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We audited the U.S. Department of Housing and Urban Development’s (HUD) Office of the Chief Procurement Officer’s use of its quality assurance surveillance plan (QASP) for its Atlanta Homeownership Center field service management (FSM) housing contracts.  We initiated the audit to support HUD’s priority on increasing efficiency in procurement.  An assessment of HUD’s use of its QASP, as part of its 3.10 FSM 5-year contract solicitation, could help HUD improve its overall effectiveness in contract administration.  Our audit objective was to determine whether HUD effectively administered QASPs for its FSM contracts to assist in achieving HUD’s mission.

HUD’s Atlanta Homeownership Center did not effectively develop and implement a QASP for the six FSM contracts reviewed.  It did not (1) include all contract performance tasks requiring surveillance in its monitoring plans, (2) sufficiently review and accurately rate contractor performance, or (3) consistently document contractor performance in the Contractor Performance Assessment Reporting System (CPARS).  These conditions occurred because HUD lacked controls to ensure that the QASP was used for contractor performance monitoring.  Instead, HUD implemented a field service manager contract monitoring plan to measure contractor performance in a freestanding database, which did not include all performance standard tasks required for monitoring and did not align with the contracts’ acceptable quality levels of performance measurement.  As a result, HUD lacked the structure necessary to ensure that contractors were held accountable for their performance in accordance with contractual requirements.

We recommend that HUD’s Chief Procurement Officer (1) direct the contracting officers to update the QASP to include all minimum performance requirements and oversee the implementation of the QASP with HUD’s FSM contracts, (2) require the contracting officers to timely complete CPARS reports and submissions to the governmentwide system for use by all Federal agencies, (3) require all staff involved in FSM contracts’ oversight to maintain required documentation to support the contracts, and (4) require the contracting officers to designate contracting officer representatives in a timely manner.  We also recommend that the Acting Deputy Assistant Secretary for Single Family Housing ensure that contracting officer representatives (1) are involved with the development, implementation, and documentation of the FSM QASP to monitor contractor performance; (2) ensure that ratings are aligned with the contract; and (3) complete CPARS in a timely manner.

Recommendations

Chief Procurement Officer

  •   2023-BO-0002-001-A

    We recommend that the Chief Procurement Officer direct the contracting officers to review the current FSM contracts’ QASP and update accordingly to ensure that all minimum contract requirements are included.

  •   2023-BO-0002-001-B

    We recommend that the Chief Procurement Officer direct the contracting officers to oversee the implementation of the current FSM contracts’ QASP.

  •   2023-BO-0002-001-C

    We recommend that the Chief Procurement Officer require the contracting officers to implement the policies and procedures in the HUD Acquisition Policy and Procedure Handbook for completion of HUD’s FSM contractor performance assessment reports in CPARS to ensure that Government past performance is documented properly and in a timely manner, at least annually, for use by all Federal agencies and maintained in the contract files.

  •   2023-BO-0002-001-D

    We recommend that the Chief Procurement Officer require all staff involved in the oversight of FSM contracts to maintain the required documentation in the official contract file identified by HUD policy to support the contracts.

  •   2023-BO-0002-001-E

    We recommend that the Chief Procurement Officer update HUD’s field service manager contract monitoring plan and FSM qualitative monitoring databases used to monitor contractor performance to align with the QASP and contractual requirements as noted in recommendation 1G below.

  •   2023-BO-0002-001-F

    We recommend that the Chief Procurement Officer require the contracting officers to formally designate CORs in a timely manner and maintain the required documentation in the proper location identified in the relevant HUD policies and procedures, which fully supports the CORs’ oversight of the FSM contract.

Housing

  •   2023-BO-0002-001-G

    We recommend that the Acting Deputy Assistant Secretary for Single Family Housing coordinate with OCPO to require that the contracting officers and CORs be involved in the development, implementation, and documentation of the FSM QASPs for their FSM contracts to ensure that performance statements, acceptable quality levels, and deviation percentages are aligned with the contracts’ requirements in the performance work statement, the performance requirement summary, and the contractor’s quality control plan.

  •   2023-BO-0002-001-H

    We recommend that the Acting Deputy Assistant Secretary for Single Family Housing coordinate with OCPO to require the contracting officers and CORs to monitor contractor performance to ensure that evidence is maintained and documented in the contract files for each performance statement completed in the FSM QASPs and that contractor quality control report deliverables resolve problems identified by the Government during reviews conducted in accordance with the QASP for its future FSM contracts.

  •   2023-BO-0002-001-I

    We recommend that the Acting Deputy Assistant Secretary for Single Family Housing require the CORs to ensure that contractor past performance evaluations are prepared at least annually and as required by HUD policy to ensure that reporting of contractors is completed properly and in a timely manner for contract options and in CPARS.