Detailed Information on the
Alaska Native Village Water Infrastructure Assessment

Develop an annual programmatic efficiency measure, which managers will find useful for improving operational performance of the program.

Investigate a strategy for improving the obligation rate of program funds.

Develop a plan to institutionalize the management framework of the program to ensure continued program effectiveness.

Correcting incomplete data fields and reporting deficiencies in database to support analysis for cost effectiveness and efficiency by January 30, 2007.

Finalizing web based project reporting system to include all projects funded by EPA dollars by April 30, 2007.

The program will issue a contract for an independent review of the Alaska Native Tribal Health Consortium financial processes and records. The independent review will begin in January 2007.

Implement stalled projects review procedures in accordance with the management control policy.

Measure: Percent of serviceable rural Alaska homes with access to drinking water supply and wastewater disposal.

Explanation:Housing information is collected at the end of the year (typically March)in order to capture progress over the previous construction season. This collection cycle does not align with the collection of information for OMB. Proposal: Housing information collected in March of 2006 actually reflects progress through 2005. Not all homes are serviceable because some are seasonal homes, some are structurally unsound and some are cost prohibitive to serve. Approximately 6% of the total homes in rural Alaska fall into this category.

Measure: 100% percent of the serviceable rural Alaska homes will have access to drinking water supply and wastewater disposal by 2011.

Explanation:The long-term program measure reported in the 2004 PART was to provide service to 100% of the remaining homes in rural Alaska which indicates all homes in rural Alaska are serviceable. Not all homes are serviceable because some are seasonal homes, some are structurally unsound and some are cost prohibitive to serve. Approximately 6% of the total homes in rural Alaska fall into the unserviceable category. The current program goal is to provide service to 100% of all serviceable rural Alaska homes or 94% of all homes in rural Alaska. Housing information is collected at the end of the year (typically March)in order to capture progress over the previous construction season. This collection cycle does not align with the collection of information for OMB. Proposal: Housing information collected in March of 2006 actually reflects progress through 2005. But to meet OMB's schedule the Program would use the March 2006 figures as the actual for 2006. The baseline numbers for the Program were established during the March 2004 housing survey and are referred to as 2003 figures.

Measure: Number of homes that received improved service per $1,000,000 of State and Federal funding.

Explanation:The Program analyzes the work plan for the annual grant to the State of Alaska to determine the number of homes served per $1,000,000 invested. Improved service is when a home is provided with water or sewer service at the home for the first time or if drinking water that is being provided at the home meets regulatory requirements as the result of infrastructure funding. These improvements are documented as reductions in "deficiency levels" for each home as defined and measured by the IHS sanitation facilities Construction Program and adopted by the Alaska Native Village Water Infrastructure Program.

Measure: 100% percent of Alaska rural population served by public water systems in compliance with Safe Drinking Water Act regulatory requirements by 2011.

Explanation:This measure demonstrates the Program progress in providing drinking water that meet regulatory requirements. The measure is reported on by the Alaska Drinking Water Program as part of their Public Water System Supervisory program. As new regulations are implemented the percent of homes and systems in compliance may drop until the Program can fund, design, and construct new facilities to meet the new regulatory standards. The program's goal for 2010 is 100%, but given the dynamic nature of the regulatory requirements the goal is very ambitious.

Is the program purpose clear?

Explanation: Legislation establishes the purpose of the program: ... The Administrator of the Environmental Protection Agency may make grants to the State of Alaska for the benefit of rural and Native villages for: (1) the development and construction of public water systems and wastewater systems to improve the health and sanitation conditions in the villages; and (2) training, technical assistance, and educational programs relating to the operation and maintenance of sanitation services in rural Native villages.

Evidence: Section 303(a) of the Safe Drinking Water Act Amendments of 1996 "SEC. 303. SDWA: GRANTS TO ALASKA TO IMPROVE SANITATION IN RURAL AND NATIVE VILLAGES. (a) In General.--The Administrator of the Environmental Protection Agency may make grants to the State of Alaska for the benefit of rural and Native villages in Alaska to pay the Federal share of the cost of-- (1) the development and construction of public water systems and wastewater systems to improve the health and sanitation conditions in the villages; and (2) training, technical assistance, and educational programs relating to the operation and management of sanitation services in rural and Native villages." and EPA's FY 1995 Appropriations Act. http://www.epa.gov/owm/mab/owm0177.pdf

Does the program address a specific and existing problem, interest, or need?

Explanation: 1. The EPA Program addresses the water and wastewater needs of rural and Native Alaska communities, many of which lack basic sanitation infrastructure - specifically, flush toilets and running water. In these communities, honeybuckets and pit privies are the sole means of sewage collection and disposal. Residents hand haul water to their homes from watering points. Raw sewage pitched from honeybuckets, uncovered sewage pits, and bunkers filled with human waste pose an immediate threat to the health and environment of village residents. Although considerable progress has been made over the years, approximately one in five homes still lack safe running water and a flush toilet. 2. The objective of the Program is clear: protecting public health. Measuring the Program's progress in fulfilling this objective and associated outcomes are straightforward: percentage of houses served with access to safe drinking water and sanitary wastewater disposal at the home, meeting all regulatory standards. A recent study was jointly conducted by CDC's Arctic Investigation Program and the Alaska Native Tribal Health Consortium to verify and quantify the presumptive public health standards for the Alaska Native Village Infrastructure Program. This study examined the relationship between lower respiratory tract infections, skin infections, gastro-enteric disease, and improved sanitation service in rural Alaska. Partial findings include: Twenty-four percent of the infants in Alaska villages with minimal or no water service are hospitalized for pneumonia. The study examined villages in the Yukon-Kuskokwim Delta in Western Alaska, where more than 2,000 homes in 49 communities lack water and wastewater service. The study also compared low-service regions of the state, where less than 80 percent of the homes have water and wastewater service, with higher-served regions. Low-service regions -- the Kotzebue area, the Norton Sound area and the Yukon-Kuskokwim Delta -- had three times the incidence of pneumonia and influenza and twice the rate of skin infections.

Evidence: 1. EPA's 2003 Drinking Water Infrastructure Needs Survey http://www.epa.gov/safewater/needssurvey/index.html, EPA's 1995 Federal Field Work Group Report to Congress on Alaska Rural Sanitation http://yosemite.epa.gov/r10/enforce.NSF/0/44a0fc978c07004188256e44007457f2/$FILE/ATT0JL6N/AK_RSan.pdf State's Rural Alaska Sanitation Status data and Indian Health Service's Sanitation Deficiency System http://www.dsfc.ihs.gov/documents/SFCAnnualReport2004.pdf Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: It is unclear from the evidence provided how the Alaska Native Villages (ANV) program avoids duplication with USDA-Rural Development, or the Indian Health Service Santiation Facilities Construction Program and the State of Alaska. ANV provides grants for drinking water and wastewater infrastructure projects to improve sanitation conditions in rural areas of Alaska similar to the USDA-Rural Development and Indian Health Services (Dept. of Health and Human Services) programs. USDA "Rural Water and Wastewater Grants and Loans" program provides loans and grants to low-income rural communities of 10,000 or less people. The program finances drinking water, sewer, and solid waste disposal facilities. Priority is given to smaller communities that have greater financial need, based on their median household income, poverty levels, and population. Although the program is collaborating with USDA and the State of Alaska to modify the web based Sanitation Deficiency System (wSDS) to track funding to prevent EPA or the USDA from funding the same project, the Alaska Native Villages program overall is duplicative. No evaluation or analysis has been presented that demonstrates which agency is the most efficient at providing sanitation services to Alaska rural communities.

Evidence: Memorandum of Understanding between EPA, USDA-RD and VSW Draft Memorandum of Understanding between VSW and IHS; Project Scope with the Indian Health Service to develop a common web based needs and tracking system. Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The current design of the program allows the EPA to award funds to the State of Alaska, who then transfers part of those funds (for rural native villages) to the Indian Health Service of the Department of Health and Human Services, who then transfers the funds to an Alaska Native Tribal Health Consortium. The remainder of funds are administered with the State of Alaska to manage projects for non-native rural villages as the lead agency. Based on Inspector General reports that questioned the financial controls and management of funds, EPA completed a Memorandum of Understanding and is developing a database for project tracking. The new database being developed will incorporate all funding for all projects for appropriate effectiveness and efficiency tracking.

Evidence: Audit Report No. 2005-P-00015, Office of Inspector General, EPA Audit Report No. 2004-P-00029, Office of Inspector General, EPA

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: (1) EPA Federal authorization and the State statute relating to the program are very specific as to program beneficiaries and the program's purpose. The beneficiaries are the 191 Alaskan rural and Native villages targeted in 1995 by the State of Alaska for public water and wastewater systems. To ensure all eligible communities receive an equal opportunity to apply for funds and to ensure project funds are targeted to program goals, the program employs a very structured application/prioritization process: 1) annually, applications are sent to every community in Alaska that is eligible, 2) completed applications and questionnaires are returned to VSW, and 3) applications are prioritized using a numerical scoring system. (2) In 2005 a MOU between the State of Alaska Department of Environmental Conservation, USDA Rural Development (USDA-RD) and the U.S. Environmental Protection Agency (EPA) was developed.. The purpose of the MOU is to facilitate the administration of Alaska Native Village Infrastructure Program (Program) with the State of Alaska for sanitation facility projects. The MOU was designed around PART requirements. The MOU identifies the processes and timelines used to administer EPA grant funds. The MOU also incorporates sustainability in Program evaluation of projects by determining the best available technology given the communities' technical, financial and managerial capabilities. The Program agrees to develop a database of infrastructure needs for the program which can be used to measure and track performance outcomes as well as to determine need and future funding levels. This MOU will be incorporated into grant agreements between the State and EPA and USDA as an enforceable term and condition of the grant. Consequently, EPA and USDA will have remedies for breach of the grant agreements under existing grant regulations for breach of the terms of the grant agreements.

Evidence: Section 303 (a) of the Safe Drinking Water Act "SEC. 303. SDWA: GRANTS TO ALASKA TO IMPROVE SANITATION IN RURAL AND NATIVE VILLAGES. (a) In General.--The Administrator of the Environmental Protection Agency may make grants to the State of Alaska for the benefit of rural and Native villages in Alaska to pay the Federal share of the cost of-- (1) the development and construction of public water systems and wastewater systems to improve the health and sanitation conditions in the villages; and (2) training, technical assistance, and educational programs relating to the operation and management of sanitation services in rural and Native villages." Alaska Statute 46 Chapter 7, http://www.legis.state.ak.us/cgi-bin/folioisa.dll/stattx05/query=village+safe+water/doc/{@19745}? VSW Project Prioritization Criteria System, see community application packages http://www.dec.state.ak.us/water/vsw/index.htm http://www.dec.state.ak.us/water/vsw/index.htm provides general information on future construction projects (2) Benefits of 2005 3-Party MOU Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The first specific long-term performance measure is providing serviceable rural Alaska homes with access to drinking water supply and wastewater disposal at the home. The second measure is individual community water systems meeting all regulatory requirements. This measure demonstrates the Program progress in providing drinking water that meets regulatory requirements. The measure is reported on by the Alaska Drinking Water Program as part of their Public Water System Supervisory program. As new regulations are implemented the actuals may drop until the Program can fund, design, and construct new facilities to meet the new regulatory standards. In response to the 2004 PART review and OIG audits, EPA established a special condition in the 2005 grant award, requiring a number of actions to be taken by the State of Alaska to address the programmatic and strategic deficiencies which had been identified. This resulted in the development and execution of a 3-party Memorandum of Understanding between EPA, the State of Alaska and the US Department of Agriculture - Rural Development Program. The stipulations of the new MOU will be incorporated into future EPA grant awards to the State as an enforceable term and condition of the grant agreements. The MOU includes a number of actions, one of which was the establishment of two long term measures for the Program.

Evidence: 3-Party MOU: MOU between the State of Alaska, EPA and United States Department of Agricultural - Rural Development Program, specifically Section III-B, Outcome Measures. Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: (1) By 2011, 100% of serviceable rural Alaska homes will be provided with access to drinking water supply and waste water disposal at the home. (2) By 2011, 100% of the rural Alaska population are served by a public water systems in compliance with the Safe Drinking Water Act. The EPA has adopted ambitious targets and time frames for long-term measures. The targets are ambitious for measure (1) given the challenge in the designing and construction facilities in rural Alaska. Given the extremely short construction seasons, limited transportation in to the rural communities (often one or two barges annually), environmental challenges (frozen ground or warm permafrost) and sustainability challenge all contribute to the ambitiousness for the Program's long term measures. For measure (2), the uncertainty of new drinking water regulations until 2011 and meeting these new regulatory requirements speaks to the ambitiousness of this Program measure. The 2004 PART long-term measure was to provide service to 100% of the remaining homes in rural Alaska which indicates all homes in rural Alaska are serviceable. Not all homes are serviceable because some are seasonal homes, some are not structurally sound for service and some are cost prohibitive to serve. As of 2006 PART goal is to provide service to 100% of all serviceable rural Alaska homes or 94% of all homes in rural Alaska.

Evidence: Letter: Long Term Performance Measures for the ANV Program Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: EPA has established and tracks its annual performance measure: (1) The annual performance measure is the percent of the serviceable rural Alaska homes provided with access to drinking water supply and wastewater disposal at the home. (2) The Program's efficiency measure for the program, as reported in the 2004 PART, is number of homes that receive improved service per $1,000,000 of Program funding. EPA tracks the same performance measure annually in order to demonstrate progress toward achieving long-term goals. Annual housing surveys are completed in March of each year to measure the progress completed during the previous construction period. These are established jointly with the State of Alaska and the US Department of Agriculture - Rural Development Program. They are identified in the MOU between these parties (3-Party MOU), which is incorporated as special grant conditions in future EPA grant awards to the State of Alaska.

Evidence: 3-Party MOU: MOU between the State of Alaska, EPA and United States Department of Agricultural - Rural Development Program, specifically Section III-B, Outcome Measures. Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program have baselines and ambitious targets for its annual measures?

Explanation: Baseline annual measures were established by EPA in 2003: (1) In 2005 the State of Alaska established a baseline of communities eligible for the EPA Alaska Infrastructure program funds. The baseline included the number of homes in each community and the existing service levels. "Service levels" describes the type of community system being used, from a piped system to honey bucket haul. The best available technology (BAT) or the most appropriate level of service for each community was determined based on sustainable annual operating costs and estimated capital construction costs to determine the highest level of sustainable service for each community. The updated 2006 Housing Service Levels for Rural Alaska is provided. The Program's annual measure is to provide the homes in the identified community with water and wastewater service given the BAT for the community at a rate of 3% per year. (2)The Program has adopted ambitious targets for annual performance. These targets are based on a number of factors, including past program performance, available funding for infrastructure development, and efficiency improvements resulting from program changes.

Evidence: (1)2006 Housing Service Levels for Rural Alaska (2)Letter: Long Term Performance Measures for the Alaska Infrastructure Program. Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The ANV program partners with the Indian Health Service and the Alaska Native Tribal Health Consortium to provide santiation construction projects. However, the Indian Health Service has not signed an MOU drafted by the the program on the implementation of the program, including establishing common goals and coordination to achieve these goals. In addition, the program has not submitted evidence that the Alaska Native Tribal Health Consortium has agreed to the draft measures in the MOU including submitting project specific financial and performance reports as specified in Section VI. The program has executed an MOU with EPA, The State of Alaska (grantee, cost-sharing partner, and government partner), United States Department of Agriculture (cost-sharing partner and government partner) on the implementation of the ANV program including establishing program goals. (3) EPA and the State of Alaska are collaborating with the IHS to modify the established web based Sanitation Deficiency System (wSDS) to incorporate, track, fund and report on annual goals for the program. This initiative will result in a common database that contains detailed infrastructure needs and associated costs, and housing inventories of all communities in Alaska. The database will be used by IHS, EPA, USDA-RD and the State of Alaska for jointly establishing their annual funding priorities, and will be used to track joint program performance goals. (4)On a national level, EPA has entered into a multi-agency MOU with respect to a federal strategy to meet the commitments made by the United States under the United Nations Millennium Development Goals for improved access to safe drinking water and basic sanitation in Indian country, including use of a cooperative system to share data and information.

Evidence: (1) 3-Party MOU: MOU between the State of Alaska, EPA and USDA-Rural Development Program (2) 2-Party MOU: Draft MOU between the State of Alaska and the Indian Health Service (3) Project Scope with the Indian Health Service to develop a common web-based needs and tracking system (4) A multi-agency MOU on Providing Access to Safe Drinking Water Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Program does not have an evaluation plan or schedule of program evaluations and program documentation describing the type of evaluation, including scope and quality, and the criteria for selecting an independent evaluator. However, two audits have been conducted by the EPA IG office as well as a single audit performed by the State of Alaska. The program used recommendations in the IG reports and in the audit to make program improvements. (1)As required by EPA grant conditions the Program undergoes an annual single audit, performed by the State of Alaska, Legislative Audit Division. (2)The EPA Program went through an Audit by the Office of Inspector General in 2004 with respect to EPA's oversight the Program, report No. 2004-P-00029. (3) The EPA Program went through an Audit by the Office of Inspector General in 2005 with respect to how the Program awarded the FY04 Program Grant, report No. 2005-P-00015. (4) The EPA program was evaluated as part of the Government Accountability Office report GAO Report GAO-05-719, Alaska Native Villages. The report is dated August 2005. These evaluations have been provided on an as needed basis to provide information to the program to support improvements in effectiveness.

Evidence: (1) Statewide Single Audit - Village Safe Water Program (2) 2004 OIG audit of audit EPA administration of the program, report No. 2004-P-00029. http://www.epa.gov/oig/reports/2004/20040921-2004-P-00029.pdf (2) 2005 OIG audit on EPA award of FY04 grant, report No. 2005-P-00015. http://www.epa.gov/oig/reports/2005/20050616-2005-P-00015-Gcopy.pdf (3) 2005 GAO report on Federal Funding in rural Alaska, report GAO-05-719, reported on all Federal funding in rural Alaska. http://www.gao.gov/new.items/d05719.pdf Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The Agency estimates and budgets for the full annual costs of operating its programs, taking into consideration any changes in funding, policy and legislative chagnes. All spending categories and the resource levels and activities associated with them are included in the annual Congressional Justification. The level of funding requested has been determined by the Agency to be sufficient for continuing our cooperative effort with the Alaska Department of Environmental Conservation (ADEC) to bring basic water and sanitation systems to Alaska Native Villages.

Evidence: President's Budget Proposal for FY2006

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: (1) To address strategic planning and other program deficiencies, EPA established special grant conditions which culminated in the execution of a 3-party MOU between EPA, the State of Alaska, and United States Department of Agriculture (see Explanation for question 2.1). The MOU includes sections which address strategic planning needs, such as Program Measures and Performance and Grant Administration. The MOU was designed to address deficiencies identified in the PART, and its provisions will be incorporated as special conditions in future EPA grant awards. (2)As the result of an EPA onsite review of the State Program in March, 2005, the State of Alaska has developed a draft MOU with the Indian Health Service (IHS) on the implementation of the program, including establishing common goals and coordination to achieve these goals. (3) EPA and the State of Alaska are collaborating with the IHS to modify the established web based Sanitation Deficiency System (wSDS) to incorporate, track, fund and report on annual goals for the program. This initiative will result in a common database that contains detailed infrastructure needs and associated costs, and housing inventories of all communities in Alaska. The database will be used by IHS, EPA, USDA-RD and the State of Alaska for jointly establishing their annual funding priorities, and will be used to track joint program performance goals. (4) A summary of Program changes are identified in the letter titled ANV Program Improvements.

Evidence: (1) 3-Party MOU: MOU between the State of Alaska, EPA and USDA-Rural Development Program, specifically Sections III (Program Measures and Performance), and Section VIII (Grant Administration). (2) 2-Party MOU: MOU between the State of Alaska and the Indian Health Service (3) Project Scope with the Indian Health Service to develop a common web-based needs and tracking system (4) ANV Program Improvements Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: Progress reports provided in evidence do not collect high quality performance data that clearly shows information is used to adjust program priorities, allocate resources, or take other appropriate management actions. Progress reports fail to comment on cause of delays, % of project complete, unexplained expenditures or number of homes to be serviced for each project which ties to the programs performance measures. However, the program is developing a database to be used by federal offices that provide funding for rural water and wastewater programs to collect additional information on project status and funding. However, no evidence is presented that shows how the database is used to improve performance. wSDS (1) EPA and the State of Alaska have collaborated with the IHS to modify the established web based Sanitation Deficiency System (wSDS) to incorporate, track, fund and report on annual goals for the program. This has resulted in a common database structure that will contain detailed infrastructure needs and associated costs, and housing inventories of all communities in Alaska. The database will be used by IHS, EPA, USDA-RD and the State of Alaska to collect some performance information. Currently 60% of the projects funded by the Program are using this reporting system, and the remaining 40% will be using the system in the near future. Performance reports are provided semiannually to the Program but will be available through the web application daily in the near future. Reports have space to comment on the following information, however, all data may not be completed by project officer, limiting its usefulness. ??Project development milestones, including design, construction, and closeout; ??Comparison of current outputs (facilities provided by the project) and outcomes (increased levels of service to homes and essential community buildings) to targeted outputs and outcomes (established in any project work plans included in the federal grant award); ??Reasons for delays, reduced scope, and cost overruns; ??An estimation of the percentage of facilities (outputs) completed; ??Financial information by facility (output), including budgets, expended funds, and remaining funds. ??Information regarding problems, delays, or adverse conditions which will materially impair the ability to meet the objective of the award. Performance reports are used to identify potential project problems and may be used to make adjustments to work plans, designs or construction activities. However, reports do not indicate how causes to problems are identified or corrected, but simply show revised targets for deadlines for project activities. (2) EPA, the State of Alaska, and the United States Department of Agriculture have entered into a three-party MOU on the implementation of the program, including sections to address collection of performance information. This MOU was designed around the PART and was a condition of the FY05 grant to the State of Alaska (see Explanation, question 2.1). This MOU will be incorporated into grant agreements between the State and EPA and USDA as an enforceable term and condition of the grant. (3)As the result of an EPA onsite review of the State of Alaska program the State has developed a draft MOU with Indian Health Service (IHS) on the implementation of the program, including sections to address collection of performance information. However, the program has not submitted project specific financial and performance reports as specified in the draft MOU.

Evidence: (1) Project Scope with the Indian Health Service to develop a common web-based needs and tracking system (2) 3-Party MOU: MOU between the State of Alaska, EPA and USDA-Rural Development Program, specifically Sections III (Program Measures and Performance), and Section VIII (Grant Administration). (3) 2-Party MOU: MOU between the State of Alaska and the Indian Health Service, specifically Section III (Program Administration) and Section VI (Project Administration). (4)Example of Standard Project Progress Report Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: No evidence was provided that grant managers follow established procedures or schedules for evaluating and notifying grantees that performance results were not met in the post award monitoring phase. A letter may be periodically sent out instructing grant managers to prepare an improvement plan for stalled projects or projects with funds remaining, however, there is no indication how grantees are held accountable. There is no indication from progress reports that if performance is evaluated between funding phases, that grantees are held accountable for poor performance, cost overruns or missed schedules before funding is given for the next phase of the project. No grants have been closed out since 1997. Program provided no evidence indicating accountability for this extended schedule or how costs were accounted for by grant. The program does provide performance standards of the top EPA management personnel, such as the Water Programs Director for EPA Region 10, as well as the Grants and Strategic Planning Unit Manager.

Evidence: (1)Letter to OIG dated March 22, 2005 (2) Letter from EPA to the State of Alaska concerning the discontinuation of advancement of funds (3)Letter from EPA to State of Alaska regarding reallocation of project funds (Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: The program has provided no evidence that there are limited unobligated funds at the end of the year. Program did not provide evidence that procedures exist that require timely and appropriate action to correct single audit findings when funds are not spent as intended. The EPA grant to the State of Alaska requires that the Program undergo an annual single audit as required by the Single Audit Act, performed by the State of Alaska, Legislative Audit Division. This audit helps to determine that funds are spent for the intended purpose. (2) As specified in both the 3-Party and 2-Party draft MOU referenced in question 2.8 above, project-specific reports will be provided to EPA on a semi-annual basis. The reports are supposed to include information about the project schedule and how funds have been expended, however these reports do not have all data fields complete. (3) An Onsite review was conducted by the EPA Region 10 Grants Administration Unit in March 2005 however this report did not review all EPA funds and excluded funds transferred to the Indian Health Service and Alaska Native Tribal Health Consortium.

Evidence: (1)Statewide Single Audits - Village Safe Water Program (2)Example of Standard Project Progress Report (3)Design then Construction Funding Process (4)2005 EPA Region 10 Grant Administration Unit Onsite Review Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program does not meet both criteria of having regular procedures in place to achieve efficiencies and cost effectiveness as explained below. The program does meet the criteria of having at least one efficiency measure with baseline and targets. Procedures not in place: The program has provided no evidence that it implements or regularly uses a competitive process or cost comparison for design and construction all sanitation projects that utilize EPA funds to determine the best value. The program has made IT improvements however, the wSDS database is not complete with 40% remaining, and does not currently measure cost effectiveness for all projects funded with EPA dollars. The wSDS database is a collaboration with EPA and the State of Alaska and the IHS to modify the established web based Sanitation Deficiency System (wSDS) to incorporate, track, fund and report on annual goals for the program. This initiative will result in a common database that contains detailed infrastructure needs and associated costs, and housing inventories of all communities in Alaska. The database will be used by IHS, EPA, USDA-RD and the State of Alaska and is anticipated to be complete by October 2006. The program provided no procedures on the post award monitoring of grants in the database to demonstrate evaluation for cost effectiveness. Cost effectiveness is not limited to the program level only. Procurement procedures are not complete, but are scheduled to be finalized and approved by September 15, 2006. However EPA has hired a Procurement Specialist to monitor Federal requirements for competitive sourcing, cost evaluation, and appropriate incentives. The program does have an efficiency measure which is the number of homes that receive improved service per $1,000,000 of State and federal funding. The Program indicates an increased cost effectiveness from 40 homes in 2004 (baseline) to 60 per $1,000,000 invested. The Alaska Native Villages Program is a formula grant program to the state of Alaska. Competitive sourcing is an effort to improve program efficiency by comparing the costs of implementing federal programs using federal employees versus private sector employees. Competitive sourcing would not apply for this grant program.

Evidence: (1) Project Scope with the Indian Health Service to develop a common web-based needs and tracking system (2)Cash Management Improvement Act, Federal Register: http://fms.treas.gov/fedreg/31cfr205final.pdf Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program collaborate and coordinate effectively with related programs?

Explanation: (1) EPA, The State of Alaska, and United States Department of Agriculture have entered into a three-party MOU on the implementation of the ANV program including establishing program goals. This MOU was designed around the PART and was a condition of the FY05 grant to the State of Alaska. This MOU will be incorporated into grant agreements between the State and EPA and USDA as an enforceable term and condition of the grant. (2)As the result of an EPA onsite review of the State Program the State has developed a draft MOU with Indian Health Service (IHS) on the implementation of the program, including establishing common goals and coordination to achieve these goals. This MOU will be finalized by both parties in the near future for execution. (3) EPA and the State of Alaska have collaborated with the IHS to modify the established web based Sanitation Deficiency System (wSDS) to incorporate, track, fund and report on annual goals for the program. This has resulted in a common database structure that will contain detailed infrastructure needs and associated costs, and housing inventories of all communities in Alaska. The database will be used by IHS, EPA, USDA-RD and the State of Alaska to collect some performance information. Currently 60% of the projects funded by the Program are using this reporting system, and the remaining 40% will be using the system in the near future. (4) On a national level, EPA has entered into a multi-agency MOU with respect to a federal strategy to meet the commitments made by the United States under the United Nations Millennium Development Goals for improved access to safe drinking water and basic sanitation in Indian country, including use of a cooperative system to share data and information.

Evidence: (1) 3-Party MOU: MOU between the State of Alaska, EPA and USDA-Rural Development Program (2) 2-Party MOU: Draft MOU between the State of Alaska and the Indian Health Service (3) Project Scope with the Indian Health Service to develop a common web-based needs and tracking system (4) A multi-agency MOU on Providing Access to Safe Drinking Water Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program use strong financial management practices?

Explanation: An Onsite review was conducted by the EPA Region 10 Grants Administration Unit in March 2005. The review did not evaluate EPA funds that are transferred to the Indian Health Service to the Alaska Native Tribal Health Consortium which is approximately 50% of the EPA funds awarded to the State of Alaska. The program provided no evidence that the recipient of these EPA funds for ANTHC, are made properly for their intended purpose, or that these funds meet financial statutory requirements. Because all EPA funds were not evaluated in this most recent review by EPA Region 10, it is not clear that funds are no longer advanced and are in compliance with the Cash Management Improvement Act. The EPA grant requires that the Program undergo an annual single audit, performed by the State of Alaska, Legislative Audit Division. This audit provides recommendations for best financial management practices which are considered by the program. The most recent State of Alaska Single Audit for Fiscal Year ended June 20, 2004 did not identify any material internal control weaknesses. The report does make four recommendations (two repeated from 2003) for corrective action regarding financial management for the program. The program is continuing to work on these issues. The program has taken the following measures to improve financial management practices. As a result of EPA and State audits the State VSW Program established three accounting positions and assumed all project accounting functions in 2005 to improve their financial management practices.

Evidence: (1) Cash Management Improvement Act, Federal Register: http://fms.treas.gov/fedreg/31cfr205final.pdf (2) 2005 EPA Region 10 Grant Administration Unit Onsite Review (3) Statewide Single Audit - Village Safe Water Program Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The Program has made improvements: (1) As the result of EPA and State audits in 2004 - 2005 the State implemented new policies to address issues identified in the Legislative Audit, replaced the Program Manager and moved the position to Anchorage in order to increase program oversight, and hired a contracting specialist to address contracting concerns in the legislative audit. (2) EPA notified the State of Alaska in July 2004 that advancement of funds is not longer authorized. The State was required to come into compliance with the Cash Management Improvement Act. (3) In March 2005 the EPA Region 10 Grants Administration Unit conducted an onsite review of the State's general financial and administration systems used to manage EPA assistance agreements as a result of the OIG audit. Policy and procedures specifically reviewed included accounting, equipment/ property management, payroll, personnel, procurement and travel. EPA funds provided to the IHS and the Alaska Native Tribal Health Consortium were excluded from this analysis. These funds are approximately 50% of the annual funds received by the program. (4) As the result of EPA and State audits in 2005 the State hired three accountants to provide accounting service in-house to address issues identified in the annual single audits. (5)EPA assigned a new Project Officer to the Program in July 2005. The new PO is a civil engineer with 9 year of experience in designing and construction water and wastewater infrastructure in rural Alaska followed by 7 years of experience as a project officer with EPA.

Evidence: (1) ANV Program Improvements (2) Letters detailing actions by the State to address findings of Special Legislative Audit (3) Letter from EPA to the State concerning discontinuation of advancement of funds (4) 2005 EPA Region 10 Grant Administration Unit Onsite Review (5) Letter from EPA to the State concerning compliance with the Cash Management Improvement Act Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The program does not provide a level of oversight that tracks actual expenditures for each grant to verify funds are used for their designated purpose at the project level. Funds that are transferred to the Indian Health Service and to the Alaska Native Health Consortium do not provide a sufficient auditable financial trail to substantiate oversight. However, the program has started the development of a database to help them provide oversight of grantee activities. EPA and the State of Alaska are collaborating with the IHS to modify the established web based Sanitation Deficiency System (wSDS) to incorporate, track, fund and report on annual goals for the program. The database does not specifically address projects that may have been funded in the past by USDA-RD, IHS or EPA to determine if facilities are being funded again prior to the end of expected design life. The IHS projects are removed from the database once funded so it is not clear how the database tracks post award performance for all projects that utilize EPA dollars. The database and corresponding progress reports rely heavily on data provided at the state level and often these fields are left blank or provide inadequate explanation to determine grantee activities at the project level. Currently 60% of the Program funds are using this reporting system the remaining 40% will be using the system in the near future. Because all grant projects are not currently in the system, it is not clear how oversight is provided for these programs. The program has also developed a 3-party Memorandum of Understanding between EPA, the State of Alaska and the US Department of Agriculture - Rural Development Program. Section III of this MOU indicates the State of Alaska will perform data collection and submit a report regarding meeting performance measures. It also states that the federal agencies will review the information to ensure the integrity of collection processes, data quality and progress in meeting perfomance outcomes. The program provided no evidence that federal agencies are providing such a review. The program has indicated the stipulations of the new MOU will be incorporated into future EPA grant awards to the State as an enforceable term and condition of the grant agreements, however, the MOU does not adequately explain the post award monitoring oversight process. In addition, the MOU specifically mentions under Section VIII Grants Administration that the State of Alaska will develop, maintain and update the Village Safe Water Program Procedures Manual which specifically addresses monitoring of grant agreements and conditions. However, this manual was last updated in 2002 and the program has indicated the Manual will be updated as time allows, not before this MOU becomes an enforcing condition for grants awarded. Evidence has not been provided that the elements of this MOU are currently implemented by the program before it was finalized. The MOU with the Indian Health Service and the State of Alaska is currently in draft form and it is not clear if it has been incorporated as a condition of any grants.

Evidence: (1) Project Scope with the Indian Health Service to develop a common web-based needs and tracking system (2) 3-Party MOU: MOU between the State of Alaska, EPA and USDA-Rural Development Program, specifically Sections III (Program Measures and Performance), and Section VIII (Grant Administration). (3) 2-Party MOU: MOU between the State of Alaska and the Indian Health Service, specifically Section III (Program Administration) and Section VI (Project Administration). (4)Example of Standard Project Progress Report Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: Dissagregated grantee performance information is not currently available to the public in the form of progress reports or via the web, however it is collected by the program. Dissagregated performance data is collected in a database that will be available to the public in the near future. The program also collects disaggregated performance data that is compiled in progress reports semi-annually. These reports are not available on the internet for public access or distributed otherwise to the public. The program does collect performance data on a program wide level which is available on the internet for the public via the State's Missions and Measures Website. This site provides the public with information about the Program's established performance targets and measures. General information is provided on the Village Safe Water Program website. (1) The number of serviceable rural Alaska homes provided with access to drinking water supply and wastewater disposal at the home. (2) Individual community water and wastewater systems meeting accepted public health standards and all regulatory requirements.

Evidence: (1) Missions and Measures Website for the Sanitation Facility Construction Program: http://www.gov.state.ak.us/omb/results/view.php?p=43 (2) Missions and Measures Website for the Alaska Drinking Water Program: http://www.gov.state.ak.us/omb/results/view.php?p=42 (3) Village Safe Water Program Information Website: http://www.dec.state.ak.us/water/vsw/pdfs/vswbrief.pdf

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: (1)In 1998, 60% of all rural Alaska homes had access to adequate water and wastewater infrastructure. (2)In 2003, 77% of all rural Alaska homes had access to adequate water and wastewater infrastructure. (3)In 2006, the percentage of Alaska homes with access to adequate water and wastewater infrastructure is anticipated to be 83% of serviceable homes. Not all homes are serviceable because some are seasonal homes, some are structurally unsound and some are cost prohibitive to serve. Approximately 6% of the total homes in rural Alaska fall into this category. (4)Since 2002, the percentage of rural Alaska homes with drinking water that meets all regulatory requirements has remained above 90%, despite several, significant new drinking water rules implemented during this period.

Evidence: (1)Report: Water and Wastewater in Rural Alaska in 2000 (2) Missions and Measures Website for the Sanitation Facility Construction Program: http://www.gov.state.ak.us/omb/results/view.php?p=43 (3) 2006 Housing Service Levels for Rural Alaska Sanitation Systems (4) Missions and Measures Website for the Alaska Drinking Water Program: http://www.gov.state.ak.us/omb/results/view.php?p=42 Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program (including program partners) achieve its annual performance goals?

Explanation: (1)The Program's annual performance goal is to increase the the number of homes served with water service and wastewater service at the home by three percent (3%). (2)The program had seen an increased level of service by 17% in five years from March 1998 through March 2004, which equates to 2.8% annually. From 2004 to 2006 the program has seen an increased level of service of 6% in two years which equates to 3% annually, which equals the program's annual goal.

Evidence: (1) Letter: Long Term Performance Measures for the Alaska Infrastructure Program. (2) Missions and Measures Website for the Sanitation Facility Construction Program: http://www.gov.state.ak.us/omb/results/view.php?p=43 Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: (1)EPA's efficiency measure for the program, as established by the 2004 PART, is number of homes that receives improved service per $1,000,000 of Program funding. The Program can demonstrate an increased cost effectiveness from 40 homes in 2004, to 60 homes in 2005, per $1,000,000 invested. Program does not provide evidence of what was done to achieve savings or what was the amount of annual savings.

Evidence: (1) Efficiency analysis of the 2004 and the 2005 Program grants Evidence is provided at: www.epa.gov/r10earth/tribalwater.htm

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The program has not provided evidence of a comparison or evaluation with other federal programs with similar purposes and goals. It is not clear that the Alaska Native Villages Program is performing favorably when compared to the USDA Rural Development Program or the Indian Health Services Sanitation Facilities Construction Program. The US Department of Agriculture - Rural Development works with the Alaska Native Village Infrastructure Program to provide access to water and wastewater systems in rural Alaska. The US Department of Agriculture - Rural Development Program was reviewed under the Rural Water and Wastewater Grant and Loan Program and received an effective PART rating in 2005.

Evidence: 1. IHS Sanitation Facilities Construction Program - PART Moderately Effective. http://www.whitehouse.gov/omb/expectmore/detail.10000284.2005.html 2. USDA Rural Water and Wastewater Grant and Loan Program - PART Effective http://www.whitehouse.gov/omb/expectmore/detail.10000458.2005.html

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: Two audits have been completed by the IG as well as a single audit by the State of Alaska. The program used recommendations in the IG reports to make program improvements such as identifying better environmental objectives. Program has indicated a study jointly conducted by Arctic Investigation Program of the Centers for Disease Control (CDC) and the Alaska Native Tribal Health Consortium has been completed, however a copy of the report has not been provided as evidence to determine independence, scope as well as effectiveness. It is not clear if this report evaluates the EPA Alaska Native Villages program or includes also the Department of Health and Human Services and USDA Rural Development programs which all contribute to the construction of sanitation services in rural Alaska. In addition, the Alaska Native Tribal Health Consortium is a direct recipient of approximately 50% of grant funds for the ANV program and it is not clear if this report satisfies the requirement for independence. The CDC/Alaska Native Tribal Health Consortium report examines the relationship between lower respiratory tract infections, skin infections, gastro-enteric disease, and improved sanitation service in rural Alaska.

Evidence: EPA IG Audit No. 2004-P-00029 EPA IG Audit No. 2005-P-00015