U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Hotline Report 

Review of Hotline Complaint on 

Employee Granted Full-Time 

Work-at-Home Privilege 

 Report No. 10-P-0002 

 October 7, 2009 
Report Contributors: Ben Beeson 

 Dan Cox 

Eric Lewis 

Abbreviations 

EPA U.S. Environmental Protection Agency 

NETI National Enforcement Training Institute 

OARM Office of Administration and Resources Management 

OECA Office of Enforcement and Compliance Assurance 

OIG Office of Inspector General 
U.S. Environmental Protection Agency 10-P-0002 

October 7, 2009 Office of Inspector General 

At a Glance
 

Catalyst for Improving the Environment 

Why We Did This Review 

We conducted this review in 

response to an anonymous 

Hotline complaint. The 

complaint alleged that the 

U. S. Environmental 

Protection Agency (EPA) 

inappropriately granted fulltime work-at-home status to 

an employee so that employee 

could move outside of the 

Washington, DC, area. 

Background 

EPA’s Office of 

Administration and Resources 

Management (OARM) 

provides national leadership, 

policy, and management for 

support functions such as 

human resources management. 

The Office of Enforcement 

and Compliance Assurance’s 

National Enforcement 

Training Institute (NETI) is 

responsible for training 

personnel in the enforcement 

and compliance of the nation's 

environmental laws, and is the 

office where the subject of the 

complaint was employed. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

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

20091007-10-P-0002.pdf 

Review of Hotline Complaint on Employee 

Granted Full-Time Work-at-Home Privilege 

What We Found 

We found an unauthorized, full-time work-at-home arrangement that has existed 

for 9 years and allows a NETI employee to work from home in Ohio instead of an 

office in Washington, DC. The employee and position were originally located in 

the Washington area and the employee later moved as the result of a spouse 

transfer. In our opinion, NETI’s actions are for the benefit of a single employee 

as opposed to being primarily in the interest of the government, and this action 

was not equitably provided within NETI. EPA has no established or consistent 

policy, procedure, or criteria for granting full-time work-at-home privilege. 

Full-time work-at-home opportunity appears to be preferentially available to only 

a few employees. Neither OARM nor NETI has any written documentation 

showing the government interest in or appropriateness of making this 

arrangement, or that senior OARM officials approved this action. 

Office of Human Resources personnel (the Associate Deputy Director of Program 

Management & Communications, and the Agency Telework Coordinator) stated 

that EPA became aware of similar arrangements due to research it performed for 

an unrelated court case. OARM raised concerns about equity in such 

arrangements, and believes this must be brought under control. To date, OARM 

has not corrected this situation. 

What We Recommend 

We recommend that the Deputy Administrator assign responsibility for 

authorizing all non-OARM duty station changes to the Assistant Administrator for 

OARM. We further recommend that the Assistant Administrator for 

Administration and Resources Management establish and implement Agency 

policy for all EPA employees that clearly articulates the process and procedures 

for changing an employee’s duty station to a location geographically separate from 

the position of record. We also recommend that the Agency quickly bring into 

compliance with the new policy all existing full-time work at a duty station 

separate from the position of record. The Agency generally agreed with these 

recommendations and estimated all of the recommendations will be implemented 

by July 2010. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

October 7, 2009 

MEMORANDUM 

SUBJECT:	 Review of Hotline Complaint on Employee Granted Full-Time 

Work-at-Home Privilege

 Report No. 10-P-0002 

FROM:	 Wade T. Najjum

 Assistant Inspector General 

 Office of Program Evaluation 

TO: Scott C. Fulton 

 Acting Deputy Administrator 

Craig E. Hooks 

Assistant Administrator for Administration and Resources Management 

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

the U.S. Environmental Protection Agency (EPA). This report represents the opinion of the OIG 

and does not necessarily represent the final EPA position. Final determination on matters in this 

report will be made by EPA managers in accordance with established audit resolution 

procedures. The Office of the Administrator and the Office of Administration and Resources 

Management provided comments to our draft audit report on August 19, 2009. The OIG 

evaluated these comments and, where appropriate, has made necessary changes in this report. 

We have included the response and the OIG’s evaluation in Appendix A. 

The estimated cost of this project – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time is – $161,118. 

Action Required 

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

report within 90 calendar days. You should include a formal corrective action plan for agreed 

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

to the public. This report will be available at http://www.epa.gov/oig. 
Should you have any questions, please contact Eric Lewis, Director, Special Reviews, at 

202-566-2664 or lewis.eric@epa.gov. 
Review of Hotline Complaint on Employee 10-P-0002 

Granted Full-Time Work-at-Home Privilege 

Table of Contents 

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

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

Scope and Methodology............................................................................................. 2 

Results of Review ....................................................................................................... 3 

NETI Rationale for the Decision........................................................................... 3 

Cost and Equity.................................................................................................... 5 

 OARM Concerns .................................................................................................. 5 

Conclusion................................................................................................................... 5 

Recommendations...................................................................................................... 6 

Summary of Agency Response and OIG Evaluation ............................................... 6 

Status of Recommendations and Potential Monetary Benefits.............................. 7 

Appendices 

A Agency Response to Draft Report.................................................................... 8 

B Distribution ......................................................................................................... 11 
10-P-0002 

Purpose 

The OIG reviewed an anonymous Hotline allegation that the U.S. Environmental Protection 

Agency (EPA) inappropriately granted full-time work-at-home status to a National Enforcement 

Training Institute (NETI) employee. This employee moved to Ohio from the Washington, DC, 

area after the spouse received a job transfer, and NETI wanted to retain the position. The 

complaint also alleged that the work-at-home arrangement created inappropriate travel costs to 

the government and other morale problems in the office. 

Background 

The Office of Administration and Resources Management (OARM) provides national leadership, 

policy, and management of many essential support functions for the Agency, including human 

resources management. NETI, within the Office of Enforcement and Compliance Assurance 

(OECA), is responsible for training federal, State, local, and tribal lawyers, inspectors, civil and 

criminal investigators, and technical experts in the enforcement and compliance of the Nation's 

environmental laws. 

OARM’s Team Leader, Compensation & Work-Life Team, in the Human Resources Policy 

Division, stated there are two official policies that allow an individual to work at home – the 

Alternative Workspace Policy and EPA Flexiplace Policy. In addition, EPA’s Conduct and 

Discipline Policy requires that the Agency treat all employees equitably. OARM stated the 

Agency also has two unofficial/unauthorized practices where individuals work at home – the 

Work Designation Separate from the Position of Record practice and Remote Reporting practice. 

Details on these policies and practices follow. 

Alternative Work Space Policy. In January 1999, the OARM Assistant Administrator 

created the Uniform Criteria and Procedures for Requesting and Assigning Alternative 

Work Space Program. The Program addresses employee requests to work at a location 

other than the officially assigned work location solely because of claims of adverse health 

effects caused or aggravated by some condition associated with the official work site. 

EPA Flexiplace Policy. EPA Flexiplace Policy 3180, December 1997, addresses 

medical, regular, and episodic flexiplace. The Policy requires the employee to 

periodically be present in the office (commute to the main office regularly) to comply 

with the policy. 

Conduct and Discipline Policy. EPA has to ensure that it treats all employees equitably. 

In EPA Order 3120.1, Conduct and Discipline, September 1985, 

The Environmental Protection Agency requires all its employees to adhere 

to the Agency Regulations on Employee Responsibilities and Conduct (40 

CFR, Part 3) and to maintain levels of behavior and efficiency that 

conform to the highest ethical standards and promote the interest of EPA 

and the Federal Service. Likewise, all managers and supervisors are 

responsible for maintaining a climate of constructive discipline within 

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10-P-0002 

their organizations by good example and practice, clear instruction, fair 

and equal treatment of all employees, and firm and decisive leadership. 

Work Designation Separate from the Position of Record Practice. Although there is 

no Agency policy to establish a duty station separate from the position of record, OARM 

personnel in the Office of Human Resources1 stated the unauthorized practice does occur. 

OARM thus described a situation where the position of record stays the same, the 

employee moves to a different geographical location, and the Agency initiates a 

personnel action that changes the employee’s locality pay entitlement. It may or may not 

entail reimbursable travel expenses. OARM had started to develop, but did not complete, 

guidance to cover this situation. The unissued guidance did not provide direction on 

what the Agency administrative coordination process should be to change an employee’s 

duty station to a place other than the position of record. The unissued guidance did not 

address establishing the employee’s home as a duty station. However, the draft guidance 

would require that the OARM Assistant Administrator approve all such requests. 

Remote Reporting Practice. Although there is no authorized remote reporting policy, 

OARM personnel stated this practice also occurs. The Associate Deputy Director of 

Program Management & Communications described remote reporting as when a worker 

is not in the office or with the first line supervisor (full-time). The Team Leader, 

Compensation & Work-Life Team, added that remote reporting means the employee 

performs all or most duties at a location a considerable distance from the employee's 

official worksite/duty station and position of record. There is no official documentation 

for this arrangement or duty station change. This arrangement is usually a personal 

accommodation the Agency makes for the employee's convenience and there is no 

official personnel status change associated with this arrangement. Consequently, 

transportation expenses, either permanent or temporary, are not permissible in this 

circumstance. The Associate Deputy Director of Program Management & 

Communications said remote reporting has crept into existence over the past 20 years. 

Scope and Methodology 

We conducted our review from January 27 to July 29, 2009. We conducted this evaluation in 

accordance with generally accepted government auditing standards. Those standards require that 

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

reasonable basis for our findings and conclusions based on our evaluation objectives. We believe 

the evidence obtained provides a reasonable basis for our findings and conclusions. Generally 

accepted government auditing standards require that auditors obtain an understanding of internal 

controls significant to the audit objectives and consider whether specific internal control 

procedures have been properly designed and placed in operation. 

We focused on the NETI main office located in Washington, DC. We interviewed all program 

staff and managers from the NETI main office. We obtained and reviewed public law, Office of 

1

 They were the Associate Deputy Director of Program Management & Communications, the Agency Telework 

Coordinator, and the Team Leader, Compensation & Work-Life Team. 

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10-P-0002 

Personnel Management and EPA policies pertaining to work arrangements, locality pay, and 

travel compensation. These included but were not limited to: 

• Title 5 U.S. Code part 531 Section 605 

• Title 5 U. S. Code Chapter 61 

• Public Law 106-346 

• Public Law 105-277 

• Public Law 104-52 

• EPA Flexiplace Policy 3180 

• A Guide to Telework in the Federal Government 

• The GSA (General Services Administration)Telework Portal 

• Title 5 U. S. Code Section 5702 Per Diem, Employee Travel and Official Business 

• Official Worksite and Travel Related Policies 

• Title 5 U. S. Code Sections 2301 and 2302 

• Uniform Criteria and Procedures for Requesting and Assigning Alternative Work Space 

• Alternative Work space – Frequently Asked Questions 

We also examined the subject employee’s expense vouchers provided by NETI to review the 

miscellaneous and travel expenses that were reimbursed by NETI. In addition, we interviewed 

the OARM Office of Human Resources personnel including the Director of Human Resources 

Policy Division; the Team Leader, Compensation & Work–Life Team; the Agency Telework 

Coordinator; and the Associate Deputy Director of Program Management & Communications on 

personnel and pay policies. 

Results of Review 

We found an approximately 9-year-old unauthorized full-time work-at-home arrangement that 

allows a NETI employee to work from home in Ohio for an office in Washington, DC. This 

arrangement is not supported by policy because EPA has no formal policy for work 

arrangements where the duty station location is separate from the position of record. The 

employee and position were originally located in the Washington area but the employee moved 

after the spouse received a job transfer. Neither OARM nor NETI have any written 

documentation showing the government interest or appropriateness of making this arrangement, 

or that senior OARM officials approved this action. The Agency incurred no permanent change 

of station costs when the Agency changed the employee's duty station location and locality pay 

to the home in Ohio. NETI requested and OARM approved changing the position from part time 

(64 hours per pay period) to full time (80 hours per pay period) concurrent with the move, which 

increased the total compensation to the employee. 

NETI Rationale for the Decision 

In providing its rationale for allowing the subject arrangement, the NETI Deputy Director 

told us that the employee had advised management that the employee would have to 

resign because the spouse had received a job transfer to Ohio. The NETI Deputy 

Director noted there was an Agency hiring freeze at the time, so the position would not 

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10-P-0002 

be filled. The NETI Deputy Director said the personnel loss would have resulted in a net 

loss of capability. The NETI Deputy Director also wanted to retain the employee 

because the employee was considered to be very valuable. As such, the then NETI 

Director tasked the Deputy Director to find a way to keep the employee. 

The NETI Deputy Director said she worked with the OECA Human Resources contact, 

who in turn worked with OARM on the solution. The Deputy Director said the nowretired OARM staff advised that changing the duty location via the Standard Form 52 

would be appropriate and all that was needed to make the solution complete. We have 

not found any corroborating evidence to verify any conversation between OARM and 

NETI management on this topic. Based on the OARM advice NETI stated it received, 

the NETI Deputy Director said an offer was made to the employee, who accepted. 

There is no policy to authorize the action taken. Further, we found documentation 

justifying the situation reviewed to be lacking. In particular, we found no documentation 

showing that: 

•	 A senior OARM official approved the decision and considered the effects on 

employee morale and the public’s perception of EPA. 

•	 NETI based the decision on policy applicable to all EPA employees. 

•	 This particular job was mission critical. 

•	 Employees with this skill-set were difficult to replace. 

•	 Existing NETI employees could not have absorbed these functions. 

•	 The action benefited the government. 

•	 The position description and grade level remained accurate for the duties being 

performed at the new work location. 

However, the NETI Deputy Director stated they tried to find the employee a job in 

another agency, until they decided to change the duty station to the new home. This 

creates the impression that NETI’s actions were for the benefit of the individual 

employee rather than the Agency. 

The OARM Associate Deputy Director of Program Management & Communications and 

the Agency Telework Coordinator stated that the Agency has a culture that continues to 

make similar arrangements outside of policy, with little or no justification. Further, in 

some cases, these arrangements were made without appropriately changing the 

employee’s duty station. We believe these arrangements raise equity concerns because 

the Agency has not developed policy to determine how and when employees are eligible 

for this arrangement. 

The NETI Deputy Director said the arrangement made in this case is available to other 

NETI employees if the employee and the work are well suited. However, NETI has not 

communicated this option to employees or made a similar offer. Further, the NETI 

Deputy Director did not have any documented criteria to administer the grant of 

privilege. 

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Cost and Equity 

The employee’s pay status changed from part time to full time as part of the change in 

duty station. Although the pay rate for Ohio is lower, the employee received a 13.46 

percent pay increase because of the change in pay status. In addition, the Agency 

incurred travel costs for the subject employee to travel to and from the main office in 

Washington, DC, that amounted to $17,458 from September 2000 to October 2008. 

Consequently, the Agency paid significantly more for the employee’s services after the 

change in duty station. 

OARM Concerns 

The Associate Deputy Director of Program Management & Communications, and the 

Agency Telework Coordinator told us they knew of other examples within EPA where 

managers had shown a willingness to make similar arrangements, and indicated there 

may be other existing arrangements they have not discovered. From the perspective of 

the Associate Deputy Director of Program Management & Communications, and the 

Agency Telework Coordinator, these arrangements exist outside of policy and the 

justifications for the arrangements were either lacking or weak. The Associate Deputy 

Director of Program Management & Communications raised concerns about equity in the 

opportunity to participate in such little known arrangements and reiterated such 

arrangements made outside of policy and with little or no justification represents a real 

and present risk for future litigation. The Associate Deputy Director of Program 

Management & Communications stated long-term work-at-home arrangements may at 

times be appropriate and an appropriate solution would be an Agency-wide policy to 

address the EPA position on all work arrangements where the duty station and position of 

record are different. A previous draft of policy attempted to address the Agency 

determination of employee's official duty station, application, and approval. The draft 

policy also addressed justifications, review, and formal approval. In our opinion, the 

Agency should establish administrative policy to provide criteria for justification and a 

centralized process for review and approval to safeguard the government's and the 

individual's interests. 

Conclusion 

In our opinion, NETI’s actions are for the benefit of a single employee as opposed to being 

primarily in the interest of the government. EPA has no established or consistent policy, 

procedure, or criteria; the opportunity appears available to only a few employees; and there is no 

justification or objective review indicating that the action was in the government’s interest. EPA 

should establish appropriate Agency policy and procedures that are consistently and fairly 

applied. This policy should include eligibility criteria for positions and personnel, records 

management requirements, periodic review and reauthorization, verification of correct pay rate 

(locality and grade) and specific approvals required from initial submission to final approval to 

ensure equity. Existing arrangements outside of current policy, such as the NETI allegation, 

should be objectively assessed and modified or terminated as necessary. 

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Recommendations 

We recommend that the Deputy Administrator: 

1. Assign responsibility for authorizing all non-OARM geographically separate duty 

station changes to the Assistant Administrator for OARM. 

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

2a. Establish and implement Agency policy for all EPA employees that clearly articulates 

the process and procedures for changing an employee’s duty station to a location 

geographically separate from the position of record. This policy should include 

eligibility criteria for positions and personnel, records management requirements, 

periodic review and reauthorization, verification of correct pay rate (locality and grade) 

and specific approvals required from initial submission to final approval to ensure 

equity. The policy should require the Assistant Administrator for OARM to be the final 

decision authority for all geographically separate duty station locations authorizations 

except those duty station location changes initiated within OARM. 

2b. Identify and review all existing arrangements of full-time work-at-duty-station separate 

from the position of record, including the situation that was the subject of this review, 

and bring each of these arrangements into compliance with implemented EPA policy. 

Summary of Agency Responses and OIG Evaluation 

The Agency generally concurred with the recommendations and offered other insights into the 

report. On Recommendation 1 the Agency concurred that a central approval authority for all 

work at home arrangements was necessary but could not decide at the time where it should be. 

The Agency can provide its decision and rationale in the 90 day response to this report. The 

Agency concurred with Recommendation 2a and has set January 2010 as a target for developing 

the policy. The Agency concurred with Recommendation 2b and has stated that a review of the 

existing arrangements should be completed 6 months after the new policy is implemented. The 

Agency requested that we define the use of “manager” when referring to OARM personnel we 

interviewed in the report. We removed the term “manager” and inserted the titles of the 

personnel interviewed. The Agency was concerned that using a number for the other 

arrangements was inappropriate because we had not verified the supporting data. We did not 

validate the number of existing arrangements as we believed the Agency should do so after 

developing a policy. We changed the report to refer to them as other arrangements. 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

1 6 Assign responsibility for authorizing all non-OARM 

geographically separate duty station changes to 

the Assistant Administrator for OARM. 

O Deputy Administrator 

2a 6 Establish and implement Agency policy for all EPA 

employees that clearly articulates the process and 

procedures for changing an employee’s duty 

station to a location geographically separate from 

the position of record. This policy should include 

eligibility criteria for positions and personnel, 

records management requirements, periodic review 

and reauthorization, verification of correct pay rate 

(locality and grade) and specific approvals required 

from initial submission to final approval to ensure 

equity. The policy should require the Assistant 

Administrator for OARM to be the final decision 

O Assistant Administrator for 

Administration and 

Resources Management 

01/31/2010 

authority for all geographically separate duty 

station locations authorizations except those duty 

station location changes initiated within OARM. 

2b 6 Identify and review all existing arrangements of 

full-time work-at-duty-station separate from the 

position of record, including the situation that was 

the subject of this review, and bring each of these 

arrangements into compliance with implemented 

EPA policy. 

O Assistant Administrator for 

Administration and 

Resources Management 

07/31/2010 

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 

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Appendix A 

Agency Response to Draft Report 

August 19, 2009 

MEMORANDUM 

SUBJECT: Office of Inspector General Draft Hotline Report: Review of Hotline Complaint 

on Employee Granted Full-time Work-at-Home Privilege 

Project No. OPE-FY09-004 Hotline 2008-096, July 30, 2009 

FROM: Scott C. Fulton 

Acting Deputy Administrator, Environmental Protection Agency 

Cynthia Giles 

Assistant Administrator for Enforcement and Compliance Assurance 

Craig E. Hooks 

Assistant Administrator for Administration and Resources Management 

TO: Bill A. Roderick 

Acting Inspector General 

Office of Inspector General 

Thank you for the opportunity to respond to the concerns that you have raised in the 

above-referenced draft Hotline Report. 

As a result of an anonymous hotline complaint the Office of the Inspector General (OIG) 

conducted a review to determine whether an EPA employee was inappropriately granted fulltime work at home status. In the draft report, the OIG reviewed a situation in which the Agency 

authorized a change of duty location for an OECA, National Enforcement Training Institute 

(NETI) employee previously assigned to Washington, DC and subsequently allowed to work 

from the employee’s home residence in Ohio. 

The OIG found that at the time of this change in duty location there was no policy in 

place that would have governed this action and that documentation justifying the approval was 

lacking. OIG concluded that this change of duty location was “for the benefit of a single 

employee as opposed to being primarily in the interest of the government,” and that this action 

“was not equitably provided within NETI.” The OIG appropriately points out that EPA does not 

yet have a final policy in place that would govern this type of personnel action. 

The OIG recommended two (2) actions to address the concerns that were raised: 

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OIG Recommendations and EPA Response 

Recommendation 1: That the Deputy Administrator assign responsibility for authorizing 

all non-OARM duty station changes to the Assistant Administrator for OARM. 

We agree that the process for authorizing all duty station changes needs to be one that assures 

consistency and equity in application. Operationally this calls for some type of central review 

point that will assure that established criteria are met and approval/disapproval decisions made 

consistently. We believe, however, that there may be a variety of review and approval 

mechanisms that achieve efficient and effective results, including having all such decisions made 

by the Assistant Administrator for OARM. EPA will address this issue when developing a final 

Agency policy regarding duty station changes and the OIG will have an opportunity to review 

and comment on the Agency’s proposal. 

Recommendation 2a: That the Assistant Administrator for OARM establish and 

implement Agency policy that clearly articulates the process and procedures for changing 

an employee’s duty station to a location geographically separate from the position of record 

for all EPA employees. 

Response: We agree with the OIG’s conclusion that the Agency does not currently have a policy 

that clearly articulates the process and procedures for changing an employee’s duty station to a 

geographic location separate from the employee’s organization. EPA has been working on 

developing such a policy and agrees that OARM will have the lead for completion of this task. 

Because there remains a need for considerable cross-region and program office collaboration to 

finalize such a policy, we are setting a target date of January, 2010 for issuance of the final 

policy. 

Recommendation 2b: That the Assistant Administrator for OARM identify and review all 

existing arrangements of full-time work at a duty station separate from the position of 

record, including the situation that was the subject of this review, and bring each of these 

arrangements into compliance with the implemented EPA policy. 

Response: We agree with this recommendation. The Agency will identify and review each 

situation where employees work at a duty station separate from the position of record to 

determine the most appropriate next steps, working to bring each case into compliance with the 

policy referenced in our answer to 2a above. We are setting a target date of 6 months after final 

promulgation of the new policy for completion of this review. 

Additional Comments on the Draft Report 

We appreciate and encourage the OIG staff to reach out to EPA employees and gather data that 

are relevant to reports such as this. We count on the integrity of the OIG to assure that the 

information they choose to use is accurate and verifiable and that the sources of their information 

are credible. We would note that it would be helpful to clearly define the term “manager” or 

“management” when presenting interview responses. 

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Also, the reference in the draft report to the existence of “54 similar arrangements” reported by 

”OARM management” and the note that ”these arrangements exist outside of policy and the 

justifications for the arrangements were either lacking or weak” could be erroneous. The draft 

report does not define or describe these “similar arrangements.” Further, OARM management is 

not aware of 54 arrangements similar to the one referenced in the draft report and is concerned 

that this information may be inaccurate. 

Again, thank you for providing the opportunity to review and respond to this draft report. 

If you have any questions, please contact either myself or Susan Hazen. We can both be reached 

at 202-564-4600. 

cc: Director NETI: Mail Code 2235A 

 OECA Audit Liaison: Mail Code 2201A 

OARM Audit Liaison: Mail Code 3102A 

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Appendix B 

Distribution 

Office of the Administrator 

Acting Deputy Administrator 

Assistant Administrator for Administration and Resources Management 

Assistant Administrator for Enforcement and Compliance Assurance 

Director, National Enforcement Training Institute 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

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

Audit Follow-up Coordinator, Office of Enforcement and Compliance Assurance 

Acting Inspector General 

11