U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Evaluation Report 

Office of Inspector General 

Access to Agency Information 

and Personnel 

Report No. 09-P-0222 

 August 25, 2009 
Report Contributors: Rae Donaldson 

Dwayne E. Crawford 

Eric Lewis 

Elizabeth Grossman 

Maria Martir 

Abbreviations 

EPA U.S. Environmental Protection Agency 

OECA Office of Enforcement and Compliance Assurance 

OIG Office of Inspector General 
 

 

U.S. Environmental Protection Agency 09-P-0222 

August 25, 2009 Office of Inspector General 

At a Glance
 

Catalyst for Improving the Environment 

Why We Did This Review 

We analyzed internal guidance 

used by the U.S. Environmental 

Protection Agency (EPA) 

program and regional offices 

for interacting with the Office 

of Inspector General (OIG) to 

determine whether the guidance 

was (1) applied consistently

Agency-wide, or (2) included 

procedures that included

burdensome administrative 

requirements or allowed 

screening of information prior 

to issuance to the OIG. 

Background 

The Office of Enforcement and 

Compliance Assurance 

instructed its managers not to

provide information directly to 

the OIG. However, the 

Inspector General Act of 1978

authorizes federal inspectors 

general to assess information 

and personnel relative to 

program operations of federal 

agencies. EPA’s own policy

also endorses OIG access to 

personnel and timely

information. 

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/ 

20090825-09-P-0222.pdf 

Office of Inspector General Access to 

Agency Information and Personnel 

What We Found 

At the time of our review, EPA did not have consistent overall guidance 

governing interaction with the OIG. Consequently, some EPA program and 

regional offices promulgated internal guidance that impeded OIG access to 

Agency information and personnel. These internal guidances included 

procedures with burdensome administrative requirements that allowed EPA 

managers to screen and potentially change information prior to issuing the 

information to the OIG. Others required personnel to seek supervisory guidance 

before responding to OIG inquiries. 

Our Agency-wide survey found that EPA employees had a significant lack of 

knowledge about interacting with the OIG. Eighty-three percent of respondents 

either were not aware or did not know of any guidance or procedures governing 

interaction with the OIG. Fourteen percent of the respondents believed they may 

face retribution if they provided information or documents to the OIG without 

permission from a supervisor. An additional 31 percent did not know whether 

they would face retribution if they provided documents or information to the OIG 

without permission. 

 Corrective Actions Taken 

We recommended that the Deputy Administrator issue guidance to all EPA 

program and regional offices on interacting with the OIG to ensure unfettered 

access to information and personnel; and that all lower level guidance, written or 

unwritten, be revoked. In response, the EPA Administrator issued prescriptive 

guidance on August 7, 2009, to address these issues. The guidance instructed 

EPA personnel to provide OIG auditors, evaluators, and investigators with full 

and unrestricted access to personnel, facilities, records, or other information or 

material needed by the OIG to accomplish its mission. The EPA Administrator 

defined unrestricted access to mean that managers and staff are not to impose 

burdensome administrative requirements or screening procedures that could 

impede OIG access to needed employees and materials. The EPA Administrator 

instructed all EPA offices to review their policies and procedures related to 

interaction with the OIG and conform to her guidance by September 4, 2009. The 

OIG believes the actions taken by the Administrator to be sufficient to address the 

draft recommendation. Since the actions were taken prior to issuance of our final 

report, no further action is necessary. 
 

 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

August 25, 2009 

MEMORANDUM 

SUBJECT:	 Office of Inspector General Access to Agency Information and Personnel 

Report No. 09-P-0222 

Assistant Inspector General for Program Evaluation 

FROM:	 Wade T. Najjum 

Office of Inspector General 

TO: Scott Fulton 

Acting Deputy Administrator 

Office of the Administrator 

This is the final report of the Office of Inspector General (OIG) of the U.S. Environmental 

Protection Agency (EPA) evaluation of guidance and procedures governing OIG access to 

personnel, records, and other information. This report represents the opinion of the OIG and 

does not necessarily represent the final EPA position. In our draft report issued on June 30, 

2009, the OIG recommended that EPA’s Office of the Administrator issue overall Agency 

guidance governing interaction with the OIG during the performance of our reviews to ensure 

unfettered access to information and personnel; and that all lower level guidance, written or 

unwritten, be revoked. In response, the EPA Administrator issued a memorandum on August 7, 

2009. The OIG has determined the actions taken by the Office of the Administrator to be 

sufficient to address issues raised during our review. Accordingly, we have made necessary 

changes in this report where appropriate. We have included the EPA Administrator’s 

memorandum as Appendix A. Further, since the action taken by the Agency was prior to 

issuance of this final report, no further action is necessary. 

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 $199,469. 

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. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Office of Inspector General Access to 09-P-0222 

Agency Information and Personnel 

Table of Contents 

Chapters 

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

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

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

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

2 EPA Lacked Consistent Guidance for Interacting with the OIG .......................... 4 

Analysis of Program and Regional Offices’ Guidance.................................... 4 

Agency-wide Survey on Employee Interaction with the OIG ......................... 6 

Conclusions.................................................................................................... 7 

Corrective Actions Taken ............................................................................... 8 

Status of Corrective Actions Taken ............................................................................. 9 

Appendices 

A EPA Administrator’s Memorandum on Cooperation with the OIG ..................... 10 

B Distribution ............................................................................................................... 13 
 

 

 09-P-0222
 

Chapter 1

Introduction 

Purpose 

We performed an Agency-wide evaluation of the U.S. Environmental Protection 

Agency’s (EPA’s) guidance and procedures governing Office of Inspector 

General (OIG) access to personnel, records, and other information.1

 We initiated 

the evaluation after news organizations reported in July 2008 that EPA’s Office of 

Enforcement and Compliance Assurance (OECA) had formally instructed 

members of the staff not to talk with the OIG without senior management 

approval. Our objectives were to determine whether: 

•	 EPA had guidance and procedures for interaction with the OIG that was 

implemented consistently Agency-wide, or applied in an ad-hoc manner; 

and 

•	 Established guidance and procedures in any way required burdensome 

administrative requirements, or allowed screening of information prior to 

submission to the OIG. 

Background 

OIGs were created to conduct and supervise audits and investigations relating to 

the programs and operations of the Federal Government to provide a means for 

keeping the heads of federal agencies and Congress fully current and informed 

about problems and deficiencies relating to the administration of such programs 

and operations, and the necessity for and progress of correction action. To help 

ensure this accountability, Congress passed the Inspector General Act of 1978. 

Section VI of the Act provides each Inspector General with the following 

authorizations: 

•	 To have access to all records, reports, audits, reviews, documents, papers, 

recommendations, or other material available to the applicable 

establishment which relate to programs and operations with respect to 

which that Inspector General has responsibilities under this Act (Section 

6(a)(1)). 

•	 Whenever information or assistance requested under the above section is, 

in the judgment of an Inspector General, unreasonably refused or not 

provided, the Inspector General shall report the circumstances to the head 

of the establishment involved without delay (Section 6(b)(2)). 

1

 Hereinafter referred to as reviews. 

1 
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Government Auditing Standards (July 2007 Revision) require that: 

•	 Statutorily appointed federal inspectors general comply with generally 

accepted government auditing standards in conformity with the Inspector 

General Act of 1978 for audits of federal establishments, organizations, 

programs, activities, and functions. 

•	 Government managers provide reliable, useful, and timely information for 

accountability of government programs and operations. 

•	 Auditors must obtain sufficient and appropriate evidence to provide a 

reasonable basis for findings and conclusions. The evidence should 

persuade a knowledgeable person that the findings are reasonable. 

EPA Manual 2750 notes the OIG is authorized access to all records, reports, 

documents, etc., under the Inspector General Act. Further, the Manual states: 

...to fulfill its responsibilities, the OIG needs the cooperation of 

Agency personnel to make full disclosure of information pertaining 

to instances of waste, fraud and abuse. EPA fully supports the 

audit management function and endorses the fullest cooperation of 

all Agency personnel during the entire audit management process. 

All EPA personnel will disclose and provide pertinent information 

to auditors. 

Scope and Methodology 

We conducted our review in accordance with generally accepted government 

auditing standards. Those standards require that we adequately plan for the audit; 

properly supervise audit staff; obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions; and prepare audit 

documentation related to the planning, conducting, and reporting for each audit. 

We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our review objectives. 

We conducted our review from July 2008 through June 2009, during which time 

we requested and analyzed internal guidance, instructions, and procedures used by 

EPA program and regional offices to govern interaction with the OIG. We also 

conducted an Agency-wide survey to assess the level of free interaction EPA 

employees, contractors and others perceive they have with the OIG. 

2 
 

 

 

 

 

 09-P-0222
 

To achieve our audit objectives, we contacted the Agency’s audit follow-up 

coordinators for EPA’s 10 major program offices2

 and 10 regional offices to 

obtain the guidance used by their respective offices for interacting with the OIG. 

Where we were able to obtain documentation, we analyzed the documents to 

determine whether the requirements were implemented consistently Agency-wide, 

or included procedures that required burdensome administrative requirements or 

allowed screening of information prior to issuance to the OIG. 

As a part of our overall evaluation, we also sponsored an Agency-wide survey 

from December 15-19, 2008, using the Agency’s mass-mailer system. The survey 

asked EPA employees and others with an EPA e-mail address questions about 

their knowledge and understanding of existing policies and procedures in their 

programs governing interaction with the OIG. We also asked questions about the 

management control environment. We received responses from 1,019 EPA 

employees and 31 others. 

In January 2009, we issued an interim report3 to the former EPA Deputy 

Administrator on the results of our survey. In this report, we informed the former 

Deputy Administrator that the OIG had not completed its analysis of the results or 

drawn any final conclusions in the interim report. Rather we provided the interim 

results for information purposes given the survey indicated potentially significant 

problems. 

2

 EPA’s 10 major programs offices are the Office of the Administrator; Office of Administration and Resources 

Management; Office of Air and Radiation; Office of the Chief Financial Officer; Office of Enforcement and 

Compliance Assurance; Office of Environmental Information; Office of Prevention, Pesticides, and Toxic 

Substances; Office of Research and Development; Office of Solid Waste and Emergency Response; and Office of 

Water. 

3 Interim Report “Office of Inspector General Access Survey Results, “Report No. 09-P-0079, January 13, 2009. 

3 
 

 

 

 09-P-0222
 

Chapter 2

EPA Lacked Consistent Guidance for 

Interacting with the OIG 

At the time of our review, EPA did not have consistent overall guidance 

governing interaction with the OIG. Consequently, some EPA program and 

regional offices promulgated internal guidance that impeded OIG access to 

information and personnel. These internal guidance documents added procedures 

with burdensome administrative requirements, such as allowing EPA managers to 

screen and potentially change information prior to issuing to the OIG. They also 

allowed employees to sometimes withhold information or refuse to talk to the 

OIG. These internal procedures were determined to have limited or delayed OIG 

access to information and personnel, as authorized by the Inspector General Act 

and EPA Order 2750.4 

We also found that over 80 percent of Agency employees responding to our 

Agency-wide survey were unaware of EPA program office or regional office 

policies or guidance on how to interact with the OIG. More troubling, 14 percent 

of the respondents believed they may face retribution if they provided information 

or documents to the OIG without permission from a supervisor. An additional 

31 percent did not know whether they would face retribution if they provided 

documents or information to OIG without permission. We believe these results 

reflected the need for overall guidance on interacting with the OIG to avoid 

confusion regarding the roles of the OIG in terms of its audit and investigative 

functions. 

Analysis of Program and Regional Offices’ Guidance 

The OIG is statutorily authorized access to Agency information on programs and 

operations, and its personnel, under the Inspector General Act. This information 

is necessary to gather sufficient and appropriate evidence to provide a reasonable 

basis for findings and conclusions. Generally accepted government auditing 

standards require that OIG personnel maintain professional skepticism and verify 

information provided. Regardless of the good intentions involved, OIG cannot 

accept a process that allows management to screen or alter information from a 

source. The OIG agrees to reasonable coordination with the Agency to avoid 

unnecessary disruptions, and the OIG may seek audit liaison assistance in 

identifying qualified personnel to interview. However, once the OIG is satisfied 

that qualified employees have been identified, the Agency should not be allowed 

the opportunity to screen answers intended for the OIG. 

4

 Inspector General Act of 1978, Sections 6(a)(1), 6(b)(1); EPA Manual 2750, Chapter 1, Section 3 – “Scope and 

Applicability,” 12/03/1998. 

4 
 

 

 09-P-0222
 

EPA program and regional offices use audit follow-up coordinators, audit 

management officials, audit management coordinators, audit liaisons, or other 

designated officials to manage communications with the OIG during a review. 

Typically, these officials try to ensure that the OIG reviewers get access to the 

personnel and information needed to complete the review. However, on occasion, 

these officials can be impediments to the review. For example: 

•	 These coordinators/officials request or are required to serve as a point of 

contact for data or access to personnel. This practice is not always feasible 

in situations when management should not know the exact nature of the 

request, creating the potential for changing data or influencing statements 

from qualified staff. When the OIG needs the services of the audit liaisons 

to help identify qualified Agency personnel for obtaining needed 

information, the OIG will make that request for assistance and set up a 

mechanism to keep management informed about the review to the extent 

practicable. 

•	 Audit follow-up and management coordinators screen or are required to 

screen information before they deliver it to the OIG. When this occurs, 

there is the possibility that management could change the data. Depending 

on the materiality of the data, this requires the OIG to perform additional 

steps to validate the data. 

•	 Some agency staff perceived that audit liaisons, along with supervisors, 

managers, or other Agency representatives, are required to be present 

when they are interviewed by the OIG. This could intimidate qualified 

staff to present only management’s side of the issue. 

We contacted EPA audit follow-up coordinators to determine and document the 

internal policies and procedures used by the Agency’s program offices and 

regional offices governing interaction with the OIG. Our intent was to determine 

whether EPA had overarching guidance in conformity with the Inspector General 

Act and Government Auditing Standards, and implemented that guidance in a 

consistent manner. Specifically, we wanted to determine whether the guidance 

included burdensome administrative requirements or allowed the potential for 

EPA managers to screen or withhold information from the OIG. 

Eleven of 20 Offices Rely on EPA Manual 2750 

Four of 10 program offices and 7 of 10 regional offices told us they rely on EPA 

Manual 2750 as guidance for interacting with the OIG. The purpose of EPA 

Manual 2750 is to implement the reporting requirements of the Inspector General 

Act. Its objectives are to detail processes by which EPA officials respond to OIG 

reports; OIG and EPA officials resolve audit report findings and 

recommendations; and EPA officials implement follow-up corrective actions. 

The Manual does instruct EPA personnel that during an OIG review they must 

5 
 09-P-0222
 

disclose and provide pertinent information to auditors in a timely manner. 

However, the Manual does not indicate whether personnel need permission to 

speak with the OIG or whether EPA management can review or edit information 

to be provided to the OIG. 

Nine Offices Developed Guidance Independent of EPA Manual 2750 

EPA Manual 2750 encourages the development of internal guidance by EPA 

offices if they need to develop and maintain office-specific operating procedures 

and controls that promote timely and effective audit resolution. The remaining 

major offices reported that they had developed their own guidance on 

communicating with the OIG. 

Program Offices’ Written Guidance. Six of the 10 program offices had 

developed internal written guidance governing interaction with the OIG. Of these 

six, internal guidance included procedures that conflict with statutory requirements 

under the Inspectors General Act or Agency policy regarding the OIG’s access to 

information and personnel. These procedures restrict OIG access through 

burdensome administrative requirements and/or create a situation that allows 

Agency managers opportunities to screen information prior to issuing to the OIG. 

Regions’ Written Guidance. Two EPA regions have written internal guidance 

for interacting with the OIG. One region’s guidance sets forth the roles and 

responsibilities during all phases of the audit process, and requires full 

cooperation with the OIG throughout the process. The other region’s guidance, 

based in part on EPA Manual 2750, encourages an open channel of 

communication but requires that a point-of-contact or an alternate collect and 

provide information (documents and/or files) to the OIG. 

A third region did not have written policy or guidance on coordination with the 

OIG. Rather, the region relies on an unwritten standard operating procedure that 

requires the region to cooperate with the OIG in accordance with the Inspector 

General’s Project Management Handbook. The region expects that requests 

concerning audits and evaluations be made through appropriate management 

channels so that management is aware of developments. Though unwritten, the 

guidance provides management the opportunity to screen information and control 

access to qualified personnel. 

Agency-wide Survey on Employee Interaction with the OIG 

We conducted an Agency-wide survey of EPA employees and others with an EPA 

e-mail address to determine their knowledge and understanding of existing 

guidance and procedures in their programs governing interaction with the OIG. 

Our survey results found that Agency personnel had a significant lack of 

knowledge regarding interaction with the OIG. Of 1,050 respondents, 83 percent 

6 
 

 

 

 

 09-P-0222
 

either were not aware or did not know of any guidance or procedures governing 

interaction with the OIG. Several survey respondents also expressed the need for 

training on what an employee or contractor can or cannot do relative to interaction 

with the OIG. 

There were also some troubling perceptions among the Agency staff about 

management’s attitudes toward staff who provided documentation or talked to 

OIG staff without permission. Of the 1,050 respondents: 

•	 Eighteen percent did not believe that they can provide documentation or 

written responses to the OIG without permission from a supervisor. An 

additional 34 percent said they did not know. 

•	 Fourteen percent believed they may face retribution if they provide 

information or documents to the OIG without permission from a 

supervisor. An additional 31 percent did not know whether they will face 

retribution if they provide documents or information to the OIG without 

permission. 

•	 Fourteen percent believed they may face retribution if they talk to the OIG 

without permission from a supervisor. An additional 29 percent did not 

know whether they will face retribution if they talk to the OIG without 

permission. 

The OIG acknowledges that comments it received in response to these particular 

questions do not represent the majority. In fact, a majority of the respondents 

expressed management’s willingness to allow their interaction with the OIG 

without fear of retribution, as long as the respondents informed management that 

they were providing the information. However, we believe these results tend to 

correspond with procedures under some program offices’ internal guidance that 

can directly influence staff interaction with the OIG. Uncorrected, these practices 

could call into question the reliability of information obtained from the Agency 

and could have required OIG reports to include impairment statements or scope 

limitations. 

Conclusions 

At the time of our review, EPA components had not implemented consistent 

guidance across all offices regarding interaction with the OIG. This resulted in a 

lack of understanding of proper roles and responsibilities dealing with statutory 

oversight organizations. Some EPA program and regional offices developed 

faulty internal guidance. Evidence obtained from staff loses its reliability when 

management screens or has the opportunity to alter data during a multi-level 

review process. Management attempts to keep information from auditors 

increases the time and costs of an audit, and reduces the reliability of information. 

7 
 

 

 

 

 09-P-0222
 

Survey results underscored the need for an overarching guidance governing 

interaction with the OIG and the need for training in this area. 

Corrective Actions Taken 

We recommended that the Deputy Administrator issue guidance to all EPA 

program and regional offices on interacting with the OIG to ensure unfettered 

access to information and personnel; and that all lower level guidance, written or 

unwritten, be revoked. In response, the EPA Administrator issued an Agencywide memorandum on August 7, 2009, that instituted overall Agency guidance 

governing interaction with the OIG. The purpose of the memorandum was to 

ensure that EPA managers and staff understand the role of the Agency’s OIG and 

to address how the EPA Administrator expected Agency programs and personnel 

to interact with the OIG. The OIG has determined that the actions taken by the 

Office of the Administrator address the issues raised during our review. 

Accordingly, we have made necessary changes in this report where appropriate. 

Since the Agency actions were taken prior to issuance of our final report, no 

further action is necessary. 

We have included the EPA Administrator’s memorandum as Appendix A 

8 
 

 

 

 

 

 

 

 

 

 

 

 09-P-0222 

Status of Corrective Actions Taken 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

Issue overall guidance to all EPA program and 

regional offices on interacting with the OIG to 

ensure the OIG has timely and unfettered access 

to information and personnel during the 

performance of OIG reviews on EPA programs and 

operations. 

Revoke all lower level guidance pertaining to 

interaction with the OIG, both written and unwritten, 

and do not allow lower level supplementation of the 

new guidance to be issued. 

C 

C 

Administrator 

Deputy Administrator 

8/7/2009 

8/7/2009 

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 

9 
 

 

 

 09-P-0222
 

Appendix A 

EPA Administrator’s Memorandum on 

Cooperation with the OIG
 

MEMORANDUM 

SUBJECT: Cooperation with the Office of Inspector General 

FROM: Administrator Lisa P. Jackson 

TO: All EPA Employees 

As I recently observed in my memorandum on Transparency in the U.S. Environmental 

Protection Agency’s Operations, “[t]he success of our environmental efforts depends on earning 

and maintaining the trust of the public we serve.” One of the key means by which we ensure the 

kind of accountability deserving of public trust is the process of internal review and oversight 

carried out by our Office of Inspector General. The purpose of this memorandum is to ensure that 

EPA managers and staff understand the role of the Agency’s OIG and to address how I expect 

Agency programs and personnel to interact with the OIG. 

The OIG is to serve as an independent and objective unit within our Agency, playing an 

important role in preventing and rooting out fraud, waste, mismanagement and abuse in Agency 

programs and operations. The OIG also endeavors to improve the efficiency of our Agency 

programs and operations through the performance of audits, evaluations and inspections. To carry 

out its statutorily required function, the OIG necessarily requires, on a regular basis, information 

and assistance from EPA managers and staff. 

There is sometimes confusion regarding the roles and responsibilities of the OIG and the 

Government Accountability Office. While the functions of the OIG and GAO are similar in some 

respects, the two are in different branches of government and have different authorities and 

responsibilities. The OIG’s primary function is to serve as an accountability and oversight 

mechanism within and for the benefit of the Executive Branch of government, in compliance with 

the Inspector General Act of 1978, as amended. GAO is the investigative arm of the United States 

Congress; this memorandum does not address directly the Agency’s interaction with the GAO. 

It is imperative that, upon request, Agency personnel provide OIG auditors, evaluators and 

investigators with full and unrestricted access to personnel, facilities, records (including, but not 

limited to, reports, databases and documents), or other information or material that is needed by 

the OIG to accomplish its mission. Unrestricted access means that managers and staff are not to 

impose burdensome administrative requirements or screening procedures that could impede OIG 

access to needed employees and materials. Management should not attempt to control or influence 

the free flow of information to and from the OIG or to frustrate the full and unfettered exchange 

between EPA personnel and the OIG during the active phase of audits. 

10 
 09-P-0222
 

My expectation is that we will cooperate with the OIG as follows: 

1. Managers and staff are to expeditiously provide materials responsive to an OIG 

request; 

2. Materials should be provided to the OIG in the manner requested, rather than routed 

through an intermediary for review prior to disclosure; 

3. EPA managers and staff must not conceal information or obstruct OIG audits, 

investigations or other inquiries. Doing so is against EPA policy, and may be in violation 

of federal law; 

4. At any time, the OIG may have access to available information such as policy, 

guidance, procedures or existing reports and other general information to focus its plans. 

In the context of specific OIG audits, evaluations or other reviews, the OIG will ordinarily 

issue a notification letter or kick-off memo to EPA management announcing the objectives 

of the OIG activity. Frequently, a meeting will be scheduled with EPA management and 

the OIG staff to discuss the activity. Under all circumstances, EPA managers and staff are 

to provide complete cooperation upon receipt of such notification; and 

5. EPA staff are not required to obtain permission from or inform managers before 

they speak with OIG representatives during audits, evaluations, investigations or other OIG 

reviews. Staff may, at their own discretion, contact their manager with any questions 

regarding their responsibility to cooperate with the OIG or their scheduling of meetings 

with the OIG, unless, in the context of an investigation, they are instructed otherwise by 

OIG. In the context of investigations, managers should not question staff about their 

interactions with the OIG. 

The OIG, for its part, has indicated its intent to respect the multiple demands made upon 

EPA managers and staff and, to the extent possible, to seek to accommodate scheduling difficulties 

or other time constraints that managers and staffs might face. Also, the OIG is committed to 

honoring requests for confidentiality to the extent permitted by the law and to handling all EPA 

documents and information in an appropriate manner. 

To ensure that reports from audits, evaluations and other reviews (collectively referred to 

here as “audits”) are fairly prepared and presented, the OIG staff will endeavor to provide 

management with significant opportunities for interaction. To this end, an audit will ordinarily 

begin with an entrance conference or kick-off meeting and will ordinarily conclude its active phase 

with an exit conference. Management should attend both entrance and exit conferences and make 

its views and concerns known. At any time during the course of the audit, EPA management may 

request and meet with the OIG staff to discuss the audit, provide information to clarify 

management assertions and discuss status and any concerns. 

The OIG intends to solicit EPA management for input regarding accuracy and tonal quality 

frequently during the audit up to and including submission of comments to the written audit 

product. This interaction should help to avoid misunderstandings. The OIG is committed to give 

11 
 09-P-0222
 

full consideration to management comments on discussion drafts and formal draft reports in the 

course of finalizing reports. EPA managers should engage with OIG leadership when it believes 

that its input is not satisfactorily addressed. In the end, formal Agency comments to the formal 

draft will ordinarily be attached, in their entirety, to the final OIG report. This interactive process, 

in which OIG engages management in the audited office in an effort to develop and refine findings 

and recommendations, is a key part of the OIG process, and Agency managers need to see these 

opportunities for interaction as their primary means of expression in the context of OIG audits. 

All offices are expected to review their policies and procedures related to interaction with 

the OIG and must conform to this guidance; the offices must certify such conformity to the Deputy 

Administrator by c.o.b. September 4, 2009. 

If you have any questions about this guidance or about an OIG request for information, 

please contact the Principal Deputy General Counsel at (202) 564-0864 or the Associate Deputy 

Inspector General and Counsel at (202) 566-0861. 

Sincerely, 

Lisa P. Jackson 

12 
 

 

 

 

 09-P-0222 

Appendix B 

Distribution 

Office of the Administrator 

Acting Deputy Administrator 

Assistant Administrator, Office of Administration and Resources Management 

Assistant Administrator, Office of Air and Radiation 

Assistant Administrator, Office of Enforcement of Compliance Assurance 

Acting Assistant Administrator, Office of Environmental Information 

Assistant Administrator, Office of Prevention, Pesticides and Toxic Substances 

Acting Assistant Administrator, Office of Research and Development 

Assistant Administrator, Office of Solid Waste and Emergency Response 

Acting Assistant Administrator, Office of Water 

Acting Chief Financial Officer 

Acting Regional Administrators, Regions 1-10 

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 Air and Radiation 

Audit Follow-up Coordinator, Office of the Chief Financial Officer 

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

Audit Follow-up Coordinator, Office of Environmental Information 

Audit Follow-up Coordinator, Office of Prevention, Pesticides, and Toxic Substances 

Audit Follow-up Coordinator, Office of Research and Development 

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

Audit Follow-up Coordinator, Office of Water 

Audit Follow-up Coordinators, Regions 1-10 

Acting Inspector General 

13