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Audit of the DS Oversight of Contractor Performance and Invoice Processing for the Domestic Guard Services Contract

AUD-AFA-26-13
    Report Contents
    Unclassified

    What OIG Audited 

    The Bureau of Diplomatic Security’s (DS) Office of Domestic Facilities Protection (DFP) is responsible for protecting people, information, and property at all domestic Department of State (Department) facilities. Accordingly, DFP is responsible for providing oversight of the domestic guard services contract, which provides a 24-hour guard force to deter unauthorized, illegal, or potentially life-threatening activities directed toward Department employees, visitors, sensitive information, and properties. The Office of Inspector General (OIG) conducted this audit to determine whether DS administered the domestic guard services contract in accordance with applicable federal and Department standards governing the oversight of contractor performance and invoice processing. The scope of the audit was the domestic guard services contract (Contract 19AQMM21C0066) from May 26, 2021, to March 31, 2025. 

    What OIG Found 

    OIG found that DS generally administered the domestic guard services contract (Contract 19AQMM21C0066) in accordance with applicable federal and Department standards governing the oversight of contractor performance and invoice processing. Furthermore, OIG found that DS made a number of improvements to its contract oversight and invoice processing in response to a prior OIG audit published in September 2022, including enhancing documentation related to delegations of authority, establishing and maintaining a (Contracting Officer’s Representative’s (COR) file, and monitoring contract performance. However, OIG identified additional opportunities for improvement. For example, OIG found that the COR file did not include correspondence with the contractor, non-compliant access control tests were not addressed in accordance with the contract, and invoice reviews were not documented. These deficiencies occurred, in part, because DS’ guidance did not include sufficient information related to maintaining correspondence in the COR file, addressing non-compliant access control tests, or performing and documenting invoice reviews. Without sufficient detailed guidance, oversight personnel working on the domestic guard services contract may not fully understand their responsibilities in administering and overseeing the contract, which could lead to management failing to achieve its objectives and respond to risk. In addition, without documentary evidence that DS reviewed invoices before approval, the Department will not have reasonable assurance that it spent federal funds in accordance with contract terms or that the contract recipient performed the required activities. Furthermore, OIG is questioning $6,000 in costs because DS did not deduct $1,000 from invoices for six failed access control tests, as required by the domestic guard services contract.

    What OIG Recommends 

    OIG made four recommendations to address the deficiencies identified with the oversight of contractor performance and invoice processing for the domestic guard services contract, including one recommendation to recover questioned costs. Based on DS’ response to a draft of this report, OIG considers one recommendation closed and three recommendations resolved, pending further action. A synopsis of management’s comments to the recommendations offered and OIG’s replies follow each recommendation in the Audit Results section of this report. DS’ response to a draft of this report is reprinted in its entirety in Appendix B.

    Recommendation Number
    1
    Open Resolved

    OIG recommends that the Bureau of Diplomatic Security modify its Standard Operating Procedures: Contracting Officers Representative, Government Technical Monitor, and Domestic Security Officer to include procedures to ensure that copies of relevant correspondence (including emails) and records of conversations (including phone calls and in-person meetings) with the domestic guard services contractor are included in the Contract Officer’s Representative’s file.

    Recommendation Number
    2
    Open Resolved Significant

    OIG recommends that the Bureau of Diplomatic Security update its Standard Operating Procedures: Contracting Officer’s Representative, Government Technical Monitor, and Domestic Security Officer to formalize a process to address non-compliance identified during access control testing that includes levying invoice deductions as described in the domestic guard services contract. The process should include guidance on documenting the results of actions taken.

    Recommendation Number
    3
    Open Resolved Significant

    OIG recommends that the Bureau of Diplomatic Security revise its Standard Operating Procedures: Contracting Officer’s Representative, Government Technical Monitor, and Domestic Security Officer to detail the specific processes its Contracting Officer’s Representatives should use to perform invoice reviews, including documenting the invoice review in the Contracting Officer’s Representative’s file.

    Recommendation Number
    4
    Open Resolved $6,000

    OIG recommends that the Bureau of Diplomatic Security (1) determine whether the $6,000 in questioned costs related to domestic guard services (Contract 19AQMM21C0066) for six instances of non-compliance identified during access control tests are allowable and (2) recover any costs determined to be unallowable.