Audit of the Library of Congress’s Implementation of Contracting Officer’s Representative Best Practices

What Office of Inspector General Evaluated

• Determine COR compliance with applicable regulations and policies in fulfilling COR-related duties.
• Assess COR Working File maintenance in accordance with standards specified by Library of Congress Federal Acquisition Regulation Supplement (LCFARS).
• Verify COR documentation practices and monitoring within working files.

What Office of Inspector General Found

• 7 of 10 Contracting Officer’s Representative (COR) Working Files sampled did not meet compliance standards outlined in Library of Congress Federal Acquisition Regulation Supplement (LCFARS).
• Significant gaps in contract closeout documentation.
• COR Working Files lacked required contractor correspondence documentation and performance data.
• Inconsistent application and understanding of Library COR Working File maintenance standards due to unclear policies and incomplete training.
• Lack of oversight for COR Working Files related to closed contracts valued above $250,000.

What Office of Inspector General Recommends

• Review and update policies and procedures to ensure that the policies and procedures include definitions and examples for required Contracting Officer’s Representative working file documentation
• Review and update policies and procedures to ensure that the policies and procedures are consistent with the Library of Congress Federal Acquisition Regulation Supplement.
• Review, update, and continue implementing the training provided to Contracting Officer’s Representatives to assist them in completing the COR working files.
• Update existing procedures to ensure Contracts and Grants Directorate provides guidance to the Federal Research Division for sampling and reviewing Contracting Officers Representative working files for all contracts, including closed contracts, on a regular basis.