ACF Used Contractor Personnel To Perform Inherently Governmental Functions and Paid Millions in Potentially Unallowable Costs

We recommend that the Administration for Children and Families provide training to program officials and contracting staff as appropriate that covers requirements for:

o administering nonpersonal services contracts for professional support services,
o specifying that contracts must not be used for the performance of inherently governmental functions,
o providing written consent for the use of subcontractors,
o reviewing and approving invoices, and
o maintaining documentation to support costs for services performed

We recommend that the Administration for Children and Families review potentially unallowable costs and obtain supporting documentation or take appropriate action to recoup from Deloitte any improperly paid amounts for the following:

o $2,022,468 for invoices that did not identify CLINs to track expenses,
o $1,362,621 in overtime charges,
o $1,226,649 of labor charges for invoices that did not include specific dates when each employee performed work,
o $244,174 in nonlabor costs that were not supported by receipts, and
o $112,945 of unsupported subcontractor charges

We recommend that the Administration for Children and Families develop and implement policies and procedures:
o requiring contracts to include FAR clauses related to overtime requirements in contracts
o for tracking and verifying that all contractor staff (including subcontractors) assigned to work on a contract complete required trainings before performing any work under the contract (or within the allowed time).