GSA - A150028P4R20009 - 1

1. For all current CM and GC contracts, perform a review and take corrective actions to ensure that:a. Qualified PBS personnel are performing the required review prior to approving government estimates prepared by non-government personnel, estimates are prepared before receipt and independent of proposals, and access to estimates is granted only to government personnel whose official duties require knowledge of the estimates.b. Non-government personnel do not perform inherently governmental functions, such as voting on source selection boards, accepting services on behalf of the government, and conducting negotiations without meaningful involvement, review, and approval from government personnel.c. PBS contracting officers identify, evaluate, and mitigate potential organizational conflicts of interest before contract award and during contract performance. d. Access to competitors’ proprietary information and government data is limited to government personnel whose official duties require knowledge of the information. PBS should conduct a comprehensive assessment to identify:i. Sensitive information, as described in Finding 2, including personally identifiable information and sensitive but unclassified information, which was placed at risk by the failure of the construction manager’s former employee to return general construction contract files. In accordance with the GSA Information Breach Notification Policy, PBS should report the unauthorized disclosure and notify all affected individuals.ii. Companies that have access to competitors’ proprietary information. PBS should obtain copies of agreements between construction managers and other companies to ensure knowledge is protected, and ensure that such agreements are properly executed.e. PBS personnel do not award services prohibited under the GSA’s Professional Engineering Services Schedule.