OIG makes 17 recommendations for NCUA contracting rep program

There are 17 recommendations for improvements for the federal credit union regulator’s contracting officer’s representative program (COR) in an inspector general’s report dated Tuesday.

The report by the National Credit Union Administration’s (NCUA) Office of Inspector General (OIG) explains that the NCUA’s CORs are delegated responsibilities to oversee contractor performance on behalf of the agency’s contracting officers. The agency’s Acquisition Policy Manual (APM) requires a COR delegation for all procurement actions exceeding $10,000, with limited exceptions. It said CORs must be fully qualified in accordance with the COR certification program as outlined in a nomination letter and must accept the duties and responsibilities outlined in the COR appointment letter.

The self-initiated audit covered contracts during period of calendar 2020-2021 and COR certification training in fiscal years 2018-2021. The NCUA’s 2020-2021 budget justification included $43.3 million for contracted services, which was approximately 14% of the agency’s operating budget, the report notes.

The audit was to determine whether the NCUA adhered to its APM regarding the COR program and whether: (1) staff serving in the role of COR have been appropriately nominated, appointed, and received training/certification; and (2) appointed CORs were performing contract administration in accordance with applicable policies and procedures.

The OIG wrote that its audit determined the NCUA’s COR program needs improvements in seven areas: (1) the maintenance of COR documents; (2) the invoice review process; (3) the accountability of CORs; (4) the timeliness of COR certifications after completing training; (5) the timeliness of replacing CORs; (6) the contract closeout process; and (7) providing names of nominated CORs to the NCUA Office of Ethics Counsel (OEC).

Below are some excerpts from audit findings:

  • We determined contracting officers and CORs did not consistently maintain their contract files. Specifically, we determined that for 38% (62 of 165) of the contracts monitored by CORs, the contracts were missing, on average, 28% of the documents that should have been maintained in the files.
  • We determined that CORs did not consistently process invoices for payment in accordance with the APM.
  • We determined CORs were not held accountable for their COR duties and responsibilities despite having a significant role in the procurement cycle to ensure the NCUA obtains its goods and services at contracted prices.
  • We determined CORs were not timely certified after completing their required COR training.
  • We determined the NCUA did not timely nominate and appoint new CORs when previously appointed CORs departed the agency.
  • We determined the NCUA’s contract closeout process could be improved.
  • We determined that Division of Procurement Facilities Management (DPFM) officials did not provide the names of nominated/appointed CORs to the NCUA’s Ethics Official as required by the APM.

Of the 17 recommendations made, 11 are attributed to updating the APM; three are directed to the (DPFM); two are directed to the Office of Human Resources (OHR); and one is for the OEC.

Audit of the NCUA’s Contracting Officer’s Representative Program (Report #OIG 23-06) May 16, 2023