United States Government Accountability Office

GAO Report to the Ranking Minority 

Member, Committee on Oversight and 

Government Reform, House of 

Representatives 

DISTRICT OF 

COLUMBIA 

Procurement System 

Needs Major Reform 

January 2007 

 

GAO-07-159 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2007

DISTRICT OF COLUMBIA 

Procurement System Needs Major 

Highlights of GAO-07-159, a report to the Reform 

Ranking Minority Member, Committee on 

Oversight and Government Reform, 

House of Representatives

To improve acquisition outcomes,

in 1997 the District established the 

Office of Contracting and 

Procurement under the direction of 

a newly created chief procurement 

officer (CPO). Since then, the 

District’s inspector general and 

auditor have identified improper 

contracting practices. 

This report examines whether the 

District’s procurement system is 

based on procurement law and 

management and oversight

practices that incorporate generally

accepted key principles to protect 

against fraud, waste, and abuse. 

GAO’s work is based on a review of 

generally accepted key principles

identified by federal, state, and

local procurement laws, 

regulations, and guidance. GAO

also reviewed District audit reports 

and discussed issues with current 

and former District officials as well

as select state and local officials. 

What GAO Recommends

GAO recommends that the

District’s Mayor submit a 

procurement reform plan to 

Congress. The former Mayor chose 

not to comment, but the new 

administration indicated 

concurrence with most of GAO’s

recommendations and intends to 

provide a plan within 60 days of the

public release of this report. 

Comments from the Chief Financial 

Officer were limited to the section

on direct vouchers. They indicated

current review of their policy and 

GAO encourages implementation 

of this report’s recommendations. 

The District’s procurement law generally does not apply to all District 

entities nor does it provide authority to the CPO to effectively carry out and 

oversee the full scope of procurement responsibilities across all agencies. A 

lack of uniformity in its procurement law and the CPO’s limited authority not 

only undermines transparency, accountability, and competition but also 

increases the risk of preferential treatment for certain vendors and 

ultimately drives up costs. The current law exempts certain entities and 

procurements from following the law’s competition and other requirements, 

and according to current and former District procurement officials, there is a 

push to expand independent procurement authority—a move that would 

reverse action taken by the District a decade ago. Other provisions of 

current law further erode competition. Notably, the law provides broad 

authority for sole source contracting and establishes high-dollar thresholds 

for small purchases, which are generally not subject to full and open 

competition. Also, in implementing the law, sufficient management 

oversight is lacking to ensure employees do not make unauthorized 

commitments. 

The District has been challenged to effectively manage and oversee its 

procurement function, due in large part to the low-level position of the 

procurement office in the governmental structure, the rapid turnover of 

CPOs, and multiple players having authority to award contracts and affect 

contract decisions. At the same time, the District does not have the basic 

tools that contracting and agency staff and financial managers need to 

effectively manage and oversee procurements—including a procurement 

manual, a professional development program, and an integrated 

procurement data system. 

In summary, the District’s procurement system does not incorporate a

number of generally accepted key principles and practices for protecting 

taxpayer resources from fraud, waste, and abuse. Specifically, the District 

lacks a comprehensive procurement law that applies to all District entities

over which the CPO has sole procurement authority and promotes 

competition; an organizational alignment that empowers its procurement 

leadership; an adequately trained acquisition and contracting workforce; and 

the technology and tools to help managers and staff make well-informed 

acquisition decisions. 

To better ensure every dollar of its more than $1.8 billion procurement 

investment is well spent, it is critical that the District have a procurement 

system grounded in a law that promotes transparency, accountability, and 

competition, and helps to ensure effective management and oversight and 

sustained leadership. High-level attention and commitment from multiple 

stakeholders—including Congress—are needed if the District’s procurement 

law is to provide the right structure and authority and if procurement 

reforms are to succeed. 

www.gao.gov/cgi-bin/getrpt?GAO-07-159.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Ann CalvaresiBarr, (202) 512-4841 or 

calvaresibarra@gao.gov. 
Contents 

Letter 1

Results in Brief 2 

Background 4

The District’s Procurement Law Does Not Promote Transparency, 

Accountability, and Competition 11 

The District’s Procurement System Does Not Reflect Sound 

Management and Oversight Practices 30 

Conclusion 42

Recommendations for Executive Action 43 

Agency Comments and Our Evaluation 46 

Appendix I Scope and Methodology 48 

Appendix II District Governance and Related Procurement

Authorities 52 

Appendix III Comments from the Chief Financial Officer for the 

District of Columbia 59 

Appendix IV GAO Contact and Staff Acknowledgments 66 

Tables 

Table 1: District Entities Procuring through the Office of 

Contracting and Procurement as of October 2006 6 

Table 2: District Procurement Law Provisions Permitting SoleSource Contracting and Awards in Fiscal Year 2005 under 

These Provisions 18 

Table 3: Limited Competition Procedures for Small Purchases in 

the District of Columbia 21 

Table 4: DCSS Program Schedule Categories and Number of 

LSDBE Vendors (as of October 27, 2006) 25 

Page i GAO-07-159 District of Columbia Procurement
Figure 

Figure 1: The Office of Contracting and Procurement Placement in 

the District of Columbia’s Government Structure 32 

Abbreviations 

ABA American Bar Association 

CFO Chief Financial Officer 

CPO Chief Procurement Officer 

DCSS District of Columbia Supply Schedule 

FAR Federal Acquisition Regulation 

GSA General Services Administration 

LSDBE Local, Small, and/or Disadvantaged Business Enterprise 

MAS multiple award schedule 

NASPO National Association of State Procurement Officials 

OCTO Office of the Chief Technology Officer 

PASS Procurement Automated Support System 

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Page ii GAO-07-159 District of Columbia Procurement
United States Government Accountability Office

Washington, DC 20548 

 

January 19, 2007 

The Honorable Tom Davis 

Ranking Minority Member 

Committee on Oversight and Government Reform 

House of Representatives 

Information from the District of Columbia’s lead contracting office and

other sources indicate that in fiscal year 2005, more than $1.8 billion—

almost 22 percent of the city’s $8.2 billion budget—was spent on 

procurement. To maintain public trust and fulfill public policy objectives,

an effective procurement system should provide timely acquisition of the 

right goods and services while efficiently addressing agency needs and 

obtaining the best value for taxpayer dollars. The success of any public 

procurement system is rooted in law and policies with appropriate internal 

controls, which if adhered to through effective management and oversight,

promote transparency, accountability, competition, and ultimately protect 

resources from fraud, waste, and abuse. 

The District’s history of procurement problems—which include poor 

planning, excessive use of sole source contracts, and unauthorized 

personnel committing government resources—is well documented. 

Contracts have suffered from poorly defined requirements, noncompliance 

with procurement rules, and avoidance of competition. Almost 10 years 

ago in an effort to improve its procurement outcomes and promote 

oversight and accountability, the District amended its procurement law—

the Procurement Practices Act of 1985.

1

 A key component of the 

amendment was the establishment of the Office of Contracting and 

Procurement to centralize the District’s acquisition function under the 

direction of a newly created chief procurement officer (CPO). Since then, 

the District’s inspector general’s and auditor’s offices as well as numerous 

press reports continue to identify improper contracting practices across 

various District entities.2

 1

 The Procurement Practices Act of 1985, codified as amended in D.C. Official Code § 2-

301.01 et seq., is the District’s primary procurement law and is implemented through Title 

27 of the District of Columbia Municipal Regulation. 

2

 For purposes of this report, the term “entities” refers to the various District departments, 

agencies, boards, and commissions. 

Page 1 GAO-07-159 District of Columbia Procurement
Given these circumstances, you asked us to assess the District’s 

procurement system. Specifically, we examined the extent to which the 

District’s (1) procurement law incorporates generally accepted key 

principles that promote transparency, accountability, and competition and 

(2) procurement system reflects sound management and oversight 

practices. Our assessment also addresses recent actions the District has 

taken to address persistent procurement challenges. 

To conduct our work, we reviewed the relevant District procurement laws 

and regulations, and compared them with generally accepted key public

procurement principles and best practices from a variety of sources, 

including the National Association of State Procurement Officials 

(NASPO), the American Bar Association (ABA) model procurement code, 

the Federal Acquisition Regulation (FAR) as well as our prior work on 

effective procurement practices. To obtain perspectives from others on 

the District’s past and current procurement management challenges, we 

reviewed various studies with recommendations that led up to the 1997 

reorganization to establish the Office of Contracting and Procurement 

headed by a CPO as well as selected District inspector general and auditor

reports since 2004. We interviewed current and former procurement, 

executive, financial management, and auditing officials in the District to 

discuss organizational, management, and policy challenges; procurement 

reform; and related issues. We also spoke with state government 

procurement leaders of NASPO about sound public procurement 

principles and practices regarding public procurement and their views on 

issues we raised about the District’s system. In addition, we visited 

Atlanta, Baltimore, and New York City to interview city procurement 

officials about their views on issues we raised concerning the District’s 

system and to learn about related challenges they have faced and their 

responses to these challenges. Appendix I presents our scope and 

methodology in more detail. We conducted our work between February 

and October 2006 in accordance with generally accepted government 

auditing standards. 

The District’s procurement law as currently in effect generally does not 

incorporate accepted key principles of sound procurement as established 

by NASPO, the ABA model procurement code, and the FAR. As a result, 

the law fails to adequately promote transparency, accountability, and 

competition to reduce the risk of fraud, waste, and abuse. Although it 

recognizes the role of a CPO—a key component of a comprehensive 

procurement law—the law falls short in a number of other key areas. First, 

despite calling for uniform procurement procedures District 

Results in Brief 

Page 2 GAO-07-159 District of Columbia Procurement
governmentwide, the law does not apply to several District entities, 

including some that spend tens of millions of dollars a year to contract for 

goods and services. According to many officials we spoke with, this lack 

of uniformity severely hampers transparency and accountability and 

increases the risk of preferential treatment of vendors, discourages 

competition, and ultimately drives up costs. Second, the law fails to 

provide authority to the CPO to effectively carry out and oversee the full 

scope of procurement responsibilities across all entities. Third, the law has 

frequently been amended to grant exemptions to its provisions and the 

CPO’s authority for certain entities and special procurements. Current and 

former CPOs, as well as NASPO and other city procurement officials, 

noted that these exemptions distort the District’s law, undermine efforts to 

establish a central authority, and circumvent the competitive process. 

Finally, the law allows the use of noncompetitive contracting methods, 

such as sole-source contracting, under broad exceptions. It further allows 

higher dollar thresholds for small purchases than are allowed in other city

and federal regulations, including the FAR; mandates the use of a District 

supply schedule with a limited list of local vendors for purchases of a 

specified threshold; and allows agencies under certain circumstances to 

bypass the District’s contracting rules to directly pay vendors without 

valid contracts—payments that accounted for as much as $217 million in 

fiscal year 2004. Ultimately, these provisions in the law create barriers to 

competition—the basic tenet of an effective public procurement system. 

In addition to generally lacking a law that reflects accepted key principles 

of sound procurement, the District has been challenged to effectively 

manage and oversee its procurement system. The low-level position of the 

procurement office within the District’s governmental structure, combined

with rapid turnover of five CPOs in the past 10 years, has resulted in 

fragmented and inconsistent procurement management and oversight with 

multiple players having authority to award contracts and affect 

procurement decisions. According to former District CPOs, the low 

organizational placement weakened their ability to direct, coordinate, and 

oversee procurement activities across the District’s entities. Each of the 

appointed CPOs cited their lack of influence and control over the 

acquisition function as a major reason for resigning their position before 

the end of their tenure. At the same time, contracting and agency staff and 

financial managers do not have the basic tools needed for effective

procurement management and oversight. Specifically, the District lacks a

procurement manual, a professional development program for contracting 

staff, and an integrated procurement data system—key tools for guiding 

District procurements and helping contracting and agency staff carry out 

their responsibilities. Officials from the other cities we reviewed have 

Page 3 GAO-07-159 District of Columbia Procurement
overcome similar challenges by reorganizing and elevating the acquisition 

function within their city’s governmental structure and implementing a 

variety of tools to strengthen the procurement system’s management and 

oversight. 

We are making a comprehensive set of recommendations to the Mayor of 

the District of Columbia to seek reform of the District’s procurement law 

and system in order to help promote transparency, accountability, 

competition, and minimize fraud, waste, and abuse. Our recommendations 

focus on establishing a procurement system that incorporates key 

procurement principles and practices identified by NASPO, the ABA 

model procurement code, and the FAR. To help ensure the District takes 

action and sustains improvements to its procurement system and to 

facilitate congressional oversight, we are also recommending that the 

Mayor develop and submit to Congress a comprehensive plan and 

schedule for carrying out major procurement system reform in line with 

our recommendations. 

After reviewing a draft of this report, the office of the outgoing Mayor 

declined to comment.3

 However, in oral comments, the new administration 

indicated concurrence with most of our findings and recommendations 

and intends to provide an action plan within 60 days of the public release 

of this report. Although most of our recommendations are directed to the 

Mayor’s office, we also made recommendations to the Chief Financial 

Officer (CFO). In written comments, the CFO disagreed with our findings 

related to the use of direct vouchers for procurement-related transactions. 

They are reviewing their policy on direct vouchers and we encourage them

to implement our recommendations as well as work with the Mayor’s 

office to coordinate procurement reform actions as applicable. The CFO’s

comments are included in appendix III along with our comments. 

For fiscal year 2005, the District’s Office of Contracting and 

Procurement—its lead contracting office—reported conducting over 

20,000 transactions valued at $1.2 billion on behalf of 55 District entities, 

five of which accounted for $596 million (see table 1 for the departments, 

agencies, and other entities reporting procurements through this office). 

Over two-thirds of the District’s procurement dollars managed through the 

Background 

 3

 On January 2, 2007, Anthony Williams ended his term and Adrian Fenty began his term as 

Mayor of the District of Columbia. 

Page 4 GAO-07-159 District of Columbia Procurement
lead contracting office was spent on professional and public safety 

services, human care, and road and highway construction. In addition, 

some District entities, including the Board of Education for District of 

Columbia Public Schools and the Department of Mental Health, procure 

independently of the lead contracting office.4

 According to information 

available from District sources, these entities spent over $600 million in 

fiscal year 2005. 

 4

 According to the Office of Contracting and Procurement, the following District entities 

procure independently of this office: Board of Education (for the public schools); Office of

the Chief Financial Officer; Child and Family Services Agency; Washington Convention

Center; District of Columbia (D.C.) Council; D.C. Court System; D.C. Housing Authority; 

D.C. Housing Finance Agency; D.C. Public Service Commission; D.C. Retirement Board;

Department of Mental Health; Pretrial Services Agency; Public Defender Service; Sports 

Commission; and the Water and Sewer Authority. The Board of Education is exempted 

from the Office of Contracting and Procurement in soliciting, awarding, and executing 

contracts for the public schools, except for security contracts that began on or after June 

30, 2005 (D.C. Official Code § 2-301.04(d)). 

Page 5 GAO-07-159 District of Columbia Procurement
Table 1: District Entities Procuring through the Office of Contracting and Procurement as of October 2006 

Office of Administrative Hearings 

Office on Aging 

Alcoholic Beverage Regulation Administration 

Commission on Arts and Humanities 

Office of the Attorney General 

Office of Boards and Commissions 

Office of Cable TV and Telecommunications 

Office of Campaign Finance 

Office of Chief Medical Examiner 

Office of the Chief Technology Officera 

Office of the City Administrator

Department of the Consumer and Regulatory

Affairs 

Office of Contracting and Procurement 

Department of Corrections 

Contract Appeals Board 

Office of the Deputy Mayor for Children, 

Youth, Families and Elders 

Office of the Deputy Mayor for Operations 

Office of the Deputy Mayor for Planning & 

Economic Development 

Office of the Deputy Mayor for Public Safety 

and Justice 

Board of Elections & Ethics 

Emergency Management Agency 

Office of Employee Appeals 

Department of Employee Services 

Energy Office 

Fire and Emergency Medical Services 

Department of Healtha 

Department of Human Servicesa 

Department of Housing and Community 

Development 

Office of Human Rights 

Department of Insurance, Securities, and 

Banking 

Commission on Judicial Disabilities and 

Tenure 

Justice Grants Administration

Office of Labor Relations and Collective 

Bargaining 

Office of Latino Affairs 

Metropolitan Police Departmenta

 

Office of Motion Pictures and Television 

Development 

Department of Motor Vehicles

Executive Office of the Mayor

Office of the Neighborhood Action 

Department of Parks and Recreation 

Office of Partnerships and Grants 

Development 

Office of Planning 

Office of Police Complaints 

Office of Property Management 

Public Employee Relations Board 

Public Library 

Department of Public Works 

Board of Real Property Assessments 

and Appeals 

Office of Risk Management 

Serve DC 

Department of Small and Local 

Business Development 

Office of State Education 

Taxicab Commission 

Department of Transportationa

 

Office of Tuition Assistance Grant 

Program 

University of the District of Columbia 

Department of Youth Rehabilitation 

Services 

Office on Zoning 

Office of Personnel 

Personal Property Division

Source: Office of Contracting and Procurement. 

Note: GAO did not independently verify all the entities. We relied on information provided by the 

Office of Contracting and Procurement and did some limited reliability assessment through the course 

of our work and found the information to be sufficiently reliable for our purposes. Of the entities 

served by the Office of Contracting and Procurement, 55 provided fiscal year 2005 procurement data.

a

One of the top five spending agencies in fiscal year 2005 in terms of millions of dollars spent on 

procurement. Specific reported amounts in procurement spending were $180 million (Department of

Transportation); $123 million (Office of the Chief Technology Officer); $123 million (Department of 

Health); $110 million (Department of Human Services); and $59 million (Metropolitan Police 

Department). 

The District also has special requirements related to being the seat of the

federal government. The fiscal relationship between the federal 

government and the District as well as city governance have been 

perennial questions for Congress, and the District’s local autonomy has 

Page 6 GAO-07-159 District of Columbia Procurement
evolved significantly in the last 30 years.5

 In 1973, Congress enacted the 

District of Columbia Self-Government and Governmental Reorganization 

Act or Home Rule Act,6

 which established the structural framework of the 

current District government. The Home Rule Act allowed for an elected 

Mayor and a council with certain delegated legislative powers. However, 

Congress explicitly reserved legislative authority over the District.7

 The 

Home Rule Act generally provides a framework and processes for 

Congress to enact, amend, or repeal any act with respect to the District. 

Congress used this authority in the 1990s to enact laws intended to restore 

the city to financial solvency and improve its management in response to a 

serious financial and management crisis.8

 Since the 1870s, the federal 

government has made financial contributions to the District’s operations. 

In fiscal year 2006, federal government appropriations included $603 

million in special federal payments to the District with $75 million for 

elementary, secondary, and post-secondary education initiatives.9

 5

 Appendix II provides more details on District governance and related procurement laws. 

6

 Pub. L. No. 93-198, (1973). 

7

 U.S. Constitution, Art. I, Section 8, Clause 17 provides authority for Congress with respect 

to governance of the District.

8

 For example, the District of Columbia Financial Responsibility and Management 

Assistance Act of 1995 created a temporary federal control board, which supplanted most 

of the elected Mayor’s powers and established the authority to review and approve all 

legislation passed by the Council; it also created a Chief Financial Officer (CFO) and added

powers to the District’s inspector general. In September 2001, the control board suspended 

its authority. In 2006, the 2005 District of Columbia Omnibus Authorization Act includes

provisions to permanently establish the CFO office and require the CFO to prepare annual

budget submissions. Pub. L. No. 109-356, § 201, amending § 424 of the Home Rule Act. 

9

 Transportation, Treasury, and Housing and Urban Development, the Judiciary, the District 

of Columbia, and Independent Agencies Appropriations Act, 2006, Pub. L. No. 109-115 

(2005). For more information on the District’s fiscal relationship with the federal 

government, see GAO, District of Columbia: Structural Imbalance and Management 

Issues, GAO-03-666 (Washington, D.C.: May 22, 2003). 

Page 7 GAO-07-159 District of Columbia Procurement
In 1997, the council, with the Mayor’s approval, amended the District’s 

procurement law to centralize procurement under one contracting office, 

which would be the exclusive contracting authority for all procurements 

covered under the act.

10 The amendment also authorized the Office of 

Contracting and Procurement to be headed by a CPO who would be 

appointed by the Mayor for a 5-year term, with the advice and consent of 

the council, and could only be removed from office for cause. The CPO 

was required to have no less than 7 years of procurement experience in

federal, state, or local procurement. The CPO, by delegation of the Mayor, 

was given the exclusive contracting authority for all procurements 

covered under the law. 

Amendment to the 

District’s Procurement 

Law Aimed at Addressing 

Reported Challenges 

The amendment was enacted around the same time that various 

procurement studies were published, with one describing procurement in 

the District as “in crisis”—as evidenced by over 600 contracts expiring in

90 days and a rushed response to ensure that vital services were not 

interrupted. The studies reported that procurement processing was 

inconsistent and responsibilities were widely distributed across the 

District; training for procurement personnel was insufficient and few were 

professionally certified; agencies maintained separate databases; and there 

was no acquisition planning process to define needs.11 Centralization under 

the CPO’s office was expected to improve the quality of the District’s 

procurement operations by promoting accountability, decreasing 

procurement costs, eliminating duplication of effort, and increasing 

financial control and performance. In particular, it was reported that 

centralization of the acquisition function could allow the District to spend

money more effectively by promoting more competition and through bulk 

purchases of goods and services used by multiple agencies. 

Despite the expected benefits, the District’s inspector general’s and 

auditor’s offices continued to identify deficiencies across the District’s 

procurement system that frequently produce negative impacts on the 

 10 D.C. Law 11-259, effective April 15, 1997. The law expanded the procurement law’s 

application to include independent agencies—which were previously excluded—and 

applied it to all departments, agencies, instrumentalities, and employees of the District 

government. 

11 These studies also found that the District’s contracts suffered from insufficient funding; 

deficient specifications; vague and conflicting delivery requirements; inadequate proposal 

evaluations and cost analysis; long processing times after bid opening; lack of 

documentation supporting technical scores; and no justification for sole-source contract 

awards and technical evaluation plans. 

Page 8 GAO-07-159 District of Columbia Procurement
integrity and operations of the District. Moreover, for the past 5 years, the 

inspector general’s annual reports have cited procurement as a significant 

area of concern due to lapses in contracting operations resulting in costly 

inefficiencies, fraud, waste, and abuse. Some of the persistent problems 

reported by District auditors and inspectors include the following—many 

of which are similar to those that prompted the 1997 law: 

• Outdated procurement law and regulations that fail to effectively 

address long-standing procurement deficiencies, policies, and

procedures for all aspects of the process specifically in the areas of 

solicitation, awarding, and monitoring of contracts. 

• Lack of continuity in procurement law, policies, and procedures as 

applied to some agencies. 

• Noncompliance with procurement law and regulations, and lax 

accountability over individuals for not complying with the District’s 

guidelines. 

• Ineffective competition and overuse and misuse of sole-source contract 

awards. 

• Unauthorized commitments and purchases by District personnel from 

vendors without valid written contracts. 

• Failure to conduct advanced planning for known projects and

procurement requirements that lead to costly sole-source acquisitions 

often based on faulty justifications. 

• Insufficient independent oversight of agencies that expend significant 

resources for information technology, construction, and 

communication projects.

• Managers not ensuring a sufficient number of experienced

procurement personnel, proper training, and certification of 

procurement workforce. 

Characteristics of an 

Effective Public 

Procurement System 

The objective of a public procurement system is to deliver on a timely 

basis the best value product or service to the customer, while maintaining 

the public’s trust and fulfilling public policy goals. The federal government

achieves this through guiding principles established in the FAR. NASPO 

and the ABA model procurement code have also established key guiding 

principles and practices that are generally accepted and should be 

Page 9 GAO-07-159 District of Columbia Procurement
incorporated into an effective procurement system. In addition, our work 

has identified best practices and other accepted elements that are 

essential for an efficient and accountable acquisition function. Key 

characteristics of a successful procurement system include: 

Transparency—Comprehensive procurement law with clear and written 

policies and procedures that are understood by all sources. 

Accountability—Clear lines of procurement responsibility, authority, and 

oversight. State and local governments recommend the CPO have fulltime, sole, and direct responsibility for the procurement program. 

Integrity—Public confidence earned by avoiding any conflict of interest, 

maintaining impartiality, avoiding preferential treatment for any group or 

individual, and dealing fairly and in good faith with all parties. 

Competition—Specifications that do not favor a single source and 

solicitations widely publicized to benefit from the efficiencies of the 

commercial marketplace. 

Organizational Alignment and Leadership—Appropriate placement of the 

acquisition function in the organization to cut across traditional 

organizational boundaries with stakeholders having clearly defined roles 

and responsibilities. For state and local governments to operate 

effectively, recommended practice is central leadership in the executive 

branch. 

Human capital management—Competent workforce responsive to mission 

requirements, with continued review and training to improve individual 

and system performance. 

Knowledge and information management—Technologies and tools that 

help managers and staff make well-informed acquisitions decisions. 

Page 10 GAO-07-159 District of Columbia Procurement
The District lacks a uniform procurement law that applies to all District 

entities and that provides the CPO with adequate authority and 

responsibility for the entire acquisition function—an essential component 

to promoting transparency, accountability, and competition. In addition, 

the law has been amended to exempt certain District entities and 

procurements from following the law’s competition and other

requirements. According to current and former District procurement 

officials, District entities are seeking to expand independent procurement 

authority—a move that would undermine attempts to establish a central 

authority. Finally, the law limits competition by broadening the exceptions 

under which sole-source contracts can be awarded; authorizing dollar 

thresholds for small purchases that are higher than those provided for in 

other city and federal government procurement regulations, including the 

FAR; requiring the use of a local supply schedule with limited vendors for 

a variety of goods and services; and encourages agencies under certain 

circumstances to bypass contracting rules to directly pay vendors without 

valid written contracts. In contrast, other cities’ procurement laws 

emphasize the competitive process and having a strong centralized 

authority for their CPOs in order to safeguard the integrity of their 

procurement systems. 

Contrary to sound procurement principles and practices as identified by a 

variety of sources, the District lacks a uniform procurement law that 

uniformly applies to all District entities and provides clear authority to the 

CPO. To promote transparency, accountability, and maintain integrity of 

public procurement, NASPO and the ABA model procurement code for 

state and local governments describe concepts for creating a uniform 

procurement law that provides for central management of the entire 

procurement system and broad discretion and authority to a CPO to 

implement policies. Similarly, in the federal procurement system, the FAR 

establishes uniform policies and procedures for acquisition by most 

executive agencies under the President. Without such a foundation, the 

District’s procurement system is vulnerable to poor acquisition outcomes 

and less capable of maintaining public trust. 

The District’s

Procurement Law 

Does Not Promote 

Transparency, 

Accountability, and 

Competition 

District Lacks a 

Procurement Law That 

Applies to All Entities and 

Provides Clear Authority 

to the CPO 

Twelve District entities, including the Water and Sewer Authority and 

Housing Authority, are not under the authority of both the District’s 

procurement law and Office of Contracting and Procurement, and are 

Page 11 GAO-07-159 District of Columbia Procurement
allowed to follow their own procurement rules and regulations.12 In many 

cases, the procurement law specifically exempts these entities from 

following the law, which is contrary to the central statutory purpose of the 

District’s procurement law to (1) eliminate overlapping or duplication of 

procurement activities; (2) improve the understanding of procurement 

laws and policies by organizations and individuals doing business with the 

District government; and (3) promote the development of uniform 

procurement procedures governmentwide. As a result, the District’s law 

has created a procurement environment where some entities follow 

different rules and practices, undermining the District’s ability to capture 

an overall view of its procurements as well as placing an added burden on 

vendors to understand how to do business with the District. 

According to NASPO, it is essential to have one uniform law that applies to

all agencies and their procurements and exclude blanket exemptions for 

any executive agency or department. If exclusions are necessary, the law 

should define them narrowly by types of goods and services procured. 

NASPO state procurement leaders we spoke with said that they would be 

unable to effectively run their own procurement systems without one 

governing law. Without it, vendors are discouraged from competing since 

they do not know what rules apply, which increases the risk that taxpayers 

pay more for goods and services. According to several former and current

CPOs in the District, not having a uniform procurement law that governs 

all entities has been problematic in ensuring transparency, accountability, 

and oversight. Officials from other cities we reviewed agreed that having a 

common procurement framework is critical for ensuring transparency and 

integrity in the procurement system. Atlanta, for example, has one 

procurement law that governs all agencies, which allows agencies, 

vendors, and contracting employees to have a clear and consistent view of 

how procurements should take place. 

The law also fails to provide a service agency that would be the exclusive 

contracting agency for all District procurements under the Mayor’s 

direction. NASPO calls for a centralized procurement official with the 

authority and responsibility to, at a minimum, develop standardized policy 

and procedure, delegate procurement authority to executive agencies, 

provide expert assistance and guidance on procurement issues, and 

 12 The D.C. Housing Authority is exempt from the authority of the Office of Contracting and

Procurement and the District’s procurement law, except for the provisions regarding the

jurisdiction of the Contract Appeals Board for contract protests, appeals, and claims 

arising from procurements of the Housing Authority. D.C. Official Code § 2-303.20 (m). 

Page 12 GAO-07-159 District of Columbia Procurement
oversee the acquisition process. While the statutory purpose of the 1996 

amendment to the procurement law was to centralize procurement in the

Office of Contracting and Procurement headed by a CPO, the law does not 

give the CPO sole authority over the full spectrum of procurement 

activities in the District. For example, although the law allows the CPO to 

delegate procurement authority to employees of District entities covered 

under the law and to the CPO’s own staff in the Office of Contracting and 

Procurement, the council, with the Mayor’s approval, has used its 

authority to pass emergency laws exempting entities and procurement 

actions from the CPO’s authority.13

The council’s use of its emergency act authority has been problematic in 

certain cases where it exempted District entities from conducting their 

procurements through the CPO’s office. For example, in October 2006, the 

council amended the procurement law to provide the District’s Board of 

Library Trustees procurement authority independent of the Office of 

Contracting and Procurement and the District’s procurement 

law—contingent upon the board issuing its own procurement 

regulations—except for provisions pertaining to contract protests, 

appeals, and claims.14 A senior official in the Office of Contracting and 

Procurement said that circumventing the CPO’s authority in this case was 

not a solution largely because the library board trustees do not have the 

contracting experience or staff to exercise the new authority.15 NASPO 

recognizes that to ensure the appropriate level of transparency and 

accountability and to preserve the integrity of the procurement system, it 

is critical that the CPO have sole responsibility for delegating procurement 

authority. 

 13 A permanent act requires approval of both houses of Congress while an emergency act,

which is only effective for 90 days or less, does not. Appendix II provides more information 

on the District’s laws and procedures. 

14 Other amendments to the law between 2000 and 2005 exempted the District of Columbia 

Public Schools, Department of Mental Health, and Child and Family Services Agency from 

the CPO’s office in order to give them independent procurement authority. D.C. Official 

Code § 2-301.04, D.C. Official Code § 2-303.20. 

15 According to a District official involved, the board asked the Mayor for independent 

procurement authority because, in its view, the CPO’s office could not support the libraries’ 

contracting needs. However, this advocate also acknowledged that the board lacked the 

expertise needed and indicated that the board intends to outsource the entire procurement

function. 

Page 13 GAO-07-159 District of Columbia Procurement
According to the District’s current and former CPOs, agencies and the 

council are pushing to expand independent procurement authority 

through exemptions. These efforts, if successful, could further undermine 

efforts to establish a central authority—a key objective of the procurement 

law amendment more than a decade ago. NASPO state procurement 

leaders as well as current and former CPOs in the District told us that this 

is a move in the wrong direction and that amendments to the procurement 

law should only be made to introduce more effective procurement 

methods or when current laws no longer make sense. 

In addition to authorizing agencies to award their contracts independently

of the CPO, the council has eliminated the CPO’s sole authority to debar or 

suspend contractors from future contracts for various reasons, such as 

conviction of certain offenses.16 In 2003, the council eliminated this 

authority after the then-CPO debarred one vendor who pleaded guilty in

federal court to conspiracy in giving cash bribes to District public works 

officials in return for falsified orders for asphalt-delivery.17 Prior to this 

time, the procurement law gave the CPO sole authority for suspensions 

and debarments. According to both a former CPO and a current senior 

procurement official who were involved in this case, the procurement law 

was amended to establish an interagency suspension and debarment panel 

that reconsidered the CPO’s decision in this case as well as made final 

decisions in all future cases.18 After the panel’s reconsideration, the vendor 

was allowed to resume doing business with the District. To ensure a 

strong, central procurement system, NASPO recommends that CPOs have 

sole authority to implement a range of remedies for poor vendor 

performance, including suspension and debarment. 

 16 A suspension is a temporary exclusion of a contractor from consideration for award of 

contracts or subcontracts based on certain convictions, judicial determinations of certain 

contract violations, or charges of certain offenses. D.C. Official Code § 2-308.04. A

debarment may be a 3-year exclusion from consideration based on these circumstances. 

Under the FAR, agency heads or designees (debarring or suspending officials) rather than

contracting officers make debarment and suspension decisions. FAR9.403. The FAR 

provides discretion to officials in developing a suspension and debarment decisions. FAR 

9.406-1(a). 

17 The Debarment Procedures Emergency Amendment Act of 2004, D.C. Law 15-327 

(codified at D.C. Official Code § 2-308.04). 

18 The interagency suspension and debarment panel was established in 2003 and includes

the CPO as well as representatives from the offices of the CFO and labor relations and

collective bargaining; deputy Mayors for planning and economic development and 

operations; and agencies deemed affected by the proposed action against a vendor. 

Page 14 GAO-07-159 District of Columbia Procurement
The council, with approval from the Mayor, has further amended the law 

to exempt temporarily or permanently certain agencies from following the

procurement law’s requirements for competition or conducting their 

contracts through the CPO. For example, in June 2006, the council 

exempted the Director of the Department of Health from following the 

competition and other requirements of the procurement law and allowed 

the Director to select and contract with a vendor for an air quality study of 

the Lamond-Riggs park within 30 days.19 In another case, in June 2006, the 

council, with the Mayor’s approval, exempted the Office of Contracting 

and Procurement from following its procurement law for awarding a 

construction contract on behalf of the Department of Youth Rehabilitation 

Services for a youth center at Oak Hill.

20 A senior District procurement 

official told us that despite this exemption, the office intends to award 

competitively. 

Other Exemptions in the 

Law Further Undermine 

Transparency and CPO 

Authority 

According to senior procurement officials in the CPO’s office, entities seek 

exemptions believing that working through the CPO or the competitive 

process required by the law takes too much time.21 Current and former 

District officials noted that in giving some entities their own temporary 

procurement authority through exemptions in the law, the council and 

Mayor have, in effect, created a culture of resistance to centralized 

management and oversight of the acquisition function. One senior District 

procurement official told us that such exemptions also create inequities 

among agencies; explicitly discourage competition—contrary to the 

statutory purpose of the law;22 and occasionally show preferences for 

certain agencies and vendors. A former District executive and former CPO 

told us that such exemptions have over time distorted the procurement 

law and made it difficult for any vendor interested in doing business with

the District to understand how and to whom the procurement law applies.

Further, it is questionable why the council would use emergency act 

authority to make noncompetitive awards given that the procurement law 

 19 Lamond-Riggs Air Quality Study Temporary Act of 2006. D.C. Law 16-113. 

20 The Oak Hill Construction Streamlining Temporary Amendment Act of 2006. D.C. Law 16-

136. 

21 In addition, District procurement officials told us of the inability of these agencies to 

effectively carry out their temporary delegations of procurement authority as demonstrated 

by the agency heads seeking informal assistance from the CPO’s office. These officials told 

us that the CPO’s office helps the agencies prepare the contracts for award, but does not 

sign the awards because they would not be authorized to do so. 

22D.C. Official Code § 2-301.01(a)(2). 

Page 15 GAO-07-159 District of Columbia Procurement
and implementing regulation already establish procedures for these types

of procurements.23

NASPO state procurement officials we spoke with voiced concerns over 

exemptions that would give certain agencies the authority to operate 

under their own rules or no rules at all and jeopardize the integrity of their 

public procurement system. Moreover, they said that such exemptions 

further undermine the CPO’s authority over the District’s procurement 

system and ability to develop consistent procurement policy. Other cities 

we reviewed have faced similar challenges with what they called “political

influence” in the procurement process. New York’s CPO told us the city 

council plays no role in making procurement policy and under no 

circumstances would the council be allowed to pass exemptions to the 

city’s procurement law similar to those passed in the District. 

Other Provisions in the 

District’s Procurement 

Law Create Barriers to 

Competition 

Long-standing procurement principles, policies, and procedures 

implemented in the FAR24 and recommended by NASPO and the ABA 

model procurement code recognize that maximizing the use of

competition ensures governments receive the best value in terms of price 

and quality. According to a procurement law expert who participated in a 

GAO forum on federal acquisition challenges and opportunities,25

contractor motivation to excel is greatest when private companies, driven

by a profit motive, compete head to head in seeking to obtain work.26

Consistent with this fundamental principle, the District’s procurement law 

 23 The D.C. Council can introduce emergency legislation when there is a situation that

adversely affects the health, safety, welfare, or economic well-being of a person for which 

legislative relief is deemed appropriate and necessary by the council, and for which 

adherence to the ordinary legislative process would result in delay that would adversely 

affect the person whom the legislation is intended to protect. Similarly, the procurement

law and implementing regulations allow the contracting officer to make an emergency 

procurement when there is an imminent threat to the public health, welfare, property, or

safety under emergency conditions. D.C. Official Code § § 2-303.12(a)(1) and 2-303.05(a)(4) 

and as implemented by 27 DC ADC 1710-10.2. 

24 The Competition in Contracting Act of 1984, Pub. L. No. 98-369 requires all acquisitions,

with some exceptions, to be made using full and open competition. FAR part 6 provides

seven exceptions to full and open competition. 

25 GAO, Highlights of a GAO Forum: Federal Acquisition Challenges and Opportunities 

in the 21st Century, GAO-07-45SP (Washington, D.C.: Oct 6, 2006). 

26 Professor Steven L. Schooner, Desiderata: Objectives for a System of Government

Contract Law, Public Law and Legal Theory Working Paper No. 37, George Washington

University Law School (Washington, D.C.: 2002). 

Page 16 GAO-07-159 District of Columbia Procurement
mandates that full and open competition is the preferred acquisition 

method. However, certain provisions in the District’s procurement law 

have resulted in a public procurement system that emphasizes flexibility 

and speed over competition. Specifically, the law (1) authorizes solesource contracting under broad provisions, (2) establishes higher dollar 

thresholds for limited competition small purchases than are allowed in 

other cities or the FAR, and (3) mandates the use of a local supply 

schedule with a limited number of vendors—each of which permits use of 

streamlined acquisition methods for high dollar procurements that result 

in limited or no competition. 

Both NASPO and the FAR recognize that circumstances sometimes make 

it difficult or impossible to conduct formal competitive procurements and 

that in such cases, the use of sole-source procurements is warranted. 

However, NASPO and the FAR also recognize that such procurements 

should only be permitted under narrowly defined conditions27 and should 

always be properly justified.28 They state that to ensure transparency in

these types of procurements, the law should also require legal notice of 

intent to initiate a sole-source procurement over a determined dollar 

value. While recognizing there are situations in which competition must 

and should be limited, NASPO states that artificially restricting 

competition when competition is possible defeats a central tenet of public

procurement. 

Broad Authority for SoleSource Contracting 

Rather than restrict the conditions under which sole-source procurements 

can occur, the District’s procurement law has been amended—as recently 

as 2002—to expand exceptions to full and open competition. 29 Although 

complete data District-wide on sole-source contracting are unavailable, 

over 14 percent—or $173 million—of the fiscal year 2005 reported 

 27 Such conditions include when there is only one vendor of a necessary good or service or

during a declared emergency.

28 To prevent the misuse of sole source provisions, the FAR and District procurement

regulations describe explicit limitations on each exception. For example, both 

procurement regulations state that sole-source contracts shall demonstrate the authority 

under which they are awarded and shall not be awarded on the basis of a lack of advance 

planning or the pending expiration of program funds. The District’s regulation also requires 

that contracting officers avoid using sole-source procurement except when it is both 

necessary and in the best interests of the District. 

29 The Procurement Practices Negotiated Pricing Amendment Act of 2001, effective March 

19, 2002, amended section 2-305.05 (a) of the procurement law to establish the (3A)

provision. (D.C. Law 14-083; D.C. Official Code § 2-305.05 (a)(3A) et seq.). 

Page 17 GAO-07-159 District of Columbia Procurement
procurement spending through the Office of Contracting and Procurement 

was on a sole-source basis. Of the District’s various sole-source provisions, 

three account for the majority of sole-source contracts and spending (see 

table 2). Of the three provisions, one is similar to an equivalent provision 

in the FAR, while the remaining two provisions have no equivalent. Senior 

procurement officials and former CPOs pointed out that these provisions 

in the procurement law establish a wide range of circumstances to bypass 

competition. 

Table 2: District Procurement Law Provisions Permitting Sole-Source Contracting and Awards in Fiscal Year 2005 under 

These Provisions

Dollars in millions 

Procurement 

law provision

Criteria or circumstance 

justifying sole-source contracting

Number 

of sole-source 

contracts awarded

Dollar value

of sole-source

contracts awarded

§ 2-303.05 (a) (1) Only one supplier (single available source) can 

provide the good or service requested 296 $79.4

§ 2-303.05 (a) (3) The contract is with a vendor who maintains a price 

agreement or schedule with any federal agency 283 88.9

§ 2-303.05 (a) (3A) The contract is with a vendor who agrees to adopt 

the pricing of a vendor who maintains a price

agreement or schedule with any federal agency 119 3.6

§ 2-303.05 (a) (4) Procurements that would ordinarily be purchased on 

a competitive basis, but an emergency has been 

declared 2 1.3

Total 700 $173.2

Source: GAO analysis of information from the Office of Contracting and Procurement on sole-source contract awards. 

Note: Complete data are not available on sole-source contract awards in 2005 for all of the District’s 

organizations, such as the public schools or Department of Mental Health. 

Over 40 percent of the District’s fiscal year 2005 sole-source contracts 

were awarded under provision (a)(1), which similar to an equivalent FAR 

provision, requires agencies to justify that there is only one available 

Page 18 GAO-07-159 District of Columbia Procurement
source for a good or service.30 Of the 296 contract awards under this 

provision, 45 percent were made by the Office of the Chief Technology 

Officer (OCTO) for a variety of information technology and 

telecommunication services. According to NASPO officials we spoke with, 

typically more than one vendor in the commercial marketplace provides 

these services and the services would normally be competed. In 2005, the

District’s inspector general reported on questionable single available 

source justifications involving information technology services.31

According to the inspector general, there were numerous competing firms 

that could have satisfied the District’s needs for eight selected single 

available sole-source contracts they reviewed. For three sole-source 

contracts for general purpose commercial information technology 

equipment, software, and service, the inspector general found that there 

were 700 vendors eligible to compete through the District’s supplier 

database and another 113 vendors located in the District eligible to 

compete through the federal supply schedules. Overall, the inspector 

general concluded that the District could have potentially saved at least 

$589,000—over 24 percent—of the $2.5 million for the sole-source 

contracts awarded. 

More than half of the fiscal year 2005 sole-source contracts were awarded 

through the (a) ( 3) and (a) (3A) provisions, which permit agencies to 

award sole-source contracts to any vendor who agrees to charge 

according to a schedule of prices for federal agencies. Unlike the District’s 

single available source provision, these provisions have no equivalent in

the FAR or NASPO and ABA procurement guidance for state and local 

governments. According to a senior District procurement official, these

two procurement law provisions were intended to save time in the 

District’s procurement process by piggybacking off the prices previously 

 30 FAR 6.302-1 states that an executive agency need not provide for full and open 

competition when the supplies or services required are available from only one responsible

source and no other type of supplies or services will meet the agency requirement. The

FAR provision defines a very limited number of circumstances under which a supply or

service may be considered to be available from only one responsible source and provides

detailed written justification and certification requirements. As implemented in the 

District’s procurement regulations, the law’s single available source provision states that a

contracting officer may award a contract by using noncompetitive negotiation upon making

a determination and findings that there is only one available source for a supply, service, or

construction and that the District’s minimum needs can only be met by this source. 

31 Office of the Inspector General, Government of the District of Columbia, Audit of 

Contracting Actions for the District’s Administrative Services Modernization Program, 

OIG No. 04-1-12MA (Washington, D.C.: May 3, 2005). 

Page 19 GAO-07-159 District of Columbia Procurement
set as a result of the prior competition—primarily contracts awarded to 

District and other vendors under the General Services Administration’s 

(GSA) multiple award schedule (MAS) program. The use of sole-source 

provisions as a time-saving measure appears to conflict with the District’s 

own procurement regulations, which calls for contracting officers to avoid 

sole-source procurements except where necessary. 

GAO’s work has also found that while MAS has provided the federal 

government with a more flexible way to buy commercial items and 

services, contract negotiators do not always use the full range of tools to 

ensure the government effectively negotiated prices.32 As a result, the 

federal government has missed opportunities to save millions of dollars in 

procuring goods and services. By eliminating competition altogether and

awarding sole-source contracts to vendors based on MAS pricing, the 

District may be similarly missing significant cost-saving opportunities. 

Moreover, the District may be at greater risk because its sole-source use of 

the federal supply schedule is not subject to the FAR,33 and the District’s 

implementing procurement regulation does not provide specific guidance 

on the use of the (a)(3) and (a)(3A) provisions.34 A senior procurement 

official we spoke with noted that the CPO’s office recently started 

requiring District contract officers to additionally justify their use of these 

methods after growing concerned about the large number of sole source 

contracts being awarded.

To ensure they get the best value for the taxpayer dollar, other cities we 

reviewed have taken steps to emphasize competition over sole source. 

These officials recommended that a procurement law—similar to statutes

 32 GAO, Contract Management: Opportunities to Improve Pricing of GSA Multiple Award

Schedules Contracts, GAO-05-229 (Washington, D.C.: Feb. 11, 2005) and Contract 

Management: Opportunities Continue for GSA to Improve Pricing of Multiple Award

Schedules Contracts, GAO-05-911T (Washington, D.C. July 26, 2005). 

33 FAR 8.4 sets forth substantial procedures for federal agencies’ use of the multiple award 

schedules contracts to procure goods and services. For instance, in procurements 

exceeding the micro-purchase threshold—$3,000 with certain exceptions—the FAR 

requires ordering activities to place orders with the schedule contractor that represents the 

best value; requires ordering activities to seek price reductions; and sets forth minimum

documentation requirements. In procurements for services that require a statement of

work, the FAR requires the ordering activity to create a request for quotation; provide it to

schedule contractors; and evaluate each response received before making the order. 

34 Though the District’s procurement regulation does not provide specific guidance for the 

use of the (a)(3) and (a)(3A) provisions, it does require a general determination and 

findings to justify use of sole-source authorities. 

Page 20 GAO-07-159 District of Columbia Procurement
implemented in the FAR—narrowly define sole-source contracting and 

require that such actions be properly justified and documented. For 

example, in Atlanta, sole-source contracts may only be awarded when the 

CPO determines after conducting a good-faith, due diligence review of 

available sources that there is only one available source for the required 

good or service. Even for emergencies, Atlanta’s procurement law requires 

the CPO to use competition to the maximum extent practicable, and sole 

source may only be considered in the case of a threat to public health,

welfare, or safety. According to Atlanta’s CPO, in fiscal year 2005, only five 

sole-source contracts were awarded. Similarly, New York’s procurement 

rules specify only one condition or circumstance in which sole-source 

contracting is permitted for purchases above $5,000; there is only a single

available source and competition is not possible. 

For purchases under a certain dollar threshold, the administrative costs to 

formally compete may outweigh the benefits of competition. In such cases,

procurement systems may permit streamlined acquisition procedures with 

limited competition for purchases not exceeding a specified dollar 

threshold. 35 In the District, small purchase procedures streamline the 

process by limiting competition to oral or written price quotes from only a 

few vendors, or eliminating competition altogether (see table 3). 

High Dollar Thresholds for 

Limited Competition Small 

Purchases 

Table 3: Limited Competition Procedures for Small Purchases in the District of

Columbia 

Small purchase threshold Small purchase procurement procedure 

Less than or equal to $10,000 Contracting officer may make non-competitive 

procurement 

Above $10,000 and less than or equal 

to $25,000 

Contracting officer must obtain three oral

price quotes 

Above $25,000 and less than or equal 

to $100,000 

Contracting officers must obtain three written 

quotes 

Source: Office of Contracting and Procurement. 

Note: For OCTO and the Metropolitan Police Department purchases, the small purchase threshold for 

no-bid procurement is less than or equal to $25,000. For purchases over $25,000, the contracting 

officer must get three written quotes. 

For the District, a series of legislative changes since 1985—when the small 

dollar threshold for small purchases was $10,000—have increasingly 

 35 Section 13.003 of the FAR provides guidance on federal small purchase thresholds. 

Page 21 GAO-07-159 District of Columbia Procurement
raised the threshold for some entities, expanding the opportunities to limit 

competition. Currently, the District’s small purchase threshold is $500,000

for OCTO and the Metropolitan Police Department and $100,000 for all

other entities. 36 The District’s small purchase authority allows for 

somewhat larger limited competitive purchases than that authorized in the 

FAR. Under the FAR’s micro-purchase authority, competition is not 

required for purchases up to $3,000 when the contacting officer 

determines that the price is reasonable. For small purchases between 

$3,001 and $100,000, the FAR’s simplified acquisition procedures require 

that the contracting officer promote competition to the maximum extent 

practicable. Generally, the contracting officer should consider obtaining at 

least three price quotes or offers from sources within the local area and 

evaluating those to determine the most advantageous to the government.

Under the District’s small purchase authority, competition is not required

for purchases up to $10,000 when the contracting officer determines that 

the purchase is in the best interest of the District. Moreover, contracting 

officers in the District are allowed to waive the competitive small 

purchase procedures under broad circumstances—such as time 

constraints and lack of available sources—when it is impractical to obtain 

the required number of quotes. 

In fiscal year 2005, over 75 percent of the District’s procurements through 

the Office of Contracting Procurement were for small purchases totaling 

$163 million. However, small purchase procurements could increase in the 

future. According to one senior District procurement official, there is a 

move to increase the small purchase threshold from $100,000 to $500,000 

for all agencies—a limit five times as high as that prescribed in the FAR. 

State and city procurement officials voiced concern that the District would 

consider this change in an effort to expedite procurements by allowing 

limited competition methods. 37 NASPO state procurement officials we 

interviewed were surprised at how high the District’s small purchase 

 36 The Procurement Practices Act of 1985 established the small purchase threshold at 

$10,000 for all District agencies. In 2002, the District amended the procurement law to 

include a small purchase threshold of $500,000 for the Metropolitan Police Department and 

OCTO and $100,000 for all other departments, agencies, and instrumentalities. D.C. Official 

Code § 2-303.21. 

37 According to NASPO, the dollar thresholds for triggering the formal competition process

for non-small purchases have increased over the years; yet, most states require some 

competitive quotations for small dollar procurements. NASPO’s small purchasing 

procedures call for soliciting a minimum of three oral or written quotations to afford the 

best practice and to ensure price comparisons. 

Page 22 GAO-07-159 District of Columbia Procurement
thresholds were set, and viewed this as one of the procurement law’s 

major barriers to competition. Each of these officials said that they 

consider such amounts to be large purchases, particularly at the $500,000 

level. As one senior procurement official in the District put it, “just about 

anything can be considered a small purchase in the District.” 

Other cities we reviewed see the economic and quality benefits of 

competition when larger procurements are involved, such as those the 

District considers small purchases. In Atlanta, for example, the small 

purchase threshold is $20,000 and New York, which spends over 

$11 billion per year on procurement, only recently increased its small 

purchase threshold to $100,000. According to the Atlanta CPO, raising 

small purchase limits across the board ultimately compromises the 

integrity of the procurement system by reducing transparency over 

procurement decisions and source selection. One District official 

remarked that, if these types of changes continue in their current 

direction, the District will no longer have a recognizable procurement 

system. 

The District of Columbia Supply Schedule (DCSS) program also limits 

competition by restricting the pool of vendors for a variety of goods and 

services to local companies; requiring entities to use the schedule as a first 

source for all procurements $100,000 and below; and allowing limited 

competition for purchases over $100,000—to a ceiling as high as 

$10 million for certain services. At the same time, there is no mechanism 

in place to ensure that the incumbent vendor does not receive all DCSS 

contracts for a particular schedule. NASPO has recognized that balancing 

the need to promote socioeconomic goals with the need to ensure 

maximum competition is an ongoing challenge. However, NASPO 

recommends caution in the use of supply schedule programs, such as the 

DCSS, because while there is the presumption of best value, competition 

among vendors is often limited with no incentive to offer best price. 

Reliance on Local Supply 

Schedule 

The DCSS program was established in 2002 to help achieve the District’s 

local and small and disadvantaged requirement established in its 

procurement law and expand the District’s tax base. According to a former

District executive, the DCSS program was also intended to expedite 

agencies’ small purchases of common and routine items for which 

competition would not be practical, such as office and janitorial supplies. 

The current program is the primary vehicle for supporting the District’s 

Page 23 GAO-07-159 District of Columbia Procurement
small, local, and disadvantaged business enterprises (LSDBE) and requires 

that District entities use DCSS small business entities to make purchases 

of $100,000 and below.38 This mandatory use of the DCSS ultimately limits 

the pool of vendors for a number of goods and services, which for some of 

the schedules is fewer than three vendors. Though it may appear similar to 

GSA’s MAS program of federal supply schedule contracts, the DCSS serves 

a different purpose. Under the FAR, the purpose of the GSA supply 

schedules program is to provide federal agencies with a simplified process 

for obtaining commercial supplies and services at prices associated with

volume buying. The FAR provides extensive guidance on the use of the 

schedules to achieve that purpose. In contrast, the DCSS is designed to 

promote LSDBEs and lacks the type of comprehensive guidance provided

to the federal supply schedules by the FAR. 

According to NASPO, unlimited use of supply schedules limits competition 

and can increase costs because vendors have no incentive to meet the best

price of their competitors. Further, open-ended contracts for the same 

goods or services are awarded to many more vendors than needs appear 

to demand, removing any consideration of need and price from the 

purchasing decision. In fiscal year 2006, reported contract awards off of 

the DCSS—which contains 19 categories of goods and services with nearly 

200 local vendors—totaled almost $22 million (see table 4). 

 38 To be eligible for the DCSS program, a vendor must first be certified as a LSDBE by the 

Department of Small and Local Business Development. To be eligible for an award on the

DCSS, a contractor must adopt a federal contract schedule for services or products

consistent with the scope of the DCSS application. This can be the vendor’s own GSA MAS 

contract or another vendor’s federal MAS contract. As discussed earlier, our previous work 

found that GSA does not always effectively negotiate MAS contract pricing and the federal 

government is missing opportunities to save millions of procurement dollars. By linking 

DCSS contract pricing to MAS pricing, the District may be similarly missing significant 

cost-saving opportunities. 

Page 24 GAO-07-159 District of Columbia Procurement
Table 4: DCSS Program Schedule Categories and Number of LSDBE Vendors (as of October 27, 2006) 

Dollars in thousands

Schedule category 

Number of

LSDBE vendors

Contract ceilings 

Total fiscal year

2006 purchase

Information Technology Services 40 $10,000 $5,332

Mission Oriented Business Integrated Services 40 10,000 1,502

Temporary Support Services 22 5,000 5,696

Information Technology Products 2 5,000 52

Furniture and Furniture Management Services 7 2,000 1,563

Office Supplies, General 10 2,000 3,078

Industrial Services 6 900 1,575

Industrial Supplies and Apparel 7 900 489

Security Equipment and Services 9 850 513

Audit and Financial Management Services 7 500 171

Marketing and Media Services 14 500 506

Medical Equipment and Supplies 5 500 568

Moving and Logistics Services 5 500 356

Training Services 8 500 50

Advertising Services and Novelty Supplies 3 400 203

Engineering and Logistics Services 6 250 6

Food Services and Equipment 1 250 39

Printing and Document Management Services 2 250 53

Laboratory and Analysis Services 0 250 0

Total 194 $21,752a

Source: Office of Contracting and Procurement. 

a

According to senior procurement officials, the discrepancy between the almost $21.8 million in 

reported purchases (i.e., expenditures) with DCSS vendors and the almost $30.9 million in orders

awarded to DCSS vendors in fiscal year 2006 is due to separate contracting and procurement data 

systems being used to track these different types of transactions. 

Some DCSS contracts are valued much higher than $100,000, including 

some fiscal year 2006 awards to DCSS vendors valued at $1 million and 

one award for $5 million. Moreover, in 2006, the CPO’s office raised the 

contract ceilings for individual DCSS vendors on several of these 

schedules including the information technology services schedule, which 

is now set at $10 million. As a result, one DCSS information technology 

vendor could in 1 year potentially receive a single limited competition 

order worth up to $10 million. NASPO officials we spoke with voiced 

concern about the ease with which the District makes what they would 

Page 25 GAO-07-159 District of Columbia Procurement
consider large limited competition purchases off a supply schedule 

originally intended to limit competition only for small purchases. 

In addition, District procurement officials told us that the DCSS program 

has limited guidance and no procedure in place to ensure that each vendor

is provided a fair opportunity to be considered for orders. Under DCSS 

terms and conditions, contracting officers must follow small purchase 

procedures as described in table 3 when buying a good or service off 

DCSS. However, these officials said that it is up to the contracting officer 

to arbitrarily select three vendors from each schedule to obtain price 

quotes; according to District procurement officials, this typically includes 

the incumbent. For the 14 schedules that have more than three vendors, 

this discretion could prove unfair to certain vendors. The FAR, in contrast, 

advises contracting officers to request quotations or offers from two 

sources not included in the previous solicitation. According to District 

procurement officials, there is currently no requirement to monitor the use

of the schedule to determine whether it is promoting small businesses 

overall or if a pattern of sole-source contracts to the same businesses is 

occurring. They told us this type of information would be beneficial to

evaluating the effectiveness of the program and that an overall assessment 

of the current program may be needed to determine if it is meeting its 

original intent. 

The District’s Law Allows 

Payments for 

Unauthorized 

Commitments to Vendors 

To safeguard the obligation of taxpayer dollars and protect the integrity of 

a public procurement system, a government’s procurement law should 

grant exclusive authority to contracting officers for establishing contracts

and restrict employees from making unauthorized commitments for goods 

and services. It should also grant the CPO the authority to ratify contracts 

and authorize payments for goods and services received without a valid 

written contract if certain conditions are met. Until recently, the District’s 

procurement law appeared to emphasize these standards. Under 

September 1996 CFO guidance, direct voucher payments without having

been first obligated in the District’s financial management system could 

only be made in 21 specific non-procurement related circumstances—all 

of which were reasonable and included situations where the payees could 

not be determined in advance, such as court ordered fines, workers’ 

compensation, jury duty fees, and medical payments for assault crime 

victims. However, in 2006, the council, with the Mayor’s approval, 

Page 26 GAO-07-159 District of Columbia Procurement
amended the procurement law that increased the circumstances under 

which such payments may be made.

39

Changing the policy may have had the unintended consequence of 

focusing agency personnel attention on the process of paying for 

unauthorized commitments rather than focusing on how to get 

management attention on preventing employees from entering into 

authorized commitments. According to financial management officials, in

2005, the District’s CFO office reviewed over 21,000 direct voucher 

payments totaling $556 million made in fiscal year 2004.40 They stated that

the purpose of the review was in part to determine to what extent these 

direct voucher payments resulted from unauthorized commitments by 

District agencies for goods and services. The analysis confirmed that of 

the vouchers reviewed, over 11,000 totaling $217 million were not in 

compliance with 21 allowed uses under the 1996 CFO policy. Rather than

take steps to hold agencies accountable for these violations, the CFO’s 

policy was changed without consulting the CPO’s office on the merits of 

the change. CFO officials told us their office determined it was necessary 

to accommodate agency circumstances for bypassing the procurement 

process to more promptly obtain goods and services needed for critical 

operations. 

Under Financial Management and Control Order No. 05-002, issued July 

22, 2005, and revised October 17, 2005, the CFO added 7 new 

circumstances for direct voucher payments to the 21 already included in 

the 1996 financial guidance. Five of the seven added circumstances were 

for new non-procurement related transactions, such as temporary welfare 

payments to families and certain lawsuit settlement payments. The 

remaining two are for procurement-related transactions, however, and are 

problematic. The first circumstance—which allows direct voucher 

payments for goods and services needed for an unanticipated and 

nonrecurring extraordinary emergency—duplicates provisions in the 

District’s procurement law that establish procedures for handling such 

circumstances under emergency contracting procedures. A senior District 

procurement official said that direct voucher payments should not be 

 39 The Procurement Practices Timely Competition Assurance and Direct Voucher 

Prohibition Amendment Act of 2006. D.C. Law 16-122.

40 CFO staff told us the internal review was in response to a Washington Post report

alleging that District agencies made $446 million in direct voucher payments in 2004 to

vendors for such unacceptable uses as computers and furniture. 

Page 27 GAO-07-159 District of Columbia Procurement
made for emergency procurements. The second circumstance allows 

agencies to make direct voucher payments for liabilities incurred through 

unauthorized commitments to vendors for goods and services without 

valid contracts after payment has been ratified—a practice that could 

further encourage employees to bypass established contracting 

procedures.41 

The District’s inspector general has voiced a similar concern with this 

change and in December 2005 testimony called for a reexamination of the 

CFO’s 2005 policy for allowing direct voucher payments for unauthorized 

vendor commitments that bypass contracting rules. More recently, the 

inspector general reported that in fiscal year 2005, District agencies greatly 

increased payment ratification requests for unauthorized vendor 

commitments and the procurement office ratified $34 million in 

payments.42

In the federal procurement system under FAR Part 1.6, the policy provides 

procedures for ratification actions to approve unauthorized commitments, 

but also states that these procedures may not be used in a manner that 

encourages such commitments be made by government personnel. 

Moreover, the FAR provides a ratification procedure that not only 

discourages unauthorized commitments, but allows for their approval if 

certain conditions are met. Specifically, under the FAR, the chief of a 

contracting office may ratify an unauthorized commitment only when the 

goods or services have been accepted; the ratifying official has the 

 41 Under District law, in order to pay vendors that have provided goods or services without 

a valid contract, agency directors must seek approval for unauthorized commitments by 

submitting a payment ratification request to the Office of Contracting and Procurement. In

August 2006, this office established written procedures under Directive 1800.04 for the

ratification of unauthorized commitments. 

42 Office of the Inspector General, Government of the District of Columbia, Office of 

Contracting and Procurement Part One: Report of Inspection, OIG No. 06-0017-PO 

(Washington, D.C.: Aug. 23, 2006). Of this amount, $33 million was to ratify payments for 

OCTO’s unauthorized vendor commitments. Further, the inspector general stated that

District employees are not consistently held accountable for unauthorized commitments. In

another report, a senior official at the Department of Health, who did not have contracting 

authority, bypassed the normal procurement process by preparing and signing a letter

authorizing a vendor to provide transportation services to medical appointments for

Medicaid recipients. The contractor billed the department $936,000 for these services and, 

after ratification was complete, received a direct voucher payment. (Office of the Inspector 

General, Government of the District of Columbia, Audit of Contractual Arrangement for 

Non-Emergency Transportation of Medicaid Recipients, OIG No. 05-2-

18HC(a)(Washington, D.C.: May 5, 2006). 

Page 28 GAO-07-159 District of Columbia Procurement
authority; the contract would have been proper if done by approved 

personnel; the price is reasonable; the contracting officer recommends 

payment; the funds were and are available; and the ratification complies 

with any additional agency regulations. In addition, the FAR states that 

cases of nonratifiable commitments may be subject to further referral and 

resolution under government claim procedures. 

Allowing government agency personnel to circumvent the normal 

procurement process and enter into unauthorized commitments with 

vendors to perform services or deliver goods eliminates the opportunity 

for competition. After reviewing a draft of this report, CFO officials 

acknowledged the need to work with the Office of Contracting and 

Procurement to strengthen the District’s ratification policy. They 

indicated that unauthorized commitments that cannot be ratified should 

be referred for possible Anti-Deficiency Act violations.43 Accordingly, we 

revised our recommendations to the mayor and the CFO concerning the

use of direct vouchers and the ratification process. 

Other cities we reviewed have taken steps to curb the use of unauthorized 

commitments. For example, New York’s CPO described the city’s stringent 

controls and regular monitoring to detect and publicize agencies’ 

unauthorized commitments with vendors as well as its discipline of 

employees for bypassing contracting rules—steps that have greatly 

decreased the number of unauthorized commitments in that city’s 

procurement system.44

 43 Under the Anti-Deficiency Act, District government officers as well as federal officials 

are prohibited from making obligations or expenditures in excess of amounts available in 

an appropriation or fund unless they are otherwise authorized to do so by law.

44 In Atlanta, direct vouchers or “confirmation purchase orders” are only used when there is

a dire need such as a threat to safety, welfare, or the financial security of the city and the

procurement process would not apply. According to the CPO, they are reviewed very 

closely and often not approved. Similarly, the Baltimore CPO said that city has taken steps 

to curb the use of these type payments for goods and services valued at over $1,000. 

Page 29 GAO-07-159 District of Columbia Procurement
In addition to generally lacking a uniform procurement law that applies to

all entities, promotes competition, and provides the CPO the authority to 

ensure sound procurement outcomes, the District’s management and 

oversight of its procurements have lacked the rigor needed to protect 

against fraud, waste, and abuse. Specifically, the Office of Contracting and 

Procurement is positioned too low within the District’s executive 

governmental structure to enforce agency compliance with policies and 

procedures, effectively coordinate procurement activities and acquisition 

planning, and sustain leadership. At the same time, the District’s 

contracting managers and staff, agency heads and program personnel, and 

other key procurement stakeholders do not have the basic tools for 

ensuring sound acquisition outcomes, including written guidance on the 

District’s procurement policies and procedures, a professional 

development program and certification requirements for contracting staff, 

and an integrated procurement data system. Although the District and 

Congress have taken actions to address management and oversight 

challenges, many remain largely unaddressed. 

The District’s

Procurement System 

Does Not Reflect 

Sound Management 

and Oversight 

Practices 

Page 30 GAO-07-159 District of Columbia Procurement
The low-level placement of the Office of Contracting and Procurement 

undermines the office’s ability to effectively manage and oversee the 

District’s procurements across dozens of agencies and departments. 

NASPO and GAO have stated that the central procurement office’s 

effectiveness is clearly linked to its location in the government structure 

and that placing the office at a high level is critical to ensuring effective 

direction, coordination, and control over a government’s procurement 

spending. Procurement is viewed as a strategic, service function within the 

executive branch with the central procurement authority being a key 

policy and management resource for the chief executive. The low-level 

placement of the District’s procurement office has led to high CPO 

turnover and a lack of sustained leadership, significantly impeding 

progress expected from the 1996 law.

Low-Level Position of the 

Office of Contracting and 

Procurement Undermines 

Management and 

Oversight 

Within the District’s government structure, the Office of Contracting and 

Procurement is placed under the Deputy Mayor for Operations—

essentially relegating procurement to an administrative and operations 

support function—as further evidenced by its position in relation to those 

agencies that procure through this office (see fig. 1). 

Page 31 GAO-07-159 District of Columbia Procurement
Figure 1: The Office of Contracting and Procurement Placement in the District of Columbia’s Government Structure 

Office of the Mayor

Office of the

City Administrator

Chief

Financial

Officer

Attorney

General

Inspector

General

Deputy Mayor

Operations

Office of

Local Business

Development

Office of

Contracting

and

Procurement

Office of

Personnel

Department of

Public Works

Department of

Motor Vehicles

Office of

Property

Management

Department of

Transportation

Energy

Office Commission

on Arts and

Humanities

Office of

Planning

Department of

Insurance,

Securities,

and Banking

Department of

Housing and

Community

Development

Department of

Employment

Services

Department of

Consumer

and

Regulatory

Affairs

Department of

Youth

Rehabilitation

Services

Child and

Family Services

Agencya

Office on

Aging

Department of

Mental Healtha

Department of

Health

Department of

Parks and

Recreation

Department of

Human

Services

Department of

Corrections

Fire and

Emergency

Medical Services

Department

Metropolitan

Police

Department

Emergency

Management

Agency

Office of the

Chief Medical

Examiner

Office of Unified

Communications

City

Council

School Board

and

D.C. Public

Schools

Deputy Mayor

Planning and

Economic

Development

Deputy Mayor

Children, Youth,

Families,

and Elders

Deputy Mayor

Public Safety

and Justice

D.C. Courts

Office of

Risk

Management

Office of

Human

Rights

Office of

the Chief

Technology

Officer

Source: District of Columbia fiscal year 2006 budget (data); GAO (analysis and presentation).

a

Entities that procure their goods and services independently of the Office of Contracting and 

Procurement. 

According to former CPOs and current procurement officials, the low-level 

position denies the CPO direct access to the city administrator, agency

Page 32 GAO-07-159 District of Columbia Procurement
heads, and deputy Mayors other than the Deputy Mayor of Operations. As 

a result, this limits the CPO’s ability to affect budget, program, and 

financial management decisions. A former District official told us that to 

improve management and oversight of the procurement system, the CPO 

needs to be at all executive meetings to raise procurement issues that cut 

across agency lines. This official told us that it would be helpful to elevate 

the CPO’s office to a high level similar to other centralized crossgovernment functions, such as the Office of the Chief Technology Officer, 

which is responsible for all meeting all of the District’s information 

technology needs. 

The low-level position of the CPO’s office in the District’s governmental 

structure has also undercut the CPO’s ability to influence day-to-day 

procurements across the District. According to several senior District 

procurement officials, agencies often bypass the procurement office and

do not consult the CPO’s designated contracting officer when initiating 

procurements—a practice that has led to unfavorable acquisition 

outcomes. For example, the District’s auditor reported in 2005 that the

offices of the Mayor and city administrator failed to involve the CPO’s 

office and violated contracting rules by entering into unauthorized 

commitments with a vendor for international trade mission services 

without a valid written contract, making the commitment invalid.45

Ultimately, the CPO’s office was left to ratify a transaction that did not 

conform to the procurement law or regulations.

One impact of CPO’s low-level placement is manifested in the inability of 

the CPO to ensure effective acquisition planning—a critical process for 

anticipating future needs, devising contracting programs to meet these 

needs, and arranging for the acquisition to promote competition and use of

 45 District of Columbia Auditor, Letter Report: Sole Source Agreements Issued by the 

Executive Office of the Mayor and Office of the City Administrator Failed to Comply

with Procurement Law and Regulations (Washington, D.C.: June 3, 2005). 

Page 33 GAO-07-159 District of Columbia Procurement
necessary resources.46 CPOs from the other cities we reviewed consider 

acquisition planning as critical to managing the procurement system and 

maximizing competition, and have put in place mechanisms and tools to 

regularly address planning. In Atlanta, for example, the CPO requires his 

contracting staff to meet bi-weekly with agency officials to plan for 

expiring contracts and new requirements. Agencies are also required to 

submit a quarterly report to the CPO detailing their procurement needs. In

New York, agencies awarding contracts must submit a draft plan detailing 

anticipated procurement actions. They are also required to hold public 

hearings on their plan within 20 days of its issuance and provide notice of 

the hearings 10 days in advance. 

While the District has a process in place to facilitate acquisition planning 

across agencies, the CPO lacks the ability to hold agencies accountable for 

submitting accurate and timely plans. According to former CPOs and 

current senior procurement officials, District entities in general do not 

understand the importance of acquisition planning or involving the CPO’s 

office in planning efforts. Consequently, agencies largely view the required 

annual plans as a paper drill. In recent years, the CPO’s office has tried to 

improve acquisition planning across the procurement system without 

much success. For example, in 2000 the then-CPO implemented a new 

acquisition planning tool that was aimed at guaranteeing short turnaround 

for small and simple buys and sharing workload with partner agencies on

larger, more complex buys. Though this was the original intent, CPO 

contracting officers we spoke with do not use the plans to schedule 

procurement support activities for their agencies. Our analysis of selected

contracts conducted by the CPO’s office in 2005 for three agencies against 

procurements listed in their 2005 acquisition plans found none of the 

contracts were recorded in the planning tool. 

 46 Requirements for federal acquisition planning are addressed in detail in the FAR. For 

example, in justifying contracting without providing for full and open competition in the 

federal procurement system, FAR Part 6.301 policy states that “a lack of advance planning 

by the requiring activity” shall not be used. Similarly, in order to promote competition, FAR

policy requires acquisition planning for all acquisitions and the efforts of all responsible 

personnel for the purpose of ensuring that the government meets its needs in the most

effective, economical, and timely manner. NASPO’s state and local government purchasing

principles similarly emphasize acquisition planning and scheduling and discuss the role of

the central procurement office—both in terms of broad, longer-term management and in

terms of day-to-day decision making on the timing of procurements and methods of 

contracting at the operations level. 

Page 34 GAO-07-159 District of Columbia Procurement
The District’s inspector general and auditor offices have repeatedly found 

that the District’s lack of effective acquisition plans results in excessive 

use of sole-source contracts and missed opportunities for competition, 

thereby contributing to unnecessary spending from higher cost 

procurements. In December 2005 testimony before the Council, the 

District’s auditor stated that as “a government striving for self-government, [the 

District] desperately needs to improve accountability and ethics in the way the 

procurement and contracting process is carried out and to restore the faith of residents

that tax dollars are being spent judiciously, economically, and competitively. The failure to

conduct advanced planning for known projects, services, and procurement requirements 

ultimately manifests in costly internally generated emergency contracts and purchases.” A

senior District procurement official agreed and stated that the lack of 

planning does not constitute an emergency, but all too often the lack of 

planning occurs and forces emergency-type procurement actions. 

Finally, sustaining procurement leadership has been difficult due to the 

low-level position of the CPO’s office. Former CPOs agreed that in a 

complex and large-scale procurement system such as the District’s, it is 

essential to have sustained leadership and a CPO with executive-level 

procurement experience and qualifications. However, over the past 10 

years, the District has had five CPOs—three appointed for 5-year terms 

and two interim—and none served more than 3 years.According to each of 

the three CPOs appointed to 5-year terms, the inability to effectively 

coordinate acquisition activities across all agencies and manage and 

oversee the District’s procurement function undermined their efforts at 

reform and ultimately discouraged them from completing their tenures. 

The lack of sustained leadership is underscored by the 2-year vacancy in 

the District’s CPO position since September 2004, at which time the 

Deputy Mayor for Operations became the interim CPO. 47 With no 

procurement experience—contrary to the District’s law requiring at least 

7 years of procurement experience—this official acknowledged that it has 

been challenging to assume the extra responsibilities of the CPO position. 

The cities we reviewed have recognized the importance of elevating the 

central procurement office in the governmental structure as necessary for 

sound procurement management and oversight. For example, in 2003, 

Atlanta recognized that the centralized acquisition function headed by a 

 47 In October 2006, we were told that this interim CPO left his deputy Mayor position in the 

District government. This latest vacancy in the District’s CPO position is now being filled 

on an acting basis by the commodity manager for human care supplies and services 

contracting. 

Page 35 GAO-07-159 District of Columbia Procurement
senior procurement director was buried in the structure and took steps to 

elevate this office with a newly appointed CPO to report through its chief

operating officer to the Mayor. According to Atlanta’s CPO, the office now 

has a seat at the table with the necessary authority to control and direct 

procurement across all agencies, and to have the Mayor reinforce the 

CPO’s role in managing the city’s council and agencies. 

The District Lacks Other 

Tools for Effective 

Procurement Management 

and Oversight 

The District lacks other basic tools to effectively manage and oversee its 

procurement system. Specifically, the city lacks (1) a procurement manual 

with clear standardized policies and procedures to guide procurement and 

agency staff; (2) certification requirements for procurement staff and 

training for agency staff so that both workforces have the necessary skills 

and knowledge to fulfill their responsibilities; and (3) an integrated 

procurement data system that can provide complete, accurate, and timely

information to inform acquisition decisions and management. Other cities

we reviewed recognize the benefit of having these tools as a way to 

effectively manage and oversee their procurement systems. 

Despite repeated recommendations since 1997 to develop a procurement 

policy and procedures manual, the District has yet to do so. Procurement 

is a complex process guided by numerous policies, documentation 

requirements, and procedures. A comprehensive manual—one that lays 

out in one place these policies and rules and standardized procedures and 

practices—is critical to ensuring procurement and agency staff have a 

clear and consistent understanding of contracting rules and processes. An 

internal study by the CPO’s office in 2004 found that in the absence of such 

guidance, there was a lack of consistency in how the District’s 

procurement work is done. This inconsistency creates frustration within 

and outside the government as well as an impression that the District’s 

procurement actions are unfair. 

The District Lacks a 

Procurement Manual to Guide 

Staff 

Each of the other cities we reviewed have developed and implemented a 

basic procurement manual for strengthening management, accountability,

and transparency in their procurement systems. In Atlanta, for example, 

when the new CPO was appointed in 2003, he found a comprehensive 

procurement manual was key and immediately took steps to update the 

manual, which had not been done in 7 years. 

According to former CPOs and current senior procurement officials, the 

District has not committed to developing a professional acquisition 

workforce For example, the CPO’s office has not fully developed 

professional certification requirements. Although the CPO is not required 

The District Lacks Professional 

Certifications for Procurement 

Staff 

Page 36 GAO-07-159 District of Columbia Procurement
to develop such requirements, this would ensure staff have the 

qualifications and skills to carry out the responsibilities commensurate 

with their delegated contracting authorities. A former District executive

told us that the CPO’s office should deliver regular training to agency 

managers and staff on procurement rules and procedures as well as 

develop metrics to ensure that agency staff participate in the training and 

obtain the necessary knowledge for fulfilling their responsibilities in the 

procurement process. 

One former CPO referred to his staff as an “accidental” procurement 

workforce because some had previously been administrative staff and few 

had any contracting background. In 2005, the CPO’s office conducted a 

skills and training assessment and determined that the current 

procurement and contracting staff required training on fundamental 

processes, such as source selection, contract negotiation, and contract 

administration. The CPO’s fiscal year 2006 budget added $668,400 

earmarked for procurement training, and the interim CPO developed a

program to train the District procurement staff on basic contracting 

concepts. While the 2006 training program appears to have addressed 

some of the immediate contracting skill gaps identified in the 2005 

assessment, this one-time effort, in our view, does not address the CPO 

office’s need for longer-term investments in training. Unlike in the federal

government, this program is not linked to a certification process or 

continuing education necessary for maintaining individual employee’s 

contracting authorities.48 In the absence of a comprehensive training and 

certification program, the CPO delegates contracting authority to 

procurement staff based on his perceptions of individual skill and 

experience.

NASPO emphasizes the importance of professional development and not 

only recommends that executive branch officials and the central 

procurement office encourage professional competence by providing 

funding for training, but endorse professional certification of staff. Several 

 48 The Federal Acquisition Institute and Defense Acquisition University have partnered to

provide a governmentwide course curriculum and other resources for the federal 

acquisition workforce. Specifically, the Federal Acquisition Institute has developed a

certification program for contracting professionals in civilian agencies that reflects 

common standards. This program closely mirrors that the requirements that the 

Department of Defense has established for its contracting workforce. The goal of the 

program is to standardize the education, training, and experience requirements for

contracting professionals, which is intended to improve workforce competencies and 

increase career opportunities.

Page 37 GAO-07-159 District of Columbia Procurement
public procurement organizations, including the National Institute for 

Government Purchasing, have developed certification programs to ensure 

procurement staff has attained a prescribed level of qualification. 

Procurement officials in other cities we reviewed also view training and 

certification of the procurement staff as critical to the success of their 

procurement system. For example, New York’s CPO office established a 

Procurement Training Institute in 2000 and requirements for staff training, 

including certifications and continuing education minimums. 

The District also lacks an integrated procurement data system to centrally 

manage and oversee agency and headquarters procurement activities, 

despite the procurement law requiring such a system over 20 years ago49

and investment in the Procurement Automated Support System (PASS), 

which was intended to provide these capabilities. Although the CPO’s 

office recognizes that capturing and reporting complete, accurate, and 

timely procurement data would increase transparency and support 

development of meaningful performance measures to promote

competition and discourage excessive use of sole-source contracts and 

unauthorized vendor commitments without valid contracts, officials have 

lacked the high-level support from District leaders and OCTO needed to

follow through on their plans for improvement. 

The District’s Integrated 

Procurement Data System Has 

Yet to Be Fully Implemented 

To make strategic, mission-focused acquisition decisions, organizations 

need knowledge and information management processes and systems that 

produce credible, reliable, and timely data about the goods and services 

acquired and the methods used to acquire them. Our prior work has shown 

that leading companies use procurement and financial management 

systems to gather and analyze data to identify opportunities to reduce 

 49The District’s Procurement Practices Act, as enacted, in 1986 required within 12 months 

of the effective date, the establishment of a comprehensive computer-based material 

management information system for collecting, organizing, disseminating, maintaining, and 

reporting procurement data that takes into account the needs of all branches of the District 

government. Further, the act required the system to permit measuring and assessing the 

impact of procurement activities on the economy of the District government and the extent

to which LSDBEs were sharing in the District’s contracts. Moreover, the act required the

system to (1) serve for policy and management control purposes, such as forecasting 

material requirements and purchasing; (2) reflect the state of the art in information systems 

technology; and (3) have the ability to accommodate future technical enhancements. 

Page 38 GAO-07-159 District of Columbia Procurement
costs, improve service levels, measure compliance and performance, and 

manage service providers.50 

After numerous discussions with procurement, financial management, and 

auditing officials, we found there is no visibility over total procurement 

actions and spending in the District. We found it difficult to get even the 

data on such basics as the number and dollar value of hundreds of millions 

of dollars in procurements for agencies not supported by the CPO’s office, 

such as the public schools and the Department of Mental Health. Data for 

the $1.2 billion in fiscal year 2005 procurement spending reported by the 

District’s CPO office are captured by several standalone systems. As a 

result, the CPO’s office cannot readily generate regular reports from these 

systems to track information on what agencies are buying, how they are 

buying, and from whom they are buying. When we initiated this review, we 

requested procurement data on such basics as the number of sole-source 

contracts awarded in a specified time frame, from the CPO’s office for 

fiscal years 2005 and 2006. The information was provided to us piecemeal. 

According to a District procurement official, to obtain this data, the CPO’s 

office must ask its contracting officers and specialists to manually 

compile, sometimes from memory, the information—a workaround that is 

not only time-consuming but at significant risk of error. Because of this, 

we were unable to obtain reliable fiscal year 2006 data on sole-source 

awards. 

In an effort to obtain complete, accurate, and timely procurement data and 

to automate and streamline the procurement process, the District has 

invested almost $13 million in PASS. Yet, almost 4 years since its inception 

in 2003, the system is only partially in operation.51 According to District 

procurement officials, PASS does not provide full information on 

completed or ongoing procurements across all agencies, nor does it 

provide CPO and District agency and financial managers reports and other 

information they need to manage and oversee the procurement system. In 

 50 GAO, Best Practices: Using Spend Analysis to Help Agencies Take a More Strategic 

Approach to Procurement, GAO-04-870 (Washington, D.C.: Sept. 16, 2004). 

51 According to the CPO’s office, PASS is a commercial procurement software application

that includes different modules. PASS supports the District’s on-line procurement process 

and is intended to help contracting personnel more efficiently purchase, report, and 

manage procurements. PASS is being incrementally deployed with the District having so far 

implemented two of the four modules, including (1) the automated, Web-based buying

module and (2) the module that facilitates Web-based obligation and approval for vendor 

payments. 

Page 39 GAO-07-159 District of Columbia Procurement
August 2006, the inspector general reported concerns over the delays in 

fully implementing PASS, noting that a conflict between the CPO’s office 

and OCTO has hindered the installation and full implementation of PASS.52

According to senior procurement officials, the CPO’s office has not 

consented to the extra $2 million that OCTO is requesting to fully 

implement PASS because all upgrades and installation were included in 

their purchase of PASS in 2003. The inspector general has recommended 

the CPO’s office seek assistance from the Mayor’s office in expediting the

installation and implementation of PASS’s contracting and sourcing 

modules. 

CPOs in the other cities we reviewed told us that a procurement data 

system is critical to managing and overseeing the procurement system, but 

some are facing challenges similar to the District’s to develop an 

integrated tool. New York’s CPO, for example, told us that the city clearly 

recognizes the importance of an integrated procurement data system and 

as a result, is engaged in a major undertaking to fully implement a data

system sometime in 2007. In the interim, she relies on information 

contained in the city’s financial management system in compiling various 

procurement performance indicators. 

The District’s Recent 

Actions to Address Its 

Procurement Management 

and Oversight Challenges 

Have Had Little Effect 

Since 2004, the District has taken several actions to improve the 

management and oversight of its procurement system. These efforts 

include an internal study for innovation and reform in the CPO’s office and 

procurement system; changes in staff assignments and review processes in 

the CPO’s office; and establishment of an expert task force to review CPO, 

procurement workforce, and competition matters and submit 

recommendations to the Mayor and council. However, information we 

obtained from former CPOs and current senior procurement and other 

officials involved with these efforts indicates that most recommended 

actions remain under study or are partially implemented at best. Most of

these officials voiced skepticism or concern about the merits and benefits

of these efforts as well as the absence of high-level and sustained attention 

from District leaders to address systemic problems that hamper 

management and oversight of the procurement system and undermine 

transparency, accountability, and competition. 

 52 Office of the Inspector General, District of Columbia, Office of Contracting and 

Procurement Part One: Report of Inspection, OIG No. 06-0017-PO (Washington, D.C.: Aug.

23, 2006). 

Page 40 GAO-07-159 District of Columbia Procurement
Following the early resignation of the District’s last full-time CPO in 

September 2004, the Mayor and city administrator directed the District’s 

Center for Innovation and Reform to work with the interim CPO’s staff to

lead a 6-week internal initiative to create a credible, transparent 

procurement process that incorporate best practices and innovation. This

internal group’s final report made several recommendations to the CPO’s 

office aimed at streamlining the process, providing tools such as a 

procurement manual, and leveraging technology.53 However, 2 years after 

these recommendations were made, many remained open. Further, none 

are aimed at the type of legal and organizational changes necessary for 

effective reform. 

More recently, the interim CPO took steps to provide better customer 

support from the Office of Contracting and Procurement to the District’s 

agencies and vendors. Specifically, the interim CPO announced in April 

2006 the establishment of sole-source contract reviews and 

implementation of a central tracking data system to ensure that contract 

ceilings are not exceeded, and to capture vendor performance data for 

consideration in future source selections affecting those vendors. The CPO 

also announced a new staffing alignment to assign a lead contracting 

officer for groups of agencies and several commodity buying groups for 

certain services that are centrally managed, such as construction and 

information technology equipment and services. According to senior 

procurement officials and the interim CPO, they expect that assigning 

contracting officers will improve communication and efficiency across the 

District as agencies will have a single point of contact for managing and 

troubleshooting contracting issues. While these are positive steps aimed at 

improving internal procurement operations, they are not far reaching 

enough to address the more fundamental problems impeding overall

effectiveness in the District’s procurement system. 

The third effort to improve District procurement has been ongoing since 

December 2005 when the Mayor and council passed legislation to establish 

a task force of local experts in contracting and procurement.54 The task 

force is comprised of 10 members appointed by the Mayor and council and 

 53 Center for Innovation and Reform, Executive Office of the Mayor, Contracting and 

Procurement Continuous Improvement Initiative: Recommendations for Reform 

(Washington, D.C.: Sept. 30, 2004). 

54 Contracting and Procurement Reform Task Force Establishment Emergency Act of 2005 

and the Contracting Reform Task Force Establishment Temporary Act of 2006. 

Page 41 GAO-07-159 District of Columbia Procurement
represents a range of professional, legal, and business expertise in District 

and public procurement operations and policy. Since March 2006, the task

force has met to obtain testimony and review other information from 

District procurement, financial management, auditors, and agency 

officials. At the time of our review, the task force chairman expected to 

report final recommendations to the Mayor and council before the end of 

2006. 

In addition to these actions the District has taken to address procurement 

system challenges, in December 2005, the Mayor, interim CPO, and CFO 

separately provided information to the Chairman of the House 

Government Reform Committee, who requested the information in light of 

press allegations about possible violations of the city’s procurement laws 

and procedures, and unauthorized payments to vendors. The Chairman 

noted that it was essential for the Committee to conduct an assessment of 

the District’s procurement system and the possible shortcomings in the 

laws, policies, enforcement and practices. In their separate responses, the 

Mayor, interim CPO, and CFO provided copies of the law, policies, and 

procedures in place in the District for procurement and contracting, 

including sole source and small purchase actions, exemptions for various 

agencies such as the public schools and Department of Mental Health, 

approval of voucher payments to vendors, and procurement and 

contracting oversight mechanisms through the District’s inspector general 

and auditor’s offices. In addition, the interim CPO provided information on 

recent actions taken by the Office of Contracting and Procurement to 

improve customer service and streamline the procurement process. 

However, information provided did not address the range of concerns and 

shortfalls in the procurement law and management and oversight that we 

subsequently identified during the course of our review. 

NASPO state government and city procurement officials we spoke with 

said they have confronted similar management and oversight challenges. 

They recognized that overcoming these challenges and achieving 

meaningful procurement reform can take several years and requires 

sustained executive support from elected leaders and legislatures. 

To better ensure every dollar of the District’s more than $1.8 billion 

procurement investment is well spent, it is critical that the District have an

effective procurement system that follows generally accepted key 

principles and is grounded in a law that promotes transparency, 

accountability, and competition, and helps to ensure effective 

management and oversight and sustained leadership. Currently, the 

Conclusion 

Page 42 GAO-07-159 District of Columbia Procurement
District’s procurement system is mired in a culture that thrives on 

streamlined acquisition processes, broad authority for sole-source 

contracts, and unauthorized payments to vendors that are eventually 

papered over through ratifications. Given this culture, it is not surprising 

that public confidence in the District’s ability to judiciously spend 

taxpayer dollars is guarded at best. To effectively address the District’s 

long-standing procurement deficiencies, it is clear that high-level attention

and commitment from multiple stakeholders—including Congress—are 

needed. Until the law provides for the right structure and authority, the 

District’s procurement reforms will likely continue to fail. 

To address needed structural and fundamental revision in the District’s 

procurement law and to strengthen management and oversight practices

as well as facilitate congressional oversight, we recommend that the 

Mayor of the District of Columbia submit a comprehensive plan and time 

frame to Congress detailing proposed changes in line with our 

recommendations. This comprehensive plan, to be submitted to Congress, 

should include the following recommendations for revising the 

procurement law: 

Recommendations for 

Executive Action 

• Apply, at a minimum, to all District entities funded through the 

District’s appropriated budget and specify that if exclusions from its 

authority are necessary, they be defined narrowly by types of goods 

and services procured. 

• Provide the CPO sole authority and responsibility as head of the 

District’s Office of Contracting and Procurement to manage and 

oversee the entire acquisition function for all entities, and if exclusions 

from the CPO’s authority are necessary, they be defined narrowly by 

types of goods and services procured. 

• Consider reestablishing the CPO as the sole authority for suspension 

and debarment decisions. 

• Eliminate sections 2-303.05(a)(3) and (a)(3A) of the District Official 

Code that allow noncompetitive procurements with a vendor who (a) 

maintains a price agreement or schedule with any federal agency; and 

(b) agrees to adopt the same pricing schedule as that of another vendor 

who maintains a price agreement or schedule with any federal agency. 

• Reconsider appropriateness of high dollar thresholds for small 

purchases to maximize competition. 

Page 43 GAO-07-159 District of Columbia Procurement
• Revise the DCSS program to (a) cap purchase ceilings at an 

appropriate threshold; (b) eliminate any schedule that contains fewer 

than three vendors or combine it with another schedule; (c) establish 

procedures to ensure all eligible vendors are provided an opportunity 

to be considered for orders; and (d) require the CPO to monitor and 

report on patterns of contracting with a limited number of the same 

vendors. 

• Require that specific guidance on the use of the DCSS program be 

incorporated into the District’s regulations. 

• Eliminate the procurement-related circumstance that allows direct 

voucher payments for emergency procurements. 

To further discourage the use of unauthorized commitments to vendors, 

we recommend that the Mayor of the District of Columbia, in coordination

with the CFO and other stakeholders take the following actions: 

• Revise Directive 1800.04 to be consistent with FAR part 1.6 and clearly

state, consistent with the policy of FAR section 1.602-3(b), that these 

ratification procedures are not to be used in a manner that encourage 

unauthorized commitments by government personnel. 

• Refer unauthorized commitments that are not ratified for further 

resolution under government claim procedures, to include in

appropriate cases, possible referrals for Anti-Deficiency Act violations. 

• Upon revision of the ratification directive, track and evaluate the use of 

direct voucher payments and ratifications to improve management 

attention and oversight of agencies’ unauthorized commitments with 

vendors. 

To strengthen management and oversight practices in the District’s 

procurement system, we recommend that the Mayor take the following 

actions: 

• Recruit and appoint a CPO with the requisite skills and procurement 

experience as required in the law. 

• Elevate the CPO’s position and office so that it is either in line with 

other critical cross-government functions, such as OCTO, or higher and 

would allow participation in cross-cutting executive management, 

budgeting, planning, and review processes. 

Page 44 GAO-07-159 District of Columbia Procurement
• Direct the CPO to develop a process and tools for frequent and regular 

interactions with agency heads and program managers to support 

acquisition planning. 

• Direct the CPO to develop a procurement manual concurrent with 

revision in the procurement law. 

• Direct the CPO to establish a plan and schedule for professional 

development and certification programs for contracting staff and to 

track personnel trained. 

• Direct OCTO to work with the CPO to expeditiously complete 

installation of an integrated procurement data system. 

To help ensure the District makes adequate progress in revising its 

procurement law and improving procurement management and oversight,

we recommend that the Mayor submit periodic reports to congressional 

oversight and appropriations committees on such elements by agency as 

(a) competitive actions by agency; (b) number, value, and type of sole 

source procurements; (c) numbers of procurement personnel trained and 

the type of training received; and other indicators as appropriate. 

In addition, to further discourage the use of unauthorized commitments to 

vendors, we recommend that the Chief Financial Officer (CFO) of the 

District of Columbia take the following actions: 

• Revise Financial Management and Control Order No. 05-002 to

eliminate the use of direct vouchers payments for emergency

procurements. 

• Work with the CPO and other stakeholders to do the following: 

(a) Revise Directive 1800.04 to be consistent with FAR part 1.6 and 

clearly state, consistent with the policy of FAR section 1.602-3(b), that 

these ratification procedures are not to be used in a manner that 

encourage unauthorized commitments by government personnel. 

(b) Refer unauthorized commitments that are not ratified for further 

resolution under government claim procedures, to include in

appropriate cases, possible referrals for Anti-Deficiency Act violations. 

(c) Upon revision of the ratification directive, track and evaluate the 

use of direct voucher payments and ratifications to improve 

Page 45 GAO-07-159 District of Columbia Procurement
management attention and oversight of agencies’ unauthorized 

commitments with vendors. 

We provided a draft of our report to the former Mayor’s office and the 

office of the CFO. The primary focus of our report deals with 

procurement reform needed in the District that falls under the 

responsibility of the Mayor. Therefore, most of our recommendations are 

made to the Mayor’s office. Given that the comment period coincided with

the final month of the administration, the outgoing Mayor chose not to 

comment. However, the new administration contacted our office and 

indicated concurrence with most of the findings and recommendations 

and, as the principal office responsible for ensuring action is taken, plans 

to provide formal comments and an action plan within 60 days of the 

report’s public release. 

Agency Comments 

and Our Evaluation 

Though most of our recommendations are made to the Mayor’s office, 

there is a role for the CFO to play in helping curb unauthorized 

commitments. Therefore, we also made recommendations to the CFO. In 

that context, the CFO provided written comments, which were limited to 

our discussion on the use of direct vouchers. Our response focuses only 

on those comments. 

In general, the CFO questions our understanding of the direct voucher 

process and the CFO’s authority. We recognize the limitations in the CFO’s 

authority for holding personnel accountable for unauthorized 

commitments and the CFO’s obligation to pay for accepted goods and 

services. However, focusing on limited authority and payment obligation 

does not address the larger issue. Specifically, our report raises a concern 

about the effect of the lack of management attention on prohibiting 

unauthorized commitments that may be ratified and ultimately paid 

through direct vouchers—a process CFO staff acknowledge is broken and 

in need of more stringent controls. Accordingly, we revised our 

recommendations to the Mayor and the CFO concerning the use of direct

vouchers and the ratification process. Strengthening this process is a 

small part of a larger procurement reform effort that must be headed by

the Mayor and implemented by the CPO, CFO, and other stakeholders in

the District. The CFO’s comments state that the office intends to review 

and clarify Financial Management and Control Order No. 05-002. We 

encourage them to implement our recommendations as well as work with 

the Mayor’s office and other stakeholders in coordinating procurement 

reform actions as applicable. 

Page 46 GAO-07-159 District of Columbia Procurement
The CFO’s comments are included in appendix III along with our 

comments on specific points he raised. 

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution of it until 30 days from 

the date of this report. We will then send copies to other interested 

congressional committees and the Mayor and Chief Financial Officer of 

the District of Columbia. We will make copies available at no charge on 

GAO’s Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-4841 or calvaresibarra@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. See appendix IV for a list of key contributors to 

this report. 

Sincerely yours, 

Ann Calvaresi Barr 

Director, Acquisition and Sourcing Management 

Page 47 GAO-07-159 District of Columbia Procurement
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

We conducted our work at the District of Columbia’s Office of Contracting 

and Procurement, Office of the CFO, Office of the Inspector General, 

Auditor’s Office, and Center for Innovation and Reform. We did not 

conduct detailed audit work at the various agencies that procure 

independently of the Office of Contracting and Procurement since this is 

the central office that was established under 1996 reform legislation and it

procures for 61 District organizations—a majority in the District. We also 

visited representatives of the National Association of State Procurement 

Officials (NASPO) in Springfield, Illinois, and city procurement officials in

Atlanta, Baltimore, and New York. In selecting cities to visit, we 

considered those that have faced similar challenges to the District as well 

as took various approaches to structuring their public procurement 

systems and implementing reform. We did not assess the effectiveness of 

their approaches or reform efforts and our report is not intended to 

suggest that we evaluated or endorse any particular approach from these 

cities, but only to draw comparisons to the District where applicable. 

In developing our criteria for generally accepted key principles for an 

effective public procurement system, we relied on a variety of sources. 

NASPO is a nationally recognized non-profit association comprised of 

directors of central purchasing offices in each of the 50 states and other 

member jurisdictions. NASPO has published a series of volumes related to 

state and local government purchasing with the most recent edition 

describing principles and suggested practices.1

 We also spoke with state 

procurement officials representing NASPO to obtain their perspectives on 

our analysis as well as their own states’ guiding principles and practices 

for an effective public procurement system. In addition to NASPO, the 

American Bar Association’s (ABA) model procurement code for state and 

local governments outlines principles for public procurement and provides 

a variety of options and strategies applicable to all public bodies.2

 The 

Federal Acquisition Regulation (FAR) also describes guiding principles of 

public procurement and though these are aimed at the federal government,

many are not unique to the federal acquisition system and are equally 

applicable to state and local governments. Finally, we leveraged our own 

 1

 NASPO, State & Local Government Purchasing: Principles & Practices, Fifth Edition 

(Lexington, Ky.: 2003).

2

 ABA, Model Procurement Code for State and Local Governments, adopted in 1979 and

updated in 2000. 

Page 48 GAO-07-159 District of Columbia Procurement
Appendix I: Scope and Methodology 

work since 2001 on effective procurement and acquisition management 

practices.3

To assess whether the District’s primary procurement law reflects 

fundamental principles that promote transparency, accountability, 

integrity, and competition, we did a detailed legal review and analysis of 

the Procurement Practices Act of 1985, as amended. We did not do a 

similar review or analysis of laws, policies, or regulations governing the 

various independent agencies or procurement authorities. In comparing 

the District’s primary procurement law to generally accepted key 

principles and assessing the impact of any shortfalls, we focused on 

several key elements that are recognized by a variety of sources for 

promoting transparency, accountability, integrity, and competition: 

(1) uniform application of the law across all District organizations; 

(2) adequacy of authority granted to the CPO for the full spectrum of 

acquisition functions; (3) exemptions in the law through various 

temporary, emergency, or permanent legislative amendments; and 

(4) provisions in the law that limit or restrict competition, such as 

authority for sole-source contracting, simplified acquisition procedures, 

and use of supply schedule. Our review also examined recent legislation 

that was passed in response to various procurement challenges that had 

been identified to include changes in law and policy resulting from the 

CFO’s review of direct voucher payments for unauthorized commitments 

with vendors for goods and services without valid contracts.

To further understand the rationale and impact of these various provisions 

and related procurement issues, we interviewed current and former 

procurement, executive, financial management, and auditing officials in 

the District. We also spoke to a D.C. Council committee representative 

regarding legislative actions to address reported procurement problems 

and related issues. In addition, we interviewed state government 

 3

 GAO, District of Columbia: D.C. Public Schools Inappropriately Used Gas Utility 

Contract for Renovations, GAO-01-963 (Washington, D.C.: Sept. 28, 2001); Best Practices: 

Taking a Strategic Approach Could Improve DOD’s Acquisition of Services, GAO-02-230 

(Washington, D.C.: Jan. 18, 2002); Metropolitan Washington Airports Authority: 

Contracting Practices Do Not Always Comply with Airport Lease Requirements, 

GAO-02-36 (Washington, D.C.: Mar. 1, 2002); Transportation Security Administration: 

High-Level Attention Needed to Strengthen Acquisition Function, GAO-04-544 

(Washington, D.C.: May 28, 2004); Homeland Security: Successes and Challenges in DHS’s

Efforts to Create an Effective Acquisition Organization, GAO-05-179 (Washington, D.C.: 

Mar. 29, 2005); and United Nations: Procurement Internal Controls Are Weak, GAO-06-577 

(Washington, D.C.: Apr. 25, 2006). 

Page 49 GAO-07-159 District of Columbia Procurement
Appendix I: Scope and Methodology 

procurement leaders of NASPO about sound principles and practices 

regarding public procurement statutory coverage and their views on issues 

we raised about the District’s procurement law. We also interviewed city 

procurement officials in Atlanta, Baltimore, and New York to obtain their

views on issues we raised concerning the District’s procurement law and 

to learn about related challenges they have faced and their responses to 

these challenges. 

To assess the extent to which the District’s management and oversight of 

the procurement process reflect generally accepted practices, we 

examined several key elements. First, we examined the organizational 

alignment and leadership for managing the acquisition function across all

District organizations. Second, we assessed management’s commitment to 

competence including elements required for a professional procurement 

workforce. Third, we reviewed the District’s development of procurement 

management and oversight tools, including a procurement manual and 

automated data systems for recording procurement information. To gain

insights on the challenges of procurement management and oversight in 

the District, we interviewed current and former city procurement and 

District executive officials to obtain their perspectives. To obtain an 

historical perspective on the management and oversight challenges in the

District that drove legislation reform in 1996, we reviewed various studies 

done at that time and their recommendations. To understand how the 

District has addressed those challenges, we reviewed selected District 

inspector general and auditor reports since 2004, and the resulting 

recommendations as well as those from the internal study of the Center 

for Innovation and Reform. We interviewed responsible city procurement 

officials on the status of addressing those recommendations. We also 

interviewed the chairman of the Contracting and Procurement Reform 

Task Force, which was established in 2006 to review the District’s 

procurement system and attended several public meetings to observe their 

discussions. 

In the course of our review, we relied on various management and other 

procurement data reports provided by the Office of Contracting and 

Procurement. Specifically, information on procurement spending in 

dollars and contracting and competition methods was generated from 

various procurement data systems or compiled from manual inputs. 

Though we did not conduct detailed tests of procurement transactions, 

data reliability was suspect for these various reports based on very limited

testing and independent auditors have also raised questions about the 

data. To fully test data reliability for all the various reports we received 

would have required resources outside the scope of this review. Moreover, 

Page 50 GAO-07-159 District of Columbia Procurement
Appendix I: Scope and Methodology 

an independent public accounting firm audits the District’s financial 

statements annually and reports on internal control and compliance over

financial reporting. Compliance with procurement regulations was part of 

the fiscal year 2005 audit in which the District received an unqualified,

clean opinion. Despite the limitations, we found the data to be reasonable 

and sufficiently reliable for our purposes. Further, we have attributed, 

where applicable and appropriate, this information to the Office of 

Contracting and Procurement and responsible officials. 

This work was done between February 2006 and October 2006 in 

accordance with generally accepted government auditing standards. 

Page 51 GAO-07-159 District of Columbia Procurement
Appendi

Procure

x II: District Governance and Related

ment Authorities 

Page 52 GAO-07-159

Appendix II: District Governance and Related 

Procurement Authorities 

In 1973, Congress enacted the District of Columbia Self-Government and 

Governmental Reorganization Act or Home Rule Act,1

 which set forth the 

structural framework of the current District government in the District 

Charter. The District Charter established the Office of the Mayor and 

vested the Mayor with the executive power. It also established the D.C. 

Council and delegated certain legislative powers to it.2

 Despite the powers 

delegated to the Council, Congress retained the ultimate legislative 

authority over the District under the Constitution.3

 Generally, the 

Constitution authorizes Congress to enact legislation on any topic for the 

District and to amend or repeal any District act. 

Home Rule Act 

With regard to the powers delegated to the Council, the Home Rule Act 

authorized it to pass permanent and emergency acts. A permanent act 

starts as a bill, which usually gets introduced by a Council member and 

then gets assigned to and considered by the proper committee. The 

committee then reports the bill to the Committee of the Whole (the entire 

Council), which reviews it before it is put on agenda for regular session. 

Hearings are required for permanent legislation before it is adopted.4

 The 

Council votes on a bill two times, during first and second readings. 

However, 15 days before the Council adopts a bill, it must be published in

the D.C. Register.5

 The Mayor then can either (1) sign the bill or take no 

action and it becomes an act or (2) veto the bill and Council can override 

the veto by two-thirds majority. The act must then be published in the 

D.C. Register. The Council chair transmits the act to both houses of 

Congress, which have 30 calendar days (or 60 calendar days for criminal 

acts) to review the act and if they take no action, the act becomes law. 6

 1

 Pub. L. No. 93-198 (1973). The federal Act was supplemented by D.C. Council Rules, which 

provide rules of organization and procedure for the Council. It should be noted that a 

Council enactment is cited as an “act” but a congressional enactment is cited as an “Act.”

2

 The D.C. Council has 13 members who are elected for 4-year terms. 

3

 U.S. Const., art. I, § 8, cl. 17. 

4

 Council Rule, Art. IV, § 305. Hearings require public notice and may be given by

publication in the D.C. Register, in newspapers, mailing notices to a mailing list maintained 

by the Secretary, and by other means. Council Rule, Article IV, § 425.

5

 Council Rule, Art. IV, § 422. 

6

 The 30-day period excludes Saturdays, Sundays, and holidays, and any day on which 

either House of Congress is not in session. Thus, if one or both of the Houses are out of 

session, a day cannot be counted within that time. Home Rule Act, section 602 (c)(1). Also, 

Congress usually adjourns in October. As a result, any act passed by the Council after July 

usually will not become law until the following year.

District of Columbia Procurement
Appendix II: District Governance and Related

Procurement Authorities 

Congress may disapprove the act by adopting a joint resolution of 

disapproval, which must be signed by the President. Unless the President 

vetoes the act, it becomes law within 30 days. 

Emergency acts are quicker to pass than permanent acts, since they are 

not required to go through (1) committee, (2) a second reading, (3) a 

public hearing, (3) congressional approval, and (4) publication in the D.C.

Register before becoming effective, but must be published after that. 7

 For 

an emergency act, the Council must decide by two-thirds of the members 

that emergency circumstances make it necessary that an act be passed. 8

Emergency acts are effective for 90 days. 

With regard to the executive power, the Home Rule Act vested in the 

Mayor, who is the chief executive officer of the District government, the 

power to properly execute all laws relating to the District. The Mayor may 

delegate any function to (1) any officer, employee, or agency of the 

executive office of the Mayor or (2) any director of an executive 

department who may, with the Mayor’s approval, further delegate all or 

part of the functions to subordinates under the Mayor’s jurisdiction. 9

In addition to establishing these branches of government in the District, 

the Home Rule Act also established five independent agencies existing 

outside the control of the executive or legislative branches of the District 

government. The independent agencies were the (1) Board of Education; 

 7

 The legislative history of the Home Rule Act does not provide insight about what 

Congress intended regarding the frequency or circumstances in which the Council should

use the emergency act provision. If the Council finds the existence of an emergency and 

approves an emergency bill, the Council may, at the same legislative session, consider a 

temporary bill on first reading without committee referral; the temporary bill must be 

“substantially similar” to the emergency bill and may remain effective for not more than 

225 days. Temporary legislation is passed with an emergency legislation to ensure that 

some legislation is in effect while permanent legislation is before Congress and to fill the 

gap between the expiration of an emergency act and the effective date of a permanent act. 

8

 Current Council rules clarify that an “emergency” means a situation that adversely affects 

the health, safety, welfare, or economic well-being of a person for which legislative relief is 

deemed appropriate and necessary by the Council, and for which adherence to the ordinary

legislative process would result in delay that would adversely affect the person whom the

legislation is intended to protect. It also clarifies that legislation must take effect, 

according to its terms, either immediately or at a specific time. Council Rule, Art. IV, § 

412(b)(c). 

9

 The Mayor cannot, however, delegate the authority of approving or disapproving acts

passed by the Council. Home Rule Act, § 422(6). 

Page 53 GAO-07-159 District of Columbia Procurement
Appendix II: District Governance and Related

Procurement Authorities 

(2) Armory Board; (3) Public Service Commission; (4) Zoning 

Commission; and (5) Board of Elections. 

Procurement Practices Act 

of 1985 

In 1986, the Council enacted the D.C. Procurement Practices Act of 1985,10

pursuant to the Council’s authority to pass acts under the Home Rule Act.11

One of the primary underlying statutory policies of the act was to provide 

for a uniform procurement law and procedures for the District of 

Columbia government. To achieve this policy, the Procurement Practices 

Act applied to all agencies and employees of District government which 

were subordinate to the Mayor.12 The Procurement Practices Act excluded 

from its application a separate branch of government or an independent 

agency (as defined in D.C. Administrative Procedures Act) that had 

authority to enter into contracts or to issue rules and regulations for 

awarding contracts pursuant to existing law.13 The Procurement Practices 

Act applied to every contract, interagency agreement, or 

intergovernmental agreement for procurement or disposal of goods and 

services by covered agencies and employees. 

The Procurement Practices Act also created in the executive branch of the 

District government the Contract Appeals Board. The appeals board was 

the exclusive hearing tribunal for and had jurisdiction to review and 

determine de novo throughout the District government the following: 

(1) protests of a solicitation or contract award and (2) appeals from a final 

decision of the Director of Administrative Services. It allowed 

disappointed contractors to appeal board decisions to the D.C. Court of 

 10 D.C. Law 6-85 (1986), codified at the D.C. Official Code, § 2-301 et seq. 

11 Home Rule Act, § 412(a). The Procurement Practices Act provided that nothing in the act

or in its implementing regulations abrogates the powers and duties of the Mayor pursuant

to the Home Rule Act or any other law not specifically repealed by the Procurement

Practices Act. D.C. Law 6-85, § 201(b) (1). 

12 Although the Procurement Practices Act did not define the term “subordinate agency,” it 

defined the term “agency” as used in the act to exclude an independent agency from its

application, so we know that a subordinate agency is not an independent agency. D.C. Law 

6-85, § 107(2). 

13 The D.C. Administrative Procedures Act provides that “independent agency” means any 

agency of the government of the District with respect to which the Mayor and the Council 

that is not authorized by law, other than by this title, to establish administrative 

procedures, but does not include the courts of the District and the District of Columbia Tax

Court. The District of Columbia Administrative Procedures Act of 1968, Pub. L. No. 90-614, 

§ 102(5). The Act did not enumerate specific agencies that were independent. 

Page 54 GAO-07-159 District of Columbia Procurement
Appendix II: District Governance and Related

Procurement Authorities 

Appeals. It also established bid protest procedures for protests of the 

solicitation or award of a contract. 

Procurement Reform 

Amendment Act of 1996 

The Procurement Practices Act was amended by the Procurement Reform 

Amendment Act of 1996 (reform act) with the primary statutory purpose 

to centralize procurement in the Office of Contracting and Procurement. 14

The law required this office to be headed by a Chief Procurement Officer 

(CPO). By delegation of the Mayor, the CPO has the exclusive contracting 

authority for all procurements covered by the Procurement Practices Act.15

The reform act further centralized procurement in the CPO by requiring 

the CPO rather than the Mayor to delegate contracting authority to 

employees of District entities subject to the act and to employees of Office

of Contracting and Procurement who are contracting officers and 

specialists in procurement. All delegations must be subject to limitations 

specified in writing. 

The reform act also changed some of the requirements for sole-source 

emergency procurements, which the Procurement Practices Act 

authorized the executive branch to use. Specifically, the reform act 

allowed contracting officers to make and justify sole source emergency 

procurements when there was an imminent threat to the public health, 

welfare, property, or safety under emergency conditions.16 The 

requirement is implemented in the District’s regulations, which defines an 

“emergency condition” as a situation, such as a flood, epidemic, riot, or 

equipment failure that created the imminent threat.17

The reform act expanded the Procurement Practices Act’s application to 

include independent agencies, which were previously excluded from its 

application. Specifically, the act applied to all departments, agencies, 

instrumentalities, and employees of the District government, including 

agencies which are subordinates to the Mayor, independent agencies, 

boards, and commissions. It applies to any contract for the procurement 

of goods and services, including construction and legal services. 

 14 D.C. Law 11-259 (1997). 

15 Id. at § 105 (a) (b). 

16 Id. at § 105 (p) (codified at D.C. Official Code § § 2-303.05(a) (4)and 2-303.12 (a)(1). 

17 27 DC ADC 1710.2. 

Page 55 GAO-07-159 District of Columbia Procurement
Appendix II: District Governance and Related

Procurement Authorities 

Despite the reform act’s primary statutory purpose of centralizing the 

District’s procurement authority in the Office of Contracting and 

Procurement, it excluded many entities from the authority of both the 

Office of Contracting and Procurement and the Procurement Practices 

Act. 18 Specifically, it excluded: 

• the D.C. Council; 

• the D.C. courts; 

• the D.C. Financial Responsibility and Management Assistance

Authority (Control Board), as Congress previously statutorily excluded 

the Procurement Practices Act’s application to the Control Board and 

vested the Board’s contracting authority in its Executive Director; 19

• the Office of the Chief Financial Officer (CFO), and required the Chief 

Financial Office, during a control year,20 to adopt the Control Board’s 

procurement rules and regulations, except that during years other than 

control years, Office of the CFO must be bound by provisions in this 

act. 21

 18 D.C. Law 11-259, § 104 (a)(c) (codified at D.C. Official Code § 2-301.04). 

19 Under the District of Columbia Financial Responsibility and Management Assistance Act 

(FRMAA) of 1995, Pub. L. No. 104-8 (1995), Congress established the Control Board upon 

finding that the District government was in a fiscal emergency, was plagued by pervasive 

mismanagement, and failed to deliver effective or efficient services to residents. FRMAA, at 

§ 305(4). The Control Board was provided wide-ranging statutory powers to improve the

District government’s operations, including authority to award contracts and review and 

approve certain contracts. FRMAA, at §§ 102(c)(2), 103(g), and 203(b). 

20 A control year, as defined in the FRMAA, means any fiscal year for which a financial plan 

and budget approved by the Control Board is in effect, and includes fiscal year 1996. 

FRMAA, § 305(4). The District government was under the Control Board’s authority from

April 1995 until September 2001. 

21 D.C. Law 11-259, § 104(c). Despite the provision that the Office of the CFO must be 

bound by provisions in the Procurement Practices Act during years other than control

years, Congress has extended the authority provided to the CFO to exercise the 

procurement authority granted to it during a control year in several appropriations acts 

relating to the District. The most recent appropriation act relating to the District exempts

the CFO’s acquisitions from all provisions of the Procurement Practices Act.

Transportation, Treasury, Housing and Urban Development, the Judiciary, the District of

Columbia, and Independent Agencies Appropriations Act, 2006, Pub. L. No. 109-115, § 132

(2005). 

Page 56 GAO-07-159 District of Columbia Procurement
Appendix II: District Governance and Related

Procurement Authorities 

Further, the reform act added a new section in the Procurement Practices

Act,22 exempting the following entities from the authority of the 

Procurement Practices Act and Office of Contracting and Procurement: 

• Redevelopment Land Agency with regard to real property or interests 

therein; 

• Administrator of Homestead Program Administration under Homestead 

Housing Preservation Act of 1986 with regard to disposal or transfer of 

real property; 

• Mayor to sell real property in D.C. for nonpayment of taxes or

assessments of any kind;

• Mayor and D.C. Council pursuant to D.C. Public Space Rental Act; 

• Convention Center Board of Directors pursuant to the Washington 

Convention Center Management Act of 1979; 

• Sports Commission pursuant to the Omnibus Sports Consolidation Act 

of 1994; 

• D.C. Housing Finance Agency; 

• D.C. Retirement Board pursuant to the D.C. Retirement Reform Act; 

and 

• Metropolitan Police Department’s authority to make procurements of 

$500,000 or less, as provided in the D.C. Appropriations Act, approved 

April 6, 1996. (Pub. L. No. 104-134). 

Since enactment of the 1996 reform act, the Council has amended the 

Procurement Practices Act many times to exempt additional entities from 

falling under the authority of the Office of Contracting and Procurement or 

Procurement Practices Act or both, despite the Procurement Practices 

Act’s statutory purposes of creating uniform procurement laws in the 

District and centralizing the District’s procurement authority in the Office

of Contracting and Procurement. To date, in addition to those entities 

mentioned above, the council excluded the following entities from the 

authority of both Office of Contracting and Procurement and Procurement 

Practices Act: 

• D.C. Water and Sewer Authority; 

• D.C. Public Service Commission; 

• D.C. Housing Authority, except for the provisions regarding contract 

protests, appeals, and claims arising from procurements of the Housing 

Authority; and 

• D.C. Advisory Neighborhood Commissions. 

 22 D.C. Law 11-29, § 320 (codified at D.C. Official Code § 2-303.20). 

Page 57 GAO-07-159 District of Columbia Procurement
Appendix II: District Governance and Related

Procurement Authorities 

Further, the Council amended to Procurement Practices Act to exclude 

the following entities from the authority of Office of Contracting and 

Procurement, but they are subject to the Procurement Practices Act: 

• Director of the Child and Family Services Agency;

• Criminal Justice Coordinating Council; 

• Director of the Department of Mental Health; and

• Board of Education to solicit, award, and execute contracts, except for 

security for the District’s public schools for security contracts to begin 

on or after June 30, 2005. 

Also, the Council exempted delivery of electrical power and ancillary 

services for the District from certain requirements of the Procurement 

Practices Act, subject to Council approval. 

In addition to these exemptions, the Council continues to use its 

emergency act authority under the Home Rule Act to exempt the 

application of all or certain provisions of the Procurement Practices Act or 

the authority of the Office of Contracting and Procurement for certain 

District entities or projects. These exemptions can last no more than 90

days or can become permanent if the emergency bill is accompanied by a 

temporary bill bridging the gap between expiration of the 90-day 

emergency bill and congressionally-approved permanent legislation on the 

same matter.

Page 58 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief Financial Officer Appendix III: Comments from the Chief for the District of Columbia

Financial Officer for the District of Columbia 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

Page 59 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief Financial Officer 

for the District of Columbia

See comment 1. 

See comment 2. 

Page 60 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief Financial Officer 

for the District of Columbia

See comment 3. 

See comment 4. 

Page 61 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief Financial Officer 

for the District of Columbia

See comment 5. 

Page 62 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief Financial Officer 

for the District of Columbia

Page 63 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief Financial Officer 

for the District of Columbia

See comment 5. 

Page 64 GAO-07-159 District of Columbia Procurement
Appendix III: Comments from the Chief 

Financial Officer for the District of Columbia

The following are GAO’s comments on the CFO’s letter dated January 5, 

2007. 

1. As we state in the report, the CFO’s analysis of fiscal year 2004 direct 

voucher payments showed that $217 million fell outside a 1996 

financial management and control order. It was only after the CFO, in 

2005, added 7 more acceptable uses of direct vouchers to the original 

order, that these payments were found to be acceptable. The $4 million 

in payments referred to in the CFO’s comments are those that fell 

outside this updated policy. 

GAO Comments 

2. We recognize that the CPO’s office is not directly responsible for 

developing financial management policies. However, we believe that in 

order to effect meaningful procurement reform, the CPO should be 

consulted on any policy changes that affect procurement—particularly 

as such changes have been amended into the procurement law. 

Elevating the CPO within the District government, as we recommend, 

would facilitate needed coordination. 

3. Because the District’s procurement law already establishes emergency 

contracting procedures, we stand by our finding and recommendation 

that including emergency procurements as an acceptable use of direct 

vouchers duplicates the provision in the law and allows agencies to 

bypass established contracting procedures. 

4. As we state in the agency comments section, we recognize the

obligation to pay for accepted goods and services, but we are 

concerned that the current policy, now codified in the law, is a 

symptom of the lack of necessary management focus to minimize the 

number of unauthorized commitments that may be ratified and 

ultimately paid through direct vouchers. In meetings with CFO staff, 

they acknowledged that the ratification process needs strengthening to

include, in appropriate cases, possible referrals for Anti-Deficiency Act 

violations. 

5. The scope of our review was on the District’s procurement system as a 

whole, not on the direct voucher process. As part of this review, we 

examined and discussed with chief procurement officers reform 

efforts in other cities. Through these discussions, we learned that 

other cities have consistently taken steps to curb the use of direct 

vouchers where at all possible and to ensure strict controls are in 

place to hold employees accountable when their actions result in an 

unauthorized commitment to vendors. 

Page 65 GAO-07-159 District of Columbia Procurement
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 66 GAO-07-159 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

Ann Calvaresi Barr (202) 512-4841 or calvaresibarr@gao.gov

In addition to the individual named above, Carolyn Kirby, Assistant 

Director; Barry DeWeese; Cynthia Auburn; Rachel Girschick; Kevin Heinz;

Bill Petrick; Sylvia Schatz; and Karen Sloan made key contributions to this 

report. 

District of Columbia Procurement

GAO Contact

Staff 

Acknowledgments 

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