Recommendations for Executive Action

1. Status: Closed - Implemented

   Comments: DOE conducted training on conflict policies and procedures in May 1991 to enable contractors and reviewers to recognize problems. Albuquerque will follow up to ensure that appropriate personnel have received this training.

   Recommendation: The Secretary of Energy should direct the Manager, Albuquerque operations office, to explore options to improve the reliability of the conflict-of-interest information that its research centers' subcontractors submit. In exploring options, Albuquerque should consider reviewing a randomly selected sample of submissions and imposing administrative sanctions on subcontractors that submit incomplete or inaccurate information.

   Agency Affected: Department of Energy

2. Status: Closed - Implemented

   Comments: DOE has highlighted and placed special emphasis on conflict-of-interest issues in its procurement management assistance reviews, according to DOE officials. If the operations offices do not perform adequately, the procurement executive will take corrective action.

   Recommendation: The Secretary of Energy should ensure that the Director of Procurement, Assistance, and Program Management revises DOE headquarters' oversight procedures so that they rely less on self-disclosures by the operations offices to identify problems with the implementation of conflict-of-interest policies and procedures.

   Agency Affected: Department of Energy

3. Status: Closed - Implemented

   Comments: DOE stated that deficiencies found will be addressed by Albuquerque officials and then followed up quarterly until resolved. DOE stated that oversight will be enhanced by requiring inclusion of a sample of conflict actions in the judgmental sample of contract actions during quarterly surveillance.

   Recommendation: The Secretary of Energy should direct the Manager, Albuquerque operations office, to ensure that: (1) Albuquerque's oversight reviews focus on the adequacy of Sandia's and Los Alamos' implementation of conflict-of-interest requirements; and (2) operations office officials follow up on research centers' actions to ensure that identified weaknesses are corrected.

   Agency Affected: Department of Energy

4. Status: Closed - Implemented

   Comments: DOE revised its criteria for assessing the application of conflict determinations by each contracting office. DOE officials stated that they have made conflict-of-interest issues a point of emphasis in DOE procurement management assistance reviews.

   Recommendation: The Secretary of Energy should determine whether the conflict-of-interest problems identified at the Albuquerque operations office exist at other operations offices.

   Agency Affected: Department of Energy

5. Status: Closed - Implemented

   Comments: DOE approved revised procedures for Sandia and Los Alamos which require that subcontracts be forwarded to Albuquerque for OCI determinations. DOE plans to assess the research centers' compliance during the operations offices' periodic reviews.

   Recommendation: The Secretary of Energy should direct the Manager, Albuquerque operations office, to ensure that its research centers forward subcontracts in the specified categories to Albuquerque for conflict-of-interest determinations.

   Agency Affected: Department of Energy

6. Status: Closed - Implemented

   Comments: The DOE Albuquerque Operations Office found that the workload of potential conflict-of-interest cases is not as great as it originally estimated. A review of Albuquerque's procurement function by a headquarters team showed that Albuquerque was carrying out all of its conflict-of-interest activities.

   Recommendation: The Secretary of Energy should ensure that the Albuquerque Operations Office has sufficient resources to carry out its conflict-of-interest responsibilities.

   Agency Affected: Department of Energy

7. Status: Closed - Implemented

   Comments: DOE stated that its policies and procedures now require decisions and actions to be documented and that when a field activity is less than satisfactory, corrective action will be taken.

   Recommendation: The Secretary of Energy should direct the Manager, Albuquerque operations office, and the managers of its other operations offices, if appropriate, to take the necessary measures to ensure that conflict-of-interest decisions are well documented.

   Agency Affected: Department of Energy

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