Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment implements DOD Directive 4715.21 on climate change adaptation and resilience by updating, as appropriate, relevant DOD guidance related to acquisition and supply processes to incorporate the directive's provisions pertaining to those processes. In doing so, the Under Secretary of Defense for Acquisition and Sustainment should consider providing guidance as to how departmental officials may leverage already existing information regarding private companies. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. In its response, the department noted that the Under Secretary of Defense for Acquisition and Sustainment will oversee updates to relevant guidance related to supply processes and that they anticipate the updates to be complete by May 31, 2021. The department further noted that the Under Secretary of Defense for Acquisition and Sustainment will ensure updates are made to the acquisition policies, when and if appropriate. However, the department stated that its Adaptive Acquisition Framework currently provides all of the necessary flexibility required. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should implement DOD Directive 4715.21 on climate change adaptation and resilience by updating, as appropriate, relevant Department of the Army guidance related to acquisition and supply processes to incorporate the directive's provisions pertaining to those processes. In doing so, the Secretary of the Army should consider providing guidance as to how departmental officials may leverage already existing information regarding private companies. (Recommendation 2)

Agency: Department of Defense: Department of the Army
Status: Open

Comments: DOD concurred with this recommendation. In its response, the department noted that the Army would update, as appropriate, Army guidance related to acquisition and supply upon updates to DOD's climate adaptation directive and other applicable DOD or federal regulations. However, DOD noted that it does not plan to update its acquisition guidance in response to our recommendation that DOD do so. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Navy should implement DOD Directive 4715.21 on climate change adaptation and resilience by updating, as appropriate, relevant Department of the Navy guidance related to acquisition and supply processes to incorporate the directive's provisions pertaining to those processes. In doing so, the Secretary of the Navy should consider providing guidance as to how departmental officials may leverage already existing information regarding private companies. (Recommendation 3)

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: DOD partially concurred with this recommendation. In its response, the department noted that the Department of the Navy had suggested that the recommendation be restated to recommend that the Department of the Navy ensure that its guidance and procedures are updated to align with DOD's directive on climate adaptation upon issuance of an updated directive. However, DOD has not identified any plans to update its directive on climate change adaptation. Thus, we continue to believe that the Department of the Navy should update its guidance related to acquisition and supply to incorporate the current guidance in DOD's climate adaptation directive, which it has not yet done. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Air Force should implement DOD Directive 4715.21 on climate change adaptation and resilience by updating, as appropriate, relevant Department of the Air Force guidance related to acquisition and supply processes to incorporate the directive's provisions pertaining to those processes. In doing so, the Secretary of the Air Force should consider providing guidance as to how departmental officials may leverage already existing information regarding private companies. (Recommendation 4)

Agency: Department of Defense: Department of the Air Force
Status: Open

Comments: DOD concurred with this recommendation. In its response, the department noted that the Air Force will work with the Office of the Under Secretary of Defense for Acquisition and Sustainment and the other military services to develop specific policies that address climate-related risks to DOD contractors. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Policy, in coordination with the Under Secretary of Defense for Acquisition and Sustainment, the Secretaries of the military departments, and any other governmental and private-sector partners, as appropriate, determine what approaches may be feasible in conducting mission assurance related assessments of commercially owned facilities. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. In its response, the department noted that formal mission assurance assessments are limited in scope in order to provide additional rigor to protect DOD's most critical capabilities. However, the department stated that the Office of the Under Secretary of Defense for Policy would work with the Office of the Under Secretary of Defense for Acquisition and Sustainment's Defense Contract Management Agency to better understand DOD's commercial dependencies. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Policy, in coordination with the Under Secretary of Defense for Acquisition and Sustainment, the Secretaries of the military departments, and any other governmental and private-sector partners, as appropriate, issue new or update existing guidance, based upon the determination of what approaches may be feasible, to clarify the steps that DOD officials involved in the mission assurance process may take to apply the mission assurance framework to commercially owned facilities, as appropriate, to include consideration of risks related to climate change and extreme weather. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. In its response, the department noted that it concurs with the need to clarify steps that officials may take to apply the mission assurance framework to defense critical infrastructure and critical defense industrial base commercially owned facilities, to include consideration of risks related to climate change and extreme weather. However, the department further noted that it does not concur with doing this for all commercial facilities because conducting such assessments for all commercially owned facilities falls outside the capacity and authority of DOD to conduct mission assurance assessments. However, we had not recommended they conduct such assessments for all commercial facilities. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to, in coordination with the Office of Program Accountability and Risk Management, develop a risk-based approach for reviewing service requirements—through the Procurement Strategy Roadmap or other means—to ensure proposed service requirements are clearly defined and reviewed before planning how they are to be procured. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: DHS disagreed with our recommendation, preferring to maintain the status quo in its policy and procedures. However, by doing so, DHS is missing important opportunities to prevent negative acquisition outcomes and the potential for wasted resources. In its response, DHS noted its processes for major acquisitions, however, DHS service programs and contracts did not rise to the level of being classified a major service acquisition.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to document the factors the Office of the Chief Procurement Officer considers when waiving procurement actions from its Procurement Strategy Roadmap to ensure it is consistently considering potential acquisition risks in its planning—including those specific to services. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation, maintaining that the factors considered when waiving a Procurement Strategy Roadmap are not static. We believe, however, that documenting the factors considered will help ensure that the decisions to waive the Procurement Strategy Roadmaps are made consistently, transparently, and help maintain institutional knowledge.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to update the Inherently Governmental and Critical Functions Analysis to require the identification of special interest functions. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and stated that it will update the Inherently Governmental and Critical Functions Analysis job aid to require the identification of a special interest function when applicable.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to update the Inherently Governmental and Critical Functions Analysis to provide guidance for analyzing, documenting, and updating the federal workforce needed to perform or oversee service contracts requiring heightened management attention. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation maintaining that the components are certifying that they have sufficient internal capacity or federal employees available for oversight within the Inherently Governmental and Critical Functions Analysis. We continue to believe, however, that without guidance, each component is making its own determination about which factors to consider, and DHS does not know how or whether the components are considering the federal workforce available to oversee service contracts in need of heightened management attention, or what steps, if any, the components are taking to mitigate risks if there are not enough federal personnel available to oversee the contracts after award.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to develop guidance identifying oversight tasks or safeguards personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental functions, special interest functions, or critical functions. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and stated that it will develop guidance that identifies oversight tasks or safeguards that personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental, special interest, or critical functions.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Financial Officer to work with Congress to identify information to include in its annual congressional budget justifications to provide greater transparency into requested and actual service requirement costs, particularly for those services requiring heightened management attention. (Recommendation 6)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation stating that its annual Congressional Budget Justification already contains substantial service contract information. We maintain, however, that the service contract information currently included limits visibility for both DHS and Congress into requested and actual service requirements costs.

Recommendation: GSA should assess and address the reliability of the information used to calculate reported cost savings for the broker program. (Recommendation 1)

Agency: General Services Administration
Status: Open
Priority recommendation

Comments: In June 2020, GSA said the agency would validate system data through regional and broker outreach and fully utilize validated system data to manage the broker program. The agency also said it will develop a quality control plan and follow-up on outcomes. We will continue to monitor GSA's progress with implementing this recommendation.

Recommendation: GSA should develop outcome-based metrics to evaluate the effectiveness of using brokers to supplement the GSA's leasing workforce. (Recommendation 2)

Agency: General Services Administration
Status: Open

Comments: Although GSA initially did not concur with this recommendation, the agency stated in June 2020 that it agrees with the recommendation and will take steps to implement it. Specifically, GSA plans to revise the broker performance standards and document broker effectiveness through lease cost avoidance, timely lease replacement, and earned commission credits. We will continue to monitor GSA's progress with implementing this recommendation.

Recommendation: The Office of the Undersecretary of Defense (Comptroller) (OUSD[C]) should include an assessment of risks related to contractor ownership as part of its ongoing efforts to plan and conduct a department-wide fraud risk assessment. As part of this assessment, consistent with leading practices, DOD should involve relevant stakeholders with knowledge of emerging risks and use this information to help inform other types of risk assessments across the department, including for national security concerns. (Recommendation 1)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Energy, in coordination with the Administrator of NNSA, should formally communicate to the relevant congressional committees concerns about, and suggested changes to, the enhanced procurement authority in a timely manner. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: NNSA agreed with the recommendation. NNSA officials said they submitted an assessment that includes information on suggested changes to the authority to the congressional committees in March 2020. We requested a copy of the assessment and will update the status of this recommendation after we receive and review it.

Recommendation: The Assistant Secretary of ETA should develop, document, and implement a comprehensive strategy that (1) accounts for Job Corps' projected workload requirements and (2) considers its acquisition workforce needs—including the number of staff, skills, and other supports necessary to plan, award, and monitor Job Corps center contracts—to enable it to effectively plan for and competitively award future Job Corps center contracts. (Recommendation 1)

Agency: Department of Labor: Employment and Training Administration
Status: Open

Comments: DOL stated that it will develop, document, and implement a comprehensive strategy that accounts for Job Corps' projected workload requirements and considers its acquisition workforce needs. DOL noted that it has released a new procurement plan which reflects its decision to re-procure 28 Job Corps centers prior to the final option year of their contract. DOL said that this action would result in each region having no more than five procurements each year, which it considers a manageable procurement workload for its current staffing level. We will consider closing the recommendation when such a comprehensive strategy is implemented.

Recommendation: The Director of OMB should ensure that information is collected regarding how centralized reporting of procurement requirements might reduce recipient reporting burden—including input from stakeholders such as contractors through an iterative and ongoing process—to inform OMB's planned expansion of the Central Reporting Portal.

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

Comments: In an October 2019 written response to the recommendation contained in GAO-19-299, OMB acknowledged the importance of collecting stakeholder input and described some steps that it has taken to do so in the past. The letter also stated OMB's intention to engage key stakeholders moving forward but was not specific regarding steps it planned to take related to the potential expansion of the Central Reporting Portal. GAO will continue to monitor this issue including what specific actions, if any, OMB takes in response to this recommendation.

Recommendation: To the extent that Congress wants to further encourage federal agencies to use tribal energy sources, it should consider amending the Energy Policy Act of 2005 to provide more specific direction to federal agencies for implementing the tribal energy preference, to include consideration of additional incentives or requirements to use these energy sources. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: We will provide updated information when we confirm what steps Congress has taken related to this matter.

Recommendation: The Director of the DOE Office of Acquisition Management should clearly define—in guidance or other documents—which subcontracts should be audited, how an audit is defined, and how to meet subcontract audit requirements if Defense Contract Audit Agency is unable to conduct the audit.(Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: In its comments on a draft of the report, DOE partially concurred with the recommendation, but stated that there is no government-wide requirement that defines an audit or prescribes the auditing of subcontracts. According to officials, DOE reviewed existing regulations, guidance, and contract provisions on audit requirements and determined that a need exists for additional guidance or contract provisions on audits for major contracts. As of June 2020, DOE was working with the Civilian Agency Acquisition Council to recommend a government-wide requirement to define audit and prescribe when to obtain audits of subcontracts. Additionally, DOE included in its Acquisition Guide information on audit options when the Defense Contract Audit Agency is unable to conduct an audit.

Recommendation: The Director of the DOE Office of Acquisition Management should require local officials to independently review subcontractor ownership information as part of DOE consent reviews and assess potential conflicts of interest to ensure contractors are mitigating them. (Recommendation 4)

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: DOE did not concur with our recommendation; instead, they plan to issue guidance emphasizing the importance of contracting officers reviewing contractors' disclosing and dealing with issues created by close working relationships, conflicts of interest, or ownership affiliations between prime and subcontractor. We have identified complex relationships among DOE contractors and subcontractors that were not documented by DOE, as well as incidents involving subcontractors related to conflicts of interest that were not disclosed to DOE. We noted that DOE officials--including those in local offices--have access to several databases and other sources of information that would allow them to independently verify ownership information that could allow the local offices to identify potential conflicts of interest that were not disclosed. In July 2020, DOE issued guidance summarizing and reiterating existing regulations, policy and procedures that require DOE contracting officers to perform independent analyses when reviewing subcontract consent packages, contractor purchasing systems, and potential organizational conflicts of interest. However, this is the same as previous guidance and it does not include direction to review subcontractor ownership information.

Recommendation: The Director of the DOE Office of Acquisition Management should require contracting officers to include assessments of the contractors' management of subcontractors as part of annual Performance Evaluation and Measurement Plans, as appropriate. (Recommendation 6)

Agency: Department of Energy
Status: Open

Comments: DOE partially concurred with the recommendation and agreed to review existing guidance and determine if additional guidance is needed to conduct an assessment of the contractors' management of subcontractors in annual Performance Evaluation and Measurement Plans. As of June 2020, DOE officials said they have reviewed existing federal and departmental policies, procedures, and available tools and determined sufficient guidance exists for contracting officers to make informed decisions on whether to include contractor management of subcontractors in annual Performance Evaluation and Measurement Plans based on the characteristics, circumstances, and requirements of a specific contract. DOE's Performance Evaluation and Measurement Plan template provides a subcontractor management evaluation factor for use by contracting officers who have determined it is appropriate for their contracts. Although we recognize the value in deferring to contracting officers to determine whether the factor is appropriate based on the characteristics, circumstances, and requirements of the contract, we continue to believe that DOE should place additional emphasis on the contractors' oversight of subcontracts by assessing the contractors on this factor.

Recommendation: The Director of the Office of Management and Budget should instruct the Office of Federal Procurement Policy: (1) To facilitate additional training to improve the understanding of the contracting workforce regarding the Buy American Act requirements; and (2) To facilitate clarifying revisions to FPDS-NG, where needed, and provide training and guidance for recording Buy American Act information in FPDS-NG to improve the accuracy of the Buy American data. (Recommendation 1)

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

Comments: The Office of Federal Procurement Policy (OFPP) within OMB concurred with our recommendation, noting that it plans to coordinate with federal agencies on the extent to which they have developed training and guidance. Based on this information, OFPP will work with agencies to determine the most appropriate course of action to address gaps, if any. As of August 2020, OFPP stated that it had not taken any additional actions to implement the recommendation because it is currently focused on implementing Executive Order 13881 "Maximizing Use of American-Made Goods, Products and Materials".

Recommendation: The Secretary of Veterans Affairs should clarify existing guidance, or provide training or other instruction, to help contracting officials: (1) Address the applicability of the Buy American Act requirements and provide instruction on how to implement the requirements, including in any training developed to implement the Veterans First policy; (2) Identify the factors that should be considered in order to determine the applicability of the Trade Agreements Act and waiver of the Buy American Act; and (3) Identify sources of information available for determining products' origins and the steps they should take to verify information that is inconsistent. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) concurred and has since taken action to address some of our three-part recommendation. For example, VA revised its "Procurement Policy Memorandum 2017-12", on April 9, 2019, to better clarify its existing Buy American Act guidance and highlight key factors contracting staff should consider when determining the applicability of Buy American Act exceptions and waivers. Additionally, in October 2019, VA provided GAO briefing slides for a new training to be offered at the agency's acquisition academy that includes specific instruction pertaining to the use of Buy American Act exceptions and waivers. However, VA has yet to address our recommendation that the agency clarify guidance or provide training to help contracting officers identify sources of information regarding product origin and the steps to be taken to verify inconsistent product origin information. We plan to keep this recommendation open until VA implements guidance or training of this nature and we are able to assess the extent to which it fully addresses our recommendation.

Recommendation: The Secretary of Health and Human Services should provide guidance, training, or other instruction to help contracting officials: (1) Identify the factors that should be considered in order to determine the applicability of the Trade Agreements Act and waiver of the Buy American Act; (2) Document determinations of the use of Buy American exceptions for domestic non-availability and ensure the required approvals are obtained; and (3) Identify sources of information available for determining products' origins and the steps they should take to verify information that is inconsistent. (Recommendation 4)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with this recommendation and has taken steps to implement it. HHS issued a memorandum in February 2019 requiring all contracting officers as part of their continuous learning program to complete the Buy American Statute course, FAC063, offered by the Federal Acquisition Institute. As of February 2020, about 90 percent of contracting officials had taken the required training. However, due to its COVID-19 Pandemic response activities, HHS stated that all of its contracting officials had not completed the training as intended. HHS also developed checklists and guidance related to the Buy American Act and Trade Agreements Act. We plan to keep this recommendation open until HHS completes its training initiative.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense for Acquisition and Sustainment to identify the reasons behind the high rate of miscoding for orders awarded under multiple award contracts and use this information to identify and take action to improve the reliability of the competition data entered into FPDS-NG. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In November 2018, and in response to our draft report, DOD stated that it would analyze the Federal Procurement Data System- Next Generation data in an effort to identify why the miscoding of orders under multiple award contracts occurs, and use this information to advise the contracting community of actions to improve the reliability of the competition data. In July 2019, DOD officials stated they did not have an update regarding planned actions to address the recommendation. As of September 2020, DOD officials did not respond to our multiple requests for updates to this recommendation.

Recommendation: The Secretary of Health and Human Services should direct the Associate Deputy Assistant Secretary for Acquisition to identify the reasons behind the high rate of miscoding for orders awarded under multiple award contracts and use this information to identify and take action to improve the reliability of the competition data entered into FPDS-NG. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open

Comments: In February 2019, HHS stated it was performing analysis and research to understand the reasons for the miscoding of orders. Once this analysis and research is completed, HHS reported it plans to work to address the root causes of the previously identified miscodings, so as to prevent future errors. In July 2019, HHS officials stated they did not have an update regarding planned actions to address the recommendation. As of September 2020, HHS officials did not respond to our multiple requests for updates to this recommendation.

Recommendation: The Secretary of the Navy should: assess why reverse auctions that are conducted using existing contract vehicles have only one bidder at higher rates than reverse auctions conducted on the open market; determine what factors indicate that conducting reverse auctions is appropriate when using existing contract vehicles; and provide this information to contracting officials so that they can consider it when developing their acquisition strategies.(Recommendation 4)

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: DOD agreed with this recommendation and stated that the department expected to complete actions to address it by the end of calendar year 2018. In August 2019, Navy officials told us that they had reviewed data on reverse auctions to determine a root cause of single bidders, and describing the factors that indicate that conducting a reverse auction are appropriate. However, they had not yet provided this information to contracting officials as of July 2020.

Recommendation: The Secretary of the Navy should: document and provide information to contracting officials that describes available reverse auction providers and platforms, and any associated fee structures; and provide guidance, as appropriate, to contracting officials to ensure that they compare the options that are available to them when considering whether to use reverse auctions. (Recommendation 6)

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: DOD agreed with this recommendation and stated that the department expected to complete actions to address it by the end of calendar year 2018. In August 2019, Navy officials stated that memorandum of understanding with reverse auction providers, including fee information, are distributed to contracting officials. However, as of August 2020, they had not provided us with evidence that they had distributed a memorandum related to the primary reverse auction provider currently used by the Navy.

Recommendation: The Secretary of Agriculture should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 3)

Agency: Department of Agriculture
Status: Open

Comments: The agency concurred with our recommendation, and in June 2018, USDA CIO delegated the review and approval of acquisition plans and strategies to the Capital Planning and Information Technology Governance Division (CPITGD) through the Associate CIO of the Information Resource Management Center. However, as of June 2020, the agency had not provided evidence to demonstrate that these reviews and approvals are taking place as required by OMB's guidance. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of Commerce should ensure that the office of the CAO is involved in the process to identify IT acquisitions. (Recommendation 4)

Agency: Department of Commerce
Status: Open

Comments: In a March 2018 response to our report, the agency agreed with our recommendation and stated that the CIO and the Senior Procurement Executive will issue a memo to their acquisition and CIO member offices clarifying the offices joint responsibilities to ensure that all IT acquisitions are submitted to the CIO for review and approval. The memo is also to provide guidance on the process by which the CIO will review proposed contract actions. However, as of February 2020, the agency had not responded to requests for updates. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of Commerce should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 5)

Agency: Department of Commerce
Status: Open

Comments: In a March 2018 response to our report, the agency agreed with our recommendation and stated that it intended to clarify its policies and procedures to comply with OMB rules, including the IT acquisition checklist, which must be completed for every proposed contract action. In addition, the CIO and Senior Procurement Executive will work together to review existing acquisition plan review and approval processes. However, as of February 2020, the agency had not responded to requests for updates. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of HHS should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 10)

Agency: Department of Health and Human Services
Status: Open

Comments: The agency agreed with our recommendation and in an April 2018 update stated that HHS has a policy for the HHS IT acquisition review process for acquisition strategies. However, as of February 21, 2020, the agency had not provided evidence that the CIO (or designee) was reviewing and approving IT acquisition plans, as required. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of State should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 22)

Agency: Department of State
Status: Open

Comments: The agency agreed with our recommendation, and in a December 2019 update provided information on the agency's CPIC process and a template for IT acquisition strategies. However, it is not clear whether the CIO is reviewing and approving IT acquisitions plans through the CPIC process and the template does not provide a place for the CIO review and approval. In addition, we have requested evidence of CIO approval of selected IT acquisitions. We will continue to monitor the implementation of this recommendation

Recommendation: The Secretary of the Treasury should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 23)

Agency: Department of the Treasury
Status: Open

Comments: The agency did not state whether it agreed or disagreed with the recommendation. In March 2019, Treasury issued a memo that requires the CIO to review and approve IT acquisition plans for acquisitions with a total value of $68 million or more, or for actions with a period of performance longer than 5 years. The review and approval of all other IT acquisition plans are delegated to the component CIOs or Chief Technology Officers. However, the agency had not yet provided evidence that the CIO (or designee) was reviewing and approving selected IT acquisition plans, as required. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of Transportation should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 26)

Agency: Department of Transportation
Status: Open

Comments: The agency concurred with the recommendation. In October 2019, Transportation issued guidance requiring that the CIO or designee to review and approve all IT acquisition plans. We have requested that the agency provide us evidence of CIO-approved IT acquisition plans. The agency stated that it planned to respond by May 15, 2020. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of VA should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 28)

Agency: Department of Veterans Affairs
Status: Open

Comments: The agency concurred with the recommendation. In November 2019, VA issued guidance that requires the CIO, in conjunction with the Chief Acquisition Officer, to review and approve all IT acquisition strategies and plans. Specifically, the CIO is to review and approve IT acquisitions valued at $15 million or more. The CIO has delegated the review and approval of IT acquisitions less than $15 million to other designees, based on the value of the contract. However, the agency had not provided evidence that the CIO (or designee) was reviewing and approving selected IT acquisition plans, as required. We will continue to monitor the implementation of this recommendation.

Recommendation: The Administrator of NASA should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 32)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: The agency concurred with the recommendation, and in September 2017, NASA's CIO delegated the review and approval authority of IT acquisitions to the Center CIOs. We have requested evidence of CIO-approved IT acquisitions. We will continue to monitor the implementation of this recommendation.

Recommendation: The Director of the Office of Personnel Management should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 34)

Agency: Office of Personnel Management
Status: Open

Comments: The agency concurred with the recommendation and in an April 2020 updated stated that OPM has contracted with a third-party vendor to evaluate the OPM IT human capital, architecture, and governance processes from planning to acquisition to implementation. The agency further stated that it is working to fully implement an IT governance process where the OPM CIO fully reviews and approves IT acquisition plans and processes. We will continue to monitor the implementation of this recommendation.

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. As of September 2020, despite numerous requests, we still have not received any information on steps HHS has taken to address this recommendation.

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. As of September 2020, despite numerous requests, we still have not received any information on steps HHS has taken to address this recommendation.

Recommendation: In order to ensure that contracting officers have clear and effective policies as soon as possible, the Secretary of Veterans Affairs should direct the OAL to identify measures to expedite the revision of the Veterans Affairs Acquisition Regulation (VAAR), which has been ongoing for many years, and the issuance of the VA Acquisition Manual.

Agency: Department of Veterans Affairs
Status: Open
Priority recommendation

Comments: VA concurred with this recommendation and has made progress in finalizing the update to its acquisition regulations and manual. In August 2020, VA reported that 31 of the 41 parts in its new acquisition regulations had been issued as draft or final rules. The remainder are at an earlier stage of the rulemaking process. VA also stated that it remains on track to release the final VA Acquisition Regulations in April 2021.

Recommendation: As NIH-DFAS begins formalizing its internal guidance, the Director of NIH-DFAS should establish a mechanism for tracking key milestones in the indirect cost rate-setting process, such as when indirect cost rate proposals are due.

Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health: Office of Management: Office of Acquisition and Logistics Management: Office of Acquisition Management and Policy: Division of Financial Advisory Services
Status: Open

Comments: HHS concurred with this recommendations. In response, HHS stated that National Institute of Health's Division of Financial Advisory Services (DFAS) will establish a mechanism for tracking key milestones in the indirect cost rate-setting process. NIH-DFAS has initiatives underway that include moving from paper to electronic submissions of indirect cost proposals and developing a replacement to its Commercial Rate Agreement Distribution Services website. DFAS is looking into the feasibility of incorporating key milestones into these two major initiatives. NIH-DFAS is currently working with a contractor to develop a web based system that will establish a tracking system to account for when indirect cost proposal are due from organizations. The original initiative to enable the electronic submission of indirect cost proposals was modified to incorporate this new requirement. NIH-DFAS anticipates the planned date for implementation of this system to be October 1, 2017. As of February 4, 2020, this recommendation is still open because DFAS does not have the "proposal due date" and "extension due date" data fields activated in eFLow. DFAS is looking into adding those enhancements and hope to have these updates implemented by June 30, 2020. On July 8th, 2020, NIH-DFAS notified us that they plan to update us with the status of this recommendation by October 2020. We will continue to monitor the status of this recommendation.

Recommendation: To ensure that DOE's control activities continue to be relevant and effective for managing supply chain risk, the Secretary should direct the Under Secretary for Nuclear Security, as the Administrator of the NNSA, to work with the Office of Intelligence and Counterintelligence and other DOE organizations, as appropriate, to assess the circumstances that might warrant using the enhanced procurement authority, and (1) if this assessment identifies circumstances that might warrant using the authority, the Secretary should direct the Under Secretary for Nuclear Security to work with other DOE organizations, as appropriate, to establish processes for using it and examine whether adequate resources are in place to support those processes, and (2) communicate the results of this assessment to the relevant congressional committees for their use in determining whether to extend the authority past its current termination date.

Agency: Department of Energy
Status: Open

Comments: In an October 7, 2016, letter the Under Secretary for Nuclear Security and Administrator of the National Nuclear Security Administration (NNSA) said he agreed with GAO's recommendation to assess situations that might warrant the use of the enhanced procurement authority and, should specific circumstances be identified for use of the authority, NNSA would develop a process for its use. The assessment would include an examination of resources to support use of the authority. NNSA would work with other Department of Energy organizations as appropriate in conducting the assessment. NNSA officials said they submitted the assessment to the congressional committees in March 2020. We requested a copy of the assessment and will update the status of this recommendation after we receive and review it.

Recommendation: To gain visibility and enable efficient management on the use of bridge contracts in federal agencies, the Administrator of OFPP should take appropriate steps to develop a standardized definition for bridge contracts and incorporate it as appropriate into relevant FAR sections.

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

Comments: Staff from the Office of Federal Procurement Policy (OFPP) had previously told us that OFPP would be convening the FAR Council to discuss regulatory action after it completes the development of management guidance. In January 2020, OFPP staff stated that they are reviewing the extent to which this guidance is necessary moving forward, and noted that there is no estimated timeframe for completion of this review. However, in August 2020, OFPP staff said that in light of the focus on COVID and related priorities, OFPP does not have immediate plans to pursue guidance on bridge contracting at this time. OFPP staff noted that OFPP continues to work with agencies to help them effectively leverage acquisition flexibilities that reduce Procurement Acquisition Lead Times to reduce the need for bridge contracts. We continue to believe these actions are important to help ensure agencies do not continue to use these noncompetitive contracts frequently or for prolonged periods of time, thereby risking paying more than they should for goods and services .

Recommendation: To gain visibility and enable efficient management on the use of bridge contracts in federal agencies, the Administrator of OFPP should, as an interim measure, until the FAR is amended, provide guidance to agencies on (1) a definition of bridge contracts, with consideration of contract extensions as well as stand-alone bridge contracts; and (2) suggestions for agencies to track and manage their use of these contracts, such as identifying a contract as a bridge in a Justification and Approval (J&A) when it meets the definition, and listing the history of previous extensions and stand-alone bridge contracts back to the predecessor contract in the J&A.

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

Comments: OMB staff had previously told us that they had drafted guidance, which included a definition for bridge contracts, and that it was under review. In January 2020, OMB staff stated that they are reviewing the extent to which this guidance is necessary moving forward and noted that there is no estimated timeframe for completion of this review. However, in August 2020, OFPP staff said that in light of the focus on COVID and related priorities, OFPP does not have immediate plans to pursue guidance on bridge contracting at this time. OFPP staff noted that OFPP continues to work with agencies to help them effectively leverage acquisition flexibilities that reduce Procurement Acquisition Lead Times to reduce the need for bridge contracts. We continue to believe these actions are important to help ensure agencies do not continue to use these noncompetitive contracts frequently or for prolonged periods of time, thereby risking paying more than they should for goods and services.