Lawrence Livermore National Laboratory
Further Improvements Needed to Strengthen Controls Over the Purchase Card Program
Gao ID: GAO-04-986R August 5, 2004
The Lawrence Livermore National Laboratory (LLNL) is a government-owned, contractor-operated national laboratory of the Department of Energy's (DOE) National Nuclear Security Administration (NNSA). The University of California manages the lab under a cost-reimbursable contract with NNSA. During the fall of 2002, the Federal Bureau of Investigation began investigating two Los Alamos National Laboratory employees for alleged misuse of lab credit cards. Other allegations of theft and misuse of government funds at Los Alamos soon followed. In light of the problems identified at Los Alamos, Congress asked us to review selected procurement and property management practices at two DOE and two NNSA contractor labs, including LLNL. This report summarizes the information provided during our June 4, 2004 briefing to Congressional staff on these issues as they relate to Lawrence Livermore. Specifically, we reviewed LLNL's purchase card program and property management practices to determine whether (1) internal controls over the lab's purchase card (Pcard) program provided reasonable assurance that improper purchases would not occur or would be detected in the normal course of business, (2) purchase card expenditures made under the contract properly complied with lab policies and other applicable requirements and were reasonable in nature and amount and thus were allowable costs payable to the contractor under the contract, and (3) property controls over selected asset acquisitions provided reasonable assurance that accountable assets would be properly recorded and tracked. Our review covered selected transactions that occurred during fiscal year 2002 and the first half of fiscal year 2003, which were the most current data available when we requested the data for our review.
LLNL had implemented a number of internal controls over its Pcard program and property management functions. However, weaknesses in LLNL's Pcard program increased the lab's risk of improper purchases. Of the 144 nonstatistically selected transactions obtained through data mining for fiscal year 2002 and the first half of fiscal year 2003, we found 15 (10 percent) totaling $23,923 lacked an invoice, credit receipt, or other sales documentation necessary to validate the dollar amount, quantity, and nature of the items purchased. The lack of such documentation minimizes the effectiveness of supervisory review of Pcard transactions. Additionally, during our review period, the lab allowed supplemental labor personnel--staff that worked at the lab for a labor subcontractor and thus were not LLNL employees--to be issued Pcards, but did not have adequate controls in place to help ensure that the Pcards were returned if supplemental employees stopped working at the lab. Instead, it relied on the subcontractor to perform this function, with no oversight by lab employees. These control weaknesses likely contributed to the $97,348 in improper, wasteful, and questionable purchases we identified in our review. While relatively small compared to the approximately $120 million in purchase card activity that occurred during the review period, it demonstrates vulnerabilities from weak controls that could be exploited to a greater extent. Specifically, 87 of the 144 purchases in the nonstatistical selection we reviewed were for the purchase of controlled items that LLNL's policy requires to be preapproved. Thirty-two of these 87 transactions (37 percent) totaling $31,571 did not have any evidence of preapproval. We also identified two improper split purchases--that is, groups of two or more similar transactions that were split to circumvent single purchase limits--consisting of 11 transactions totaling $28,137 from a statistical sample. Further, we considered 11 transactions totaling $9,945 to be wasteful because they were excessive in cost compared to other available alternatives and/or were of questionable need. We considered 12 transactions totaling $28,220 to be questionable because they were missing key documentation that would enable us or the lab to determine what was purchased, the quantity and cost of the items purchased, and whether the items purchased were proper and reasonable. Because we only tested a small portion of the transactions we identified that appeared to have a higher risk of fraud, waste, or abuse, there may be other improper, wasteful, and questionable purchases in the remaining untested transactions. Accountable assets we tested generally were properly accounted for and tracked in LLNL's property management system. Out of 144 transactions reviewed, there were 6 transactions for the purchase of 26 accountable assets totaling $70,048. Of these 26 assets, one item totaling $3,481 had not been recorded in the property management system. In response to recent internal audit and other reviews, LLNL management has made a number of improvements to its internal controls that, if properly implemented, should further enhance controls over the Pcard program. However, additional corrective actions are needed to address weaknesses identified.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
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GAO-04-986R, Lawrence Livermore National Laboratory: Further Improvements Needed to Strengthen Controls Over the Purchase Card Program
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August 5, 2004:
Congressional Requesters:
Subject: Lawrence Livermore National Laboratory: Further Improvements
Needed to Strengthen Controls Over the Purchase Card Program:
The Lawrence Livermore National Laboratory (LLNL) located in Livermore,
California is a government-owned, contractor-operated national
laboratory of the Department of Energy's (DOE) National Nuclear
Security Administration (NNSA).[Footnote 1] The University of
California manages the lab under a cost-reimbursable contract with
NNSA. The university is paid a management fee to operate the lab and is
reimbursed for all allowable costs charged to the contract.
During the fall of 2002, the Federal Bureau of Investigation began
investigating two Los Alamos National Laboratory employees for alleged
misuse of lab credit cards. Other allegations of theft and misuse of
government funds at Los Alamos soon followed. In light of the problems
identified at Los Alamos, you asked us to review selected procurement
and property management practices at two DOE and two NNSA contractor
labs, including LLNL.[Footnote 2]
This report summarizes the information provided during our June 14,
2004 briefing to your staff on these issues as they relate to Lawrence
Livermore. The enclosed briefing slides highlight the results of our
work and the information provided.[Footnote 3] Specifically, we
reviewed LLNL's purchase card program and property management practices
to determine whether (1) internal controls over the lab's purchase card
(Pcard) program provided reasonable assurance that improper purchases
would not occur or would be detected in the normal course of business,
(2) purchase card expenditures made under the contract properly
complied with lab policies and other applicable requirements and were
reasonable in nature and amount and thus were allowable costs payable
to the contractor under the contract, and (3) property controls over
selected asset acquisitions provided reasonable assurance that
accountable assets would be properly recorded and tracked.[Footnote 4]
Our review covered selected transactions that occurred during fiscal
year 2002 and the first half of fiscal year 2003 (October 1, 2001,
through March 31, 2003), which were the most current data available
when we requested the data for our review. This report also includes
five recommendations for action--four related to actions needed to be
taken by Livermore and one related to action needed to be taken by the
NNSA contracting officer for Livermore.
Results in Brief:
LLNL had implemented a number of internal controls over its Pcard
program and property management functions. However, weaknesses in
LLNL's Pcard program increased the lab's risk of improper purchases.
For example, lab policy did not require approving officials to verify
purchases listed in the cardholder's transaction summary report against
supporting documents, which compromised the effectiveness of the review
process in detecting improper purchases. Of the 144 nonstatistically
selected transactions obtained through data mining[Footnote 5] for
fiscal year 2002 and the first half of fiscal year 2003, we found 15
(10 percent) totaling $23,923 lacked an invoice, credit receipt, or
other sales documentation necessary to validate the dollar amount,
quantity, and nature of the items purchased. The lack of such
documentation minimizes the effectiveness of supervisory review of
Pcard transactions. Additionally, during our review period, the lab
allowed supplemental labor personnel--staff that worked at the lab for
a labor subcontractor and thus were not LLNL employees--to be issued
Pcards, but did not have adequate controls in place to help ensure that
the Pcards were returned if supplemental employees stopped working at
the lab. Instead, it relied on the subcontractor to perform this
function, with no oversight by lab employees.
These control weaknesses likely contributed to the $97,348 in improper,
wasteful, and questionable purchases we identified in our
review.[Footnote 6] While relatively small compared to the
approximately $120 million in purchase card activity that occurred
during the review period, it demonstrates vulnerabilities from weak
controls that could be exploited to a greater extent. Specifically, 87
of the 144 purchases in the nonstatistical selection we reviewed were
for the purchase of controlled items that LLNL's policy requires to be
preapproved. Thirty-two of these 87 transactions (37 percent) totaling
$31,571 did not have any evidence of preapproval. We also identified
two improper split purchases--that is, groups of two or more similar
transactions that were split to circumvent single purchase limits--
consisting of 11 transactions totaling $28,137 from a statistical
sample. Further, we considered 11 transactions totaling $9,945 to be
wasteful because they were excessive in cost compared to other
available alternatives and/or were of questionable need. For example,
one cardholder spent $1,559 for a reclining leather chair. While the
requester had a documented medical need for a special chair due to back
problems, in a similar situation another cardholder purchased an
orthopedic chair from a medical supply store for $599. We considered 12
transactions totaling $28,220 to be questionable because they were
missing key documentation that would enable us or the lab to determine
what was purchased, the quantity and cost of the items purchased, and
whether the items purchased were proper and reasonable. Because we only
tested a small portion of the transactions we identified that appeared
to have a higher risk of fraud, waste, or abuse, there may be other
improper, wasteful, and questionable purchases in the remaining
untested transactions.
Accountable assets we tested generally were properly accounted for and
tracked in LLNL's property management system. Out of 144 transactions
reviewed, there were 6 transactions for the purchase of 26 accountable
assets totaling $70,048. Of these 26 assets, one item totaling $3,481
had not been recorded in the property management system.
In response to recent internal audit and other reviews, LLNL management
has made a number of improvements to its internal controls that, if
properly implemented, should further enhance controls over the Pcard
program. However, additional corrective actions are needed to address
weaknesses identified.
Recommendations for Executive Action:
In order to address the issues identified in our review, we recommend
that the Administrator of NNSA direct Lawrence Livermore National
Laboratory's Director to take the following four actions to strengthen
internal controls over the purchase card program and reduce the lab's
vulnerability to improper, wasteful, and questionable purchases.
* Establish policies and procedures requiring that purchasers request
and maintain a copy of the detailed sales receipt, invoice, or other
independent support showing the description, quantity, and price of
individual items purchased.
* Require approving officials to review transaction documentation
before approving transactions listed on the cardholders' monthly
transaction summary reports. This should include determining that there
is independent support for the description, quantity, and price of
individual items purchased, and that the cardholder obtained and
documented any required preapprovals before purchase.
* Consider modifying the Pcard system so that purchases that are not
reconciled timely by the cardholder are charged to a temporary suspense
account rather than to each cardholder's default account codes.
* In conjunction with the implementation of the lab's online training
and recertification for cardholders and approving officials, include in
such training an emphasis on (1) the lab's policy to obtain
preapprovals for all purchases of items listed on the controlled items
and services list, and (2) consideration of best value in making and
approving purchases. Because the controlled items and services list is
frequently updated, the training should include reviewing the items on
the current list and any recent changes.
We also recommend that the Administrator of NNSA direct the NNSA
contracting officer for the lab to review the improper, wasteful, and
questionable items we identified to determine whether any of these
purchases should be repaid to NNSA.
Agency Comments:
We obtained oral comments on a draft of this briefing from NNSA
officials. They generally agreed with the findings and recommendations,
and indicated that the lab has made a number of improvements to its
controls in light of the problems identified at Los Alamos.
We also obtained oral comments from LLNL officials, who disagreed with
the recommendations to (1) require sales documentation such as a
receipt or invoice and (2) require approving officials to review such
documentation before approving purchases. They indicated sales receipts
and invoices were not always available and did not feel they were
necessary to support purchases. Instead, they felt that as long as the
order amount entered into the Pcard system by the cardholder matched
the total purchase amount charged by the bank, that was sufficient
evidence to support that the purchase was proper.
We disagree. The matching of the total dollar amount of the transaction
to the order amount entered by the cardholder without independent
evidence of the description, quantity, and price of individual items
purchased does not provide sufficient evidence that the items purchased
were proper. Because the cardholder enters the order, makes the
purchase, and reconciles any differences, a reviewer would not be able
to determine if the original order amounts were correct nor whether
additional items were purchased under that order. Consequently,
sufficient independent evidence for the individual items purchased and
corresponding supervisory review of such evidence is necessary to help
reduce the risk of improper purchases.
The lab also provided technical and clarifying comments, which we
incorporated as appropriate.
Scope and Methodology:
To determine if LLNL's internal controls over its Pcard program
provided reasonable assurance that improper purchases would not occur
or would be detected in the normal course of business, we reviewed
LLNL's contract with NNSA and applicable provisions of the DOE
Acquisition Regulation (DEAR) and the Federal Acquisition Regulation
(FAR), performed walkthroughs of key processes, interviewed LLNL and
NNSA management and staff, and compared the results to the lab's
policies and GAO's Standards for Internal Control in the Federal
Government.[Footnote 7] These standards provide the overall framework
for establishing and maintaining internal control and for identifying
and addressing major performance and management challenges and areas at
greatest risk of fraud, waste, abuse, and mismanagement and are based
on internal control guidance for the private sector.[Footnote 8]
To determine whether Pcard expenditures complied with lab policies and
other applicable requirements and were reasonable in nature and amount,
we performed data mining on fiscal year 2002 and the first half of
fiscal year 2003 Pcard transactions to identify indicators of potential
noncompliance with policies and procedures and to identify purchases
that appeared to be from unusual vendors, purchases made on weekends,
during the holidays, or at fiscal-year end, and purchases of attractive
assets. Based on the results, we (1) selected a statistical sample of
27 potential split purchases and tested to determine whether they were
in fact split purchases, and (2) tested a nonstatistical selection of
144 transactions for evidence of supervisory review and approval,
adequacy of supporting documentation, and reasonableness of the
purchases.
To determine if property controls over selected asset acquisitions
provided reasonable assurance that accountable assets would be properly
recorded and tracked, we performed walkthroughs to observe property
controls, reviewed property management policies and procedures, tested
accountable property items selected in the nonstatistical selection to
determine whether these assets had been entered into the lab's property
system prior to our review, performed data mining on the property
database to identify possible database errors or inaccuracies such as
property assigned to terminated employees and multiple property items
with the same serial number, and performed a physical observation of
selected assets to determine whether they could be properly accounted
for.
We requested oral comments on a draft of the enclosed briefing slides
from the Administrator of NNSA or his designee and have included any
comments as appropriate in the letter and enclosed slides. While we
identified some improper, wasteful, and questionable purchases, our
work was not designed to determine the full extent of such purchases.
We conducted our work on all four labs from March 2003 through May 2004
in accordance with generally accepted government auditing standards.
This report is available at no charge on our home page at http://
www.gao.gov. If you have any questions about this report, please
contact me at (202) 512-9508 or Doreen Eng, Assistant Director, at
(206) 287-4858. You may also reach us by e-mail at calboml@gao.gov or
engd@gao.gov. Additional contributors to this assignment were Rick
Kusman, Delores Lee, Kelly Lehr, Diane Morris, Estelle Tsay, and Eric
Wenner.
Linda M. Calbom:
Director, Financial Management and Assurance:
Enclosure:
List of Requesters:
The Honorable Sherwood Boehlert, Chairman:
The Honorable Bart Gordon, Ranking Minority Member:
Committee on Science:
House of Representatives:
The Honorable Joe Barton, Chairman:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Jerry Costello:
The Honorable James Greenwood:
The Honorable Billy Tauzin:
House of Representatives:
Enclosure:
[See PDF for image]
[End of slide presentation]
FOOTNOTES
[1] The National Nuclear Security Administration (NNSA) was created in
fiscal year 2000 as a separately organized agency within DOE. As part
of its national security mission, NNSA has responsibility for the
institutional stewardship of three national security laboratories.
[2] The four labs we reviewed were DOE's Lawrence Berkeley National
Laboratory and Pacific Northwest National Laboratory, and NNSA's
Lawrence Livermore National Laboratory and Sandia National
Laboratories.
[3] Separate briefings were provided for each of the labs reviewed,
which we also summarized in separate letters.
[4] Throughout this document, references to purchases and transactions
refer to those made by the contractor employees of the lab that are
charged to the NNSA contract. Although the lab's purchase cards are
issued by the contractor, purchases charged to the NNSA contract are
ultimately reimbursed and thus paid for by the federal government.
Similarly, property purchased that is charged to NNSA becomes
government property.
[5] Data mining applies a search process to a data set, analyzing for
trends, relationships, and interesting associations. For instance, it
can be used to efficiently query transaction data for characteristics
that may indicate potentially improper activity.
[6] This is the net total after adjusting for one $525 purchase that
was both improper because the cardholder failed to obtain a required
preapproval and wasteful because it was excessive in cost.
[7] U.S. General Accounting Office, Standards for Internal Control in
the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November
1999).
[8] Internal Control--Integrated Framework, Committee of Sponsoring
Organizations of the Treadway Commission (COSO).