PBGC Needs to Strengthen Oversight Controls Between CORs and Other Technical Personnel

Develop IPT processes and procedures for overseeing contractors to include integration of key roles into the procurement oversight process according to the Quality Assurance Surveillance Plan standards.

For IPT procurements including the Agile method, ensure IPT team members who participate in contractor oversight receive appropriate training on their roles and responsibilities.

Ensure CORs formally appoint technical monitors for overseeing the contractors and include in the appointment letter a detailed description of the monitoring responsibilities.

Ensure designated contracting officials document the acceptance of all deliverables in accordance with FAR, PBGC FARS, and/or contract requirements.

Improve controls to properly centralize, maintain and safeguard COR contract files, as required by the FAR and internal policies.

Ensure the annual COR file review process identifies improvements needed in COR files and communicates them to the CORs.

Require the PD to follow up on annual COR file reviews within 90 days to ensure the COR fixed any identified discrepancies.

Develop a Labor Hour invoice process to ensure CORs are properly reviewing supporting documents before they approve or reject contractor Labor Hour invoices.

Develop a control to ensure that options are exercised in accordance with contractual language. Implementing this recommendation could have ensured $1,442 would have been put to better use.

Provide training for individuals responsible for writing contracts to ensure requirements are clear and options comply with the FAR.