Report Number 13-12: The SBA Used Inappropriate Contracting Practices to Reconfigure Space for the Office of International Trade

This advisory memorandum presents the results of our audit of the Small Business Administration’s (SBA) procurement process used to reconfigure space for the Office of International Trade (OIT). This is the second of two audit reports related to the reconfiguration of OIT’s office space. We found that the Contracting Officer’s Representative (COR) inappropriately authorized the use of an existing contract to complete the OIT reconfiguration, and in doing so exceeded his authority. Additionally, the COR failed to develop a Statement of Work to ensure the requested work was completed in accordance with SBA’s requirements. Further, the COR and Contracting Officer (CO) did not review and approve the OIT invoice for the reconfiguration work in accordance with federal and SBA’s policy.

We recommended that the SBA (1) implement procedures to ensure that COs and CORs properly review invoices for compliance with the terms of the contract and the scope of work; (2) direct the CO, for purchase order SBA-HQ-11-M-0018, to review all invoices and make a determination of whether all work that was billed to the SBA was actually performed. If not, the CO should take appropriate action; (3) implement procedures to ensure the COs and CORs maintain supporting documentation of contract actions in the contract files as required by the Federal Acquisition Regulations; and (4) perform a review of the purchase order discussed in this report, focusing on the authority of the COR. If appropriate, initiate appropriate administrative action against the COR assigned to the purchase order.