In contrast, the EPA IG has determined that the Chemical Safety Board’s purchase card program is at “high risk for illegal, improper or erroneous purchases and payments.” Issues included that:
CSB was unaware of the requirement to submit a written charge card management plan to OMB by January 2014 and did not produce one until last November.
Management made assurances it had the appropriate policies and controls in place for purchase cards in FY 2014, but CSB did not establish them until FY 2015.
The management plan, even once in place, did not identify all key management officials, nor did it contain the required compliance summary and internal control assurance assessment.
CSB did not always obtain prior written supervisory approvals for purchases.
CSB disagreed that it certified controls without written internal policies and procedures and that the management plan did not identify key management officials. The IG replied that it found no evidence that CSB staff were made aware that there were no agency-specific policies and therefore they were required to follow Bureau of the Fiscal Service guidance, and that the CSB managing director approves funding for all purchase card transactions and should be listed as a key management official.