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Rec. A.7: The DoD OIG recommended that the Commander of the Mission and Installation Contracting Command perform a review of the two contracts for which adequate documentation related to subcontracting amounts was not collected or maintained by contracting personnel and determine whether the small business prime contractors complied with subcontracting limitations. The reviews should include, at a minimum, collecting information related to amounts the prime contractors paid to any subcontractors, including a breakout between materials and other costs, where applicable, and calculating the percentage the prime contractors paid to subcontractors that are not similarly situated based on the total amount paid to the prime contractors by the Government. If the percentages exceed established subcontracting limitations, the Commander should determine whether the small business prime contractors are subject to a penalty, identify the amount of the penalty, and pursue collection. In addition, the Commander should report the non-compliance with subcontracting limitations in the contractors' performance information.
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