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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460


The Honorable Darrell Issa
Chainnan, Committee on Oversight
and Government Reform
House of Representatives
Washington, D.C. 20515
Dear Mr. Chairman:
APR 1 5 2011
OFFICE OF
CHIEF FINANCIAL OFFICER
Thank you for the opportunity to respond to your March 8, 2011 letter requesting the
Environmental Protection Agency (EPA) provide answers to questions on our electronic systems.
The questions related to the systems we use at our agency to support business and accounting
functions; grants and loans management; contracts management; and reporting to government-
wide systems such as USASpending.gov and Recovery.gov are addressed in the enclosed
document.
We hope this response provides the details to meet your information needs. If you have
any questions about the response, please have your staff contact Clara Jones in EPA's Office of
Congressional and Intergovernmental Relations at (202) 564-3701 or jones.c1ara@epa.gov.
Enclosure
rbara J. Bennett
Chief Financial Officer
cc: Honorable Elijah Cummings, Ranking Member
Committee on Oversight and Government Reform
internet Address (URL) _ http://\wvw.epa.gov
Recycled/Recyclable _ Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
Responses to Committee on Oversight and Government Reform - Financial Systems
The Committee on Oversight and Government Reform ("Committee") is the principal oversight
committee in the House of Representatives and has broad oversight jurisdiction as set forth in
House Rule X. To enable the Committee to perform oversight of the federal government's
attempts to modernize its financial management systems they have requested the answers to the
below 23 questions.' '
1. Identify and briefly describe each of your agency's business and accounting systems. If
separate divisions, bureaus, or offices of your agency use separate systems, identify which
divisions, bureaus, or offices use each system.
The Integrated Financial Management System (IFMS) has been EPA's core financial
management'system since 1989. IFMS supports core budget execution and accounting functions;
including posting updates to ledgers and tables as transactions are processed and generating
source data for the preparation of financial statements and budgetary reports. IFMS is used
throughout EPA.
The Budget Automation System' (BAS) integrates the Agency's budget planning, execution, and
reporting, and tracks progress towards meeting the requirements of the GPRA. BAS is primarily
used by the Office of Budget in the Office Chief Financial Officer (OCFO) and all EPA
regional offices.
The Superfund Cost Recovery Imaging. Online System (SCORPIOS) assists EPA in the
recovery of Superfund site-specific cleanup costs by 'summarizing the funds that EPA has spent
cleaning up a Superfund site. SCORPIOS is used by EPA's Office of the Chief Financial
Officer,' EPA's Chief Information Officer, Office of Enforcement and Compliance Assurance,
Office of Solid Waste and Emergency Response and' all EPA regional offices.
The Property Inventory System transmits scanned barcode and decal data to confirm and track
agency property. This system also supports day-to-day property management such as
property assignments, transfers, and disposals to provide accountability and resource reutilization
within EPA. The Office of Administration and Resource Management is the principal
user of the Property Inventory System.
is a system designed to allow Working Capital Fund (WCF) customers to establi?h the
necessary accounts, shop for EPA WCF products and services via an on-line catalog, obtain
products and services, and monitor usage. eBusiness is used throughout EPA.
The Integrated Resource Management System (IRMS) integrates research planning, budget
formulation, budget execution, and strategic plan management for EPA's research programs and
tracks commitments, obligations, and payments for these programs. IRMS is used by EPA's
Office of Research and Development.
In addition to the systems mentioned above, there are a number of smaller systems integrated
with IFMS that track transactions and payments. EPA uses the Contract Payment System (CPS)
to process contract payments. The Small Payment Information Tracking System (SPITS) tracks
and processe.s small purchase payments. !he Bankcard Payment System records all EPA
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Responses to Committee on Oversight and Government Reform - Financial Systems
purchase card transactions and allocates transactions for processing into IFMS. The Fellowship
Payment System (FPS) records payment schedules for fellowship recipients and prepares stipend
and tuition payments 'to students and universities. The Interagency .. Doc Online Tracking System
'(IDOTS) tracks payments for interagency agreements. EPA's fina1)ce centers are the principal
user base for these payment systems. The Web-based Ordering System (WEBOS) records
obligations and work orders from EPA's WCF customers.
PeoplePlus (PPL) is the centralized system to support the human resources (HR) and
time and attendance business functions. It is the official repository for HR data on employees,
positions, and organizations. The system is used by EPA's Office of Human Res01.Jrces for
HR related activities and throughout EPA to manage the time and attendance 'process for all EPA
employees and managers.
2. Explain how the business and accounting systems identified in response to Request No.1
interact with one another.
IFMS serves as the central nexus and all other systems interface with IFMS to input and/or
extract data. BAS provides Available Funding, Account Structure, Transaction Code, Budget,
Appropriatfon, Organization, and Program information to IFMS through an automated interface.
SCORPIOS extracts data from the reporting utility for IFMS to prepare cost recovery summaries.
The, Property Inventory System sends equipment information on the inventory results and asset
clarification to IFMS on an annual basis. eBusiness retrieves information on funding from
and pushes billing data to IFMS through a IRMS receives summary
level budgetary, commitment, obligation, and payment data from IFMS on a nightly basis and
transmits commitment information to IFMS in real time. SPITS sends payment information to
IFMS daily and retrieves obligation and commitment information from IFMS in real tin1e. The
Bankcard Payment System provides commitment, obligation, and payment information, to IFMS
on a daily basis. The Fellowship Payment System sends fellowship data to IFMS on an
as-needed basis. IDOTS transmits obligation and payment redistribution transactions to IFMS
and retrieves obligation and commitment information from IFMS in real time. PPL uses
accounting data from IFMS and sends payroll and associated financial information to IFMS.
Finally, WEBOS transmits customer funding obligations to IFMS in real time.
3. For each system identified in to Request No.1, state whether information found
in that system is regularly or periodically submitted to any of the government-wide
accounting systems maintained by the Department of the Treasury, e.g., GFRS, FACTS I,
FACTS II, IFCS, etc., and explain how and at what intervals those submissions occur,
including descriptions of both manual. and automated processes.
EPA uses accounting data captured in the IFMS to submit federal mandated deliverables through
the Department of Treasury's government-wide accounting systems. The Agency uses the IFMS
adjusted trial balance which reports general ledger account balances by"Treasury Symbol, to
prepare financial statements and federal reporting to meet the following:
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Responses to Committee on Oversight and Government Reform - Financial
Cash Report to Treasury: Submitted monthly to Treasury by manually entering general
ledger balances into the Government 'Wide Accounting Classification Transactions and
Accountability (CTA) module (Formerly Partial 224).
. .
Receivable and Debt Collection Activities: Submitted quarterly to Treasury by manually
entering general ledger balances into the Debt Management Information System (DMIS).'
Report on Budget Execution and Budgetary Resources (SF133), Year-End Closing
Statement (FMS 2108) and a portion of the Program and Financing (P&F) Schedule of
the President's Budget: Submitted quarterly to Treasury by uploading a file with
ledger balances and required attributes into the Federal Agencies' Centralized Trial ..
Balance System (FACTS II). .'
Confirmation of Fiduciary 'Activity: Submitted quarterly to Treasury by manually
confirming that EPA balances for fiduciary intragovemmental transactions agree with
what Treasury has reported in the Intragovernmental Fid'uciary Confirmation System
(IFCS). Discrepancies, if any, are explained.
Agency Preclosing Trial Balance at Fund Group Level: Submitted annually to Treasury
by manually entering general ledger balances at the fund group level with required
attributes into the Federal Agencies' Centralized Trial-Balance System
(FACTS I).
Agency's Closing Package: Submitted annually to Treasury by manually entering
audited financial statement data into the Governmentwide Financial Report System
,(GFRS) for inclusion in the Federal Report of the United States.
4. For each system identified in response to Request No.1, state whether inforJDation found
in that system is regularly or periodically submitted to tbe Office of Management and
Budget's (tfOMBtf) MAX Information System, and explain how and at what intervals
those submissions occur, including descriptions of both automated and manual processes.
The Agency uses the IFMS adjusted trial balance, which reports general ledger account balances .
by Treasury Symbol, to report the following into OMB MAX:
Interim unaudited and annual audited financial statements along with associated variance
analysis: Submitted quarterly to OMB by uploading files to OMB MAX.
Reconciliation of the Statement of Budgetary Resources (SBR) and the SF 133:
Submitted quarterly to OMB by manually entering SBR and SF 133 comparable line item
amounts and providing an explanation for any material differences.
Budgetary information from BAS is extracted and submitted to the OMB MAX enviroIunent
throughout the fiscal year. In Novembet, prior year budget data is submitted to MAX. In
December and January, currellt year budget data is submitted to MAX. After a mid-session
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Responses to Committee on Oversight and Government Reform - Financial Systems
review in July, if budgetary projections suggest substantial changes from the baseline established
in the submission, data on these changes are manually submitted to MAX.
5. For each system identified in respon$e to Request No.1, describe recent, current, and
planned migration or modernization projects.
In October 2011, EPA plans to go-live with a new core financial and accounting system to
replace its legacy mainframebased system, IFMS. This system is.1mown as COMPASS Core
Financials and is based on a Commercial off the Shelf (COTS) product from CGI Federal known
as Momentum. COMPASS Core Financials will be configured to integrate with all of the
systems identified in the response to the first question. This replacement of EPA's core financial
system is the first stage in a component-based modernization strategy presented to the OMB
Financial Systems Advisory Board in 2010. Building on COMPASS core financial and
accounting system, this modernization strategy will include projects to modernize EPA's BAS,
SCORPIOS, payment systems, and to adopt the Common Government .. Wide Accqunt
Code Structure (CGAC) within COMPASS Core Financials. At present, these projects are in the
initial conceptual planning stage as EPA focuses on the successful deployment of COMPASS
Core Financials. '
6. In addition to Y9ur agency's submissions to government-wide accounting systems
maintained by the Department of the Treasury and OMB, as described in response to
Requests Nos. 3 and 4, does your agency publish any of the same information on-line for
public viewing? If so, describe how and in what format that information is published.
EPA does not publish any of our Treasury reports for on-line public viewing. However, most of
the infonnation is contained, in EPA's annual financial statements. These statements are posted
. on EPA's public web site after the annual audit is complete.
7. Identify and briefly describe each system that your agency uses to manage grants, direct
loans, and/or loan guarantees. If separate divisions, bureaus, or offices of your agency use
separate systems, identify which divisions, bu'reaus, or offices use each system.
EPA processes grants electronically through the Integrated Grants Management System (lGMS),
a Lotus Notes based system. lGMS consists of a series of integrated modules that support
grant/financial management from application to closeout. EPA project officers submit funding
. recommendations using IGMS to the Grants Management Officers for review and award.
EPA uses the Department of the Treasury's Automated Standard Application for Payments
(ASAP) system for the majority of its grant payments. EPA's Grants Payment Allocation
System (GPAS), interfaces with ASAP to help the Agency track grant payments. Reporting
infonnation on EPA's grant management programs accomplished through a system known as
the Grants Data Mart. The Grants Data Mart includes data from the grants and finance systems
and provides standard reports to monitor matches between grants data and financial records. The
Grants Data Mart provides data sets for USASpending.gov and the Federal Assistance Award
Data System (F AADS).
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Responses'to Committee on Oversight and Government Reform - Financial Systems
The principal users of these systems are the Office of Grants and Debarment (OOD) and OeFO.
IOMS, ASAP, and the Grants Data Mart are principally used by OOD. GPAS is used by both
OGD and OCFO.
8. For each system identified in response to Request No.7, explain how it interacts with any
business or accounting system identified in respo'nse to Request No. 1.
Grant funding obligations are committed within IFMS. IGMS retrieves commitment, obligation,
document control, and account structure information on a nightly basis from IFMS to support its
grant management workflow. EP A uses ASAP to process grant payments and ASAP provides
GP AS with a file of payment transactions. GP AS serves to connect grant payments to
obligations and submits this information to IFMS. The Grants Data Mart interacts with IGMS
and GPAS to facilitate comparisons of data against financial information.
9. For each system identified in response to Request No.7, state whether information found
in that system is regularly or periodically submitted to the Catalogue of Federal Domestic
Assistance (CFDA), and describe how and at what intervals those submissions occur,
including of both automated and manual processes.'
While the lGMS does contain Catalog of Federal Domestic Assistance (CFDA) nu-mbers arid
titles, the system is not involved in the maintenance of EPA's entries in the CFDA system. Each
year EPA updates its CFDA program descriptions in accordance with General Service
Administration (GSA) guidance to ensure that the descriptions provide the public with accurate
information on EPA funding opportunities. Updated GSA guidance is expected to require
reporting new CFDAs to OMB by July 15,2011; updates for existing CFDAs by August 16,
2011; and final updates for all programs by September 16, 2011. OGD has a web-enabled
database tool for receiving CFDA updates from EPA's program offices.
10. For each system identified in response to Request No.7, state whether information
found in that system is regularly or per:iodically submitted to any of the government-wide
grants management and reporting systems, e.g., FAADS, FAADS PLUS, etc., and describe
how and at what intervals those submissions occur, including descriptions of both
automated and'manual processes.
OGD monitors data quality through its oversight of the F AADS PLUS and F AADS data
submission process. FAADS PLUS and FAADS data is tested against electronic edits in the
Grants Data Mart and manually checked for completeness prior to, data transmittal. OOD also
includes data quality review in its internal grants management reviews and forced edit checks ,in
the lGMS. OaD submits F AADS PLUS data monthly using the USASpending.gov Data
Submission and Valuation Tool. FAADS data is submitted quarterly via an Excel file emailed to
the Census Bureau.
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Respenses to. Co.mmittee en Oversight and Government Referm - Financial Systems
11. For each system identified in to Request No.7, describe recent, current, and
planned migration or modernization projects. .
CGD, along with program and regional suppert, conducted a preliminary alternatives analysis
comparing the three Grants Management Line of Business (OMLOB) providers selected by
OMB. Based on the findings from this preliminary analysis, CGD selected Health and Human
Services (HHS) for further evaluation and completed a fit/gap analysi's on the GrantSelutions
system in FY 2010. OOD also completed a fit/gap in FY 2010 with CompuSearch's PRISM, a
commercially available product used by EPA's Office of Acquisition Management (OAM).
OGD documented the rationale for pursuing Prism-Grants and submitted it to the OMLOB
Pregram Management Office at the National Science Feundation fer cemment. The OMLOB
appeal'te further explore Prism-Grant was sent to OMB in August and appreved in Odeber 2010.
IOMS and OPAS will interface with EPA's new cere financial and acceunting system,
COMPASS Cere Financials, to. replicate the interaction that exists between these systems and
IFMS.
12. In addition to your agency's submissions to government-wide grants and
reporting systems, described in response to Requests Nos. 9 and 10, does your agency
publish any of the same information on-line for public viewing? If so, describe how and in
what that information is published.
EP A maintains the Internet accessible Grants Awards Database that prevides infermation to. the
public abeut EPA non-constructien grants awarded in the last 10 years. The URL fer the
is http://yosemite.epa. gov/earm/igms egf.nsf/Hemepage?ReadF erm.
13. Identify and briefly describe each system that your agency uses to manage contracts. If
separate divisions, bureaus, or offices of your agency use separate systems, identify which
divisions, bureaus, or offices use each system.
EP A uses the EPA Acquisitien System (EAS) to. manage contracts. This system is based en the
Compusearch PRISM COTS software product and replaced EPA's legacy precurement systems:
the Integrated Contract Management System (ICMS) and Small Purchases Data
Interchange (SPEDI). EAS is used throughout.EPA.
OAM is responsible fer managing EAS.
EPA uses the Contract Payment System (CPS) to. process contract payments. CPS precesses
contract invoices from EAS in with Prompt Pay regulations. After receiving invoice
apprevals from officers, CPS transmits check and Automated Clearing Heuse (ACH)
payment schedules in a machine-te-machipe connection to the Department of the Treasury. CPS
transmits ebligation and payment data back to IFMS after the cempletien ef the payment precess"
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Responses to Committee on Oversight and Government Reform - Financial Systems
14. For each system 'identified in response to'Request No. 13, explain how it interacts with
any business or accounting system identified in response to Request N(). 1.
EAS sends commitment and obligation transactions associated with procurements to IFMS.
EAS also uses IFMS to validate accounting strings and available balances for procurements.
For contracts, EAS transmits contract invoices to CPS to initiate the contract payment process
through the Department of the Treasury with this system. In tum, CPS passes obligation and
payment data back to IFMS to reflect payments within Agency accounts.
15. For each system identified in response to Request No. 13, state whether information '
found in that system is regularly or periodically submitted to any of the government-wide
contract management and reporting systems, e.g., FPDS, FPDS-NG, FAPIIS; etc., and
describe how and at what intervals those submissions occur, including descriptions of both
automated and manual processes.
EAS reports data to FPDS-NG through an automated process. FPDSNG then transmits this data
to USASpending.gov. EPA does not transact data directly with USASpending.gov. Data. "
submitted to FPDSNG is organized around t ~ e Treasury Accounting Symbol (TAS). FPDSNG
does not have the capability to capture or collect data from multiple lines of accounting (each
associated with a unique T AS), thus EPA rolls up accounting lines and reports data under the
TAS corresponding to the predominant funding amount. Data is finalized in FPDSNG based
upon an electronic approval in EAS. Once contracting data has been loaded into FPDS-NG,
EPA does not know the transaction time for data to be transmitted from FPDSNG to
USASpending.gov.
"-
16"For each system identified in response to Request No. 13, describe recent, current, and
planned migration or modernization projects.
EP A completed the migration of its legacy procurement and acquisitions systems, ICMS and
SPED I, to EAS in December 2010. EAS currently interfaces 'with IFMS and will be fully
integrated with EPA's new core financial system, COMPASS Core Financials, in October 2011.
17. In addition to your agency's submissions to government-'wide contract management
and reporting systems, described in response to Request No. 15, does your agency publish
any of the same information on-line for public viewing? If so, describe how and in what
format that information is published.
EPA's web site includes service contract inventories for all service contract actions over $25,000
a w a r d e ~ in the specified fiscal ye(if. Closed procurements, award notices, active contracts, and:
new award information also is published on the EPA web site. This information is in HTML
format and published as Adobe Portable Document Format.reports.
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Responses to Committee on Oversight and Governnlent Reform - Financial Systen:s
18. Briefly describe your agency's efforts to comply withOMB's memorandum on the
Open Government Directive Federal. Spending Transparency, dated April 6, 2010. In
particular, describe whether and how your agency has begun to collect and report s1Jb-
award data, as required by the memorandum, and describe how your agency's reports on
OMB's data quality metrics, as required by the memorandum, are generated.
EPA initiated sub-award reporting on October 1,2010, consistent with the process outlined in
OMB's August 27,2010 supplementary guidance, Open Goverru:nent Directive - Federal
Transparency and Subaward and Compensation D(;lta Reporting, Appendix A. The guidance
required EPA to (1) ensure the quality of its existing F AADS PLUS data submissions; (2) .
convey to prime awardees, through revised standard terms and conditions, the requirement for
subaward and executive compensation reporting; and (3) communicate ~ o prime awardees the
requirement to register in the Central Contractor Registratiol1 (CCR) system. Baseline metrics
. on spending data quality have not yet been shared 'with EPA.
EPA's overall approach and efforts to comply with the Open Government Directive and the
Federal Funding Accountability and Transparency Act are detailed in our Open Government
Data Quality Plan, released on May 18, 2010 and publically available at
http://www.epa.gov/openJopengov data quality plan.pdf. The Data Quality Plan describes
EPA's internal process for ensuring the timeliness, cOlnpleteness, and accuracy of spending data.
In order to communicate the new requirements to prime awardees, EPA developed standard
terms and conditions, Implementing Guidance for prime awardees, and participated in public
workshops.
Per FAR Part 19 guidance, EPA contractors have been accessing and inputting s,:!bcontracting
activity information into electronic Subcontracting Reporting System (eSRS). Additionally,
EPA Contracting Officers also have been provided access to eSRS to monitor and oversee
subcontracting activities on EPA contracts.
Additionally, EPA participates on all Govemment .. wide acquisition data system workgroups in
order to understand and improve data quality across the acquisition spectrum. Furthermore,
OAM has implemented several data quality initiatives to monitor and review the accuracy and
completeness of contract data input into the various Government-wide data systems. The goal
with these individual initiatives is to ensure the overall quality of EPA datalmetrics reported to
OMB through these feeder systems.
19. If your agency interacts directly with USASpending.gov, in addition to submitting
information to the s y s t e ~ s that feed USASpending.gov, describe tbe nature, frequency, and
purposes of that interaction.
EPA submits grant information on a bi-monthly basis to USASpending.gov through FAADS
PLUS. EPA awards mandatory and discretionary grants, cooperative agreements, and .
fellowships. EPA reports on all grants and fellowships awarded in compliance with the Federal
Funding and Transparency Act (FFATA).
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Responses to Committee on' Oversight and Government - Financial Systems
EPA also reports on any and all contract actions through FPDS .. NG, which transmits this data to
USASpending.gov (includes new modifications, delivery or task orders, blanket
purchase agreements, and simplified acquisitions/purchase orders). Data submissions to
FPDS-NG are orchestrated in a real-time automated process 'based upon approvals in EAS).
EP A reports on actions in with FF A T A.
EP A staff occasionally contacts USASpending.gov contractor staff with questions about
submission issues. The USASpending.gov support group answered all questions and provided
guidance that was accurate and helpful. .
20. Describe the data quality controls and procedures that your agency has implemented
for information that is submitted to USASpending.gov, including information submitted
directly and information submitted to one of the systems that feeds USASpending.gov.
For each data set submitted directly or indirectly to USASpending.gov, EPA instituted a quality
assurance process to assess and ensure the accuracy and reliability of spending data. Each data
set is reviewed to assess the risk level associated with the data accuracy and reliability. This risk
level is used to determine the scope of a random sample of data used by the reviewer to provide a
significant assurance of its accuracy. The reviewer will cross check the accuracy of
this sample against supporting documentation and will verify the accuracy of an additional
sample of transactions by dollar value. Tests of internal controls are conducted to verify their
reliability. The data flow for data set generation is reviewed to verify the procedures and
policies were followed. Spot checks are performed to ensure that data is properly labeled in a
clear and accurate manner. If applicable, all data must have a clean audit opinion and if there are
any outstanding audit issues with the data, the data will not be posted. Each office requesting a
posting of a spending data set must be able to c.ertify and trace the origin of the data. OARM AA
certifies the accuracy of current data sets on USASpending.gov on a quarterly basis to the CFO.
A copy of the EPA data quality plan is available at:
http://www.epa.gov/openJopengov data quality plan.pdf
oon monitors data quality through its oversight of the USASpending.gov data submission
process. USASpending.gov data is submitted to Dun and Bradstreet to establish confidence
levels for Duns numbe!s. Subsequently, the data is tested against electronic edits in the Grants
Data Mart and manually checked for completeness prior to data transmittal. oon also includes
data quality review in its internal grants management reviews and forced edits in the EPA Grants
System.
EAS has built-in checks to verify completeness and accuracy of the data.
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Responses to Committee on Oversight and Government Reform - Financial Systems
21. State whether all of your agency's current grants, contracts, and loans are accurately
reflected on USASpending.gov, and, if not, estimate the percentage of current grants,
contracts, and loans that are .not accurately reflected, using both the number of
transactions and dollar figures.
Currently, all EPA grants are accurately reflected on USASpending.gov with the exception of six
awards during the last three months as a result of the active CCR registration requireP1ent. These
six awards represent less than one percent of EPA grants. The six recipients are currently in the
process of completing registration in the CCR. EP A believes the contract data reflected on
USASpending.gov is accurate.
22. State whether your agency incurs any reporting burdens or as a result of its
obligations under the Federal Financial Assistance Transparency Act C'FFATAff) that it
does not incur as a result of other reporting obligations, estimate those burdens and
costs in worker-hours and dollars.
EPA personnel have additional data entry requirements to look up the T AS associated with the
"line(s) of accounting, determine the predominant TAS, and enter that data into FPDS. We have
no method of accurately measuring the atnount of time spent on this activity.
23. Identify the individual(s) who serve(s) as Senior Accountable Official(s) (,'SAO
H
) over
federal spending data quality for your as defined by 01\1B.
EPA's Chief Financial Officer, Barbara J. Bennett, serves the Agency's Open Government
SAO to ensure spending data integrity. EPA's Chief Information Officer (CIO), Malcolm
Jackson, is accountable for general data quality. EPA established an Open Government
Spending Information Quality Work Group consisting of representatives from OARM, Office of
Environmental Information (OEI), and the OeFO. Both the SAO and CIa work in parallel to
ensure the quality of all high-value Agency data.
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United States
Environmental Protection Agency
Washington, DC 20460
Official Business
Penalty for Private Use
$300 1:3(} /1}


CA4920110420005B3
..,)
The Honorable Darrell Issa
Chairman
Committee on Oversight and Government Reform
House of Representatives
Washingtonl D.C. 20515
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