Audit of Department of State Administration of Subcontracting Plans for Small Businesses

Date Issued

Thursday, March 20, 2025

Submitting OIG

Department of State OIG

Agencies Reviewed/Investigated

Department of State

Components

Bureau of Administration, Office of the Procurement Executive

Report Number

AUD-CGI-25-16

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

External Link

https://www.stateoig.gov/report/aud-cgi-25-16

Open Recommendations

This report has 8 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
OIG recommends that the Bureau of Administration develop and implement oversight activities to effectively administer subcontracting plans. At a minimum, this should include reviewing administrative actions and communicating policies and procedures to Contracting Officers to comply with the statutory requirements from Federal Acquisition Regulation 19.702 for subcontracting plans.
2	Yes	$0	$0
OIG recommends that the Bureau of Administration, within 6 months of the issuance of this report, issue guidance to Contracting Officers that includes a mechanism for the maintenance of contract files and required documentation if eFiling is not required to be used.
3	No	$0	$0
OIG recommends that the Bureau of Administration, within 6 months of the issuance of this report, develop and implement oversight procedures to confirm that contract actions are properly designated in the Federal Procurement Data System - Next Generation.
4	No	$0	$0
OIG recommends that the Bureau of Administration issue guidance and training to Contracting Officers that includes the proper interpretation of subcontracting plan requirements and exemptions, in accordance with Federal Acquisition Regulation 19.702(b)(1-4) and Department of State Acquisition Regulation 619.000(b).
5	No	$0	$0
OIG recommends that the Bureau of Administration develop and implement a process for achieving the goals, objectives, and timeframes for individual subcontracting report reviews, as prescribed in Federal Acquisition Regulation 19.705-6(f)(1)(2), Department of State Acquisition Manual 619.705-6, and supplemental guidance. At a minimum, this should include identifying and reporting to management contractors that fail to submit required reports.
6	No	$0	$0
OIG recommends that the Bureau of Administration develop and implement standard operating procedures describing the post-award responsibilities of Contracting Officers to comply with Federal Acquisition Regulation 19.705-6. At a minimum, the procedures should include regular reporting from the Small Business Technical Liaison to Contracting Officers and management officials in the Bureau of Administration, Office of Global Acquisitions, Acquisitions Management Directorate.
7	Yes	$0	$0
OIG recommends that the Bureau of Administration develop and implement standard operating procedures describing Contracting Officers' responsibilities to (1) determine contractors' good faith efforts to comply with their small business subcontracting plans and (2) take action to address a contractor's failure to make a good faith effort to comply with the requirements in Federal Acquisition Regulation 19.705-7.
8	No	$0	$0
OIG recommends that the Bureau of Administration develop and implement standard operating procedures describing Contracting Officers' responsibilities to comply with the contractor past performance evaluation requirements in Federal Acquisition Regulation 42.1502. At a minimum, the procedures should include timely and accurate assessments of contractors' small business subcontracting plan performance in the Contracting Performance Assessment Reporting System.