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Followup Audit: U.S. Army Corps of Engineers Use of Cooperative Agreements for Environmental Compliance DODIG-2019-028

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Objective:

We determined whether DoD Components implemented appropriate corrective actions in accordance with recommendations made in Report No. DODIG-2015-174, “U.S. Army Corps of Engineers–Alaska District Needs to Improve Competitive Procedures for Cooperative Agreements for Alaska Integrated Natural Resources Management Plans,” September 16, 2015.

Background:

Report No. DODIG-2015-174 identified that, U.S. Army Corps of Engineers (USACE) Alaska District grants officers did not properly award or effectively use cooperative agreements issued on a sole‑source basis, valued at $18 million, for the development and implementation of integrated natural resources management plans at Joint Base Elmendorf–Richardson (JBER) and Fort Wainwright, Alaska. Integrated natural resources management plans incorporate military mission requirements with natural resources stewardship on DoD installations. Our report determined that these grants officers issued the cooperative agreements or task orders as directed by JBER and Fort Wainwright personnel rather than performing sufficient market research to determine recipients.

Finding:

In this followup audit, we determined that DoD officials implemented corrective actions to address all nine of the prior recommendations. Specifically, the Office of Assistant Secretary of Defense (Energy, Installations, and Environment) issued guidance clarifying implementation of the Sikes Act related to working with Federal and State agencies and awarding task orders competitively if multiple sources are interested in providing support. Additionally, USACE Alaska District personnel completed training related to issuing grants and cooperative agreements, conducted outreach events with universities in an attempt to increase interest in entering cooperative agreements for integrated natural resources management plan support, and developed procedures to increase compliance with DoD Grants and Cooperative Agreements requirements. Also, the 673rd Civil Engineer Squadron and the Fort Wainwright Directorate of Public Works personnel discontinued identifying preferred sources within the documentation provided to USACE Alaska District personnel when requesting assistance to award a task order under a cooperative agreement.

However, DoD Components that were not recipients of previous recommendations continued to include the cooperative agreement number or preferred provider on documentation provided to USACE, but USACE Alaska District grants officers ignored these potential source identifiers and competed the grants when required.

A DoD official stated that he included the cooperative agreement number or preferred source on the funding and requirements documentation because that was how he had submitted the documentation previously and that it was a way to track the process. As a result, DoD officials implemented corrective actions that increased controls over the issuance and management of cooperative agreements used for environmental projects on DoD installations. However, the DoD officials responsible for developing requirements that preserve natural resources continue to identify preferred sources, which could inhibit the competitive process instead of allowing grants officers to determine the most appropriate source and methods for obtaining the required support.

Recommendation:

We recommend that the USACE Commanding General develop instructions and best practices for working with grants personnel, including guidance related to developing requirements that allow for maximum competition that can be provided to other DoD Components that request support from USACE for issuing and administering grants and cooperative agreements.

Management Comments and Our Response:

The USACE Commanding General did not respond to the recommendation. Therefore, the recommendation is unresolved. We request that the Commanding General provide comments on the final report.

This report is a result of Project No. D2017-D000CG-0196.000).