Footnote 1: The OIG adapted this definition from the publication: Advisory and Assistance Services, A Practical Reference Guide, issued in December 2000 by the President’s Council on Integrity and Efficiency (PCIE). The PCIE is charged with conducting interagency and inter-entity audit, inspection, and investigation projects to effectively and efficiently deal with government-wide issues of fraud, waste and abuse.
Footnote 2: Title 48 of the Code of Federal Regulations.
Footnote 3:According to the Office of Federal Procurement Policy, services such as those that involve or relate to budget preparation; reorganization and planning; or analyses, studies, and strategy options to be used by agency personnel in developing policy, are examples of services that are not considered to be inherently governmental, but which could fall into that category depending on the way in which the contractor performs the contract or the manner in which the Government administers contractor performance.
Footnote 4: GAO/AFMD-8.1.2, Guide for Evaluation and Testing Controls Over Sensitive Payments, dated May 1993.
Footnote 5: Other organizations, including the Legal Division; the Office of Diversity and Economic Opportunity; the Security Management Section, DOA; and the Accounts Payable Processing Unit, Division of Finance; also play a role in contract administration.
Footnote 6: Interim Acquisition Policy #2004-9, Implementing Acquisition Planning, dated August 31, 2004.
Footnote 7: Noncompetitive contracts are those where only one source is solicited, not requiring competition to make an award or modification.
Footnote 8: Market research is obtaining general knowledge about the availability and types of goods or services for future acquisitions and identifying firms offering goods or services that are available in the marketplace. Market research is required to substantiate justifications for noncompetitive procurement.
Footnote 9: The Competition Advocate Program was established to monitor noncompetitive awards on a corporate-wide basis in relation to overall competitive awards. According to ASB officials, the Competition Advocate Program was not in place at the time of our review.
Footnote 10: Interim Acquisition Policy #2004-13, entitled, Non-Competitive Procedures, Addendum to Acquisition Policy Manual (Revision 3) Chapter 2.J., "Justification for Non-Competitive Procurement (JNCP)" dated December 8, 2004.
Footnote 11: The initial contract period was 6 months; however, the period of performance was extended through March 2002. In April 2002, ODEO awarded a new noncompetitive contract for coaching and mentoring services through March 2004 for $170,000. In March 2004, ODEO modified the contract to extend the period of performance through March 31, 2005. A total of $50,656 had been spent on this contract as of March 2004.
Footnote 12: We were unable to obtain copies of all of the task orders issued for the service costing (benchmarking) contract and thus we could not reconcile all task orders to the total contract amount per the POS. Therefore, we could not identify all work requirements, including the purpose of all modifications made to this contract. However, the difference between the original contract amount and the total amount as reported by POS (March 2004) was $982,000 or a 95-percent increase from the original contract amount.
Footnote 13: Report Number 04-043, dated September 29, 2004.
