Contractor Integrity and Fitness

This graphic focuses on SRA, which is on the top level of the ISC Governance Structure.

The top level of governance is made up of three parts, the Award Fee Evaluation Board, FEDSIM, and SRA. The Millennia Contract for the ISC is between FEDSIM and SRA. FEDSIM also provides input to the Award Fee Evaluation Board.

We sampled six subcontractors engaged by SRA to provide services under the ISC and found that one had not completed Integrity and Fitness Representations and Certifications required by 12 Code of Federal Regulations Part 366. DIT and SRA officials advised us that this particular subcontractor did not complete the Integrity and Fitness Representations and Certifications because the subcontractor is considered to be a “vendor,” and as such, its services are exempt from the requirements of Part 366. However, such an exemption does not exist under Part 366. Subsequent to our fieldwork, DIT obtained the Integrity and Fitness Representations and Certifications for this subcontractor. Accordingly, we are not making a recommendation in this area.

The FDIC generally completed background investigations, confidentiality agreements, and contractor pre-exit clearance procedures for the contractor and subcontractor employees that we sampled. However, we did note some exceptions. DIT and DOA should place additional emphasis on ensuring that such procedures are consistently followed. We are not making a recommendation, however, because OIG Evaluation Report No. EM-08-002, Information Technology Procurement Integrity and Governance, includes a recommendation to address our concerns.

The FDIC does not have a corporate program for conducting periodic audits of contractor invoices to ensure that billed costs are allowable, allocable, reasonable, and consistent with contractual terms and conditions. The OIG is establishing a risk-based contract audit program to address this issue; accordingly, we are making no recommendation in this area.

Read the following text for a description of the ISC governance structure.

The first level of governance is made up of three parts, the Award Fee Evaluation Board, FEDSIM, and SRA. The Millennia Contract for the ISC is between FEDSIM and SRA. FEDSIM also provides input to the Award Fee Evaluation Board.

FEDSIM has an interagency agreement with the FDIC, while SRA provides IT services and reports to the FDIC.

The second level of governance and all following levels are within the FDIC. The second level consists of the ISC Oversight Committee.

The third level of governance consists of ISC Program Management (Program Manager and supporting Subject Matter Experts), DIT’s Procurement Management Board, and the Division of Administration Acquisition Services Branch (ASB). The ISC Oversight Committee (from the second level of governance), ISC Program Management and ASB all provide input to the Award Fee Evaluation Board (in the first level of governance). ISC Program Management and ASB also participate in the ISC Oversight Committee.

The fourth and final level of governance consists of four groups that provide input to ISC Program Management (in the third level of governance). The four groups are Operations, Security, Engineering, and Asset Management and Procurement. Each group has a technical monitor and supporting subject matter experts.