What We Did:
The objective of this audit was to determine whether the Washington Headquarters Services and DoD Office of Net Assessment’s (ONA) personnel administered ONA contracts in compliance with applicable Federal and DoD policies.
What We Found:
We found that WHS/AD and ONA acquisition personnel did not administer contracts in accordance with Federal, DoD, and WHS internal regulations and policies. WHS/AD acquisition personnel did not:
• designate contracting officer’s representatives (COR) within 14 days of contract award or after the initial COR was terminated, or retain and execute COR duties in the absence of a COR,
• award contracts and exercise option periods within agreed upon timeframes,
• use required contract modification forms to issue contract modifications,
• coordinate with the ONA to establish surveillance measures in quality assurance surveillance plans,
• conduct adequate annual reviews of COR files, or
• assign a contracting officer with the appropriate security clearance for an ONA contract that required access to classified material.
In addition, ONA acquisition personnel inappropriately performed COR duties without a COR designation letter from the contracting officer for 20 contracts. Further, as identified in a previous DoD OIG review of ONA, WHS/AD and ONA acquisition personnel did not maintain complete contract files, including pre award and contract administration documentation.
This occurred because WHS/AD and ONA acquisition personnel did not execute their responsibilities when awarding and administering contracts. In addition, WHS/AD policy personnel reviewed a limited number of WHS/AD contracting officer files between 2018 and 2020 and did not identify deficiencies, such as untimely COR designations and ONA CORs inappropriately delegating responsibilities.
The lack of adequate contract administration and oversight by WHS/AD and ONA acquisition personnel resulted in WHS/AD and ONA acquisition personnel inappropriately approving invoices for payment in Wide Area Workflow, totaling $9.8 million. In addition, without established and documented surveillance measures for ONA service contracts, ONA may not have received all services outlined in contractor’s statements of work. Further, due to WHS/AD delays in awarding contracts and exercising contract option periods, the ONA was at an increased risk of not executing $4.6 million of its FY 2021 budget.
What We Recommend:
We recommended that the WHS/AD Director and the ONA Director coordinate to update policy that ensures recurring meetings between contracting officers and CORs for all ONA contracts. Furthermore, the WHS/AD Director should review all active ONA contracts to ensure the designation of COR responsibilities. In addition, the Director should provide WHS/AD contracting officer’s refresher training to address deficiencies related to COR appointments, contract surveillance, COR file review requirements and procedures, and proper issuance of contract modifications and direct an Internal Procurement Management Review of ONA contracts to ensure compliance with Federal, DoD, and WHS regulations.
The ONA Director should require that ONA CORs maintain complete record of the contract, including documenting correspondence with the contractor, and implement a process to verify that the CORs completed all requirements outlined in COR designation letters.