It may become tempting for protocol and attentiveness to detail to take a backseat in the face of crises; however, this puts government agencies at more of a risk from procedural error and fraudulent infiltration. To combat this, the Department of Defense released a report on best practices and lessons learned for contracting officials in the pandemic environment.

Below, we have summarized key takeaways from the report:

Communication and Coordination

  • Maintain communication between contracting personnel and contractors.
  • Communicate with FEMA officials to ensure that FEMA’s requirements are being met and that FEMA officials are aware of the DoD’s ongoing response efforts.
  • Communicate and coordinate throughout all stages of the process.

Documentation

  • Ensure that contracting personnel are keeping documentation of important decisions in the contract files.
  • The methodology and results of contractor oversight through observations and testing and any remedial and corrective actions taken.

Consistency in Contracting Process

  • Ensure that contracts and task orders are accurate and complete when awarded to the contractor.
  • Ensure that contractor quality control plans meet the minimum level of detail required by agency policy.
  • Instruct the contracting personnel to comply with the Federal Acquisition Regulation and establish a method of validating contractor invoices before authorizing payment. 

Staffing and Training

  • Ensure the use of long-term Government employees for program management and key technical positions that exercise oversight over contract employees.
  • Ensure that sufficient staff are available and trained on requirements in the contract, the documentation required to support payment of contractor invoices, and the performance of quality assurance activities.
  • Establish and ensure, to the maximum extent possible, proper segregation of duties.

Undefinitized Contract Actions

  • Establish and manage a definitization schedule and continually coordinate the schedule with contractors;
  • Hold contractors accountable for not providing qualifying proposals in accordance with regulations
  • Manage the allowable profit based on whether the Government or contractor bears the risks associated with the UCA;
  • Definitize UCA awards as soon as is practical to do so.

Potential Procurement Fraud Schemes

  • Phantom vendors (creating a fictitious entity to create false invoices), providing counterfeit or substituted materials other than those identified in the contract.
  • Conflicts of interest between Government and contractor personnel.
  • Bribes and kickbacks.
  • Double or falsified invoices presented for payment.
  • Anti-competition agreements between vendors.

Tips to Avoid Potential Fraudulent Activity

  • Verify the identity of companies and individuals that offer assistance.
  • Check past performance of companies through the Contractor Performance Assessment Reporting System.
  • Review the articles of incorporation.
  • Search for company addresses to determine whether addresses are residential.

Read the full report online.

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