Division of Compliance Management, Office of Surface Mining, Washington, DC

Project Point of Contact

Mike Mills


The Division of Compliance Management is responsible for ensuring compliance with the reclamation fee requirements of the Surface Mining Control and Reclamation Act. It accomplishes this mission by conducting audits of coal companies nationwide. Employees are strategically located throughout the United States to minimize travel costs and the majority of the auditors now work from their home. An average of 150 audits is completed each year. Prior to the in-house development of WOW, this work required a staff of over sixty the same amount of work is now accomplished with a staff of thirty-four.


The conversion of Workpapers on Windows (WOW) to Paperless on Windows (POW) created a totally paperless audit environment which is now used for all audits and applied to many other ancillary work products in DCM. It is noteworthy that both of these automated programs were conceived and developed in their entirety by in-house staff. Setup as a small Division within a small Bureau, these innovative employees were accustomed to developing strategies in-house to take advantage of technology. They had been primarily responsible for taking the specialized reclamation fee compliance audits from an archaic green ledger sheets and red pencils setting through an evolutionary process to Workpapers on Windows, the integrated, automated process used by the Division which was internally developed from off- the- shelf Microsoft products. While many in the room voiced numerous reasons why paperless would never work for OSM audits, you could see the excitement in the faces of a few employees as they considered the possibilities for the auditing program. This small group of auditors requested permission to explore the possibilities of reducing some of the paper flow each audit created, from the initial selection of the audit until the audit was reviewed and the final report prepared. Because of their proven track record and management s willingness to let employees think outside of the box (an often difficult undertaking for the rigorous mindset of an auditor), the journey of DCM s paperless audit was begun. The journey is still evolving as new paths are explored. However, DCM auditors now function in a completely paperless environment using Paperless on Windows (POW), an integrated, automated audit process developed internally from off- the- shelf Microsoft products combined with Adobe. Paperless was initially touted as a way to save trees and reduce storage and filing space. The environmental impact, advantages and cost savings go far beyond what was originally envisioned.

Results and Achievements

  • The use of paper and toner cartridges has decreased dramatically, now paper use has diminished to an average of one ream per auditor per year.

  • Government Auditing Standards require each audit be thoroughly reviewed. Paper audits were frequently mailed. Previously, each audit was printed, express mailed for review, returned by express mail for revision, forwarded by express mail to the manager for report issuance, and finally mailed to the operator and another division within OSM to begin the billing process. The expense of this mailing has now been eliminated, because all audit files and documentation are now electronically transmitted. The carbon footprint of the Fed Ex truck making the numerous deliveries has been eliminated.

  • The need for clerical support has been reduced because of the elimination of handling paper. DCM has identified two thirds of the clerical positions for restructuring through attrition.

  • Sister Divisions within OSM have revamped some operations to work in tandem with the paperless initiative.

  • The Division of Financial Management (DFM), responsible for audit billing, now receives audit results electronically. Previously, the audit results were scheduled on paper, mailed, and then entered manually into the billing data system upon receipt days later. Eventually, this should also reduce the number of contractors required for input of billing documents as the need to manually enter data is now automated.

  • The Applicant Violator System (AVS) now electronically sends each new permit or permit revision to DCM for a weekly review; DCM reviews are performed without paper and the data and supporting documentation transferred electronically to DFM for action, eliminating the requirement for paper and weekly Fed Ex costs.

  • POW has expedited the entire audit process. Auditors can immediately receive supervisory assistance on specific working papers, regardless of their physical location, because they send the item in question electronically, have it quickly reviewed, and their questions answered by email or telephone.

  • POW has enhanced DCM's telework effort. The majority of auditors work from their home, eliminating the daily commute and its associated environmental costs. Going paperless has eliminated the need for expensive laser printers and telecommuters are able to function with an inexpensive all-in-one multifunction machine.

  • DCM has closed seven offices and is in the process of closing an additional office as the need to store hard copy files is eliminated.


POW has high potential to be replicated in audit functions throughout the Department. It has particular applicability for the Department s newly proposed Hard Rock Mining fee collection initiative, and the ensuing audit responsibility. POW is especially innovative in both its design and approach. It is the result of the synergy of employees familiar with the specific workgroup needs, using materials (software and equipment) readily available, to design a process which is green, highly functional and highly efficient.