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OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

AUDIT

The U.S. Geological Survey and 

Quantum Spatial, Incorporated, 

Did Not Always Comply With

Federal Regulations, Policies, 

and Award Terms for Task Order 

No. 140G0218F0251 and Contract 

No. G16PC00016

In recognition of Secretarial Order No. 3380, we are providing estimated costs 

associated with certain work products. Applying a formula involving prior salary and 

benefit expenses, we estimate the cost of preparing this report to be $118,000.

Report No.: 2018-FIN-051 August 2020

This is a revised version of the report prepared for public release.
 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: Scott Morton 

Bureau Procurement Chief, U.S. Geological Survey 

From: Chris Stubbs 

Director, Office of Financial and Contract Audits 

Subject: Final Audit Report – The U.S. Geological Survey and Quantum Spatial, 

Incorporated, Did Not Always Comply With Federal Regulations, Policies, and 

Award Terms for Task Order No. 140G0218F0251 and Contract 

No. G16PC00016 

Report No. 2018-FIN-051 

This report presents the results of our audit of Task Order No. 140G0218F0251 and 

Contract No. G16PC00016 between the U.S. Geological Survey (USGS) and Quantum Spatial, 

Incorporated. 

We make two recommendations regarding invoice review and three recommendations 

regarding contract administration to help the USGS improve its contract oversight and maintain 

complete and comprehensive documentation. Based on the USGS’ response to our draft report, 

we consider all five recommendations to be resolved but not implemented. We will refer the 

recommendations to the Assistant Secretary for Policy, Management and Budget for 

implementation tracking. 

If you have any questions about this report, please contact me at 202-208-5745. 

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit, inspection, and evaluation reports issued; actions taken to 

implement our recommendations; and recommendations that have not been implemented. 

Office of Inspector General | Washington, DC 
Table of Contents 

Results in Brief ................................................................................................................................1 

Introduction......................................................................................................................................2 

Objectives ................................................................................................................................. 2 

Background............................................................................................................................... 2 

Findings............................................................................................................................................3 

QSI Did Not Comply With Contract Terms ............................................................................. 3 

QSI Submitted Mathematically Incorrect Invoices............................................................. 3 

QSI Submitted Invoices Without Required CLINs ............................................................ 5 

The USGS Did Not Comply With Federal Regulations and Award Terms ............................. 6 

The USGS Did Not Include a Required Clause in the Contract......................................... 6 

The USGS Did Not Document the Contract Negotiations Properly................................... 7 

The USGS Negotiated a Fair and Reasonable Price for the Task Order .................................. 8 

Conclusion and Recommendations..................................................................................................9 

Conclusion ................................................................................................................................ 9 

Recommendations Summary .................................................................................................... 9 

Appendix 1: Scope and Methodology............................................................................................11 

Appendix 2: Response to Draft Report..........................................................................................12 

Appendix 3: Status of Recommendations......................................................................................15 
 

 

 

 

 

 

 

 

 

 

 

 

Results in Brief 

We audited Task Order No. 140G0218F0251 and Contract No. G16PC00016 between Quantum 

Spatial, Incorporated (QSI) and the U.S. Geological Survey (USGS) to determine whether 

(1) QSI complied with all applicable Federal regulations and terms and conditions of the task

order and the governing contract, (2) the USGS complied with all applicable Federal regulations,

USGS policies and procedures, and award terms and conditions when awarding and monitoring

the contract and the task order, and (3) the USGS negotiated a fair and reasonable price for

services rendered under the task order. We reviewed supporting documentation and compliance

from the beginning of the solicitation phase in October 2014 through December 2018.

We found that QSI and the USGS did not always comply with applicable regulations, policies, 

and contract terms and conditions. Specifically: 

• QSI submitted invoices that were mathematically incorrect.

• QSI submitted invoices that did not include contract line item numbers as required.

• The USGS did not include a required clause in the contract.

• The USGS did not document the contract negotiations properly.

In addition, we found that the USGS negotiated a fair and reasonable price for the task order. 

We make two recommendations regarding invoice review and three recommendations regarding 

contract administration to help the USGS improve its contract oversight and maintain complete 

and comprehensive documentation. Based on the USGS’ response to our draft report, we 

consider all five recommendations to be resolved but not implemented. We will refer the 

recommendations to the Assistant Secretary for Policy, Management and Budget for 

implementation tracking. 

1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Introduction 

Objectives 

The objectives of our audit were to determine whether: 

1. Quantum Spatial, Incorporated (QSI) complied with all applicable Federal regulations 

and terms and conditions of the task order and the governing contract 

2. The U.S. Geological Survey (USGS) complied with all applicable Federal regulations, 

USGS policies and procedures, and award terms and conditions when awarding and 

monitoring the contract and the task order 

3. The USGS negotiated a fair and reasonable price for services rendered under Task Order 

No. 140G0218F0251 

See Appendix 1 for the audit scope and methodology. 

Background 

On February 9, 2018, the U.S. Congress passed the Bipartisan Budget Act of 2018 (Pub. L. 

No. 15-123), which provided funding for recovery from the 2017 wildfires and necessary 

expenses related to the consequences of Hurricanes Harvey, Irma, and Maria. The USGS 

received $42,246,000 in supplemental appropriations as part of the legislation. 

The USGS had previously awarded an indefinite-delivery/indefinite-quantity (IDIQ) contract, 

Contract No. G16PC00016, to QSI on February 10, 2016.1 The contract was for 

photogrammetric mapping, survey, and other services. The contract ceiling was $750 million 

over a 12-month base period plus four additional 12-month option periods. 

Using the supplemental appropriations funding from the Bipartisan Budget Act, the USGS 

awarded firm-fixed-price Task Order No. 140G0218F0251 under Contract No. G16PC00016 to 

QSI in the amount of $3,007,097 with a period of performance from May 15, 2018, to May 31, 

2021. The task order was modified to add $2,168,963 as of December 31, 2018, increasing the total 

value to $5,176,060. The purpose of the task order was to provide mapping and surveying 

services for approximately 19,990 square miles in northern California. The images will be used 

to support various programs of the Federal Emergency Management Administration, the 

U.S. Forest Service, and California Wildfire. 

From this point forward in the report, we use the term “contract” to refer to both the IDIQ 

contract and the task order issued under it. 

1 Indefinite-delivery/indefinite-quantity contracts do not define the exact time or quantity of services or supplies to be provided 

within a fixed time period. They provide the rate for those services or supplies and other terms and conditions the contractor must 

meet. This provides flexibility to best meet U.S. Government needs when the exact supplies or services required are not known at 

the time of award. 

2 
 

 

 

 

 

 

Findings 

We found that QSI and the USGS did not always comply with applicable regulations, policies, 

and contract terms and conditions. Specifically: 

• QSI submitted invoices that were mathematically incorrect.

• QSI submitted invoices that did not include contract line item numbers (CLINs) as

required.

• The USGS did not include a required clause in the contract.

• The USGS did not document the contract negotiations properly.

In addition, we found that the USGS negotiated a fair and reasonable price for services rendered 

under the task order. 

QSI Did Not Comply With Contract Terms 

QSI Submitted Mathematically Incorrect Invoices 

We examined all the invoices paid during our scope—a total of seven invoices from the start of 

the task order on May 15, 2018, to December 31, 2018, totaling $2,450,865. We found that five 

of those invoices were mathematically incorrect (see Figure 1). 

Figure 1: Math Errors on QSI Invoices Submitted For Work Performed 

From May 15, 2018, to December 31, 2018 

Cumulative Cumulative Cumulative 

Invoice Billed Correct Over/(Under) 

No. Amount ($) Amount ($) Billed ($) 

1 60,142 60,142 – 

2 105,248 105,248 – 

3 350,627 350,026 601 

4 562,327 958,606 (396,279) 

5 1,200,846 1,270,205 (69,359) 

6 1,337,912 1,359,233 (21,321) 

7 2,450,865 2,449,413 1,452 

3 
We found that QSI did not conectly calculate the cumulative amount billed, which resulted in 

QSI either overbilling or underbilling the USGS. For each billable item, the invoice shows the 

percentage of work completed at that time. The billable amount is dete1mined by multiplying the 

fixed total cost by the percentage complete (see Figure 2 for an example invoice). QSI made 

enors in those calculations that resulted in incon ect cumulative amounts billed. 

Figure 2: QSI Invoice No. 4, With Errors Identified 

INVOICE PERIOD Of' Pfffl'ORMANCE: ll6!01f18 ·- 08/3V18 

BU..JltG METHOD: Mlie6b:le Peroent 

TASK ORDER 'IIAILUE: 55.176~.00 

Bllaible 

~ 

0001 1 1DOJIO% s 103.521.20 s •03.S21c20 $fill.141.94 w.oo i 

0002 dffillt W.M.:RI SIIM Sd'.oo $3.M 

0014 0..00% $103,,521.20 $1!1.00 $0..00 $OJlO 

0006 

IIOIJ7 

0008 

0003 

0004 $155,281.80 $1].00 $0..00 $0.00 

0005 $155,281.80 ,51lJ.OO ».00 I0.00 

II009 $ 1 $,.281.80 $11.00 ».00 $0.IIO 

0010 5155,.26'1,BD m.oo ».00 I0.00 

0011 $-155,.281.80 $111.00 ».00 $0..IIO 

0012 $155,281.80 $1].00 $0..00 $0.00 

0013 $-155,281.80 ~.DO ».00 I0.00 

0015 ~ 1.760.EiD $1].00 ».00 $0JIO 

0016 5517.(i06.III m.oo SOJIO ______ J0=.00--' 

SUblotalL ••.•..•.••.•. ·-·······-·· .• - .............................................................. _ $211,699.65 

TOTAL AIIOl.fiT NOW DUE .. - ·-·- ·- ....... -·-··-······ ... - .............. _ ........ - ....... - ... ····-·- $211.CS.GS 

Pn!'t10ll61y Blled $35!'.l.,6Z7 .53 

BIiied T1llS ll'nrc:1:e $2I1,.(i~.65 

Tilltal 881~ ID Dai!! 5562,.327 .18 

As an example, looking at Invoice No. 4 above, QSI made the following math en ors in line 

items 1, 7, and 8: 

• For item 1, QSI subtracted the previous amount billed of $60,142 from the billable 

amount of $103,521 and recorded $0 as the cumulative amount instead of $43,379. 

• For item 7, QSI multiplied the delive1y value of $2,225,706 by 34 percent complete and 

recorded $444,449 instead of the con ect amount of $756,740, an underbilling of 

$312,291. 

• For item 8, QSI multiplied the delive1y value of $517,606 by 19 percent complete and 

recorded $57,736 instead of the con ect amount of $98,345, an underbilling of $40,609. 

The total of all these enors was an underbilling of $396,279 for Invoice No. 4. Across all seven 

invoices, the cumulative amount overbilled was $1,452, as shown in Figure 1. 

QSI acknowledged the invoicing discrepancies we noted and took immediate conective action. 

The miscalculations resulted from human enor during invoice preparation and were not caught 

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because an independent party did not perform a final check. QSI stated that it implemented a 

change to the invoice process. Each project manager now receives a draft copy of the monthly 

invoice for review, paying particular attention to validating the amount billed, percentage 

complete, delivery value, and total amount for each item. 

At the USGS, the math errors in the invoices went unnoticed by the contracting officer’s 

representative (COR), who is responsible for invoice review per USGS policy. According to the 

chief of the Acquisition Branch, neither the financial operating procedures nor the 

accounting operating procedures calls for reviewing invoices for math errors, but CORs are 

expected to review them for accuracy and seek any needed correction. The COR recognized that 

reviewing the math on invoices was his responsibility and that he failed to do so. 

Recommendation 

We recommend that the USGS: 

1. Develop and implement procedures to hold the COR accountable for reviewing 

invoices for accuracy 

QSI Submitted Invoices Without Required CLINs 

Contract line item numbers (CLINs) define the supplies or services to be delivered and 

characteristics such as pricing and funding source. CLINs improve the accuracy, traceability, and 

usability of procurement and contract data. 

We found that none of the seven QSI invoices we examined provided costs by CLIN as required 

in the contract and USGS guidance for invoicing and payment (see Figure 3 for an example 

invoice). In addition, the contract contained four CLINs, two of which had different funding 

sources. 

When a contractor does not include CLINs on invoices, the USGS cannot determine the total 

costs incurred for each CLIN or properly monitor CLIN progress for each funding source. 

The USGS contracting officer (CO) did not return the invoices for correction because he 

believed that CLINs are used for accounting purposes and not required to be acknowledged on 

the invoices. He said that the accounting team uses CLINs to manage the multiple accounting 

codes used to fund the task order. 

5 
6llilble 

lllllllWl1 

0001 100.00% $103,521.211 $103,.521.20 5103;5212D 111.00 

0002 100.00,C, $362,324.20 $362.,324.20 50.00 $362.32420 

OOD.1 65..80Y. 551,760.60 $34,058.47 moo s34.0sa.;11 

OOIM 65.~ $2,225,Til5,60 $1,464,St-4.42 $1,176,654.40 $287 )160..112 

OOll5 55.00% $517,606.00 $284,683.30 $57,736..:25 $226..947..ll-4 

0006 80,00,C, $155,281.60 $124.225.A-4 moo $124.225.A-4 

0007 49_00,C, $155,281.60 $77,537.37 $0.00 $77,537.37 

0006 0,00,C, $155,281.60 $0,00 moo 111..110 

0009 O.OO>lil. $155,281.60 $0.00 $0.00 $0..110 

0010 0,00% $155,281.BO $0,00, $i1LOO $0..llD 

0011 0 ,00,C, $155,281.BO $0,00 moo RJJJ0 

0012 O.OO"Jil. $155,281.60 $0.00 $0.00 $0..110 

0013 0 .00,C, $155,281 ,BO $0.00 moo w..110 

0014 O.OO"Jli. $1 SS,21t1.60 $0,00 SD.DO $0.IJD 

0015 0.00% $517,606.00 $!LOO 50.DD ___ ,._III_JJO.__ 

SUbtolaL •... ··-··-· . --·-· .... ·- ·-· ··--·--··- · ·-·. _ .. ·--···· _ ...•... _ ... ___ __ _ ...•. ·--·--· $1,112.952.54 

Figure 3: QSI Invoice No. 7 Shows a List of Items Billed But Does Not 

Segregate Costs by CLIN 

INVOICE PERIOD OF !PERFORMANCE: 12/01/18- 12/31/18 

BIU.JlltG r.lETiiOD: MllleQDne Pen:eni 

TASK ORDl5R VALUf : $5,176,060.00 

TOTAL AIIOUNT NOW DUE..·-····-··-··-··----······-··------··-··--·--·----······-··-··---··· 

~ Bl le<I $1,337 .9111.87 

BIDl!d Tlll5 lnVdlce $1 , 112.952.54 

Total Bllng lo Date $2,AS0,86,U1 

Recommendation 

We recommend that the USGS: 

2. Work with QSI to identify the appropriate CLINs for the costs presented on all 

invoices 

The USGS Did Not Comply With Federal Regulations and 

Award Terms 

The USGS Did Not Include a Required Clause in the Contract 

The USGS excluded a required clause from the contrnct. The Federal Acquisition Regulation 

requires inclusion of the "Contrnctor Code of Ethics and Conduct" clause (FAR§ 52.203-13) if 

the expected value of a contract exceeds $5.5 million and the period of pe1fonnance is 120 days 

or more. The clause provides requirements for disclosure of fraud, conflicts of interest, bribe1y, 

and false claims and requirements for business ethics and establishing a system of internal 

controls. 

Because the IDIQ contract value had a ceiling of $750 million and the task order was expected to 

exceed $5.5 million with a period of perfo1mance of more than 120 days, the USGS should have 

6 
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included this clause in the contract. In addition, we found that the USGS’ accounting operating 

procedures do not address verifying that all required clauses are included. 

The Federal Acquisition Regulation, specifically FAR § 52.3, provides a matrix to help 

contracting personnel determine which required clauses should be included in a contract. While 

the chief of the Acquisition Branch told us that review of required contract clauses using 

the matrix is part of the process of writing contracts, the requirement was not documented in the 

accounting operating procedures. The CO did not include the “Contractor Code of Business 

Ethics and Conduct” clause in the contract, and the error was not identified during management 

review. 

Without robust contract review policies and procedures, the USGS cannot ensure the protection 

of the U.S. Government’s interest and could have difficulty enforcing contract requirements. 

Recommendations 

We recommend that the USGS: 

3. Modify Contract No. G16PC00016 to include FAR § 52.203-13 

4. Provide instructions in the accounting operating procedures that address 

required contract clauses and notify contracting personnel of the update 

The USGS Did Not Document the Contract Negotiations Properly 

When documenting the contract negotiations, the CO did not include a description of the status 

of QSI’s management systems, such as ethics or quality control, as required by FAR § 15.406-

3(4). Moreover, when considering QSI’s ability to perform the work, the CO did not document 

the necessary operating controls such as payroll, ethics, or invoicing, as required by FAR 

§ 9.104-1(e). 

The chief of the USGS Office of Acquisition and Grants stated the template and checklist used 

mirror the FAR requirements to ensure that COs document all the required information in the 

contract file, and that in this case the CO’s omissions were an oversight. The chief also stated 

that the CO did not document the QSI systems because the USGS had experience with the 

contractor and no problems in the past, so the documentation was unnecessary. Regardless of 

past experience, documenting the status of management systems and operating controls during 

negotiations is necessary because a vendor’s corporate environment may have changed. Without 

proper documentation of contract negotiations, it is unclear if the CO has considered all the 

information necessary to determine whether a contractor is able to perform the contract scope of 

work and has controls to protect against fraud, waste, and abuse. 

7 
 

 

 

 

 

Recommendation 

We recommend that the USGS: 

5. Review any open procurements in which the CO participated to ensure that 

negotiation documentation was completed in accordance with FAR §§ 15.406-

3 and 9.104-1 

The USGS Negotiated a Fair and Reasonable Price for the 

Task Order 

We found that the USGS negotiated a fair and reasonable price for services rendered under the 

task order in accordance with FAR § 15.402, “Pricing Policy.” We analyzed the price negotiation 

memorandum and the USGS’ independent Government cost estimate to determine that the price 

obtained was fair and reasonable. 

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Conclusion and Recommendations 

Conclusion 

Although the USGS obtained a fair and reasonable price for QSI services, we found that QSI and 

the USGS did not always comply with applicable regulations, policies, and contract terms and 

conditions. QSI invoices, which the USGS paid, were inaccurate and did not segregate costs by 

CLIN as required by the contract. The USGS must provide better oversight when reviewing 

invoices and verify that costs are accumulated in accordance with contract terms. 

In addition, we found that the USGS did not include a required clause in the contract and 

improperly documented contract negotiations regarding QSI’s management systems and 

operational controls. Comprehensive and complete documentation is critical to protect the 

Government’s interest and ensure prospective contractors can perform the scope of work with 

appropriate internal controls. 

Recommendations Summary 

We issued a draft version of this report to the USGS to review and respond. Based on the 

response, we consider all five recommendations resolved but not implemented. See Appendix 2 

for the full text of the USGS’ response and Appendix 3 for the status of recommendations. 

We recommend that the USGS: 

1. Develop and implement procedures to hold the COR accountable for reviewing invoices 

for accuracy 

USGS Response: The USGS concurred with our finding and recommendation. Its 

acquisition operating procedures will be updated to include COR procedures for 

invoicing. If a COR fails to do his or her duties or behave in a responsible or ethical way, 

the Office of Acquisition and Grants will alert the supervisor to the situation, refer any 

applicable matter to the appropriate authority, and take appropriate action (including 

suspension of COR appointment, where necessary). 

OIG Comment: Based on the USGS’ response, we consider Recommendation 1 

resolved but not implemented. 

2. Work with QSI to identify the appropriate CLINs for the costs presented on all invoices 

USGS Response: The USGS concurred with our finding and recommendation. The CO 

will incorporate invoicing instructions into the award for all CLINs. 

OIG Comment: Based on the USGS’ response, we consider Recommendation 2 

resolved but not implemented. 

9 
 

 

 

 

 

 

 

 

3. Modify Contract No. G16PC00016 to include FAR § 52.203-13 

USGS Response: The USGS concurred with our finding and recommendation. The CO 

will modify the award as recommended. 

OIG Comment: Based on the USGS’ response, we consider Recommendation 3 

resolved but not implemented. 

4. Provide instructions in the accounting operating procedures that address required contract 

clauses and notify contracting personnel of the update 

USGS Response: The USGS concurred with our finding and recommendation. The 

USGS will update the acquisition operating procedures accordingly and will notify 

contracting personnel of the update. 

OIG Comment: Based on the USGS’ response, we consider Recommendation 4 

resolved but not implemented. 

5. Review any open procurements in which the CO participated to ensure that negotiation 

documentation was completed in accordance with FAR §§ 15-406-3 and 9.104-1 

USGS Response: The USGS concurred with our finding and recommendation. The 

USGS will review all open procurements assigned to the CO to ensure compliance. 

OIG Comment: Based on the USGS’ response, we consider Recommendation 5 

resolved but not implemented. 

10 
 

 

 

Appendix 1: Scope and Methodology 

Scope 

We performed an audit of Task Order No. 140G0218F0251 under Contract No. G16PC00016 

between the U.S. Geological Survey (USGS) and Quantum Spatial, Incorporated (QSI). We 

examined QSI’s and the USGS’ compliance with applicable Federal regulations, USGS policies 

and procedures, and terms and conditions of the task order and the governing contract from the 

beginning of the solicitation phase in October 2014 to December 2018. 

Methodology 

We conducted this audit in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

To accomplish our objectives, we: 

• Gained an understanding of the Federal Acquisition Regulation and U.S. Department of 

the Interior guidance related to contract compliance 

• Interviewed the contracting officer, QSI employees, and other appropriate individuals 

• Identified compliance requirements in the contract 

• Examined supporting documentation related to contract negotiations, invoicing, progress 

reports, and wage determination provided by QSI and the USGS 

• Tested invoices, progress reports, and labor expenditures to determine compliance with 

Federal regulations, USGS policies and procedures, and contract terms and conditions 

In planning and performing our audit, we obtained an understanding of timekeeping, progress 

reporting, invoicing, and file maintenance for contract negotiations to design audit procedures for 

the purpose of developing our findings and conclusion, but not for the purpose of forming a 

conclusion on the effectiveness of internal control. Our audit was not designed to identify all 

deficiencies in internal control and therefore, significant deficiencies may exist that have not 

been identified. 

We relied on computer-generated general ledger data to verify QSI’s compliance with Federal 

regulations and contract terms. To assess the reliability of the computer-generated general ledger 

provided by QSI, we performed testing for obvious errors in compliance, reviewed related 

supporting documentation, and interviewed QSI officials knowledgeable about the data. We 

determined that the data were sufficiently reliable for the purposes of this audit. 

11 
Appendix 2: Response to Draft Report 

The U.S. Geological Survey’s response to our draft report follows on page 13. 

12 
June 8, 2020 

Memorandum 

To: Chris Stubbs 

Director, Office of Financial and Contract Audits 

From: Becky Bageant /signed/ 

Audit Liaison Officer, U.S. Geological Survey 

Subject: U.S. Geological Survey’s (USGS) response to the Office of Inspector General 

(OIG) Draft Audit Report “U.S. Geological Survey and Quantum Spatial, 

Incorporated, Did Not Always Comply with Federal Regulations, Policies, and 

Award Terms for Task Order No. 140G0218F0251 and Contract No. 

G16PC00016” (Report No. 2018-FIN-051) 

Please find below the USGS response to the draft report for the subject above. 

Recommendation 1: Develop and implement procedures to hold the COR accountable for 

reviewing invoices for accuracy. 

Response: Concur. The Acquisition Operating Procedures (AOP) will be updated to 

include Contracting Officer Representative (COR) procedures for invoicing. If a COR 

fails to do his or her duties or behave in a responsible or ethical matter, OAG will alert 

the supervisor to the situation, refer any applicable matter to the appropriate authority, 

and take appropriate action (including suspension of COR appointment, where 

necessary). 

Target Date: August 1, 2020 

Responsible Official: Jennifer Kelley, OAG Senior Policy Analyst 

Recommendation 2: Work with Quantum Spatial, Incorporated (QSI) to identify the 

appropriate Contract Line Item Numbers (CLINs) for the costs presented on all invoices. 

Response: Concur. The Contracting Officer (CO) will incorporate invoicing instructions 

into the award for all CLINs. 

Target Date: August 1, 2020 

Responsible Official: , Contracting Officer 

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Recommendation 3: Modify Contract No. G16PC00016 to include FAR § 52.203-13 

Response: Concur. The Contracting Officer will modify the award as recommended. 

Target Date: August 1, 2020 

Responsible Official: , Contracting Officer 

Recommendation 4: Provide instructions in the accounting operating procedures that 

address required contract clauses and notify contracting personnel of the update. 

Response: Concur. The Acquisition Operating Procedures (AOP) will be updated 

accordingly, and contracting personnel notified of the update. 

Target Date: August 1, 2020 

Responsible Official: Jennifer Kelley, OAG Senior Policy Analyst 

Recommendation 5: Review any open procurements in which the CO participated to ensure 

that negotiation documentation was completed in accordance with FAR § 9.104-1. 

Response: Concur. All open procurements assigned to the CO will be reviewed to 

ensure compliance. 

Target Date: August 1, 2020 

Responsible Official: , OAG Branch Chief 

14
 

 

 

 

Appendix 3: Status of Recommendations 

Recommendation Status Action Required 

We will refer these 

recommendations to the Assistant Resolved but not 1, 2, 3, 4, and 5 Secretary for Policy, Management implemented and Budget for implementation 

tracking. 

15 
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