Audit of Time and Material Expenses and Performance Incentive Payments Under the Bureau of Information Resource Management, Vendor Management Office Vanguard Program

OIG recommends that the Bureau of Information Resource Management develop and implement guidelines specific to the Vanguard Information Technology Consolidation Program that adhere to Department policy, including Procurement Information Bulletin 2014-10, regarding outgoing and incoming Contracting Officer's Representative responsibilities during a Contracting Officer's Representative transfer.

OIG recommends that the Bureau of Administration update the Foreign Affairs Handbook to clarify that the Contracting Officer is ultimately responsible for certifying that the Contracting Officer’s Representative is maintaining contract files properly and verifying the status of those files during any transition of Contracting Officer’s Representatives.

OIG recommends that the Bureau of Information Resource Management develop and implement guidelines requiring the Vanguard Information Technology Consolidation Program Contracting Officer's Representatives and government technical monitors to use SharePoint to maintain all supporting documentation for the Vanguard Information Technology Consolidation Program task orders. Guidelines should include, at a minimum, the type and extent of documentation to be maintained, expectations for timeliness, standardized methods for organizing and naming documents, and guidance on the storage of documentation created prior to the existence of SharePoint.

OIG recommends that the Bureau of Information Resource Management develop and implement training for Vanguard Information Technology Consolidation Program Contracting Officer’s Representatives that clearly outlines the requirements for reviewing various types of invoices including the requirement to confirm contractors meet the labor category requirements specified in Vanguard Program task orders.

OIG recommends that the Bureau of Information Resource Management (a) formally analyze the cost and benefits of the performance incentive payment for the Vanguard Information Technology Consolidation Program, including the cost of reviewing hundreds of metrics to determine the amount of the performance incentive payments; (b) implement the findings from the cost and benefits analysis; and (c) revise the Vanguard Information Technology Consolidation Program as needed.

OIG recommends that the Bureau of Information Resource Management develop and implement policies and procedures for Contracting Officer's Representatives and government technical monitors to use to validate the calculation of performance incentive payments performed by the Vanguard Information Technology Consolidation Program contractors. As part of this effort, the Bureau should identify opportunities for automation and standardization that would reduce the manual nature of the current process and the time needed to process performance incentive payments.