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DoD Task Orders Issued Under One Acquisition Solution for Integrated Services Contracts DODIG-2019-029

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Objective:

We determined whether the contractor employees met labor qualifications and whether the DoD was properly charged for task orders issued under the One Acquisition Solution for Integrated Services (OASIS) contracts. The OASIS contracts provide a full range of service requirements, including program management, management consulting, logistics, engineering, scientific, and financial services.

Background:

The U.S. General Services Administration (GSA) Federal Acquisition Services (FAS) program management office is responsible for awarding, administering, and managing the OASIS base contracts. Since the establishment of OASIS in May 2014, the GSA FAS established seven multiple‑award, indefinite-delivery, indefinite-quantity OASIS base contracts. All Federal agencies, including DoD agencies, can issue task orders under the OASIS base contracts. The OASIS base contracts define labor categories based on standard occupational classifications, as well as years of experience, education, duties, and responsibilities.

From September 2014 to October 2017, DoD contracting officers awarded 540 task orders under the OASIS base contracts with a total estimated ceiling value of $7.1 billion and actual expenditures of $950.5 million. We reviewed 12 task orders with total expenditures of $245.3 million, primarily for program management, engineering, and scientific services issued by the Army, Air Force, and the Defense Advanced Research Projects Agency (DARPA). The Army and DARPA each issued one task order. The Air Force issued the remaining 10 task orders we reviewed.

Findings:

The DoD was properly charged for 1,175 of 1,287 employees who met the labor category requirements for the 12 task orders. However, the DoD was improperly charged for 101 of 112 employees who did not meet the labor category requirements. In addition, the Air Force was unable to provide qualification documentation for 11 of 112 employees. This occurred because the Army, Air Force, and DARPA contracting officers did not validate 1,219 of 1,287 employee qualifications through resume reviews.

Furthermore, the DoD was charged for 41 of 1,175 employees who met the OASIS base contract requirements but did not have relevant education and work experience. This occurred because Army and Air Force contracting officers did not specify in the task order request for proposals that employees needed relevant education and years of work experience to meet the labor category requirements.

As a result, based on our statistical projection, Army, Air Force, and DARPA contracting officers authorized $28 million of potential improper payments for incorrect contract costs. Additionally, contracting officers authorized $574,162 of potential improper payments for employees who did not have qualification documentation. Finally, Army and Air Force contracting officers did not consider any potential impacts on the contracts’ requirements in terms of performance and price before authorizing $6.8 million for employees without relevant education and work experience.

Recommendations:

We make several recommendations to address our findings, including that the Defense Pricing and Contracting Director develop policy related to the qualifications of employees performing work on DoD task orders issued under the OASIS contracts and other applicable indefinite-delivery, indefinite-quantity service contracts.

Additionally, we recommend that the Army Contracting Command–Redstone Arsenal Executive Director; Air Force Life Cycle Management Center Commander; Air Force Research Laboratory Director; and Air Force Test Center Vice Commander require contracting officers to:

  • Determine if the employees met the labor categories specified in task orders and, if not, take appropriate corrective action, including the recovery of improper payments.

 

  • Report all improper payments to the Office of the Under Secretary of Defense (Comptroller), Accounting and Finance Policy Directorate and notify the DoD OIG.

 

We do not make any recommendations to DARPA in this report. The corrective actions taken by DARPA officials are sufficient to reduce the risk of potential improper payments on the DARPA OASIS task order in the future.

Management Comments and Our Response:

The Defense Pricing and Contracting Director agreed with our recommendation to develop guidance for the Military Departments and Defense Agencies. This recommendation is resolved but will remain open. We will close this recommendation when the Director issues guidance to the Military Departments and Defense Agencies that ensures proper verification and documentation of labor categories, education, and work experience of contractor personnel performing work on OASIS and other indefinite-delivery, indefinite-quantity services contracts.

The Director for Management Support, Assistant Secretary of the Army (Acquisition, Logistics and Technology), responding for the Army Contracting Command–Redstone Executive Director, agreed with our recommendation. The Director agreed to determine if the employees meet the labor categories in the task order and report all improper payments. This recommendation is resolved but will remain open. We will close this recommendation when the Director provides the results of the review and the corrective actions taken, and reports any improper payments.

The Principal Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics), responding for the Air Force Life Cycle Management Center Commander, Air Force Research Laboratory Director, and the Air Force Test Center Vice Commander, agreed with our recommendations. The Principal Deputy agreed to pursue recovery of any improper payments and report any improper payments. These recommendations are resolved but will remain open. We will close these recommendations when the Air Force completes the review to determine whether any employees did not meet the qualification requirements and a substitution was not approved; assesses whether the Government received any benefit from the performance received; recovers and reports any improper payments if it did not receive benefit.

This report is a result of Project No. D2018-D000AT-0062.000.