U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Attestation Report 

Costs Claimed Under EPA Grant 

XP9468195 Awarded to the 

City of Flowood, Mississippi

 Report No. 10-4-0013 

 October 27, 2009 
 

Report Contributors: Richard Howard 

 Yeon Kim

 Leah Nikaidoh 

Abbreviations 

A&E Architectural and Engineering 

CFR Code of Federal Regulations 

EPA U.S. Environmental Protection Agency 

FAR Federal Acquisition Regulation 

FSR Financial Status Report 

OIG Office of Inspector General 

SAAP Special Appropriation Act Project 

SRF State Revolving Fund 

Cover photo: City of Flowood pump station. (Photo taken by OIG staff in March 2009) 
 

 

 

U.S. Environmental Protection Agency 10-4-0013 

October 27, 2009 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

The U.S. Environmental 

Protection Agency (EPA) 

Office of Inspector General 

(OIG) conducts reviews of 

earmarked grants known as 

Special Appropriation Act 

Projects issued to local and 

tribal governments. The City 

of Flowood, Mississippi, was 

selected for review. 

Background 

Costs Claimed Under EPA Grant XP9468195 

Awarded to the City of Flowood, Mississippi

 What We Found 

The grantee did not perform a cost analysis or negotiate a fair and reasonable 

profit as a separate element of the contract price as required under Title 40 Code 

of Federal Regulations (CFR) 31.36(f). As a result, we questioned $1,755,157 in 

unsupported architectural and engineering (A&E) costs claimed. The grantee will 

need to repay $896,224 of grant funds. The grantee also did not have its own 

written procurement procedures and did not maintain records sufficient to detail 

the procurement of the A&E contract. 

What We Recommend 

Region 4 awarded Grant No. 

XP9468195 to the City of 

Flowood, Mississippi 

(grantee), on February 10, 

1995. The purpose of the 

grant was to provide federal 

assistance of $7,679,032 to 

fund the construction of the 

Hogg Creek Interceptor 

pipeline segment. EPA 

funded 69.86 percent of the 

eligible project costs and the 

grantee funded 30.14 percent. 

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/ 

20091027-10-4-0013.pdf 

We recommend that the EPA Region 4 Regional Administrator: 

1.	 Require the grantee to provide the documentation demonstrating that it 

performed a cost analysis for the A&E contract at the time of negotiation. 

If the grantee is unable to do so, EPA should recover the federal share of 

questioned A&E costs of $896,224. 

2.	 Require the grantee to develop written procurement procedures in 

accordance with 40 CFR 31.36(b)(1). 

3.	 Require the grantee to incorporate the procurement record keeping 

requirements in 40 CFR 31.36 (b)(9) into its written procurement 

procedures, and comply with those requirements. 

The grantee agreed with the recommendations to develop written procurement and 

record keeping procedures. However, the grantee did not agree with the 

questioned A&E costs and stated that it had performed the equivalent of the 

required cost analysis for its A&E contract. 
 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

October 27, 2009 

MEMORANDUM 

SUBJECT:	 Costs Claimed Under EPA Grant XP9468195 

Awarded to the City of Flowood, Mississippi 

Report No. 10-4-0013 

FROM: Robert K. Adachi

Director of Forensic Audits 

TO: A. Stanley Meiburg 

Acting Regional Administrator 

EPA Region 4 

This report contains a time-critical issue the Office of Inspector General (OIG) identified. This 

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

the U.S. Environmental Protection Agency (EPA). EPA managers 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 $81,847. 

Action Required 

In accordance with EPA Manual 2750, Chapter 3, Section 6(f), you are required to provide us 

your proposed management decision for resolution of the findings contained in this report before 

you formally complete resolution with the recipient. Your proposed decision is due in 120 days, 

or on February 24, 2010. To expedite the resolution process, please e-mail an electronic version 

of your proposed management decision to adachi.robert@epa.gov. 

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

available at http://www.epa.gov/oig. If you or your staff has any questions regarding this report, 

please contact me at (415) 947-4537 or at the above e-mail address, or Leah Nikaidoh at 

(513) 487-2365 or nikaidoh.leah@epa.gov. 
Costs Claimed Under EPA Grant XP9468195 10-4-0013 

Awarded to the City of Flowood, Mississippi 

Table of Contents 

Introduction ................................................................................................................. 1 

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

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

Independent Attestation Report ................................................................................ 2 

Results of Examination .............................................................................................. 4 

Weaknesses in Procurement Procedures............................................................ 4 

 Recommendations ............................................................................................... 5 

Grantee Comments and OIG Analysis................................................................. 5 

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

Appendices 

A Grantee Response.............................................................................................. 9 

B Distribution ......................................................................................................... 11
 
 

10-4-0013 

Introduction 

Purpose 

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

Special Appropriation Act Project (SAAP) grants to identify issues warranting further analysis. 

This includes reviewing the total project costs incurred by selected grant recipients. We 

reviewed the SAAP grant awarded to the City of Flowood, Mississippi (grantee). 

Background 

Region 4 awarded Grant No. XP9468195 to the grantee on February 10, 1995. The purpose of 

the grant was to provide federal assistance of $7,679,032 to fund the construction of the Hogg 

Creek Interceptor pipeline segment connecting to the West Rankin Regional Sewer System north 

of the Jackson international airport and extending easterly to the Castlewoods/Millcreek 

residential areas of West Rankin County, Mississippi. EPA was responsible for 69.86 percent of 

the eligible project costs. The grantee was responsible for matching, at a minimum, 30.14 

percent of the eligible project costs. Per the Financial Status Report (FSR), project costs were 

$11,464,301. The grantee was responsible for the remaining project costs of $3,785,269 

($11,464,301-$7,679,032). EPA amended the grant four times resulting in a budget and project 

period that started February 15, 1995, and ended December 31, 2004. 

1
 
 

10-4-0013 

Independent Attestation Report 

As part of our continued oversight of SAAP grants awarded by EPA, we have examined the costs 

claimed by the grantee in its Financial Status Report (FSR) covering the period from February 

15, 1995 to December 31, 2004. By signing the award documents, the grantee has accepted 

responsibility for preparing its cost claim to comply with the requirements of 40 CFR Part 31, 

Office of Management and Budget Circular A-87, EPA policies, and the terms and conditions of 

Grant No. XP9468195. Our responsibility is to express an opinion on the grantee’s FSR based 

on our examination. 

Our examination was conducted in accordance with the Government Auditing Standards issued 

by the Comptroller General of the United States, and the attestation standards established by the 

American Institute of Certified Public Accountants. We examined evidence about the grantee’s 

compliance with 40 CFR Part 31, Office of Management and Budget Circular A-87, EPA 

policies and the terms and conditions of the grant, and performed procedures, as we considered 

necessary in the circumstances. We believe that our examination provides a reasonable basis for 

our opinion. 

We conducted our field work from March 30, 2009, to July 29, 2009. We made a site visit to the 

grantee and performed the following steps: 

• Reviewed the grant agreement and the amendments. 

• Toured the facilities constructed under the grant. 

• Reviewed the grantee’s supporting documents for payment requests. 

• Verified deposits of grant cash draws to the bank statements. 

• Conducted interviews of grantee personnel. 

• Reviewed the grantee’s procurement procedures and related documents. 

• Verified that the grantee met the required grant match. 

We considered the grantee’s internal controls over cost reporting in order to determine our audit 

procedures for the purpose of expressing our opinion on the FSR, and not to provide assurance 

on the internal controls over cost reporting. Our consideration of internal controls would not 

necessarily disclose all matters in the internal controls that might be material weaknesses. A 

material weakness is a significant deficiency or combination of significant deficiencies that 

results in more than a remote likelihood that a material misstatement will not be prevented or 

detected. A significant deficiency is a deficiency in internal controls, or combination of control 

deficiencies, that adversely affects the grantee’s ability to initiate, authorize, record, process, or 

report data reliably in accordance with the applicable criteria or framework, such that there is 

more than a remote likelihood that a misstatement of the subject matter that is more than 

inconsequential will not be prevented or detected. 

Our examination disclosed the following noncompliances and material weaknesses that resulted 

in the grantee not complying with the financial management requirements specified by Title 40 

CFR Part 31. The grantee: 

2
 
10-4-0013 

•	 Did not perform a cost analysis required by 40 CFR 31.36(f) for the architectural and 

engineering (A&E) service contract. 

•	 Did not have its own written procurement procedures required by 40 CFR 31.36 (b) (1), 

(2), and (3). 

•	 Did not maintain all required procurement documents required by 40 CFR 31.36(b)(9). 

As a result of these issues, we were unable to determine the price reasonableness of A&E costs 

and have questioned $1,755,157 of costs claimed under the grant. 

In our opinion, because of the effect of the issues described above, the FSR referred to above, 

does not meet, in all material respects, the requirements of 40 CFR Part 31 for the period ended 

December 31, 2004. 

Robert K. Adachi 

Director for Forensic Audits 

July 29, 2009 

3
 
 

10-4-0013 

Results of Examination 

The grantee did not meet the procurement requirements of 40 CFR Part 31.36. As a result, we 

questioned $1,755,157 in unsupported A&E costs claimed. The grantee also did not have its 

own written procurement procedures, and did not maintain records sufficient to detail the 

procurement of the A&E contract. The grantee claimed total project costs of $11,464,301, but 

only $10,992,384 was approved under the EPA grant. The grantee provided the additional 

$471,917 of project costs with excess matching funds. The excess funds can be used to offset 

the $1,755,157 in questioned costs. As a result, the grantee is required to reimburse the EPA 

$896,224. Below is a summary of the questioned costs. 

 Table 1: Summary of Questioned Costs 

Cost Element Questioned Costs 

Total Eligible Project Costs 11,464,301 

Less: Questioned Procurement Costs 

Total Allowable Project Costs 

(1,755,157) 

9,709,144 

Federal Share (69.86%) 6,782,808 

Payments Made 7,679,032 

Amount to be Repaid (896,224) 

Sources: Claimed costs are from the Financial Status Report. 

Costs questioned are based on OIG’s analyses of the supporting 

documentation provided by the grantee. 

Weaknesses in Procurement Procedures 

The grantee did not perform a cost analysis or negotiate a fair and reasonable profit as a separate 

element of the contract price for its A&E contract. Title 40 CFR 31.36(f) requires grantees to 

perform a cost analysis to determine price reasonableness for procuring A&E professional 

services. It also requires grantees to negotiate a fair and reasonable profit as a separate element 

of the contract price in all cases where cost analysis is performed. Without a cost analysis, we 

were unable to determine whether the A&E contract price was fair and reasonable. Therefore, 

we questioned as unsupported the A&E costs of $1,755,157 claimed under the grant. 

The grantee did not meet the requirements of 40 CFR 31.36(f) because its managers involved in 

the award process believed that the applicable standards to follow were the State of Mississippi 

Purchase Law (State Law), which allows the grantee to select an A&E firm based upon 

qualifications. Federal regulations also allow the selection of an A&E firm based upon 

qualifications. However, under federal regulations, the grantee is also required to perform a cost 

analysis as part of the price negotiation process. This requirement is not in the State Law; 

therefore, the grantee was unaware of the federal requirement to perform a cost analysis. 

The grantee also did not have its own written procurement procedures. Title 40 CFR 31.36(b) 

requires grantees to: 

4
 
10-4-0013 

(1) Use their own procurement procedures that reflect applicable State and local laws and 

regulations, provided that the procurements conform to applicable federal laws and 

standards. 

(2) Maintain a contract administration system that ensures that contractors perform in 

accordance with the terms, conditions, and specifications of their contracts or purchase 

orders. 

(3) Maintain a written code of standards of conduct governing the performance of their 

employees engaged in the award and administration of contracts. 

In the absence of written procurement procedures that include compliance with EPA regulations, 

the grantee did not ensure that its A&E contract met all compliance standards. 

The grantee did not maintain all required procurement records required by 40 CFR 31.36(b)(9). 

The grantee could not find its score sheets used to rank the three firms that responded to the 

Request for Qualifications for the A&E contract under the subject SAAP grant. The grantee only 

provided copies of the board meeting minutes documenting the selection of the highest-ranked 

A&E firm. Title 40 CFR 31.36(b)(9) requires that grantees to maintain records sufficient to 

detail the significant history of a procurement. These records will include, but are not 

necessarily limited to, the following: rationale for the method of procurement, selection of 

contract type, contractor selection or rejection, and the basis for the contract price. 

As a result, we were unable to determine whether the grantee properly assessed each firm based 

upon prescribed ranking criteria to ensure that the ultimate selection of the A&E firm was 

justified. 

Recommendations 

We recommend that the EPA Region 4 Regional Administrator: 

1. Require the grantee to provide the documentation demonstrating that it performed a cost 

analysis for the A&E contract at the time of negotiation. If the grantee is unable to do so, 

EPA should recover the federal share of questioned A&E costs of $896,224. 

2. Require the grantee to develop written procurement procedures in accordance with 

40 CFR 31.36(b)(1). 

3.	 Require the grantee to incorporate the procurement record keeping requirements in 

40 CFR 31.36 (b)(9) into its written procurement procedures, and comply with those 

requirements. 

Grantee Comments and OIG Analysis 

We held an exit conference with representatives from Region 4 and the grantee on August 18, 

2009, to obtain their comments regarding the factual accuracy of the discussion draft. The 

grantee provided a written response to the OIG on August 31, 2009, to verify its exit conference 

comments. Appendix A provides the full text of the grantee’s comments. 

5
 
 

10-4-0013 

The grantee agreed with the recommendations in the discussion draft and stated that it is 

currently taking steps to comply with the recommendations. These steps include developing 

written procurement and record keeping procedures and submitting them to Region 4 for 

comment and approval. The grantee needs to provide Region 4 with the specific steps it is taking 

to address the recommendations, along with milestone dates for each step. 

The grantee did not concur with the questioned A&E costs. The grantee stated that it performed 

the equivalent of a required cost analysis along with the engineering firm selected to perform 

work under the EPA grant. This analysis consisted of an EPA Form 5700-41,1 the experience of 

its Director of Public Works, and ensuring that the fees the City paid to its engineering firm did 

not exceed fees recommended by the State Revolving Fund (SRF) Curve established by the State 

of Mississippi. 

The grantee also stated that the selection process for its engineering firm took place more than 

15 years ago, and it hoped the OIG would take this into account since the grantee could not 

locate its ranking score sheets. However, the grantee provided its official board meeting minutes 

that documented the selection of the most qualified engineering firm to the OIG. 

We disagree with the grantee’s assertion that its EPA Form 5700-41, along with the SRF Curve 

and the experience of the Director of Public Works, who is not an engineer, provided the 

equivalent of the cost analysis required by 40 CFR 31.36(f). The City of Flowood did not meet 

the cost analysis requirements of 40 CFR 31.36(f), and did not support how it determined that the 

costs listed on its Form 5700-41 forms were fair and reasonable. 

Title 40 CFR 31.36(f)(3) requires that the costs included in negotiated prices to be consistent 

with the federal cost principles outlined in 40 CFR 31.22. However, 40 CFR 31.36(f) does not 

clearly describe what constitutes an adequate cost analysis. To assist the grantee, we identified 

criteria in the Federal Acquisition Regulations (FAR) that provides specific criteria that 

contractors and subcontractors should use to perform a cost analysis. According to FAR 15.404-

1(c), a cost analysis is the review and evaluation of the separate cost elements and profit in the 

offeror’s proposal (including cost or pricing data). FAR 15.404-1(c)(2)(iii) provides cost 

analysis techniques and procedures to ensure a fair and reasonable price. These techniques and 

procedures include the comparison of costs proposed by the offeror for individual cost elements 

with: 

•	 Actual costs previously incurred by the same offeror, 

•	 Previous cost estimates from the offeror or from other offerors for the same or similar 

items, 

•	 Other cost estimates received in response to the government’s request, 

•	 Independent government cost estimates by technical personnel, and/or, 

•	 Forecasts of planned expenditures. 

1

 EPA Form 5700-41 (2-76): Cost or Price Summary Format for Subagreements Under U.S. EPA Grants, EPA 

Handbook of Procedures, Construction Grants Program for Municipal Wastewater Treatment Works February 1976. 

6
 
10-4-0013 

EPA Form 5700-41 was used during the construction grants program and was the basis for a cost 

and price review by EPA or the State agency delegated to monitor the construction grants 

program. The information contained in the grantee’s form was prepared and certified by the 

contractor or subcontractor. Although the form provided the costs and price details, the grantee 

did not provide adequate documentation to satisfy the federal cost analysis requirements. In 

particular, the grantee did not determine whether the information contained in the EPA Form 

5700-41 was current, accurate and complete. As a result, the grantee could not certify that the 

proposed cost and price was reasonable. 

The grantee also mentioned that the SRF Curve developed by the State of Mississippi was used 

to determine cost reasonableness. The SRF curve is identical to the practice outlined in 40 CFR 

Part 35 Subpart I, Appendix B. Appendix B to the CFR applied to construction grants awarded 

after October 1, 1984, under Section 201 (g)(1) of the Federal Water Pollution Control Act. 

Appendix B was used to determine the allowance EPA would provide for facilities planning and 

design services. Appendix B was not intended to reimburse grantees for costs incurred and was 

not meant to be used to answer questions of equity. Since Appendix B is identical to the SRF 

Curve established by the State of Mississippi, the grantee should not imply its use is a substitute 

for or an enhancement of a cost and price analysis. 

Our position that the A&E costs of $1,755,157 are unsupported remains unchanged. 

While the OIG understands that the engineering firm selection process took place years ago, the 

grantee did not comply with the record keeping requirements of 40 CFR 31.36(b)(9). The 

grantee’s board meeting minutes only contained the total scores the three engineering firms 

received. Without the individual score sheets, the OIG could not determine the scores each of 

the five members of the Selection Committee gave each firm, how these scores were computed, 

or if the most qualified firm was selected. The grantee needs to ensure that the written 

procurement procedures it is developing contain the record keeping requirements of 40 CFR 

31.36(b)(9). 

7
 
 

 

 

1 

10-4-0013 

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 5 Require the grantee to provide the documentation 

demonstrating that it performed a cost analysis for 

the A&E contract at the time of negotiation. If the 

grantee is unable to do so, EPA should recover the 

federal share of questioned A&E costs of 

$896,224. 

U Regional Administrator, 

Region 4 

$896.2 

2 

3 

5 

5 

Require the grantee to develop written 

procurement procedures in accordance with 

40 CFR 31.36(b)(1). 

Require the grantee to incorporate the procurement 

record keeping requirements in 40 CFR 31.36 

(b)(9) into its written procurement procedures, and 

comply with those requirements. 

O 

O 

Regional Administrator, 

Region 4 

Regional Administrator, 

Region 4 

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
 
 

10-4-0013 

Appendix A 

Grantee Response 

August 31, 2009 

VIA ELECTRONIC TRANSMISSION and FIRST CLASS MAIL 

Mr. Robert K. Adachi 

Director of Forensic Audits 

Office of the Inspector General 

United State Environmental Protection Agency 

Washington, D.C. 20460 

Re: Response to Draft Attestation Report – Costs Claimed Under EPA Grant 

XP9468195 Awarded to the City of Flowood, Mississippi; Project No. 2009-843 

dated July 29, 2009 

Dear Mr. Adachi: 

This letter is in response the draft report referenced above and in furtherance of our 

telephone conference which took place on August 18, 2009 with representatives of your office 

and those of Region 4-EPA in Atlanta, Georgia. 

First, let me thank the participants in this audit for their questions and comments during 

this audit process. As you might imagine, responding to this audit was a challenge to the City of 

Flowood (“Flowood”) because the first grant which was the subject of this audit was awarded in 

February 10, 1995, more that fourteen years ago, and the last grant was more than five year ago. 

Although the Mayor Rhoads and Public Works Director Garry Miller were in place in 1995, the 

long- time City Clerk, Ms. Dew, is no longer with Flowood. Locating documents dating back to 

1995 was in some cases simply not possible. 

We agree with the recommendations contained in the draft report and are currently taking 

steps to comply with those recommendations in the future. However, we feel compelled to 

respond to the factual basis for these recommendations. 

With regard to the first recommendation regarding documentation of the performance of 

a cost analysis for the A&E Contract, an analysis was performed by Flowood in cooperation with 

the engineering firm selected by Flowood using an outdated Form 5700-41 for the original 

contract. We would argue that this analysis was the functional equivalent to the mandates of 40 

CFR 31.36(f). I have enclosed a copy of the contract forms for your review and consideration. 

This analysis coupled with Mr. Miller’s considerable experience should adequately serve to 

satisfy the requirement of 40 CFR 31.36(f). 

As you know, there were three substantive amendments to the contract. I have enclosed 

copies of each amendment for your convenience. Each contract provided that the fee to be 

9
 
 

 

10-4-0013 

charged for engineering services would be in accordance with the SRF Curve which was 

attached to each as an exhibit. In fact, some of the fees were significantly lower than that 

recommended by the curve. As I am sure that you know, the SRF Curve was developed by the 

State of Mississippi as a guideline for circumstances such as the one at hand. We would submit 

to you that the SRF Curve coupled with Mr. Miller’s experience was the functionally equivalent 

to the analysis required by 40 CFR 31.36(f). Furthermore, the contract we submitted to Region 4 

with the SRF Curve attached as an exhibit and no objection was ever made to this method of 

verifying the reasonableness of the engineers’ fees. 

I hope the foregoing explanation persuades you to conclude that while Flowood may not 

have complied with the letter of the law, it did verify that the costs charged by the engineers 

were reasonable under the circumstances. 

As for the lack of score sheets used to rank the three firms that responded to the request 

for qualifications, I would hope that you would consider the fact that this selection process took 

place more than fifteen years ago and it is impossible to keep up with every scrap of paper 

generated by the city. As noted in the draft, Flowood did have in its official board minutes 

copies of the documents which evidence the selection of the most qualified engineering firm. I 

am enclosing a copy of those minutes for your reference. 

In closing, I hope that we have provided you sufficient information regarding the 

reasonableness of the engineering fees and the documentation of the procurement process. As I 

indicated earlier, Flowood is in the process of developing written procurement and record 

keeping procedures and will be submitting them to Region 4 for comment and approval. 

If you have any further questions, please don’t hesitate to contact me. 

 Very truly yours, 

WATSON & JONES, P. A. 

J. Kevin Watson 

JKW:ew 

Enclosures 

ec/enc: A. Stanley Meilburg, Acting Regional Administrator 

Leah Nikaidoh, Audit Manager, Northern Audit Division 

Ed Springer, Region 4 Special Appropriation Act Projects Coordinator 

Carol Williams, Region 4 Audit Coordinator 

Bill Roderick, Acting Inspector General 

Melissa Heist, Assistant Inspector General for Audit 

John Manibusan, OIG Office of Congressional, Public Affairs and Management 

Mayor Gary Rhoads, City of Flowood 

Julia Williams, City Clerk, City of Flowood 

10
 
10-4-0013 

Appendix B 

Distribution 

Acting Regional Administrator, Region 4 

Director, Office of Wastewater Management, Office of Water 

Director, Office of Wastewater Management - Municipal Support Division, Office of Water 

Director, Office of Grants and Debarment 

Director, Grants and Interagency Agreements Management Division 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Region 4 Audit Follow-up Coordinator 

Region 4 Public Affairs Office 

Region 4 Special Appropriation Act Project Coordinator 

Mayor, City of Flowood, Mississippi 

Acting Inspector General 

11