An oversight program will generally include monitoring of the third partys quality of service, risk management practices, financial condition, and applicable controls and reports. When procuring Critical Functions, agencies considered strategic human capital planning analyzing agency staff resources, and internal capability and capacity. important initiatives, and more. An official website of the United States government. The FDIC, however, provided no details as to how it plans to do so. Phase 1: Procurement Planning - Program Office and DOA Acquisition Services Branch develop a management oversight strategy for the planned acquisition of a Critical Function, which includes determining the contract structure (key provisions). Determine the contract structure during the solicitation and award process for the procurement of a Critical Function. In addition to current practices, the FDIC plans to further address this recommendation through the study and actions described in our response to Recommendation 1. o Comparing and contrasting DOA, CIOO, and the Legal Divisions policy and procedures related to management procurement and oversight activities to best practices the OIG identified. SlVl&!MDs@bQ*P fA24k42P %c : In October 2020, the FDIC awarded BOAs to 10 vendors for Security and Privacy Professional Services (SPPS). Risks are identified from various sources and are captured in the risk inventory. Without the identification of procured Critical Functions and its associated risk, the FDIC may not accurately capture and assess the Agencys inherent and residual risk related to its contracts and contractors. In addition, if the FDIC determines contract services are essential in the event of an emergency or business continuity event, the statement of work or statement of objectives must include: Footnote: 6 The APM includes a descriptive list of inherently governmental functions and services and actions that are not inherently governmental functions. This list of inherently governmental functions is derived from the FAR (48 C.F.R. OMB Policy Letter 11-01 provides guidance on managing the performance of Inherently Governmental and Critical Functions. However, in relation to overseeing contractors who perform Critical Functions on behalf of the FDIC, the Agency procedures fell short in several important respects, including with respect to conducting periodic reviews to assess for over-reliance on the contractor. hMk1c[(1. Footnote: 12 According to the FDICs Acquisition Procedures, Guidance and Information (January 2020), a Basic Ordering Agreement (BOA) is a written instrument of understanding negotiated between the FDIC and a contractor for future delivery of as yet unspecified quantities of goods or services. To resolve these 12 recommendations, we would expect that the FDIC provide a clear indication of the specific actions within the next 6 months, and we will determine whether the recommendations may be converted to being resolved at that time, or whether they will remain as unresolved. For the 12 unresolved recommendations, the FDIC plans to consider and further study the issues and does not intend to implement corrective actions for another year (between March 31 and June 30, 2022). The partnership brings new innovations, tools and technologies that will help FDIC drive operational efficiencies, control IT costs and improve the user experience. [Text box Prior OIG report. hWr6}WS Footnote: 29 For Contract CORHQ-14-C-0778, the FDICs IGCE estimated that it would cost $26,387,825 to procure the services from a third party versus the estimated cost of $23,834,747 to perform the services internally with Federal employees, a variance of $2,553,077. While OMB Policy Letter 11-01 does not apply to FDIC procurements as a matter of law, the FDIC envisions developing (as an added component of our existing risk-based system) criteria for identifying a subset of contracts supporting essential FDIC functions or those that provide services in a business continuity event that will further enhance FDIC contract management consistent with the spirit the Policy Letter.
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