Evaluation of the EPA Office of Water's Guidance to State Revolving Fund Programs for Implementing the Build America, Buy America Act Requirements

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Date Issued

Wednesday, February 19, 2025

Submitting OIG

Environmental Protection Agency OIG

Agencies Reviewed/Investigated

Environmental Protection Agency

Report Number

25-E-0016

Report Description

While the EPA Office of Water issued two memorandums on implementing the Build America, Buy America Act requirements, its guidance related to manufactured products, documenting compliance, the consequences for noncompliance, using current waivers, and applying for new waivers was not sufficient. Without additional guidance, state revolving fund program administrators and manufacturers had concerns about complying with the Act's requirements.

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 4 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
Develop and issue guidance that clarifies how to determine whether an item should be classified as a manufactured product and how to determine the cost of manufactured product components. The guidance should include other resources, such as job aids, examples, or flow charts.
2	No	$0	$0
Develop and issue guidance for documenting compliance with the Build America, Buy America Act requirements. The guidance should provide more detail on the potential consequences for noncompliance and include real-world scenarios and other job aids or resources.
3	No	$0	$0
Develop and issue guidance that explains how the adjustment period waiver impacts multiyear projects.
4	No	$0	$0
Develop and issue clarifying guidance on the Build America, Buy America Act waiver request and determination process. The guidance should include job aids.