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To accomplish our objective, we reviewed applicable sections of the FAR and identified certain criteria from which to assess the CFPB's contract solicitation and selection processes and practices. This review would not have necessarily disclosed all instances of noncompliance or internal control weaknesses in areas not covered by our evaluation. Specifically, we assessed (1) whether the CFPB developed overall processes and procedures that facilitated compliance with particular FAR requirements and (2) the extent to which a sample of CFPB contracts complied with certain FAR guidance for performing acquisition planning, promoting competition, evaluating proposals, and reviewing contractor qualifications.
We also reviewed other relevant guidance, including GAO's Internal Control and Management Evaluation Tool, GAO's Standards for Internal Control in the Federal Government, and Office of Management and Budget guidance. In addition, we reviewed various CFPB procurement documents, including policies and procedures, organizational charts, position descriptions, training materials, and performance reports.
We interviewed CFPB procurement and program officials and staff, and we consulted another federal agency's procurement team to understand practices related to contract solicitation and selection.
We selected a sample of CFPB contracts awarded from October 1, 2010, through December 31, 2011, targeting contracts with large dollar amounts or those with a potential for large dollar amounts. We judgmentally selected a sample of 10 contracting actions that were above $150,000 or that did not have a specified ceiling amount. These 10 contracting actions included both task orders placed under established contracts or with government sources, as well as blanket purchase agreements.13
We conducted our fieldwork from December 2011 through September 2012 in accordance with the Quality Standards for Inspection and Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.