Weatherization Assistance Program: IG/GAO – Monitoring – QA

1. Weatherization Assistance Program: IG/GAO – Monitoring – QA March 4, 2011 Holly Ravesloot, Christine Platt-Patrick & Erica Burrin

2. Inspector General and General Accountability Office IG/GAO Reports: A Review of Findings and Next Steps Presenter: Christine Platt Patrick, DOE Policy Advisor

3. Overview • Introduction • The IG/GAO • Findings and Trends • Next Steps

4. 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.

5. IG/GAO – The Process • 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.

6. IG/GAO – The Process • 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

7. 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

8. IG/GAO – Next Steps • Investigations Are Changing Focus • Prior Focus: Department level • New Focus: CAA level

9. IG/GAO – Next Steps What CAAs Can Do

10. IG/GAO – Next Steps • 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.

11. IG/GAO – Next Steps • 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.

12. IG/GAO – Next Steps • 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.

13. Inspector General IG Hotline Complaints

14. Questions?

15. Inspector General and General Accountability Office Monitoring: DOE’s Monitoring Approach Presenter: Holly Ravesloot

16. Frequency • 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)

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

18. 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

19. Monitoring Instruments

20. Monitoring Preparation • Grantee/Subgrantee Preparation:

21. P&M: Question 14 ELIGIBILITY 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 Requirements 10 CFR 440.22: Eligible Dwelling Units Application Package, III.1 WPN 10-15: Eligibility of Multi-Family WPN 10-15a: Accrual of Benefits WPN 10-18: Income Guidelines WPN 11-1, 5.2: Multi-family Eligibility WPN 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.

22. P&M: Question 28 ENERGY AUDITS 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? Source Documentation: 10CFR440.14: State Plan 10CFR440.21: Energy Audits 10CFR440.23: Oversight, Training & Technical Assistance 10CFR440.24: Recordkeeping WPN 11-1.5.5: Energy Audit Criteria WPN 01-4 WPN 05-5 WPN 09-4 WPN 09-8 Material Review: State Plan Review Audit System Review Sample Audit Report (from client files) Priority List Approval Information

23. Next Steps • Finalize Checklist • Issue Guidance Document with checklist as attachments • Any questions?

24. Inspector General and General Accountability Office Quality Assurance Presenter: Erica Burrin

25. Quality Assurance (QA) Contractor Process • 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

26. 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.

27. Quality Assurance (QA) Contractor Process • 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

28. Quality Assurance (QA) Contractor Protocols • Communication Process • File Collection • Scheduling Site Visits

29. Quality Assurance (QA) Contractor • How will DOE use the information from the QA contractor? 1. Database Creation 2. Project Officer Review 3. National Data Trends