

3) Suspend work under the current agreements and refrain from awarding new funds until the 

Consortium can demonstrate that its accounting practices are consistent with 40 CFR 30.21. 

At a minimum, the Consortium’s system must: (a) ensure that financial results are current, 

accurate, and complete; (b) include written procedures to determine reasonableness, 

allocability, and allowability of costs in accordance with OMB Circular A-122; (c) include 

accounting records that are supported by adequate source documentation; (d) require the 

Consortium to establish an adequate time distribution system that meets the requirements of 

OMB Circular A-122, Attachment B, paragraph (7) – the system should account for total 

hours worked and leave taken, and identify all the specific activities and final cost objectives 
09-X-0196 

13 

that the employees work on during the pay period, including membership and lobbying 

activities; and (e) require the Consortium to follow all procurement standards under 40 CFR 

30.40 through 30.48. 

4) Require the Consortium to submit an indirect cost rate proposal prepared in accordance with 

OMB Circular A-122. 

5) Require the Consortium to provide detailed documentation supporting its use of program 

income to fund additional activities furthering eligible project or program objectives under 

assistance agreement X828802-01. If the Consortium cannot provide documentation, 

program income should be deducted from any costs EPA determines to be allowable under 

the assistance agreement. 

If EPA determined some costs were allowable, we recommended that EPA’s GIAMD: 

6) Deduct from allowable costs any program income earned by the membership activities 

funded under assistance agreement X828299-01. 

7) Consider using program income from agreement number X828802-01 to fund the study not 

completed under agreement number X828299-01 per administrative condition number 15. 

Report: EPA Cooperative Agreements Awarded to the Coordinating Committee for 

Automotive Repair (Region 7 Proactive) (2003-S-00001), May 29, 2002 

We questioned over $2 million because the Coordinating Committee for Automotive Repair did 

not account for the funds in accordance with federal rules, regulations, and agreement terms. 

Recommendations: We recommended that the Director, Grants Administration Division: 

1) Require the Committee to modify its financial management system to meet the requirements 

of 40 CFR 30.21. At a minimum, the system must: 

• Ensure that financial results are current, accurate, and complete. 

• Include written procedures to determine reasonableness, allocability, and allowability 

of costs in accordance with OMB Circular A-122. 

• Include accounting records that are supported by adequate source documentation. 

2) Require the Committee to develop a time distribution system that meets the requirements of 

OMB Circular A-122. 

3) Refrain from providing any new funds until the Agency confirms that the Committee has the 

financial management capabilities to manage funds in accordance with 40 CFR 30.21 and 

OMB Circular A-122. 

4) Require the Committee to reconstruct the accounting records necessary to support the 

expenditure of funds in accordance with OMB Circular A-122. At a minimum, the 

Committee will need to review timesheets, logs, or other records to identify the time actually 

spent on EPA authorized activities. 

5) Require the Committee to submit indirect cost proposals for the fiscal periods 1995 to the 

present in accordance with OMB Circular A-122. 

6) Recover all ineligible costs that do not meet the requirements of OMB Circular A-122. 

7) Recover all funds that cannot be supported in accordance with OMB Circular A-122. 
09-X-0196 

14 

Report: Procurement Practices Under Grant No. X825532-01 Awarded to MBI International

(2002-2-00008), January 29, 2002 

MBI did not have adequate justifications to support the award of sole source contracts. Also, 

MBI’s procurement practices did not meet federal requirements. As a result, $1,301,365 in 

contract costs and $99,508 in consultant costs are not eligible for federal reimbursement. 

Further, there were apparent conflicts of interest between MBI, a subsidiary, and companies that 

the subsidiary created. 

Recommendation: We recommended that the Director, Grants Administration Division, 

disallow the $1,301,365 of ineligible costs incurred under EPA grant X825532-01.
09-X-0196 

15 

Forensic Audits of Assistance Agreement and Contract Recipients 

The OIG conducts forensic audits of EPA assistance agreement and contract recipients to 

determine the acceptability and allowability of costs claimed and whether recipients complied 

with federal regulations. The OIG determines whether safeguards exist to ensure recipients and 

sub-recipients use funds for their intended purposes. We identified four forensic audit reports 

with open findings and recommendations as of June 30, 2009. 

Report: Costs Claimed under EPA Grant XP98011401 Awarded to the City of Rupert, Idaho

(09-2-0078), January 12, 2009 

The grantee did not meet Title 40 CFR Part 31 requirements for financial management. The 

grantee claimed: unsupported costs, unallowable pre-award costs, unallowable interest costs, and 

unallowable equipment costs. The grantee also reported cumulative total project costs that were 

not supported by accounting records. Therefore, EPA needs to recover $63,256 of the $423,106 

in costs questioned under the grant. 

Recommendation: We recommended that EPA Region 10’s Regional Administrator disallow 

$423,106 and recover $63,256 in costs questioned under grant XP98011401. 

Report: ML Wastewater Management, Inc. – Procurement, Financial Management, and 

Lobbying Issues Under EPA Grant Number XP97572201 (09-4-0112), March 9, 2009 

The grantee’s financial management system was not sufficient to ensure that reported costs 

complied with federal regulations. The grantee’s claim included unallowable costs involving 

procurement, interest, organizational costs, lobbying, indirect costs, and labor and fringe benefit 

costs. Further, total project costs may be unreasonable. The grantee also may not have provided 

at least 0.4 new acres of wetlands to replace wetlands filled during construction.

Recommendations: We recommended that the Regional Administrator, EPA Region 5, recover 

$801,118 of the questioned costs, recover any unreasonable project costs, and designate the 

grantee as a high-risk grantee.

Report: 09-4-0135, April 3, 2009 

Based on our review, we found the contactor over-billed EPA for labor charges. 

Recommendations: We recommended that the Regional Administrator, EPA Region 3, request 

the Office of Policy and Management’s Contracting Officer to seek reimbursement of the overbilled labor charges.
09-X-0196 

16 

Report: 09-4-0133, April 3, 2009 

We found, the contractor had not maintained books and records (i.e., general ledger, monthly 

financial statements, etc.) and was not able to reconcile labor hours to its accounting system. 

Recommendations: We recommended that the EPA Regional Administrator, Region 5, utilize 

the information provided in deciding whether to exercise the award term options and in any 

future contracting decisions concerning the contractor. 
09-X-0196 

17 

Single Audits 

The Single Audit Act, as amended, requires non-federal entities (States, local governments, 

universities, tribal governments, and non-profit organizations) that expend $500,000 or more of 

federal financial assistance during a fiscal year to have an annual, comprehensive “single audit”4

that covers all federal expenditures (including grants, contracts and loans). The single audit is 

performed on the recipient’s financial statements and compliance with major federal program 

requirements. The single audit report contains the applicable opinions given by the single 

auditor as well as the following major sections: (1) the recipient’s financial statements; (2) the 

schedule of expenditures of federal awards; (3) a report on compliance with laws, regulations, 

and grant/contract requirements; (4) a schedule of findings and questioned costs (if applicable); 

and (5) the recipient’s corrective action plan(s). Federal agencies use single audits as a means to 

ensure that recipients are expending federal resources properly, and to assess the overall financial 

management capability of these recipients. 

Table 2-1 lists prior Single Audit reports with open findings and recommendations as of June 30, 

2009. 

Table 2-1: Single Audit Reports with Open Recommendations 

Action Official Single Audit Report Summary of Findings and Recommendations 

GIAMD Report No. 2005-3-00036 

National Indian Health 

Board 

FY 2002 

Issued: 12/30/2004

The Board allocated salary costs to grants based on 

pre-determined formulas not supported by timesheets 

and charged amounts to various grants not always 

supported by original documentation. As a result, the 

single auditor questioned $31,960 in unsupported costs. 

Recommendations: We recommended that the Action 

Official recover the questioned costs of $31,960, unless 

the recipient can provide adequate documentation to 

support these costs. We also recommended that EPA 

confirm the corrective action identified in the single audit 

report was implemented; if not, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report.

GIAMD Report No. 2006-3-00006 

Alfred University 

FY 2004 

Issued: 10/13/2005

The University's accounting system provided certified 

payroll information on an individual grant basis. 

However, the payroll distribution system did not provide a 

proportionate breakdown of each employee's total time 

between each sponsored program he/she may be 

working on and other non-sponsored activities. The 

auditor questioned costs of $649,506, but could not 

determine the direct impact upon EPA's program. 

Recommendations: We recommended that EPA 

require the University to provide adequate documentation 

to demonstrate that payroll costs claimed are allowable 

and allocable to EPA’s grant. If the University is unable 

 

4

 OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations, and the Compliance 

Supplement, provide guidance in implementing single audit requirements. The auditor must conduct the single audit 

in accordance with Government Auditing Standards. 
09-X-0196 

18 

Action Official Single Audit Report Summary of Findings and Recommendations 

to provide sufficient and adequate documentation to 

support the payroll costs; EPA should recover these 

costs. We recommended the Action Official confirm the 

recipient implemented the corrective action identified in 

the single audit report. 

GIAMD Report No. 2006-3-00199 

Howard University 

FY 2005 

Issued: 09/07/2006 

The University had numerous payroll charging errors. 

The University did not: (1) have a formal procedure for 

documenting the journal entries made relating to cost 

transfers; (2) consistently perform sub-recipient 

monitoring procedures in accordance with its published 

policy; (3) allow for specific identification in the general 

ledger of the items used to meet the matches on 

federally-sponsored grants with cost-share requirements; 

(4) communicate with the applicable federal awarding 

agency regarding $435,654 in assets that were disposed 

of, as required by federal regulation; (5) follow its 

established internal controls over the financial reporting 

process for quarterly and final financial status reports; 

and (6) have adequate procurement procedures. 

Recommendations: We recommended the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If corrective 

action has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report. 

Region 1 Report No. 2006-3-00203 

Indian Township Tribal 

Government 

FY 2002 

Issued: 09/18/2006 

The Tribe did not invest in governmental securities as 

required by OMB Circular A-133, Compliance 

Supplement, or have written investment policies and 

procedures. The Tribe did not: have an adequate 

accounting system to record, process, and summarize 

accounting transactions; timely reconcile its bank 

accounts within its internal accounting system; and 

submit its financial statement audits, which had been as 

late as 2 years, in a timely manner. The Tribe maintains 

manual general ledger and bookkeeping systems 

decentralized from the Tribal books. The Tribe did not 

attach or could not find supporting receipts for various 

transactions. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If corrective 

action has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report. 

Region 1 Report No. 2006-3-00204 

Indian Township Tribal 

Government 

FY 2003 

Issued: 09/18/2006 

The Tribe did not invest in governmental securities as 

required by OMB Circular A-133, Compliance 

Supplement. The Tribe did not have written investment 

policies and procedures; or an adequate accounting 

system to record, process, and summarize accounting 

transactions. The Tribe maintains bank accounts within 

its internal accounting system that have not been timely 

reconciled. The Tribe has a chronic problem of late 
09-X-0196 

19 

Action Official Single Audit Report Summary of Findings and Recommendations 

financial statement audits and has been recently as far as 

2 years behind in submission of audit reports. The Tribe 

maintains manual general ledger and bookkeeping 

systems decentralized from the tribal books. While 

testing transactions for federal programs, specifically 

environmental, supporting receipts were not attached and 

could not be found for payments of various transactions 

by the Tribe. Tribal and federal program requirements 

over fiscal spending require approved budgets. For the 

year audited, the Tribe exceeded various budget line 

items for tribal government. The Tribe has numerous 

bank accounts with financial institutions; approximately 

$557,000 was uninsured or uncollateralized cash as of 

September 30, 2003. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If corrective 

action has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report. 

Region 1 Report No. 2006-3-00205 

Indian Township Tribal 

Government 

FY 2004 

Issued: 09/19/2006 

The Tribe did not invest in governmental securities as 

required by OMB Circular A-133, Compliance 

Supplement. The Tribe did not have written investment 

policies and procedures. The Tribe did not have an 

adequate accounting system to record, process, and 

summarize accounting transactions. The Tribe maintains 

bank accounts within its internal accounting system that 

have not been timely reconciled. The Tribe has a chronic 

problem of late financial statement audits and has been 

recently as far as 2 years behind in submission of audit 

reports. The Tribe maintains manual general ledger and 

bookkeeping systems decentralized from the tribal books. 

While testing transactions for federal programs, 

specifically environmental, supporting receipts were not 

attached and could not be found for payments of various 

transactions by the Tribe. Tribal and federal program 

requirements over fiscal spending require approved 

budgets. For the year audited, the Tribe exceeded 

various budget line items for tribal government. The 

Tribe has numerous bank accounts with financial 

institutions; approximately $592,634 was uninsured or 

uncollateralized cash as of September 30, 2004. The 

Tribe did not submit timely quarterly reports. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If corrective 

action has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report. 

GIAMD Report No. 2007-3-00037 

Alfred University 

FY 2005 

The University's current system provided certified payroll 

information on an individual grant basis. However, the 

payroll distribution system did not provide a proportionate 
09-X-0196 

20 

Action Official Single Audit Report Summary of Findings and Recommendations 

Issued: 12/11/2006 breakdown of each employee's total time between each 

sponsored program he or she may be working on and 

other non-sponsored activities. The auditor questioned 

costs of $856,419, but could not determine the direct 

impact upon EPA's program. 

Recommendations: We recommended that EPA 

require the University to provide adequate documentation 

to demonstrate that payroll costs claimed are allowable 

and allocable to EPA’s grant. If the University is unable 

to provide sufficient and adequate documentation to 

support the payroll costs; EPA should recover these 

costs. We recommended the Action Official confirm the 

recipient implemented the corrective action identified in 

the single audit report. 

Region 2 Report No. 2007-3-00139 

New York, State of 

FY 2006 

Issued: 07/26/2007 

The State had 191 audit reports with findings that were 

required to have management decisions rendered within 

6 months. Of these, only 72 had been completed in a 

timely manner, 73 required more than 6 months to 

complete, and 46 had no decision rendered. The 

recipient did not have adequate program asset controls, 

inventory procedures, and proper tagging of items. The 

State did not maintain a complete list of its assets. 

Additionally, the State could not always locate items that 

appeared on the asset lists. The recipient did not have 

any evidence of a policy or procedure in place to ensure 

proceeds from the sale or disposal of the assets could be 

identified and returned to the federal program. The single 

audit report for the year ended March 31, 2005, was 

received by the New York Department of Environment 

Conservation (the prime recipient) in July 2005. 

However, the management decision was dated May 

2006, five months late. The recipient has had the same 

finding in prior years and the Department has not 

ensured that its recipient has taken timely and 

appropriate corrective action. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If corrective 

action has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report. 

Region 8 Report No. 08-3-0247 

North Dakota, State of 

FY 2006 

Issued: 09/04/2008 

Program income was not properly recognized and 

reported by North Dakota State University. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the findings in the report. 

Region 1 Report No. 08-3-0250 

Indian Township Tribal 

The Tribe did not submit Standard Forms 269 and 272 

within required timeframes (see Finding 2005-9 on page 
09-X-0196 

21 

Action Official Single Audit Report Summary of Findings and Recommendations 

Government 

FY 2006 

Issued: 09/05/2008 

77 of the audit report). We reported this finding to EPA 

for resolution since the Tribe did not fully address this 

issue in FY 2006, and in FY 2006, the Tribe continued to 

struggle with processing financial information timely. For 

the EPA Partnership Performance grants, the single 

auditor reported that the Tribe did not have records or 

formal calculations to demonstrate that it met the 

matching requirements under these grants. During the 

review of the EPA Lead Educational Outreach grant 

PH-97122801, the single auditor identified payroll 

charges for an employee who traditionally had been paid 

using general fund resources. A review of the 

employee's timesheets and data sheet did not indicate 

that this individual's job responsibilities had changed. 

Therefore, there is no reason for this employee to charge 

the EPA grant. The single auditor questioned $26,134 in 

unsupported costs. 

Recommendations: We recommended that EPA: 

(1) Recover the $26,134 in questioned unsupported 

costs, unless the Tribe can provide adequate 

documentation to support these costs. (2) Ensure that 

the Tribe has taken appropriate corrective action to 

address the findings in the single audit report. If the Tribe 

has not completed corrective action, it needs to provide a 

corrective action plan and milestone dates to address the 

findings. (3) For the EPA Performance Partnership 

grants, ensure that the Tribe has adequate 

documentation to support its matching requirements. If 

the Tribe cannot provide adequate support, EPA should 

recover any unmatched costs accordingly. 

Region 8 Report No. 08-3-0307 

Oglala Sioux Tribe 

FY 2004 

Issued: 9/30/2008 

The Tribe did not: (1) have an adequate system of 

accounting duties and internal controls to assure 

adequate internal controls over the safeguarding of 

assets and reliability of financial records and reporting; 

(2) perform reconciliations on a timely basis; (3) post 

cash receipts and other activity regularly into the general 

ledger; and (4) record several bank accounts in the 

general ledger. Additionally, there were many significant 

adjusting journal entries posted after the close of the 

books at year end. The single auditor identified several 

findings that affect indirect costs. First, the Tribe was not 

allocating the indirect cost rate properly to various 

programs. Second, during testing of indirect cost 

expenditures, the auditor found expenditures that should 

have been charged directly to programs. Also, some 

expenditures charged to the indirect cost fund were not 

necessary and reasonable. In testing transactions, the 

single auditor found that the Tribe did not have 

documentation to support accounts payable, travel costs, 

and fringe benefits. As a result, we questioned all 

reported expenditures of $1,158,903. 

Recommendations: We recommended that EPA 

Region 8: (1) Require the Tribe to prepare a 
09-X-0196 

22 

Action Official Single Audit Report Summary of Findings and Recommendations 

reconciliation of its reported expenditures to its official 

general ledger. (2) Once the reconciliation is completed, 

select a sample of transactions to review, in detail, to 

ensure the costs are allowable, allocable, and reasonable 

under federal regulations and EPA grant requirements. 

Prior to sample selection, the Region should meet with 

the OIG to discuss its proposed sampling approach. 

(3) For any costs that are not adequately supported, 

recover these costs, accordingly. 

Region 1 Report No. 09-3-0024 

Indian Township Tribal 

Government 

FY 2007 

Issued: 11/12/2008 

There are several EPA grants where the official time 

period has expired, but the Tribe still has funds available 

under these grants and potential related expenditures. 

To have access to these funds, the Tribe needs to 

request time extensions from EPA. The Tribe has drawn 

funds from various federal programs to pay general fund 

expenditures, which is not allowable. The single auditors 

noted a net deficit to federal programs of $189,961. 

The Tribe recognized this condition existed due to 

misappropriation activities by the former Tribal governor. 

Recommendations: We recommended that EPA ensure 

the Tribe took corrective action to address the findings in 

the single audit report. If the Tribe has not completed 

corrective action, it needs to provide a corrective action 

plan with milestone dates to address the findings. 

GIAMD Report No. 09-3-0038 

Water Environment 

Federation 

FY 2006 

Issued: 11/21/2008 

In the prior year audit, the single auditor found that some 

expenses had been charged twice to this grant. To 

correct this error, the Federation was required to post an 

adjusting entry; however, the entry was not posted until 

almost a year after the errors were identified.

Recommendations: We recommended that EPA 

ensure that the recipient has taken appropriate action to 

address the finding in the single audit report. If the 

recipient has not completed corrective action, it needs to 

provide a corrective action plan and milestone dates to 

address the finding. 

Region 2 Report No. 09-3-0050 

St. Regis Mohawk Tribe 

FY 2007 

Issued: 12/08/2008 

The Tribe requested grant drawdowns in excess of 

current cash needs. The Performance Partnership 

program had a material positive cash balance for 

6 months. The Tribe was unable to provide 

documentation that a fixed asset physical inventory was 

completed for the audit year for the Performance 

Partnership Grant program. The Tribe had one credit 

card charge that was not properly authorized for the 

Performance Partnership Grant program, BG99267201. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If corrective 

action has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the findings in the audit report. 
09-X-0196 

23 

Action Official Single Audit Report Summary of Findings and Recommendations 

Region 2 Report No. 09-3-0063 

Cayuga County Soil and 

Conservation District 

FY 2006 

Issued: 12/18/2008 

The District did not have proper segregation of duties 

over assets. The District did not have one individual 

charged with overseeing the entire Anaerobic Digester 

Project. Instead, funds were requested by different 

individuals. Therefore, a single disbursement could be 

claimed under more than one grant as either a direct 

expense or as a cost share of the District. The District did 

not request drawdowns on a reimbursement basis as 

preferred by the grantor agency. Additionally, no 

supporting documentation was maintained to justify the 

amounts requested, whether for an advance or a 

reimbursement of expenses. The single auditors noted 

that 16 of 46 transactions selected for examination were 

not approved by the Executive Director as required by the 

District’s purchasing policy. 

Recommendations: We recommended that the Action 

Official confirm the corrective action the recipient 

identified in the single audit report was implemented. 

If the corrective action has not been implemented, EPA 

needs to obtain a corrective action plan, with milestone 

dates, for addressing the finding in the audit report. 

GIAMD Report No. 09-3-0073 

Environmental Council of 

the States and Affiliates 

FY 2006 

Issued: 01/06/2009 

The Council did not: (1) properly segregate duties; 

(2) formally review and approve journal entries prepared 

by the accountant; (3) reconcile major accounts such as 

cash, accounts receivable, grants receivable, deferred 

revenue, and grant revenue, to supporting schedules in a 

timely manner; (4) reconcile various accounts such as 

cash, accounts receivable, grants receivable, and 

deferred revenue that contained material misstatements; 

(5) consistently reflect an accurate recording of federal 

grant revenue and receivables in its accounting system; 

and (6) submit its FY 2006 reporting package within a 

timely manner. Compensation time earned by working 

hours in excess of standard weekly hours in 1 week and 

used in a subsequent week is charged to the federal 

program for the week the time is used rather than for the 

week the time was worked and earned. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the findings in the report. 

GIAMD Report No. 09-3-0062 

Missouri, University of 

FY 2006 

Issued (Revised): 

01/07/2009 

The University did not have an effective system of 

internal control in place to ensure compliance with (1) the 

activities allowed or unallowed costs/cost principles 

compliance requirements; (2) the procurement and 

suspension and debarment compliance requirements; 

and (3) the sub-recipient monitoring compliance 

requirement. The University also did not perform an 

effective or timely review of the sub-recipients' OMB 

Circular A-133 Single Audit Reports; issue management 
09-X-0196 

24 

Action Official Single Audit Report Summary of Findings and Recommendations 

decisions on audit findings within 6 months after receipt 

of the sub-recipients' OMB Circular A-133 Single Audit 

Reports; and ensure that the sub-recipients took 

appropriate and timely corrective action as required by 

OMB Circular A-133. The auditor questioned $90,973. 

Recommendations: We recommended that the Action 

Official: (1) Confirm the recipient implemented the 

corrective action identified in the single audit report. If 

the corrective action has not been implemented, EPA 

needs to obtain a corrective action plan, with milestone 

dates, for addressing the findings in the audit report. 

(2) Recover $90,973 in questioned costs unless the 

University can provide adequate documentation that the 

costs claimed are allowable and allocable to the 

assistance agreement(s). 

Region 9 Report No. 09-3-0075 

Lone Pine PaiuteShoshone Reservation 

FY 2006 

Issued: 01/08/2009 

The Reservation’s cash on hand ($136,000) exceeded 

current expenditures. This finding was originally reported 

in FY 2005, and was not corrected in FY 2006. 

Recommendations: We recommended that the Action 

Official: (1) Require the Reservation to provide 

expenditure documentation to support the $136,000 in 

excessive cash draws. If the Reservation is unable to 

provide adequate documentation, the Reservation should 

reimburse EPA, including applicable interest. (2) Confirm 

the corrective action the recipient identified in the single 

audit report was implemented. If the corrective action 

has not been implemented, EPA needs to obtain a 

corrective action plan, with milestone dates, for 

addressing the finding in the report. 

Region 9 Report No. 09-3-0077 

La Jolla Band of Luiseno 

Indians 

FY 2006 

Issued: 01/08/2009 

Due to improperly prepared bank account reconciliations 

in prior years up to FY 2005, as well as changes made to 

transactions subsequent to reconciliation, many bank 

account reconciliations do not agree with the financial 

statements. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the finding in the report. 

Region 6 Report No. 09-3-0093 

Seminole Nation of 

Oklahoma 

FY 2006 

Issued: 02/11/2009 

The cash balance on hand, $2,677, for the EPA grant 

under the Tribal Air Quality Program, was less than the 

amount required, $3,410. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the finding in the report. 
09-X-0196 

25 

Action Official Single Audit Report Summary of Findings and Recommendations 

Region 8 Report No. 09-3-0102 

Northern Cheyenne Tribe 

FY 2006 

Issued: 02/24/2009 

The Tribe was unable to produce property listings for 

FY 2006. The property listings provided were dated July 

2007. Also, the Tribe has not performed a physical 

inventory of property and equipment within the past 

2 years for EPA Grant Number BG98852306. Of 27 

disbursements selected for testing, 4 I-9 forms were not 

properly completed for EPA Grant Number BG98852306. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the findings in the report. 

Region 8 Report No. 09-3-0103 

The City of Hill City 

FY 2006 

Issued: 02/25/2009 

The City did not: (1) begin the A-133 audit until after the 

9-month period had passed; (2) have segregation of 

duties over revenue, expenditure, and payroll functions; 

(3) prepare, publish, or file its annual report for the year 

ended December 31, 2006; (4) report capital assets on its 

financial statements in accordance with Governmental 

Accounting Standards Board 34 and accounting 

principles; (5) present capital asset purchases as a 

separate line item in the Statement of Revenues, 

Expenditures, and Changes in Fund Balances for the 

Governmental Funds; (6) complete the year-end 

recordkeeping; and (7) post year-end entries to the 

general ledger. Deficiencies were noted in internal 

accounting control and recordkeeping, resulting in a 

diminished assurance that transactions are properly 

executed and recorded and that assets are properly 

safeguarded. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the findings in the report. 

Region 10 Report No. 09-3-0104 

Snoqualmie Tribe 

FY 2006 

Issued: 02/25/2009 

The Tribe's policies and procedures were not designed to 

ensure time elapsing between the transfer of funds from 

the U.S. Treasury and disbursement was minimized. The 

approximate duration for cash carried is 5 working days 

cash needs; however, the Tribe carried cash for 9 months 

for an EPA grant. Travel advance payments to 

employees were not consistently reconciled with receipts. 

Evidence of event attendance was not consistently 

provided. Overpayments to employees and vendors 

were apparently disbursed. Federal funds were loaned to 

treasury cash from an EPA program; as a result, the 

auditors questioned $20,963. 

Recommendations: We recommended that the Action 

Official: (1) Confirm the recipient implemented the 

corrective action identified in the single audit report. If 
09-X-0196 

26 

Action Official Single Audit Report Summary of Findings and Recommendations 

the corrective action has not been implemented, EPA 

needs to obtain a corrective action plan, with milestone 

dates, for addressing the findings in the report. 

(2) Recover the $20,963 in unallowable costs that were 

loaned to the recipient's treasury cash account. 

Region 6 Report No. 09-3-0108 

Seminole Nation of 

Oklahoma 

FY 2007 

Issued: 03/03/2009 

The negative cash balance on hand, -$591, for the EPA 

grant, Tribal Air Quality Program, was less than the 

amount required, $2,341. This was due to the Nation 

lending funds to other programs. The auditors 

questioned $2,932. 

Recommendations: We recommended that the Action 

Official: (1) Confirm the recipient implemented the 

corrective action identified in the single audit report. If 

the corrective action has not been implemented, EPA 

needs to obtain a corrective action plan, with milestone 

dates, for addressing the finding in the audit report. 

(2) Recover the $2,932 in questioned unsupported costs 

unless the Nation can provide adequate documentation 

that the costs claimed are allowable and allocable to the 

assistance agreement. 

Region 10 Report No. 09-3-0109 

Nooksack Indian Tribe 

FY 2006 

Issued: 03/03/2009 

The Tribe submitted late its indirect cost proposal, which 

was due June 30, 2005, for the year ended December 

31, 2006; the negotiated rate was not obtained until April 

23, 2007. For the Environmental Services Program 

(Annual Performance Grant), the single auditor could not 

determine the dates the annual performance report or 

Standard Forms 272 were filed. The Tribe did not have 

adequate internal controls to certify payroll allocation 

between federal programs. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the findings in the audit report. 

Region 3 Report No. 09-3-0126 

Alliance for the 

Chesapeake Bay 

FY 2007 

Issued: 03/23/2009 

Cumulative temporarily restricted net assets were not 

reconciled to the job cost system. The Alliance accrued 

non-vesting accumulating sick leave. 

Recommendations: We recommended that the Action 

Official confirm the recipient implemented the corrective 

action identified in the single audit report. If the 

corrective action has not been implemented, EPA needs 

to obtain a corrective action plan, with milestone dates, 

for addressing the findings in the report. 

Region 8 Report No. 09-3-0140 

Anaconda-Deer Lodge 

County 

FY 2007 

Issued: 04/20/2009 

While the auditor maintained independence under the 

American Institute of Certified Public Accountants Ethics 

Interpretation of 101-3, Performance of Non-Attest 

Services, the auditor assisted in posting client-approved 

adjusting entries to the trial balance and in the 

preparation of draft financial statements, notes, and 
09-X-0196 

27 

Action Official Single Audit Report Summary of Findings and Recommendations 

supplementary schedules. The Treasurer of the County 

was unable to reconcile the County’s cash. At June 30, 

2007, the unreconciled amount was $39,568. The 

County has consulted with outside sources to help with 

the reconciliation process with considerable progress; 

however, the cash is still out of balance. Further, cash 

has not been reconciled since June 30, 2007. The 

County has not performed a physical inventory of fixed 

assets and compared the physical inventory to existing 

detailed records of fixed assets. Equipment was 

purchased without being approved in the Superfund 

Cooperative Agreement between EPA and the County. 

The auditors questioned $16,576. The County does not 

have an investment policy currently in force and has not 

been active in collecting personal property taxes. The 

Public Administrator has not posted an annual report in 

the office of the Clerk of the District Court. The County 

has not included a Management’s Discussion and 

Analysis as part of its supplementary information 

accompanying the basic financial statements, as required 

by Governmental Accounting Standards Board 

Number 43. 

Recommendations: We recommended that the Action 

Official: (1) Confirm the recipient implemented the 

corrective action identified in the single audit report. If 

the corrective action has not been implemented, EPA 

needs to obtain a corrective action plan, with milestone 

dates, for addressing the findings in the report. 

(2) Recover the $16,576 in questioned ineligible costs. 

Also, given the nature and extent of findings presented, 

we recommended that the Region closely consider the 

recipient’s financial capability prior to awarding any 

additional funds, including monies the Recovery Act may 

provide. 

Source: OIG analysis 
09-X-0196 

28 

Defense Contract Audit Agency Audits 

The Defense Contract Audit Agency (DCAA) audits contracts for the Department of Defense 

and provides contract audit services to other government agencies. DCAA audits include 

evaluations of contractor policies, procedures, and controls. These audits identify and evaluate 

activities that contribute to or impact proposed or incurred government contract costs. 

A contractor may have contracts with multiple Federal agencies and the reports cover all 

government funding, not just EPA. The Federal agency that provides the most funding is 

generally identified as cognizant and has the lead for resolving the report findings. For many 

DCAA reports, EPA is not cognizant. Even though OAM is identified as the action official, 

EPA may not be the lead agency responsible for resolving the report issues. Table 2-2 below 

lists the 34 DCAA reports with open findings and recommendations related to EPA contract 

recipients as of June 30, 2009. 

Table 2-2: DCAA Reports with Open Recommendations 

Action 

Official DCAA Audit Report Summary of Findings and Recommendations 

OAM/FAOSC OIG Report No. 2004-1-00099 

Issued: 09/14/2005 

DCAA questioned $3,595,399 in proposed general 

and administrative costs for FY 2002, of which EPA’s 

share equals $2,128. DCAA qualified the audit results 

pending receipt of assist audit reports. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2006-4-00120 

Issued: 07/20/2006 

DCAA determined that the Information Technology 

system general internal controls were inadequate in 

part in 2006. DCAA’s examination disclosed certain 

significant deficiencies in the design or operation of 

the general internal controls that could adversely 

affect the organization’s ability to record, process, 

summarize, and report direct and indirect costs in a 

manner that is consistent with applicable government 

contract laws and regulations. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 2006-4-00165 

Issued: 09/27/2006 

DCAA reported that the service centers cost system 

and related internal control policies and procedures 

were inadequate in part in 2006. DCAA's examination 

disclosed certain significant deficiencies in the design 

or operation of the Indirect/Other Direct Costs system 

process that could adversely affect the organization’s 

ability to record, process, summarize, and report 

Indirect/Other Direct Costs in a manner consistent 

with applicable government contract laws and 

regulations. 

Recommendation: We recommended that the Action 

Official resolve the issue. 
09-X-0196 

29 

Action 

Official DCAA Audit Report Summary of Findings and Recommendations 

OAM/FAOSC OIG Report No. 2006-4-00169 

Issued: 09/29/2006 

DCAA reported that the labor accounting system was 

inadequate in part in 2006. DCAA's examination 

disclosed significant deficiencies in the design or 

operation of the internal control structure that could 

result in increased control risk for the reliability of 

labor charges.

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 2007-1-00016 

Issued: 11/13/2006 

DCAA questioned $188,772,784 in claimed direct 

costs and proposed indirect costs for FY 2001, of 

which EPA’s share is $1,729,601. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2007-4-00038 

Issued: 01/08/2007 

DCAA determined that certain labor practices require 

corrective action to improve the reliability of the 

contractor's labor accounting system in 2006. 

DCAA expressed no opinion on the adequacy of the 

system taken as a whole. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 2007-1-00059 

Issued: 04/05/2007 

DCAA questioned $787,774 in proposed indirect costs 

in FY 2004, of which EPA’s share is $70,900. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2007-1-00061 

Issued: 04/09/2007 

DCAA questioned $34,708,911 in claimed direct costs 

and proposed indirect costs for FY 2004, of which 

EPA’s share is $694,178. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2007-4-00058 

Issued: 04/30/2007 

DCAA determined that certain labor practices require 

corrective action to improve the reliability of the 

contractor's labor accounting system. DCAA did not 

express an opinion on the adequacy of the 

contractor's labor accounting system taken as a 

whole. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 2007-1-00079 

Issued: 07/18/2007 

DCAA questioned $11,969,625 in proposed indirect 

costs for FY 2005, of which EPA’s share is $119,696. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 
09-X-0196 

30 

Action 

Official DCAA Audit Report Summary of Findings and Recommendations 

OAM/FAOSC OIG Report No. 2007-1-00090 

Issued: 08/29/2007 

DCAA questioned $2,201,507 in claimed direct costs 

and proposed indirect costs for FY 2002, of which 

EPA’s share of questioned indirect costs is $123,686. 

None of the questioned direct costs impact EPA 

contracts. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2007-1-00080 

Issued: 08/30/2007 

DCAA questioned $10,982,460 in proposed indirect 

costs for FY 2005, of which EPA’s share equals 

$133,069. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2007-1-00097 

Issued: 09/20/2007 

DCAA questioned $300,645 in proposed indirect costs 

for FY 2003, of which EPA’s share is $27,058. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 2007-4-00079 

Issued: 09/25/2007 

DCAA reported that the billing system and related 

internal control policies and procedures were 

inadequate. The DCAA examination noted certain 

significant deficiencies in the design or operation of 

the internal control structure, which in its judgment 

could adversely affect the contractor's ability to record, 

process, summarize, and report billings in a manner 

that is consistent with applicable government contract 

laws and regulations. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 2007-4-00080 

Issued: 09/26/2007 

DCAA reported that the budget and planning system 

and related internal control policies and procedures 

were inadequate in part in 2006. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 08-4-0002 

Issued: 10/02/2007 

DCAA reported that the compensation system and 

related internal control policies and procedures are 

inadequate in part in 2007. DCAA's examination 

noted certain significant deficiencies in the design or 

operation of the internal control structure, which could 

adversely affect the contractor's ability to record, 

process, summarize, and report compensation in a 

manner that is consistent with applicable government 

contract laws and regulations. 

Recommendation: We recommended that the Action 

Official resolve the issue. 
09-X-0196 

31 

Action 

Official DCAA Audit Report Summary of Findings and Recommendations 

OAM/FAOSC OIG Report No. 08-1-0114 

Issued: 03/24/2008 

DCAA questioned $2,082,837 in proposed indirect 

costs for FY 2004, of which EPA’s share is $197,869. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 08-1-0129 

Issued: 04/10/2008 

DCAA questioned the proposed carry forward 

FY 2005 amounts of $377,330, of which EPA’s share 

is $45,280. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 08-1-0131 

Issued: 04/15/2008 

DCAA questioned $15,966,631 in claimed direct costs 

and proposed indirect costs for FY 2001, of which 

EPA’s share equals $44,648. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 08-1-0130 

Issued: 04/15/2008 

DCAA questioned $7,177,256 in claimed direct costs 

and proposed indirect costs for FY 1999, of which 

EPA’s share equals $57,369. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

OAM/FAOSC OIG Report No. 08-4-0157 

Issued: 05/20/2008 

DCAA reported that the control environment and the 

overall accounting system and related internal control 

policies and procedures were inadequate in part in 

2006. DCAA noted one significant deficiency in the 

design or operation of the internal control structure 

that could adversely affect the organization's ability to 

record, process, summarize, and report costs in a 

manner consistent with applicable government 

contract laws and regulations. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 08-4-0207 

Issued: 07/24/2008 

DCAA reported that certain contractor labor practices 

require corrective action to improve the reliability of 

the contractor's labor accounting system. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 08-4-0208 

Issued: 07/24/2008 

DCAA reported that during the period of January 1, 

2006, through December 31, 2006, the contractor was 

in noncompliance with Cost Accounting Standard 409 

Depreciation of Tangible Capital Assets and Federal 

Acquisition Regulation Part 31. 

Recommendation: We recommended that the Action 

Official resolve the issue. 
09-X-0196 

32 

Action 

Official DCAA Audit Report Summary of Findings and Recommendations 

OAM/FAOSC OIG Report No. 08-4-0259 

Issued: 09/12/2008 

DCAA reported that certain contractor labor practices 

require corrective action to improve the reliability of 

the contractor's labor accounting system. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 08-4-0308 

Issued: 09/30/2008 

DCAA reported that the information technology 

system general internal controls of the contractor were 

inadequate in part. The DCAA examination noted 

certain significant deficiencies in the design or 

operation of the internal control structure. In their 

judgment, these deficiencies could adversely affect 

the organization's ability to record, process, 

summarize, and report direct and indirect costs in a 

manner that is consistent with applicable government 

contract laws and regulations. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 09-4-0018 

Issued: 11/05/2008 

DCAA reported that the contractor was in 

noncompliance with Cost Accounting Standard 409, 

Depreciation of Tangible Capital Assets. DCAA was 

not able to obtain the date of the initial failure to 

comply with the standard. As of the date of the 

report, the condition causing the noncompliance had 

not been corrected. 

Recommendation: We recommended that the Action 

Official resolve the issue. 

OAM/FAOSC OIG Report No. 09-1-0034 

Issued: 11/24/2008 

DCAA questioned proposed indirect costs and rates 

for FY 2006. EPA’s share of the questioned costs is 

$710,170. 

Recommendation: We recommended that the Action 

Official resolve the questioned costs. 

Source: OIG analysis 
09-X-0196 

33 

Appendix A 

Distribution 

Acting Assistant Administrator for Administration and Resources Management 

Assistant Administrator for Air and Radiation 

Assistant Administrator for Solid Waste and Emergency Response 

Acting Assistant Administrator for Water 

Acting Regional Administrators, Regions 1-10 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

Acting General Counsel 

Director, Office of Brownfields and Land Revitalization 

Acting Director, Office of Acquisition Management 

Acting Director, Office of Underground Storage Tanks 

Director, Office of Grants and Debarment 

Director, Grants and Interagency Agreements Management Division 

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

Audit Follow-up Coordinator, Office of Air and Radiation 

Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response 

Audit Follow-up Coordinator, Office of Water 

Audit Follow-up Coordinators, Regions 1-10 

Acting Inspector General