Audit of Noncompetitive Contracts in Support of Overseas Contingency Operations in Afghanistan and Iraq

OIG recommends that the Bureau of Administration develop and implement additional internal control procedures for monitoring to ensure that justifications and approvals for other than full and open competition are completed and approved in accordance with Federal Acquisition Regulation requirements and Office of the Procurement Executive guidance and that reviewing officials verify that the justifications include all required content.

OIG recommends that the Bureau of Administration (a) determine the feasibility, practicality, and cost-effectiveness of adding functions to the new online application being developed for justifications and approvals that will automatically transfer completed justifications to the electronic contract file and also post the justifications publicly in accordance with the Competition in Contracting Act and the Federal Acquisition Regulation and (b) if determined to be feasible, practical, and cost-effective, incorporate such a function in the application.

OIG recommends that the Bureau of Administration issue a directive to the Office of Acquisitions Management to update its Quality Assurance Plan to expand the steps necessary to ensure compliance with Federal Acquisition Regulation provisions regarding preparing fair and reasonable price determinations for noncompetitive awards. The steps should include requiring that Contracting Officers use the sample template for price negotiation memoranda and retain evidence of the analysis conducted in support of such determinations in the contract files.

OIG recommends that the Bureau of Administration issue a directive to the Office of Acquisitions Management to update its Memorandum 15-09, Contract File Documentation, regarding price negotiation memoranda. The updated memorandum should include instructions for Contracting Officers to verify that all price negotiation memoranda packages are properly approved and placed in the contract file.