>>> TABLE OF
CONTENTS
Executive Summary......................................................... 1
Results of Review............................................................ 3
Background....................................................................... 6
Objective, Scope, and Methodology................................ 6
Appendix
>>> Executive
Summary
Summary of Results of
Review
>
The Architect of
the Capitol (AOC) has improved the training provided to Contracting Officer’s
Representatives (CORs).
>
The AOC’s process
to maintain a comprehensive database of fire protection system contracts needs
to be improved.
>
The AOC’s fire
protection systems contracting and project completion guidance should be more
inclusive and be applied consistently throughout the organization.
>
The AOC uses
personal service contracts to accomplish some fire systems related tasks.
Report
Recommendation Summary
The
Architect of the Capitol should:
>
Develop a
comprehensive database of contracts/task orders capable of being sorted by
major categories, to account for all contractual actions.
>
Ensure that the
Fire Protection Master Plan is maintained continually to keep track of all
actions related to fire protection throughout the Capitol Complex.
>>> Executive
Summary (Cont’d)
Report Recommendation
Summary (Cont’d)
>
Develop
comprehensive procedures to ensure Statements of Work are developed in a
standard format, with clearly defined projects/tasks, allowing sufficient
timeframes for review and oversight, and designating CORs.
>
Develop
comprehensive standardized contract/task order oversight review procedures that
(1) ensure all responsible parties are afforded sufficient time to review
contractor studies, designs, and drawings; (2) compile, consolidate, and
coordinate comments and deficiencies for all levels of contract/task order
review; and (3) clearly define the parameters needed to monitor contractor
performance.
>
Review and
analyze the existing contracts to determine the extent of the use of personal
service contracts and develop procedures that educate CORs on the proper
methods of supervision and/or oversight that ensure procurement policy is not
violated.
AOC Response
>
The AOC concurred
with the findings and is implementing the recommendations. All corrective actions should be completed by
October 2006.
>>> Results of Review
Condition: The AOC’s process used to maintain a central
repository or database of all contracts, specifically, those related to fire
protection systems, needs to be improved.
Furthermore, the Fire Protection Master Plan has not been kept up to
date.
Criteria: Procurement
Division, Standard Operating Procedure (SOP) 4-3, Contract Log -
Solicitation/Contract/Modification,
establishes a standardized procedure for use of the contract log.
Agreed Upon Action Plans by the AOC:
The
AOC
began using the procurement module on the Financial Management System
(FMS) in January 2005 to track solicitation/contract/order/modification numbers
of all new awards after January 2005 and has added all active contract/task
orders awarded prior to January 2005.
The system can be queried to produce lists of contract numbers, as well
as funding and other discrete fields previously unavailable in the manual contract
log. The AOC is working to automate a
system to track contract and task order deliverables and milestones which is
estimated to be completed in May 2006. The
Fire Protection Engineering Division completed the Fire Safety Improvements
timelines for the House update. These
timelines are currently under AOC internal review with estimated finalization
date of July 2006.
Condition: SOWs did not contain realistic and adequately
defined milestones, timeframes, and adequate periods for both internal and
external review.
Agreed Upon Action Plans by the AOC: The AOC has developed task
order templates for small, medium, and large projects to assist in
standardizing the language of the task orders.
The Procurement Office is developing a program that will assist in
monitoring contractor performance, including tracking milestones and contract
deliverables. In addition, the AOC,
through the Project Management Division, has created monthly reporting for each
project to assess current contract progress versus published contract
milestones and required deliverables.
The AOC is developing comprehensive standardized contract/task order oversight
procedures that (a) ensure all responsible parties are afforded sufficient time
to review contractor studies, designs, and drawings; (b) compile, consolidate,
and coordinate comments and deficiencies for all levels of contract/task order
review; and (c) clearly define the parameters needed to monitor contractor
performance. The estimated completion
date is October 2006.
>>> Results of Review
Finding 3 Unauthorized
Use of Personal Service Contracts
Condition: The AOC administered
six contracts with a combined worth in excess of $1 million which were in
violation of published guidance.
Effect: The AOC received fire protection services in
violation of published guidance and regulations by awarding personal service
contracts in lieu of hiring full time equivalent (FTE) personnel to perform
similar services.
Agreed Upon Action Plans Completed by the
AOC: The AOC issued a personal service contract information letter on
October 31, 2005. This letter describes
the characteristics, inherently governmental functions, and practical actions
for AOC personnel to observe in their interactions with contractors. The AOC is also developing a questionnaire to
be completed by contractor personnel who are working on identified at-risk
contracts. Any responses that give the
appearance of improper interaction between contractor and AOC personnel will be
addressed by the Contracting Officer with appropriate AOC or contractor
personnel. The AOC implemented the
contractor questionnaire in May 2006.
BACKGROUND
The AOC
has embarked on an aggressive improvement plan to enhance the fire protections
systems within the House Complex, Library of Congress (LOC), and Capitol Power Plant
(CPP). Since most of the work to install
new and upgrade existing fire protection systems requires the expertise and
knowledge of fire protection engineering and standards, the AOC has awarded
numerous task-oriented contracts to major fire protection contractors. With the exception of the CPP, all
jurisdictions now employ fire protection engineers on their staff to oversee
internal projects; however, with the magnitude of the work being studied,
designed, and undertaken, additional contractors are employed to provide the
necessary oversight expertise.
SCOPE
Fire
protection systems contracts active as of January 2002 and related contracts
initiated earlier. We selected 14 contracts
for review from a list provided to us by the AOC, and from contracts we had
knowledge of through our fire protection systems oversight role.
OBJECTIVE
Evaluate
the effectiveness of the AOC’s contracting process for fire protection systems
in the
METHODOLOGY
We
conducted this review in accordance with government auditing standards as
implemented in the OIG policies and procedures.
To accomplish our objectives, we interviewed associated personnel and
reviewed AOC documents. Our field work
was conducted during the period May 2004 to March 2005, with follow-up work
conducted in February 2006.
