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The U.S. Navy’s Oversight and Administration of the Base Support Contracts in Bahrain DODIG-2018-074

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Objective

We determined whether the U.S. Navy provided effective oversight of the contracts for base support services in Bahrain. We focused on the U.S. Navy’s oversight of two contracts for base operating support services (BOSS) at Naval Support Activity (NSA)-Bahrain and Isa Air Base (ISA) in Bahrain.

Findings

The U.S. Navy did not provide effective oversight of the base support contracts in Bahrain. Specifically, contracting officer’s representatives (CORs) relied on performance assessment representatives (PARs)—who were foreign national direct hires at NSA-Bahrain and foreign national contractors at ISA—to execute all quality assurance oversight of the contractors. However, the CORs did not ensure the PARs:

  • oversaw all contractual requirements, or
  • possessed the knowledge and experience to oversee their respective annexes.

In addition, the contracted PARs at ISA performed oversight tasks that approached inherently governmental functions. For example, the ISA PARs executed performance assessments on the ISA BOSS contractor and accepted the contractor’s services, without the required oversight from the CORs.

This occurred because Naval Facilities Engineering Command (NAVFAC) and Public Works Department (PWD)-Bahrain did not properly train the NSA-Bahrain and ISA CORs on their contract oversight responsibilities and did not provide CORs or PARs with adequate performance assessment procedures.

As a result, NAVFAC did not have assurance that the $161.5 million the U.S. Navy paid for base support resulted in adequately performed or contractually compliant services and the CORs may not have obtained sufficient evidence to evaluate contractor performance.

NAVFAC also did not effectively administer the NSA-Bahrain and ISA BOSS contracts. Specifically, NAVFAC did not:

  • maintain complete contract files,
  • account for $1.6 million in Government-furnished property provided to ISA contractors, or
  • ensure the NSA-Bahrain and ISA BOSS contractors complied with Combatting Trafficking in Persons (CTIP) requirements.

In addition, NAVFAC and PWD-Bahrain allowed ISA PARs to perform administrative tasks that approached inherently governmental functions.

This occurred because NAVFAC did not properly delegate contract administration responsibilities, and NSA-Bahrain and ISA CORs did not monitor PARs’ performance of contract administration functions.

As a result, NAVFAC did not have adequate evidence to support contractor assessments, which could negatively affect the U.S. Navy’s ability to properly assess and document contractor performance. In addition, there is an increased risk that $1.6 million of U.S. Navy property could be lost, stolen, or unaccounted for. Furthermore, without ensuring compliance with CTIP requirements, BOSS contractors could use trafficked persons in the provision of contracted services without U.S. Navy detection. Finally, by allowing contractors to perform tasks that approached inherently governmental functions, NAVFAC created an environment where the U.S. Navy may not have paid the best value for services. Specifically, for services that were beyond the scope of the firm-fixed price portion of the contract and required a separate task order, NAVFAC allowed the ISA PARs to evaluate whether the BOSS contractor’s prices were reasonable without overseeing the ISA PARs’ evaluations.

Recommendations

To improve the oversight of the NSA-Bahrain and ISA BOSS contracts, we recommend that the Commander, NAVFAC Europe, Africa, Southwest Asia (EURAFSWA), establish a summary of the COR’s contract oversight responsibilities, provide incoming CORs with BOSS contract-specific training on contract oversight responsibilities, and review and monitor COR usage of PARs. We also recommend the Commander, NAVFAC EURAFSWA, coordinate with PWD-Bahrain to tailor the NSA-Bahrain and ISA performance assessment procedures to require review of all contractual requirements, ensure the PARs have access to all applicable assessment criteria, and train the PARs on proper assessment procedures.

To improve administration of the NSA-Bahrain and ISA BOSS contracts, we recommend that the Commander, NAVFAC Atlantic (LANT), coordinate with the Commander, NAVFAC EURAFSWA, to update the NAVFAC delegation procedures. We also recommend the Commander, NAVFAC EURAFSWA, require the Bahrain administrative contracting officer (ACO) to routinely monitor contract files, train CORs on contract file contents, implement a records retention method that ensures contract files are available upon transition in personnel, and assign all required property administration responsibilities to the ACO and COR in Bahrain.

Management Actions Taken

The Chief Contracting Officer (CCO), NAVFAC EURAFSWA, agreed with our contract oversight and administration suggestions and immediately initiated actions to address the issues.

To improve oversight of the Bahrain BOSS contracts, the CCO stated that NAVFAC EURAFSWA:

  • developed a COR responsibilities summary checklist;
  • assigned a facility support contract specialist to PWD-Bahrain who will provide quarterly one-on-one training on oversight processes to all current and future CORs;
  • updated the PWD-Bahrain Readiness Evaluation Assessment requirements, so that they will now be performed on a semi-annual basis, instead of annually; and
  • revised PAR training to emphasize proper completion of performance assessment documentation and provided this newly revised training to the current PARs in October 2017.

To improve administration of the Bahrain BOSS contracts, the CCO coordinated with NAVFAC LANT to implement a revised contract administration process that establishes explicit delegation procedures. The process, which was implemented during the recent award of the NSA-Naples BOSS contract and will be used to delegate responsibilities for the newly awarded NSA-Bahrain BOSS contract, assigns the CORs the primary responsibility for maintaining the files and the ACO responsibility to oversee the contract files for accuracy and completeness. The CCO also confirmed that a standardized COR electronic filing system was implemented as of February 2018.

In addition, NAVFAC included the required CTIP clause in the newly awarded NSA-Bahrain BOSS contract and modified the ISA BOSS contract to include the clause. The Chief Contracting Officer stated that she would coordinate with PWD-Bahrain oversight personnel to update the NSA-Bahrain and ISA performance assessment procedures to ensure that the contract clause is enforced.

The management actions taken addressed the root of the deficiencies we identified pertaining to contract oversight and administration and were fully responsive to our proposed recommendations. Therefore, the recommendations are considered resolved and remain open.

This report is a result of Project No. D2017-D000JB-0149.000.