Report Contents
Report Terms
Report Recommendations
OIG recommends that Bureau of Administration, Office of Logistics Management, Office of Acquisition Management, utilize contractual remedies under contract SAQMMA13D0120 and seek adjustment for any nonconforming fuel included in the $64 million of questioned costs paid from January 2014 to January 2016.
OIG recommends that the Bureau of Near Eastern Affairs require PAE Government Services, Inc., to immediately a) establish and implement a fuel inspection system in accordance with Federal Acquisition Regulation 52.246-2 and b) provide fuel inspection results to contracting officer’s representatives that demonstrate conformance with all fuel quality standards outlined in the Baghdad Life Support Services contract.
OIG recommends that Bureau of Administration, Office of Logistics Management, Office of Acquisition Management, determine whether any additional costs were incurred by the Department for laboratory services that PAE Government Services, Inc. identified in its technical proposal but did not use to ensure the fuel complied with quality control standards, and utilize contractual remedies under contract SAQMMA13D0120 to seek adjustment.
OIG recommends that the Bureau of Administration, Office of Logistics Management, Office of Acquisition Management, modify contract SAQMMA13D0120 to require PAE Government Services, Inc. to test gasoline for octane and provide test results to contracting officer’s representatives prior to transferring fuel from the delivery trucks to the storage tanks at Department of State facilities in Iraq.
OIG recommends that the Bureau of Near Eastern Affairs conduct a study to determine the appropriate numbers of trained, technically experienced, and certified oversight personnel required to oversee the Baghdad Life Support Services and Operations and Maintenance Support Services contracts, to include specific consideration of 2-year assignments, required Federal Acquisition Certification for Contracting Officer's Representatives certification levels, and appointment of additional assistant contracting officer’s representatives.
OIG recommends that the Bureau of Near Eastern Affairs use the results of the study from Recommendation 5 to nominate appropriate personnel so contracting officers with the Bureau of Administration, Office of Logistics Management, Office of Acquisitions Management, can assign qualified oversight personnel for those contracts and task orders.
OIG recommends that the Bureau of Near Eastern Affairs develop and disseminate tools—such as quick reference matrices that identify key fuel quality requirements, equipment maintenance requirements, applicable Federal Acquisition Regulation requirements, and historical concerns or prior nonconformance with contract requirements—to assist contracting officer’s representatives and alternate contracting officer’s representatives with acclimating to the voluminous contract and technical requirements associated with the Baghdad Life Support Services and Operations and Maintenance Support Services contracts and task orders.
OIG recommends that the Bureau of Near Eastern Affairs, in coordination with the contracting officer in the Bureau of Administration, Office of Logistics Management, Office of Acquisitions Management, contractually require PAE Government Services, Inc., to conduct a full inventory of all fuel storage and distribution equipment and machinery that require maintenance, as part of fuel-related task orders under the Operations and Maintenance Support Services contract.
OIG recommends that the Bureau of Near Eastern Affairs, a) in coordination with the contracting officer in the Bureau of Administration, Office of Logistics Management, Office of Acquisitions Management, contractually require PAE Government Services, Inc., to obtain operation and maintenance manuals for all fuel storage and distribution equipment and machinery, to include the manufacturers’ recommended maintenance schedules; and b) include steps for inspecting these requirements in the corresponding quality assurance surveillance plans.
OIG recommends that the Bureau of Near Eastern Affairs review all requirements included in the fuel-related task orders under the Baghdad Life Support Services and Operations and Maintenance Support Services contracts, and develop and implement quality assurance surveillance plans that address key requirements and high–risk areas related to all fuel acquisition and services.
OIG recommends that the Bureau of Near Eastern Affairs develop and implement training for contracting officer’s representatives that emphasizes contractor responsibilities for inspecting goods prior to delivery and focuses on limitations of authority for contracting officer’s representatives to accept nonconforming goods.
OIG recommends that the Bureau of Near Eastern Affairs develop reference guides that summarize contract requirements specific for fuel for the Baghdad Life Support Services and Operations and Maintenance Support Services contracts and provide the guides to all contracting officer’s representatives and alternate contracting officer’s representatives assigned to those contracts.
OIG recommends that the Bureau of Near Eastern Affairs document all instances of contract nonconformance with regard to fuel deliveries in support of the annual review of PAE Government Services, Inc.’s, performance to be recorded in the Contractor Performance Assessment Reporting System.
OIG recommends that the Bureau of Near Eastern Affairs develop and implement a procedure, such as establishing a group email address for all pertinent oversight personnel, to ensure that all contracting officer’s representatives are aware of significant, performance-related correspondence between the contracting officer’s representative, contracting officer, and contractor.
OIG recommends that the Bureau of Near Eastern Affairs update its “Contracting Officer’s Representative (COR) File Audit Plan” to include a requirement for the contracting officer’s representatives for the Baghdad Life Support Services and Operations and Maintenance Support Services contracts to conduct monthly reviews of the contracting officer’s representative files for sufficiency of oversight documents, such as documentation regarding the acceptability of goods and services, site-visit results, and copies of all correspondence and synopses of telephone calls to and from the contractor and contracting officer, to accurately report contractor performance in the Contractor Performance Assessment Reporting System.
OIG recommends that the Bureau of Near Eastern Affairs update its “Contracting Officer’s Representative (COR) File Audit Plan” to include a requirement for departing contracting officer’s representatives to a) certify that contract files are complete in accordance with the Bureau of Administration, Office of the Procurement Executive, Procurement Information Bulletin 2014-10, and b) maintain a copy of the certification in the contract files.
OIG recommends that the Bureau of Near Eastern Affairs, in coordination with its Contract Management Office in Frankfurt, Germany, update its Invoice Review Processes and Procedures standard operating procedure with the requirement for invoice reviewers to verify that domestic fuel prices invoiced by contractors correspond to the domestic fuel prices established by the Oil Products Distribution Company, for all fuel purchased and invoiced in Iraq.
OIG recommends that the Bureau of Administration, Office of Logistics Management, Office of Acquisitions Management, recover the remaining fuel overpayment in the amount of $2,265,095 from PAE Government Services, Inc.