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Appendix A: A Chart for Compliance Screening for Project XL

Appendix A: Chart of Compliance Screening for Project XL

Type of Compliance Screening
Is Any Screen Needed?
Yes, ("High Visibility
recognition events"*)
What is screened?
IDEA run
Contract Debarment list
Regional check
DOJ check
Citizen suit info (from applicant)
Regional update
Criminal update
Who Conducts Screen?
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.
Effect of Findings

(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
Who makes the decision about Effect of Findings?
HQ & Reg.: OR/Regional Office**
HQ & Reg.: Program/Regional Office**

* "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.

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