We recommend that the Regional Administrator for Region 9 direct the contracting officer for EPS90804 to require CORs to document oversight according to regulations and policies, which he agreed to do. We also recommend that the Regional Administrator recover funds for the prohibited clause, as well as determine if the clause is in other contracts and recover funds for those contracts. Finally, we recommend that the Assistant Administrator for Administration and Resources Management enforce the requirement for CORs to ensure contract staff meet the qualifications, and review EPA's practices for paying contractors who perform similar activities. For the latter recommendations, the EPA officials provided alternative corrective action without completion dates or they disagreed. EPA must provide a corrective action plan in its final response.