Report: Audit of the EPA’s Oversight of State Subrecipient Monitoring in the Clean Water State Revolving Fund Program

Report # 25-P-0030, May 13, 2025
Why We Did This Report

The U.S. Environmental Protection Agency Office of Inspector General conducted this audit to assess the EPA’s oversight of state subrecipient monitoring in the Clean Water State Revolving Fund Program, including the monitoring of subrecipients of Infrastructure Investment and Jobs Act funds.
 

Summary of Findings

While the annual review procedures for nondiscrimination laws, suspension and debarment, and single audit requirements follow statutory requirements, we found opportunities for the EPA to improve its oversight practices in the annual review steps devoted to subrecipient monitoring activities in these areas. The EPA provided CWSRF Program guidance that supported the three states that we reviewed in monitoring the subrecipients in their state CWSRF programs. The EPA could further support the states in their subrecipient monitoring activities by providing a guide of best practices for subrecipient monitoring and a best practices guide for helping equivalency subrecipients compliance.

We also made observations outside of our audit objective. The CWSRF capitalization grant terms and conditions could include a requirement that recipients and subrecipients must report violations of federal criminal law involving fraud, bribery, or gratuity violations to the OIG. The EPA could also encourage states to include a provision in their CWSRF loan agreements consistent with 2 C.F.R. § 200.113.

Report Materials

• At a Glance - 25-P-0030 (pdf) (1.37 KB)

• Full Report - 25-P-0030 (pdf) (1.37 KB)