Weatherization Assistance Program: IG/GAO – Monitoring – QA

1 | Weatherization Assistance Program: The Federal Perspective (Part 1) eere.energy.gov

NASCSP 2011 Mid-Winter Training Conference

March 4, 2011Weatherization Assistance Program: IG/GAO – Monitoring – QA

Holly Ravesloot, Christine Platt-Patrick & Erica Burrin


Inspector General and General Accountability OfficeIG/GAO Reports:

A Review of Findings and Next Steps

Presenter: Christine Platt Patrick, DOE Policy Advisor


Overview

IntroductionThe IG/GAOFindings and TrendsNext Steps


IG/GAO – The Process

The Inspector General (IG) Mission - To help the Department and the American taxpayer by identifying opportunities for cost savings and operational efficiencies in Department programs; and returning hard dollars to the Department and the U.S. Treasury as a result of Office of Inspector General civil and criminal investigations.

The General Accountability Office (GAO) - GAO exists to support the Congress in meeting its constitutional responsibilities and to help improve the performance and ensure the accountability of the Federal government for the benefit of the American people.



The audit process commences upon receipt of the incoming notification letter from IG or GAO of their intent to conduct a review with EERE.

Information contained in the notification letter includes:

Job title, job code and a brief description of the assignment; Indication of whether the audit is the result of a Congressional

request or a IG/GAO initiative; Proposed entrance conference dates; Locations and specific program offices where work will be

performed, and Identification of the performing division, and the name and

telephone number of the appropriate IG/GAO contact for the audit.



Attend entrance conference

Respond to requests for information and documentation

Statement of Facts/Coordination Copy

Draft Report

Respond with management decision letter with corrective actions and estimated completion dates

Exit Conference

Final Report


IG/GAO – Findings and Trends

General IG/GAO Findings:– Substandard performance in weatherization workmanship– Substandard performance in initial home assessments

Assessments that called for inappropriate weatherization measures Assessments overlooked key measures to make homes more

energy efficient– Inadequate oversight of contractors– Inaccurate documentation for contractor billing– Homes failing final inspection– Inadequate recordkeeping– Inadequate payroll systems to track employee’s time on projects– Incomplete client files– Fraud, waste and abuse of funds


IG/GAO – Next Steps

Investigations Are Changing Focus–Prior Focus: Department level

–New Focus: CAA level



What CAAs Can Do



Procure contractor weatherization services through a competitive process as required by Federal regulations and perform cost analyses in the selection of contractors to ensure price competiveness.

Obtain and/or review supporting documentation for contractors' invoices to ensure that materials and labor costs incurred on projects are associated with allowable weatherization services and materials.

Ensure that employees charging payroll costs to the Weatherization Program Recovery Act grants are actually providing such services to the Program.



Develop written policies and/or procedures for ensuring cost reasonableness and supportability.

Develop/ensure payroll systems are structured to track employee's time incurred on projects.

Ensure payments for expenditures are appropriately documented and accounted for.

Ensure contractors are billed for labor charges that have been incurred and for materials that have been installed.



Initial assessments that called for inappropriate weatherization measures or the assessments overlooked key measures needed to make the homes more energy efficient.

Ensure that income eligibility source documentation be a part of every client’s file.

Ensure the eligibility documentation, whether stored electronically or hard copy (off site is ok), be readily available at the request of an outside reviewer.


IG Hotline Complaints

Inspector General


Questions?


Inspector General and General Accountability OfficeMonitoring:

DOE’s Monitoring Approach

Presenter: Holly Ravesloot


Minimum Frequency of On-Site Monitoring visits per Year (more visits may be required based on specific situations or needs):– Grants over $90 Million (Quarterly)– Grants between $90 Million - $40 Million (Three visits)– Grants under $40 Million (Semi-Annual)

Frequency


Monitoring Revamp

What were the goal and objectives?• The main goal is to transform the current “one size fits all” monitoring

process into a more efficient, comprehensive, and streamlined process.

• Make sure areas of interest from the IG and GAO are reviewed and any issues documented.

• The main objectives are:

1) Create on-site monitoring checklist questions to provide more specific answers and a system to appropriately weight and quantify the results.

• Baseline score, # of findings, concerns, recommendations, etc.

2) Simplify and create a consistent reporting process.• Checklist + narrative answers becomes the report.

3) Have an online system to track and archive information.• Need a tracking system to confirm corrective and action items were issued

and closed out/completed.


Monitoring Revamp

What is the result?• A refined process to allow the Project Officers to focus

monitoring efforts on specific areas to better identify existing and potential problems or concerns.

• The checklist was divided into 3 sections:• Programmatic & Management

• Awards Administration• Field/Subgrantee Review


Monitoring Instruments

Programmatic & Management

Awards Administration

Field/Subgrantee


Grantee/Subgrantee Preparation:

Monitoring Preparation


Explain how the Grantee assures Subgrantees comply with income eligibility requirements and identify what procedures the Subgrantees must follow.

Source Documentation:10 CFR 440.16: Minimum Program Requirements10 CFR 440.22: Eligible Dwelling UnitsApplication Package, III.1WPN 10-15: Eligibility of Multi-FamilyWPN 10-15a: Accrual of Benefits WPN 10-18: Income GuidelinesWPN 11-1, 5.2: Multi-family EligibilityWPN 11-1.5.8: Eligibility Levels Material Review:Policies on income documentation and eligibility.Completed monitoring files to determine if eligibility is part of Grantee oversight.

P&M: Question 14ELIGIBILITY


How does the Grantee verify the DOE approved energy audit or priority list (on file at DOE) is consistent with what the Grantee monitors the Subgrantee against:

a. Single Family Units?b. Mobile Homes?c. Multi-Family Units?

P&M: Question 28

Source Documentation:10CFR440.14: State Plan10CFR440.21: Energy Audits10CFR440.23: Oversight, Training &

Technical Assistance10CFR440.24: RecordkeepingWPN 11-1.5.5: Energy Audit CriteriaWPN 01-4WPN 05-5WPN 09-4WPN 09-8

Material Review:State Plan ReviewAudit System ReviewSample Audit Report (from client files)Priority List Approval Information

ENERGY AUDITS


Finalize Checklist Issue Guidance Document with checklist as attachments Any questions?

Next Steps


Inspector General and General Accountability OfficeQuality Assurance

Presenter: Erica Burrin


Oakridge National Laboratory is the responsible party that oversees the QA contractor, Institute for Building Technology and Safety (IBTS)

IBTS will conduct both file reviews and quality assurance visits at homes completed using ARRA funds

Quality Assurance (QA) Contractor Process


QA visits will include the following activities at the subgrantee’s office and various work sites:

1. Examining of a representative sample of client work files based on weatherized homes reported or

planned to be reported by the subgrantee during the ARRA period

2. Scheduling of site visits to a representative sample of completed homes

3. Visiting a representative sample of homes reported as completed by the subgrantee.



Observations made and recorded by IBTS may include:

1. Completeness of client files

2. Measures called for on a work order as compared to measures installed

3. Documentation of a completed final inspection by the subgrantee

4. Measures billed to the WAP program for labor and material costs versus measures installed on units

5. Quality of workmanship/adherence to state field guides



Communication Process

File Collection

Scheduling Site Visits

Quality Assurance (QA) Contractor Protocols


How will DOE use the information from the QA contractor?

1. Database Creation

2. Project Officer Review

3. National Data Trends

Quality Assurance (QA) Contractor

Documents

Weatherization Assistance Program: IG/GAO – Monitoring – QA