FDIC Oversight of a Telecommunications Contract

Develop, document, and communicate FDIC CIOO Executive Managers’ expectations for staff to comply with FDIC acquisition policies and procedures; and consequences for non-compliance or for creating an Unauthorized Contractual Commitment.

Develop, provide, and require periodic training to FDIC CIOO personnel on the following:
• Their roles, responsibilities, and limitations in interacting with contractors;
• The identification and avoidance of Unauthorized Contractual Commitments; and
• Disciplinary ramifications that may result from creating an Unauthorized Contractual Commitment.

Develop and implement FDIC CIOO processes to monitor and oversee internal controls for procurement activities, including ensuring the internal control environment is clearly understood, adhered to, and achieving its intended objectives and reporting out the results.

Identify which FDIC CIOO contracts do not have an assigned Technical Monitor, review whether a Technical Monitor(s) should be nominated and appointed and, in cases where a Technical Monitor should be nominated and appointed, ensure such nomination and appointment occurs, in compliance with FDIC guidance.

Develop and implement a process to document the Program Office’s analysis and conclusion for not nominating a Technical Monitor(s) when initiating or significantly modifying a contract.

Perform and document a periodic assessment that analyzes and determines the appropriate staffing level of Oversight Managers, including resources, time, and effort needed to comply with FDIC policies and procedures.

Develop a strategy to periodically assess workload imbalances and implement a strategy to address such imbalances among Oversight Managers in the FDIC CIOO.

Develop and implement a process to ensure proper communication of proposed contract changes or new procurement activities among the Program Office, Technical Monitor, Oversight Manager, and Contracting Officer, in order to avoid Unauthorized Contractual Commitments and overpayments, which in this case, resulted in $1.5 million in Funds Put to Better Use.

Develop and implement processes to identify and perform a secondary review of variations in invoice amounts and burn rates, and depletions in contract funds, in accordance with FDIC acquisition policies and procedures.

Develop and implement a process to report and track Procurement Requests and approvals to FDIC CIOO Executive Management.

Ensure that the FDIC Risk Inventory clearly articulates the risks related to the FDIC CIOO procurement activities and lack of a strong internal control environment and organizational culture surrounding its contract management.

Review the facts presented in this report, assess whether these facts support further management action related to the performance or conduct of any FDIC employee or FDIC contractor employee, and implement any management actions determined to be appropriate.