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    Subject Term: "Indefinite delivery contracts"

    2 publications with a total of 18 open recommendations
    Director: Marie Mak
    Phone: (202) 512-4841

    15 open recommendations
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense and Housing and Urban Development should take steps--such as clarifying guidance, providing additional training, or issuing reminders to officials--to help ensure that guidance on when to prepare an IGCE is followed.

    Agency: Department of Defense
    Status: Open

    Comments: DOD agreed with the recommendation and stated that it is in the process of developing guidance and training on independent government cost estimates.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense and Housing and Urban Development should take steps--such as clarifying guidance, providing additional training, or issuing reminders to officials--to help ensure that guidance on when to prepare an IGCE is followed.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: HUD agreed with the recommendation. In July 2017, HUD noted that it is writing an acquisition instruction to guide acquisition workforce personnel on when and how to prepare an independent government cost estimate which will address this recommendation. It is also planning training on this issue in the fall of 2017.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretary of Education should consider making Contracts and Acquisitions Management guidance applicable to all agency procurements, and if so, take steps--such as clarifying guidance, providing additional training, or issuing reminders to officials--to help ensure that guidance on when to prepare an IGCE is followed.

    Agency: Department of Education
    Status: Open

    Comments: Education agreed with the recommendation and stated that it will enhance or clarify guidance on independent government cost estimates.
    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Defense and Homeland Security should take steps to ensure that IGCE guidance is followed by, for example, providing training or issuing reminders to officials.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS agreed with the recommendation and stated that it will take steps to determine why guidance on independent government cost estimates is not followed. In July, DHS reported that the Office of the Chief Procurement Officer(OCPO) reached out to the nine DHS contracting activities soliciting feedback on why program officials may not be developing IGCEs in accordance with existing policies. Feedback was received in late May 2017. OCPO is currently evaluating the feedback and identifying consistent themes which will lead to the development of IGCE policy compliance measures.
    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Defense and Homeland Security should take steps to ensure that IGCE guidance is followed by, for example, providing training or issuing reminders to officials.

    Agency: Department of Defense
    Status: Open

    Comments: DOD agreed with the recommendation and stated that it is in the process of developing guidance and training on independent government estimates.
    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency: Department of Education
    Status: Open

    Comments: Education agreed with the recommendation and stated that it will enhance or clarify guidance on independent government cost estimates.
    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: HUD agreed with the recommendation. In July 2017, HUD noted that it is writing an acquisition instruction to guide acquisition workforce personnel on when and how to prepare an independent government cost estimate which will address this recommendation. It is also planning training on this issue in the fall of 2017.
    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS agreed with the recommendation and stated that it will revise guidance on independent government cost estimates.
    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency: Department of Labor
    Status: Open

    Comments: DOL agreed with the recommendation and stated that it will review guidance and training on independent government estimates.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS agreed with the recommendation. In July 2017, DHS reported that the Office of the Chief Procurement Officer (OCPO) disseminated a new draft policy on this issue and solicited feedback from the Component's contracting activities. The Components provided feedback on the draft policy and OCPO is currently adjudicating their comments and will incorporate, as appropriate.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency: Department of Education
    Status: Open

    Comments: Education agreed with the recommendation and stated that it will enhance or clarify guidance on independent government cost estimates.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency: Department of Defense
    Status: Open

    Comments: DOD agreed with the recommendation and stated that it is in the process of developing guidance and training on independent government estimates.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: HUD agreed with the recommendation. In July 2017, HUD noted that it will remind managers to ensure they review price analysis, pre-negotiation and price negotiation memoranda to ensure that differences between the independent government cost estimate and final contract award value are properly documented in the contract file.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS agreed with the recommendation and stated that it will revise guidance on independent government cost estimates.
    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency: Department of Labor
    Status: Open

    Comments: DOL agreed with the recommendation and stated that it will review continue to work with contracting officials to ensure proper documentation and issue a policy on this issue no later than the end of fiscal year 2017.
    Director: Michele Mackin
    Phone: (202) 512-4841

    3 open recommendations
    Recommendation: To improve coordination and communication between FEMA OCPO and region mission support officials region mission support officials, the FEMA Administrator should establish a plan to ensure that the agreement is reviewed on an annual basis as intended.

    Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
    Status: Open

    Comments: In commenting on this report, DHS concurred with this recommendation. According to FEMA officials, the Office of Procurement Operations has since formed a team that will address this recommendation. We will provide updated information as it becomes available.
    Recommendation: To improve coordination and communication between FEMA Office of the Chief Procurement Officer (OCPO) and region mission support officials region mission support officials, the FEMA Administrator should direct OCPO and the regional administrators to revisit the 2011 service level agreement to: add details about the extent of operational control headquarters and regional supervisors should exercise to minimize potential competing interests experienced by regional contracting officers; further detail headquarters and regional supervisors' roles and responsibilities for managing regional contracting officers to improve coordination and communication; and ensure that the agreement reflects any new requirements, including recent changes in training that may require travel funds.

    Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
    Status: Open

    Comments: In commenting on this report, DHS concurred with this recommendation. According to FEMA officials, the Office of Procurement Operations has since formed a team that will address this recommendation. We will provide updated information as it becomes available.
    Recommendation: To address PKEMRA, the Secretary of Homeland Security should take action to address the requirements of Section 692 to implement subcontractor limitations or request that Congress amend the law to delete Section 692.

    Agency: Department of Homeland Security
    Status: Open

    Comments: In 2016, DHS took steps to ask Congress to repeal PKEMRA Section 692, which prohibits the use of subcontracts for more than 65 percent of the cost of cost-reimbursement type contracts that exceed the simplified acquisition threshold. DHS submitted a legislative change proposal to the Office of Management and Budget (OMB), who approves such proposals before they are submitted to Congress. OMB approved the proposed change for PKEMRA Section 692 in April 2016. We will provide additional updates as information becomes available.