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Audit of the Administration and Oversight of Contracts and Grants Within the Bureau of African Affairs

AUD-CG-14-31
    Report Contents
    Unclassified
    Recommendation Number
    1
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement procedures to ensure that it complies with the Office of the Procurement Executive's guidance to nominate eligible Federal Acquisition Certification for Contracting Officer's Representative candidates to the contracting officer (CO) for official designation as a contracting officer's representative (COR) and ensure that other COR candidates do not fulfill this role without the CO's concurrence.

    Recommendation Number
    2
    Closed Implemented

    OIG recommends that the Bureau of African Affairs (AF) develop and implement a process to review the Office of the Procurement Executive’s Federal Acquisition Certification for Contracting Officer’s Representatives list on, at a minimum, a bi-annual basis, reconcile the list against contracting officer’s representatives who are currently employed by AF, and request that the Office of the Procurement Executive correct any discrepancies identified.

    Recommendation Number
    3
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement a process to match the reconciled Office of the Procurement Executive's Federal Acquisition Certification for Contracting Officer's Representatives list against planned procurements during the upcoming year and build or maintain a roster of certified contracting officer's representatives to ensure that contracts have continual oversight throughout the lifecycle of the contract.

    Recommendation Number
    4
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement contingency plans that eliminate lapses in oversight by qualified and trained contracting officer's representatives throughout the lifecycle of all contracts.

    Recommendation Number
    5
    Closed Implemented

    OIG recommends that the Bureau of African Affairs discontinue the use of site coordinators in locations that allow Government personnel to work within that country and develop and implement processes to ensure that contracting officer’s representatives and government technical monitors with the appropriate levels of Federal Acquisition Certification for Contracting Officer’s Representatives are officially delegated to conduct oversight of their assigned contracts.

    Recommendation Number
    6
    Closed Implemented Significant

    OIG recommends that the Bureau of Administration, Office of the Procurement Executive, issue guidance on whether the use of site coordinators by the Bureau of African Affairs meets Federal regulations and Department of State guidance for contract administration and oversight.

    Recommendation Number
    7
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop a quality assurance plan template that can be tailored for the unique needs of each contract and develop and implement a policy to ensure that contracting officer's representatives use these plans to perform oversight of contracts.

    Recommendation Number
    8
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop guidance that requires contracting officer’s representatives to perform site visits for each contract recipient at least once during the life of the contract or annually for those recipients identified as high-risk.

    Recommendation Number
    9
    Closed Implemented

    OIG recommends that the Bureau of African Affairs follow the Department's Foreign Affairs Handbook guidance to ensure that each contracting officer's representative documents the findings and results of their site visits and provides this information to the contracting officer.

    Recommendation Number
    10
    Closed Implemented

    OIG recommends that the Bureau of African Affairs issue a memorandum to Embassy Freetown prohibiting the inappropriate use of Government furnished equipment and require contracting officer's representatives to monitor the appropriate use of Government-furnished equipment.

    Recommendation Number
    11
    Closed Implemented Significant

    OIG recommends that the Bureau of African Affairs establish and implement policies and procedures to ensure the completeness, accessibility, retention, and review of contracting officer's representative files in accordance with the Federal Acquisition Regulation and the Foreign Affairs Handbook.

    Recommendation Number
    12
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement a process to ensure that certified and technically qualified candidates are nominated to the Grants Officer for formal designation as a Grants Officer Representative throughout the lifecycles of all grant awards.

    Recommendation Number
    13
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and maintain a list of certified Grants Officer Representative (GOR) candidates that also identifies each candidate's areas of technical expertise, certification appointments, and dates of continued training and that it reviews ongoing grants semiannually to ensure active GORs are administering and overseeing its grants.

    Recommendation Number
    14
    Closed Implemented

    OIG recommends that the Bureau of African Affairs maintain an inventory of its grants and their implementation dates with corresponding Grants Officer Representatives (GOR) and that it develop and implement pre-departure planning activities for its GORs in accordance with the Federal Assistance Policy Handbook.

    Recommendation Number
    15
    Closed Implemented Significant

    OIG recommends that the Bureau of Administration, Office of the Procurement Executive, conduct a management review of grants administered by the Bureau of African Affairs (AF) in accordance with Grants Policy Directive 34, "Grants Management Reviews," and that it provide training as necessary to AF's administrative and oversight personnel.

    Recommendation Number
    16
    Closed Implemented

    OIG recommends that the Bureau of African Affairs utilize Grants Policy Directive 28, "Roles and Responsibilities for the Award and Administration of Federal Assistance," and the Standard Terms and Conditions for Domestic and Overseas Federal Assistance Awards to develop and implement standard operating procedures that document responsibilities of the Grants Officer Representative for monitoring the terms and conditions of all grant awards, including promptly notifying the Grants Officer (GO) of all changes that require the GO's attention.

    Recommendation Number
    17
    Closed Implemented Significant

    OIG recommends that the Bureau of African Affairs develop and implement procedures to ensure that all future Notices of Award include appropriate performance indicators and require that grantees provide performance reports that measure program achievements in comparison to performance indicators and program objectives.

    Recommendation Number
    18
    Closed Implemented

    OIG recommends that the Bureau of African Affairs (AF) develop a monitoring plan template that is consistent with the requirements detailed in Grants Policy Directive 42, "Monitoring Assistance Awards," and that it develop and implement a process to ensure that monitoring plans are utilized to meet the AF's oversight needs for all future grant awards.

    Recommendation Number
    19
    Closed Implemented Significant

    OIG recommends that the Bureau of African Affairs (AF) develop and implement a process to ensure that, if grant recipients do not submit timely quarterly, annual, and final performance and financial reports, Grants Officer Representatives will implement remedies as required by the Foreign Affairs Handbook, the Federal Assistance Policy Handbook, and AF's grant agreements.

    Recommendation Number
    20
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement a process to ensure that the requirements in Grants Policy Directive 16, "Designation of Grants Officer Representative," for the Grants Officer Representatives to review, analyze, and provide written assessment of the required recipient Program Progress and Financial Status Reports are implemented.

    Recommendation Number
    21
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement a process to ensure that guidance provided in Grants Policy Directive (GPD) 16, "Designation of Grants Officer Representative," and GPD 42, "Monitoring Assistance Awards," is implemented and require Grants Officer Representatives to perform and document site visits for each grant recipient commensurate with the complexity and value of the grant.

    Recommendation Number
    22
    Closed Implemented

    OIG recommends that the Bureau of African Affairs develop and implement a risk identification and management strategy that is incorporated into policy and provide training to its Federal assistance oversight personnel on how to properly implement this strategy.

    Recommendation Number
    23
    Closed Implemented

    OIG recommends that the Bureau of African Affairs establish and maintain a grants monitoring strategy that adopts a risk-management approach and provide training to its Federal assistance oversight personnel on how to properly implement this strategy.

    Recommendation Number
    24
    Closed Implemented

    OIG recommends that Bureau of African Affairs Grants Officer Representatives (GOR) assess the risk of ongoing grants and identify and re-classify high-risk grant recipients. For each high-risk recipient, GORs should develop a risk mitigation strategy that includes changes to oversight and a corrective action plan.

    Recommendation Number
    25
    Closed Implemented $159,180

    On November 21, 2013, OIG recommended that the GO terminate the grant because the grant recipient did not follow Federal and Department guidance and did not have the capacity to execute the grant. Because action was taken and completed during the course of the audit, no formal recommendation was made in this report. However, OIG is inputting the results for management information purposes. Excerpt from AUD-CG-14-31, page 33 "As a result of our site visit related to Grant No. S-LMAQM-12-GR-1217, on November 21, 2013, we recommended that the CO terminate the grant because the grant recipient did not follow Federal and Department guidance and did not have the capacity to execute the grant. On December 3, 2013, the CO terminated the grant, which saved AF $159,180 in funds that could be put to better use."