[Audit Report on Procurement and Property Management Activities, National Conservation Training Center, U.S. Fish and Wildlife Service]
[From the U.S. Government Printing Office, www.gpo.gov]
Report No. 01-I-288
Title: Audit Report on Procurement and Property Management Activities,
National Conservation Training Center, U.S. Fish and Wildlife
Service
Date: March 30, 2001
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Memorandum
To: Assistant Secretary for Fish and Wildlife and Parks
From: Roger La Rouche
Assistant Inspector General for Audits
Subject: Audit Report on Procurement and Property Management Activities, National
Conservation Training Center, U.S. Fish and Wildlife Service (No. 01-I-288)
This report presents the results of our audit of the procurement and property management
activities of the National Conservation Training Center, U.S. Fish and Wildlife Service.
Since the report's recommendations are considered resolved and implemented, no further
response to the report is required (see Appendix 4).
Section 5(a) of the Inspector General Act (Public Law 95-452, as amended) requires the Office of
Inspector General to list this report in its semiannual report to the Congress. In addition, the
Office of Inspector General provides audit reports to the Congress. U.S. Department of the Interior Office of Inspector General
EXECUTIVE SUMMARY
Procurement and Property Management Activities,
National Conservation Training Center,
U.S. Fish and Wildlife Service
Report No. 01-I-288
The U.S. Fish and Wildlife Service (FWS) established the National Conservation Training
Center as the principal source of training and educational services for its 8,329 employees and
for conservation professionals from other agencies. The Center, which began full-time
operations during fiscal year 1998, has a residential campus in Shepherdstown, West Virginia.
On campus and at remote locations throughout the country, the Center offers about 250 courses.
The objective of the audit was to determine whether the Center complied with applicable laws,
regulations, and policies in making purchases and accounting for property. Our review covered
property management and procurement activities that occurred from the beginning of Center
operations through January 31, 2000. During this period, the Center purchased about $20 million
of goods and services and had an accountable property inventory of about $3 million.
We found that the Center did not have adequate management controls to ensure that goods and
services were purchased in a competitive manner, as recommended by the Federal Acquisition
Regulation, or to ensure that prudent procurement decisions were made, appropriate contracting
methods were used, and contractor payments and performance complied with requirements. For
example, because the Center paid wages for contract labor at rates that were higher than wage
rates set by the Department of Labor for comparable services, the Center paid a $59,100
premium for its contract labor. We concluded that FWS needed to establish additional controls
over its procurement activity to ensure that the Center obtained the best quality goods and
services at the lowest cost.
We also found that the Center did not establish adequate administrative controls over its property
and Government property furnished to contractors. For example, the Center's automated
property management system included duplicate cost entries and other posting errors, and
acquisitions were not entered into the system.
At the conclusion of the audit, we made 10 recommendations to the Director of FWS regarding
the establishment and implementation of controls to improve procurement and property
management practices at the Center. FWS concurred with all of the report's recommendations,
which are considered resolved and implemented.
CONTENTS
Page
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . .5
BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . .5
OBJECTIVE AND SCOPE . . . . . . . . . . . . . . . . . . .5
FINDINGS AND RECOMMENDATIONS . . . . . . . . . . . . . . . .6
A. PROCUREMENT. . . . . . . . . . . . . . . . . . . . . .6
B. PROPERTY MANAGEMENT. . . . . . . . . . . . . . . . . 10
AUDIT STANDARDS. . . . . . . . . . . . . . . . . . . . . . 13
PRIOR AUDIT COVERAGE . . . . . . . . . . . . . . . . . . . 13
APPENDICES
1. CLASSIFICATION OF MONETARY AMOUNTS. . . . . . . . . 14
2. FWS RESPONSE. . . . . . . . . . . . . . . . . . . . 15
3. COMMENTS ON FWS RESPONSE. . . . . . . . . . . . . . 25
4. STATUS OF AUDIT REPORT RECOMMENDATIONS. . . . . . . 29
INTRODUCTION
BACKGROUND
During the 1990s, the U.S. Fish and Wildlife Service (FWS) established the National
Conservation Training Center as the principal source of training and educational services for
its 8,329 employees. The Center, which began full-time operations during fiscal year 1998,
has a residential campus in Shepherdstown, West Virginia, and offers 250 courses on campus
and at remote locations around the country. The Center trains 5,000 participants annually,
provides a distance-learning program that can be accessed by up to 20,000 additional
participants via satellite broadcasts, and offers training videotapes. Although some training
courses are developed specifically for FWS employees, most are open to all conservation
professionals. For example, the Center offers technical courses on subjects such as
biotelemetry techniques and natural resource damage assessments, as well as nontechnical
courses such as public outreach planning and supervision and leadership.
OBJECTIVE AND SCOPE
The objective of our audit was to determine whether the Center complied with applicable
laws, regulations, and policies in making purchases and accounting for property. We
conducted our review at Center offices in Shepherdstown and at FWS's Division of
Contracting and General Services (headquarters) in Arlington. Our review covered property
management and procurement activities that occurred from fiscal years 1998 to 2000
(through January 31, 2000). During this period, the Center procured about $20 million of
goods and services and had an accountable property inventory valued at about $3 million.
To accomplish our objective, we interviewed Center and FWS headquarters personnel and
reviewed program and financial documentation. We reviewed selected transactions
including orders placed under blanket purchase agreements, purchase orders, Government
purchase card orders, and training form purchases.
FINDINGS AND RECOMMENDATIONS
A. PROCUREMENT
The Federal Acquisition Regulation (FAR) requires Federal agencies to use full and open
competition, when practicable, in acquiring goods and services and, in general, to select the
contractor or vendor that offers the best value to the Government. It also prescribes methods
and procedures for acquiring goods and services. FWS, however, did not have adequate
management controls to promote competition and to ensure that the Center made prudent
procurement decisions, used appropriate contracting methods, and complied with
requirements for contractor payments and performance.
Competition
FAR 13.104 states that contracting officers "shall promote competition to the maximum
extent practicable to obtain supplies and services from the source whose offer is the most
advantageous to the Government, considering the administrative cost of the purchase." It
also states that contracting officers should "consider the solicitation of at least three sources
and whenever practicable, request quotations or offers from two sources not included in the
previous solicitation." Despite these requirements, FWS did not establish a process to ensure
that procurement transactions were competitive. For example:
- Of 275 purchase orders reviewed totaling $1,800,000, we found that Center contracting
officers documented the solicitation of competition for only 7 percent and provided
justifications for less than full and open competition for only 16 percent. The remaining
purchase orders, although ratified by Center procurement officials, were originated by Center
personnel who did not have procurement authority to place the orders or were orders placed
with vendors for goods and services that previously were purchased from the same vendors
without the solicitation or consideration of competitive offers.
- Although FAR 13.104(b) recommends that purchasing agents solicit price quotations
from at least three vendors, two of which were not included in the previous solicitation, to
enhance competition, Center procurement officials generally did not seek competitive price
information. Of the 200 purchase card transactions reviewed, we found documentation that
the cardholder had contacted other vendors for only 2 transactions. While all cardholders
indicated that they solicited competition, they stated that they did not document that
competition was sought for each purchase.
- FAR 13.303-5(c) states that "the existence of a BPA [basic purchasing agreement]
does not justify purchasing from only one source or avoiding small business set-asides."
However, for the 50 BPA files reviewed, we found no documentation that competitive
procedures had been used to select vendors that provided similar supplies and services for
any of the 698 purchases totaling $1.5 million that were made during fiscal years 1998, 1999,
and 2000. In September 1999, a contracting officer inserted statements entitled
"Memorandum To File" into each of the 50 BPA files, which said, "Calls [purchases] made
against this BPA are done on a rotational basis with other BPAs of similar nature; thereby
meeting the competition requirements." We found no indication, however, that orders were
"rotated" to ensure competition or that orders were not placed competitively because of
vendor "availability" or the need for a more timely response.
- None of the files on 112 training forms used to purchase training services totaling
$651,200 contained documentation to show that the Center had obtained catalog or lower
pricing for the courses, although the Department's Contracting Officers Warrant System
Manual required such action. Part III.A of the Manual was revised in March 1999 to allow
nonwarranted personnel to acquire commercial off-the-shelf group training of up to $25,000
using the training form. The guidance also stated that employees should "challenge
established catalog prices" in an effort to obtain the best possible prices. Center officials
stated that they generally attempted to get the best prices for the courses offered at the Center
but that they did not document the results.
Wage Standards
FWS did not ensure that reasonable prices were charged by firms that were issued BPAs,
although required to do so by FAR 13.303-1. We compared some of the hourly rates paid
under the BPAs with wage standards prepared by the U.S. Department of Labor for the State
of West Virginia as of June 1, 1999 and concluded that the Center paid the vendors excess
amounts for their services. In total, we found that the Center overpaid vendors $59,100
from September 1998 through January 2000 and that it was still overpaying three vendors
in March 2000 with active BPAs. For example:
- FWS arranged for minor repairs of the Center under two BPAs. In the justification for
selecting the vendors, the contracting officer stated that facility management "has
interviewed these two individuals and has deemed them competent in pursuing these tasks
and at a reasonable price." The vendors were paid $22 per hour based on the contracting
officer's technical representative's recommendation and statement that this amount was the
"going" rate for journeymen carpenters, plumbers, and electricians. We found, however, that
the workers were not journeymen and that the assigned tasks, minor repairs, generally did
not require the professional level of services procured. As such, we concluded that the
Center overpaid the vendors at least $5.65 per hour ($22.00 per hour paid versus $16.35 per
hour for an electrician, according to Department of Labor rates).
- Issuing orders under BPAs for a variety of services, the Center paid four vendors
amounts that ranged from $20 per hour to $35 per hour. Comparing the hourly rates paid to
these vendors with the payment rate standards prepared by Labor, we found that the Center
overpaid these vendors as much as $12.58 per hour.
Acquisition Method
The Center did not establish a system to ensure that the appropriate acquisition method was
used and that employees complied with limitations on the dollar value of purchases made by
the Center. We found that the Center used BPAs and training forms to acquire training,
production, and laboratory services that should have been acquired through contracts and/or
purchase orders issued by a warranted contracting officer. In addition, we found that Center
training officials and purchase cardholders split single purchases into multiple transactions
to avoid purchase limits. For example:
- Under FAR 13.303-2, contracting officers may establish BPAs when the exact items,
quantities, and delivery requirements within a broad class of supplies or services are not
known in advance and the use of BPAs would avoid issuance of numerous purchase orders.
The FAR also states that, for a single firm, a BPA can be established from which numerous
individual purchases at or below the simplified acquisition threshold will likely be made in
a given period. However, based on our review of transactions involving 50 vendors, we
found that the services of only 4 vendors were appropriately acquired through BPAs. The
services of the remaining 46 vendors should have been acquired through the issuance of a
contract (26 vendors) or a purchase order (20 vendors).
- The Departmental Contracting Officers Warrant System Manual, Part III.A, states that
training forms can be used only to purchase standard off-the-shelf training courses and that
the cost of such training cannot exceed $25,000. We found, however, that Center officials
used training forms to purchase training that had been customized to meet the Center's needs
(thus, a purchase order should have been issued) and that it split training requirements into
multiple awards to avoid the $25,000 limitation. During the scope of our audit, Center
officials issued 23 training forms totaling $97,284 to vendors that provided customized
teaching courses.
- We reviewed purchases made by 10 of the 24 Center employees who were authorized
to use the purchase cards and found that 7 cardholders split 45 single purchases into 128
transactions totaling $313,000 during fiscal years 1998 and 1999 to avoid exceeding
limitations on their procurement authority. In one case, a former contracting officer whose
purchase card authority was limited to a one-time purchase of $25,000 made two purchases
of $22,425 each (classroom chairs) on her purchase card within an 8-day period. The
acquisition request stated that 150 chairs were needed. The chairs cost a total of $44,850.
A note attached to the request directed the contracting officer to charge this purchase "under
two MasterCard orders of $22,425 each," thus directing the contracting officer to exceed the
single purchase limit.
Contractor Payments
We found two instances in which the Center paid for products that were unauthorized or
services that were unacceptable. In one instance, the Center paid for equipment that,
according to the contract, should have been purchased by the contractor. In the other
instance, because the Center did not develop adequate specifications for a contractor-
performed inventory, the Center did not obtain needed information on Government property
assigned to contractors.
Recommendations
We recommend that the Director, FWS:
1. Establish and implement controls to ensure that competition is solicited and the
results are documented in the files for all types of acquisitions, including purchase order,
purchase card, BPA, and training form transactions.
2. Cancel all BPAs that are not for repetitive acquisitions whose totals are under $2,500.
If the goods and services are needed, the appropriate acquisition method, such as a purchase
order or a contract, should be used.
3. Implement controls to ensure that use of the training form is limited to off-the-shelf
training that does not exceed $25,000.
4. Implement controls to ensure that employees comply with acquisition threshold levels
for the use of the training form and/or purchase card.
5. Ensure that contracts contain provisions for compensating contractors for their
equipment purchases before authorizing payments to contractors for their equipment
purchases.
6. Ensure that future procurements of services for physical inventories include a detailed
statement of work that provides for delivery of a usable product.
FWS Response
In its August 25, 2000 response (Appendix 2) to the draft report, FWS agreed with these
recommendations and advised us that all recommendations have been implemented. Our
comments on the FWS response are provided in Appendix 3. B. PROPERTY MANAGEMENT
The FWS Manual (310 FW) requires that detailed accounting records for controlled property
and cost data be verified to ensure that data entered at the time of purchase are correct.
Further, FAR 45 requires that contractors maintain an inventory of all equipment furnished
by the Government regardless of value and that they perform inventories annually. FWS,
however, had not established adequate administrative controls over the Center's accountable
9and capitalized property, and as a result, the Center's automated Property Management
System included duplicate cost entries and other posting errors, and acquisitions were not
entered into the system. In addition, FWS had not established adequate administrative
controls over the Center's Government property furnished to contractors.
Property Verification
We randomly sampled 65 items from the 313 property items valued at $2.9 million listed in
FWS's Property Management System as of October 13, 1999. The sampled items were
tested to determine whether the property was in the custody of a designated Center employee
and whether the recorded property, the serial numbers, and the dollar value were correct. We
did not review computer software, structures, facilities, leaseholds, or land. We located and
verified that 38 sampled items with a value of $510,000 were properly accounted for by the
Center. However, we could not verify the custodianship or reporting accuracy of the
remaining 27 items.
Property Posting Errors
We found that the inventory was overstated by a net amount of $406,000 because five
posting errors totaling $502,000 were made by FWS's Contracting and General Services
Office, which inputs data into the Property Management System. This amount was offset
by $96,000 because the Office had not entered $59,000 in inventory adjustments that were
identified by the Center's property specialists and by another $37,000 because the Center had
not recorded property that we located at the Center.
We also selected 17 items of accountable property to determine whether these items were
recorded in the property records. We found that 7 of the items valued at $37,000 were not
in the property records.
During our audit, the Center's Property Specialist submitted correction sheets to the Office
for six sample items that needed either a property number or other identifying data. When
we obtained the updated property listing as of January 6, 2000, however, we found that the
Office had inadvertently deleted these six items, including a $15,000 computer server, from
the property listing. Until these items are corrected, the listing will be understated by
$59,000.
We believe that these property management system deficiencies were the result of not having
a property management official at the Center until July 1999. Prior to the appointment of the
property officer, none of the required custodial officers had been appointed, and no controls
were in place to ensure that property removed from the Center was accounted for. In
addition, no Center official was responsible for ensuring that property data entered into the
automated System were complete and accurate. Since the appointment of the property
officer, improvements have been made in addressing these issues. Custodial officers have
been appointed, internal controls have been established for tracking the use of Government-
owned property that is removed from the Center, and corrections have been made to
inaccurately recorded items. As of January 31, 2000, however, Center employees had not
completed all the processes to resolve and reconcile fiscal year 1999 inventory items and had
not ensured that all other errors identified during our review had been corrected.
Government-Furnished Property
Part 45 of FAR requires that contractors maintain a record of all equipment furnished by the
Government regardless of value, perform annual inventories, and report the results to the
contracting officer. The Center provides equipment to private firms and nonprofit
organizations under contracts and memoranda of agreement. We selected three contracts and
three agreements for review to determine whether these documents contained the necessary
language to protect the Government's interest in equipment furnished to others. We found
that the Center did not properly account for $3.4 million of Government property assigned
under the agreements because one of the agreements did not contain provisions requiring the
contractor to maintain an inventory and Center officials did not enforce provisions contained
in the remaining agreements. The Center also did not ensure that contract provisions were
enforced. For example:
- One contractor was authorized to acquire the equipment necessary to complete work
on a production facility and was required to account for this equipment, as well as any
equipment provided by the Center. Center officials, however, did not enforce the contract
provisions under which the contractor was responsible for about $2.6 million in Government-
furnished property. Specifically, no physical inventories were conducted by the Center or
the contractor, and the property records were not reconciled to inventory records. While
Center officials maintained a listing of equipment provided to the contractor, the list did not
contain information that was necessary for inventory record keeping of the property.
Recommendations
We recommend that the Director, FWS, direct the Center Director to:
1. Complete the fiscal year 1999 inventory and reconcile the inventory with data in
FWS's Property Management System. Once the reconciliation process is completed, FWS
should ensure that the System has complete and accurate information, including serial
numbers and acquisition costs, for each item.
2. Certify, through an annual physical inventory, that all property has been verified
and accounted for and fully document all adjustments.
3. Ensure that all Center memoranda of agreement and contracts include the
appropriate and necessary clauses to account for Government-furnished property.
4. Conduct a detailed physical inventory of all property assigned to contractors,
reconcile the inventory to any existing lists and/or source documents, and ensure that annual
inventories are conducted for all agreements and contracts that provide Government property
to contractors and other organizations.
FWS Response
In its August 25, 2000 response (Appendix 2) to the draft report, FWS agreed with these
recommendations and advised us that all recommendations have been implemented. Our
comments on the FWS response are provided in Appendix 3.
AUDIT STANDARDS
Our review was made, as applicable, in accordance with the "Government Auditing
Standards," issued by the Comptroller General of the United States. Accordingly, we
included such tests of records and other auditing procedures that were considered necessary
under the circumstances. As part of our audit, we evaluated internal controls in the
procurement and property management processes to the extent we considered necessary. We
found internal control weaknesses in the Center's procedures for procuring goods and
services and for recording, tracking, and verifying property used by Center personnel or
government contractors. Our recommendations, if implemented, should improve the internal
controls in these areas.
We also reviewed the Departmental Report on Accountability for fiscal year 1998, which
includes information required by the Federal Managers' Financial Integrity Act, and
determined that no reported weaknesses were within the objective and scope of our audit.
In addition, we reviewed FWS's Annual Performance Plans for fiscal years 1999 and 2000,
required by the Government Performance and Results Act, and determined that no
performance goals and measures were related to the Center's procurement and property
management functions.
PRIOR AUDIT COVERAGE
During the past 5 years, the General Accounting Office has not issued any audit reports on
FWS procurement and property management activities. The Office of Inspector General,
however, has issued one report, "Costs Billed by Aramark Services, Inc., for the Fiscal Year
Ended September 30, 1997, Under U.S. Fish and Wildlife Service Contract No. 1448-98695-
97-C001" (No. 99-E-153), in December 1998. The report, which addressed costs billed by
the Center's major contractor, did not take exception to any of the $1.4 million billed by the
contractor. APPENDIX 3
COMMENTS ON FWS RESPONSE
In its response, FWS provided comments on the finding and text of the draft audit report.
FWS's comments and our replies are as follows:
Background
FWS Response. FWS said that the draft report did not contain sufficient
background material on the Center for readers to better understand the context of our
findings and recommendations.
OIG Reply. We generally do not include material that is not pertinent to the scope
of our audit in the background; however, background information on the Center is provided
in FWS's response.
Procurement
FWS Response. FWS said that the report did not reflect the "significant
improvements [made by the Center] to its procurement processes since 1998" and that "most
of the findings in this report refer to practices conducted in the first two years of operation."
FWS further said that it believes it "provides high quality goods and services" at the Center
"at low cost."
OIG Reply. We reviewed Center procurement activities from October 1997 through
January 2000, a period that encompasses more than the first 2 years of the Center's
operations. Although FWS and Center personnel were responsive to our draft report's
recommended actions to improve Center procurement activity, we found no trend of
"significant improvements" in Center procurement actions during the scope of our review,
and we did not evaluate the quality of Center goods and services.
Competition and Competition/Purchase Orders
FWS Response. FWS said that "over half" of the purchase orders reviewed would
not be subject to the competition requirements of FAR 13.104. FWS further said that 30 of
the purchase orders were placed against supply schedules of the General Services
Administration (GSA), which offers goods at competitive prices. FWS further stated that
an additional 112 purchase orders were micro-purchases, which, according to FAR
13.202(a)(2), may be awarded without competition if the contracting officer considers the
price to be reasonable. FWS recommended that the report be "revised to more accurately
reflect the actual number of actions that required competition versus those that are not
subject to the requirements for competition."
OIG Reply. The FAR citation in the report states that contracting officers "shall
promote competition to the maximum extent practicable." Based on our review, we did not
find that such efforts were undertaken. Regarding the GSA schedule purchases, FAR states
that before placing an order, the contacting officer should consider reasonably available
information for the supply or service being offered that represents the best value. We found
that the contracting officer documented this process for 7 of the 30 schedule purchases
reviewed. Also, we agree that the requirements for documenting the solicitation of
competition for micro-purchases is not the same as for purchases over $2,500 and that FAR
provides for the award of micro-purchases without competition if the contracting officer
considers the price to be reasonable. However, we did not find that the contracting officer
had considered price prior to the award. In addition, the only micro-purchase transactions
included in our review were those made to vendors that received multiple, cumulative awards
or orders of more than $10,000. For example, 66 of the 130 micro-purchases reviewed were
awarded to 27 vendors who also received $709,611 BPA orders and/or training form awards.
The solicitation of competition was not documented for any of these awards.
Purchase Orders
FWS Response. FWS stated that the draft report "incorrectly implies" that work was
authorized on July 19, 1999 for the construction of museum cases but that a letter provided
by the vendor indicated that the work did not proceed until receipt of the purchase order on
July 30, 1999.
OIG Response. We deleted certain examples from our final audit report because
FWS concurred with and implemented all of the report's recommendations. Thus, the
examples were not needed to convince FWS that inappropriate procurement actions had
taken place. In the draft report, we discussed the museum case transaction to illustrate an
item that had been purchased by an employee who did not have procurement authority. In
this example, a vendor's proposal dated March 23, 1999 quoted a price of $17,108 to provide
the museum cases. The Museum Curator, who did not have procurement authority, accepted
the proposal on July 19, 1999, stating, "The above prices, specifications, and conditions are
satisfactory and are hereby accepted. You are authorized to do the work as specified." This
authorization to proceed with work was inappropriate.
Wage Standards
FWS Response. FWS disagreed with our use of the Department of Labor's wage
rates as a basis for evaluating the reasonableness of wages paid to the Center's contracted-for
employees. FWS cited the Service Contract Act of 1965, which it said requires contractors
to pay employees at least the wages and fringe benefits found by Labor to prevail in the local
community. It also said that these amounts may not be the same as the hourly rate that the
Government pays to obtain services from commercial contractors. FWS further said that the
"usual hourly rate paid to contractors by the Government is the sum of a 'market determined'
hourly rate plus overhead and profit" and that the rates paid appear to be fair and reasonable.
OIG Reply. We continue to believe that FWS overpaid for services because (1) the
awards for contract services (issued to individuals) were not issued on a competitive basis
and (2) there was no documentation on how the Center determined that its rates were
reasonable ($20 an hour to clean and store laboratory equipment and bottles, $35 an hour for
using the Internet to search for training opportunities, and $22 an hour to pay for the repair
of minor punch list items). Because the Center had no documentation on its "market
determined" hourly rate, we relied on the rates established by Labor and used Labor's highest
wage rates for a particular skill level for our wage comparisons. For example, we used
Labor's rate for journeymen carpenters as the basis for evaluating the reasonableness of the
hourly rate paid by the Center to employ laborers.
Acquisition Method/Purchase Cards
FWS Response. FWS stated that one of the examples cited in the draft audit report
as splitting orders "implies there was wrongdoing." FWS further said that the transaction
was well within the contracting officer's procurement authority and therefore was not a
violation of her authority or the policy in FAR 13.003(c) and that "[u]se of the purchase card
for payments is a preferred method, and the use of a purchase card for the purchase of . . .
furniture was proper."
OIG Reply. The example cited in our draft audit report referred to a contracting
officer who had procurement authority for the dollar amount of the purchase and for the use
of a purchase card to buy the items. However, the contracting officer's purchase card had
a $25,000 limitation on the amount of each purchase. Because the contracting officer bought
furniture that cost $44,850 using the purchase card and split the purchase into two
transactions of $22,425 each, she exceeded the one-time limitation.
Contractor Payments
FWS Response. Referring to our discussion of the Center's having inappropriately
purchased equipment for a contractor, FWS said that although the contractor's initial
proposal "included costs for equipment as required by the solicitation, . . . during
negotiations, the Government subsequently determined that it would provide existing
equipment to the contractor for use under the contract." According to FWS, while the
contractor's revised price excluded the cost of equipment, the contract was not revised to
reflect this change, and after the original contracting officer retired, the replacement
contracting officer "modified the contract to clearly reflect that equipment will be provided
by the Government."
OIG Reply. The contract files did not contain documentation that the Government
would provide the equipment. Section C of the contract clearly stated that it was the
contractor's responsibility to provide the equipment. On April 6, 2000, after we completed
our fieldwork, the contracting officer modified the contract to list the Government property
provided to the contractor and reiterated that the contractor was responsible for replacing the
listed equipment.
Property Management
In its response to our finding on property management, FWS said that the sentence in our
draft report regarding the property management position "could lead the reader to think that
there was no property management prior to April 1999." FWS added that it had managed
property at the Center prior to this date by "assigning these tasks as a collateral duty." FWS
further said that in early 1999, Center management "realized that the property management
activities had grown sufficiently to warrant a full-time Property Management Officer
position."
At the exit conference, FWS officials agreed that property management duties were not being
carried out efficiently through the collateral duty process. As stated in the report, prior to
the appointment of the property officer there were no custodial officers, no controls were in
place to ensure that property removed from the Center was accounted for, and no Center
official was responsible for ensuring that property data entered into the automated system
were complete and accurate. Since the appointment of a property officer, the Center has
made improvements in addressing these issues.