Report 2019-001-EOIG - Evaluation of EEOC’s Contracts Administration Activities

We reviewed 45 fiscal year 2018 contract files at the Equal Employment Opportunity Commission (EEOC). We found that some contract files had incomplete contract orders and were missing the Contracting Officer Representative (COR) acceptance page. In addition, progress reports were not found in any of the contract files. Although the files usually contained sub dividers and were organized, it was cumbersome to find contract administration documents in many of the folders.
We interviewed nine CORs and reviewed 20 COR contract files. We found that insufficient oversight of CORs and internal guidance contribute to incomplete COR documentation and uncertainty among CORs about how to perform their duties. We found 29 documents were missing from the files, including COR appointment letters, invoices, and progress reports. Five CORs expressed a need for more consistency among the Contracting Officers and three said they would benefit from more procedural guidance on how to perform their duties.
Lastly, we found that the Office of the Chief Financial Officer (OCFO) usually pays contractor invoices on time; however, the COR review and approval process causes significant delays. Of the 268 invoices in our sample, 56 (21 percent) were overdue. On average, OCFO paid the invoices within 9 days of the CORs approval. However, contract invoices were in the system an average of 64 days prior to the CORs approval. CORs stated that the invoice system does not notify them when vendors submit invoices, which may contribute to the payment delays. We issued five recommendations to improve EEOC’s contracts administration activities.