ML18099A077
| ML18099A077 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/2018 |
| From: | Kristine Svinicki NRC/Chairman, NRC/OCM |
| To: | Rusco F US Government Accountability Office (GAO) |
| Jolicoeur, John, EDO | |
| Shared Package | |
| ML18081A332 | List: |
| References | |
| CORR-18-0043, GAO-18-318, LTR-18-0114 | |
| Download: ML18099A077 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Frank Rusco, Director Natural Resources and Environment U.S. Government Accountability Office 441 G Street, NW Washington, DC 20226
Dear Mr. Rusco:
May 10, 2018 On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am writing to describe the actions taken or planned in response to the recommendations identified in the U.S. Government Accountability Office (GAO) report entitled, "Nuclear Regulatory Commission:
Additional Action Needed to Improve Process for Billing Licensees (GA0-18-318)," published on March 8, 2018.
In the report, the GAO recommended that the Chief Financial Officer (CFO) of the NRC take the following five actions to improve the process for billing of NRC's regulatory user fees:
Formally communicate to all licensees that supplemental billing information-including biweekly reports and monthly status reports on contractor charges is available and how to request it. Formal communication that would reach all licensees could include adding information to their quarterly invoices.
(Recommendation 1)
Develop policy and guidance for staff on what billing information related to contractor charges NRC staff can provide to licensees and how it should be provided. (Recommendation 2)
As the NRC transitions to electronic billing, develop a project plan that incorporates standards for project management, which includes establishing plans for schedule and cost. (Recommendation 3)
In developing the project plan for electronic billing, include steps to involve licensees in developing system capabilities, which includes soliciting and considering licensees' information needs. (Recommendation 4)
In developing the project plan for electronic billing, include steps to assess the results of implementing electronic billing, which includes comparing the actual performance to intended outcomes. (Recommendation 5)
The NRC agrees with the GAO recommendations and is committed to providing our licensees with additional information to facilitate their understanding of NRC billed charges and to the successful transition to electronic billing (e-billing). As GAO has identified, the current NRC financial system used to pay contractors and generate licensee invoices does not capture the level of detail requested by licensees; therefore, the NRC is unable at this time to provide that level of detailed information on the invoice. However, NRC will attempt to leverage contractor status reports, which are typically sent monthly to the technical staff responsible for oversight of the contract work. Since the contractor monthly status reports contain sensitive and proprietary information, the NRC will develop policy and guidance for staff related to releasing certain billing information for contractor charges prior to formally communicating to our licensees that the information is available. This effort will require input from multiple sources (e.g., Office of the General Counsel, Acquisitions Management Division, and Program/Regional Offices).
Internal coordination in the development of the policy and guidance will ensure staff provide consistent information at the appropriate level of detail to all licensees. After developing the policy and guidance, NRC will provide our licensees who receive a quarterly Part-170 (i.e., fee-for-service) invoice with instructions for requesting additional data on billing charges within the timeframe of the October 2018/January 2019 invoice period.
To address the recommendation concerning NRC's efforts to implement e-billing, the NRC has implemented standard practices for project management into our e-billing project plan and activities. A full-time experienced Senior Project Manager (PM) with a proven track record of delivering project outcomes within scope, schedule, and budget has been assigned to the e-billing project. The PM has developed an initial project plan that includes major milestones up to the point of selecting thee-billing tool/platform. The PM will develop a final schedule and budget for the project, and incorporate them into the project plan, after selection of thee-billing tool targeted for award by October 2018. To date, a request for market research information has been completed. The results and the recommendations were provided to the CFO on April 13, 2018. The PM is also developing additional project artifacts (e.g., requirements documentation, risk analysis and mitigation plan) that will be further refined and finalized after the selection of the e-billing tool.
Concerning licensee involvement in the e-billing project, the NRC has initiated outreach to a sampling of licensees to understand their system requirements for an e-billing tool. The Nuclear Energy Institute provided a list of licensees who are willing to assist the NRC in the initial requirements gathering. Additionally, the NRC held a public meeting on March 15, 2018, to discuss the new invoice structure and talk about the agency plans fore-billing. Due to the wide range of licensees that pay fees to the NRC, the agency needs to design a solution that is flexible for the licensee population. The NRC is considering piloting the e-billing solution with a select group of licensees to gather feedback and improve the design prior to the production roll-out of the final product. Additionally, the NRC is considering a phased e-billing implementation based on licensee readiness. The selection of the licensee population for the pilot and phased approach will take place later in project development. The NRC recognizes that frequent communication with the licensees on the progress of this effort is critical to the success of the project. Therefore, the NRC will provide periodic project status updates using a variety of methods, such as periodic written communications, and/or additional meetings, to keep licensees informed of our progress.
Finally, to assess the progress and success of thee-billing project, the NRC will develop metrics as part of the final project plan and documentation. Potential areas for metrics to assess the effectiveness of the e-billing solution include:
Payment timeliness Billing dispute resolution timeliness Licensee participation rates in e-billing The NRC appreciates the opportunity to provide agency actions taken regarding the recommendations in the GAO Report. Should you have any questions, please contact Mr. John R. Jolicoeur, at (301) 415-1642 or via email at John.Jolicoeur@nrc.gov.
cc: Hilary M. Benedict, GAO Wyatt R. Hundrup, GAO Breanna Trexler, GAO Sincerely,
~-,,.,~..... --
Kristine L. Svinicki
Identical letter sent to the following recipients, with the exception of the replacement of the point of contact with the Chairman and the Director of the Office of Congressional Affairs:
Mr. Frank Rusco, Director Natural Resources and Environment U.S. Government Accountability Office 441 G Street, NW Washington, DC 20226 cc: Hilary M. Benedict, GAO Wyatt R. Hundrup, GAO Breanna Trexler, GAO The Honorable Trey Gowdy Chairman, Committee on Oversight and Government Reform United States House of Representatives Washington, DC 20515 cc: Representative Elijah Cummings The Honorable Ron Johnson Chairman, Committee on Homeland Security and Governmental Affairs United States Senate Washington, DC 20510 cc: Senator Claire McCaskill The Honorable John Barrasso Chairman, Committee on Environment and Public Works United States Senate Washington, DC 20510 cc: Senator Thomas R. Carper The Honorable Shelley Moore Capito Chairman, Subcommittee on Clean Air and Nuclear Safety Committee on Environment and Public Works United States Senate Washington, DC 20510 cc: Senator Sheldon Whitehouse The Honorable Greg Walden Chairman, Committee on Energy and Commerce United States House of Representatives Washington, DC 20515 cc: Representative Frank Pallone, Jr.
The Honorable Fred Upton Chairman, Subcommittee on Energy Committee on Energy and Commerce United States House of Representatives Washington, DC 20515 cc: Representative Bobby L. Rush The Honorable John Shimkus Chairman, Subcommittee on Environment Committee on Energy and Commerce United States House of Representatives Washington, DC 20515 cc: Representative Paul Tonko