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April 9, 2015

Some Deficiencies Exist in DOT’s Enforcement and Oversight of Certification and Warrant Authority for Its Contracting Officers

Self-Initiated
Project ID: 
ZA2015041
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In fiscal year 2014, the Department of Transportation (DOT) obligated $2 billion on contracts. DOT’s contracting officers (CO) are responsible for awarding and managing a significant portfolio of contracts. To help ensure these contracts meet Federal and departmental requirements, the Office of Federal Procurement Policy (OFPP) requires that COs be certified at the appropriate level to correspond with the dollar value of contracts they are authorized to award and administer. OFPP also directed each agency’s chief acquisition officer to establish agency-specific certification and warrant requirements.

Of the 63 COs we reviewed, 15 (24 percent) did not fully comply with these requirements. For example, 10 COs had expired certifications who approved over 3,000 contract actions and obligated over $731 million. While the Department’s acquisition workforce policies align with Federal requirements, a few policy areas are unclear or do not reflect current practices. Additionally, some Operating Administrations do not always enforce these policies, as DOT lacks a clear policy for enforcing their compliance with CO certification and warrant requirements. Failure to enforce certification and warrant requirements creates risks that DOT’s complex, high-dollar acquisitions may be awarded and administered by COs who lack appropriate training and experience. DOT concurred with the seven recommendations we made to improve oversight of CO warrant and certification practices.

Recommendations

Open

Closed

Closed on 04.04.2018
No. 1 to OST

That the Office of the Senior Procurement Executive address the cases of noncompliance with CO certification and warrant requirements at FMCSA, FRA, MARAD, and NHTSA, as noted in this report. Specifically, the Operating Administrations should ensure that (a) CO warrants are issued in compliance with Federal and departmental requirements and (b) COs obtain and maintain their FAC-C certifications.

Closed on 12.30.2015
No. 2 to OST

We recommend that the office of Senior Procurement Executive update departmental policies to (a) clearly require immediate revocation or modification of warrants upon expiration of FAC-C certifications and (b) define the role of the Operating Administrations' ACMs.

Closed on 12.30.2015
No. 3 to OST

That the Office of the Senior Procurement Executive update departmental policies to require OSPE to conduct periodic reviews of Operating Administrations' compliance with DOT's AWF policy and to correct deficiencies identified during these reviews as necessary.

Closed on 04.04.2018
No. 4 to OST

That the Office of the Senior Procurement Executive direct the Heads of Contracting Activity at each Operating Administration to: (a) develop and implement, oversight procedures to ensure compliance with DOT's AWF policy including procedures for annual reviews of level I and II CO warrants and reviews of level III warrants at least every 2 years to determine if COs remain qualified to perform their duties and there is a continued need for warrants and (b) report to OSPE on their oversight procedures.

Closed on 04.04.2018
No. 5 to OST

That the Office of the Senior Procurement Executive direct the Heads of Contracting Activity at each Operating Administration to (a) review CO warrants to ensure they include required elements and restrictions specified in DOT's AWF policy, (b) address any instances of noncompliance, and (c) report their planned and implemented corrective actions to OSPE within established timeframes.

Closed on 04.04.2018
No. 6 to OST

That the Office of Senior Procurement Executive correct the FAITAS data inaccuracies noted in this report at FTA and MARAD.

Closed on 12.30.2015
No. 7 to OST

That the Office of Senior Procurement Executive update departmental policies to require Operating Administrations monitor FAITAS data to ensure that CO warrant and certification data are current, complete, and accurate.