Evaluation of PBGC’s Contract Type Justifications

Date Issued

Thursday, March 13, 2025

Submitting OIG

Pension Benefit Guaranty Corporation OIG

Agencies Reviewed/Investigated

Pension Benefit Guaranty Corporation

Report Number

EVAL-2025-06

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 5 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
2025-06-01	No	$0	$0
Develop guidance for staff on the requirements of FAR § 16.103(d)(1), including updating templates. The guidance should address all the required elements and specify whether it will be documented in the acquisition plan or another document in the contract file.
2025-06-02	No	$0	$0
Provide training to PBGC staff involved in contracting on the requirements of FAR § 16.103(d)(1), highlighting how the staff are required to document contract type risk considerations in the contract file.
2025-06-03	No	$0	$0
Ensure timely development and approval of contract type D&Fs that address all FAR requirements, including a mechanism to track the timeliness of this process.
2025-06-04	No	$0	$0
Review and update guidance to program office staff to ensure they provide information to support all required FAR elements for contract type D&Fs.
2026-06-05	No	$0	$0
Provide training to procurement and program office staff on additional requirements for contract types other than firm-fixed-price. This training should include guidance as to what is needed for sufficient justifications required to comply with FAR requirements related to maximizing the use of firm-fixed-price on future acquisitions.