U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Special Report 

EPA Recovery Act 

Recipient Reporting and 

Data Review Process 

Report No. 10-R-0020 

 October 29, 2009 
Report Contributors: Rudolph M. Brevard 

 Cheryl Reid 

 Neven Morcos 

Abbreviations 

ARRA American Recovery and Reinvestment Act 

EPA U.S. Environmental Protection Agency 

OMB Office of Management and Budget 

Cover Illustration: The logo for the American Recovery and Reinvestment Act. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

October 29, 2009 

The Honorable Earl Devaney 

Chairman 

Recovery Accountability and Transparency Board 

Washington, DC 

Dear Chairman Devaney: 

Attached are the results of our limited review of the U.S. Environmental Protection Agency’s 

(EPA’s) process for performing data quality reviews of recipient-reported data, as required by 

the American Recovery and Reinvestment Act (ARRA, or Recovery Act) of 2009. The 

Recovery Act awarded $7.2 billion to EPA. We conducted this review to determine whether 

EPA established a process to perform limited data quality reviews intended to identify material 

omissions and/or significant reporting errors, and to notify the recipients of the need to make 

appropriate and timely changes. In the attachment, we provide details for the six specific areas 

for which you requested information. 

Office of Management and Budget (OMB) Memorandum 09-21 requires Federal agencies to 

develop internal policies and procedures for reviewing reported data and to highlight certain data 

elements for review. In addition, the memorandum provides a timeline and guidance for (1) 

recipients to register and report required data, and (2) Federal agencies to review and comment 

on reported information. The memorandum defines the scope of those data quality reviews, with 

a focus on material omissions and significant reporting errors, and requires Federal agencies to 

continuously evaluate recipient efforts to meet Recovery Act reporting requirements. 

We performed this audit during October 2009 at EPA Headquarters in Washington, DC. We 

performed this audit in accordance with generally accepted government auditing standards. 

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

evidence. The evidence is to provide a reasonable basis for our findings and conclusions. We 

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

We reviewed EPA’s policies and procedures for reviewing quarterly Recovery Act data and met 

with the Agency’s Recovery Act governing officials to discuss those policies and procedures in 

addition to the review questions. We had not performed prior reviews/audits related to Recovery 

Act data quality reviews. 
Although we did not test implementation of EPA’s procedures for reviewing quarterly Recovery 

Act data, we believe the Agency sufficiently designed its internal controls to detect material 

omissions and significant reporting errors. 

We shared our results with EPA officials and they generally agreed with the results of this 

review. 

If you or your staff have any questions regarding this report, please contact me at (202) 566-0894 

or hill.patricia@epa.gov; or Rudolph M. Brevard, Director, Information Resources Management 

Assessments, at (202) 566-0893 or brevard.rudy@epa.gov. 

 Sincerely,

 Patricia H. Hill 

 Assistant Inspector General for Mission Systems 

Attachment 
10-R-0020 

Attachment 1 

RECOVERY ACT REPORTING 

Data Quality Review Guide 

For the Inspector General Community 

U.S. Environmental Protection Agency 

1) Obtain the Federal agency’s policy and procedures for reviewing quarterly Recovery 

Act data pursuant to OMB Memorandum 09-21 (section 3.12). 

The Agency provided us with the following five documents, one of which is still in draft format. 

The first two documents listed below discuss the Agency’s process for reviewing quarterly 

Recovery Act data. In response to our question as to when the EPA draft Procedure for Review 

of Recovery Act data will be finalized, Agency officials indicated it is a “living document” that 

will keep changing to meet OMB requirements, and no date has been set to issue the final 

procedure. In addition, the Agency later indicated that based on discussions with OMB and the 

Recovery Accountability and Transparency Board, there will be a “lessons learned” review of 

this initial reporting cycle and adjustments may be made. This will require agencies, including 

EPA, to modify how and what they are reviewing. 

3⁄4 EPA Procedure for Review of ARRA Section 1512 Recipient Reported Information 

(DRAFT – V4, October 2009) 

3⁄4 EPA ARRA Reviewer Guidance (October 2009) 

3⁄4 Management Action Plan I (May 2009) 

3⁄4 Management Action Plan II (October 2009) 

3⁄4 EPA Stewardship Plan (July 2009) 

2) Determine how the Agency plans to ensure that all prime recipients have filed the 

required quarterly reports pursuant to section 1512 of the Recovery Act and how the 

Agency will ensure that it conducts the required reviews of the reported data. 

EPA will conduct a limited review of recipient-reported information associated with the six 

Agency programs with related Recovery Act resources. Agency-specific recipient submission 

data will be supplied by FederalReporting.gov via a data feed to EPA no later than the 21st day 

following quarter end. The data shall be composed of all submitted recipient data received on or 

before the 10th day following quarter end. The Agency later indicated that they have 

implemented an informal review beginning on day 11 of the cycle. This involves obtaining an 

extract from federal reporting.gov, producing the identified exception reports and posting on the 

Agency’s management dashboard, and informally contacting recipients to discuss and clarify any 

identified issues. Extracted data will be used to assist reviews in two areas of emphasis. The 

first area will be those data elements subject to a central, macro (Agency-wide) review across all 

programs. The second area will be a review locally by National Program Managers and regional 

staff. After completing the macro and local reviews, omissions and errors will be noted and 

comments provided in the Federal reporting solution. 

To ensure prime recipients submit required reports for the first reporting cycle, Agency officials 

indicated EPA completed a cross check of all DUNs1

 numbers associated with EPA stimulus 

assistance and contracts against FederalReporting.gov registrants. The Agency’s process for 

1

 A Dun &Bradstreet® D-U-N-S® Number is a unique nine-digit sequence recognized as the universal standard for identifying 

and keeping track of over 100 million businesses worldwide. 

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10-R-0020 

RECOVERY ACT REPORTING 

Data Quality Review Guide 

For the Inspector General Community 

U.S. Environmental Protection Agency 

ensuring that reviews were completed consists of an established feedback loop where recipient 

programs report to a lead person within their geographical area. When reviews are completed, 

the lead person reports to the Acting Deputy Assistant Administrator for Environmental 

Information, who then reports to the Assistant Administrator for Administration and Resources 

Management/Recovery Act Senior Accountability Official. Further, Agency officials indicated 

that, in many cases, they rely on the prime recipients to ensure reviews are completed for 

subrecipients. 

3) Conduct a walk-through of the agency’s process to perform limited data quality 

reviews. 

The Agency’s process was designed in accordance with OMB Memorandum 09-21. See 

response to question 1 above for a description of the Agency’s process. 

4) Determine whether the agency’s policy and procedures have been designed to 

emphasize the avoidance of two key data problems: material omissions and significant 

reporting errors. 

Agency officials indicated that EPA’s limited review focuses on two primary elements: material 

omissions and significant errors. They indicated that they will rely on FederalReporting.gov to 

minimize material omissions related to specific data fields by requiring completed data fields for 

successful transmission. In addition, they will continue to cross check DUNs numbers with 

reports submitted each reporting cycle to identify any missing reports. EPA’s macro reviews 

will identify potential errors based on pre-established action limits. Any data elements flagged 

in a macro review are subject to follow-up by the involved program. Local reviews will identify 

clear errors or anomalies. Further, the Agency generates reports for identifying major omissions 

and potential significant errors. 

We asked Agency officials about other measures they take to prevent errors during submissions. 

OMB Memorandum 09-21 states “a material omission may still occur to the extent submitted 

data is not responsive to a specific data request.” Agency officials indicated they concentrate on 

significant issues within the applicable reporting period, and that they will handle small errors in 

subsequent reporting periods so that the errors do not persist. 

We asked Agency officials about controls for preventing double counting in the case of prime 

recipient and subrecipient reporting. They indicated that they match who reported the data 

against recipient or award data. They stated that in doing the reviews, data has been matching 

well with submitters thus far. 

5) Determine whether the Agency has an adequate process in place to remediate systemic 

or chronic reporting problems. 

EPA plans to monitor closely the progress and performance of reporters from quarter to quarter 

to identify problems that could be deemed systemic or chronic. After the first reporting cycle 

has been completed, EPA plans to assess the extent and nature of any material omissions or 

reporting errors. Based on that assessment, tailored outreach to reporters will be used to mitigate 

continued issues in subsequent reporting periods. 

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RECOVERY ACT REPORTING 

Data Quality Review Guide 

For the Inspector General Community 

U.S. Environmental Protection Agency 

We asked Agency officials about their process for elevating systemic or chronic problems to the 

governing body. They indicated that each recipient program is required to report to the Recovery 

Accountability and Transparency Board. They have not yet identified the form in which 

problems will be reported. They indicated that these details are on the governing body’s agenda 

and will be addressed in the near future. 

6) With the understanding that OMB Memorandum 09-21 is a reporting tool rather than 

a management tool, determine whether the agency anticipates that it will be able to use 

the reported information as a tool for: 

a) assessing compliance with the terms and conditions of award agreements, 

b) assessing risk, and 

c) determining when to release remaining funds. 

EPA has developed a series of exception reports as part of its review process. These reports will 

allow the Agency to identify material omissions or significant reporting errors by grant and 

contract recipients. Under the terms of EPA’s Stewardship Plan, the Agency will use these 

reports, along with other information generated during post-award monitoring, to assess 

compliance with grant and contract terms and conditions. The Agency will also use the reports 

to identify/mitigate risks associated with providing the public misleading or confusing 

information or jeopardizing OMB accountability objectives. 

We asked Agency officials if they have found the Recovery Act’s recipient reporting and review 

process to be useful. They indicated that this process has promoted consistency with its program 

and regional offices and promoted emerging controls. It has allowed the Agency to learn about 

their existing processes where they are doing things correctly, and how to improve where 

needed. They indicated that they will use reports created for compliance checks with other grant 

and contract systems in checking accuracy of information. 

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Appendix A 

Distribution 

Office of the Administrator 

Acting Assistant Administrator for Environmental Information and Chief Information Officer 

Acting Deputy Assistant Administrator for Environmental Information 

Assistant Administrator for Administration and Resources Management 

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

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Acting Inspector General 

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