Architect of the Capitol:

Contracting Function Generally Follows Key Practices, but Certain Improvements Are Needed

GAO-16-348: Published: Apr 7, 2016. Publicly Released: Apr 7, 2016.

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William T. Woods
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What GAO Found

The Architect of the Capitol (AOC) recently implemented a contracting manual that centralizes current law and regulations applicable to the AOC, as well as policies, orders and procedures. As a legislative branch agency, the AOC is not subject to the Federal Acquisition Regulation (FAR) which governs executive branch agencies; however, its manual draws on the FAR and covers topics central to the AOC's day-to-day contracting functions, such as acquisition planning, market research, and competition, all of which are key aspects of a sound acquisition process. In the 21 contracts and task orders GAO reviewed, AOC officials generally followed the policies in the contracting manual related to these critical functions—such as documenting justifications for the use of noncompetitive procedures.

The AOC began to collect competition data in fiscal year 2012, but the agency only conducts a limited assessment of its efforts to achieve competition. The AOC manual states it is agency policy to promote competition, and federal internal control standards state that agencies should establish mechanisms to track and assess performance against their objectives. While the AOC monitors data to track the number of sole-source contracts awarded, other analyses are limited. GAO's analysis of the AOC's data found that the agency competed approximately 50 percent of its contract obligations for the past 3 fiscal years—compared to 65 percent for the overall federal government. By examining the factors driving the number of sole-source awards or level of competition across different product types, AOC may be better positioned to identify where additional management attention may be needed to maximize competition.

The AOC uses a variety of approaches to monitor contractor performance on its projects, with contracting officers and their technical representatives being the primary officials responsible for providing oversight. The AOC uses a number of methods to address contractor performance problems, as shown in the figure below.

Architect of the Capitol Approaches to Monitor and Address Contractor Performance

Architect of the Capitol Approaches to Monitor and Address Contractor Performance

While the AOC has tools for addressing poor performance on specific contracts, it does not have a suspension and debarment process in place that could bar irresponsible contractors from working for the AOC or provide notice to other government agencies. Past GAO work has shown that having suspension and debarment procedures is critical to ensuring that the government only does business with responsible contractors.

Why GAO Did This Study

The AOC is responsible for the maintenance, operation, and preservation of the buildings and grounds of the U.S. Capitol complex, which covers more than 17.4 million square feet in buildings and 587 acres of grounds. In fiscal year 2015, Congress appropriated $600.3 million to fund AOC's operations, over half of which was used to procure various goods and services ranging from large projects like the restoration of the Capitol Dome, to routine custodial services.

GAO was asked to review the AOC's contracting practices. This report examines (1) the extent to which the AOC has developed and implemented acquisition policies and processes to guide its contracting function, and (2) the tools used by the AOC to monitor and address contractor performance. GAO reviewed the AOC's acquisition policies, interviewed contracting officials, and reviewed a non-generalizable sample of 21 contracts and task or delivery orders with dollars obligated in fiscal years 2013 through 2015. The sample consists of a mix of high-value contracts for goods and services.

What GAO Recommends

GAO recommends that AOC explore options for developing a more robust analysis of its competition levels and establish a suspension and debarment process suitable to its mission and structure. AOC agreed with GAO's findings and concurred with the two recommendations and noted it is taking steps to implement them.

For more information, contact William T. Woods at (202) 512-4841 or

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In June 2017, the Architect of the Capitol (AOC) took steps to enhance its oversight of competition levels. Using data from its performance metrics database, AOC has begun to provide bimonthly reports to its senior leadership on metrics such as the number of awards competed. By the end of 2017, AOC expects to have sufficient data to begin tracking trends to identify areas of concern that need further monitoring or corrective action.

    Recommendation: To further enhance the acquisition function, the Architect of the Capitol should explore options for developing a more robust analysis of AOC's competition levels, including areas such as the trends in competition over time, the use of market research to enhance competition, and the types of goods and services for which competition could be increased.

    Agency Affected: Architect of the Capitol

  2. Status: Closed - Implemented

    Comments: In June 2016, the Architect of the Capitol established a suspension and debarment program including its policies and procedures regarding the suspension, debarment, and ineligibility of government contractors to receive Architect of the Capitol contracts.

    Recommendation: To further enhance the acquisition function, the Architect of the Capitol should establish a process for suspensions and debarments that is suitable for the AOC's mission and organizational structure, focusing on policies, staff responsibilities, and a referral process.

    Agency Affected: Architect of the Capitol


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