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Sixth Semiannual Report to the Congress - Federal Housing ...

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No. Recommendation Report Status<br />

AUD-2013-002-4<br />

The Director of the Office of Budget<br />

and Financial Management should<br />

issue guidance to all acquisition staff<br />

and approving officials, including<br />

contracting officers and contracting<br />

officer’s representatives, on:<br />

• cost allocation and proper<br />

procedures for assigning costs<br />

to contracts in accordance with<br />

benefits received and based on the<br />

appropriate cost objective;<br />

• proper procedures for ensuring that<br />

contract employees meet labor<br />

category qualifications specified<br />

in time and material/labor hour<br />

contracts;<br />

• proper procedures for obtaining<br />

sufficient justification prior to<br />

increasing funds, adjusting fixed<br />

labor rates, and approving payments<br />

on time and material contracts;<br />

• appropriate procedures for<br />

evaluating contractor price<br />

proposals and documenting<br />

the agency’s pre-negotiation<br />

position prior to awarding contract<br />

modifications; and<br />

• appropriate use of contractor<br />

employees to substitute for internal<br />

agency positions and approving<br />

invoices based on contractual terms<br />

and provisions.<br />

FHFA’s Oversight of<br />

Contract No. FHF-<br />

10-F-0007 with<br />

Advanced Technology<br />

Systems, Inc.<br />

Recommendation<br />

agreed to by FHFA;<br />

implementation of<br />

recommendation<br />

pending.<br />

AUD-2013-002-5<br />

The FHFA contracting officer should<br />

remove the $105,000 of excess funds<br />

from contract line item number 1 to<br />

account for technical writing services<br />

ATSC was no longer required to<br />

perform under the contract line item<br />

number. Thereafter, the contracting<br />

officer should compare the new<br />

contract ceiling to the actual amount<br />

ATSC billed against contract line<br />

item number 1 and recapture any<br />

unallowable costs that exceed the new<br />

ceiling price.<br />

FHFA’s Oversight of<br />

Contract No. FHF-<br />

10-F-0007 with<br />

Advanced Technology<br />

Systems, Inc.<br />

Recommendation<br />

agreed to by FHFA;<br />

implementation of<br />

recommendation<br />

pending.<br />

92 Federal Housing Finance Agency Office of Inspector General

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