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Appendix A: A Chart for Compliance Screening for Project XL
Appendix A: Chart of Compliance Screening for Project XL
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recognition events"*) |
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IDEA run Contract Debarment list Criminal Regional check DOJ check Citizen suit info (from applicant) |
Regional update Criminal update |
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HQ lead: OR initiates, by contacting
OC (IDEA run & Agency debarment list); OCEFT (criminal); Regional
contacts (recent Regional activity that may not appear in IDEA, follow-up
on IDEA info) and DOJ (DOJ statutes, info). OR also contacts applicant for citizen suit information. |
HQ lead: OR contacts Regions (Regional
info) and OCEFT (criminal) for updates. Regional lead: Regional Office does Regional update and contacts OCEFT for criminal updates. |
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(What screening findings presumptively bar participation in a program or an award event?) |
Deferral of eligibility: Criminal activity; Planned, pending, ongoing civil action; Current contract debarment. Discretionary factors: Significant non-compliance history; Overall compliance (incl. non-EPA laws) Citizen suits |
Deferral of event: Criminal conviction, or open criminal investigation. Planned, pending, ongoing civil action |
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* "High
visibility" recognition events involve high-level government officials
(including White House and Congressional officials, EPA's Administrator,
Deputy Administrator, Assistant Administrators, General Counsel, Associate
Administrators, and Regional Administrators) and can include ceremonies,
awards, written materials, etc., related to the XL Program, or referencing
a company's successful XL participation.
** OECA
concurrence is needed for departures from the XL screening policy for
a particular project.