Identifying Multi-Program Cases in ICIS
As a reminder, when entering multi-program enforcement cases into ICIS, it is important to correctly identify the actions as multi-program. There are three basic rules which determine whether a case qualifies as multi-program:
a. When a case addresses separate environmental problems under different programs, even if the violations arose from a single event or the same set of facts, it is entitled to multi-program status; if a case addresses a single environmental or regulatory problem and the choice of whether to cite multiple statutes is primarily a tactical one, that case does not count as multi-program.
b. Failure to respond to a multi-statute information request constitutes failure to respond to one reporting requirement and does not quality a case as multi-program.
c. Penalty collection actions and bankruptcy referrals that include a claim under more than one program are not treated as multi-program actions.
This information was also included in the FY 2008 Reporting Plan.
To correctly identify an action in ICIS as multi-program, the Multimedia Action field on the Basic Info Screen in the Enforcement Module must be populated with at least two programs. The Multimedia Action field must be used even when multiple statutes were selected when entering the Law Section Violated data on the Basic Info screen. If this Multimedia Action field is not populated, the action will not be correctly identified or counted as multi-program in any of the ICIS standard reports.
The Multimedia Action field is located on the lower right hand side of the Basic Info screen. To identify multi-program cases in ICIS, select the “Multimedia Actions” button and a drop-down list will appear that provides the acceptable statutes and programs which can comprise a multi-program case.
Submitted: Sara Ager; February