Audit of Department of State Actions To Prevent Unlawful Trafficking in Persons Practices When Executing Security, Construction, and Facility and Household Services Contracts at Overseas Posts

Submitting OIG:

Department of State OIG

Date Issued:

Tuesday, May 24, 2022

Agency Reviewed / Investigated:

Department of State

Submitting OIG-Specific Report Number:

AUD-MERO-22-28

Component, if applicable:

Bureau of Administration

Bureau of Administration, Office of the Procurement Executive

Foreign Service Institute

Office to Monitor and Combat Trafficking in Persons

Location(s):

Agency-Wide

Germany

Central African Republic

Iraq

Egypt

Peru

Pakistan

Mexico

Japan

Jordan

Sudan

Type of Report:

Audit

Questioned Costs:

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
AUD-MERO-22-28-Web-Posting508.pdf	1.5 MB

Recommendation Number	Recommendation Status	Significant Recommendation
1	Open	No
OIG recommends that the Bureau of Administration update guidance to clearly communicate to Department of State contracting personnel which training courses are approved and available to meet the annual trafficking in persons (TIP) training requirement.
3	Open	No
OIG recommends that the Bureau of Administration update Department of State guidance including the Foreign Affairs Handbook (FAH) and applicable Procurement Information Bulletins (PIB) to clarify that trafficking in persons monitoring, including developing and implementing trafficking in persons (TIP) monitoring strategies, is required for all applicable contracts, not just those that employ third-country national or migrant labor.
4	Open	No
OIG recommends that the Bureau of Administration develop and implement guidance that Contracting Officers (CO) and Contracting Officer’s Representatives (COR) review contractor trafficking in persons compliance plans to determine whether their content meets requirements of Federal Acquisition Regulation (FAR) 52.222-50(h) and to inform required trafficking in persons (TIP) monitoring strategies.
5	Open	Yes
OIG recommends that the Bureau of Administration, in coordination with the Foreign Service Institute (FSI), update Department of State (Department) trafficking in persons (TIP) training to clarify that TIP monitoring is required for all applicable contracts, not just those that employ third-country national or migrant labor.
6	Open	Yes
OIG recommends that the Bureau of Administration, in coordination with the Foreign Service Institute (FSI), update Department of State (Department) trafficking in persons (TIP) training to include discussions of Federal Acquisition Regulation (FAR) 52.222-50(h) requirements for contractors to maintain TIP compliance plans and Department guidance and requirements for reviewing the plans and using them to inform TIP contract monitoring strategies established in accordance with Recommendation 3.
7	Open	No
OIG recommends that the Bureau of Administration instruct Contracting Officers (CO) with oversight responsibility for active contracts in OIG’s nonstatistical subsample, listed in Table A.4, to review contractor trafficking in persons (TIP) compliance plans associated with these contracts and determine whether to apply any of the remedies outlined in Federal Acquisition Regulation (FAR) 52.222-50(e) based on contractors’ failure to adhere to FAR 52.222-50(h) requirements.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

Open

OIG recommends that the Bureau of Administration update guidance to clearly communicate to Department of State contracting personnel which training courses are approved and available to meet the annual trafficking in persons (TIP) training requirement.

Open

OIG recommends that the Bureau of Administration update Department of State guidance including the Foreign Affairs Handbook (FAH) and applicable Procurement Information Bulletins (PIB) to clarify that trafficking in persons monitoring, including developing and implementing trafficking in persons (TIP) monitoring strategies, is required for all applicable contracts, not just those that employ third-country national or migrant labor.

Open

OIG recommends that the Bureau of Administration develop and implement guidance that Contracting Officers (CO) and Contracting Officer’s Representatives (COR) review contractor trafficking in persons compliance plans to determine whether their content meets requirements of Federal Acquisition Regulation (FAR) 52.222-50(h) and to inform required trafficking in persons (TIP) monitoring strategies.

Open

Yes