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    Results:

    Subject Term: Subcontracts

    7 publications with a total of 19 open recommendations
    Director: Steve Morris
    Phone: (202) 512-3841

    5 open recommendations
    Recommendation: The Administrator of AMS should revise the standard operating procedures for AMS's check-off programs to state that management reviews include a sample of subcontracts for review. (Recommendation 1)

    Agency: Department of Agriculture: Agricultural Marketing Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Administrator of AMS should establish a mechanism for documenting and tracking follow-up with check-off boards on the implementation of management review recommendations. (Recommendation 2)

    Agency: Department of Agriculture: Agricultural Marketing Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Administrator of AMS should ensure that annual independent audits include the five statements of assurance as outlined in the standard operating procedures. (Recommendation 3)

    Agency: Department of Agriculture: Agricultural Marketing Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Administrator of AMS should include in the guidelines and standard operating procedures that key check-off board documents, such as bylaws and policy statements, annual reports, and independent evaluations of economic effectiveness are posted on the check-off programs' websites. (Recommendation 4)

    Agency: Department of Agriculture: Agricultural Marketing Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Administrator of AMS should develop criteria by which to assess the methodology and results of independent evaluations and document those reviews to ensure that the standard operating procedures are met. (Recommendation 5)

    Agency: Department of Agriculture: Agricultural Marketing Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: William Shear
    Phone: (202) 512-8678

    2 open recommendations
    Recommendation: To provide reasonable assurance that DOD's Pilot Mentor-Protege Program meets its mission, the Director, DOD's Office of Small Business Programs, should conduct periodic reviews of the processes DOD components follow to approve agreements and take oversight actions, as appropriate.

    Agency: Department of Defense: Office of Small Business Programs
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To provide reasonable assurance that DOD's Pilot Mentor-Protege Program meets its mission, the Director, DOD's Office of Small Business Programs, should complete actions to develop performance goals and related measures that are consistent with the program's stated purpose.

    Agency: Department of Defense: Office of Small Business Programs
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: David Trimble
    Phone: (202) 512-3841

    2 open recommendations
    Recommendation: To strengthen acquisition planning for M&O contract acquisitions, the Secretary of Energy should direct the Office of Acquisition Management, Office of Policy to require that acquisition planning documents for M&O contracts discuss alternatives beyond extending the M&O contract or conducting a competition for essentially the same scope of work.

    Agency: Department of Energy
    Status: Open

    Comments: In November 2016, DOE officials stated that the Office of Acquisition Management will amend existing or issue new policy or guidance, as appropriate, with an estimated completion date of January 2017.
    Recommendation: To strengthen acquisition planning for M&O contract acquisitions, the Secretary of Energy should direct the Office of Acquisition Management, Office of Policy to establish a process to periodically analyze DOE's experience with alternatives to the single M&O contract approach to identify and apply lessons learned during acquisition planning for M&O contracts.

    Agency: Department of Energy
    Status: Open

    Comments: In November 2016, DOE officials stated that the Office of Acquisition Management will amend existing or issue new policy or guidance, as appropriate, to require programs to periodically analyze their experiences with alternatives. Officials provided an estimated completion date of July 2017.
    Director: William T. Woods
    Phone: (202) 512-4841

    3 open recommendations
    Recommendation: To ensure consistent implementation of the Buy Indian Act procurement authority across the agencies and to enhance oversight of implementation of the Act at regional offices, the Secretaries of the Interior and Health and Human Services should direct the Bureau of Indian Affairs and Indian Health Service respectively, to clarify and codify their policies related to the priority for use of the Buy Indian Act, including whether the Buy Indian Act should be used before other set-aside programs.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: The Department of Health and Human Services (HHS) has made progress towards addressing this recommendation. The Indian Health Service (IHS) is currently working on efforts to revise the Acquisition Management section of the Indian Health Manual to clarify and codify policies related to the priority for use of the Buy Indian Act. IHS plans for the revision to include implementation and reporting mechanisms for contracts awarded under the Buy Indian Act. HHS reported that IHS plans to issue new policy guidance relating to the Buy Indian Act and how it is to be implemented and prioritized in conjunction with other set asides.
    Recommendation: To ensure consistent implementation of the Buy Indian Act procurement authority across the agencies and to enhance oversight of implementation of the Act at regional offices, the Secretaries of the Interior and Health and Human Services should direct the Bureau of Indian Affairs and Indian Health Service respectively, to collect data on regional offices' implementation of key requirements, such as challenges to self-certification.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: Officials at the Department of Health and Human Services' Indian Health Service (IHS) told us they plan to continue oversight to ensure that contractors comply with key requirements such as (1) maintaining the proportion of Indian ownership, (2) not subcontracting more than half the work to other than Indian firms, and (3) providing a preference to Indians in employment, training, and subcontracting. However, as of July 2017, IHS had not provided evidence that they were collecting data on regional offices' implementation of these key requirements. IHS officials told us they plan to incorporate Buy Indian Act policy language and clauses into all contracts and track Buy Indian award actions and obligations. IHS officials also stated they will ensure that the contracting officer authenticates an Indian Economic Enterprise's categorization/credentials, before award and throughout the contract period.
    Recommendation: To ensure consistent implementation of the Buy Indian Act procurement authority across the agencies and to enhance oversight of implementation of the Act at regional offices, the Secretaries of the Interior and Health and Human Services should direct the Bureau of Indian Affairs and Indian Health Service respectively, to include Buy Indian Act contracts as a part of their regular procurement review process.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: Department of Health and Human Services officials told us initial on-site communications to raise awareness of the Buy Indian Act was included in the fiscal year 2017 Indian Health Service (IHS) Procurement Management Reviews (PMR) being conducted at all area offices. Starting in the fall of 2017, IHS plans to develop webinar training sessions to ensure that a large, diverse audience of contracting and management officials have access to the training. IHS will also incorporate the Buy Indian Act Policy into the established annual procurement management reviews beginning in fiscal year 2018 to ensure compliance.
    Director: Michele Mackin
    Phone: (202) 512-4841

    3 open recommendations
    Recommendation: The Administrator of OFPP should take appropriate steps to amend the FAR to include the following requirement: at the time of the contract award, contracting officers shall conduct and document an assessment of the 8(a) firm's ability to comply with the subcontracting limitations.

    Agency: Executive Office of the President: Office of Management and Budget: Office of Federal Procurement Policy
    Status: Open

    Comments: OFPP concurred with our recommendation. We asked for updates on actions taken however as of September 2017 no updates were provided. GAO will continue to monitor OFPP's actions to address this recommendation.
    Recommendation: The Administrator of OFPP should take appropriate steps to amend the FAR to include the following requirement: contracting officers shall include monitoring and oversight provisions in all 8(a) contracts to ensure that the contractors comply with the subcontracting limitations.

    Agency: Executive Office of the President: Office of Management and Budget: Office of Federal Procurement Policy
    Status: Open

    Comments: OFPP concurred with our recommendation. We asked for updates on actions taken however as of September 2017 no updates were provided. GAO will continue to monitor OFPP's actions to address this recommendation.
    Recommendation: The Administrator of OFPP should take appropriate steps to amend the FAR to include the following requirement: prime 8(a) contractors shall periodically report to the contracting officer on the percentage of subcontracted work being performed.

    Agency: Executive Office of the President: Office of Management and Budget: Office of Federal Procurement Policy
    Status: Open

    Comments: OFPP concurred with our recommendation. We asked for updates on actions taken however as of September 2017 no updates were provided. GAO will continue to monitor OFPP's actions to address this recommendation.
    Director: Shear, William B
    Phone: (202)512-4325

    3 open recommendations
    Recommendation: To more fully evaluate the effectiveness of their mentor-protege programs, the OSDBU and Mentor-Protege Program Directors of DHS, DOE, DOS, EPA, FAA, GSA, HHS, SBA, Treasury, and VA should consider collecting and maintaining protege postcompletion information.

    Agency: Department of Health and Human Services: Office of Small and Disadvantaged Business Utilization
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To more fully evaluate the effectiveness of their mentor-protege programs, the OSDBU and Mentor-Protege Program Directors of DHS, DOE, DOS, EPA, FAA, GSA, HHS, SBA, Treasury, and VA should consider collecting and maintaining protege postcompletion information.

    Agency: Environmental Protection Agency: Office of Small and Disadvantaged Business Utilization
    Status: Open

    Comments: Following issuance of the report, EPA established a working group to review mentor-protege policies and procedures and determine the viability and relevance of the program at EPA. The working group recommended that EPA maintain the mentor-protege program and suggested other program improvements. EPA has since suspended implementation of the working group recommendations pending finalization of SBA's revised mentor-protege program guidance. In addition, EPA noted in May 2015 that the agency did not have any mentor-protege agreements in place and thus no need to develop and implement a systemic methodology for tracking program results. EPA added that it anticipates taking steps necessary to implement program tracking in accordance with SBA's revised mentor-protege guidance once it is finalized.
    Recommendation: To more fully evaluate the effectiveness of their mentor-protege programs, the OSDBU and Mentor-Protege Program Directors of DHS, DOE, DOS, EPA, FAA, GSA, HHS, SBA, Treasury, and VA should consider collecting and maintaining protege postcompletion information.

    Agency: Department of Energy: Office of Small and Disadvantaged Business Utilization
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Shear, William B
    Phone: (202)512-4325

    1 open recommendations
    Recommendation: To ensure compliance with federal contracting regulations and to more transparently disclose the extent to which subcontracting opportunities are available to small businesses, the Secretaries of Homeland Security and Defense and the Administrator of General Services should consider asking their respective Inspectors General to conduct a review at an appropriate future date to ensure that this guidance and related requirements are being followed.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS issued a chapter on its small business subcontracting program in its DHS Acquisition Manual in October 2009 and developed a subcontracting plan checklist that officials are to use when awarding a contract. In May 2010, DHS officials stated that these documents were examples of progress they have made to address the recommendation on ensuring compliance with federal contracting regulations and other related requirements. We disagreed with the agency and do not believe that these documents constitute agency guidance on the contract administration duties to monitor contractor compliance with subcontracting plan reporting requirements. In the fall of 2017, we met with DHS officials to discuss the recommendation. Subsequently, in September 2017, DHS emailed a description of the role of the OSDBU in ensuring that: (a) prime contractors report timely on their small business subcontracting accomplishments, and (b) determinations that call for no subcontracting plans are properly vetted. We requested formal documentation of the roles and responsibilities of the OSDBU, as well as evidence of the work performed, in September 2017. The recommendation remains open until DHS provides documentation to support its written description of the OSDBU's efforts to help ensure guidance and related requirements related to subcontracting opportunities for small businesses are being followed.