U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Audit Report 

EPA Did Not Properly Account for All 

Property for Implementing Homeland 

Security Presidential Directive-12 

 Report No. 09-P-0233 

 September 15, 2009 
 

 

 

 

Report Contributors:	 Nancy Dao 

 Mike Davis 

Heather Layne 

Janet Kasper 

Abbreviations 

EPA U.S. Environmental Protection Agency 

FAS Fixed Assets Subsystem 

HSPD Homeland Security Presidential Directive 

IFMS Integrated Financial Management System 

OIG Office of Inspector General 

SMD Security Management Division 

Cover photos: From left: EPA’s ID Proofing Station, Enrollment Station, and 

Issuance Station used to issue Smartcards. (EPA photos) 
 

 

 

 

09-P-0233 U.S. Environmental Protection Agency September 15, 2009 

Office of Inspector General 

At a Glance
 

Catalyst for Improving the Environment 

Why We Did This Review 

We initiated this audit based 

on a hotline complaint related 

to Homeland Security 

Presidential Directive 

(HSPD)-12 and the fact that 

the U.S. Environmental 

Protection Agency (EPA) had 

nearly $1 million in such 

property. Our objective was 

to determine whether property 

purchased to support 

HSPD-12 was accounted for 

in accordance with EPA 

policies and procedures. 

Background 

HSPD-12, Policy for a 

Common Identification 

Standard for Federal 

Employees and Contractors, 

established a mandatory, 

government-wide standard for 

secure and reliable forms of 

identification issued by the 

Federal Government to its 

employees and contractors. 

HSPD-12 requirements 

included identity proofing, 

registration, card issuance, and 

card management. 

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/ 

20090915-09-P-0233.pdf 

EPA Did Not Properly Account for All Property for 

Implementing Homeland Security Presidential Directive-12 

What We Found 

EPA generally recorded HSPD-12 property accurately in EPA’s Fixed Assets 

Subsystem (FAS). However, we noted the following discrepancies: 

•	 four pieces of property valued at $29,538 were missing and not recorded 

in FAS, 

•	 acquisition costs in FAS were incorrect for some equipment, and 

•	 nonfinancial information for several pieces of property was not accurately 

recorded. 

To meet an Office of Management and Budget deadline, EPA shipped property to 

other EPA locations before the property was recorded in FAS. Effective personal 

property management requires integration of property and financial management 

records. Incorrect information in FAS could have an adverse effect on the 

Agency’s financial statements. 

The contract for implementing HSPD-12 did not include clauses to address 

property management responsibilities. Tasks under the contract statement of work 

required the contractor to account for the property as if it were governmentfurnished property, but because the property was used in government facilities, 

EPA did not consider the property to be government-furnished property. 

Consequently, the contract did not properly reflect the status of the property. 

As a result of the deficiencies noted, there is an increased risk of loss of 

government property and inaccurate reporting. 

What We Recommend 

We recommend that EPA use established procedures to resolve accountability for 

the missing property, and review accuracy of HSPD-12 property information in 

FAS and update any discrepancies. We also recommend that EPA modify the 

HSPD-12 contract to reflect contractor requirements and accountability for using 

government property in government facilities. 

The Agency concurred with the report recommendations and provided corrective 

action plans. EPA established a December 2009 milestone for resolving missing 

HSPD-12 property and updating FAS with accurate records. The Agency also 

modified the contract on July 22, 2009, to reflect contractor requirements and 

accountability for the HSPD-12 property. 
 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

September 15, 2009 

MEMORANDUM 

SUBJECT:	 EPA Did Not Properly Account for All Property for Implementing 

Homeland Security Presidential Directive-12 

 Report No. 09-P-0233 

FROM:	 Melissa M. Heist 

Assistant Inspector General for Audit 

TO:	 Craig Hooks, Assistant Administrator 

 Office of Administration and Resources Management 

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

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the 

problems the OIG has identified and corrective actions the OIG recommends. This report 

represents the opinion of the OIG and does not necessarily represent the final EPA position. 

EPA managers in accordance with established resolution procedures will make final 

determinations on matters in this report. 

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

applicable daily full cost billing rates in effect at the time – is $123,103. 

Action Required 

In responding to the draft report, the Agency provided corrective action plans for addressing all 

of the recommendations. Therefore, a response to the final report is not required. The Agency 

should track corrective actions not implemented in the Management Audit Tracking System. 

We have no objections to the further release of this report to the public. The report will be 

available at http://www.ega.gov/oig. 

If you or your staff have any questions regarding this report, please contact Janet Kasper at 

(312) 886-3059 or kasper.janet@epa.gov, or Michael Davis at (513) 487-2363 or 

davis.michaeld@epa.gov. 
 

 

 

 

 

 

 

 

EPA Did Not Properly Account for All Property for 09-P-0233 

Implementing Homeland Security Presidential Directive-12 

Table of Contents 

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

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

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

Results of Review .......................................................................................................... 2 

EPA Fixed Assets System Is Not Always Accurate.............................................. 3 

EPA Did Not Update HSPD-12 Implementation Contract .................................... 5 

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

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

Status of Recommendations and Potential Monetary Benefits................................. 8 

Appendices 

A Agency Response to Draft Report ................................................................... 9
 

B Distribution ......................................................................................................... 12
 
 09-P-0233 

Purpose 

We initiated this audit based on a hotline complaint related to Homeland Security Presidential 

Directive (HSPD)-12, which alleged that property was shipped to regional offices and labs 

without being recorded in EPA’s Fixed Assets Subsystem (FAS), and the fact that the U.S. 

Environmental Protection Agency (EPA) had nearly $1 million in such property. Our objective 

was to determine whether property purchased to support HSPD-12 was accounted for in 

accordance with EPA policies and procedures. 

Background 

HSPD-12, Policy for a Common Identification Standard for Federal Employees and 

Contractors, issued August 27, 2004, established a mandatory, government-wide standard for 

secure and reliable forms of identification issued by the Federal Government to its employees 

and contractors. HSPD-12 program requirements include identity proofing, registration, card 

issuance, and card management. EPA’s Security Management Division (SMD) is responsible for 

implementing HSPD-12. SMD is within the Office of Administration and Resources 

Management’s Office of Administration, which is responsible for the acquisition of all Agency 

facilities, property management, and property security. 

EPA selected a contractor to serve as both the designer and implementer of EPA’s HSPD-12 

program. This included but was not limited to providing technical and programmatic support; 

project management services; and the configuration, installation, operation, and acquisition of 

new and existing systems. Property purchased for implementation of the directive included: 

•	 ID Proofing Station - Dell Laptop or Desktop, ViiSage Authenticator, Intellicheck Card 

Reader, and HP Flatbed Scanner. 

•	 Enrollment Station - Dell Laptop or Desktop, SIIG Firewire Card, Belkin Hub, Identix 

Touch Print Scanner, and Canon Digital Camera. 

•	 Issuance Station - Dell Laptop/Desktop, Fargo High Definition Printer 600, Precise 

Reader, numeric keypad, and Omni Key Card Reader. 

The cover of this report contains pictures of the three stations. 

EPA’s Personal Property Policy and Procedures Manual prescribes policy and procedural 

guidance for personal property management by EPA employees and contractors. According to 

the manual: 

•	 Control of accountable personal property is to be established in EPA’s Integrated 

Financial Management System (IFMS) upon receipt of property and must be maintained 

until disposal. 

•	 Accountable personal property is personal property with an acquisition cost of $5,000 or 

more, all leased personal property, and sensitive items. Sensitive items are those that 

have a high potential for theft, including laptop computers, digital cameras, and scanners. 

•	 Property accountable officers and custodial officers are responsible for accounting for 

accountable personnel property, including sensitive items. 

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 09-P-0233 

•	 Determination of the cost used in recording personal property in the appropriate accounts 

is an essential element of personal property accounting. 

FAS supports the accounting and managing of physical property items. FAS interfaces with 

IFMS subsystems to support fiscal and risk management as well as standard reporting. FAS 

maintains the original and subsequent value of assets as well as replacement values. According 

to SMD’s custodial officer, SMD is responsible for recording information on equipment 

supporting HSPD-12 in FAS. SMD reported the purchase of $977,918 in HSPD-12 property as 

of October 6, 2008. 

Scope and Methodology 

We conducted this audit from September 2008 through June 2009 in accordance with 

generally accepted government auditing standards. Those standards require that we plan 

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

basis for our findings and conclusions based on our audit objective. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on 

our audit objective. 

We visited EPA Headquarters in Washington, DC, where we met with SMD management 

responsible for the oversight and control of HSPD-12 property. We interviewed Office 

of Administration and Resources Management staff, such as the property accountable 

officer, contracting officer, contract property coordinator, and SMD’s custodial officer, to 

determine the processes used to manage and account for HSPD-12 property. 

We assessed the internal controls relevant to our objective. We gained an understanding of the 

internal controls by reviewing EPA’s Personal Property Policy and Procedures Manual, 

Contracts Management Manual, Acquisition Regulations, and Custodial Officer’s Guide. To 

determine whether property purchased in support of HSPD-12 was accounted for in accordance 

with EPA policies and procedures, we reviewed documentation, such as contracts, modifications, 

and statements of work. We also reviewed property information recorded in the Agency’s FAS, 

SMD’s and the contractor’s listing of property, and EPA orders and invoices for supplies. 

Our scope was limited to evaluating EPA activities as they related to property acquired to 

support implementation of HSPD-12; we did not evaluate Agency activities as they related to 

accountability for any other property. 

We are not aware of any prior report recommendations specifically related to this report’s audit 

objective. 

Results of Review 

EPA generally recorded HSPD-12 property accurately in FAS. However, several items were not 

recorded in FAS and could not be located, and cost information and other information was not 

always properly recorded in FAS. Further, the EPA contract statement of work for implementing 

HSPD-12 required the contractor to maintain an inventory of the property as if it were 

2 
 

 

 09-P-0233 

government furnished despite the Agency’s determination that it is not government-furnished 

property. As a result of the deficiencies noted, there is an increased risk of loss of government 

property and inaccurate reporting. 

EPA Fixed Assets System Is Not Always Accurate 

Four pieces of property, valued at $29,538, were missing and not recorded in FAS. Also, the 

acquisition cost recorded for property in FAS was incorrect, and nonfinancial information for 

several pieces of property was not accurately recorded. To meet an Office of Management and 

Budget-mandated deadline, the Agency shipped property to other EPA locations before it was 

recorded in FAS. Effective personal property management requires integration of property 

records and financial management records; incorrect information in FAS could potentially have 

an adverse affect on the Agency’s financial statements. 

Missing Property 

SMD discovered four pieces of equipment, valued at $29,538, missing when property 

was transitioned from the previous contractor to the current contractor. The four items in 

the records of the previous contractor but not transferred to the current contractor are 

listed in Table 1. 

Table 1: Missing Items 

Item Cost 

Camera $2,025 

Fargo Printer 8,321 

ViiSage Authenticator 9,596 

ViiSage Authenticator 9,596 

Total $29,538 

Source: SMD 

The missing items were not recorded in FAS, or SMD’s or the contractor’s listing of 

HSPD-12 property. SMD’s director stated that an equipment inventory reconciliation 

was performed before transitioning property to the current contractor (the new contract 

was awarded on March 12, 2008). The four pieces of equipment were not located during 

the reconciliation. SMD has disapproved the final invoice submitted by the previous 

contractor pending resolution. 

The Agency should use the established policies and procedures for lost, damaged, or 

destroyed property that are in the Personal Property Policy and Procedures Manual to 

resolve accountability for the missing property. These procedures include notifying the 

security office and property accountable officer; preparing a Survey Report 

Memorandum describing the circumstances of the lost, damaged, or destroyed property; 

and submitting the memorandum to the property accountable officer. After review, the 

property accountable officer submits information to the property management officer, 

who determines whether to convene the Board of Survey. The Board of Survey serves as 

a fact-finding body charged with determining the circumstances and conditions when 

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property is declared lost, damaged, or destroyed, and issues findings and 

recommendations to the property management officer for action. 

Inconsistent Cost Information in FAS 

We found 31 instances in which property was incorrectly recorded in FAS (see Table 2) 

and thus in IFMS. The recorded value for these 31 items totaled $200,419. Property cost 

provided by SMD was not consistent with the cost recorded in FAS. For example, items 

such as laptops and scanners were purchased by SMD as a “kit,” but these items were 

listed as separate items with different costs in FAS. SMD is currently working on 

determining the unit cost and updating any incorrect information in FAS. 

Table 2: Cost Recorded for 31 Property Items 

No. of 

Items Description 

SMD Listing 

of Cost 

Total 

SMD 

Cost 

FAS Listing 

of Cost 

Total 

FAS 

Cost 

3 Desktop - OptiPlex GX620 $10,080 (3) $30,240 $575 (3) $1,725 

25 Touchprint Fingerprint $7,800 (16) $124,800 $7,900 (16) $126,400 

Capture $7,900 (6) $47,400 $2,720 (1) $2,720 

$3,725 (1) $3,725 

$7,900 (4) $31,600 

$10,080 (3) $30,240 $7,900 (3) $23,700 

3 Dell Latitude D520 $7,800 (2) $15,600 $1,169 (1) $1,169 

$2,500 (1) $2,500 

Dell Latitude D520 $7,900 (1) $7,900 $6,880 (1) $6,880 

Total (31) $256,180 $200,419 

Source: OIG analysis of EPA data 

The SMD deputy director stated that during implementation, SMD decoupled the laptop 

and scanner, and the acquisition prices for the individual components were not available. 

In addition, acquisition prices of individual components were recorded as the kit price, 

while other times a reasonable approximation of what the individual component 

acquisition price would be was recorded. The deputy director indicated “SMD will work 

with the Property Management team to develop a consistent strategy of recording the 

acquisition prices of individual components, where an error in recording the acquisition 

prices has been detected; SMD will work with the Property Management team to update 

FAS with the correct purchase information.” 

According to EPA’s Personal Property Policy and Procedures Manual, determination of 

the cost used in recording personal property is an essential element of personal property 

accounting. The current value of accountable personal property is to be maintained in 

IFMS and should be recorded on an item-level basis (i.e., each individual item is a 

separate record). 

4 
 

 

 

 

 

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Inaccurate Property Information in FAS 

Our review of property information in EPA’s FAS found seven items with incorrect 

purchase order numbers, property locations, or acquisition dates (see Table 3). In Fiscal 

Year 2006, SMD began purchasing property for the issuance of smartcards. Upon receipt, 

SMD calibrated and shipped the property to various EPA locations. 

Table 3: Inaccurate Property Information 

Decal Number Item Incorrect information in FAS 

B11866 Scanner Acquisition date 

B11878 Scanner Acquisition date 

S10865 Laptop Acquisition date, location of property 

SA7047 Scanner Purchase order number, location of property 

B11654 ViiSage Acquisition date, location of property 

S12071 Camera Acquisition date 

B11872 ViiSage Acquisition date 

Source: OIG analysis of EPA data 

Not all property was affixed with an EPA decal number and accounted for in FAS before 

shipping. In September 2008, an EPA contractor sent correspondence to 13 different 

EPA locations stating items shipped were not decaled before leaving and, therefore, were 

not entered into IFMS. The correspondence listed 34 property items, of which only 7 had 

EPA decal numbers at the time. The SMD director said SMD was aware of the property 

not being decaled and entered into FAS before it was shipped to other EPA locations, but 

flexibility was required to get the smartcards issued by the Office of Management and 

Budget-mandated deadline of September 30, 2008. SMD’s deputy director indicated 

SMD would work with the Property Management team to get FAS updated with the 

correct information. 

EPA’s Personal Property Policy and Procedures Manual requires that personal property 

records be maintained and entered into FAS in a timely manner. In addition, EPA 

Custodial Officer’s Guide requires that property received at a central receiving point 

(warehouse) be decaled and entered into FAS before delivery to the end user. It further 

states that for property delivered directly to the end user, as was done for some HSPD-12 

property, the end user/purchaser must notify the property accountable officer so that the 

property can be properly decaled and entered into FAS. 

EPA Did Not Update HSPD-12 Implementation Contract 

The contract for implementing HSPD-12 does not include the correct clauses to address property 

management responsibilities. Tasks under the contract statement of work require the contractor 

to account for the property as if it were government-furnished property. However, the property 

is used in government facilities, and EPA officials do not consider government property used by 

a contractor in government facilities to be government-furnished property. An exception was not 

written in any EPA policy or guidance until February 2009. The contract did not properly reflect 

the status of the property because the contracting officer did not provide the contract to the 

contract property coordinator for review prior to issuance as required. We could not determine 

5 
 09-P-0233 

why the initial contracting officer involved in the awarding of the contract did not provide the 

contract to the contract property coordinator because he has left the Agency. 

Government-furnished property is defined as property directly acquired by the government and 

furnished to the contractor for the performance of the contract. The current contract requires the 

contractor to maintain an accurate, complete, and updated inventory of equipment, and the 

contractor was meeting this requirement. The contract language was similar to what would have 

been included in a contract if the property were government-furnished property used at a 

non-EPA facility. 

On February 27, 2009, the Office of Acquisition Management issued a Contract Property 

Accountability FLASH Notice that stated, “EPA property located in an EPA facility should 

remain under the care and control of EPA facilities personnel. Contractors entering an EPA 

facility to perform services that involve the use of EPA property (whether solely or shared with 

EPA employees) should not be contractually liable for the EPA property. Therefore, EPA 

property located at an EPA facility should not be placed on EPA contracts nor be the 

responsibility or liability of the contractor.” 

EPA’s contract property coordinator plays an important role in contract property management 

under EPA contracts. The coordinator provides technical expertise and assistance to contracting 

and project officers relative to contract property management under EPA contracts. According 

to the contract property coordinator, contracting officers are required to submit copies of all 

contracts that include property to the contract property coordinator for review before issuance. 

This was not done for the HSPD-12 implementation contract. The contract property coordinator 

explained the contract requirements should be changed to clarify the contractor’s role as it relates 

to the use of the property. The February 2009 FLASH Notice requested action by contracting 

officers for contracts with government property when the property is located at an EPA facility. 

Contracting officers were requested to modify contracts to remove all government property and 

send copies of those modifications to the contract property coordinator to ensure accountability 

of property identified on the modifications. 

EPA should modify the contract to ensure property roles and responsibilities are clearly 

delineated. 

Recommendations 

We recommend that the Director, Office of Administration, Office of Administration and 

Resources Management: 

1. Require SMD to use established policies and procedures in the Personal Property Policy 

and Procedures Manual for lost, damaged, and destroyed property to resolve 

accountability for the missing property. 

2. Require SMD to review the accuracy of HSPD-12 property information in FAS and 

update any discrepancies such as decaled identification, location, purchase order 

numbers, and cost. 

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 09-P-0233 

We recommend that the Director, Office of Acquisition Management, Office of Administration 

and Resources Management: 

3. Modify the HSPD-12 contract to reflect contractor requirements and accountability for 

using government property in government facilities. 

Agency Comments and OIG Evaluation 

In responding to the draft report, the Office of Administration and Resources Management’s 

Office of Administration and Office of Acquisition Management concurred with the report 

recommendations. 

The Office of Administration, in responding to recommendation 1, instructed SMD to use 

established policies and procedures in the Personal Property Policy and Procedures Manual for 

lost, damaged, and destroyed property to resolve accountability for the missing HSPD-12 

property. The Agency milestone listed for completing this corrective action was December 

2009. The planned corrective action meets the recommendation intent. 

The Office of Administration instructed SMD, in response to recommendation 2, to review the 

accuracy of HSPD-12 property information in FAS and work with the Property Management 

team to update any discrepancies related to such items as decaled information, location, purchase 

order numbers, and cost. SMD has already worked with the Agency Property Management 

Officer in the Facilities Management and Services Division to update certain purchase 

information in FAS and plans to complete the updates by December 31, 2009. The planned 

corrective action meets the recommendation intent. 

The Office of Acquisition Management, in response to recommendation 3, issued modification 

#11 to the HSPD-12 Contract GS-35F-4997G, Task Order 15, to reflect contractor requirements 

and accountability for using government property in government facilities. The modification was 

issued to the contractor on July 22, 2009, to establish accountability for the property, to clarify 

that the task order does not include government property, and to identity the EPA Contract 

Property Coordinator. We reviewed the modification and it addresses the recommendation. 

The complete Agency response to the draft report is in Appendix A. 

7 
 

 

 

 

 09-P-0233 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

1 

2 

3 

6 

6 

7 

Require SMD to use established policies and 

procedures in the Personal Property Policy and 

Procedures Manual for lost, damaged, and 

destroyed property to resolve accountability for the 

missing property. 

Require SMD to review the accuracy of HSPD-12 

property information in FAS and update any 

discrepancies such as decaled identification, 

location, purchase order numbers, and cost. 

Modify the HSPD-12 contract to reflect contractor 

requirements and accountability for using 

government property in government facilities. 

O 

O 

C 

Director, 

Office of Administration, 

Office of Administration and 

Resources Management 

Director, 

Office of Administration, 

Office of Administration and 

Resources Management 

Director, 

Office of Acquisition 

Management, 

Office of Administration and 

Resources Management 

12/31/2009 

12/31/2009 

07/22/2009 

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 

8 
 

 

 

 09-P-0233 

Appendix A 

Agency Response to Draft Report 

MEMORANDUM 

SUBJECT: Response to Audit Report Draft 

FROM: Renee Page, Director 

Office of Administration 

TO: Janet Kasper, Director 

Contracts and Assistance Agreement Audits 

On behalf of the Acting Administrator for OARM, Craig Hooks, please find attached 

OARM’s written response to the findings and recommendations as referenced in your 

memorandum to Mr. Hooks dated June 19, 2009. 

Please note that the written response has been provided by and through the Director for 

the Office of Administration for OARM and the Acting Director for the Office of Acquisition 

Management for OARM as both are responsible for specific areas or elements within the scope 

of audit. 

Should you have any questions or wish to discuss this response, please call me at (202) 

564-8400 or my Acting Deputy, Dennis Bushta, at the same number. 

Attachment 

9 
 

 

 

 09-P-0233 

MEMORANDUM
 

SUBJECT: Response to Audit Report Draft 

FROM: Tami Franklin, Director 

Security Management Division 

THRU: Renee Page, Director 

Office of Administration 

John Gherardini, Acting Director 

Office of Acquisition Management 

TO: Janet Kasper, Director 

Contracts and Assistance Agreement Audits 

Office of Inspector General 

Thank you for the opportunity to comment on the Office of Inspector General’s (OIG’s) 

Draft Audit Report (“Report”) of June 19, 2009: EPA Did Not Properly Account for All Property 

for Implementing Homeland Security Presidential Directive-12. 

The Security Management Division (SMD) concurs with the Report’s Recommendations 1 

and Recommendation 2. In addition, the Office of Acquisition Management (OAM) concurs 

with Recommendation 3, which involves contract modification. The planned or actual 

completion dates for the recommendations, as well as corrective actions already initiated, are 

below. 

1.	 Require SMD to use established policies and procedures in the Personal Property Policy 

and Procedures Manual for lost, damaged, and destroyed property to resolve 

accountability for the missing property. 

The Director of the Office of Administration has instructed SMD to use established 

policies and procedures in the Personal Property Policy and Procedures Manual for lost, 

damaged, and destroyed property to resolve accountability for the missing items detailed 

on page 3 of the Report, due by the date indicated. Planned Completion Date: December 

31, 2009. 

2.	 Require SMD to review the accuracy of HSPD-12 property information in FAS and 

update any discrepancies such as decaled identification, location, purchase order 

numbers, and cost. 

The Director of the Office of Administration has instructed SMD to review the accuracy 

of HSPD-12 property information in FAS and work with the Property Management team 

to update any discrepancies related to such items as decaled information, location, 

purchase order numbers, and cost, by the date indicated. SMD has already worked with 

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 09-P-0233 

Connie Posey, Team Leader, Agency Property Management Officer in the Facilities 

Management and Services Division, to update certain purchase information in FAS. 

Planned Completion Date: December 31, 2009. 

3.	 Modify the HSPD-12 contract to reflect contractor requirements and accountability for 

using government property in government facilities. 

To reflect contractor requirements and accountability for using government property in 

government facilities, OAM issued modification #11 to the HSPD-12 Contract GS-35F4997G, Task Order 15. The modification was issued to the contractor to clarify that the 

task order does not include Government property, and to clarify the identity of the EPA 

Contract Property Coordinator (CPC). The recommended action was completed as of 

July 22, 2009. 

SMD’s comments on the Report are only to clarify the extent of the incorrect information in 

the Fixed Assets Subsystem (FAS). At a Glance: What We Found says: “Acquisition costs in 

FAS were incorrect...” (second bullet). SMD respectfully requests this be changed to: “Certain 

[or Some] acquisition costs in FAS were incorrect...” so as not to imply that all such information 

was incorrect. 

For the same reason, SMD requests that the section title EPA Fixed Assets System is Not 

Accurate (page 3) be changed to: Certain [or Some] Information in EPA Fixed Assets System is 

Not Accurate. Within that section, SMD asks that the second sentence in the first paragraph be 

changed to: “Also, the acquisition cost recorded for certain [or some] property in FAS was 

incorrect....” 

SMD believes that the section entitled Inconsistent Cost Information in FAS (p. 4) overstates 

the extent of incorrect information. As SMD Acting Director Tami Franklin documented in her 

May 7, 2009, comments on the Discussion Draft of this Report, 20 of the Dell Latitude laptops 

were accurately recorded in FAS as costing $3,440, and one of the Touchprints was accurately 

recorded as costing $4,460. SMD therefore requests that reference to these 21 items be removed 

from Table 2 (page 4) and from the related discussion in this section. 

Thank you for considering these requests, which SMD believes to be consistent with portions 

of the Report that do clarify the extent of the incorrect information. For example, At a Glance: 

What We Found also says: “Non-financial information for several pieces of property was not 

accurately recorded” (third bullet; emphasis added). Text under EPA Fixed Assets System is Not 

Accurate (page 3) limits the scope of discussion to four pieces of property. 

Again, we appreciate this opportunity to review and comment on the Report. If you have 

additional questions, please contact SMD Acting Director Tami Franklin at 202-564-9218. 

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Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Administration and Resources Management 

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

 Resources Management 

Director, Office of Administration, 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 

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

Acting Inspector General 

12