Management Assistance Report: Lapse in Oversight at Embassy Islamabad, Pakistan, Allowed Design Change To Proceed Without the Contracting Officer’s Knowledge

OIG recommends that the Bureau of Administration instruct BL Harbert International, LLC, to provide to the contracting officer a detailed written request of all proposed material substitutions that change or alter the final design documents for the construction of staff diplomatic apartments 1, 2, and 3 as part of the New Embassy Compound and Housing construction project in Islamabad, Pakistan, in accordance with the contract terms and conditions prescribed in the contract No. SAQMMA-10-C0284.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, reviews the proposed material substitutions that change or alter the final design documents (as referenced in Recommendation 1) from BL Harbert International, LLC, and, if the proposed material substitution is accepted, follow contract modification procedures to execute the decision in accordance with the Federal Acquisition Regulation with an appropriate adjustment in contract price. If it is determined that the proposed substitution is not in the public interest, then direct BL Harbert to immediately cease its plans to substitute building materials until such time that the Bureau of Administration and Bureau of Overseas Buildings Operations can determine the best course of action that is compliant with contract requirements.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, review the contract oversight activities of the contracting officer, Bureau of Overseas Buildings Operations project directors, contracting officer’s representatives, and alternate contracting officer’s representatives assigned to the New Embassy Compound and Housing construction project in Islamabad, Pakistan, between September 2010 and February 2017 to determine if unauthorized changes or alterations to the final design documents that require the contracting officer’s approval have occurred and to take action to address those found not to be duly authorized.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, a) review the lines of communication between the contracting officer and oversight personnel in Islamabad, Pakistan, including the contracting officer’s representative and his assistant, b) determine whether communication mechanisms are in place and understood by all officials who keep the contracting officer appropriately aware of contractual proceedings related to contract oversight, and c) develop and implement corrective actions to address any deficiencies identified.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, establish and implement internal controls to ensure that the contracting officer for the New Embassy Compound and Housing construction project in Islamabad, Pakistan, designates replacement contracting officer’s representatives for contract oversight prior to the departure of the incumbents.