In a message that could apply to other agencies as well, the Defense Department IG has said that agency employees involved in spending money appropriated under the virus relief laws may need to justify their decisions under a high level of scrutiny.
“DoD officials will be under scrutiny from Congress, the DoD OIG, and the public on the use and tracking of all disaster relief funding related to the COVID-19 pandemic. DoD officials need to ensure their response is deliberate and they are adequately prepared for the increased scrutiny that will inevitably occur,” said a special report to management.
“DoD contracting officials should lean on past experiences in disaster recovery efforts and apply these best practices and lessons learned to the COVID-19 pandemic response,” it adds, echoing statements made recently by the IGs of several other departments.
It said in particular to focus on:
Proper Use of Personnel. It recommended using “long-term government employees for program management and key technical positions that exercise oversight over contract employees,” ensuring that “sufficient staff are available and trained on the requirements in the contract, the documentation required to support payment of contractor invoices, and the performance of quality assurance activities” and segregating duties in the purchase request and invoice payment processes.
Consistency in the Contracting Process. This includes ensuring that contracts and task orders are accurate and complete, that contracting personnel clearly define contract requirements in solicitations and that contractor quality control plans meet the minimum level of detail required by agency policy.
Documentation. “Ensure that contracting personnel are keeping documentation of important decisions in the contract files, including cost data from contractors, negotiated agreements, and detailed written explanations if there is a need to deviate from normal procedures and an explanation of why the deviation was necessary.” Also, ensure that quality assurance personnel “fully document in the contract files, the methodology and results of contractor oversight through observations and testing and any remedial and corrective actions taken,” and that contracting personnel “establish an archival process for completed projects.”
Fraud Awareness. Contracting personnel should familiarize themselves with common fraud schemes, verify the identity of companies and individuals that offer assistance, check past performance of companies, and determine when a corporation was created and whether the company is in good standing. Companies with residential addresses “can be an indicator of it not being a viable business concern.”