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CFPB Report: 2017-FMIC-C-007 March 30, 2017

The CFPB Can Strengthen Contract Award Controls and Administrative Processes

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In FY 2015, the CFPB obligated $244 million in contract awards. We assessed the agency's compliance with internal policies and the Federal Acquisition Regulation for soliciting and awarding contracts.

Though generally compliant with applicable laws and policies, on some occasions the CFPB's records were missing required documentation. For example, records for a $2.2 million sole-source contract did not include evidence of certain reviews and approvals. We found additional opportunities to strengthen the CFPB's internal control environment during acquisition planning, improve contract file documentation, better use performance goals, and improve communication with program offices during the acquisition process.

Our report includes several recommendations to address these findings.

Overview of the C.F.P.B.'s Contract Award Process. First, a purchase requisition is sent to CFPB Procurement. Second, Procurement management reviews the requisition and assigns a contracting officer (C.O.). Third, C.O. and the program office complete the acquisition package and the C.O. develops the solicitation. Fourth, there is a tier and legal review of the solicitation (when required). If the solicitation does not pass those reviews, it goes back to the previous step. Fifth, the C.O. distributes the solicitation and receives proposals. Sixth, the C.O. performs a price evaluation.  Seventh, the program office evaluation team performs a technical evaluation. Eighth, the C.O. writes the source selection decision document. Ninth, there is a tier and legal review of the award (when required). If the award does not pass those reviews, it goes back to the previous step. Finally, the C.O. makes the award to the vendor.